View source for NUREG-1201, Forwards Proposed Commission Policy Statement on Integrated Scheduling of Plant Mods,Proposed Commission Paper & Supporting Info,For CRGR Consideration

{{Adams
| number = ML20246E303
| issue date = 03/11/1987
| title = Forwards Proposed Commission Policy Statement on Integrated Scheduling of Plant Mods,Proposed Commission Paper & Supporting Info,For CRGR Consideration
| author name = Denton H
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name = Sniezek J
| addressee affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
| docket = 
| license number = 
| contact person = 
| case reference number = RTR-NUREG-1201
| document report number = GL-83-20, GL-85-07, GL-85-7, NUDOCS 8905110219
| package number = ML20149C371
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 14
}}

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11 MAR 19o7 MEMORANDUM FOR:             James H. Sniezek Deputy Executive Director for Regional Operations and Generic Requirements FROM:                      Harold R. Denton, Director Office of Nuclear Reactor Regulation

==SUBJECT:==
CRGR REVIEW 0F PROPOSED POLICY STATEMENT ON INTEGRATED SCHEDULES The staff has prepared a proposed Commission Policy Statement on Integrated Scheduling of Plant Modifications. This Policy Statement, the proposed Commission Paper, and appropriate supporting information, are attached. These                                          4 documents are hereby submitted for consideration by the CRGR. The Offices of                                           i Inspection and Enforcement and Nuclear Material Safety and. Safeguards have
                   .provided their concurrence in the proposed Policy Statement. The Office of General Counsel has indicated it h6s no legal objection to the proposed Policy Statement.
The proposed Policy Statement is in response to the Commission's Policy and Planning Guidance and is part of the staff action plan, documented in SECY-86-226, for implementation of recommendations by the independent ad hoc group for the Davis-Besse incident (NUREG-1201).
The proposed Policy Statement on Integrated Schedules does not impose any new requirements or require any response from licensees. However, the Policy State-ment, which is proposed to be published for public comment, does set forth a number of new staff positions on the subject of integrated scheduling for comple-tion of plant modifications. First, it would describe the basic approach for the development and application of integrated schedules and note that the NRC plans to view plants in three categories:
: 1) plants with no staff-reviewed integrated schedule process,
: 2) plants with a staff-reviewed integrated schedule process with a license condition, and
: 3) plants with a staff-reviewed integrated schedule process without a licensee condition.
Further, the Policy Statement describes the NRC's role for each of these categories.
The Policy Statement would also. serve to provide Commission endorsement of this concept and note that the experience to date has demonstrated that integrated schedules can help optimize both NRC and licensee resources with regard to scheduling plant modifications. The Policy Statement also points out that while .
the staff believes that integrated scheduling is a useful management tool for scheduling of completion dates for planned plant modifications, a utility's decision as to whether or not to participate is strictly on a voluntary basis.
8905110219 870507                           ,
PDR        REVGP NRCCRGR MEETING 112              PDC

i                 ,
James H. Sniezek                                                 After consideration of comments received and a favorable recommenostion by CRGR, staff proposes to transmit the enclosed Comniission Paper for the Commission's consideration.
For further information on this subject, please contact Ken Eccle.ston, Technical and Operations Support Branch (x29518).
                                                                           /
                                                                          </:il' Harold R. Denton, Dir tor Office of Nuclear Reactor Regulation Attachments: 'As stated

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Jamss H. Sniezek                                                         After cor. sideration of comments received and.a favorable recommendation by-CRGR, staff proposes to transmit the enclosed Commission Paper for NRC consideration.
                     -For further information on this subject, please contact Ken Eccleston,
                      -Technical and Operations Support Branch (x29518).
L Harold R. Denton, Director' Office.of Nuclear Reactor Regulation Attachments: As statea DISTRIBUTION:
                     -Central Files TOSB R/F HDenton RVollmer
                      -JFunches JLyons KEccleston CRGR REVIEW OF PROPOSED POLICY
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j  ,                                  James H. Sniezek                                                                                                 -2 1                                                                                                           .
After consideration of comments received' and a favorable recommenda' tion by                                                                                                                                                     ,
CRGR, staff proposes to transmit the enclosed Commission Paper for the Commission's consideration.
For further information on this subject, please contact Ken Eccleston,
                               - Technical and Operations Support Branch (x29518).
Original Signed By:
Richard H. Vollmer Harold R. Denton, Director Office of. Nuclear Reactor Regulation Attachments: As stated DISTRIBUTION:
Central files TOSB R/F HDenton RVollmer JFunches JLyons KEccleston CRGR REVIEW 0F PROPOSED POLICY
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DATE :2/ 3 /87                                  :2/ 3 /87                   :b 3 /87                                          :)/ h /87                                                   :3/5\ /87                     : 3/ 3 /87            -
0FFICIAL RECORD COPY                                                             _ .-_- _ - - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

i      .
Information Provided for CRGR Review Folicy Statement on Intearated Schedules, The following information is provided in accordance with Section IV'. B of
 ,          Revision 3 to the CRGR charter (September 1986). The numbers in parentheses correspond to the numbers in Section IV. B of the charter (i) and (ii) Attachment 1 and its Enclosures 1, 2, and 3 provide appropriate material. Attachment 1 provides the proposed Commission Paper on this subject.
Enclosures 1.and 2 to this attachment provide appropriate background information in the form of generic letters issued by the staff. Enclosure 3 of Attachment 1 provides the staff's proposed Policy Statement on Integration Schedules.
(iii) Inasmuch as integrated scheduling is offered on a completely voluntary basis the proposeo Policy Statement does not increase requirements. However, those licensees which request and receive a license condition requiring the utility to follow its integrated scheduling plan would of course be required to abide by this license condition.         Similarly, licensees which have submitted an integrated scheduling plan for staff review and have committed to following this plan would be expected to do so.
Although the utility decision as to whether or not to participate in this progran is a voluntary one, the proposed Policy Statement does set forth a number of new staff positions. First, the proposal to view plants in three categories is a r.ew staff position; these three categories were selected as one convenient way of grouping plants. This grouping was selected because it delineates the degree of staff involvement in the review of licensee proposals on integrated scheduling.
The basic approach for the development and application of integrated schedules outlined in the proposed Policy Statement represents a new staff position. In essence the approach to be followed by a utility utilizing integrated schedules requires a comprehensive, integrated basis for assigning appropriate priority to necessary ongoing site activities.
Finally, the NRC role in the integrated scheduling process also represents a new staff position. This role, which depends upon the utility's choice of options, is more completely described in item (vii) b) below.
(iv) The Policy Statement proposes that plants be viewed in three categories, viz., plants with integrated schedule license amendments, plants with staff-reviewed integrated schedule plans without license amendment, and plants without any staff-reviewed integrated scheduling plans. The proposed methoc of scheduling plant modifications would vary according to the option selected by the licensee. Those facilities electing to adopt a formal license condition would of course be expected to abide by this license condition; utilities otherwise committing to follow a staff-reviewed plan would also be expected to take those actions committed to unless these commitments are subsequently modified.
OGC has reviewed the proposed Commission Paper (and its enclosures) and has                                                                             ,
no legal objection to it.
1
* i 1
I (v) The proposed Policy Statement provides that the utility's decision as to whether or not to adopt integrated scheduling is strictly on a voluntary basis.
For those utilities which do not at present use an integrated scheduling process for planning site activities, an initial cost would be required to establish such a program. This cost to the utility would, in the staff's judgment, be more than offset by intermediate and long term cost savings to                                                                                   I the utilities. In fact, in response to Generic Letter 85-07 (Enclosure 2 to                                                                              j Attachment 1), only six licensees (representing 7 units) indicated that they did not at present employ, or intend to employ, an integrated scheduling process. Thus in most cases, utilities see a need for integrated scheduling in assistina them to map out the most suitable agenda for performing required                                                                                ,
(or desired) work based on manpower, schedule, and budgetary limitations while                                                                               !
considering project safety benefits.
As a result of this organized look at the totality of ongoing site work                                                                                      !
activities, potential conflicts in refueling, maintenance and modification activities may be identified and addressed before work actually begins. This may result in significant cost savings to the utility as a result of either improved work efficiency or reduced unit unavailability.
From the staff's point of view, agency resources may be saved as a result of more timely allocation of these resources. A better understanding of the status of completion of necessary safety n, modifications should also result.
Finally, the staff has discussed the concept of a Policy Statement on Integrated Schedules with the Industry Group on Integrated Schedules, and then with an Atomic Industrial Forum (AIF) Subcommittee on Integrated Scheoules.
The AIF subconcittee has provided its views on the matter in a November 5,1986 memorandum (Attachment 2).
(vi) This Policy Statement applies to all licensed power reactors.
(vii) For licensed power reactors, the following information is provided with respect to the proposed Policy Statement, a)    The specific objective that the proposed action is designed to achieve is to establish guidelines to utility management involved in the decision-making process and to encourage utilities to adopt integrated schedules by providing NRC endorsement of the overali process. Additional objectives of the proposed actions are stated on page 2 of the Policy . Statement.
b)    No action is required by the licensee, unless the licensee elects to request either a license condition on this subject or staff review of its plans and activities in the area of integrated schedul-ing.
In either of these two cases the licensee would be expected to subtrit l                        the necessary request for staff review of its scheduling methodology and prioritization scheme, a detailed implementation plan, the necessary documentation to support and provide a sound basis for its proposed act'eities in this area and, if appropriate, a license amendment application.
_ __ _ __-_ --_________ -________ _____ - ____ -                                                         ~

