ML20209B541

Application for Amend to License DPR-16,consisting of License Amend Request 156,adding Plan for long-range Planning Program

ML20209B541
Person / Time
Site:	Oyster Creek
Issue date:	01/27/1987
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20209B500	List: ML20209B494 ML20209B541
References
0170F, 170F, NUDOCS 8702040068
Download: ML20209B541 (14)

Text

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GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION Provisional Operating License No. DPR-16 License Anendment Request No.156 Docket No. 50-219 Applicant submits, by this License Anendment Request No.156 to the Oyster Creek Nuclear Generating Station Operating License, the addition of license condition 2.C.8 By P. R. Clark, President Sworn and Subscribed to hpfore me this 7/S day of d7MOAl 198 /'#

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) Docket No. 50-219 GPU Nuclear Comoration )

CERTIFICATE OF SERVICE 4

This is to certify that a copy of License Amendment 156 for Oyster Creek Nuclear Generating Station Technical Specifications, filed with the U.S.

Nuclear Regulatory Commission on January 27, 1987 , has this day of January 27, 1987 , been served on the Mayor of Lacey Township, Ocean County, New Jersey by deposit in the United States mail, addressed as follows:

The Honorable Christopher Connors Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 B.y -

J P. R. Clark, President 0170F 4

4 p 3 GPU Nuclear Corporation J [r4,', . UOlM[ 100 Interpace Parkway Parsippany, New Jersey 07054-1149 (201)263-6500 TELEX 136-482 Writer's Direct Dial Number.

January 27, 1987 The Honorable Christopher Connors Mayor of Lacey Township 818 West Lacey Road Forked River, New Jersey 08731

Dear Mayor Connors:

Enclosed herewith is one copy of License Amendment Request No.156 for the Oyster Creek Nuclear Generating Station Operating License.

This document was filed with the United States Nuclear Regulatory Commission on January 27, 1987 -

Very truly yours, UUh P. R. Clark, President c

PRC/PC/pa 0170F Attach.nent 0170F GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation

GPU Nuclear Corporation i G Guclear n3n:r "

Forked River. New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

January 27, 1987 Mr. Frank Cosolito, Acting Chief Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, New Jersey 08628

Dear Mr. Cosolito:

Sub.iect: Oyster Creek Nuclear Generating Station Provisional Operating License No. DPR-16 License Amendment Request No.156 Pursuant to 10CFR50.91(b)(1), please find enclosed a copy of the sub.iect document which was filed with the United States Nuclear Regulatory Commission on January 27, 1987 .

Very truly yours, cc J v .

P. R. Clark, President PRC/PC/pa 0170F Attachment

1 OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE N0. DPR-16

, DOCKET NO. 50-219 j LICENSE AMENDMENT REQUEST NO.156 f

Applicant hereby requests the Commission to amend the above captioned license as below and, pursuant to 10CFR50.91, an analysis concerning the determination of no significant hazards considerations is also presented:

Proposed License Amendment 2.C.8 Lona Range Planning Program The " Plan for the Lono Range Planning Program for the Syster Creek i Nuclear Generatina Station" (the Plan) submitted i on is approved.

a. The Plan shall be followed by the licensee from and after the effective date of this amendment.

b. Changes to dates for completion of items identified in Categories B and C of the plan do not require a license amendment. Dates specified in Category A shall be changed only in accordance with applicable NRC procedures.

t Discussion Generic Letter 85-07, dated May 2,1985 requested nuclear power plant licensees to document intentions regarding implementation of the Intearated Implementation Schedule concept. GPU Nuclear responded by letter dated August l 27, 1985 indicating our intention to pursue the development of an Integrated

! Implementation Schedule for both Oyster Creek and Three Mile Island I. As the long range plannino function was implemented for Oyster Creek first, a proposed license amendment incorporating the Long Range Plannino Proaram into the operating ifcense can now be requested.

This amendment request is to incorporate the Plan for the Long Range Plannina Proaram (LRPP) into the Oyster Creek Nuclear Generating Station Operating i License (DPR-16). The LRPP by itself has no safety function but the projects covered by the Plan may affect the function of safety systems or components at Oyster Creek. The LRPP will establish an improved basis for plannino, j scheduling and implementing necessary plant projects.

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The primary objectives of the Plan for the LRPP are:

1) To optimize the allocation of GPUN and NRC resources to those projects necessary to assure safe, reliable and economic plant operation.

2) To achieve the appropriate balance and prioritization amono all proposed projects based on their relative value and effect regardless of source.

The Plan contains three categories of projects, as follows:

Cateoory A: All projects involving regulatory issues which have resolutions and/or issue resolution dates mandated by NRC rules, orders or license conditions.

Scheduled completion dates for Cateoory A items will be modified only upon receipt of prior approval from the NRC in accordance with applicable NRC procedures.

