ML20247R636
| ML20247R636 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/1989 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247R640 | List: |
| References | |
| NUDOCS 8906070282 | |
| Download: ML20247R636 (16) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
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UNITED STATES NUCLEAR REGULATORY COMMISSION 7,,
gy WASHINGTON, D. C. 20555
.....l SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM. CALIFORNIA
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DOCKET NO. 50-361 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 72 License No. NPF-10 1.
The Nuclear Regulatory Comission (the Commission) has found that:
A.
The application for amendment to the license for San Onofre Nuclear Generating Station, Unit 2 (the facility) filed by Southern California Edison Company (SCE) on behalf of itself and San Diego Gas and Electric Company, the City of Riverside, California and the City of Anaheim, Californir (licensees) dated August 28, 1986, and supplemental submittals dated November 21, 1986 and February 1,1988, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act,'and the regulations of the Comission; C.
Thereisreasonableassurance(i)thattheactivitiesauthorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common l
defense and security or to the health and safety of the public; and 1
E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
8906070282 890515 ADOCK0500g1
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Accordingly, the license is amended by adding the following paragraph 2.C(26):
(26)IntegratedImplementationSchedule The Southern California Edison Company (SCE) shall implement a plan for scheduling all capital modifications based on the attached Integrated Implementation Schedule Program Plan (the " Plan").
(I) The Plan shall be followed by the licensee beginning with the effective date of this amenament.
(2) Changes to completion dates for items identified in Schedules B and C of the Plan do not require a license amendment. Dates specified in Schedule A of the Plan shall be changed only in accordance with applicable NRC procedures.
3.
This license amendment is effective as of the date of its issuance.
FOR THE HUCLEAR REGULATORY COMMISSION George. Knightog irector Project Directorate V Division of Reactor Projects - III, IV, V and Special Projects
Attachment:
Integrated Implementation Schedule Program Plan D~ ate of Issuance: M y 15, 1989
i ATTACHMENT INTEGRATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAN ONOFRE. NUCLEAR.CENERATING. STATION,. UNITS 2. AND.3 I.
INTRODUCTION This document provides the methodology to be used in determining the implementation schedules of capital projects at San Onofre Units 2 and 3.
The program has as its goal the implementation of capital modifications in a stable, controlled manner with the implementation of projects with the greatest potential for enhancing the safe operation of the unit generally given highest priority. The projects of regulatory crfgin will be ranked using the Westinghouse Analytical Ranking Process to specifically determine the relative. potential safety contribution of each modification. The safety ranking will then be used as a primhry criterion in scheduling the projects. For betterment projects the priority and schedule will be determined by the Plant Modification Review Committee. The Committee consists of management representatives involved in many areas of plant operation and is the most effective means of determining implementation schedules for those projects necessary for continued or improved plant operation, maintenance, etc.
The program reflects ilmited outage time, financial and manpower resources, while at the same time implementing those modifications deemed necessary for enhanced plant safety. The plan provides for integration of all future identified work into one comprehensive schedule and has built-in mechanisms for changes to the schedule when new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of SCE.
II.
SUMMARY
OF PRIORITY. DETERMINATION The Integrated Implementation Schedule is based on a priority determination to assist in maximizing the benefit derived from modifications. Since it is not always possible or beneficial to try to implement a large number of modifications in a single outage, the integrated schedule provides a mechanism for focusing attention on those projects of highest priority.
Regulatory related projects will be ranked using the Westinghouse Analytical Ranking Process. This process was approved for Sen Onofre Unit 1 by the NRC in a letter from D. G. Eisenhut, to K. P. Baskin, SCE, dated November 16, 1983. SCE will use the same methodology for SONGS 2 and 3. A description of the Westinghouse process was submitted to the NRC by letter dated Septaber 2,1983 from Kenneth P. Baskin to H. R. Denton.
. Betterment projects do not always have major direct safety impact and' very in their effect on operation, maintenance, ALARA, reliability, availability, etc. These prnjects also vary in magnitude from those requiring a small expenditure of resources to those requiring substantial resources and outage time.
