NRC Generic Letter 1985-07: Difference between revisions

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{{#Wiki_filter:-, _ .-; -. _ _ _ _ _ F _ _ _ -g .- ~ ~., f. .* 9i ,' .- .-~ 'I.- .../ *$ a 7.UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:-, _ .     - ; -.                               _ _ __      _ F                 __ _   -     g .- ~~.,
COMMISSION
                                                                                                        f. .
4 e'WASHINGTON, D. C. 20555 May 2, 1985 TO ALL OPERATING
                                                        'I.-               ...             / *$             a   7.
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 with respect to implementing integrated schedules, and (2) to solicit wide-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).On May 3, 1983, the Commission issued Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. This amendment incorporated a license 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 informing 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.
*    ,'  9i.-          .            -~
                                                              UNITED STATES
                                                NUCLEAR REGULATORY COMMISSION                                    4 e'WASHINGTON,                                  D. C. 20555 May 2, 1985 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 with respect to implementing integrated schedules, and (2) to solicit wide- 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).
                      On May 3, 1983, the Commission issued Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. This amendment incorporated a license 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.


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.
Generic Letter 83-20 was issued on May 9, 1983 in the interest of informing 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 Commission'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." fl54t #; 5oq2.qIq9.
The Nuclear Regulatory Commission'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."
    ;                     5oq2.qIq9.


-2- 44 The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management.
fl54t                      #


To make the i transition from our past practice of treating new actions on 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.
-2-                                      44 The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management. To make the i transition from our past practice of treating new actions on 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 living 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.


We stand ready to work with each of you on a voluntary basis to develop plant-specific living schedules for your operating reactors.
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.


Our intentions in some of the broad areas of consideration relative to the implementation of integrated schedules are briefly stated in Enclosure
Thank you for your cooperation.
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.
Sincerely, Hugh L . Thompson,9O., p~rq~tor Di iion of Licensing l Of e of Nuclear Reac in Regulation Enclosures:
  As stated


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)
4 Summary In summary, the staff views the development of living schedules at operating reactors to be a worthwhile endeavor that can provide positive benefits to both the industry and the NRC, and with a good-faith joint effort believe that any potential pitfalls can be overcome. We stand ready to work with each of you on a voluntary basis to develop plant-specific living schedules for your operating reactors.
in particular.


We would appreciate receiving a response within 60 days that uses the format provided as Enclosure
In this regard, we would be interested in your individual views on the Inte- grated Living Schedule (ILS) concept, and particularly, your intentions with regard to your operating reactors. You may have additional concerns that warrant discussion or alternative approaches that you would want us to consider.
2 to this letter.Thank you for your cooperation.


Sincerely, Hugh L .Thompson,9O., p~rq~tor Di iion of Licensing l Of e of Nuclear Reac in Regulation Enclosures:
Please feel free to request a meeting with our staff to discuss the concept in general or its application on your facility(s) in particular. You are requested to respond using the format in the attachment to this letter.
As stated
4 Summary In summary, the staff views the development of living schedules at operating reactors to be a worthwhile endeavor that can provide positive benefits to both the industry and the NRC, and with a good-faith joint effort believe that any potential pitfalls can be overcome.


We stand ready to work with each of you on a voluntary basis to develop plant-specific living schedules for your operating reactors.In this regard, we would be interested in your individual views on the Inte-grated Living Schedule (ILS) concept, and particularly, your intentions with regard to your operating reactors.
We would appreciate a reply within 120 days from the date of this letter.


You may have additional concerns that warrant discussion or alternative approaches that you would want us to consider.Please feel free to request a meeting with our staff to discuss the concept in general or its application on your facility(s)
This request for information was approved by the Office of Management and Budget under clearance number          , which expires          . Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D. C. 20503.
in particular.


You are requested to respond using the format in the attachment to this letter.We would appreciate a reply within 120 days from the date of this letter.This request for information was approved by the Office of Management and Budget under clearance number , which expires .Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D. C. 20503.Thank you for your cooperation.
Thank you for your cooperation.


Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
*See Previous Concurrence iAr DL ORB-2
*See Previous Concurrence                       iAr DL           ORB-2 *       AD/OR *         II"Do           OELD     '/ \
* AD/OR
JHannon:mcs   DVassallo     GLainas           DGEisenhut   C     ,,v%-
* II"Do OELD '/ \JHannon:mcs DVassallo GLainas DGEisenhut C f4l ,,v%-9/ /84 9/ /84 9/ /84 9/ /84 /0/7S4 ENCLOSURE
                                                                      f4l
1 Formal License Amendment From the regulatory standpoint, the intent of the formal 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.
9/ /84         9/ /84         9/ /84             9/ /84       /0/7S4


These schedules are subject to change for good cause and with prior notification.'  
ENCLOSURE 1 Formal License Amendment From the regulatory standpoint, the intent of the formal 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 good 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.
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.


Program Implementation As a minimum, the schedule should include all NRC-initiated plant modifications, whether mandated, (as in a rule, regulation, or order) or committed to by the licensee (originating in a generic letter or IE Bulletin, for example).As part of the licensing review, the project manager will determine that the schedule scope is adequate.
Program Implementation As a minimum, the schedule should include all NRC-initiated plant modifications, whether mandated, (as in a rule, regulation, or order) or committed to by the licensee (originating in a generic letter or IE Bulletin, for example).
As part of the licensing review, the project manager will determine that the schedule scope is adequate. The extent to which a licensee wishes to include additional items not directly associated with plant modifications initiated by the NRC, such as region inspection follow-up items or engineering analysis activities, is purely a matter of the licensee's discretion and overall goals for their program.


The extent to which a licensee wishes to include additional items not directly associated with plant modifications initiated by the NRC, such as region inspection follow-up items or engineering analysis activities, is purely a matter of the licensee's discretion and overall goals for their program.Licensee-initiated plant changes would only appear on the schedule as necessary to permit an overall understanding as to how they are being integrated with the NRC initiatives.
Licensee-initiated plant changes would only appear on the schedule as necessary to permit an overall understanding as to how they are being integrated with the NRC initiatives. For example, a licensee modification initiative that can be installed independent of ongoing 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 for 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.


For example, a licensee modification initiative that can be installed independent of ongoing 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 for 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.
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 framework for revising the 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.
Utility-Sponsored Projects From the regulatory standpoint, one of the fundamental underlying benefits of adopting a preplanned, structured management approach to implementing plant changes is the added assurance that utility sponsored "plant better- ment" projects will have an opportunity to be scheduled and completed, along with NRC-initiated activities in the appropriate order of priority. The MPC
does not intend to regulate the schedule for implementation of utility-sponsored


The schedule including the completion date may be changed as provided for in the plan. The plan describes the framework for revising the schedule.Utility-Sponsored Projects From the regulatory standpoint, one of the fundamental underlying benefits of adopting a preplanned, structured management approach to implementing plant changes is the added assurance that utility sponsored "plant better-ment" projects will have an opportunity to be scheduled and completed, along with NRC-initiated activities in the appropriate order of priority.
1..
                                    &4
                                      -2 projects, but rather to permnt an orderly process for such work to be scheduled and performed. It appears that both regulatory and utility interests will be served by the successful Integration of these two components, and we plan to make every effort to ensure that the integrated scheduling process is structured so that the Inclusion of licensee plant betterment projects will be viewed as a strong incentive rather than an impediment to utility cooperation.


The MPC does not intend to regulate the schedule for implementation of utility-sponsored
Prioritization Methodology Although 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.
&4 1..-2 projects, but rather to permnt an orderly process for such work to be scheduled and performed.


It appears that both regulatory and utility interests will be served by the successful Integration of these two components, and we plan to make every effort to ensure that the integrated scheduling process is structured so that the Inclusion of licensee plant betterment projects will be viewed as a strong incentive rather than an impediment to utility cooperation.
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.


Prioritization Methodology Although 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.
Practical Application As a result of our close work with Iowa 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 1 to NUREG-0737, including the SPDS, Control Room Design Review, Regulatory Guide 1.97, Emergency Operating Procedures, and Emergency Response Facilities.