Category B: Projects involving issues identified by the NRC and/or GPUN for which commitments have been made to NRC by GPUN. The issue resolutions would result in significant a) plant modifications, b) procedure revisions, or c) chances in facility staffing requirements.

GPUN will inform the Oyster Creek NRR Project Manaaer when a change is made to the schedule completion date for a Category B project. GPUN will provide the NRC with written notification of a change including the basis for the chance and any compensatory action initiated.

Category C: Other major projects, identified by GPUN or other reaulatory agencies.

GPUN will advise the NRC for information only of chances to Cateoory C projects semi-annually.

l l The long range planning function is not currentiv described in any Licensing l

Basis Document. It was initiated in 1984 to establish controls for the efficient utilization of resources to implement identified projects which significantly impact available resources. The proposed amendment would incorporate this function as a license conditions.

The LRPP by itself has no safety function. The projects covered by the Plan may af fect the function of plant systems important to safety; however, any changes in plant confiouration or operation resulting from projects in the Plan are required to be evaluated separate 1.y in accordance with safety review and/or confiouration control procedures. The long rance plannino function results in a prioritization and rankina of projects so that appropriate implementation schedules can be established.

The proposed license amendment does not in and of itself result in any chance to Appendix A or B Technical Specifications. Therefore, maroins of safety stated in Technical Specification bases are not chanced.

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Determination We have determined, based upon the above discussion, that this license amendment request involves no significant hazards considerations in that operation of the Oyster Creek plant in accordance with the proposed amendment will not:

1. Involve a significant increase in the probability or consequences of any accident previously evaluated; or

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in margin of safety.

In summary, the basis for the above determination is as follows:

The establishment as a license condition of the Plan for the Long Range Planning Program by itself performs no safety function. The long range planning function does not directly change plant configuration or operation.

Pro.iects covered by the Plan may affect systems important to safety; however, any impact resulting from these projects is evaluated separately in accordance with applicable safety review and/or configuration control procedures. As no changes to Appendix A or B Technical Specifications occur as a direct result of this proposed amendment there is no change in margins of safety.

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PLAN FOR THE LONG RANGE PLANNING PROGRAM FOR THE OYSTER CREEK NUCLEAR GENERATING STATION I. Introduction GPU Nuclear Corporation (GPUN) has developed a comprehensive program which will enable GPUN to effectively manage implementation of '

significant changes to the Oyster Creek Nuclear Generating Station (0.C.) which have been mquired, or proposed by, the NRC, as well as other measures to enhance plant safety and reliability which have been identified by GPUN or other agencies (e.g., the Institute of Nuclear

" Power Operations). The program is identified as the "GPUN Long Range Planning Program". This program was developed to assess, coordinate and schedule major work tasks or projects at 0.C., including those mandated or proposed by the NRC, or identified by GPUN and others. The program objectives are to (1) satisfy regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize changes for operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed projects and associated schedules. This will be accomplished within the overall objective of plant safety and availability.

This program reflects the recognition by GPUN and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary. Routine functional plant operations and maintenance require a abstantial portion of available resources, further limiting resources which can be applied to the resolution of non-routine but important regulatory and non-regulatory issues that arise. The program integrates a significant portion of such presently planned non-routine work at 0.C. over a nominal five-year period to ensure that tasks associated with issue resolution are properly assessed and effectively scheduled and coordinated. It provides a means for new requirements to be accommodated taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program. It describes how the

! program functions, mechanisms for changing the program and updating it, l the interactions and responsibilities of the NRC and licensee staffs under the program, and its resultant assessments and schedules.

The term project as used herein refers to the projected allocation of significant fiscal and manpower resources at 0.C. The term issue resolution as used herein refers to the actions necessary to resolve concerns (safety related or othewise) which have been identified by the NRC or GPUN.

l II.

SUMMARY

OF PROGRAM DEVELOPMENT The program is based on a list of projects and their completion dates each of which is assigned a priority resulting from an established i assessment method. The assessment method involves ranking each project t

based on its importance relative to public safety (e.g., safe shutdom, l

radiological release potential), personnel safety, plant

availability / capacity factor and economic incentive.

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The scheduling of projects takes into account projections for budgets and site manpower and engineering support requirements for up to five years, on an item-by-item basis covering all significant plant projects. The list represents that significant portion of the O.C.

work list and commitment list which is regularly modified and updated to meet changing conditions, including new NRC regulatory requirements. The final product of this program is the assessment of projects and the development of associated schedules as discussed below.

