ML23151A465

PR-050 - 52FR45344 - Integrated Schedules for Implementation of Plant Modifications: Proposed Policy Statement

ML23151A465
Person / Time
Issue date:	12/27/1987
From:	NRC/SECY
To:
References
52FR45344, PR-050
Download: ML23151A465 (1)

Text

DOCUMENT DATE:

TITLE:

CASE

REFERENCE:

KEYWORD:

ADAMS Template: SECY-067 11/27/1987 PR-050 - 52FR45344 - INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS:

PROPOSED POLICY STATEMENT PR-050 52FR45344 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

PAGE 1 OF 2 STATUS OF RULEMAKING RECORD 1 OF 1

PROPOSED RULE:

PR-050 OPEN ITEM (Y/N) N RULE NAME:

INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT M ODIFICATIONS: PROPOSED POLICY STATEMENT PROPOSED RULE FED REG CITE:

52FR45344 PROPOSED RULE PUBLICATION DATE:

11/27/87 ORIGINAL DATE FOR COMMENTS: 01/25/88 NUMBER OF COMMENTS:

EXTENSION DATE:

I I

20 FINAL RULE FED. REG. CITE: 57FR43886 FINAL RULE PUBLICATION DATE: 09/23/92 NOTES ON: FILE LOCATED ON Pl.

STATUS F RULE:

PRESS PAGE DOWN OR ENTER TO SEE RULE HISTORY OR STAFF CONTACT PRESS ESC TO SEE ADDITIONAL RULES, (E) TO EDIT OR (S) TO STOP DISPLAY PAGE 2 OF 2 HISTORY OF THE RULE PART AFFECTED: PR-050 RULE TITLE:

INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT M ODIFICATIONS: PROPOSED POLICY STATEMENT OPOSED RULE SECY PAPER: 87-172 FINAL RULE SECY PAPER:

PROPOSED RULE DATE PROPOSED RULE SRM DATE:

09/24/87 SIGNED BY SECRETARY:

11/20/87 FINAL RULE SRM DATE:

I I

DATE FINAL RULE SIGNED BY SECRETARY:

09/17/92 STAFF CONTACTS ON THE RULE CONTACTl: SUZANNE C. BLACK CONTACT2: CLAUDIA M. ABBATE MAIL STOP: P-528 MAIL STOP: 12 E 4 PHONE: 492-7628 PHONE: 504-1281 PRESS PAGEUP TO SEE STATUS OF RULEMAKING PRESS ESC TO SEE ADDITIONAL RULES, (E) TO EDIT OR (S) TO STOP DISPLAY

DOCKET NO. PR-050 (52FR45344)

DATE DOCKETED 12/12/87 12/22/87 01/26/88 01/26/88 01/27/88 01/28/88 In the Matter of INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT M ODIFICATIONS: PROPOSED POLICY STATEMENT DATE OF DOCUMENT 11/20/87 TITLE OR DESCRIPTION OF DOCUMENT FEDERAL REGISTER NOTICE - PROPOSED POLICY STATEMENT 12/15/87 COMMENT OF OHIO CITIZENS FOR RESPONSIBLE ENERGY (SUSAN L. HIATT) (

1) 01/25/88 COMMENT OF SACRAMENTO MUNICIPAL UTILITY DISTRICT (G. CARL ANDOGNINI) (

2) 01/25/88 COMMENT OF NUCLEAR MANAGEMENT & RESOURCES COUNCIL (JOE F. COLVIN) (

3) 01/25/88 COMMENT OF YANKEE ATOMIC ELECTRIC COMPANY (DONALD W. EDWARDS) (

4) 01/22/88 COMMENT OF VERMONT YANKEE NUCLEAR POWER CORPORATION (WARREN P. MURPHY) (

5) 01/28/88 01/28/88 01/25/88 01/15/88 COMMENT OF NEW YORK POWER AUTHORITY (JOHN C. BRONS) (

COMMENT OF WISCONSIN ELECTRIC POWER COMPANY (C.W. FAY) (

7) 01/28/88 01/22/88 COMMENT OF DUKE POWER COMPANY (HAL B. TUCKER) (

8) 01/29/88 01/26/88 COMMENT OF CAROLINA POWER & LIGHT COMPANY (S.R. ZIMMERMAN) (

9) 01/29/88 01/23/88 COMMENT OF PHLADELPHIA ELECTRIC COMPANY (S.J. KOWALSKI) (

10) 01/29/88 01/25/88 COMMENT OF WASHINGTON PUBLIC POWER SUPPLY SYSTEM (G.C. SORENSEN) (

11) 02/01/88 02/02/88 01/25/88 01/25/88 COMMENT OF GEORGIA POWER COMPANY (L.T. GUCWA) (

12)

COMMENT OF GULF STATES UTILITIES COMPANY (J.E. BOOKER) (

13)

6)

DOCKET NO. PR-050 (52FR45344)

DATE DOCKETED 02/02/88 02/02/88 02/02/88 02/03/88 02/08/88 02/08/88 02/22/88 03/01/88 11/13/92 DATE OF TITLE OR DOCUMENT DESCRIPTION OF DOCUMENT 01/25/88 01/29/88 01/25/88 01/29/88 02/01/88 02/02/88 02/17/88 03/01/88 09/17/92 COMMENT OF EBASCO SERVICES INCORPORATED (EDWARD J. BORELLA) (

14)

COMMENT OF ILLINOIS POWER COMPANY (F.A. SPANGENBERG, III) (

15)

COMMENT OF WISCONSIN PUBLIC SERVICE CORPORATION

( D. C. HINTZ) (

16)

COMMENT OF GPU NUCLEAR CORPORATION (J.R. THORPE) (

17)

COMMENT OF PUBLIC SERVICE ELECTRIC AND GAS COMPANY (CORBIN A. MCNEILL, JR.) (

18)

COMMENT OF THE TOLEDO EDISON COMPANY (DALE R. WUOKKO) (

19)

COMMENT OF BALTIMORE GAS AND ELECTRIC (JOSEPH A. TIERNAN) (

20)

NOTE TO RECEIPIENTS - COMMENT FROM BALTIMORE GAS AND ELECTRIC SHOULD BE MARKED AS COMMENT #20 FINAL POLICY STATEMENT ON INTEGRATED SCHEDULES PUBLISHED ON 9/23/92 AT 57 FR 43886

AGENCY:

ACTION:

SUMMARY

NUCLEAR REGULATORY COMMISSION 10 CFR PART 50 Integrated Schedules; Policy Statement Nuclear Regulatory Commission.

• 92, V 13 P 5 :4 6 Final Policy Statement on Integrated Schedules.

The Nuclear Regulatory Commission (NRC) is publishing its Final Policy Statement on Integrated Schedules.

This policy statement describes the policy the Commission intends to use to promote voluntary implementation of licensee integrated schedules for regulatory requirements and other activities at nuclear power plants.

The primary focus of the policy addresses the way licensees may establish realistic integrated schedules and the ways the Commission intends to interact with these licensees.

It also documents the Commission's support for the establishment of integrated schedules at each nuclear power plant.

Integrated schedules for plant modifications and activities will permit the NRC, the nuclear industry, and the public to focus on safety issues while forecasting and maintaining long-term schedules and will permit more effective use of licensee resources to implement these plant changes and NRC resources to review them.

EFFECTIVE DATE:

Sixty days after publication in the Federal Register.

2 FOR FURTHER INFORMATION, CONTACT:

Claudia M. Abbate, Policy Development and Technical Suppor.t Branch, Off ice of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555; Telephone (301) 504-1281.

SUPPLEMENTARY INFORMATION:

Background

On November 27, 1987, the "Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications" was published in the Federal Register (52 FR 45345).

The proposed policy statement described the policy the Commission intended to use to promote the development of voluntary integrated schedules for implementing regulatory requirements and other improvements in nuclear power plants.

The comment period ended on January 25, 1988.

The staff received and evaluated 19 sets of comments.

Seven facilities implemented the proposed policy on integrated schedules.

On December 27, 1990, the NRC requested comments on SECY 347, "Regulatory Impact Survey Report," in the Federal Register (55 FR 53220).

SECY-90-347 included a discussion of the proposed integrated regulatory requirements implementation schedule

3 (IRRIS) concept.

The staff developed IRRIS to better manage the impact on licensees of implementing generic requirements.

During the 30-day comment period, the NRC received and evaluated 22 sets of comments that addressed IRRIS.

On June 7, 1991, SECY-91-172, "Regulatory Impact survey Report - Final," was issued which stated that the staff would not go forward with the IRRIS program, but would revise the 1987 proposed policy by integrating the proposed integrated schedule policy, the IRRIS program, as well as the experience gained from licensees that have implemented integrated schedules.

Summary of Public Comments All but two comments received regarding the proposed policy on integrated schedules were from licensees.

Most comments opposed the policy statement as written for several reasons.

First, some respondents stated that too much emphasis was placed on incorporating integrated schedules into the operating license through a license condition.

There was a concern that licensees not requesting a license condition would not receive equal consideration on schedular issues as licensees that did request a license condition.

Second, respondents indicated that development of a negotiated integrated schedule by licensees with good regulatory compliance records is neither necessary nor

4 appropriate.

The respondents believe an amendment to the operating license would require additional resources on their part as well as the NRC and would not significantly enhance the effort to complete licensing activities.

Third, respondents indicated that all work efforts should be included in the schedule rather than just NRC-initiated tasks as was discussed in the proposed policy statement.

Respondents felt that only including part of the tasks in the schedule may not show that regulatory requirements are receiving timely attention.

Respondents submitting comments regarding the IRRIS program as proposed in SECY-90-347 stated that IRRIS would only address the symptoms of cumulative generic requirements and would not address the problem of management of generic requirements at the front-end of the process.

The respondents commented that the IRRIS program should:

(1) include all regulatory actions and information requests, (2) be implemented through a pilot program with appropriate guidelines and evaluation of the pilot program, (3) have provisions to eliminate low priority items, and (4) remove the freeze on the schedule one year before an outage.

Operational Experience The licensees for seven operating facilities (including two multi-unit sites) have implemented integrated schedules.

The

5 licensees include all activities above a certain threshold (such as number of person-hour or cost) in the integrated schedule.

Such items would include NRC-mandated items, commitments to NRC generic letters and bulletins, significant actions to resolve I

items from NRC inspection reports and licensee event reports (LERs), and licensee-initiated actions.

Most of these licensees implement a two-or three-tier approach with NRC rules being one tier and the other tiers consisting of commitments and licensee-initiated projects.

The licensees submit integrated schedules to the NRC semi-annually.

The priorities are determined by different methodologies, but are based upon general considerations such as safety significance, cost, availability of the plant and of resources.

One licensee used the integrated schedule to delay implementation of items indefinitely.

In a few cases the NRC has disagreed with the licensees' priority of certain items.

, However, the process has generally benefitted both the NRC and the licensees.

The proposed policy statement was revised as a result of the comments and feedback from licensees' experience in implementing the integrated schedule.

Although the Commission believes that integrated schedules should be developed, licensees are not required to participate in the program or incorporate an

6 integrated schedule into the operating license.

Licensees may voluntarily develop and coordinate an integrated schedule with the NRC.

Those licensees already implementing an integrated schedule may continue with their current program or adopt a program consistent with the final policy.

Final Commission Policy r

The Commission believes the implementation of integrated schedules on a plant-specific basis will provide a systematic method of coordinating, managing, and scheduling major modifications and activities initiated by both the NRC and licensees.

Integrated schedules could enhance timely compliance with regulatory requirements and accommodate licensee-initiated activities.

The integrated schedule provides a major benefit in its flexibility to assign or reassign resources in recognition of the safety significance.

The integrated schedule program, including the prioritization methodology, the schedule, and periodic schedule updates will be determined by the licensee and submitted to the NRC for review.

The major elements of an integrated scheduling program should include the following:

7

1.

A systematic process for identifying and defining those activities to be scheduled;

2.

A process for prioritizing and a process for scheduling the individual actions, taking into account factors such as safety, plant availability, radiation exposure, procurement requirements, and costs;

3.

A plan for maintaining and updating implementation schedules;

4.

A provision for NRC review of the prioritization and scheduling process, the initial schedule and updates;

5.

6.

A provision for requesting schedular relief on NRC-initiated schedules; and A process for evaluating a licensee's maintenance of schedules through the issuance of periodic reports on actions completed, schedules for new actions, and schedule changes that result from new actions or implementation problems.

Licensees who volunteer will develop a program which will result in an integrated schedule containing three levels.

Items

8 contained in level 1 of the integrated schedule will be those items with specific implementation dates to be implemented in response to a rule, order, or license condition, including Technical Specifications and amendments.

These items will be included in the integrated schedule to provide a complete view of the items that the NRC requires to be implemented.