In many instances, the implementation of a betterment project may be necessary on an expedited schedule due to a anticipated negative impact on plant operation. Due to these and other factors, the betterment projects have their priority and schedule determined by SCE's Plant Modification Review Comittee. The Comittee is incorporated into the review cycle for approval of plant modifications by San Onofre Procedure 50123-XIX-3.D. This comittee consists of SCE representatives from areas of plant operations and management.
In this way, special consideration is given to particular attributes of a betterment project that may make it imperative to implement on an expedited schedule.
III. _ SCHEDULING Once the projects are ranked they will be evaluated using normal scheduling methods to determine how long they will take to implement.
The projects ranked highest will first be evaluated to determine whether they can be implemented during the next scheduled refueling outage.
Projects will continue to be selected from the top of the ranked lists 1
and scheduled for the earliest outage in which implementation constraints of a normal refueling outage have not been exceeded. These schedules will then be separated into three lists as described below:
i
. Schedule.t.
All items which have implementation dates required by NRC regulations, orces or license conditions.
Schedule C Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation cates comitted to by)SCEandwhichwouldresultineither(a)plantmodifications, (b procedure revisions, or (c) changes in facility staffing requirements; or items perceived by SCE as prospective NRC requirements; or major tasks resulting from mandates of agencies other than the NRC. Also included are evaluations for major initiated issues not required by regulation, license conditions or orders.
Schedule C SCE initfated plant betterment projects.
. Schedule A dates may be modified only with prior NRC approval in accordance with existing NRC procedures.. Changes in Schedule B dates require written notification to the NRC as described in Section V below.
Schedule C dates are provided for information to allow the NRC to gain perspective on the scope of overall modifications and may be changed at SCE's discretion. Schedules A, B and C together provide the basis for assessing the overall effect of changes to schedules and serve as a departure point for discussion between the NRC and SCE regarding such changes, as discussed below.
IV. SCHEDULE MODIFICATIONS
'An important aspect of SCE's planning effort is the recognition that the schedule will need,to be modified at times to reflect changes in regulatory requirements, to accommodate those activities that SCE finds necessary to improve plant efficiency and reliability, and to take into account delays'resulting from events beyond SCE's control.
It is important that the procedure used by SCE for changing the schedules be documented. */ In addition, the NRC must play a role in the oversight of the scheduling prbcess and must, in fact, judge the acceptability of proposed date changes in Schedule A.
Accordingly, it is important that the NRC's role, and the interaction between the NRC and SCE be clearly defined, as discussed below.
Y.
SOUTHERN CALIFORNIA EDISON. COMPANY. RESPONSIBILITIES The Integrated Implementation Schedule requires that SCE monitor the progress of the work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a schedule change is needed.
~
A.
periodic. Updating Southern California Edison will update Schedules A, B and C semi-annually and submit the revised schedules to the NRC beginning six months following NRC approval of the Plan. In addition to updating the schedules, SCE will:
Sumarize progress in implementing NRC requirements concerning plant modifications.
Identify changes since the last report.
Summarize the reasons for schedule changes associated with Schedules A and B.
~/
Schedules A, B and C will contain sufficient detail to identify those plant capital modifications with completion dates keyed to fuel cycle outages. The schedules may also contain specific dates (either calendar date or keyed to some other milestone) for major evaluations.
,c 1
- Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling /
modification outage.
B.
Changes to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications to the scope of scheduleJ work; problems in delivery, procurement, etc.; changes in NRC ?nles and regulations; or other NRC or SCE actions.
Where it is necessary to add a new work item or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
Determine the priority of the project, or changed priority, using the Westinghouse Analytical Ranking Process.
Schedule the new or changed item to avoid rescheduling other items already well underway, if it can be reasonably achieved.
Alter Schedule B and C items before Schedule A items.
Gelect a schedule for the new or changed item which will help maintain an optimum integrated program of work.
If a new Schedule A item is added, regardless of the results of the above ranking / scheduling process, the implementation schedule of the new item shall comply with applicable NRC regulations, orders, or license conditions unless a different schedule has been formally established in accordance with appropriate Commission procedures.