III. ASSESSMENT AND SCHEDULING A first step in the development of this program involves the identification and listing of significant open issues and their associated resolutions. Following initial screening and evaluation of all identified issues, those whose proposed resolution will require significant planning or resources are defined as proposed projects to be considered in development of the list of all projects approved and proposed for approval by GPUN for 0.C. over the next 5 years. With GPUN on a yearly budget cycle, proposed projects may not yet be formally approved and therefore are subject to changes with regard to funding approval. An assessment of all proposed projects is required to determine their appropriate value/ worth and relative priority. Upon completion of the project prioritization and subsequent ranking, the tasks are scheduled bascd on their assigned priority, available resources and schedular constraints. The projects are organized into Categories A, B and C based upon their origin. Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. The three categories are briefly described below:

Category A - All projects involving regulatory issues which have resolutions and/or issue resolution dates mandated by NRC rules, orders or license conditions.

Category B - Projects involving issues identified by the NRC and/or GPUN for which commitments have been made to NRC by GPUN.

The issue resolutions would result in significant a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements.

Category C - Other major projects, identified by GPUN or other regulatory agencies.

Projects and/or implementation dates in Category A may be modified or deleted only with prior approval of the NRC, in accordance with existing NRC regulations. Changes to project scope and/or completion dates in Categories B and C require notification to the NRC as described in Section V. Categories A, B and C, taken together, provide a basis for assessing the overall effects of changes to projects and/or schedules, and a departure point for discussion between the NRC and the licensee regarding such changes, as discussed below.

I V. ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS Project schedules for each planning cycle include required milestones for engineering, procurement and, where appropriate, regulatory review and approval. Inability to meet these milestones will require changes to previous plans and schedules.

Accordingly, an important aspect of GPUN's planning effort is the recognition that projects, project scopes, and scheduled completion dates will need to be modified or deleted at times to reflect chances in regulatory requirements, to accommodate those activities that GPUN finds necessary to improve plant efficiency and reliability, to incorporate the results of investfoations into issues, and to take into account delays resultino from events beyond GPUN's control l . The method used by GPUN for changing or deleting projects or scheduled completion dates is proceduralized.

V. GPUN AND NRC RESPONSIBILITIES The proper functioning of the Long Ranoe Planning Program requires that GPUN apply consistent criteria to the assessment of projects, monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a project scope or schedule change is needed. As set forth herein the NRC will treat all projects consistently and recognize that, when necessary, ranking, project scope, and/or scheduled completion date changes are based on a comparison of the project scope and/or completion date being changed to all projects, and also account for resource constraints.

A. PERIODIC UPDATING GPUN will update Categories A, B and C semi-annually and submit the revised listing of scheduled completion dates to the NRC, beginnino six months following NRC approval of this plan. The revised project listino will include the followino:

o Summarize progress in completino or implementing projects, o Identify changes since last update report.

o Summarize the reasons for project scope and/or schedule changes associated with regulatory requirements.

i The listing of projects in Categories A, 8 and C will contain sufficient detail to identify those projects with tasks and/or completion dates keyed to refueling outaoes. In such cases, a change in outage period (i.e., initiation or duration) shall not be considered a schedule change.

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B. CHANGES TO ISSUE RESOLUTIONS AND/OR SCHEDULES Changes to the project listing may arise from a variety of reasons, such as new projects identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (e.g., PRA findinos); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or GPUN actions, f Where it is necessary to add a new project or to change the schedule for a project, the following general cuidance will be utilized to the extent appropriate

o Assess the priority of the project relative to all existino i projects.

o Schedule the new or changed project to avoid reschedulina other l projects, if it can be reasonably achieved.

1 o Select a schedule for the new or chanced project which will help in maintaining an optimum integrated program of work, i Addition of activities to Category A requires GPUN to propose appropriate projects and/or completion dates and requires NRC approval of such proposals. Changes to previously established Category A resolutions and/or resolution implementation dates will be proposed only af ter GPUN has determined that changing Category l B and C items will not significantly assist in maintainino Category A without change; or that safety, resource or schedule pena 11 ties from rescheduling Cateoory B and C activities significantly outweich the consequences of a change in a Category A comp 12 tion date. As with proposals to add Category A

activities, proposals to change previously existino Category A l activities also requires NRC approval, t GPUN will inform the NRC Project Manager when serious consideration is given to requesting a chance in Category A. When i GPUN determines that a change in Category A is necessary, it will submit a written request for NRC approval in accordance with applicable regulations.

I Projects in Category B or C may be modified, deleted or

rescheduled, or new projects may be added to Category C by GPUN without NRC approval; however, GPUN will inform the NRC Pro.iect 4

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Manager once a chance, deletion, or addition to Cateaory B is necessa ry. GPUN will provide the NRC with written notification of chances or deletions of Cateoory B projects or completion dates associated with NRC initiated issues at a minimum in each semi-annual update but in any event at least 30 days prior to the scheduled completion date. Such notification will also include the reasons for the change and describe any compensatory actions which GPUN determines to be appropriate.