The licensee cannot change the implementation schedules for these items through the integrated schedule program.

The licensee must request schedule changes for these items in accordance with standard procedures for applications for license amendments or exemptions.

Items contained in level 2 of the integrated schedule will result from licensee commitments to NRC actions, including generic communications (generic letters and bulletins).

Licensees will have the flexibility to establish and revise their schedular commitments for level 2 items.

When an NRC communication is issued, licensees with an integrated schedule will review the recommended implementation date, will include the item in the integrated schedule, and will prioritize the item among other NRC items in the integrated schedule.

The licensee will then provide the NRC with the proposed implementation date in the initial response to the NRC communication.

If other items of more significance to safety prevent the licensee from scheduling the newly-initiated item by the date recommended in

9 the NRC correspondence, the licensee will submit to the NRC the justification for the proposed schedule in the initial response to the NRC communication.

The licensee with an integrated schedule program will be able to substitute licensee-initiated safety enhancements in place of NRC-recornmended initiatives in those instances in which the licensee's initiatives yield an equivalent safety benefit.

The licensee will submit the proposed schedule for the licensee-initiated item and the justification for the substitution.

The NRC staff will have 90 days to review the proposed schedule for implementing level 2 items (90-day negative consent).

If the schedule cannot be agreed upon by both parties and if the staff believes that a significant safety concern exists, the staff at any time can issue an order to implement such items.

The staff can take this action whether or not a licensee has an integrated schedule.

The licensee can request relief from implementing specific NRC items in level 2 that have not been implemented over a number of years because of their low safety significance.

The licensee will need to obtain specific NRC approval for removal of these items.

The 90-day negative consent process does not apply.

10 Items contained in level 3 of the integrated schedule will be other activities such as licensee-initiated projects, LER follow-up, and INFO or NUMARC initiatives.

The licensee will identify items to include in level 3 and the threshold above which level 3 tasks will be included in the integrated schedule.

The integrated schedule will include only those items above the threshold.

Licensees will schedule items in level 3 consistent with commitments and other items in the schedule.

Level 3 activity schedules will be submitted to the NRC, but no formal review will be performed by the staff on these items.

They are included so the staff can obtain a complete overview of licensee activities.

_._T~e _1.icense~ _ will ~ot_ b~_ requi1:ed _ te> -~~corporate the integrated schedule into the operating license as a license condition.

Licensees who volunteer for the program will develop and submit the integrated schedule program, the detailed integrated schedule for a fuel cycle, and a less detailed schedule for future fuel cycles to the NRC.

Thereafter, the licensee will submit the detailed integrated schedule for the upcoming fuel cycle and a less detailed schedule for items to be implemented in future fuel cycles.

The staff will have a 90-day negative consent period to respond to the integrated schedule proposed by the licensee.

11 A fundamental premise of integrated schedules is that plant tasks can and should be prioritized.

This can also apply to design engineering and analysis efforts that require substantial resources for an extended period of time.

The prioritization of these projects can provide a consistent and defensible basis for the initial implementation schedule and for_ negotiating future changes or additions.

As the prioritization method will be based on a number of factors, many of which will be plant specific, the Commission has concluded that the licensee should select the prioritization methodology, except to the extent that items in level 1 may have to be implemented by specific dates in accordance with the regulation, order, or license condition.

Although integrated schedules will be developed and proposed by the licensee, the licensee is obligated to describe the process comprehensively to the NRC.

The Commission must understand the planning and scheduling practices and have an overview of ongoing activities at the plant to ensure that licensees are establishing realistic and timely implementation schedules.

The NRC's Divisions of Reactor Projects in the Office of Nuclear Reactor Regulation will manage the implementation of the integrated schedule program.

The staff will work with the

12 licensees and other NRC offices, such as the responsible regional office, to develop mutually acceptable schedules.

Licensees currently implementing an integrated schedule may continue their program or adopt the program outlined above.

Licensees may withdraw from the program upon notifying the NRC.

This policy statement contains information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

These requirements were approved by Office of Management and Budget approval number 3150-0168, which expires August 31, 1995.

Public reporting burden for this collection of information is estimated to average 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> annually per licensee.

In addition, there is a one-time burden of 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> per licensee for submittal of the initial program and a one-time burden of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for termination of the program.

This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing* this burden, to the Information and Records Management Branch (MNBB-7714),

Division of Information Support Services, Office of Information

13 and Resources Management, U. s. Nuclear Regulatory Commission, Washington, D.C.

20555; and to Ronald Minsk, Office of Information and Regulatory Affairs (3150- 0168), NEOB-3019, Office of Management and Budget, Washington, D.C.

20503.

Dated at Rockville, MD, this ~ 'f_ day of~, 1992.

For the Nuclear Regulatory Commission.

Secretar

OFFICE OF THE SECRETARY UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 March 1, 1988 DOlK[ fEC*

U NRC QfF! C!.-. CJ,* ~-t :JI\\~: iAt :'

OOCKE1 ING & 'i[i1 VICL BRA.NC~

NOTE TO RECEIPIENTS OF PR INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS:

PROPOSED POLICY STATEMENT (52 FR 45344)

Please note the comment from Baltimore Gas and Electric (Tiernan) dated February 17, 1988 and marked as Comment No. 17 is incorrect and should be marked Comment No. 20.

Please mark appropriately.

Sorry for any inconvience.

Docketing and Service Branch

JOSEPH A.TIERNAN VICE PRESIDENT NUCLEAR ENERGY BALTIMORE GAS AND ELECTRIC CHARLES CENTER* P. 0. BOX 1475

• BALTIMORE, MARYLAND 21203 February 17, 1988 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

REFERENCE:

Gentlemen:

Docketing and Service Branch Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications (a) Letter from Mr. J. F. Colvin (NUMARC) to Mr. S. J. Chilk (NRC),

dated January 25, 1988, same subject (b) Letter from Mr. A. E. Lundvall, Jr. (BG&E) to Mr. H. L. Thompson (NRC), dated July 8, 1985, Generic Letter 85-07, Implementation of Integrated Schedules for Plant Modifications Baltimore Gas and Electric is pleased to have the opportunity to comment on the proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications. We have reviewed the proposed policy statement and have participated in the formulation of the NUMARC comments (Reference a). We would like to take this opportunity to endorse the NUMARC comments as representing our position on this issue with the following clarifications.

We have chosen not to submit our scheduling process for review by the NRC for the reasons outlined m

our response to Generic Letter 85-07 (Reference b).

We feel strongly that the utility management should retain control over the scheduling process.

Additionally, the policy statement should clearly state that penalties, either implicit or explicit, will not be applied to utilities who fall into categories 2 and 3. This will emphasize the voluntary nature of this program and allow utilities to choose a course of action based on the merits of the program, without duress.

We understand that comments were due to the Commission by January 25, 1988. We apologize for this late endorsement and hope that you will consider it prior to any further action concerning this policy statement.

FEB 2 ~ 1988 Acknowledged by card...**.*..*,~...

i).

IJ. S. NUCLEAR P ~*" t, T' "Y COMMISSIOI-J DOCK~Tli,G,\\

~ 'i...., SECT ION Postma, k,'

Cop1E>,

Add' I r Spacic.l 1..

er

.. :E i/,i y

'. GN

Secretary of the Commission February 17, 1988 Page 2 Should you have any questions regarding this matter, we will be pleased to discuss them with you.

JA T /PSF /dlm cc:

D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC W. T. Russell, NRC D. C. Trimble, NRC Very truly yours,

<f#JI~

DOCKET NUMBE.. R PR -:;7J

~j'/1 PROPOSED RULE "if l!J,,'

DOChr.TG: (_52 F£45E44 USNRC 18 FEB -8 P3 :55 -eEDisoN DONALD C. SHELTON Vice President-Nuclear

[419] 249-2399 February 2, 1988 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Docketing and Service Branch Subj ect:

Comments on Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications (52 FR 45344).

Gentlemen :

Toledo Edison has reviewed the NRC's proposed policy statement on Integrated Schedules for Implementation of Plant Modifications as noticed in the Federal Register issue of November 27, 1987 (52 FR 45344).

The following comments are provided for NRC consideration in finalizing this proposed policy statement:

1.

Toledo Edison concurs in the concept of the establishment and maintenance of an integrated schedule as a pl anning tool in integrating NRC-required modifications with a licensee's requirements for plant modifications, maintenance, refueling and operations.

The optimized allocation of both NRC and licensee resources with regards to scheduling these modifications while maintaining safety, reliability and availability should be the clearly stated overall purpose of such an integrated schedule.

2.

Prioritization of these modifications by a licensee is valuable in providing a prudent and consistent basis for the implementation of the modification and discussions with the NRC.

Toward this end, Toledo Edison has significantly expanded and strengthened its planning and scheduling staff during the past two years.

A Resource and Commitment Management Program has been established to optimize the allocation of resources in meeting Toledo Edison objectives.

The Resource and Commitment Management Program utilizes a formal process to identify, and prioritize NRC modifications, and to budget, plan and schedule these modifications consistent with the prudent allo-cation of Toledo Edison resources.

3.

Toledo Edison concurs in the proposed policy statement that the prioritization methodology must be determined by the licensee, and not prescribed by the NRC due to plant-specific factors.

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652

IJ. S NUCl.fAR P.eCUlATORY COMMISSIOfl OO(K~Tf~'.G fl.. 5-rr"- CE <;[CT ION on i(t (X Tfl'; !;tC :'.' I A~'f t1~ r~iE l.C..,, :\\" 1 ~~, :()~"

Page 2

4.

The policy portion "Suggested Elements of a Plan for the Integrated Scheduling of Plant Modifications" is more suited for issuance by the NRC through another means, e.g., via a Generic Letter.

This would be a more appropriate format for issuing such guidance.

5.

The decision as to whether an integrated schedule should be implemented via a license amendment or via another mechanism should be maintained as voluntary, i.e., the licensee's decision.

Integral to this decision must be a clear understanding of the NRC's expectati ons for the elements of the plan for integrated scheduling and the NRC's enforcement, inspection and evaluation process.

Therefore, the continued clarification of the NRC's expectations through published guidelines is encouraged.

6.

The NRC should consider re-instituting regulatory incentives to a licensee who implements an integrated schedule via either a license amendment or submitted plan.

These incentives should include scheduling of modifications resulting from Generic Letters, Confirmatory Orders, etc. consistent with the integrated schedule plan in lieu of generically stipulated due dates.

Toledo Edison appreci ates the opportunity to provide comments on this proposed policy statement and requests that these connnents be considered in the NRC's future deliberations concerning this policy.

Vew n

yours, iw,':Y~

cc:

A. W, DeAgazio, NRC/NRR Davis-Besse Project Manager

DOCKtf tJUM3ER

-§0

(§:Z F;f_ 4§.J</t) ri"c, I\\,,F,*

~ ~l.J'>NiH'-.

Corbin A. McNeil!, Jr.

Senior Vice President -

Nuclear Public Service Electric and Gas Company Public Service Electric and Gas Company P 0. Box 236, Hancockli-idi~,j(~ofs~o~439-4800 February 1, 1988 NLR-N88013 Mr. Samuel J. Chilk, Secretary United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

Dear Mr. Chilk:

PROPOSED POLICY STATEMENT ON INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS SALEM AND HOPE CREEK GENERATING STATION DOCKET NOS. 50-272/50-311 AND 50-354 Public Service Electric and Gas Company (PSE&G) has been a longstanding member of the Atomic Industrial Forum (AIF) subcommittee on Integrated Implementation Schedules and, as such, participated in the preparation of comments previously submitted by AIF on this issue.

Relative to the request for comments on the NRC draft Policy Statement published on November 27, 1987 (FR45344), PSE&G fully endorses the comments submitted by the Nuclear Utility Management and Resources Council (NUMARC).

The development of an Integrated Implementation Schedule can provide an important tool to both Utility and NRC management in planning and scheduling plant modifications.

However, as identified in the NUMARC comment letter, clarification is required on several points outlined in the draft Policy Statement and additional generic implementation guidance to the industry, separate from the Policy Statement, is also necessary.

It is our be l ief that additional dialogue between the NRC and NUMARC would facilitate resolution of the comments provided and would also be beneficial in the development of any generic guidance.

A J,.... *~ -

NOID1;,.111\\a;s 'ii 9, lJ>I.Jbo E,IOISSIWWO J A~U. 'v' 1:J,ll. V1DON c;.,,

Mr. Samuel J. Chilk 2

02/01/88 We appreciate the opportunity to provide comments on the draft Policy Statement.

Should there be any questions, please feel free to contact us.

