View source for B12860, Application for Amend to License DPR-61,adding License Condition Requiring Util to Implement & Maintain Integrated Implementation Schedule Program Plan

{{Adams
| number = ML20148Q236
| issue date = 03/31/1988
| title = Application for Amend to License DPR-61,adding License Condition Requiring Util to Implement & Maintain Integrated Implementation Schedule Program Plan
| author name = Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B12860, NUDOCS 8804120364
| package number = ML20148Q241
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 8
| project = 
| stage = Request
}}

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CONNECTICUT YANKEE ATOMIC POWER COMPANY B E R L I N, CONNECTICUT P O BOX 170
* HARTFORD. CONNECTICtJT 061.14270 March 31, 1988 TELEPHONE
                  -5*                                              Docket No. 50-213 B12860 Re:  Integrated Safety Assessment Program U.S. Nuclear Regulatory Comnission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Haddam Neck P14 Integrated Implementation R hedule License Amendment Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPC0) hereby requests an anendment to Facility Operating License DPR-61 for the Haddam Neck Plant. The proposed amendment would add a license condition requiring CYAPC0 to implement and maintain its Integrated Implementation Schedule (IIS) Program Plan (the Program Plan). The Program Plan provides a methodology to be followed for seneduling plant modifications and engineering evaluations.      This license amendmant application does not involve a significant hazards consideration.
RISCUSSION In a {{letter dated|date=November 13, 1987|text=letter dated November 13,1987}},(I) CYAPC0 submitted its initial IIS for the Haddam Neck Plant. This initial IIS was a direct result of CYAPC0's Integrated December 12,Safety 1986. g'pessment The initialProgram    (ISAP)completion IIS included      described indates a letter fordated all currently planned plant modi fications, plant-improvement projects, and engineering evaluations of well-defined scope.              These activities generally address the Haddam Neck Plant ISAP topics and were scheduled based in part on their relative ISAP rankings.
CYAPC0 now plans to formalize its methodology for developing ad updating the Haddam Neck Plant IIS.        As discussed in the Novemtser 13, 1987 letter, CYAPC0 (1)    E.J. Mre:zka letter    t*., U.S. Nuclear Regulatory Commission, "Integrated Safety Assessment. Program," dated November 13, 1987.
(2)    J.F. Opeka letter to C.I. Grimes, "Integrat 1 Safety Assessment Program -
Final Report for the Haddam Neck Plant," dated December 12, 1986.
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1 U.S. Nuclear Regulatory Commission B12860/Page 2 March 31, 1988 1s hereby proposing a license condition to be added to the Haddam Neck Plant operating license, requiring that the IIS be developed and maintained consis-tent with an NRC-approved IIS Program Plan. The proposed license condition is providad in Attachment I.
CYAPC0's approach is different in concept from "integrated living schedules" at sote other nuclear power plants. Under CYAPCO's approach, the Program "lan is being submitted for NRC review and approval. However, the specific implementation schedules for each topic will not be fixed by license amend-ment. CiAPC0 believes that its approach is less cumbersome than alternate approaches, allowing the licensee sufficient          flexibility in scheduling projects and in updating the schedule as necessary. The Prograni Plan in turn provides a consistent methodology and provides for NRC oversight in order to assure the integrity of the IIS process.       The Program Plan is provided in Attachment II.
Essentially, under the Program Plan, ISAP serves as CYAPC0's prioritization methodology for developing the IIS. However, the Program Plan inherently recognizes that the ISAP methodology is evolving and will be refined for future revisions of the IIS. Further, in addition to the ISAP rankings, other considerations such as resource availability, outage duration, and ALARA goals must be factored into the IIS development process on a principled basis. The Program Plan provides the framework for this analysis.
The Program Plan also specifically provides for NRC oversight of the IIS. The Program Plan describes the responsibilities of CYAPC0 with respect to submit-ting the IIS to the NRC; describes the mechanisms for updating the IIS and reporting to the NRC; and describes the mechanism for changin; the Program Plan itself.
The IIS will incorporate: 1) activities mandated by NRC rules, orders, and lica.,c conditions; 2) regulatory items identified by the NRC, resulting in plant modifications, procedure revisions, or changis in staffing requirements;
: 3) prospective NRC requirements, or tasks mandated by other agencies; and 4) licensee-identified changes for operational improvement. The IIS may also incorporate other ongoing CYAPC0 proiects inat require significant resource commitments.                                                                    l l
Generally, under the Program Plan, if an implementation date for an activity    l is fixed by NRC regulation or order, CYAPC0 will meet that date or seek an      I appropriate exemption to the regulation or modification to the order to support a later date in the IIS. Otherwise, all implementation dates will be set by the ISAP/IIS methodology described in the Program Plan. Provisions in the Program Plan address changes to the schedule to accommodate newly identified activities, unforeseen circumstances, or new NRC requirements.
In summary, CYAPC0 believes this scheduling process provides a coherent and consistent basis for enhancing nuclear power plant safety and operation. As 1
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e U.S. Nuclear Regulatory Commission B12860/Page 3 March 31, 1988 has been the case with ISAP, the IIS process is, by necessity, an interactive one between CYAPC0 and the NRC Staff.                                             )
SIGNIFICANT HALARDS CONSIDERATION The proposed license amendment to add the IIS license condition to the Haddam Neck Plant operating license does not involve a significant hazards consid-eration. The proposed license amendment adds a license condition to the Haddam Neck Plant operating license to require implementation of the IIS Program Pl an. The purpose of the Program Plan is to describe CYAPC0's methodology to develop a plant-specific improvement schedule for the Haddam       j Neck Plant based in part on the prioritization methodology of ISAP.               ;
The IIS resulting from the prxess described in the Program Plan, and required     '
by the proposed license condition, will be CYAPC0's controlling schedule for      '
implementing all modifications and engineering evaluations of a well-defined scope fcr the Haddam Neck Plant. This includes activities identified to address NRC regulatory issues as well as activities identified by CYAPC0 to enhance safe, reliable, and economic operation of the plant. The IIS process described in the Program Plan is intended to assure that in scheduling imple-mentation of these projects and studies, available (and finite) resources are devoted to the extent practicable in a prioritized and cost-effective manner.
The Program Plan specifically describes the ISAP prioritization methodology, the mechanism for addressing other "real-world" scheduling constraints, the g     mechanism for updating the IIS to reflect new issues and new circumstances, CYAPC0's periodic reporting requirements, NRC oversight, and the mechanism for updating the Program Plan itself.
Although the proposed license amendment will not incorporate specific imple-mentation dates for each topic, CYAPC0's IIS Program Plan will assure a consistent ..;d principled scheduling process with appropriate NRC oversight.
In summary, through ISAP and the IIS, CYAPC0 intends to optimize allocation of resources available for enhancing nuclear power plant safety and operation.
In 10CFR50.92(c), the NRC has provided standtrds for determining whether a
              ;ignificant hazards consideration is involved in a licence amendaent applica-tion. By applying these standards, CYAPC0 concludes that this amendment l
does not involve a significant hazards consideration.
: 1. Operation of the fac;! tty in accordance with this proposed change will not involve a signif tunt increase in the prooability or consequences of any accident previously evaluated.
The proposed change would require the implementation of the IIS methodol-ogy described in the Program Plan. As such, it cequires that CYAPC0 establish an administrative means for tracking, prioritizing, and schea-uling NRC-required plant modifications and engineering evaluations, and licensee-identified plant improvement 7 m ets.        This methodology is