As noted above, no changes will be made to Schedule A without prior NRC approval. Should a change become necessary, it will only be proposed after SCE has determined that rescheduling of lower priority work either will not significantly assist in maintaining Schedule A without change, or that the safety, cost or schedule penalties from rescheduling lower priority work significantly outweigh the change in a Schedule A completion date.
SCE will inform the NRC Project Manager when serious consideration is given to requesting a change in Schedule A.
When SCE determines that a change in Schedule A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.
SCE will notify NRC in writing at least 30 days before adopting a planned delay for an item in Schedule B.
Such notification will also incluce the reasons for the delay and describe any compensatory actions indicated. The revised date proposed by SCE will go into effect
. unless NRC, in writing, requests further explanation or discussion concerning such change.
If NRC makes such a request, it will be made within 15 days of receipt of SCE'S written notification.
In this event, discussions wil? be initiated to promptly develop a schedule date which is autually acceptable to SCE and the NRC Project Manager while considering overall program impact. The written notification by NRC will serve to extend the schedule date for the period of time required for such discussions.
If a new date is established in these discussions such date will supersede the
- date set forth in Schedule B.
The new date will be incorporated in a revised Schedule B in the next semi-annual schedule update submitted to NRC.
If a new date cannot be established in these discussions, SCE changes in scheduled dates will be effective unless subsequently modified by NRC Order.
Work items in Schedule C may be rescheduled or work items may be coded to Schedule C by SCE without NRC notification. SCE will report changes to Schedule C items in its semi-annual update to be provided in accordance with Section V.A above. This schedule is provided for information purposes only and is intended to provide the NRC a better understanding of the unit's overall modifications program.
VI. NRC. REVIEW As pointed out in Section V.B above, changes to the schedules are inevitable, Actions required by the NRC are discussed below:
A.
Southern California. Edison. Originated. Changes 1.
Upon receipt from SCE of a request for modification of Schedule A, NRC will act promptly (consistent with resource availability and priority of other work) to act on the request in accordance with applicable procedures.
2.
If the request for a modification of Schedule A is denied, the
(
NRC shall promptly inform SCE and provide the reasons for denial.
3.
NU :.ansideration of SCE changes in non-Schedule A items is cc,ered by V.B above.
B.
NRC Originated. Changes.(Schedule.A)
It is recognized that formal NRC regulatory actions ma (1) impose a new regulatory requirement with a fixed date or (2) y:establish a l
firm date for a previously identified regulatory requirement.
In taking any such action, the hRC, to the extent consistent with this overall regulatory responsibilities and, unless public health, l
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- r
" safety, or interest require otherwise, will take into account the impact of such action on SCE's ability to complete effectively the items on Schedules A, B and C and, in consultation with SCE, will try to minimize such impact. Although any formal regulatory actior, taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and SCE recognize the desirability of incorporating such action into Schedule A, particularly in order to incorporate at the same time any other appropriate changes in the total integrated schedule program.
Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such require-ments. Any resulting changes in items in Schedule A will be submitted to the NRC for review in accordance with established procedures, and,..
if approved by the Commission, will thereupon be reflected in a revised Schedule A submitted by SCE. SCE will inform the NRC of any resulting changes in Schedule B in accordance with Section V above.
C.
New NRC Issues.(Schedule.B) new regulatory issues which The NRC may, from time to time, identify (b) procedure revision or may result in (a) plant modifications, development, or (c) changes in facility staffing requirements.
For issues on which the NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date commitment developed in discussion between SCE and the NRC staff.
As for the ecse of NRC originated changes to Schedule A items, the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such issues. Any resulting changes in integrated program schedules will thereupon be reflected in a revised Schedule B submitted by SCE.
VII. MODIFICATIONS.TO.THE. PLAN The licensees and the NRC recognize that the Plan itself may require future modifications. Accordingly, SCE will draft proposed modifications and submit a license amendment application for approval of the proposed changes. The changes, if approved, will be made effective upon amendment issuance by the NRC.