Sincerely,

Nuclear Mr. Samuel J. Chilk Secretary of the Comnission U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chilk:

DOCKET NUMBER PR

~

/J/1)1 P,RO POSED RU LE ~:-::-.;,,1=::::

u :::::".!:': (!..!.,)

eocKE rec, {_ 52 F,e 4 5'.B.-f 4 USNHC 138 FEB -3 P2 :38 OFF"t(;~. F ~[,,t;t iAh OOCKE1 ING &. ScYVlf:f.

BRANCH January 29, 1988 C300-88-0256 GPU Nuclear Corporation One Upper Pond Road Parsippany, New Jersey 07054 201-316-7000 TELEX 136-482 Writer's Direct Dial Number:

Subject:

Request for Comnents on Proposed Policy Statement on Integrated Schedules For Implementation of Plant Modifications The staff of GPU Nuclear Corporation herewith submits comments on the subject proposed policy statement.

Comments were requested in a November 27, 1987 Federal Register notice (52 FR 45344).

As a general comment, GPU Nuclear supports the Commission's proposed policy statement and has, in fact, submitted license amendment applications to implement Integrated Schedule plans for both Three Mile Island (Unit l) and Oyster Creek Nuclear Generating Stations.

However, we would like to put forth three specific conments on the proposed policy statement and these are included in the Attachment to this letter.

JRT/RPJ:fg Attachment t~t-Director, Lie. & Reg.

6245f/0173f GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation Affairs

,§. fflJO..M~ i?CGW J. 10?-Y COMMI SSIOA IX:JCKrft;.:G 8r SE :/!Ct SECT ION OrftCf C*: n*: SECf'~rA~Y C:f r:~r cc.:, i:;s:o:-~

- r.,

GPU Nuclear Comments on Proposed Policy Statement for Integrated Schedules

1.

The Policy Statement states that 11 *** no schedule exemption for the implementation of new NRC requirements would be required for those plants with a license amendment.

11 This statement should be clarified to identify its impact on requirements imposed by regulations, e.g., 10 CFR 50.62 (ATWS) or Appendix R.

2.

Some of the items listed under Prioritization Criteria in the draft Plan guidelines are not prioritization criteria but are resource constraints.

Nuclear safety, personnel safety, plant availability, radiation exposure and economic incentive would be appropriate prioritization criteria.

Other items such as budget projections, site manpower, engineering support, etc., are resource constraints and should not be listed as prioritization criteria.

3.

Under Categories of Tasks in the draft Plan guidelines category 2 should not include tasks mandated by agencies other than NRC.

As NRC has no jurisdiction over those tasks, to include them with NRC requirements is inappropriate.

These tasks could be included with licensee-identified changes in category 3.

6245f/0173f

WPSCl414l433-1598 TELECOPIER 14141433-1297 DOCKET NUMBER PR -I>~

,/

-

• OPCJ}~,,e 4; 3~4 ;- <P

,/ EASYLINK 62891993 DOCKEiEQ WISCONSIN PUBLIC SERVICE CORPORATION USNRC 600 North Adams* P.O. Box 19002

• Green Bay, WI 54307-9002 January 25, 1988 Secretary of the Commission U.S. Nuclear Regulatory Commission Attn:

Docketing Service Branch Washington, D.C.

20555 Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on Integrated Schedules for Implementation of Plant Modifications (52 FR 45344)

"BB FEB -2 P 3 ;59 On November 27, 1987 in 52 FR 45344 the Nuclear Regulatory Commission (NRC) requested comments on a proposed policy statement addressing integrated scheduling.

This letter contains our comments.

Presently the NRC allows Licensees and their NRC Project Managers to negotiate schedules for NRC mandated changes.

See for example Generic Letter 83-28 "Required Action Based on Generic Implementation of Salem ATWAS Events." This improvement in scheduling was implemented in response to the wide spread inabi-lity of Licensees to achieve NRC mandated schedules.

The present approach has increased and opened the communication between the NRC and the Wisconsin Public Service Corporation (WPSC), resulting in an "informal living schedule." Through a posture of open communication and trust, WPSC has successfully integrated NRC mandated initiatives into a timely and achievable schedule.

This has accomplished the purpose of an integrated schedule without an accompanying drain on NRC and Licensee resources.

If a Licensee is still unable or unwilling to complete NRC mandates in a timely manner, NRC has recourses under current rules and policy, which it can take on a plant speci-fic basis.

WPSC is opposed to the integrated schedule because it would require additional NRC and licensee resources to write, process, and review a license amendment or integrated schedule amendment when the schedule is revised.

Therefore, coercing the majority of utilities into adopting an integrated schedule would increase the demand on the NRC 1 s and the licensee 1 s resources without a commensurate increase in plant safety or reliability.

~tfrn w!edgedbycarcf.~... -;;;~

U.S. NUCLEAR Rft, 1_1:,\\ TC*~Y COMMf SSIOB DOCKETll'JG E:,. ~"'WICC ~~CTION Offl(~ C*~ 1 rl' SEU.r L".RY OF *r,,: C(.. '-*t/~ 3',1°JI"~

Secretary of the Commission January 25, 1988 Page 2 contains our responses to specific questions posed by the NRC on 52 FR 45346.

If you have any questions concerning any of our comments please feel free to contact me or a member of my staff.

D. C. Hintz Vice President - Nuclear Power Attach.

TJW/cmg cc - Mr. Robert Nelson, US NRC US NRC, Region III to the Letter Dated :

January 25, 1988 From:

D. C. Hintz (WPSC)

To :

Secretary of the Commission RE :

Integrated Scheduling (52 FR 45344)

TJW8.3

Secretary of the Commission January 25, 1988 TJW8.4 Page 1 Ql.

What is the value of integrated schedules as a planning tool for utilities?

Al.

WPSC supports the purpose of an integrated of schedule, i.e., timely but achievable schedules for NRC mandated changes.

The majority of nuclear utilities already develop long and short term schedules in order to optimize their resources and to run their nuclear plants safely and economically.

Open and frank communications between the NRC and these utilities will accomplish this purpose without increasing the demand on the NRC's and Licensee's resources.

WPSC does not deny that some plants have not completed NRC mandated changes in a timely manner.

In these few cases, integrated scheduling might be an effective method of improving plant performance.

However, the present approach to scheduling can work efficiently for the majority of plants.

There is no safety or economic reason to impose additional scheduling requirements on these plants.

Q2.

What are the advantages and disadvantages of a negotiated commitment on scheduling of the implementation of regulatory requirements?

A2.

The widespread inability of licensees to respond to the mandated schedules following the accident at the TMI-2 plant demonstrate that NRC imposed schedules are often unachievable.

As a result, the present method of allowing the Licensee and the NRC Project Manager to negotitate schedules was developed.

This method ensures proper priority is placed on the requirement while ensuring there is sufficient NRC and Licensee resources to support the schedule.

The integrated schedule, as described in the

Secretary of the Commission January 25, 1988 TJW8.5 Page 2 Federal -Register, would not change this method of negotiating schedules but would increase the administrative burden.

Therefore, there is a disadvantage to adopting the integrated scheduling process.

Q3.

What is the value of having the schedule become a license amendment?

A3.

Making the integrated schedule a license amendment would be disadvantageous for the majority of plants.

The majority of nuclear utilities develop long and short term schedules in order to optimize their resources.

Imposing the additional requirement of a license amendment would divert the licensee ' s resources from scheduling and implementation of plant improvements to filing and implementing License amendments.

It would also divert the NRC's resources from auditing plant modifications to reviewing license amendments.

Conclusions In conclusion the present system of scheduling NRC mandated changes can work for the majority of nuclear utilities.

In those few cases where a management breakdown occurs, an integrated schedule may be an effective requlatory tool.

However, encouragi ng implementation industry wide would place greater demands on the NRC's and the Licensee's resources without a commensurate improvement in safety.

DOCKET NUMBER R §6 (ij)

PROPOSED RULE

j

• 1~

(!JZF£ 4~34,V,.

U-601123 130-88(01-29)-LP 1A.1 7ifuc:Knrn lll/NOIS POWER COMPANY I IP I CLINTON POWER STATION, P.O. BOX 67~

LIN~

ILI.J..NOIS 61 72.7

.oo "tl1-~ PJ:41 USNRC Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketi ng and Service Branch January 29, 1988 Sf~1rc u~* ~-.,

' "'"- r.~ t1.,RtIAh Y OCKf t ING & S-t?VJC'{

BRANCl-i

Subject:

Comments on Proposed Policy Statement Integrated Schedules for Implementation of Plant Modifications

Dear Sir:

This letter provides Illinois Power's comments on the proposed policy statement on integrated schedules for implementation of plant modifications.

The Nuclear Management and Resources Council (NUMARC) is also responding to this proposed policy statement.

Illinois Power, by means of this letter, endorses NUMARC's position.

In addition to this endorsement, Illinois Power believes that a policy statement is not the appropriate way to establish and implement an integrated scheduling plan.

If you have any questions, please contact me.

Sincerely yours,

'1.-.~~:: rg, DWW/krm cc:

NRC Clinton Licensing Project Manager Regional Administrator, Region III, USNRC NRC Resident Office

. q -

v. S. NUCLEAR REGULMORY COMMISSION DOCKETB-JG t, S" ?."IG 'SECTION.

OFFICF. C "i:- '.:,[ ~:~ CTl'..RY OF *:1~~ ( C

• • *.:.... i ** t~

fostmllf!, D,,1,,

Copies R,1**

=----------- ------

• NUCLEAR MANAGEMENT AND RESOURCES COUNCIL 1776 Eye $tree*. NW.

• SJ 1e 300

• Wos inoiori. DC 20006-2496

[202) 872-1 280 Joe F. Colvin January 25, 1988

xe~u11Ve Vice Pres.dent &

Cnie' Ope(ot1ng C'i'ce*

Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch Re:

Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications {52 Fed.Reg.45344, November 27, 1987}

Dear Mr. Chilk:

These comments are submitted on behalf of the Nuclear Management and Resources Council {NUMARC) in response to the Nuclear Regulatory Commission's invitation for comments in the above-captioned proposed policy statement.

NUMARC is a nonprofit nuclear power industry organi~ation whose basic objective is to draw upon the industry.'s knowledge, operational and technical expertise and responsibility for the safe operation of nuclear power plants to contribute to the attainment of operational excellence and the enhancement of nuclear power plant safety and reliability. The members of NUMARC include all the utilities that are licensed by the NRC to construct and operate nuclear power plants.

In addition, NUMARC is supported by all of the major nuclear steam supply system vendors and by major architecthengineering firms.

We have provided the proposed NRC policy statement to our members and participants so that we could provide substantive comments representative of industry concerns.

We support the position that the implementation of integrated schedules is on a plant specific and voluntary basis. It wi11 provide a stable environment to allow the effective use of resources for coordinating, managing, and scheduling major modifications, both regulatory and utility originated.

We support the policy statement's recognition of three broadly defined categories available to utilities for implementation of an integrated schedule.

These are:

(1)

Plants with an integrated scheduling license amendment; (2}

Plants with an integrated scheduling p1an submitted to the NRC, but without a license amendment; and

{3)

Plants without a submitted, integrated scheduling plan.

We believe that this distinction of categories is absolutely necessary in that it adds definition to what is described as a voluntary process and in so doing, acknowledges that decisions addressing the use and implementation of integrated schedules are, and must remain, decisions of the individual utilities.

January 25, 1988 Page Two However, of primary concern to many of our members ;s the emphasis placed on the amendment process relative to the other two categories, and the concern that a licensee may not receive equal consideration on schedular issues, if the amendment process is not selected.

The following comments address these concerns:

1.

The amendment process is not currently the approach being considered by the majority of the utilities. Its potential for developing into a workable licensing tool exists if the flexibility required by both NRC and the licensee can be maintained.

We suggest that the following two issues be addressed:

o As currently structured, the proposed poiicy statement 1s si1enL on a number of important subjects which are critical to a utility's decision to use the license amendment approach.

Although we do not propose a detai1ed description of these key elements be placed in the final policy statement, without more detail the approach may not be as positively received.

We agree with the staff that if the license amendment category is to be developed into a viable option, guidelines need to be developed addressing key elements of the amendment process including the scope of the review of the submittal, and implementation and maintenance of the process.

o It is not clear in the po11cy statement that once the process is agreed to by both the NRC and utility that both will use it for future additions.

Following the staff's rev1ew of an individual utility's voluntarily submitted integrated scheduling process, that process should be amenable for app1icat1on to all required activities -- whether NRC or util1ty initiated. Subjecting the proposed activities to the same process will assure a level of stability and a consistent basis for forecasting and scheduling.

It will result in giving the NRC and the utility the same basis from which to plan and on which to base discussions from a common understanding.

We suggest.that th~ pol1cy statement exp11c1tly recognize the commitment that, once the process has been agreed to by both the licensee and the NRC, both will utilize it for future defined act ivities.