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L                                                                                              c)    No potential change in the risk to the public is foreseen.
d) .No potential impact on radiological exposure of facility employees
;                                   and other onsite workers is foreseen.
l-L                             e)   .No cost.of facility downtime or construction delay is. involved.
Any potential incremental short term costs would likely be offset t                                  'by intermediate and long term savings.
f)    ho changes in plant or operational complexity are involved.
g)    In the short term, a small resource burden (0.25 man-amendment, 0.125 man-year / plan w/o license amendment)   would be year /1icense involved. In the. intermediate and long term, staff' effort.to follow ongoing site activities would likely be reduced on a continuing basis.
h)    Differences in facility type, desigr. or age are not relevant to the proposed action.
: 1)    The proposed action would be to' publish the proposed NRC Policy Statement'on Integrated schedules for public comment.
(viii) No evaluation pursuant to 10 CFR 50.109 is'recuired or applicable.
(ix) This item is not applicable since no current requirements or staff positions are being relaxed or decreased.
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L                                                                                                                                                                                                                     1 FOR:               'The Commissioners FROM:               : Victor Stello, Jr.
Executive Director 'or f Operations

==SUBJECT:==
INTEGRATED SCHEDULES POLICY STATEMEhT PURPOSE:            To obtain C' ommission approval of a notice of policy.
CATEGORY:           This paper; covers a policy on regulation of nuclear power reactors.
                         ' ISSUE:               Statement of proposed NRC policy on integrated schedules'for implementation of plant modifications.
: BACKGROUi4D: On.May'3,1983 the Commission issued Amendment 11o. 91 to 'the Duane Arnold Energy Center (DAEC) operating license.
This. amendment approved the licensee's (Iowa Electric Light and Power Company - IELP) " Plan for the Integrated Scheduling' of Plant Modifications at the Duane Arnold Energy Center" (Plan) and required IELP to' follow the Plan.
This action represented the first step towards implementation of.
integrated schedules for completion of plant modifications on an.
industry-wide basis. On May 9,1983 the Commission issued Generic Letter (GL) 83-20 (Enclosure 1) informing the industry of the DAEC amendment and' inviting other utilities to participate.in similar programs.
CONTACT:
K. Eccleston, TOSB                                                                                                                                                                ,        ;
492-9518                                                                                                                                                                                   !
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Amenaments similar to DAEC's were issued on July 13, 1964, for Boston Edison Company's Pilgrim Nuclear Power Station and on Februa ry 12, 1986 for Consumer Power's Big Rock Point facility.
On July 9, 1985, in response to its application for renewal, IELP was granted a two-year extension for its plan.
DISCUSSION:   The experience thus far with the DAEC and Pilgrim piens has demonstrated that integrated schedules can help optimize both NRC and licensee resources with regard to scheduling and implementa-tion of plant modifications, while maintaining plant safety, reliability and availability.
In its Policy and Planning Guidance for the last several years the Commission has indicated its desire that integrated imple-mentation schedules for new and existing requirements should be established for each power reactor licensee.
This proposed Policy Statement provides the mechanism by which this goal can be attained.
On May 2, 1985, the NRC issued GL 85-07 (Enclosure 2) to describe the staff's intentions regarding integrated schedules ano to solicit widespread industry participation in developing appro-priate procedures to establish and maintain integrated schedules.
As part of GL 85-07, a survey was taken to determine-industry        ;
interest. Of the 48 responses received, 21 licensees (representing 50 reactors) indicated an interest in integrated schedules which involved staff review or approval of the program.
An additional 27 licensees (representing 42 plants) indicated they were not interested in submitting such a program for staff review. At the same time, only six licensees (representing 7 plants) indicated that they did not at present employ or intend to employ an integrated scheduling process.
On October 25, 1985, staff participated in an industry seminar to obtain a better understanding of the industry-perspective regarding integrated schedules. One of the main concerns voiced      ,
by the industry representatives was the lack of guidance from the Commission regarding the preparation and implementation of-integrated schedules. Many licensees were apprehensive about participating in a voluntary program without clear criteria or standards by which such scheduling processes would be judged.
In addition, some licensees were concerned that implementation of such a program for their facilities would either involve NRC in
                                 'their internal decision-making processes or preclude management decision-making in the utility's development of integrated schedules.                                                         .
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Consequently, the NRC has developed this policy statem'nt                                         e to:
i Reiterate the Commission's interest and support for a                                                                i voluntary integrated schedule process at each nuclear power plant.
Describe the basic approach for the development ano application of integrated schedules.
Initiate a dialogue with industry to develop basic criteria and procedures for the evaluation of an integrated schedule proces s.
Delineate the NRC's role in the integrated schedule process.
Note that integrated schedules are not developed or implemented in a manner which precludes the exercise of management decisionmaking.
In developing this Policy Statement it was considered that there are three broad categories into which industry interest may be grouped.
While most utilities either utilize, or plan to utilize, an integrated scheduling process for determining plant modification completion dates, some utilities are reluctant to have NRC involvement in the internal decision-making activities of their company. Further, some utilities believe that while staff review of their integrated schedules plan or process may be acceptable, they do not believe that incorporation of a license condition requiring the use of integrated scheduling is appropriate.
The staff has developed this Policy Statement to reiterate its support for the integrated scheduling process and to encourage licensees to adopt a formal integrated scheduling process, particularly one incorporated as a license condition.
The staff believes that a number of advantages exist for both the                                                        !
NRC and for licensees through utilization of the integrated scheduling process. Since this process requires the licensee (and hence, the NRC) to look at the totality of ongoing activities at the site, it should enable site activity to be performed in a L           more planned, organized, and controlled fashion. At the same
[           time, regulation of safety related activities may be enhanced due to the more detailed consideration of priorities in the licensee's conduct of ongoing site activities.                                                                                 '
                                                                                                                              ~
The scheduling process should provide a comprehensive, integratea basis for assigning appropriate priorities to necessary ongoing site activities giving due consideration to regulatory factors and~ utility resource constraints.
l l

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                           '                                                                                                                                       3 l                                                                                           .4 While-the staff believes that integrated' scheduling is,a useful management tool.for scheduling of completion dates for planned plant modifications; it has emphasized that the utility oecision as to whether or not to participt te in such a program is strictly-on a voluntary basis.
The staff believes that the most effective mechanism for implementation of an integrated schedule plan is through a license amendment which requires the licensee to follow its integrated scheduling plan. This plan would describe in general
                                                              . terms the licensee's program and -provide guidelines and require-ments for establishing or changing modification completion dates and for providing reports'to the NRC. Such a license condition facilitates the establishment of completion dates for regulatory requirements'en a plant specific basis through discussions with the 14RC Project Manager.
COORDINATION: OGC has reviewec this paper and has.no legal objections to it.
RECOMMENDATION: That the Commission approve publication of the proposed Federal Reaister notice'on the " Policy Statenent on Integrated Schedules for implementation of Plant Modifications" for a 60 day comment period (Enclosure 3).
Victor Stello, Jr.
Executive Director for Operations

==Enclosures:==
: 1.            Generic Letter 83-20
: 2.             Generic Letter 85-07
: 3.             Proposed Federal Reaister Notice
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3                                                                             Enclosure 1
                         'o.                        UNITED STATES
             !      y                    NUCLE AR REGULATORY COMMISSION
            ' $ j ^* 'i j '
                      ,-   8                     WASHINGTON, D. C. 20555 May 9,1983
              % .k. [
TO ALL OPERATING REACTOR LICENSEES AND HOLDERS OF CONSTRUCTION PERMITS Gentlemen:
t

==SUBJECT:==
INTEGRATED SCHEDULING FOR IMPLEMENTATION OF PLANT MODIFICATIONS
  !                             (GENERIC LETTER 83-20)
On May 3,1983 the Commission issued Amendment No. 91 (Enclosure 1) to the Duane Arnold Energy Center (DAEC) operating license. This amendment incorporates a license condition which approves Iowa Electric Light and Power Company's." Plan for the Integrated Scheduling of Plant Modifications for the Duane Arnold Energy Center."
The Nuclear Regulatory Commission's statement of policy and planning guidance for 1983 endorses the concept. of establishing implementation schedules for new and existing requirements which reflect the importance of the safety requirement to the public health and safety and the licensee's ability to complete the necessary engineering, evaluation and design.
Enclosure 1 represents the first step towards development of an industry -
wide program to establish r6alistic schedules for implementation of safety improvements, both utility-initiated and NRC-required, at operating reactors.
Enclosure 1 is provided for your information and possible use. Although this enclosure represents an approach which is acceptable at present to the NRC, other approaches may be acceptable and will be considered if                          .
you elect to adopt such a plan.
Please contact your Project Manager if you have any questions on this matter.
{incerely, A.
                                                                                   )
1 4( [<
                                                                      . Eisenhut. Director Division of Licensing Office of Nuclear Reactor Regulation

==Enclosure:==

As Stated                                                                                    ,
cc: w/ enclosure See Next Page tee 0000m l

            .. '                                                                                               J
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                  ,        [g.arcy   'c,                             UNITED STATES 1
{y y .       yj L                                        .
NUCLEAR REGULATORY COMMISSION                          j
                        ;            ~j                         ' WASHINGTON, D. C. 20555
:j
                        %.y    ...*
                                     /                         l'ay 3,1983 i
l u
Docket No. 50-331-i Mr. Lee Liu-President and Chief Executive Officer M
Iowa El'ectric Light and Power' Company P. O. Box 351 Cedar Rapids, Iowa 52406                                    -
        ~