'o UNITED STATES
-7 g
NUCLEAR REGULATORY COMMISSION n
WASHINGTON,0. C. 20555
\\...../
SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-362 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.60 License No. NPF-15 1.
The Nuclear Regulatory Comission (the Comission) has founo that:
3 A.
The application for amendment to the license for San Onofre Nuclear Generating Station, Unit 3 (the facility) filed by Southern California Edison Company (SCE) on behalf of itself and San Diego Gas and Electric Company, the City of Riverside, California and the City of Anaheim, California (licensees) dated August 28, 1986, and supplemental submittals dated November 21, 1986 and February 1,1988, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth in 10 CFR Chapter I; l
B.
The facility will o)erate in conformity with the ap)11 cation the provisions of t.1e Act, and the regulations of tie Comission; C.
There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; l
D.
The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied.
L
7-t
. 2.
Accordingly, the. license is amended by adding the followin; p6ragraph 2.C(27):
(27) Integrated Implementation Schedule The Southern California Edison Company (SCE) shall. implement a plan for scheduling all capital modifications based on the attached IntegratedImplementationScheduleProgramPlan(the" Plan").
(1) The Plan shall be followed by the licensee beginning with the effective date of this amendment.
(2) Changes to completion dates for items identified in Schedules B and C of the Plan do not require a license amendment. Dates specified in Schedule A of the Plan shall be changed only in accordance with applicable NRC procedures.
3.
This license amendment.is effective as of the date of its issuance.
FOR THE NUCLEAR REGULATORY COMMISSION George W Knighton.
rector.
Project Directorate V Division of Reactor Projects - III, IV, V and Special Proiects
Attachment:
Integrated Implementation Schedule Program Plan Date of Issuance: May 15, 1989
L b
ATTACHMENT INTEGPATED IMPLEMENTATION SCHEDULE PROGRAM PLAN SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 I.
INTRODUCTION This document provides the methodology to be used in determining the L
implementation schedules of capital projects at San Onofre Units 2 and 3.
The program has as its goal the implementation of capital modifications in a stable, controlled manner with the implementation of projects with the greatest potential for enhancing the safe operation of the unit generally given highest priority. The projects of regulatory origin will be ranked using the Westinghouse Analytical Ranking Process to specifically determine the relative potential safety contribution,of each modification. Tne safety ranking will then be.used as a primary criterion in scheduling the projects. For betterment projects the priority and schedule will be determined by the Plant Modification Review Committee. The Committee consists of management representatives involved in many areas of plant operation and is the most effective means of determining implementation schecules for those projects necessary for continued or improved plant operation, maintenance, etc.
The program reflects limited outage time, financial and manpower resources,'while at the same time implementing those modifications deemed necessary for enhanced plant safety. The plan provides for integration of all future identified work into one comprehensive schedule and has built-in mechanisms for changes to the schedule when new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of SCE.
II.
SUMMARY
OF PRIORITY DETERMINATION The Integrated Implementation Schedule is based on a priority determination to assist in maximizing the benefit derived from modifications. Since it is not always possible or beneficial to try to implement a large number of modifications in a single outage, the integrated schedule provides a mechanism for focusing attention on those projects of highest priority.
Regulatory related projects will be ranked using the Westinghouse Analytical Ranking Process. This process was approved for San Onofre Unit 1 by the NRC in a letter from D. G. Eisenhut, to K. P. Baskin, SCE, dated November 16, 1983. SCE will use the same methodology for SONGS 2 and 3. A description of the Westinghouse process was submitted to the NRC by letter dated September 2, 1983 from Kenneth P. Baskin to H. R. Denton.
2-Betterment projects do not always have a major direct safety impact and vary in their effect on operation, maintenance, ALARA, reliability, availability, etc. These projects also vary in magnitude from those requiring a small expenditure of resources to those requiring substantial resources and outage time.