2.

Ut ilities agree that i ntegrated schedules are important.

However, most current ly favor uti lizing the process provided for in categories 2 or 3.

Unfortunat ely, the policy statement offers little discussion on these categories.

Al though not discussed in t he d~aft pol1cy statement, it is our understanding that licensees selecting options 2 or 3 would not be penali zed with a lower priority in obtaining needed regulatory relief on schedule issues.

It should be clearly delineated in t he policy statement that for those ut ilities that elect to not submit integrated schedule plans, t he current practices regarding est ablishing ~chedules for regulatory modifi cations are acceptable.

r "

January 25, 1988 Page Three

3.

A policy statement is not the appropriate vehicle to establish the nM:P4-<:;:irv ouidance to imo1ement an intearated schedulinq plan.

• 1heretore, we *would recommend cieietion of i.i1~ uriir\\ ~u~y~:..~~u ~i~,11~11~:)

as described on page 45346 of the federal register notice.

The NRC could issue a generic letter {GL) providing guidance to the utilities, (e.g. GL 85-07 referred to in the background section of the policy statement).

In the paragraph before these suggested elements, the NRC stated that it will continue to work with the licensees to clarify the draft guidelines.

We are very pleased to hear this and will coordinate industry efforts to work with the staff on this matter.

In conclusion, we appreciate the opportunity to comment on the draft policy statement and look forward to working with the staff in the development of guidelines, a key element that 1s needed to address concerns expressed by our members.

If you have any questions regarding these comments, please contact Tom Tipton, Director of the Operations, Management and Support Services Division, or me.

Sincerely, JFC:tpg (7'1°1.~L

""Joe F. Colv1n

DOCl<ET NUMBER PR.

.A"')

~

PjiqPOSED RULE ~

--w/_10_..,.&

C52 Pl! 4o-:344 DOCK[ iT.C EBASCO SERVICES INCORPORATED u:;NRC' Two World Trade Center, New York, N.Y. 10048 113 FEB -2 P3 :56 OFFIC:: ~;, 3tl..1!t,Ard OOCKEi iNG &. SU<VICf.

BRANCH Secretary of the Commission US Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch January 25, 1988

Subject:

PROPOSED POLICY STATEMENT -

INTEGRATED SCHEDULE FOR IMPLEMENTATION OF PLANT MODIFICATIONS Sir:

Ebasco Services Incorporated appreciates the opportunity to express its support of NUMARC 1 s comments on the proposed policy statement concerning Integrated Schedule for Implementation of Plant Modifications.