The change, addition or deletion in Cateaory B will go into effect upon evaluation by GPUN, unless the NRC, in writing, requests further explanation or discussion. NRC requests will be made within 15 days of receipt of GPUN written notification. In this event, discussions will be initiated to promptly develop a project scope and/or schedule which is mutually acceptable to GPUN and the NRC Pro,iect Manager while considering overall program impact. The written notification by the NRC will serve to extend the schedule date for the period of time required for such discussion. If a revised project scope and/or schedule is established in these discussions, such project scope and/or schedule will supersede the project scope and/or schedule set forth in Category B. The revised project scope and/or schedule will be incorporated in a revised Category B in the next update submitted to the NRC. If a revised proiect scope and/or schedule cannot be established in these discussions, GPUN changes to projects scope and/or schedule dates will be effective unless subsequently modified by NRC Order.

In the event of unplanned delays, delays which become manifest within 30 days of the scheduled completion date or in the event of circumstances beyond GPUN's control, GPUN shall provide timely notification to the NRC Pro,iect Manager of the revised pro.iect and/or schedule date and incorporate it in a revised Category B in the next update submitted to the NRC.

GPUN will provide notification of chanaes, deletions, additions or rescheduling of Category C pro.iects to NRC semi-annually. This is for information purposes.

VI. NRC REVIEW As pointed out in Section V.B above, chances to project scope and/or schedules are inevitable. Action required by the NRC is discussed below:

A. GPU NUCLEAR ORIGINATED CHANGES

1. Upon receipt from GPUN of a request for modification of Category A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request in accordance with applicable procedures.

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If the request for a modification of Category A is denied, NRC 2.

shall promptly inform GPUN and provide the reasons for denial.

3. NRC consideration of GPUN changes to non-Category A projects and/or schedules is covered by Section V.B.

B. NRC ORIGINATED CHANGES (CATEGORY A)

It is recognized that formal NRC regulatory actions (i.e., NRC i rules, orders, or license conditions) may: (1) impose a new regulatory requirement with a fixed date, or (2) establish a firm date for a previously identified regulatory requirement. In taking any such action, the NRC, to the extent consistent with its

-overall regulatory responsibilities and, unless public health, i' safety, or interest require otherwise, will take into account the impact of such action on GPUN's ability to complete effectively 1 the projects in Categories A, B, and C; and in consultation with GPUN, will try to minimize such impact. Although any formal

regulatory action (i.e., regulatory rule, order, or license condition) taken by the NRC will be effective in accordance with l Its terms without inclusion in Category A, the NRC and GPUN recognize the desirability of incorporating such action into Category A, particularly in order to incorporate at the same time any other appropriate chances in the total integrated assessment 4 program. Accordingly, once such formal regulatory action is taken I

(or earlier, if practicable), the NRC will provide GPUN a a reasonable opportunity to propose overall changes in the total integrated assessment program which would most effectively accommodate such requirements. Any resulting changes in projects in Category A will be (1) reviewed by the NRC, taking in account l the overall objective of the Long Range Planning Program to use

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available resources effectively, and (2) approved by the NRC in accordance with established procedures, and will thereupon be reflected in a revised Category A submitted by GPUN. GPUN will i inform the NRC of any resulting changes in Categories B and C in accordance with Section V above.

C. NEW NRC ISSUES (CATEGORY B) f The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure i revision or development, or (c) chances in facility staffing requi rements. With respect to issues which the NRC requests (1) scheduling information or (2) responses by a certain date, these issues may be included in Category B in accordance with the

! project priority resulting from GPUN assessment. Projects and/or

! schedule date commitments resulting from GPUN evaluation will form i

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the basis for discussions between the NRC and GPUN. As for the case of NRC-originated changes to Category A issues, the NRC will provide GPUN a reasonable opportunity to propose overall changes in the total integrated plan program which would most effectively accommodate such issues. Any resultino changes in the integrated plan program will thereupon be reflected in a revised Category B or C list submitted by GPUN.

D. INSPECTIONS AND AUDITS The Plan and the Lona Ranoe Planning Program implementation processes and procedures do not fall within the scope of GPUN's Quality Assurance Program or the requirements of 10CFR50 Appendix B. The existence of the Plan does not change the extent or nature of NRC inspection or audit activities which would be applied in the absence of the Plan. Specifically the management processes by which resource limits are established and allocated are not subject to detailed audit or inspection. GPUN will provide information as discussed in Section V for review and/or approval by NRC of the basis for the Category A and B project schedules.

Implementation of those projects are subject to inspection and audit as required by GPUN QA Program and NRC Regulations.

VII. MODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, all Plan revisions will be submitted for prior NRC approval in accordance with existing NRC regulations. The revisions will be made effective on a mutually agreed date subsequent to amendment issuance by the NRC.

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