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.
I< .;
 
                                                                    4 ENCLOSURE 2
Practical Application As a result of our close work with Iowa 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
1 RESPONSE FORMAT - GENERIC LETTER 85- a-  ..
1 to NUREG-0737, including the SPDS, Control Room Design Review, Regulatory Guide 1.97, Emergency Operating Procedures, and Emergency Response Facilities.
      PLANT NAME:
 
      UTILITY:
I< .;1 4 ENCLOSURE  
      I.
2 RESPONSE FORMAT -GENERIC LETTER 85-PLANT NAME: UTILITY: I.


==INTENT==
==INTENT==
IONS
IONS
a- ..A. Intend to work with the staff to develop an ILS B. Have reservations that must be resolved before developing ILS C. Do not presently intend to negotiate an ILS with the staff D. Plan to implement an informal ILS only II. STATUS A. If you answered I.A above: 1. Have you settled on a method for the work at your plant(s)?prioritizing i-Circle One: Yes No If yes, select best description:
            A. Intend to work with the staff to develop an ILS
Engineering judgement Analytic Hiearchy process Risk based analysis Cost-benefit analysis Other (please describe)  
              B. Have reservations that must be resolved before developing ILS
_ _ .If no, provide estimated date for selecting a methodology:
              C. Do not presently intend to negotiate an ILS with the staff D. Plan to implement an informal ILS only II.   STATUS
-Da-te or If not presently available, provide estimated date for scheduling the selection of a methodology:
              A. If you answered I.A above:
I ;2. What is your estimated date for making a submittal to the NRC-or If not presently available, planned date for scheduling a submittal to the NRC  
                  1. Have you settled on a method for prioritizing the work at your plant(s)?                     i- Circle One:         Yes         No If yes, select best description:                 I ;
I i I!:1 @f- --,.4 B. If you answered I.B above: 4 I 1.- Please explain your reservations on separate sheet(s)or provide your schedule for supplying an explanation See separate sheet(s)or Separate submittal scheduled for 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 (Date)1. Would you be willing development of an ILS Circle One: to meet with the staff to discuss the for your facility(s)?
                      Engineering judgement Analytic Hiearchy process Risk based analysis Cost-benefit analysis Other (please describe)             _ _   .
Yes No If yes, propose a time frame for such a meeting and provide a contact that can make arrangements.
                      If no, provide estimated date for selecting a methodology:
                                                        -   Da-te or If not presently available, provide estimated date for scheduling the selection of a methodology:
                  2. What is your estimated date for making a submittal to the NRC-
                                      or If not presently available, planned date for scheduling a submittal to the NRC
 
i       I                             4
!:1
  @f- --
      I
  ,.
          B. If you answered I.B above:                                             4 I
              1.- Please explain your reservations 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 be 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 be appreciated.
Contact Time Frame Phone Number If no, any constructive comments you have would be appreciated.


III. ADDITIONAL  
III.     ADDITIONAL ITEMS
ITEMS Please make any suggestions you may have as to how a utility sponsored availability/reliability project might be credited for plant safety enhancement.
          Please make any suggestions you may have as to how a utility sponsored availability/reliability project might be credited for plant safety enhancement. Provide additional constructive comments as appropriate.