EJB:maa Very truly yours,

~~~~

Chief Engineer Nuclear Licensing

/ S. NOtlEAR REr-;r !I A'1'0PY COMMf'55" DOCKETl~JG f, c~RVIC:: SECTION

?ostmar~ f\\,,

Add' I C{ *c, **>Ar-p41/i£

~~5~a1tou~~cl _PR ___ --~-1d~.. 03J C2~F;t4ff341)

• a D0.(K[i[r USNHC.*.

GULF STATES UTILITIES CO.JWPANY li8 FE9 -2 p.

p O S T O F F I C E B O X 2 9 5 1 B E A U M O N T, T E X A S 7 7 7 0 4 3.55 AREA CODE 713 838-6631 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch Gentlemen:

January 25, 1988 RBG-27343 File No. G9. 23 DFFIC'

• z. *

• Onr "- v,.).t.

tit iAh,.,

""K[T ING & S[iiVl(T BRANO~

Gulf States Utilities Company (GSU) is pleased to submit its comments on the proposed Policy Statement on Integrated Schedules (52 FR 228).

Because of each utilities' capacities and resources, integrated schedules must be configured first to support the utilities' own needs.

GSU is concerned that promulgation of a policy statement may demand a

move toward a

prescribed format that could compromise the utilities' ability to serve its own needs or serve its needs less efficiently.

In order to demonstrate the necessary scheduling of regulatory requirements into an integrated schedule, GSU believes disclosure of all work efforts assigned resources would be necessary; partial disclosure, as discussed in the draft policy statement, may be ineffective in demonstrating that regulatory requirements are receiving timely attention.

In order to achieve the desired schedule confidence, considerable additional resource burden would be required of the utilities without providing substantial improvement in planning information to the NRC.

A utilities' implementation schedules should be internally maintained.

Frequent dialogue with the NRC Project Manager on implementation of regulatory matters can continue to be effective even in the absence of formal integrated schedules, where mutual integrated schedules are not found to be practicable.

We appreciate the opportunity to comment on the subject proposed policy statement and trust these comments will be of assistance in its final disposition.

JEB/~do

/~cq~Y&~

l. E. Boo*k: -

- ~

Manager-River Bend Oversight River Bend Nuclear Group

• J v.

NUCLEAR P.f(~ULJ\\TORY COMMISSION DOCKETING /l srnvtCE SECT ION OFFICE er-i~lE s.:-:":;-d/>.:'Y OF THf. Cvi.',lv\\!S.,JON

Georgia Power Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526-6526 Mailing Address:

Post Office Box 4545 Atlanta, Georgia 30302 L. T. Gucwa Manager Nuclear Safety and Licensing bOCKET NUMBER

.. ~

PtWPOSED RULE PR -51J-~ J/51

{ ~,t, F£ 4t;.$4-1)'

OOtKETED

~

USNRC 18 FEB.. 1 p 4 :28 Georgia Power fFIC E. OF $~ CHE'lA~ 'f

~OCKETING 6: <.;EHV ICL BRANC~

tile southern electnc system SL-3980 0753U X7 GJ 1 7 -C800 January 25, 1988 Secretary of the Commission U.S. Nuclear Regulatory Corrmission Washington, D. C.

20555 Attn: Docketing and Service Branch

Dear Sir:

GEORGIA POWER COMPANY COMMENTS 0~ A PROPOSED POLICY STATEMENT ON INTEGRATED SCHEDULES On November 27, 1987, the Nuclear Regulatory Corrmission (NRC) solicited comments on the subject proposed policy statement in Federal Register notice 52 FR 45344.

Georgia Power Company (GPC) sincerely appreciates the opportunity to comment on the proposed policy.

GPC places strong emphasis on strategic planning and scheduling.

As a result, and based on our needs, GPC has initiated a detailed Nuclear Planning and Scheduling Strategic Plan to further enhance our effectiveness.

We therefore affirm the safety and economic value of maintaining and implementing an integrated schedule within a utility.

An integrated schedule facilitates the effective application of resources based on a prioritization system designed to suit a utility's unique environment.

As a result, stable, realistic, and long-term plans can be developed, maintained, and properly funded for both regulatory and licensee initiated plant modifications.

In that such plans involve complex managerial issues, it is vitally important that any policy statement assure utility flexibility and be voluntary.

While GPC is improving its strategic planning and scheduling system, we currently do not see any benefits to submitting an Integrated Schedule Plan to the NRC.

We believe the NRC already has access under current practices to all the infonnation necessary to assess whether GPC is operating and maintaining its plants in accordance with acceptable criteria and is implementing regulatory modifications in a timely manner.

I.

I

0. S. NUCLEAR REGULATORY COMMI SSIO.B DOCKETING & SERVICE SECTION OFFIC!: c;: TH:: S[(R!:TARY OF *1 ! L: (.::,\\\\,'* 1$S ION Postmark D;i:~

Copies r-,1: *.

Add' I Ccr*

Special Di:.:,;1,*,ti,, 1 J ____ _

--~ JI 'JJ'lisltJLI(

• Georgia Power, \\

70077~

Secretary of the Convnission January 25, 1988 Page Two If a policy on this subject is further considered, we believe it should include specific guidelines and criteria for what should be included in the scope and format of an integrated schedule plan.

Without guidelines, the application of effort required to develop an integrated schedule plan that would be fully acceptable to the NRC could result in an inefficient use of our resources.

Also, without guidelines, GPC foresees a high probability of regulatory uncertainties in the application of staff interpretations and enforcement actions over time.

If it is decided to issue a policy on this subject, GPC appreciates the NRC Staff I s expressed intent to work with interested 1 i censees to further clarify the proposed policy.

However, we would suggest that NUMARC serve as a focal point to achieve more universal understanding and acceptance.

If you have any questions in this regard, please contact this office.

L TG:ju c:

J. P. O'Reilly J. T. Beckham, Jr.

G. Bockhold, Jr.

GO-NORMS Sincerely,

~~

~

- T. Gucwa

WASHINGTON PUBLIC POWER SUPPLY SYSTEMlc;KCTEu I

P.O. Box 968

• 3000 George Washington Way

• Richland, Washington 99352 January 25, 1988 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attn:

Docketing and Service Branch

Subject:

PROPOSED POLICY STATEMENT

'88 JAN 29 P 4 :22 OFF!Ct: OF -r Cf:t. iAti.;

DOCK£'! !N-6 & SEtlV!C{

BRANCH INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS The Supply System has completed its review of the subject proposed Policy Statement published November 20, 1987.

The Supply System has also actively participated in the development of comments on this issue through the Nuclear Management and Resources Council ( NUMARC).

The NUMARC comments, which will be filed separately, have our support and endorsement.

The underlying concept of integrating the schedules for NRC mandated modi fi cations may be worthy of further study by the Commission and utilities.

To be frank however, we have questions about the potential benefits to be derived from pursuing the course laid down in the proposed Policy Statement, and concerns regarding implementation of the policy on a voluntary basis.

Primarily, we have reservations about including schedules in the Plant Operating License.

Should a schedule change become necessary, even if the NRC staff agrees to the change, the license amendment process can be so cumbersome as to cause concern over the ability to process the change in a timely manner.

We propose that the license contain a statement that "items shall be completed on a schedule agreed to by the NRC staff".

Schedule changes, if necessary, can then be negotiated outside of the license amendment process.

These comments are basically the same as in our reply to Generic Letter 85-07.

We see the logic in including an integrated schedule in a license amendment for plants which had a large backlog of NRC required modifications and which were seeking stability in the process.

For those plants which do not have a large backlog, we feel that an "informal " integrated schedule offers the best option.

An additional area of concern was raised by the Commission's usage of the term "appropriate inspection and enforcement policies" in the proposed Policy Statement.

We would hope that the Commission will

_f B 2 1988 t Kri'owtedged 6y card.. -.-...-.---...

)

(J, S; NUCLEAR REGULATORY COMMISSION DOCKETING & SH:ViCE SECTION OFFICE C~ THE SCCR!:TARY OF THE C-: -\\:.\\1.: SION Postm,uk D.1 tc Copies R2("*"'c:I

Secretary of the Commission Comments - Integrated Schedules Page 2 clarify, in detail, its intent in this area.

This clarification should include some discussion of how this contrasts with the "voluntary" nature of the proposed program.

To follow-up on this last

point, we note that the Policy Statement still contemplates the Integrated Living Schedule (ILS) as a voluntary program.

There will be utilities who do not intend to participate in this program.

This 1 ack of i nvo 1 vement on the part of some uti 1 i ti es shou 1 ct in no way affect current or future decisions by the NRC pertaining to those non-participants.

Pending Regulatory actions should proceed, and no discrimination or sanctions should be levied against those licensees who choose not to volunteer.

This is in keeping with the spirit of the proposed Policy and the intent of 10CFR 50.109.

Additionally, we consider inappropriate the inclusion of detailed guidance as is found in the section of the proposed Policy titled "Draft Suggested Elements of a Plan for the Integrated Scheduling of Plant Modifications".

This information would be more appropriately located in a

lower level guidance document, not in the Policy Statement itself.

To summarize, the Supply System is concerned that the Policy as proposed may not be workable due to the nature of the license amendment process.

Our approach will be to work out a schedule, separate from the Operating License. with our Project Manager.

We consider schedule commitments to be binding whether they are in the license or stated in a letter.

We are also concerned that the Commission's implementation of this Policy may fall short of being completely voluntary.

We would urge the Commission to reexamine its intentions and compare them with the wording of the proposed Policy Statement.

We woul ct hope that some cl arifi cation on this point wi 11 be forthcoming.

Finally, regarding Generic Letter 85-07.

In this document the NRC requested a contact and time frame to meet with the staff to discuss our concerns regarding the ILS.

It is unfortunate that this was not pursued by the NRC.

We suggest that an appropriate course of action would be for the NRC to engage with NUMARC, as representative for the industry. in discussions about these and other concerns being voiced by licensees which have arisen from the subject proposed Policy Statement.

Thank you for this opportunity to participate in the NRC's policy making process.

Should you have any questions or desire further information on this matter, please feel free to contact me directly.

c~

G. C. Sorensen, Manager Regulatory Programs

DOCKET NUM13tK PR

-1 PROPOSED RULE

-> -/;,{./_~ *

{ j ;t, P£ 4f.J4,{J- {[j)

OOlK[iEC:

PHILADELPHIA ELECTRIC COMPANY u:,HRC 5. J. KOWALSKI VICE-PRESIDENT NUCLEAR EN G IN EE R ING 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA. 19101 (215) 841 -450 2 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

SUBJECT:

NRC Proposed Policy Statement on Integrated Schedules

Reference:

Proposed Rules, Federal Register Vol. 52 No. 288 Dated Friday, November 27, 1988 Integrated Schedules as depicted in the Proposed Policy Statement are a product of an Integrated Management Process which prioritizes and schedules modification work on Nuclear Power Plants.

This Integrated Management Process allows for implementation of owner initiated modifications and NRC mandated and/or license commitment tasks i n a timely manner considering all aspects of plant operation.

In our review, this is a necessary process which we plan to implement.

We consider this Integrated Management Process to be invaluable in determining the utility's ability to implement plant changes.

The main advantage of such a process is that all changes to the plant, both regulatory imposed or owner imposed will be evaluated, prioritized, and scheduled based on a net benefit to the plant operation and safety.

It also allows evaluation of these changes in an organized manner whereby commitments for implementation are handled by a management process rather than by management or regulatory mandates.

Appropriate negotiation with the NRC considering plant/owner specific conditions and value for the change are then more realistic for any imposed regulatory requirement since there will be an established plan that acts as a base for all discussions.

It is also our position that the Integrated Management Process be issued to the NRC for review in understanding the process for developing an Integrated Schedule but that we do not see a need for nor do we support a licensing amendment.

The following are some specific comments on content of the Proposed Policy Statement.

_JES 2 1988 know le gea by c'arcf *. ;,.-;;, **,, #'

o:

(l; S1 NUCLEAR REGULA TORY COMMISSI08 POCKETING & SERVICE SECTION OFFICE OF THE S~CRETARY OF Ti::: CC MM ISS l()N

2 -

1.

Budget projection, site manpower, engineering support, management resources and procurement requirements are all identified as prioritization criteria.

These are constraints to implementation and as such, should be listed under "Scheduling".

2.

Although not specifically stated within the policy statement, it is implied that the NRC Staff wants to be involved with plants with an integrated scheduling license amendment.

The policy statement should provide NRC acceptance of plants without a license amendment who have submitted the integrated schedule plan for NRC review.

3.

4.

A benefit of an integrated schedule is the inclusion of scheduled activities for the entire nuclear program.

To request "As a minimum the integrated schedule should include all NRC -

initiated plant modifications" and "Licensee - initiated plant changes would only appear as necessary" can only lead to confusion. It's only by viewing the entire integrated schedule that it becomes apparent that. resources are being optimized and that all projects are being worked in their order of priority.

The Draft Suggested Elements of a Plan section should remain suggested since each utility program need not address all items as depicted.

JTS/gfh/01228801

DOCKET NUMBER PR PROPOSED RULE

-;j2 ~

CM.I. {52 F,e :::[~?)

Carolina Power & Light Company USNRC JAN 2 6 1988

• ea JAN Z9 p 3 :42 EM-770 Mr. Samuel J. Chilk Secretary of Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Docketing and Service Branch Room 1121, 1717 H Street, NW Washington, DC 20555 PROPOSED POLICY ST A TEMENT ON INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS (52FR 45344; NOVEMBER 27, 1987)

Dear Mr. Chilk:

Carolina Power & Light Company (CP&L) appreciates the opportunity to comment on the proposed policy statement, "Integrated Schedules for Implementation of Plant Modifications" (52FR 45344; November 27, 1987). We have reviewed the proposed policy as well as other recent NRC staff documents regarding integrated schedules.

We support the integrated schedule concept and are in general agreement with the proposed policy. However, while we believe that the Commission and Senior NRC staff management share our support in integrated schedules, we believe that there could be NRC staff resistance to certain elements of the policy. In this letter we address the matters of major concern to CP&L In addition, CP&L endorses the comments submitted by the Nuclear Management and Resource Council.

I.

NRC INTEGRATION OF PENDING REGULATORY ISSUES The effectiveness of plant-specific integration of issues depends on the degree to which the NRC has first integrated and prioritized regulatory initiatives.

Ideally, the NRC would prioritize all pending regulatory issues (e.g., rules, regulations, orders, generic letters, bulletins, and information notices) through a method similar to the one promoted in the proposed policy. However, the NRC is addressing current regulatory requirements discreetly without full consideration for their relative contribution to the overall protection of the public health and safety considering the direct and indirect costs of implementations. This often results in inefficient use of licensee resources and duplication of efforts.

411 Fayetteville Street

• P. 0. Box 1551

• Raleigh. N. C. 27602 FEB 2 1988 Acknowledged by card. *.;:;;;; * ;;,,...,.....,

");S, NUCI.EA~ f!fGU' \\i *I

• r()tv\\,/\\ISSIO.N DOCKET!l':G & ~H 1i i: srCT ION OFFIG 'X -

r

" {

OF I~

Postmark D.~:,

Cop:~s

~c *;

Add' I C0~.,~ "

Special D, s "

Mr. Samuel J. Ch ilk EM-770 / Page 2 The resolution of seismic concerns at nuclear power plants illustrates the difficulties that licensees face in the integration of pending regulatory issues.

Currently, there are a number of seismic related issues pending resolution:

USl A-46, Seismic Qualification of Equipment in Operating Reactors Seismic Design Margins Eastern United States Seismicity (Charleston Earthquake Issue)