==Dear ~Mr. Liu:==

The Corsnission has. issued the enclosed Amendment No. 91 to Facility Operating License.'No. . DPR-49 for the Duane Arnold Energy ~ Center -(DAEC).
This amendment. incorporates a license condition in response to your G                application dated November.12 ,1982, as revised in subsequent discus-siens between the-NRC- and your staff.
This license condition requires Iowa Electric Light and Power Company (IELP) to follow its " Plan for the Integrated Scheduling of Plant Modifications for_ the Duane Arnold Energy Center" (the. Plan) and the terms therein fer modifying the schedules.' The revised Plan has been discussed with your staff and is enclosed as Attachment 1 of. Enclosure 2 to this letter.
_ Iowa Electric's Integrated Scheduling Program has been the subject of extensive discussions between the NRC and your staff in an effort to define an acceptable approach for. implementation of this unique prograr to establish realistic schedules for modification of the Duane. Arnold fa cili ty.      Iowa Electric is to be commended for its initiative in developing such an integrated program for scheduling safety modifications at the DAEC. We hope that the resultant improved control and manage.
         .               ' ment of available resources will facilitate more systematic and timely
_ implementation of such modifications.
We believe these discussions have been most productive and, as noted in
                        - the enclosed ^ evaluation of your proposed program, conclude that your
                        . program is acceptable. However,tthe implementation of this program re-presents only the first step towards development of an industry wide           -
program to assure that necessary safety issues are implemented in a timely fashion at all operating reactors. As experience is gained with
         =--
your program and that of others, program changes may be necessary to incorporate additional or modified features which will enhance program effectiveness and assure timely implementation of safety issues.          As
                                 ,           C $~LWM

        ..i.
                   .Mr. Lee Liu.                                       discussed with your staff, in view of recent staff actions and the necessity of awaiting final staff review in a number of
* areas, the schedules contained in your November 12, 1982 application may require some revisions.
Copies of the Program Evaluation and Notice of Issuance are also en-closed.
ine'e rely, Vj    E s.e hut, O
: a.                             1 rector Division of Licensing Office of Nuclear Reactor Regulation

==Enclosures:==
: 1. Amendment No. 91 to DPR-49
: 2. Program Evaluation
: 3. Notice cc w/ enclosures:
See next page                                                  .
e 9
e

e Mr.' Lee Liu                                                                                                                                                                                      '
Iowa Electric Light & Power Compeny                                                                                 .       -                                                         .
c cci Mr. Jack Newman, Esquire" Harold F. Reis, Esquire n
* Lowenstein, Neaman, Reis and Axelrad                                                                                       ,
1025 Connecticut Avenue, N. k'.
Washington, D. C. 20035 Officefor'hlannkngandProgramming-523 East 12th Street                                                         -
Des Moines, Iowa                    50219 Chairman, Linn County Soard of Supervisors
                      .Cecar Rapiis, Iowa 52405 Iowa Electric Light & Power company ATTN:              D. L. Mineck P. O. Box 351 Cedar Rapids, Iowa 52405 U.S. Environmental Protection Agency Region VII Office Regional Radiation Representative                                                                                                                                                             .
324 East lith Street                                                                                                                                                                                                       '
Kansas City, ':issouri                   64106                                                                                                                                                  .
U.S. Nuclear Regulatory Commission Resident Inspector's Office Rural Rou'.e !1 Palo, Iowa 52324 James G. Keppler '                                                                                                                                                                   '
Regional Administrator, Region III
      .                U.S. Nuclear Regulatory Commission 799 Roosevelt Road I
Glen Ellyn, IL 60137
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                *...+                                                                                                                      j ICWA ELECTRIC LIGHT AND POWER COWANY cE ATRAL 10mA FOWER c00FERAlivE                                                             ,
l CORh BELT POWER C00PERATlvE                                                                    !
DOCKET NO. 50-331                                                                        ,
DUANE ARNOLD ENERGY CENTER
                                                            ~
LMENDMENT TO FACILITI OPERATING LICENSE Amendment No. 91                                           ;
License No. DPR-49
: 1. The Nuclear Regulatery Commission (the Commission) has found that:                                                  !
A. The application for amendment by Iowa Electric Light and Power                                                  l Company, et al, dated November 12, 1982 complies with the standards                                            ;
and requirements of the Atomic Energy Act of 1954, as amended                                                  l (the Act), and the Commission's rules and reguistions set forth                                                I in 10 CFR Chapter I;                                                                                           l l
B. The facility will e;erate in cenfcmity with the application,                                                   j the provisions of the Act, and the rules and regulations of the                                               _j C:mmission;                                                                                                    !
C. . There is reasenable assurance (i) that the activities autherized                                               j by this amencment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in ecmpliance with the Commission's regulations;                                                     ;
D. The issuance of this amendment will not be inimical to the common                                              j defense and security or to the health and safety of the public; and
      ~
                     . E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable require ents have been satisfied.
1
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               '2.       Accordin;1y', the license is atenced by adding a new paragraph 2.C(E',
                        .to read as .follows-:                                                           ,
L                        2.C(6)    1.  -The " Plan for the Integrated Scheduling of Plant Mocifica:icns for the Duane Arnoic Energy Center" (the Plan) submittec en November 12, 1982 (as revised) is approved.
a) The Plan shall be followed by the licensee from and af ter the effective date of this amendment.
b)    The licensee is required to maintain current revisiens of, and provide reports regarding, schedules' associated with the Plan in accordance with the terms of the Plan and failure to do so shall constitute a violatier of- this license condition.
c)    Changes to. dates for completion of items identified in Schedule B do not require a license amendment.                                                                               Dates.
specified in Schedule A shall be changed only in accer-dance with applicable NRC procedures. Failure to complete items listed in the schedules in accordance with dates there specified shall not consititute a violation of this license condition but may constitute a violation of any regulations, orders or license condition imposing such date.
: 2. This license amendment shall be effective until. May 3, 1955, subject to renewal upen application by the licensee.
: 3.        This license amendment is effective as of the date of issuance.
FOR THE NU irAR RgggLA70RY COMMISSION Domenic B. Vassall , Chief                                                                                             +
Operating Reactors Branch #2 Division of Liceriing                                                                                                    ,
Dat'e of Issuance:         May 3,1983
 .}

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* UNITED STATES '
              --         '!)Wr)/.eg(                                    NUCLEAR REGULATORY COMMISSION                                                                     .
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                               . .h INTEGRATED SCHEDULING DROGRAM                                                              ,
1 EVALUATION BY THE OFFICE OF' NUCLEAR REACTOR RE.GULATION
                                              ._ SUPPORTING AMENDMENT NO. - 91 TO FACILITY LICENSE NO. DPR-49 g               1                                        , IOWA ELECTRIC LIGHT AND POWER COMPANY
_o, y                 ,
DUANE ARNOLD ENERGY CENTER                                                              ,
DOCKET NO. 50-331 L
1.0           Introduction By letter dated May 28, ~ 1982, Iowa Electric Light and Power Company (IELP)' submitted 4 request. (initial submittal) .for approval of a five-year integratet' program for implementing self-imposed and NRC-imposed modifications of.the Duane Arnold Energy Center (DAEC).
     .c     ,
The basic' objective of Irwa Electric's (the licensee) program is to enable the utility to obtain b.etter control and management of available resources and to perfom required activities in a manner which would enhance plant safety by (1) improved control of safety related modifications and (2) more-prompt implementation of these modifications.
On- Aucust 11 and . August 12, lee 2, a meeting was. held with IELP and its contracter.,
Techno1c;y for Energy Corporation (TEC), to obtain additional information reger:i :
              .                   IELP's submittals and discuss _in further detail the licensee's program. This meeting focused on discussing points identified in a preliminary review of the licensee's proposed program and obtaining additional information regarding the details of the meinodologies and assumptions used in developing the IELF crecre-
                                .to cetermine the reasonableness of the schedules proposed by the licensee.
As a result of these discussions, the licensee simplified and streamlined its submittal. Iowa Electric requested in a November 12, 1982 application that'a' requirement to follow its " Plan for the Integrated Scheduling of Plant Modifications for the Duane Arnold Energy Center" (the Plan), which was
                                 ' submitted with the November 12, 1982 application, be added as a condition
                                .of the operating license for the DAEC.
Further discussions between.the NRC and IELP identified additional areas where further clarification of and revisions to lowa Electric's November 12,19E2 submittal were desirable. The licensee agreed to revise its Plan ( Attachmert 1)                                                          ,
I                           >
                                . accordingly in response to staff comments.
                                         <$ % T L.L f V L' % Q                                                 ,
2.0 procram Description y                                'The' program developed.b.y lowa Electric utilizes a computerized l                                  scheduling; technique which 1ntegrates the engineering, procurement,