In many instances, the implementation of a betterment project may be necessary on an expedited schedule due to a anticipated negative impact on plant operation. Due to these and other factors, the bettennent projects have their priority and schedule determined by SCE's Plant Modification Review Comittee. The Comittee is incorporated into the review cycle for approval of plant modifications by San Onofre Procedure S0123-XIX-3.D. This cont.11ttee consists of SCE representatives from areas of plant operations and management.
In this way, special consideration is given to particular attributes of a betterment project that may make it imperative to implement on an expedited schedule.
III. SCHEDULING Once the projects are ranked they will be evaluated using normal scheduling methods to determine how long they will take to implement.
The projects ranked highest will first be evaluated to determine whether they can be implemented during the next scheduled refueling outage.
Projects will continue to be selected from the top of the ranked lists and scheauled for the earliest outage in which implementation constraints of a normal refueling outage have not been exceeded. These schedules will then be separated into three lists as described below:
Schedule A All items which have implementation dates required by NRC regulations, orders or license conditions.
Schedule B Regulatory items (of either generic or plant specific nature)
I identified by the NRC which have implementation dates committed to by)SCEandwhichwouldresultineither(a)plantmodifications, 4
(b procedure revisions, or (c) changes in f acility staffing requirements; or items perceived by SCE as prospective NRC requirements; or major tasks resulting from mandates of agencies l
other than the NRC. Also included are evaluations for major I
initiated issues not required by regulation, license conditions or orders.
q Schedule C SCE initiated plant betterment projects.
- (,
. Schedule A dates may be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC as described in Section V below.
Schedule C dates are provided for information to allow the NRC to gain perspective on the scope of overall modifications and may be changed at SCE's discretion. Schedules A, B and C together provide the basis for assessing the overall effect of changes to schedules and serve as a departure point for discussion between the NRC and SCE regarding such chan~ges, as discussed below.
IV. SCHEDULE MODIFICATIONS An important aspect of SCE's planning effort is the recognition that the schedule will need to be modified at times to reflect changes in regulatory requirements, to accommodate those activities that SCE finds necessary to improve plant efficiency and reliability, and to take into account delays resulting from events beyond SCE's control.
It is important that the procedure used by SCE for changing the schedules be occumented. */ In addition, the NRC must pl6y a role in the oversight of the scheduling process and must, in fact, judge the acceptability of proposed date changes in Schedule A.
Accordingly, it is important that the NRC's role, and the interaction between the NRC and SCE be clearly defined, as discussed below.
V.
SOUTHERN CALIFORNIA EDISON COMPANY RESPONSIBILITIES The Integrated Implementation S:hedule requires that SCE monitor the progress of the work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a schedule change is needed.
~
A.
Periodic Updating l
Southern California Edison will update Schedules A, B ano C semi-annually and submit the revised schedules to the NRC beginning six months following NRC appruval of the Plan.
In addition to updating the schedules, SCE will:
Summarize progress in implementing NRC requirements concerning plant modifications.
Identify changes since the last report.
l Summarize the reasons for schedule changes associated with Schedules A and B.
- /
Schedules A, B and C will contain sufficient detail to identify those plant capital modifications with completion dates keyed to fuel cycle outages. The schedules may also contain specific dates (either calendar date or keyed to some other milestone) for major evaluations.
e o
i 4 !
Indicate the expected percentage allocation of resources on Regulatory and Betterment projects for the next refueling /
modification outage.
B.
Changes to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications to the scope of scheduled work; problems in delivery, procurement, etc.; changes in NRC rules and regulations;.or other NRC or SCE actions.
Where it is necessary to add a new work item or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
' Determine the priority of the project, or changed priority, i
i using the Westinghouse Analytical Ranking Process.
Schedule the new or changed item to avoid rescheduling other items already well underway, if it can be reasonably achieved.
I Alter Schedule B and C items before Schedule A items.
Select a schedule for the new or changed item which will help maintain an optimum integrated program of work.
If a new Schedule A item is added, regardless of the results of the above ranking / scheduling process, the implementation schedule of the new item shall comply with applicable NRC regulations, orders, or license conditions unless a different schedule has been formally established in accordance with appropriate Commission procedures.