USl A-17, Systems Interactions USl A-40, Seismic Design Basis USl A-44, Station Blackout USl A-45, Shutdown Decay Heat Removal Severe Accident Policy Implementations Quantification of Safety Goals There is overlap between these issues. However, for the most part, the NRC is addressing these issues individually, without a comprehensive review to remove areas of redundancy. In addition, the NRC has not coordinated the timing of these initiatives. Therefore, licensees may be exposed to multiple walkdowns and evaluations of the same components. Notwithstanding this, on February 19, 1987, the NRC issued Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, USl A-46," requesting that licensees submit a schedule for final resolution. The Seismic Qualification Utility Group (SQUG) is currently developing a methodology to resolve USI A-46. However, this effort, as it stands today, will not resolve the other seismic issues.

Individual licensees could, and probably will, attempt to integrate these issues to the extent possible. However, it would be more effective if the coordination were done by the NRC, with assistance of industry groups such as SQUG.

The integration of seismic issues is only one example of the optimum NRC integration of pending regulatory issues. Ideally, the NRC could integrate all pending issues by prioritizing based on safety risk reduction. Licensees would then integrate these NRC-mandated actions with the self-identified changes to come up with a plant-specific integrated schedule.

II.

DEFINITION OF THE TERM "MODIFICATIONS" The proposed policy states that "the implementation of integrated schedules on a plant-specific basis would provide a systematic means of coordinating, managing, and scheduling major modifications." The term "major modifications" does not capture the full reason for integrated schedules.

CP&L suggests the term "major modifications" be replaced with "major resource-intensive activities." This term would also capture activities such as

Mr. Samuel J. Chilk EM-770 / Page 3 major design basis documentation or procedure update, etc. We believe everyone of these elements to be a legitimate candidate for the integrated schedule process because of the potential for significant resources requirement. The objective of the integrated schedule process is to optimize the use of resources.

III.

INTEGRATED SCHEDULING CATEGORIES The NRC uses the word "voluntary" to describe their integrated schedule program. The licensee may indeed be given a choice, but the consequences of non-participation as outlined in this policy statement needs to be carefully considered. Perhaps the crucial part of the policy statement is the paragraph that states:

When circumstances warrant, the Commission can impose new deadlines with the understanding that they could affect the completion of other regulatory requirements or other licensee projects already scheduled.

This approach is contrary to the integrated schedule philosophy which presumes that you schedule a project based on its relative merit (the benefit index including PRA) and its resource requirements (versus the available resources). If, after all factors have been taken into consideration, the integrated schedule process should schedule a new regulatory project out in the 1990's, then that is where the project belongs. The NRC, however, says that NRC will decide where the project should be scheduled unless the licensee has a formal integrated schedule license amendment in place, in which case the NRC will not impose such schedule dates. The policy statement also states:

The existing integrated scheduling license amendments give the licensee the flexibility to change schedules, as needed, by delays beyond the licensee's control or by the imposition of new regulatory requirements.

The implication here is that a plant choosing not to seek a license amendment may not have the flexibility to revise its schedules for delays and impositions which are beyond its control.

The NRC's emphasis is misplaced; the license amendment is not the issue, integrated scheduling is. NRC should encourage the implementation of a comprehensive integrated scheduling program regardless of whether a formal license amendment is in place.

The policy statement also mentions that changes are to be resolved on a case-by-case basis for those who choose to forego a license amendment. This statement is misleading. Even with a formal license amendment request in place, our scheduled dates and changes (e.g., Environmental Qualification) were reviewed on a case-by-case basis with apparently little regard for other scheduled projects and schedule constraints.

IV.

INTEGRATED SCHEDULE GUIDELINES The proposed policy provides, for licensee consideration, draft guidelines for integrated schedules. Further, the NRC indicates that, in the future, it will issue additional inspection and enforcement policies. We recognize that, from an NRC perspective, it may be desirable to refine the ground rules as programs

Mr. Samuel J. Chilk EM-770 / Page 4 are implemented because it minimizes the agency's resource requirements.

However, this translates into licensee uncertainty and could deter utility participation. We believe this issue should be resolved before the Commission publishes the final policy statement.

CP&L recommends, in this connection, that the NRC use the experience gained during the Integrated Safety Assessment Program (ISAP) to develop what it considers to be the minimal acceptability criteria, including any inspection and enforcement policy. Further, the NRC should foster, among utilities, the notion that the rules will not capriciously change in the middle of the process. Since the recent NRR consolidation of the Inspection and Enforcement function, this should present no problem in resolving this issue within NRR prior to publishing the final policy statement.

In summary, we support the integrated schedule concept and commend the Commission for its efforts. Further, we believe that it will be in the best interest of the public, the NRC, and the industry to develop and refine the integrated resolution process to the point where all NRC initiatives are fully integrated.

If you have any question, please contact Pedro Salas at (919) 836-8015.

PS/vtn Yours very truly, erman Manager Nuclear Licensing Section

DOCKET NUMBER p P.ROPOSED RULE

-:5?;

C5z F-,,e,4~~44,.

DuKE PowER GoMPANY ooc.;KUtt' P.O. BOX 3 3 189

u. NRC HAL B. TUGKER VJOE PRE SIDE N T N UCL E AR PRO O UGTION January 22, 1988 CHARLOTTE, N.G. 28242

~

cretary of the Commission U.S. Nuclear Regulatory Commission Wa shington, D.C.

20555 ATTENTION:

Docketing and Service Branch

Subject:

NRC Proposed Policy Statement 10CFR Part 50 Duke Power Company Comments

Dear Sir:

18 28 AS :48 TELEPHONE (704) 373-4~31 In the Federal Register (52 FR 45344) dated November 2 7, 1987, the Nuclear Regu-latory Commission published for comment a proposed policy statement describing the policy the Commission intends to use for promoting voluntary licensee integrated schedules for i mplementing regulatory requirement and other improvements in nucle-ar power plants.

The Commission specifically requests public comments on the value of integrated schedules as a planning tool for utilities; the advantages and disadvantages of a negot i ated commitment on scheduling of the implementation of regulatory require-ments; the value of having the schedule become a license amendment; and additional options f or i mp l ementation of integrated schedules.

Duke Power feels an integrated scheduling process is an invaluable planning tool as evidenced by its long term use f or various activities at Duke Power nuclear stations, including regulatory requirements.

Ther efore, we support the concept of integrated scheduling and feel the Commis-sion's Policy Statement can serve as the means to accomplish consistent integrated scheduling throughout the industry,

provided flex ibility to accommodate licen-see-initiated plant changes is ensured.

As we understand the policy statement as proposed, this latter point will be accomplished by allowing licensee discretion f or including internal items in the integrated scheduling process.

The Nuclear Management and Resources Council (NUMARC ) is submitting constructive comments on the proposed policy statement.

We have reviewed these comments and feel they should be considered for inclusion in the f inal policy statement devel-opment.

I U, S. NUCLEM r>tCL'.~ f".l'!Y ('OMMfSSION DOCKflli'lG & ~: '"!

<;rCTION O~F1.:-; r*:

~

c -*, \\I?_'(

Po,,m~r Cop1c*

Add' i

• iSpccial f:.,

),1;~

f 1JJ'f: 'i3,lmC

The Secretary of the Commission January 22, 1988 Page 2 Duke Power appreciates the opportunity to comment on this item.

Very truly yours, Hal. B. Tucker DM/246/jgc

0 DOCKET NUMBER PR

. ~

PROPOSED RULE

-./;4__ Ct/

C62 I="'~ 4~.34V -~

Wtscons,n Electr,c Powrn coMPANY 231 W. MICHIGAN, P 0. BOX 2046, MILWAUKEE, WI 53201 VPNPD-88-052 NRC-88-009 January 15, 1988 Secretary of the Commission U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C.

20555 OO(;KETED USNHC "88 JAN 28 A 8 :38 OFF IC'- GF.St. i..tir. i J;K

• OOCKEilNG & Sf:.flVIU.

BRANCl-1 Attention:

Docketing and Service Branch Gentlemen:

PROPOSED POLICY STATEMENT ON INTEGRATED SCHEDULES (414) 221-2345 On November 27, 1987, the Nuclear Regulatory Commission published in the Federal Register, Volume 52, No. 228, a proposed policy statement regarding integrated schedules for implementation of plant modifications.

The Commission specifically requested comments on the value of integrated schedules as a planning tool, the advantages and disadvantages of a negotiated commitment on scheduling of the implementation of regulatory requirements, and the value of having the schedule become a license amendment.

As the licensee and operator of a nuclear power plant, we offer the following comments on these issues.

We recognize the need for licensees to develop internal schedules for plant modifications and changes in order to properly manage these projects and maximize utilization of limited resources.

We do not, however, note an advantage in negotiating the entire schedule with a regulatory agency.

We are currently obligated to inform the NRC of the schedule for completion of those projects necessitated by their initiatives and to advise the NRC of any changes necessary to those completion dates and to justify such changes.

Requiring, or even encouraging, the whole scheduling process to be subject to scrutiny and examination by the NRC staff would, we believe, cause a considerable work load for the NRC staff and would generate a need for more regulatory exchange than it could possibly save.

t I w'

<l

IJ,S, NUCLEAR REGULATORY COMMISSIOij DOCKETING & S~'='VlCE SECTION OFFICE 0r-1 ° ~~cR.:~.\\RY er r:< ("c.-.*1, 1

, rJ

,,f,.J' I (, ~

• 1/J6-I 2-fl!A B/tL~lv..

Secretary of the Commission January 25, 1988 Page 2 We are concerned with the concept of an integrated schedule becoming a license amendment.

The license amendment process, and the required noticing, is inherently tedious, cumbersome, and time-consuming and provides opportunities for lengthly delays.

These characteristics are inconsistent with effective scheduling.

In addition, the process would be subject to 10 CFR 170 fees, thereby further increasing costs with little or no benefit.

In the suggested elements for a plan for integrated scheduling, there appears to be an emphasis on approving the scheduling acceptance criteria without taking account of the financial and direct and indirect cost aspects of this planning.

These financial concerns often provide the major consideration for the acceptability of schedules.

We agree that it would be inappropriate for the Commission to become involved in the licensee's financial planning and therefore question the appropriateness of approving or establishing acceptability criteria for scheduling practices.

The notice states that for the purposes of the Policy Statement three categories of plants are considered and list these categories.

However, there is no differentiation within the Policy Statement for these plant categories and, in fact, no further mention of the plant categories.

Many licensees have had an excellent record of setting and meeting realistic goals for the completion of NRC directed activities.

The Policy Statement should recognize this category of licensees and acknowledge that development of a negotiated integrated schedule for licensees with good regulatory compliance records is neither necessary nor particularly appropriate.

We appreciate this opportunity to submit our comments and would be pleased to respond to any questions you may have.

Very truly yours, C. W F y Vice1 President Nuclear Power Copies to NRC Regional Administrator, Region III NRC Resident Inspector

123 MJ r Street Wh1tP Pie 1m, New Yo*k '0o01 914 681 6240 DOCKET NUMBER Dff

'~ ~

PROPOSED RULE r1 --.§ZJ,___ '21

{5ZPA!,4~344;)

CJlK[ Ti:C*

U::iNRC

,. NewVorkPower

., Authority "88 JAN 28 AS :41 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 ATTN:

Docketing and Service Branch

Dear Sir:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Indian Point 3 Nuclear Power Plant Docket No. 50-286 Comments on NRC Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications This letter provides the Power Authority's comments John C. Brons E:><Pc.utive Vice President Nuc;lear Generation on the proposed policy statement "Integrated Schedules for Implementation of Plant Modifications", published in the Federal Register, dated November 27, 1987 (52 FR 45344).

The Authority agrees with the proposed policy that integrated schedules for regulatory requirements and other improvements should be established on a voluntary basis.

The integrated schedule is an excellent tool for resource allocation.

It prioritizes activities necessary for safe, reliable, and efficient power generation.

The Authority also agrees with the major elements to be addressed in an integrated schedule plan.

The list of elements contained in the policy statement is inclusive without being unduly prescriptive.

The Authority has concerns about the integrated schedule as a license amendment.

According to the proposed policy, the intent of the integrated schedule license amendment is to assure the timely scheduling and completion of regulatory modifications.

The policy states that if a new NRC requirement is imposed, no schedule exemption would be required.

This statement requires elaboration.

The policy statement should clearly state fEB 2 1988

~-~aw edged by eard..... r........,.....,......-c

0. S NUCLEAR REGULATORY COMMISSIOS DOCl<ETING,1 SC:f!'/IC~ SECT ION OFFICE Or Tr"~ ::."C~.:T/.SY Postm1,':

r..

Add l ::

~ecial [

1/4;

• I

/!1J.-B&C

that new regulatory requirements will not impose an implementation date on plants having an integrated schedule license amendment.

The policy statement should also say that new regulatory requirements will specify that these plants should propose a date in accordance with their integrated schedule, for NRC approval.

Plants with an integrated schedule plan submitted to the NRC, but without a license amendment, can have implementation dates imposed.

These plants can use the integrated schedule as a negotiating tool, but they would still require schedule exemptions if they could not meet the imposed dates.

Guidance, regarding the amount of information or the level of detail required to support a schedular exemption, should be included in the policy statement.

Should you have any questions regarding this matter, please contact Mr. J. A. Gray, Jr. of my staff.

cc:

Very truly yours, o n(}!h xecutive Vice President uclear Generation U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093 Mr. Harvey Abelson Project Directorate I-1 Division of Reactor Projects-I/II U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory Commission P. o. Box 377 Buchanan, New York 10511 Mr. J. D. Neighbors, Sr. Project Manager Project Directorate I-1 Division of Reactor Projects - I/II U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014

VERMONT YANKEE 00( '[ f[ C, U')NifC NUCLEAR POWER CORPORATION

• aa J 28 AS :39 FVY 88-05 RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 BEPLYTO OfF I~!:. :,;r,~ 1 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 00CKfT 1W ~... It.JG OFFICE BR ~

1-wORCESTER ROAD FRAM INGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 January 22, 1988 Attention:

Docketing and Service Branch

Subject:

Integrated Schedules for Implementation of Plant Modifications Vermont Yankee Nuclear Power Corporation appreciates the opportunity to reply to the subject NRC Proposed Policy Statement.

Vermont Yankee presently employs a process for developing integrated sche-dules wherein efforts associated with NRC requirements are negotiated between Vermont Yankee and the NRC Division of Licensing Projec t Manager.

The process has proven to be generally successful and is based on the daily interactions between Vermont Yankee's Licensing Engineer and NRC's Project Manager.

Vermont Yankee has successfully scheduled many large tasks such as CRDR, Appendix R, EQ, SPDS and Recirc Pipe Replacement over the past several years without a formal Integrated Living Schedule (ILS), as described in the proposed policy statement, with the NRC.

Vermont Yankee believes the goal of the proposed policy statement, i.e.,

developing and maintaining realistic schedules for completing major activities, is already being achieved at Vermont Yankee.

An ILS as part of a formal license condition is not necessary and in many cases, given the current licensing pro-cess, would be less efficient in reaching agreement for the scheduling of NRC required modifications.

Based on the above, Vermont Yankee feels ILS should not be a formal part of the licensing process.

/dm Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION

~~~ tw-Warren P. Murphy Vice President and Manager of Operations FEB 2 1988

.J, S, NUCLEAP. P.~c.ur Ai\\.) ¥ ( vMM1.S.. I DOCKETING ~. SEP-VIC SfCTION OFFICE C:- lHE !:c,-:r:r \\ '(

OF THt CC i' "1 1:iSIO l Add I '~*

p,.

~~~~6l~ou~sct ~PR~-~~-LJ~ ~

/~2 Fi-:-,a Ar~ AA )'

Telephone (617) 872-8100

(._,,'::..I*

/'C.., ""'I'~ O~V TWX 710-380-7619 YANKEE ATOMIC ELECTRIC COMPANY G:.)

1671 Worcester Road, Framingham, Massachuse'f58 01JAN 27 P2 :38 January 25, 1988 OFFIC[ _;f SE;.,h* iAfi y OOCKfTiN (.i f. S[i< 'ICF:

BRANCH Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:

Docketing and Service Branch

Subject:

Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications (52FR45344)

Dear Sir:

Yankee Atomic Electric Company appreciates the opportunity to comment on the subject proposed policy statement on integrated schedules.

Yankee Atomic Electric Company owns and operates a nuclear power plant in Rowe, Massachusetts.

Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the Northeast, including Vermont Yankee, Maine Yankee, and Seabrook.

We agree that systematic coordination, management, and scheduling of NRC-and utility-initiated activities are very important.

We have found that integrated scheduling results in resource optimization and thus, efficient and timely completion of scheduled activities.

In addition to our own experiences, we understand that many other utilities are using integrated scheduling, and using it successfully.

Therefore, we question the need for a policy statement at this time.

However, if the Commission deems it necessary to proceed with this policy statement, we recommend that several changes, as di scussed in the following paragraphs, be made.

It appears that the objective of the policy statement is an integrated schedule via a license amendment, i.e., Category 1.

We suggest that a "license amendment" has nothing to do with accomplishing the goal of effectively coordinating, managing, and scheduling completion of major activities.

We believe the Commission recognizes that point, and has thus offered utilities two other choices, i.e., Category 2 and 3, in which no license amendment is involved.

However, in light of those choices, the Commission provides little discussion on any scenario other than Category 1.

In recognition of the acceptability of Categories 2 and 3, we urge the Commission to discuss all three options on an equal footing within the policy statement.

FEa 2 1988

~fiO'Nlt~d* by C!trtt.~;:;t""'.;;.;_.,~~~

8

, f lJ. S. NUCLEAR REG!JLt* TORY COMMISSIOS DOCKETING P,

~:~ 'ICE SECTION OFFIC: (,

~ *rpCT'R'f Of'..

l>o!lmtirk [' '

':opies

~ *

\\ dd°' l,:-,

!~ei:,al t>, 'r

Secretary of the Conunission January 25, 1988 Page 2 To develop the license amendment category into a viable option, we reconunend that the Conunission highlight the benefits to those utilities who volunteer to develop an integrated schedule through such an approach.

Unfortunately, the policy statement is silent on the matter.

Instead, the policy statement leaves the reader with the inference that utilities who do not develop an integrated schedule or those who do develop one, but do not choose to volunteer for a license amendment, will be treated differently.

That is, the NRC will afford such utilities less flexibility and/or priority in negotiating a schedule.

We do not believe that the Conunission intended that the policy statement result in such a practice.

Given that belief, we urge the Conunission to clearly state in the policy statement that negotiations will be unaffected by the utility's choice to volunteer or not volunteer for a license amendment.

As a benefit to those utilities who choose to have integrated schedule approved via a license amendment, we urge the Conunission to specifically delineate that both the NRC and utility will be explicitly bound to use the approved prioritization and scheduling methodology whenever changes and additions of activities are necessary.

In conclusion, we reiterate our belief that the proposed policy statement, as a vehicle for accomplishing the noted goals, may no longer be timely.

However, given the assumption that a policy statement on integrated schedules is necessary, we agree with the Conunission that the program should be a voluntary one and urge the Conunission to adopt the suggested changes we have outlined above.

Truly yours, Donald W. Edwards Director of Industry Affairs JMG/22.530

NUCLEAR MANAGEMENT AND RESOURCES COUNCIL 1776 Eye Street. N.W.

• Suite 300

• Washington. DC 20006-2496 (202) 872-1280 "88 JAN 26 P 2 :4~

Joe F. Colvin January 25, 1988 Executive Vice President &

Chief Operating Officer OF FICE vr St u\\t l,,.*(

OOCKE11NG & SE-1v1cr:

BRANCl-i Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch Re : Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications (52 Fed.Reg.45344, November 27, 1987)

Dear Mr. Chilk:

These comments are submitted on behalf of the Nuclear Management and Resources Council (NUMARC) in response to the Nuclear Regulatory Commission's invitation for comments in the above-captioned proposed policy statement.

NUMARC is a nonprofit nuclear power industry organization whose basic objective is to draw upon the industry's knowledge, operational and technical expertise and responsibility for the safe operation of nuclear power plants to contribute to the attainment of operational excellence and the enhancement of nuclear power plant safety and reliability.

The members of NUMARC include all the utilities that are licensed by the NRC to construct and operate nuclear power plants.

In addition, NUMARC is supported by all of the major nuclear steam supply system vendors and by major architect-engineering firms.

We have provided the proposed NRC policy statement to our members and participants so that we could provide substantive comments representative of industry concerns.

4t We support the position that the implementation of integrated schedules is on a plant specific and voluntary basis. It will provide a stable environment to allow the effective use of resources for coordinating, managing, and schedul i ng major modificati ons, both regulatory and util ity originat ed.

We support the policy statement's recognition of three broadly defined categories available to utilities for implementation of an integrated schedule.

These are:

(1)

Plants with an integrated scheduling license amendment; (2)

Plants with an integrated scheduling plan submitted to the NRC, but without a license amendment; and (3)

Plants without a submitted, integrated scheduling plan.

We believe that this distinction of categories is absolutely necessary in that it adds definition to what is described as a voluntary process and in so doing, acknowledges that decisions addressing the use and implementation of integrated schedules are, and must remain, decisions of the individual utilities.

F'E'B 2 1988

U S. NUCLEAR REGU1 A TORY COV1MI SSIO°N ooc1-:mr--1,::;,?,. S[RVICE S~CTION Postmar1<

Copies r.,,

O r

Add' I Ccr:-1. '..

I,*, --:'

Special 0;5trib11', 't /

1~

January 25, 1988 Page Two However, of primary concern to many of our members is the emphasis placed on the amendment process relative to the other two categories, and the concern that a licensee may not receive equal consideration on schedular issues, if the amendment process is not selected.

The following comments address these concerns:

1.

The amendment process is not currently the approach being considered by the majority of the utilities. Its potential for developing into a workable licensing tool exists if the flexibility required by both NRC and the licensee can be maintained.

We suggest that the following two issues be addressed:

o As currently structured, the proposed policy statement is silent on a number of important subjects which are critical to a utility's decision to use the license amendment approach.

Although we do not propose a detailed description of these key elements be placed in the final policy statement, without more detail the approach may not be as positively received.

We agree with the staff that if the license amendment category is to be developed into a viable option, guidelines need to be developed addressing key elements of the amendment process including the scope of the review of the submittal, and implementation and maintenance of the process.

o It is not clear in the policy statement that once the process is agreed to by both the NRC and utility that both will use it for future additions.

Following the staff's review of an individual utility's voluntarily submitted integrated scheduling process, that process should be amenable for application to all required activities -- whether NRC or utility initiated. Subjecting the proposed activities to the same process will assure a level of stability and a consistent basis for forecasting and scheduling.

It will result in giving the NRC and the utility the same basis from which to plan and on which to base discussions from a common understanding.

We suggest that the policy statement explicitly recognize the commitment that, once the process has been agreed to by both the licensee and the NRC, both will utilize it for future defined activities.

2.

Utilities agree that integrated schedules are important.

However, most currently favor utilizing the process provided for in categories 2 or 3.

Unfortunately, the policy statement offers little discussion on these categories. Although not discussed in the draft policy statement, it is our understanding that licensees selecting options 2 or 3 would not be penalized with a lower priority in obtaining needed regulatory relief on schedule issues.

It should be clearly delineated in the policy statement that for those utilities that elect to not submit integrated schedule plans, the current practices regarding establishing schedules for regulatory modifications are acceptable.

January 25, 1988 Page Three

3. A policy statement is not the appropriate vehicle to establish the necessary guidance to implement an integrated scheduling plan.

Therefore, we would recommend deletion of the draft suggested elements as described on page 45346 of the federal register notice.

The NRC could issue a generic letter (GL) providing guidance to the utilities, (e.g. GL 85-07 referred to in the background section of the policy statement).

In the paragraph before these suggested elements, the NRC stated that it will continue to work with the licensees to clarify the draft guidelines.

We are very pleased to hear this and will coordinate industry efforts to work with the staff on this matter.

In conclusion, we appreciate the opportunity to comment on the draft policy statement and look forward to working with the staff in the development of guidelines, a key element that is needed to address concerns expressed by our members.

If you have any questions regarding these comments, please contact Tom Tipton, Director of the Operations, Management and Support Services Division, or me.

Sincerely, JFC:tpg r7r1/4M>L

"'0oe F. Colvin

DOCKET NU1~BER PR L-,i

~

PROPOSED RULE

-~- ~

(~ F/!, 4ff.!41)

SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.O. Box 15830, Sacramento CA 95852-1830, (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 88-043 JAN 2 5.

Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 PROPOSED POLICY STATEMENT:

INTEGRATED SCHEDULES FOR IMPLEMENTATION OF PLANT MODIFICATIONS

Dear Mr. Chilk:

The District has taken the opportunity provided by the Commission to review the proposed policy statement entitled "Integrated Schedules for Implementation of Plant Modifications."

As a member of the Nuclear Management and Resources Council (NUMARC) we have been involved with the development of the NUMARC position which has been provided to the Commission in response to the proposed policy statement.

We fully endorse the NUMARC position and wish to add our support to its use and consideration in the final policy statement.

Please contact me if you have any questions.

Members of your staff with questions requiring additional information or clarification may contact Mr. Steve Crunk at (209) 333-2935, extension 4913.

Sincerely,

-~

Chief Executive Officer, Nuclear cc:

G. Kalman, NRC, Bethesda FEB 2 1988 flOWledged by OOrcl -~

• *'.'l":-r-:ir-rrrrrf"'l'*-

• ,.......t;;a RANCHO SECO NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638-9799; (209) 333-2935

IJ. S NUCLEAR REG' 11 A TORY CO,'AMI SSIOli DOCKET Ii l~ & S~RVICE ~(CT ION 0°F!r' r,

¥~" S~C.,A>I..Y C'

,. (*N Postrr.* \\ P Ccp': r.

• Ade' I l*

• Special Di,tr'b, *.,

-J (iec~mbi;i~

• IC J.._,' i987 DOCKET NUMBER PR r?1

'JI PROPOSED RULE

-..; u

.e \\._!,I

{52-F~ 4§J44).

17 DOC:K[ i((:

USNRC DEC 22 A10 :05 COMMENT*; OF OHIO CITIZENS FOR RESPONSIBLE ENERGV, INC.

("OCRE*)

ON PROPOSED POLICY STATEMENT, "INTEGRATED SCHEDULEi~Ftc~*F ~ R.. CRU At?Y IMPLEMENTATION OF PLANT MODIFICATIONS"'

52 FED.

REG.

f ~3*~~.. lNcAERv1cr.

l*J o v e m ~ e, r-2 7,

1 9 8 l OCRE is opposed purpose appears

l. i cen*;ees must to the use of to be to avoid compl y with licensees do not possess the integrated schedule.;.

setting a date certain by regulator y requirements, financial, managerial or Their which If human resources to comply with the NRC's regulatory a timely manner, then they do not deserve to be integrated schedule concept is yet another step of deregulation of the nuclear power industr y,

requirement: *;;

licensees.

down the in The path It is also of dubious

legality, Among the factors to be considered in setting the schedule for implementing, inter

alia, "items mandated by NRC

rules, orders,

and license conditions*

are licensee "budget projections *,

"plant a *,,ailability*, and *co*;;ts.

• The D.C. Circuit court of Appeal*;

has recently held that the NRC may not consider costs ta licensees in either establishing regulatory standards necessary for adequate protection of the public or in enforcing those stand a 1~ d s

• Union of Concerned Scientists v

• N,R C,

8 2 4 F

• 2 d 108

{C*.C. Cir, 1987 ).

In short, the NRC *;;hould simply not concern itself with the financial affairs of its licensees, but rather should ensure that all its safety regulations are enforced and implemented without delay, If a licensee is unable to compl y with all these regulatory requirements in a

timel y

fashion, then the NRC should take the appropriate enforcement

action, including suspension of a license until the requirements ar-e met.

The NRC ' s regulations should be enforced promptly and uniformly, and not at the con v enie n ce of the licensees.

Respectfully submitted,

~~~

Su s an L. Hia~t OCRE Representati v e B275 Munson Road Mentor, OH 44060 (216 ) 255-3158

o: OJ\\

(" i..1 a*

' (

t 1-;;

,. J u

. ' 'JI nu~ ITT'";t.fr/,1'~~r COM'M15Sf0N KET I~ 1d t;, S:"!'/

11., S(CTION 0°lFfC! or tf 1 -

' ~nAn

~* iW

~sr!ff -!< 1::M

• Copi,?s Ptt"'I'*

• Adct'f C,;'

pod f D,

45344 Proposed Rules This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules.

DEPARTMENT OF AGRICULTURE Food Safety and Inspection Service 9 CFR Parts 317 and 381

[DocketNo.86-037Cl A

Ingredients That May Be Identified as W Flavors or Natural Flavors When Used In Meat or Poultry Products AGENCY: Food Safety and Inspection Service, USDA.

ACTION: Proposed rule; reopening of comment period; correction.

SUMMARY

This document corrects a notice.which reopened the comment period on the proposed rule by noting that the Agency will accept oral comments to the proposed rule during the reopened comment period in accer.dance with the Poultry Products lnspect~on Act.

FOR FURTHER INFORMATION CONTACT:

Margaret O'K. Glavin, Director, Standafds and Labeling Division, Technical Services, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, DC 20250, (202) 447-6042.

SUPPLEMENTARY INFORMATION: On August 18, 1987, the Food.Safety and Inspection Service (FSIS) published a proposed rule in the Federal Register (52 FR 30922) to amend the Federal meat and poultry products inspection regulations to require that certain substances added to meat and poultry products and identified only as flavors or natural flavors be identified on product labels by their common or usual name.

Following publication of the proposed rule, the Agency received comments for 60 days. and on October 23, 1987, published a notice in the Federal Register (52 FR 39658) which reopened the comment period for an additional 60 days. While the original proposed rule provided for presenting oral comments, the notice did not reiterate information concerning the reception of oral comments pursuant to the Poultry 9.)

Produc s seq.).

Accordingly, FSlS is now issuing this correction to inform the public that any person desiring an opportunity for an oral presentation of views on the proposed rule should make such request to Ms. Glavin at the address mentioned above so that arrangements can be made for such views to be presented.

Done at Washington, DC on: November 23, 1987.

Lester M. Crawford, Administrator, Food Safety and Inspection Service.

[FR Doc. 87-27319 Filed 11-25-87;* 8:45 am]

BIWNG COOE 341~

NUCLEAR REGULATORY COMMISSION 10 CFR Part 50

• Integrated Schedules for Implementation of Plant Modifications; Proposed Policy Statement AGENCY: Nuclear Regulatory Commission.

ACTION: Proposed policy statement.

SUMMARY

This proposed policy statement describes the policy the Commission intends to use to promote voluntary licensee integrated schedules for-implementing regulatory requirement and other improvements in nuclear power plants. Its primary focus concerns the ways licensees may establish integrated schedules to develop realistic schedules and the ways the Commission intendslo interact with these licensees.

It also documents the Commission's support for the establishment of integrated schedules at each nuclear power pla!ll. Integrated schedules for plant modifications (1) will permit the NRC, the nuclear industry, and the public to forecast and maintain longer-term schedules and (2) will permit more effective use of licensee resources to implement these plant changes and NRC

-resources to review them.

DATE: The.comment period expires on January 25, 1988. Comments received after that date will be considered if-i.t is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date.

Federal Reguit_e~....

Vol. 52, -Na. m U,

Friday, November 27, 1987.

ADDRESSES: 'Submit, conitilents, '

suggestions, er recomittendatiens to the Secretary of.the-:Obmmlfein!l\\ tJ.S, Nuclear Regulator¥.otnrri'is&ioni Wa11hington; De.-~55,"Attention:

Docketing and~ice:Braoch:

• Commentsmraµlto be:delivered ;to RoOJJ1 nz1..~stree:t,1NW-,

Washington,'DQrbetween 7:30 a.m.-and 4:15 p.m CS'.qp~~P'4 ~ived may be~"~~~

~blic Document Room; 1717 H Street NW.,

Washington, OC.

/

.,.., q '?, ;7r

4)

'1'

)'C FOR FURTHER INFORMATION CONTACT:

. Suzanne C. Black, 'Section'Oli~f.

Technical Policy an8 Suppart.~ion, Policy Development and 11eduaical

. Support Branch, Office of Nadear 1 Reactor Regulation, u~S.,,Nudltar Regulatory Co.lDllllssion, Washington, DC 20555, Telephone: 301-49~7628.