J requirementsforpiantmodifications, maintenance, refueling, and operations. The computer model used by the licensee identifies critical paths and considers the interrelationships among projects and the constraints imposed by engineering support and site manpower limitations. The program proposed by the licensee appears to be capable of adapting schedules in the event of unforeseen delays in procurement or installation, strikes, changes in fuel cycle schedules,          ,
etc. In addition, the program has considered the necessity of                   )
coordinating plant modifications with revisions to plant operating
         <              procedures and operator retraining. ~                                         '
The licensee's program, as originally presented, proposed implementation dates as program goals and provided fo- semi-annual reporting to the NRC of utility progress with regard to implementation of each of the            l NRC required items and identification of project schedule slippages.
One critical assumption made in the IELP proposed program is that "NRC would not require additional plant modifications during its five year period." However, Iowa Electric has incorporated into its program currently proposed NRC requirements which are likely to be approvad for implementation on operating reactors. Proposed requirements (or re-quirements planned but not finalized, such as an upgraded suppression pool temperature monitoring syste.m) were included for implementation in the IELP program in anticipation of NRC requirements for these items.
In addition, the licensee assumed for purposes of its program that the guidance contained in SECY 82-111 concerning Emergency Response Facilities would become requirements.
Iowa Electric indicated in its May 28, 1982 submittal some of the boundary
           ~
conditions associated with its program. For example, the program assumes
* in-house engineering support of some 50 personnel. Which necessitated l                       deferral of several lower priority design intensive work items. A peak site day-shift manpower loading of some 555 personnel (1985) was set based on worker efficiency, craft availability, and effective management of these resources on-site.
The assumed in-house engineering support of 50 personnel 'does not include some 148,000 man-hours of engineering support outside of IELP's Mechanical / Nuclear Engineering Department during the five-year period of interest. Assuming approximately 1800 man-hours per work year, this is equivalent to an average of about 17 additional man-years per year over the five year period.
Although not specifically accounting for future new requirements (other    .
than those currently envisaged in its present proposed program)'the utility's program is structured so that additional required plant modifications can be integrated into the overall program to identify the impact of such new requirements on the overall schedule.
ee e go
                                                             .                                  e

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               -                                           -a-                                                           ,
The Plan submitted by the licensee identifies two           catecories of modifica icns.
1
              - Schedule A identifies schedules for modifications estatli'shed by existing Rule or Order. Schedule B icentifies schedules for completion of:
: 1)    regulatory items (of either a generic or plant specific nature) identified by NRC which would result in either a) plant modifications, b) procedure revisions, or c) changes to facility staffing requirements and which have an implementation date committed to by Iowa Electric, and;
: 2)     items perceived by IELp as prospective NRC requirements, and; 4                                                     .
: 3)    all major DAEC tasks resulting from mandates of agencies other than NRC and IELP initated system upgrades for availability improvement.
3.0- Evaluation 3.1 - Implementation-Since any major new requirements could result in significant schedule modifications, IELP suggested in its initial submittal that this program not be implemented by Order or License Condition.       Rather, the licensee suggested that it " report semi-annually to the NRC as to.its progress with regard to the NRC required items, and as to any slippage which threatens to delay completion of such items beyond the goals specified..."
i Such a program would net provide for sufficient accountability and leave -
NRC with no means of having assorance that NRC-identified regulatory issues are
* satisfied insofar as completion dates are concerned, short of revoking approvai of the program and ' subsequent issuance of Orders. In st,bsequent discussions with licensee representatives, they indicattd that an Order or License Conditicn would be acceptable, provided that this Order er License Con-dition made provisions in some fashion for flexibility in the event that certain requirements could not be done in a timely fashion due to circum-stances beyond Iowa Electric's control. New requirements would be incer-porated into the licensee's program af ter appropriate implementation dates have been established.
i The licensee's November 12, 1982, submittal (as revised) incorporates an application for amendment to incorporate a license condition requiring that Iowa Electric follow the Plan and permitting the licensee to make changes to the Plan and its schedules for certain category of items in accordance with the provisions of the Plan. We have reviewed the licensee's Plan and have determined that:                              .
: 1) Changes to schedules for completion of modifications imposed by Rule er Order (Schedule ' A' completion dates) will continue to be sought through the exemption or Order-date extension process (For example, Iowa Electric's existin; request for exemption from the schedular requirements of 10 CFR 50.44 regerding hydrogen recombiner- capability.) 2) Schedules for completion of other modifications (Schedule 'B' completion dates) are identified and provisions are made in the Plan to re' quire the utility to provide the NRC with prior written notification of changes to schedule B completion dates to*~
provide the opportunity m ~ , _- -_ n

           - g
               ..                                      -4.
in the Plan for incorporating new or anticipated regulatory items into Schedules A and B es,these require ents are identified by,NRC anc/cr ferralized by Rule er Order. The' licensee's proposal to incorporate a condition into the OAEC operating license which requires Iowa Electric to follow the Plan provices an appropriate mechanism to assure that NRC is informed as to whether requirec safety modifications are performed in a timely manner. At the same time, the Plan provides a suitable mechanism for changes to completion dates (due to unforseen circumstances) for modifications not imposed by Rule or Order and for keeping the NRC informed of such changes. Thus, the degree of flexibility
       .       needed to assure effective program implementation is provided while at the same time assuring that NRC's responsibilities are not compromised.
Numerous modifications, principally NUREG-0737 items, not specifically identified in the IELP program initially submitted, were considered by the licensee as part of its " base load
* of work requirements and grouped together as one or two line items in its forecasted work requirements. The licensee identified in its Ncvember 12,19E2 submittal each planned NRC-required modification as an individual line item for inclusion in the implementing
     .         vehicle.
Semi-annual reports of utility progress towards meeting NRC required modifica-tions would be proviced as preposed by the licensee.
Findines:
The propesal by Iowa Electric to add a license condition requiring the utility to follow the Plan provides a suitable mechanism for implementation of IELPs L              integrated plan. Completion dates imposed by Rule or Order are unaffected by L              the Iowa Electric creposal. As new requirements are identified anc/or formali:ed by the NEC provisions are made in the Plan to incorporate these into Schedule l-or B, as appropriate. Provisiens are made in the Plan to permit the licensee to develcp new dates for other modifications (Schedul,e B) and to keep the l-NRC informed of'such changes,                              .
Each planned NRC required modification is individually identified in the Schecules.
: 3. 2 Procesed Schedules Attachments 2 and 3 provide Iowa Electric's revision of its initially proposed schedule to include dates for completion of all presently known IELP-planned and NRC-required modifications over the next five years.
For modifications imposed by Rule or Order (other than the schedule requirements of the Interim Hydrogen Control Rule) the utility proposes completion by required dates.                                                                     ;
   }           With respect to NUREG-0737 items, the utility also proposes completion of all NUREG-0737 items originally scheduled for completion by 1/1/82 before startup from its 1983 refueling outage as required by Order issued on March 14, 1953.
This is acceptable in view of the responsible efforts demonstrated by the licensee and the unforeseen circumstance responsible for the delay. The licensee has shown that adequate compensatory measures are in piece. The following discusses the acceptability of other , completion dates proposed by IELP in its (3rogram.

N'
{
l q
With respect to items covered by SECY 82-111, schedules were developed before these items were approved by the Comission for implementation on operating reactors. In view of the responsible efforts demonstrated by the licensee, and the lead times necessary for bidding, procurement, and installations of these work items, the schedules proposed by IELP appear reasonable.
Other NRC-identified' modifications whose proposed completion dates extend as late 'as 1986 are essentially limited to modifications associated with the issue of " Control of Heavy Loads." The licensee is conducting an extensive evaluation of this issue to detemine the need for modifications to make the DAEC polar crane single-failure proof, demonstrating its responsible effort towards resolution of this issue.
As a compensatory action until modifications to this crane (if any) are completed Iowa Electric has made procedural revisions and improvements to provide an increased level of safety. We find that the necessity for conducting detailed engineering evaluations of potential modifications to the polar crane justifies a 1986 schedule for these modifications.
Certain schedules for completion of modifications to the Duane Arnold facility are keyed to completion of required NRC staff reviews that would result in sub-sequent approvals. For example, the schedule for certain modifications re-quired by 10 CFR 50.48 is determined by the date of completion of the staff review. In addition, certain modifications which will be necessary to satisfy the licensee's proposed radiological effluent technical speci-fications, have been proposed to be completed by the licensee on a schedule determined by completion of the staff review of this issue. Completion dates for such items are identified in Attachment 3. In view of the necessity of awaiting completion of staff reviews on these issues, this is acceptable.
{                                  Finally, it is recognized that with issuance of Generic Letter 82-33 pertaining to SECY 82-111, the schedules contained in the Nove%er 12, 1982 application may require some revisions. Additionally, the licensee is awaiting final staff action on the review of Iowa Electric's exemption requests associated with Appendix R. requirements.                      However, a schedule update will be provided in accordance with the terms and provisions of the Plan.
I Findincs The completion dates for modifications proposed by the licensee in its November 12,
{-                                 1982 submittal show IELP's responsible efforts towards satisfying NRC requirements. Where the dates proposed by the li:ensee extend more than about three years in the future, initial action wil* have been taken by the licensee to provide a high level of safety. Modifications which extend into 1986 or 1987 are of such a nature that full compliance could not reasonably be expected to be attained much sooner.                               Dates for                 -
completion of modifications not yet deteminet d"e to the necessity of awaiting staff approval will be included in the licensee's plan after the requisite staff reviews are complete.

a l
6-r                                                                                      .
Based upon our review of the information contained in IELP's submittals, the dates proposeo by the licensee in its November 12, 1982 application appear reasonable.
4.0 Sumary Based on the considerations addressed herein, we find that:                  ,
: 1) The proposal by Iowa Eledr'- r at its plan be implemented by a License Condition requiring the utility to follow the Plan is acceptable.
: 2) The licensee's proposal that changes to implementation dates imposed by existing Rule or Order will continue to be sought through the exemption or order date extension process is acceptable.
: 3) Schedules for new requirements should be estabMshed for the DAEC on a plant specific basis.
: 4) Based upon our review of the dates proposed by the licensee in its November 12, 1982 submittal, the dates proposed by the licensee appear reasonable.
5.10 Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment            .
involves an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement, or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this amendment.                     .
6.0 Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of an accident of a type different from any evaluated previously, and does not involve a significant reduction in a margin of safety, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered'by             .
operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Date: May 3,1983 ' - -                                              ,,
Principal Contributor:     Kenneth T. Eccleston