Provide additional constructive comments as appropriate.
I


I
LIST OF RECENTLY ISSUED GENERIC LETTERS
LIST OF RECENTLY ISSUED GENERIC LETTERS GENERIC LETTER NO. -SUBJECT DATE 84-17 Annual Meeting to Discuss Recent Develop-ments Regarding Operator Training, Qualifications and Examinations  
GENERIC
7/3/84 84-18 Filing of Applications for Licenses and Amendments  
LETTER NO.         -       SUBJECT                     DATE
7/6/84 84-19 Availability of Supplement  
84-17     Annual Meeting to Discuss Recent Develop- ments Regarding Operator Training, Qualifications and Examinations             7/3/84
1 to NUREG-0933
84-18     Filing of Applications for Licenses and Amendments                                   7/6/84
'A Prioritization of Generic Safety Issues" 8/6/84 84-20 Scheduling Guidance for Licensee Submittals of Reloads that Involve Unreviewed Safety Questions  
84-19     Availability of Supplement 1 to NUREG-0933
8/20/84 84-21 Long Term Low Power Operation in PWR's 10/16/84 84-22 Not used 84-23 Reactor Vessel Water Level Instrumentation in BWRs 10/26/84 84-24 Clarification of Compliance to 10 CFR 50.49 Environmental Qualification of Electrical Equipment Important to Safety for Nuclear 1 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  
            'A Prioritization of Generic Safety Issues" 8/6/84
4/15/85 85-03 Clarification of Equivalent Control Capacity 1/28/85 For Standby Liquid Control Systems 85-04 Operator Licensing Examinations  
84-20     Scheduling Guidance for Licensee Submittals of Reloads that Involve Unreviewed Safety Questions                                   8/20/84
1/29/85 85-05 Inadvertent Boron Dilution Events 1/31/85 85-06 Quality Assurance Guidance for ATWS Equipment that is not Safety-Related  
84-21     Long Term Low Power Operation in PWR's       10/16/84
4/16/85 85-07 Implementation of Integrated Schedules  
84-22     Not used
5/02/85 for Plant Modifications I'i May 2, 1985-2-The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management.
84-23     Reactor Vessel Water Level Instrumentation in BWRs                                     10/26/84
84-24     Clarification of Compliance to 10 CFR 50.49 Environmental Qualification of Electrical Equipment Important to Safety for Nuclear   1 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           1/31/85
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


To make the transition from our past practice of treating new actions on 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.
I'i May 2, 1985
                                          -2- The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management. To make the transition from our past practice of treating new actions on 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 living 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.


We stand ready to work with each of you on a voluntary basis to develop plant-specific living schedules for your operating reactors.
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.


Our intentions in some of the broad areas of consideration relative to the implementation of integrated schedules are briefly stated in Enclosure
Thank you for your cooperation.
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.
Sincerely, Original Signed by a7 L.T hnnipsn, Jr, Huh Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation Enclosures:
    As stated
    *SEE PREVIOUS CONCURRENCE
    ORAB:DL        ORB#2:DL*      AD/OR:DL*        OELD*              DL
    JHannon:mcs    DVassallo      GLainas          GCunningham      HThompson
    9/ /84        9/24/84        9/25/84          10/22/84        4/lo/85
    8504290442


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)
Ig. Sf .
in particular.
                                              -4- Summary In summary, the staff views the development of living schedul      at operating reactors to be a worthwhile enl1eavor that can provide positi    benefits to both the industry and the t ,    -;C- ^ and with a good-fait joint effort believe that any potential pitfalls can be overcome. We      and ready to work with each of you on a voluntary basis to develop plant- ecific living schedules for your operating reactors.


We would appreciate receiving a response within 60 days that uses the format provided as Enclosure
In this regard, we would be interested in your indi dual views on the Inte- grated Living Schedule (ILS) concept, and partlcu rly, your intentions with regard to your operating reactors. You may hay additional concerns that warrant discussion or alternative approaches t t you would want us to consider.
2 to this letter.Thank you for your cooperation.


Sincerely, Original Signed by Huh a7 L. T hnni psn, Jr, Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation Enclosures:
Please feel free to request a meeting with o staff to discuss the concept in general or its application on your facility ) in particular. You are requested to respond using the format in the attach nt to this letter.
As stated*SEE PREVIOUS CONCURRENCE
ORAB:DL ORB#2:DL*
AD/OR:DL*
OELD* DL JHannon:mcs DVassallo GLainas GCunningham HThompson 9/ /84 9/24/84 9/25/84 10/22/84 4/lo/85 8504290442 Ig. Sf .-4-Summary In summary, the staff views the development of living schedul at operating reactors to be a worthwhile enl1eavor that can provide positi benefits to both the industry and the , t ;C --^ and with a good-fait joint effort believe that any potential pitfalls can be overcome.


We and ready to work with each of you on a voluntary basis to develop plant- ecific living schedules for your operating reactors.In this regard, we would be interested in your indi dual views on the Inte-grated Living Schedule (ILS) concept, and partlcu rly, your intentions with regard to your operating reactors.
We would appreciate a reply within 120 ays from the date of this letter.


You may hay additional concerns that warrant discussion or alternative approaches t t you would want us to consider.Please feel free to request a meeting with o staff to discuss the concept in general or its application on your facility ) in particular.
This request for information was appr ed by the Office of Management and Budget under clearance number          , which expires          . Comments on burden and duplication may be di ected to the Office of Management and Budget, Reports Management, R m 3208, New Executive Office Building, Washington, D. C. 20503.