SUPPLEMENTARYINFORMAflON:

Background

On May 3, 1983. the Commission issued the first integrated ada,edille plan, which was incor:porated as a cpnilition of the Duane Arnold Energy Ceqter *

(DAEC) operating license. On Ma_y 9, 1983, the Commission issued ~neric Letter (GL}83-20, which informed the industry of the DAEC amendment and invited other utilities to participate in similar programs on a volwitary basis.

The NRC issued similar amendments to the Pilgrim Nuclear Power Station operating license on July 13, l~d to the Big Rock Point Nuclear ro~ant operating license on February"'12, 1988.

On July 9, 1985, DAEC was granted a 2-year extension for its plan. The experience thus far with the DAEC and Pilgrim plans has demonst-rated that integrated schedules can help optimize the use of both NRC and licensee resources with regard to scheduling modifications, while maintaining plant safety, reliability, and availability.

On May 2, 1985, the NRC issued GL 85--07 to describe the NRC staffs intentions regarding integrated schedules and to solicit widespread industry participation in the development of appr:opriate procedures to establish and maintain integrated schedules. As pert of GL 85--07, a survey was taken to determine industry interest. Of the 41 responses received, 21 licensees repreunting 50 reactors indicated an interest in integrated schedules that involved staff review or

a

• r

. Ne / yo1_. 52, No. 228 / Friday, November 27, 1981 / Propoeed Rules 45MS apJllO\\tal~ll,e Pf9Rl!MII. An edllit1ena1 27.. licemeee re.presenting 42 p1aat8 indicated_.~ were 1M>t.Hltalated ~

submitting such a progra...Z.., lt.aff review. <m1y u ~atms seven plants indicated JMt tAitV.md,not employ or Intend to emptoy an Integrated scheduling-precess. Th1is, with these Generic Letters, 83-20 and 85--07, the NRC has sought inc:reued industry participation-In this concept.

but has only minimal success.

On October 25, 1985, the.NRC aufi participated In an Industry seminar to obtain a better underst&Dding of the industry's perspective on Integrated schedules. One of the main concerns voiced b) iadwtr; ~epm8m1atnes was the lack of suidance nom tae Commission regarding the preparation and implementation of Integrated schedules. Many 1iceneees Wffe apprehensive about participating in ll voluntary program witbaat dear cnleria or standards for evaluatiqg Integrated schedules.

Consequently, the NRC has developed this policy statement to

• Reiterate the Commission'*

interest and support tor a voluntary Integrated scheduling p,ecea at.di nucleal' power-plat.

• Descrme lbe buic ~

I.er the implemeniatioll of iutecre.W schedules,

• Initiate a~

wita iBdHeby

• develop baaicmtaria amlpmoeduiea -

for the evaluaticm of aa iueer.ated schedloll.iq~aa. aarl

• ~

the NRC'a role.ia the Integrated scheduwagFQOeSL Proposed Commission Polk::,

The Cuttnnission believes 1he

• imple.tation of integrated scbedul_es on a pfint-wpeclfl~sia wou1d provide a systematic mean~ of coordimlttng, managing and sc.hednffng major modificati9n8 lnitlri,d-byi>oGi MIC end its licensees. An integra'9cf.aedaiin8 process could enhance timely co111pli 11ce with requirements and at the saaut e

accommodate,ucanaee-mf

• moditicaflona. A mafor'ben d'f:'an integrated schedule plan is* 4" flexibility in Integrating implementation schedules as new projects arise. In addition, the capability O~...,P~ovidlng ~

consment~am fMfoereca-sftug and.

scheduling future plaat modificetiooa may impre.Ye-pnblic c,:inidence ia the

- industry's attention.to plant safety.

For*the purpose of this Policy Statement. three.cateaorum afpbmts are

• \\ r:n~z~ "ti~~JR-'""d ~~

llcensP~

2. Plants with an intesrated echeduling plan submitted to the NRC, but withoat a license amendment; and

3. Plants without a eubmitted, Integrated scheduling plan.

Because of the positive experience with the inttJ8mt2d ICh~-programa of both the Duane Arnold En&gy Center and the Pilgrim Nuclear Power-Station, the Commission betie..es that a license amendment may be an effective means of implementing these achedwes.

However, the Commission believea that an Integrated scheduling plan. 811bmit-ted for staff review although oot u a license amendment, provides some canaistent basis for negotiation of schedulea.

Licensees may refer to auch a plan to support both proposed implementation schedules for new regulatory requirements and also chanses to existing implenrentafion s-ctredules.

Because such scheduies lade the formality of a license condition, any changes would be resolved on a case-by-case basis.

The regulatory Intent of theliceme amendmentis to provide aaaurance tliat NRC-requinid actMlies are scheduled and completed oonaiflellt widt.the optimum use af1icenaee ~.

When circumstances 'waTa1lt. dte Commission can impoae.aew deadlines with the understanriini@ that they ceialci affect the completion dates of other regwat,ary r,equiMmcDb c other licensee projects already schedaded.

Howe.er., no -=hedale exemptiall for the implementaticn ef new NllC requirements woaJd. be required for those pJaabi with a licenae amendment.

Otm cbangea :in Urie schedule 0fJllld be made by licensees far good caue and with prim netification to the NRC. The existing-ime3rated 111:bedating licenae amendmelat. ~

tin! ti~ the -

flexibility to change sclaedules, as needed, by delays beyond the licensee'a control or by the imposition of new regmtary ieqmrements.

from variom NRC ~

1'egarding the appropriatenem, of specific implementation schedules. F"mal resolution of any conflicts with licensees will be determined by the Director of Nuclear Reactor Regulation and senior utility management; The major elements of an integrated scheduling pro~s may include:

1. A systematic process fm identifying and defining those activities to be schedulett.

2. A. process for prioritizing and scheduling the individual actions, taking into account factors such as safety, plant availability, radiation expOBUl'e, procurement requirements, and costs;

3. A plan for maintaining and updating implementation schedules;

4. A provision for NRC review of the prioritization and scheduling procen and approval of the plan and initial schedure; -and

5. A procesll for evaluating a licensee's maintenance of schedules thnmgh the iawmmce of pmodic repom on acfu>ns completed. schedules for'Dew actions, and '9'Cheduh! changes as a result ofirew-actions and/or implementation problems.

As a minimmn. flle inregrated schedule shonld include an NRC-ini tia ted plantmodificatiOIB, whether mandated (as in a rure, regulation. or orderjor committed to by the lit:enaee (originating in a generic letter or bulletin, fur example). 'The extent to which a licensee wishes to include additional items not diret:fly associated with plant modifications initiated by the NRC, such as regional. in~on fofh:m-up items or engineering analysis activities, is a matter of the licen~*s discretion end overall program goals.

Licensee-initiated plant cmmges would only appear on the schedule as necessary to permit an overall understanding as to how they are being integrated with the NRC initiatives. For example, for a Ucemee-initiated modification that can be instaHed independently of ongoing NRC work, required activities would not be expected nor need to appeu OB the The Reactor Projec-Hr-eage111 will have the.ew.rali-reapoalibitityior evaluating and 1lpprqffll8 the integrated schedu-.i.Jlaeme ameadmeata and for reviewinljM8D'" evbentil!d to the NRC without a liceme ~

Tee Project~ muat have an understa~ of the adledlWll8 t'-

integrated schedule at all. Furthermere,

. processes and IMAll8 and.an ownlew of ongoing activities at the plant to ensure that t~censees are establishing reaiistic and timely impiementatiml echedureL In addition, Project Manasers will lleYiew the prioritization criteria, scbedalea. and scope in vww of Nae~ far generic issues and multiulant actione.

licensee p,riarmes, and op~t-specific action items. WJ.en nac:eu,ary.

the Project~ wilt.eeic advice if the licensee found it necessary to revise a schedule for one of its plant betterment modifications and the schedule could be revised without impacting the completion date for.NRC-required activities, prior notification with written follow-up notification would be unnecessary, even though the item appeared on the integrated schedule.

A fundamental premise of the integrated scheduling proceas is tnat plant modificatiolla can and should be

45346 prioritized. This principle can also apply to design engineering and analysis efforts that require substantial resources for an extended period of time. The prioritization of these activities can provide a consistent and defensible basis for the initial implementation schedule and for negotiating future changes or additions. As the prioritization methodology will be based on a number of factors, many of which will be plant specific, the Commission has concluded that the selection of the prioritization methodology should be decided by the licensee. However, because of the importance of the prioritization methodology in the integrated scheduling process, it is essential that the NRC staff clearly understand the.methodology.

Although the integrated scheduling process will be established by the licensee, it will be incumbent on the licensee to provide a comprehensive description of the process to the NRC.

Because of the financial aspects of many of the specific scheduling activities (e.g.,

planning, estimating, procuring, funding, and personnel constraints), it would be inappropriate for the Commission to become involved in the licensee's financial planning or to establish acceptability criteria for scheduling these aclivities. However, the Commission must understand the planning and scheduling practices associated with any integrated schedule plan. *.

To asJist licensees in their efforts to developjintegrated schedules for plant modifications, draft guidelines are provided here for consideration but are A

not presumed to be all inclusive. NRC W staff will continue to work with the licensees to clarify the guidelines, including the appropriate inspection and enforcement policies. When clarification has progressed to a sufficient point, the Commission will publish them to further encourage the development and application of integrated scheduling plans.

Draft Suggested Elements of a Plan for the Integrated Scheduling of Plant Modifications I. Introduction A. Purpose of Program

1. To effect management of plant modifications required or proposed by NRC and identified by the licensee B. Goals

1. To conform to regulatory requirements

2. To provide lead time for *modifications

3. To effectively manage financial and human resources C. Elements of-Program 1.Scheduling

2. Addition of new items

3. Interface with NRC

4. Evaluation D. Duration of Program (years)

II. Program Basis A. Prioritization Criteria

1. Safety significance

2. Budget projections

3. Site manpower

4. Engineering support

5. Management resources

6. Plant availability

7. Procurement. requirements

8. Radiation exposure

9. Costs

10. Others B. List of Prioritized Work Items.

C. Interface with NRC

1. Review

2. Approval Ill. Scheduling A. Selection of Scheduling Techniques

1. To integrate NRC-required modifications with utility's requirements.for plant Qlodifications, maintenance, refueling, operations

2. To identify *critical paths

3. To consider interrelationships among projects

4. To consider constraints imposed by engineering support and site manpower limitations

5. To accommodate unforeseen delays (e.g., procurement, strikes, fuel cycle schedule changes)

6. To provide for coordination of plant modifications with revisions to plant operating procedures and operator retraining B. Categories of Tasks

1. Items mandated by NRC rules, orders, license conditions

2. Regulatory items identified by NRC, resulting in plant modifications, procedure revisions, or changes in staffing requirements or tasks

'

• mandated by other agencies or prospective NRC requirements

3. Licensee-identified changes for operational improvement C. Procedures for Modifying Schedules

1. Add new NRC requirements

2. Account for delays (e.g., procurement)

3. Change scope

4. Include NRC inspection followup items

5. Assess impact on completion of scheduled items

6. Licensee-identified changes for operational improvement D. Updating/ Assessment of Sch'edlll~

1. Frequency

2. Identification of completed and delayed items

3. Evaluation of sche~uling process

4. Evaluation of causes for delay E. Interface with NRC

1. Review

2. Approval IV. Addition of New Items A. Assess Priority

1. Prioritiz

" 0 tia.

2. Relatie.

rps already ptjorl B. Avoid Rescheduling of-Other-Items -

• C. Alter Schedule of Least Significant Items D. Maintain Optimum Integrated Program E. Interface with NRC V. Evaluation of Integrated Schedule Program A. Frequency B. Success j.n"Meeting Goals C. Interface with NRC The Commission specifically requests public comments on the value of integrated schedules as a plannirig*tool for utilities; the advantages and disadvantages of a negotiated commitment on scheduling of the implementation of regulatory requirements; the valu*e of having the schedule become a license amendment;*

and additional options for

_ implementation of integrated sc;h~d9Je.s:

Dated at Washington, DC, this 20th day of, November, 1987.

For the Nuclear Regulatqiw omm1saion.

Samuel J. Ch1lk, Secretary of the Commission.

[FR Doc. 87-27211 *Filed 11-25-67;'8:45 am)

IIIWNG CODE 7111CM11-M FEDERAL HOME LOAN BANK BOARD 12 CFR Part 505

[No. 87-11881 Avallablllty and Character of Records.

Date: November 19, 1987.

AGENCY: Federal Home Loan Bank Board.

ACTION: ~POii~ rule.

SUMMARY

The Federal Home Loan Bank

("Board") pryposes to amend its public access to information regulations on fees and fee waivers in order to comply