Attachnes; 1 Plan for the :ntegrated Scheduling of Plant
* Modifications fer the Duane t.rncid Energy Center L                  2. Introduction                                                                                                -
L                       Icwa Electric Light and Power Company (IILP) has develcped a i                       comprehensive program which will enable the Company to
!                       effectively manage implementation of certain modifications p                       which have been required, or proposed by, the NRC, as well as other measures to enhance plant. safety and reliability which have been identified by the Company. A description of l                       the program, identified as " Integrated Program for Modifica-tien of the Duane Arnold Energy Center (DAEC) , " was submit-l                       ted~to the NRC on May 28, 1962, by Iowa Electric letter LDR-L                       82-0140.                                                                         ,
This program was developed to coordinate and schedule all necessary work at the DAEC, whether mandated by NRC or identified by IELP and others. The program objectives are to (1) conform to regulatory requirements; (2) provide sufficient lead times for modifications; (3) rinimice changes for operators; (4) assure training requirements are fulfilled; (5) effectively manage financial and human resources; and (6) specify the framework for changes to developed schedules.
1 This program reflects that fiscal and manpower resources are finite and that a limit on the onsite manpower is neces-sary.                                                          The program integrates all presently planned work at DAIC ever a nominal five year period to ensure that in-dividual tasks are effectively scheduled and coordinated.
It provides a means for new requirements to be accommodated
* taking into account schedule and resource constraints.
The purpose of this document is to cescribe the plan used to implement the program (the " Plan").                                                         It describes how the program functicns, mechanisms for changing the Plan and updating it, and the interactions of NRC and licensee staffs                                                                                        ;
under the Plan, and its associated schedules.
II. Summary of Program Development The program is based on a computer generated listing of over
     ,                  600 items of prioritized work.                                                          The listing takes into account projections for budgets and site manpower and engineering support requirements for five years, on an item-by-item basis covering all plant modification activities.
It represents a total DAEC work list and commitment list                                                                                        -
which is regularly modified and updated to meet chLnging conditions, including new NRC regulatory requirements.                                                                                      The final product of this program is the development of schedules as discussed below.
e 4*
e
____m_______           _ . _ _ _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _            __._
9                                                      0

4 3, . .
2-111. Scheduline                                                                                                                                                        ,
                               'Upon ccepletien of the complete work listind, Iowa Electcic l
I determined that. detailed-and integrated schedules were                                                                                                       j required for'the major work items. . Upen completing the                                                                                                         '
comprehensive listing of,majer work items, the tasks. vere organized into Schedules A and B using critical' path methodology (CPM) for selected work' items. CPM schedules identify critical paths in the work ' effort for each task,'which in turn, enables prompt ad .
aptation of schedules.to meet contingencies such as strikes, delays in procurement or installation or modification of fuel cycle schedules, Both Schedules are briefly described below:
                                      ' Schedule A -                              All items which have imple-mentation dates mandated by NRC rules, orders, or' license.cen-ditions.
Schedule B -                               Regulatory items (of either a
                                                                            - generic or plant specific nature) identified by NRC which have in-plementation dates committed te by Iowa Electric and which would result in either a) plant medi-fications, b) procedure revisiens, or c) changes in facility staf-fing requirements; or
                                                                        . items perceived by Iowa Electric as prospective NRC requirements; er major DAIC tasks resulting frcm mandates of agencies other than NRC and IELP-initiatec system upgrades for availability imprcvemen:.
Schedule A dates may be modified only with the prior approval of NRC, in accordance with existing NRC procedures.
Changes in Schedule B dates require written notification to
                                     'NRC as described in Section V.                        Schedules'A and B, taken together, provide a basis for assessing the overall effects of changes to schedules and a departure point for discussion between NRC and the licensee regarding such changes, as dis-cussed below.                                                                                                                                         -
IV.        Schedule Modifications An important aspect of Iowa Electric's planning effect is the'recogniticin that the attached schedules will need to be t
6
                                                  .f.             _ _ _ . . - _ .               - . _ - - . - . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ - - - _ _ . - _ - - - - - _ - - _ _ -

44 e
ecdified at times to reflect changes in regulatory re-quirements, to accon.modate those activities that Iowa Electric finds necessary to improve plant efficiency and reliability, and to take into account delays resulting f:c-events beyond IELP's control.         It is important that the procedure used by Iowa Electric for changing the schedules be documented.*/ In addition, the NRC must play a role in the oversight of the scheduling process (and must, in fact, judge the acceptability of proposed date changes in Schedule A). Accordingly, it is important that the NRC's role, and the interaction between the NRC and IELP, be clearly defined, as discussed below.
V. IELP Responsibilities The integrated schedule requires that IELP conitor the progress of all work undertaken, manage its activities tc maintain the schedule, and act premptly to take necessary actions when a schedule change is needed.
A. Periodic Updatinc IELP will upda'.e Schedules A and B semi-annually and submit the revised schedules to NEC, beginning six months following NRC concurrence in the Plan. In cddition to updating the schedules.
IELP will:
Summarize progress in implementing NRC requirements concerning plant m0 deifications Identify changes since the last repcrt Summarize the reasons fer schedule changes associated with regulatory requirements.
B. Chances to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications in the scope of
                      ~
                       */    Schedules A and B will contain sufficient detail tc identify those items with completion dates keyed to fuel cycle outages.        In such cases, a change in outage perioc shall not be considered a schedule change.
4"

l;    I    c.
l 4-L
                 . scheduled work: problems in delivery, procurement, etc.;
changes in NRC rules and regulations; or other NRC or IELP
                -actions.
Where it is necessary to add a new work item or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
                       . Assess the priority of the work item and its safety significance Schedule the new or changed item to svoio rescheduling other items, if it can be reasonably achieved Alter Schedule S items before Schedule
                           .A items Select a schedule for the new or changed iter which will help in maintaining an optimum .integrat,ed program of work.
As noted above, no changes will be made in Schedule A without prior NRC approval. Should a change become neces-sary, it will.only be proposed after Iowa Electric has
                .dete=ined that rescheduling of non-NRC required werk items
                .either will not significantly assist in maintaining Schedule A without change; or,that the safety, cost or schedule penalties.from rescheduling ~non-NRC required work sig-                                                                                                                                   -
nificantly outweigh the change in a                                                                                                             Schedule A completien
                -date.
Iowa. Electric will inform the NRC Project Wanager when serious consideration is given to.requr ting a change in Schedule A. When IELP detemines that a change in Schedule A is necessary, it.will submit a written request for NRC approval in accordance with applicable proc'edures.
Work items in Schedule B may be rescheduled or work items may be added to Schedule B by Iowa Electric without NRC approval; however, IELP will inform the NRC Project Manager when serious consideration is given to changing the schedule for or adding an item in Schedule B.
In addition, at least 30 days (unless otherwise agreed to by the NRC Project fianager or unless circumstances beyond IELP's control ari.se within 30 days of the scheduled date) before IILP adopts a
_ - , - . _ _ _ _ _ _ _ - - - _ . _ . _ . _ . - _ - _ _ - - . - - _ _ . - _ _ ~ _ _ _ _ _ _ _ - - - _ _ _ _ _

                           #                                                                                i 4                                            .
change f r an item in SchecuYe B (as defined in Section III above),
it will provide the NRC writte'n notification thereof, including the reasons therefcr and any compensatory actions instituted. If not provided 30 days in advance, such notification.will be provided by IELP as promotly as practicable. NRC may request further explanation
  '                            or discussion:concerning such change. In       this event, discussions will be initiated with the NRC Project Manager       However  IELP changes in scheduled dates will be effective unless s. bsequentfy u           modified by IEL:.
VI. NRC Review          .
                               'As pointed out in Section V.B above, changes to the sched-ules are inevitable.- Action required by.NRC is discussed below:
t.r A.        Iowa Electric originated Changes
: 1. Upon receipt from IELP of a request for modi-fication of Schedule A, NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the re-Quest in accordance with applicable procedures.
: 2. If the request for a modification of Schedule A is denied, NRC shall promptly inform Iowa Elec-tric and provide the reasons for denial.
: 3. NRC consideration of IELP changes in non-Schedule A itens is covered by V.S.       '
: 3.       NB_C Oricinated Chances (Schedule A)
It is recognized that fernal NRC regulatory actions l
may:     (1) impese a new regulatory requirement with a fixed date er (2) establich a firm date for a previously ident:-
fied regula:Ory requirement.          In taking any such action the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on IELP's ability to complete effectively the items on Schedules A, and E, and, in consultation with IELP, will try to minimize such impact. Although any formal regulatory action taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and IELP recognize the desirability of incorporating such action into Schedule A, particularly in order to                -
incorporate at the same time any other appropriate changes l                                        in the total integrated schedule program. Accordingly, ence such fermal regulatory action is taken (or earlier, if 1
l l
l