You are requested to respond using the format in the attach nt to this letter.We would appreciate a reply within 120 ays from the date of this letter.This request for information was appr ed by the Office of Management and Budget under clearance number , which expires .Comments on burden and duplication may be di ected to the Office of Management and Budget, Reports Management, R m 3208, New Executive Office Building, Washington, D. C. 20503.Thank you for your cooperatio Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation DL B-2 DL OELD JHannon:mcs Vasallo G s OGEisenhut
Thank you for your cooperatio Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation DL               B-2                         DL             OELD
9/ /84 / 9t/84 9 /J84 9/ /84 9/ /84 I .I*.}}
        JHannon:mcs     Vasallo     G     s         OGEisenhut
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Latest revision as of 02:56, 24 November 2019

NRC Generic Letter 1985-007: Implementation of Integrated Schedules for Plant Modifications
ML031140395
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill, Crane
Issue date: 05/02/1985
From: Thompson H
Office of Nuclear Reactor Regulation
To:
References
GL-85-007, NUDOCS 8504290442
Download: ML031140395 (10)
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UNITED STATES

NUCLEAR REGULATORY COMMISSION 4 e'WASHINGTON, D. C. 20555 May 2, 1985 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 with respect to implementing integrated schedules, and (2) to solicit wide- 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).

On May 3, 1983, the Commission issued Amendment No. 91 to the Duane Arnold Energy Center (DAEC) operating license. This amendment incorporated a license 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 informing 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 Commission'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."

5oq2.qIq9.

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-2- 44 The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management. To make the i transition from our past practice of treating new actions on 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 living 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, Hugh L . Thompson,9O., p~rq~tor Di iion of Licensing l Of e of Nuclear Reac in Regulation Enclosures:

As stated

4 Summary In summary, the staff views the development of living schedules at operating reactors to be a worthwhile endeavor that can provide positive benefits to both the industry and the NRC, and with a good-faith joint effort believe that any potential pitfalls can be overcome. We stand ready to work with each of you on a voluntary basis to develop plant-specific living schedules for your operating reactors.

In this regard, we would be interested in your individual views on the Inte- grated Living Schedule (ILS) concept, and particularly, your intentions with regard to 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 request a meeting with our staff to discuss the concept in general or its application on your facility(s) in particular. You are requested to respond using the format in the attachment to this letter.

We would appreciate a reply within 120 days from the date of this letter.

This request for information was approved by the Office of Management and Budget under clearance number , which expires . Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D. C. 20503.

Thank you for your cooperation.

Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation

  • See Previous Concurrence iAr DL ORB-2 * AD/OR * II"Do OELD '/ \

JHannon:mcs DVassallo GLainas DGEisenhut C ,,v%-

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9/ /84 9/ /84 9/ /84 9/ /84 /0/7S4

ENCLOSURE 1 Formal License Amendment From the regulatory standpoint, the intent of the formal 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 good 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.

Program Implementation As a minimum, the schedule should include all NRC-initiated plant modifications, whether mandated, (as in a rule, regulation, or order) or committed to by the licensee (originating in a generic letter or IE Bulletin, for example).

As part of the licensing review, the project manager will determine that the schedule scope is adequate. The extent to which a licensee wishes to include additional items not directly associated with plant modifications initiated by the NRC, such as region inspection follow-up items or engineering analysis activities, is purely a matter of the licensee's discretion and overall goals for their program.

Licensee-initiated plant changes would only appear on the schedule as necessary to permit an overall understanding as to how they are being integrated with the NRC initiatives. For example, a licensee modification initiative that can be installed independent of ongoing 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 for 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 framework for revising the schedule.

Utility-Sponsored Projects From the regulatory standpoint, one of the fundamental underlying benefits of adopting a preplanned, structured management approach to implementing plant changes is the added assurance that utility sponsored "plant better- ment" projects will have an opportunity to be scheduled and completed, along with NRC-initiated activities in the appropriate order of priority. The MPC

does not intend to regulate the schedule for implementation of utility-sponsored

1..