U.S. Nuclear Regulatory Commission B12860/Page 4 March 31, 1988 intended to enhance plant safety by more effectively controlling the number and scheduling of plant modifications, thereby assuring that issues required for safe operation of the plant receive priority and are completed in a timely manner.
Because the license condition addresses only an administrative scheduling mechanism, it does not affect directly the design or operation of the plant. Therefore, no accident analyses are affected and the proposed change does not increase the probability or consequences of any previous-ly evaluated accident.
: 2. Operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
As discussed above, the proposed license condition establishes a new requirement relating to scheduling of modifications and engineering        ,
evaluations. Therefore, the proposed change does not create         the possibility of a new or different kind of accident from any previously evaluated.
: 3. Operation of the facility in accordance with this proposed change will not involve a significant reduction in any margin of safety.
As discussed above, the proposed license condition establishes a nu administrative requirement intended to enhance public safety and reliable plant operation. It does not affect any accident analysis or involve any modification to the plant configuration or operation.      Therefore, the proposed change does not involve a reduction in any margin of safety.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6,1986). The proposed amendment most closely resembles example (ii), a change that consti-tutes an additional limitation, restriction, or control not presently included in the technical specifications (e.g., a more stringent surveillance require-ment), in that the proposed license amendment would require the implementation of the IIS Program Plan (not currently reauired) for the scheduling of plant modifications and well-defined engineering evaluations.
In accordence with 10CFR50.91(b)(1), a copy of this amendment request is being i
forwarded to the State of Connecticut.
Although this license amendment is not required for continued plant operation, CYAPC0 recognizes the benefits of this program and therefore requests that the Staff act on this application in a timely manner.
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U.S. Nuclear Regulatory Commission B12860/Page 5 March 31, 1988 Pursuant to the requirements of 10CFR170.12(c), enclosed with this license amendment request is the application fee of $150.
Very truly yours, CONNECTICUT YANKEE ATOMIC P0hER COMPANY tW W E.      roczka #
Se      Vice President cc:   W. T. Russell, Region 1 Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shediosky, Resident Inspector, Haddam Neck Plant Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT)
                                   ) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Connecticut Yankee Atomic Power 3            Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the :
best of his knowledge and belief.                                             l t4d(h'?5,            ??!s'd sNotary Pub)ic                      j yyCommM1E hsf.'
9 arch 31,1993 l
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Docket No. 50 E B12860 Attachment I Haddam Neck Plant Proposed License Condition Farch 1988

IIS License Condition 1
(8) Intearated Imolementation Schedule i
: a. The Connecticut Yankte Atomic Power Company shall implement and maintain in effect the Integrated Implementation Schedule Program Plan (the Program Plan) to be followed for scheduling of plant     !
modifications and engineering evaluations. The Program Plan shall be followed from and after the effective date of this        '
license condition.
: b. This license condition shall be effective until           (date of approval of amendment by NRC plus three years), subject to renew-al upon application by the licensee.
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Docket No. 50-213 EllBf2 Attachment II Haddam Neck Plant Integrated implementation Schedule Program Plan March 1988}}