4 6-               -
practicable), the NRC will provide IELP a rease, nable ep-pertun ty to propose overall changes in the total intee:ated schedule program which would most ef fectively accommodate such requirements. Any resulting changes in items in Schedule A will be approved by NRC in accordancr! with established procedures, and will thereupon be 7,eflected in a revised Schedule A submitted by IELP. IELP vill inf orm the NRC of any resulting changes in Schedule B in accordance with Section V. above.
C.'  New NRC Issues (Schedule B)
The NRC rnay, from time to tirne, identify new regulatory issues which may result in a) plant modifications, b) procedure revision or development, or c) changes in facility staffing requirements. For issues as to which NRC requests scheduling information, these issues may be included in Schedule B in accorden:e with the date commitment developed in discussions between IELP and the NRC staff. As for the case of NRC-originated changes to Schedule A items, the NRC will provide IELP a reasonable opportunity to prepose overall changes in the total integrated schedule program which wculd most effectively accommodate such issues. Any resulting changes in integrated program schedules will thereupon be reflected in a re-vised Schedule B submitted by IELP.
972I. Modifications to thq Plan The licensee and the NRC recognize that the Plan itself may require future modifications.          Accordingly, IELP will; draft proposed modifications and submit a license amendment application for approval of the proposed changes.             The changes will be made effective upon amendment issuance by NRC.                                          .
I 1
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                       ,                                                                                                     7550-01 a          ,
g                         ,.                         ' UN TED STATES NUCLEAR REGULATORY COMMISSION M             '
100CKIT ND. 50-331                           ',
                                                      ,LOWELECTE!C'LIGHTANDPOWER' COMPANY,ET-AI
[">                                                    NOT]CE-0F ISSUANCE OF AMENDMENT TO FACILITY OPERAT1NG LICENSE-
                ..           1
    ~'
The U. 5. Nuclear Rigulatory Commission (the Comission) has issued 7
Amendment No. 91 to Facility Operating License No. DPR 49 issued to. Iowa
: E'lectric Light'and Power Company, Central Iowa Power Cooperative,.and Corn Belt Poser Cooperative, which revises the License for operation of.the i                              Duane Arnold E4ergy. Center, located in Linn County Iowa.      The amendment is effective as of its 'date of. issuance.
                                         -The amendment incorporates a license condition requiring the licensee.
to' follow its :" Plan for the Integrated Scheduling of Plant Modifications for
                                                                ~
the' Duane Arnold Energy Center."' "
The application for the amendment complies with tne standards and ,
requirements of the Atomic Energy Act of 1954, as amended (the Act). and the Commission's rules and regulations. The Corr.ission has mace appropriate fin' dings as required by the Act and the Commissicn's rules and regulatier.s in -10 CFT< Chapter I, which are set forth in the l'icense amendment.             Prior g                            ' public notice of this amendment was not required since the amendment does not involve a significant hazards consideration.
The Comission has determined that the issuance of this amendment will not' result in any significant environmental impact and that pursuant to
:   10 CFR 51.5(t)(4) an' environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with issuence of this amendment. ,
j}D T1.b IZ$h ?0

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2 Fcr further details with respe: t: this a: tion, see (1) the 4;;. 3:eti:n for amendment deted Novetter 12, 1952, (2) A, .endment No. 91 t0 License N .
DPR-49, and (3) the Cc=ission's related Program Evaluation.                  All ef these iters are available for public inspe: tion at the Comission's Public Decument Re :,
1717 H Street, N. W., Washingten, D.C. and at the Cedar Rapids Public Library, 425 Third, Avenue, S.E., Cedar Rapids, 1owa'52401.   ,
A copy of items (2) and (3) may be ebtained upon re:;uest addressed to the U.S. Nuclear Regulatery Comissier.,
Washing               n, D.C. 2055E, Attention:     Director, Division cf Licensing.
Dated at Bethesde, Maryland, this 3rd day of May 1983.
FOR THE NUCLEAR REGL'LATORY C09.!5510N r
                                                                                                      , .    .ff                                1 Vernon L. Rooney, Acting C. ef Operating Reactors Branch d2 Division of Licensing a
e l

Enclosure 2
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                                ,                         UNITED STATES
                 <[h 5            .j g             NUCLE AR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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                  \...../                                                      May 2, 1985   ',
L TO ALL' OPERATING REACTOR LICENSEES Gentlemen:

==Subject:==
IMPLEMENTATION OF INTEGRATED SCHEDULES FOR PLANT MODIFICATIONS (GENERIC LETTER 85 07 )
The purpose of this Generic Letter is (1) to describe the staff's intentions withrespecttoimplementingintegratedschedules,and(2)tosolicitwide-spread industry participation in helping to place the priority for modifications at individual plants so as to permit a well founded integration of implemen-tation efforts. A survey form is enclosed to collect your views, intentions, and concerns regarding an integrated schedule for your plant (s).
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On May 3,1983, the Comission issued Amendment No. 91 to the Duane Arnold EnergyCenter(DAEC)operatinglicense. This amendment incorporated a license Q           condition which approved Iowa Electric Light and Power Company's " Plan for
                      -the Integrated Scheduling of Plant Modification for the Duane Arnold Energy Center." Implementation of this program for DAEC represented the first step toward development of an industry-wide approach to achieve more effective management of NRC-required plant changes and optimum uses of NRC and licensee resources.
Generic Letter 83-20 was issued on May 9,1983 in the interest of infoming the industry of the DAEC amendment and inviting other utilities to participate in similar programs on a voluntary basis. So far, we have received only six applications from the industry, although experience with the DAEC plan has been very favorable. Our experience indicates that a cooperative effort between the NRC and each licensee in scheduling completion dates for NRC-required plant modifications will benefit both the NRC and the licensee in the utilization of their respective resources.
The Nuclear Regulatory Comission's Statement of Policy and Planning Guidance for 1985 states in part:
                             "An integrated implementation schedule for new and existing require-ments reflecting relative priorities should be established for each power reactor licensee."
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The NRC is not able to support the effective management of safety-related               ]
modifications and optimize the allocation of resnurces without the full support         }
and cooperation of the individual utility and plant manaaement. To make the               I transition from our past practice of treating new actions en an ad hoc basis,            !
to a more structured pre-planned approach to management of plant changes we               '
must approach the problem in a spirit of joint cooperation. We stand ready to work with each of you on a voluntary basis to develop plant-specific livino          '
schedules for your operating reactors. Our intentions in some of the broad areas of consideration relative to the implementation of integrated schedules are briefly stated in Enclosure 1.
In this regard, we request your views on the Integrated Living Schedule (ILS) concept, and particularly, your intentions for your operating reactors. You may have additional concerns that warrant discussion or alternative approaches that you would want us to consider. Please feel free to contact the assigned NRC Project Manager to request a meeting with our staff to discuss the concept in general or its application on your facility (s) in particular. We would appreciate receiving a response within 60 days that uses the format provided as Enclosure 2 to this letter.
Thank you for your cooperation.
Sincerely,                             /
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Hugh   . Thompson, V. ir tor Di i ion of Licens ng Of ce of Nuclear React   Regulation

==Enclosures:==

As stated
                                                                                                     )

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                      -(                                                                                                                                                                                                       ENCLOSURE 1 3                             'Fermal License Amendment LFrom the regulatory standpoint, the intent of the fomal license condition is to confirm an agreement showing good faith on the part of the licensee and the NRC in assuring satisfactory schedules for implementing necessary plant modifications. These schedules are subject to change for goed cause and with prior ~ notification. It is not intended, nor would it be appropriate, for the NRC to become_ involved in the licensee's financial planning and funding processes for these plant improvements.                                                                                                                                                             .
4                               Procram Implementation As a minimum, the schedule'should include all NRC-initiated plant modifications, whether mandated, f as in a rule, regulation, or order) or commit,ted to by the licensee (originating in a ceneric letter or IE Bulletin, for example).
As part of the licensing review, the project manager will detemine that the schedule scope _is adeounte. The extent to which a licensee wishes to include additional items not directly associated with plant modifications initiated by
: the NPC, such as region inspection follow-up items or er,pineering analysis activities, is purely a matter of the licensee's discretion and overall goals for.their progran.
O              Licensee-initiated plant changes would only appear on the schedule as necessary to pemit an overall understandir g as to how they are being integrated with the NRC initiatives. For example, a licenset modification initiative that can be installed independent of engoing NRC work, required activities would not be expected nor need to appear on the integrated schedule at all. Further, if the licensee found it necessary to revise a schedule #or one of their plant betterment modifications, and the schedule could be revised without impacting the completion date for NRC required activities, prior notification with. written follow-up would be unnecessary, even though the item did appear on the integrated schedule.                                                                                                                               It should be clear that the regulatory intent of the license amendment is to provide assurance that NRC required activities are scheduled and completed at the plant consistent with an optimum utilization of resources under the constraints applicable to the specific licensee.
Regional review of the program implementation would be geared to confirming that the program plan is carried out as approved. The schedule including the completion date may be changed as provided for in the plan. The plan describes the framewnrk for revising the schedule.
Utility-Soonsored Projects From the regulatory standooint, one of the fundamental underlying benefits                                                                                                                                    -
of adopting a preplanned, structured management approach to implementing plant chances is the added assurance that utility sponsored " plant better-t                  ment" projects will beve an opportunity to be scheduled and completed, along with NRC-initiated activities in the appropriate order of priority. The NDC does ont intend to reculate the schedule for implementation of utility-sponsored
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projects, but rather to perr.it an orderly process for such work to be scheduled and perforred. It appears that both regulatory and utility interests will be served by the successful integration of these two components, end we plan to make every effort to ensure that the integrated scheduling process is structured so that the inclusion of licensee plant betterment pro,iects will be viewed as a strong incentive rather than an impediment to utility cooperation.
Prioritization Methodology Althouch the staff generally uses some form of risk-cost benefit ratio methodology for the prioritization of new issues, we understand that a utility's prioritization of existing requirements will be based on other factors (including safety) that may result in a different perception of relative importance at a specific plant.
This is precisely why we have not tried to prescribe a prioritization methodology for plant-specific application. It is here that we feel the utility should be left to its own devices; no one else knows the plant better than the people who operate it. Whatever methodology is best suited to an individual licensee is appropriate and will be considered.
Practical Application
         .          As a result of our close work with lowe Electric and Power Co. in connection with its integrated schedule plan, we have found it unnecessary to issue Confirmatory      [
Orders for modifications addressed in Supplement I to NUREG-0737, including the SPDS, Control Room Design Review, Regulatory Guide 1.97, Emergency Operating Procedures, and Emergency Response Facilities.
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ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-                                                             .
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PLANT NAME:
UTILITY:
I. INTENTIONS A. Intend to work with the staff to develop an ILS                                                                   -  -
B. Have reservations that must be resolved                                                                                                   !
before developing ILS                                                                                                                     '
Do not presently intend to negotiate an C.                                                                                                                                             !
ILS with the staff D. Plan to implement an infonnal ILS only                                                                                                    !
                     .II.      STATUS                                                                                                                                         ,
s               A. If you answered I.A above:                                                                                                                !
                 )
: 1. Have you settled on a method for prioritizing the work at your plant (s)?
Circle One:                                                  Yes        No If yes, select best description:
Engineering judgement Analytic Hiearchy process                                                                -
Risk based analysis Cost-benefit analysis Other (please describe)
If no, provide estimated date for selecting a methodology:                                        '
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Date or                                                                         l If not presently available, provide estimated date for scheduling the selection of a f                                        methodology:                                                                                                                       ,
: 2. What is your estimated date for making a l        (                               submittal to the NRC-1 or If not presently available, planned date for                                                                                         ,
scheduling a submittal to the NRC                                                                                                    l
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ .                              _---____-__--_L-