1 As noted above, no changes will be made to Schedule A without arfor l
NRC approval. Should a change become necessary, it will only )e l
proposed after SCE has determined that rescheduling of lower priority work either will not significantly assist in maintaining Schedule A without change, or that the safety, cost or schedule penalties from rescheduling lower priority work significantly outweigh the change in a Schedule A completion date.
l SCE will inform the NRC Project fianager when serious consideration is given to requesting a change in Schedule A.
When SCE determines that a change in Schedule A is necessary, it will submit a written l
l request for NRC approval in accordance with applicable procedures.
SCE will notify NRC in writing at least 30 days before adopting a planned delay for an item in Schedule B.
Such notification will also i
include the reasons for the delay and describe any compensatory actions indicated. The revised date proposed by SCE will go into effect I
y,...
., unless NRC, in writing, requests'further explanation or discussion concerning such change.
If NRC makes such a request, it will be made within 15 days of receipt of SCE'S written notification.
In this event, discussions will be initiated to promptly develop a schedule date which is mutually acceptable to SCE and the NRC.
Pro, ject Manager while considering overall program impact. The written notification by NRC will serve to extend the schedule date for the period of time required for such discussions.
If a new date is established in these discussions such date will supersede the date set forth in Schedule B.
The new date will be' incorporated ~1n a revised Schedule B in the next semi-annual schedule update submitted to NRC.
If a new date cannot be established in these discussions SCE changes in-scheduled dates will be effective unless subsequently modified by NRC. Order.
Work items in Schedule C may be rescheduled or work items may be added to Schedule C by SCE without NRC notification. SCE will report changes to Schedule C-items in its semi-annual update to be provided in accordance with Section V.A above. This schedule is provided for information purposes only and is intended to provide the NRC a better understanding of the unit's overall modifications program.
VI. NRC REVIEW As pointed out in Section V.B above, changes to the schedules are inevitable, Actions required by the NRC are oiscussed bel _ow:
A.
Southern California Edison Originated Changes 1.
Upon receipt from SCE of a request for modification of Schedule A, NRC will act promptly (consistent with resource availability ano' priority of other work) to act on the request in accordance with applicable procedures.
2.
If the request for a modification of Schedule A is denied, the NRC shall promptly inform SCE and provide the reasons for denial.
3.
NRC consideration of SCE changes in non-Schedule A items is covered by V.B above.
B.
NRC Originated Chanoes (Schedule A)
It is recognized that formal NRC regulatory actions ma (1) impose a new regulatory requirement with a fixed date or (2) y:
establish a firm date for a previously identified regulatory requirement.
In taking any such action, the NRC, to the extenc consistent with this overall regulatory responsibilities and, unless public health,
=
. safety,'or interest require otherwise, will take into account the impact of such action on SCE's ability to complete effectively the items on Schedules A, B and C and, in consultation with SCE, will try to minimize such impact. Although any formal regulatory action taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and SCE recognize the desirability of incorporating such action into Schedule A, particularly in order to incorporate at the same time any other appropriate changes in the total integrated schedule program.
Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such require-ments. Any resulting changes in items in Schedule A will be submitted to the NRC for review in accordance with established procedures, and, if approved by the Commission, will thereupon be reflected in a revised Schedule A submitted by SCE. SCE will inform the NRC of any resulting changes in Schedule B in accordance with Section V above.
C.
New NRC Issues (Schedule B) new regulatory issues which The NRC may, from time to time, identify (b) procedure revision or may result in (a) plant modifications, development, or (c) changes in facility staffing requirements.
For issues on which the NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date comitment developed in discussion between SCE and the NRC staff.
As for the case of NRC originated changes to Schedule A items, the hRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such issues. Any resulting changes in integrated program schedules will thereupon be reflected in a revised Schedule B submitted by SCE.
VII. MODIFICATIONS TO THE ptAN The licensees and the NRC recognize that the Plan itself may require future modifications. Accordingly, SCE will draft proposed modifications and submit a license amendment application for approval of the proposed changes. The changes, if approved, will be made effective upon amendment issuance by the NRC.
t.
-_ _