&4

-2 projects, but rather to permnt an orderly process for such work to be scheduled and performed. It appears that both regulatory and utility interests will be served by the successful Integration of these two components, and we plan to make every effort to ensure that the integrated scheduling process is structured so that the Inclusion of licensee plant betterment projects will be viewed as a strong incentive rather than an impediment to utility cooperation.

Prioritization Methodology Although 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 Iowa 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 1 to NUREG-0737, including the SPDS, Control Room Design Review, Regulatory Guide 1.97, Emergency Operating Procedures, and Emergency Response Facilities.

I< .;

4 ENCLOSURE 2

1 RESPONSE FORMAT - GENERIC LETTER 85- a- ..

PLANT NAME:

UTILITY:

I.

INTENT

IONS

A. Intend to work with the staff to develop an ILS

B. Have reservations that must be resolved before developing ILS

C. Do not presently intend to negotiate an ILS with the staff D. Plan to implement an informal ILS only II. STATUS

A. If you answered I.A above:

1. Have you settled on a method for prioritizing the work at your plant(s)? i- Circle One: Yes No If yes, select best description: I ;

Engineering judgement Analytic Hiearchy process Risk based analysis Cost-benefit analysis Other (please describe) _ _ .

If no, provide estimated date for selecting a methodology:

- Da-te or If not presently available, provide estimated date for scheduling the selection of a methodology:

2. What is your estimated date for making a submittal to the NRC-

or If not presently available, planned date for scheduling a submittal to the NRC

i I 4

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I

,.

B. If you answered I.B above: 4 I

1.- Please explain your reservations 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 be 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 be appreciated.

III. ADDITIONAL ITEMS

Please make any suggestions you may have as to how a utility sponsored availability/reliability project might be credited for plant safety enhancement. Provide additional constructive comments as appropriate.

I

LIST OF RECENTLY ISSUED GENERIC LETTERS

GENERIC

LETTER NO. - SUBJECT DATE

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

84-19 Availability of Supplement 1 to NUREG-0933

'A Prioritization of Generic Safety Issues" 8/6/84

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

84-22 Not used

84-23 Reactor Vessel Water Level Instrumentation in BWRs 10/26/84

84-24 Clarification of Compliance to 10 CFR 50.49 Environmental Qualification of Electrical Equipment Important to Safety for Nuclear 1 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 1/31/85

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

I'i May 2, 1985

-2- The NRC is not able to support the effective management of safety-related modifications and optimize the allocation of resources without the full support and cooperation of the individual utility and plant management. To make the transition from our past practice of treating new actions on 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 living 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, Original Signed by a7 L.T hnnipsn, Jr, Huh Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation Enclosures:

As stated

  • SEE PREVIOUS CONCURRENCE

ORAB:DL ORB#2:DL* AD/OR:DL* OELD* DL

JHannon:mcs DVassallo GLainas GCunningham HThompson

9/ /84 9/24/84 9/25/84 10/22/84 4/lo/85

8504290442

Ig. Sf .

-4- Summary In summary, the staff views the development of living schedul at operating reactors to be a worthwhile enl1eavor that can provide positi benefits to both the industry and the t , -;C- ^ and with a good-fait joint effort believe that any potential pitfalls can be overcome. We and ready to work with each of you on a voluntary basis to develop plant- ecific living schedules for your operating reactors.

In this regard, we would be interested in your indi dual views on the Inte- grated Living Schedule (ILS) concept, and partlcu rly, your intentions with regard to your operating reactors. You may hay additional concerns that warrant discussion or alternative approaches t t you would want us to consider.

Please feel free to request a meeting with o staff to discuss the concept in general or its application on your facility ) in particular. You are requested to respond using the format in the attach nt to this letter.

We would appreciate a reply within 120 ays from the date of this letter.

This request for information was appr ed by the Office of Management and Budget under clearance number , which expires . Comments on burden and duplication may be di ected to the Office of Management and Budget, Reports Management, R m 3208, New Executive Office Building, Washington, D. C. 20503.

Thank you for your cooperatio Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation DL B-2 DL OELD

JHannon:mcs Vasallo G s OGEisenhut

9/ /84 / 9t/84 9 /J84 9/ /84 9/ /84

. I I

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