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  .c B. If you answered I.B abo've:
: 1. Please explain your reserva'tions on separate sheet (s)              -
or provide your schedule for supplying an explanation                .
See separate sheet (s) or Separate submittal scheduled for (Date)
: 2. If available to meet with the ' staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Number C. If you answered I.C
: 1. Would.you he willing to meet with the staff to discuss the development of an ILS for your facility (s)?
Circle One:     __     Yes.         No If yes, propose a time frame for such a meeting and provide a contact that can make arrangements.
Contact
              .       Time Frame Phone Number                                              -
If no, any constructive comments you have would't: appreciated.
III.      ADDITIONAL ITEMS Please make any suggestions you may have as to how a utility sponsored availability / reliability pro.iect might be credited for plant safety enhancement. Provide additional constructive comments as appropriate.
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I LIST OF RECENTLY ISSUED GENERIC LETTERS
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GENERIC                                                                    -
,                  -LETTER NO.                     SUBJECT                                         -DATE
!L '                84-17        Annual Meeting to Discuss Recent Develop-ments Regarding Operator Training, Qualifications and Examinations                            7/3/84 84-18        Filing of Applications for Licenses and Amendments                                                  7/6/84 1
84-19       Availability of Supplement I to NUREG-0933 "A Prioritization of Generic Safety Issues" 8/6/84
  ,1-
   )                84-20       Scheduling Guidance for Licensee Submittals of Reloads that Involve Unreviewed Safety Questions                                                   8/20/84 84-21       Long Term Low Power Operation in PWR's                      10/16/84 64-22.       Not used 84-23        Reactor Vessel Water Level Instrumentation in BWRs O          84 -24       Clarification of Compliance to 10 CFR 50.49 10/26/84 Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants                                                12/27/84 85-01'      Fire Protection Policy Steering Committee Report                                                      1/9/85 85-02       Staff Recommended Actions Stemming From NRC Integrated Program for the Resolution of Unresolved Safety Issues Regarding Steam Generator Tube Integrity                                    4/15/85 85-03       Clarification of Equivalent Control Capacity 1/28/85 For Standby Liquid Control Systems 85-04       Operator Licensing Examinations                             1/29/85 85-05       Inadvertent Boron Dilution Events                           1/31/86 85-06       Quality Assurance Guidance for ATWS                                                                                     ,
Equipment that is not Safety-Related 4/16/85 85-07       Implementation of Integrated Schedules                      5/02/85
(                      for Plant Modifications l
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Enclosure 3
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i FEDERAL REGISTER NOTICE OF PUBLICATION FOR COMMEN1
    =i OF COMMISSION POLICY STATEMENT ON INTEGRATED SCHEDULES FOR IMPLEMENTAT10r; 0F PLANT MODIFICATIONS MARCH 1987 1

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[7590-01)
Nuclear Regulatory Commission 10 CFR Part 50.
Proposed Commission Policy Statement on Integrating Schedules for Implementation of Plant Modifications AGENCY:     Nuclear Regulatory Commission ACTION:     Notice of Proposed Commission Policy Statement
                           ~

==SUMMARY==
Thi's proposed policy statement describes the policy the Commission intends to use to promote voluntary licensee integrated schedules for implementing
                          . regulatory requirements and other improvements in nuclear power plants. . Its primary focus concerns the ways integrated schedules may be. established by licensees to develop realistic schedules and the ways the Commission intends to
                           , interact with these li n tsees. Secondly, it documents the Comission's support for the establishment of int.: grated schedules at each nuclear power pli:nt.
DATES: Subtit comentr, by [ sixty days from date of publication in the Federal Register]. Comments received after that date will be considered if it is practical to de so, but assurance of consideration cannot be given except as to comments received on or before this date.
ADDRESSEE: Submit comments, suggestions, or recommendations to the Secretary
                                           ~o f the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555,JAttention:                              Docketing and Service Branch. Copies of comments received may be examined at the NRC .Public Document Room,
                                          '1717 H Street N.W., Washington, D.C.
                           'FOR FURTHER INFORMATION CONTACT:
Kenneth T. Eccleston, Technical Assistant Planning and~ Program Analysis Staff Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555                                                                                                                    t
                                                           . Telephone: (301)492-9518 9

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SUPPLEMENTARY INFORMATION:                                                                                .
BACKGROUND On May 3, 1983, the Commission issued the first integrated schedule plan, incorporated as a condition of the Duane Arnold Energy Center (DAEC) operating license. On May 9,1983, the Commission issued Generic Letter (GL) 83-20 informing the industry of the DAEC anendment and inviting other utilities to participate in similar programs on a voluntary basis.
Similar license amendments were issued to Pilgrim on July 13, 1984, and to Big Rock Point on February 12, 1986. On July 9, 1985, DAEC was granted a two-year extension for its plan. The experience thus far with the DAEC and Pilgrim plans has demonstrated that integrated schedules can help optimize both NPC 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 staff's intentions regarding integrated schedules and to solicit widespread industry participation in developing appropriate procedures to establish and maintain integr6ted schedules. As part of GL 85-07, a survey was taken to determine industry interest. Of the 48 responses received, 21 licensees (representing 50 reacters) indicated an interest in integrated schedules which involved staff review or approval of the program. An additional 27 licensees (representing 42 plants) indicated they were not interested in submitting such a program for staff review. At the same time, only six licensees (representing 7 plants) indicated that tliey did not at present employ or intend to employ an integrated scheduling process. The NRC, with these two generic letters, has sought increased industry participation in this concept with minimal success.
On October 25, 1985, the NRC staff participated in an industry semirear to obtain a better understanding of the industry's perspective on integrated schedules. One of the main concerns voiced by industry representatives was the lack of guidance from the Commission regarding the preparation anc implementation of integrated schedules. Many licensees were apprehensive about participating in a voluntary program without clear criteria or standards for evaluating integrated schedules.
Consequently, the NRC has developed this policy statement to:
Reiterate the Commission's interest and support for a voluntary integrated scheduling process at each nuclear power plant.
Describe the basic approach for the implementation of integrated schedules.
Initiate a dialogue with industry to develop basic criteria and                                                            -
procedures for the evaluation of an integrated scheduling process.
Delineate the NRC's role in the integrated scheduling process.

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Proposed Commission Policy              .
The Commission believes the implementation of integrated schedules on a plant specific basis would provide a systematic means to coordinate, manage, and schedule major modifications, L0th regulatory and licensee-initiated. An integrated scheduling process can help ensure timely compliance with regulatcry requirements, while maintaining an appropriate balance between the regulatory and the licensee-initiated modifications based on the relative importance of the actions and the available resources. It would also provide a consistent basis for scheduling future plant modifications at individual facilities. The ability to forecast and maintain long-term schedules should improve public confidence and will provide the industry with a more stable environment with regard to resources to be expended on nuclear program changes and modifications.
The major elements of a formal integrated scheduling process are:
: 1) A systematic process-for identifying and defining those activities to be scheduled.
: 2) A means for "prioritizir.g" the individual actions based on a licensee specific "prioritization" process which considers various factors or attributes such as safety, plant availability, radiation exposure, procurement requirements, costs, etc.
: 3) An integrated scheduling plan, describing the manner by which the implementation schedules will be maintained and updated, which is supported by a separate procedure detailing the prioritization and scheduling process.
: 4) NRC review of the prioritization and scheduling process and approval of the plan and initial schedule.
: 5) Licensee maintenance of the schedule as evidenced by periodic reports describing actions completed, schedules for new actions, and schecule changes resulting from new actions and/or implementation problems.
A fundamental premise of the integrated scheduling process is that plant modifications can and should be 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 prioriti-zation 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 priori-tization methodology should be decided by the licensee. However, because of the importance of the prioritization methodology in the integrated schedule process, it is essential the NRC staff clearly understands the process. While    .
the actual process will be established by the licensee, it will be incumbent i
upon the licensee to provide a comprehensive description of the integrated scheouling process to the NRC staff. Because of the financial aspects of many of the specific scheduling activities (e.g., planning, estimating, procuring,

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: funding, and personnel constraints), it would be inappropriate for the Commission to establish acceptability criteria for these activities; however, the Commission must understand the planning and scheduling pract1ces associated with any integrated schedule plan.
The Commission proposes to view plants in three categories:
: 1) Plants with an integr'ated scheduling license amendment,
: 2) Plants with a submitted, integrated scheduling plan but without a license amendment, and
: 3) Plants without a submitted, integrated scheduling plan.
Because of the positive experience with the DAEC and Pilgrim integrateo schedule amendments, the Commission believes the optimum effect of an integrated ~ schedule is realizec when implemented with a license amendment.
The major benefit of the integrated schedule plan will be the ability to
: integrate implementation schedules as new projects arise. The Commission, however, would still retain the ability to impose deadlines with the under-standing that it could affect completion dates of other regulatory requirements                         i or licensee projects in the current schedule. All new regulatory requirements would be imposed only in accordance with applicable Commission regulations.
Accordingly, future rules that impose implementation schedules will also specify the manner by which schedule extensions or relief may be requested for licensees with an approved integrated scheduling plan. Since the integrated scheduling process deals with management and scheduling of major modifications, the process would not come under 10 CFR Part 50, Appendix B requirements.
The Commission will also consider integrated scheduling plans without a license amendment. Those plants with an inform 1, integrated scheduling plan, which has been submitted for staff review, may refer to that plan in support of proposed implementation schedules for new regulatory requirements and changes to existing implementation schedules. The informal plan provides a tool in the negotiation of schedules, but since they lack formality of a license conditicn,
   #             implementation schedules would still be resolved on a case-by-case basis. The Commission believes that an informal, integrated scheduling plan provides at the very least some consistent basis for the negotiation of schedules.
Those plants without a submitted plan will propose and justify implementation schedules on a case-by-case basis.
               - The existing integrated scheduling license amendments have been structureo to provide the industry with flexibility in changing schedules necessitated by delays beyond the licensees' control or by the addition of new requirements, while allowing the Commission to assure that regulatory requirements are diligently and expeditiously implemented. The NRC Project Manager will have the overall responsibility for evaluating and approving the integrated scheduling license amendment. As such, the Project Manager will need to have a comprehen-sive understanding of the process and plan for the assigned plant to assure the licensee is establishing realistic and timely implementation schedules. This formal process will provide the Project Manager with an overview of all ongoing work at the plant and a clear understanding of the utility's decision-making process. The Project Manager will seek advice, as necessary, from various NRC
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o                  offices regarding the appropriateness.of-specific implementation sc'hedules.
!                 . Final-resolution cf any schedule conflicts will be by the Director of NRR and t-                 senicr utility management utilizing the integrated schedule as a basis for negotiations.
By the nature of. scheduling activities, the Commission is offering these es voluntary alternatives. The Commission hereby directs the NRC stuff to con-tinue to work with industry representatives to develop guidelines, consistent with this policy statement, for integrated scheduling plans and the supporting
                  . processes, including the appropriate inspection and enforcement policies. When a consensus is reached on these guidelines, the Commission will publish them to further: encourage the development and application of integrated scheduling plans.
Dated at Washingicn, D.C.'.this                day of                 , 1987.
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For the Nuclear Regulatory Commission, Samuel J. Chilk, Secretary of the Commission s

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( .1 d8' Atomic Industrial Forum, Inc.
7101 Wisconsin Avenue o                     >                                                      Bethesda, MD 20814-4891 Telephone; (301) 654-9260 TWX 71o824960.2 Atomic FoR DC November 5, 1986 n                                         _Kenneth T. Eccleston,' Technical Assistant p                                          planning'and Program Analysis Staff
                                         ' Office of-Nuclear Reactor Regulation
[                                          U.S.' Nuclear Regulatory Commission
[                                          Kashington,: DC 20555

==Subject:==
 ' Draft Integrated Schedules Policy Statement

==Dear Mr. Eccleston:==

)                                          In May,1986, the'' Steering Group of the AIF Committee on Reactor Licensing and -
Safety-(CRLS) endorsed the'' formation of the Subcommittee on Integrated Schedules y                                          to interact with the: NRC toward the development of acceptable policies and guidance describing how Integrated Schedules might be voluntarily established by licensees to. develop realistic schedules. The Steering Group of the CRLS supports the posi-tion that the implementation of Integrated Schedules on a plant specific and vol-untary basis can provide a more stable environment, with regard to resources to
                                         -be expended for coordinating,' managing, and scheduling major modifications, both regulatory and licensee originated. To date, the Subcommittee has concentrated much of its efforts on developing its assessment of the NRC Staff's ongoing acti-vities to' develop a proposed palicy statement on integrated schedules for the Commission's review.
It is our~ understanding that a " comment period" for the final proposed policy statement may not be' offered. This causes us great concern in view of the progress achieved thus far by working in a mutually cooperative vein. The purpose of this letter is to document formally our concerns regarding our current understanding of the content of the draft policy statement being reviewed within the SRC Staff. We desire to'be constructive in our input and have therefore limited our comments to areas of particular sensitivity or potential negative implications from our view-point. To provide our mere specific comments in the clearest fashion, we have
                                          ' delineated those comments in Attachment 1.
Additionally, we wish to single out that it is our understanding that the draft policy statement specifically avoids discussions of various detailed aspects of Integrated Schedules (content,. implementation, enforcement, etc.) in favor of deferring these to subtier documents and future joint discussion / development efforts. As'such, the document merely summarizes the current environment sur-rounding' industry use rif " Integrated Schedules", and suggests this environment might be improved.through joint NRC/ industry involvement. It is with this knowl-edge that the Steering Group of the CRLS and the Subcommittee on Integrated                                                   .
Schedules could support such a draft policy statement given the incorporation of our specific suggestions (Attachment 1) and thus, defer the discussions of otherwise critical elements of the Integrated Schedule issue.
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9 Mr. Kenneth T. Eccelston                                            November 5, 1986 J
l  __     I As a final comment, it is important to note a fundamental concept upon which our support of the draft policy statement would be based. There are three broadly defined categories into which utilities fall as regards implementation of Inte-grated Schedules:
: 1) Plants with integrated schedule license amendments;
: 2) Plants with submitted integrated schedule plans without a licease amendment; and
: 3) Plants without submitted integrated schedule plans.
We believe this distinction of categories is absolutely necessary in that it adds definition to what is described as a voluntary process and in so doing, acknowl-edges that decisions surrounding use/ implementation of integrated schedules are, and must remain, decisions of the individual utilities. Obviously, such a process also must not allow for negative incentives which add " penalties" that discourage selection of one category over another. Also, any implementation of integrated schedules must not preclude the appropriate exercise of management decision-making as well as allow for the recognition of the need for plant specific aspects to integrated schedule plans. hbintenance of a truly voluntary process is and will continue to be primary to our objectives if we are to continue to work beyond the policy statement on the development of guidelines and supporting documents.
We thank you in advance for your consideration of these comments. The Subcommittee on Integrated Schedules of the AIF Committee on Reactor Licensing and Safety is prepared to continue to work with the NRC on its activities regarding the potential further implementation of integrated schedules by licensees.
Sincerely, Wid Larry V. Parscale, Chairman AIF Subcommittee on Integrated Schedules LVP:wp Enclosures cc: R.H. Vollmer

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    ,.; +   e, ATTAGBEST 1 Suggestions to be considered in drafting a Policy Statement on Integrated Schedules:
: 1. Implementation of an integrated schedule can not be technically demonstrated to result in a substantial additional increase in the overall protection of the public health and. safety. Therefore, there should not be any reference in a policy statement to plant safety being improved via implementation of inte-grated schedules.
: 2. Regarding the actual integrated schedule process established by.the licensee to prioritize the plant modifications, the policy statement should clearly acknowledge that it would be inappropriate for the. Commission to establish acceptability. criteria for the actual process, due to the financial aspects of many of the specific scheduling activities. Accordingly, while it is-understood that the NRC intends to review and approve the integrated' scheduling plan, the supporting but separate prioritization and scheduling process itself should not be subject to h7C approval.
: 3.      It is recommended that the three categories as described in the cover letter into which utilities fall regarding implementation of integrated schedules be described in the policy statement and that the overall voluntary nature of the program be clearly delineated. Additionally, the three categories could be introduced via the following phrase: "The Commission proposes to view plants in these categories...".
: 4.        It should be clearly delineated in any policy statement that for those plants without submitted integrated schedule plans, the current practices regarding establishment of schedules for regulatory modifications are acceptable and will remain unchanged.
: 5. . Regarding actual development of the individual licensee's integrated schedule plan and license amendment, the ability for the licensee to tailor these documents to individual circumstances should be allowed. Therefore, we would not advocate that any recommendation that licensees incorporate the essential elements of previously issued amendments be included in any policy statement.
: 6.        One of the intents of the integrated schedule process is to provide a defined and consistent basis for the establishment of schedules thereby precluding the need for individual negotiation of the schedule for each regulatory modifica-tion. Therefore, it is recommended that the term " negotiation" not be used when referring to the finalization of the initial schedule for a licensee that has an integrated schedule license amendment.
_ . - _ _ _ _ _ _ _ _ - _ _ . _ _ _ - _ . _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _}}