NRC Generic Letter 1985-07
-, _ .-; -. _ _ _ _ _ F _ _ _ -g .- ~ ~., f. .* 9i ,' .- .-~ 'I.- .../ *$ a 7.UNITED STATESNUCLEAR REGULATORY COMMISSION 4e'WASHINGTON, D. C. 20555May 2, 1985TO ALL OPERATING REACTOR LICENSEESGentlemen: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 intentionswith respect to implementing integrated schedules, and (2) to solicit wide-spread industry participation in helping to place the priority for modificationsat 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 ArnoldEnergy Center (DAEC) operating license. This amendment incorporated a licensecondition which approved Iowa Electric Light and Power Company's "Plan forthe Integrated Scheduling of Plant Modification for the Duane Arnold EnergyCenter." Implementation of this program for DAEC represented the first steptoward development of an industry-wide approach to achieve more effectivemanagement of NRC-required plant changes and optimum uses of NRC and licenseeresources.Generic Letter 83-20 was issued on May 9, 1983 in the interest of informingthe industry of the DAEC amendment and inviting other utilities to participatein similar programs on a voluntary basis. So far, we have received onlysix applications from the industry, although experience with the DAEC plan hasbeen very favorable. Our experience indicates that a cooperative effortbetween the NRC and each licensee in scheduling completion dates for NRC-required plant modifications will benefit both the NRC and the licensee inthe utilization of their respective resources.The Nuclear Regulatory Commission's Statement of Policy and Planning Guidancefor 1985-states in part:"An integrated implementation schedule for new and existing require-ments reflecting relative priorities should be established foreach power reactor licensee."fl54t #; 5oq2.qIq The NRC is not able to support the effective management of safety-relatedmodifications and optimize the allocation of resources without the full supportand cooperation of the individual utility and plant management. To make thei 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 wemust approach the problem in a spirit of joint cooperation. We stand readyto work with each of you on a voluntary basis to develop plant-specific livingschedules for your operating reactors. Our intentions in some of the broadareas of consideration relative to the implementation of integrated schedulesare 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 mayhave additional concerns that warrant discussion or alternative approaches thatyou would want us to consider. Please feel free to contact the assigned NRCProject Manager to request a meeting with our staff to discuss the concept ingeneral or its application on your facility(s) in particular. We wouldappreciate receiving a response within 60 days that uses the format providedas Enclosure 2 to this letter.Thank you for your cooperation.
Sincerely,Hugh L .Thompson,9O., p~rq~torDi iion of Licensing lOf e of Nuclear Reac in Regulation
Enclosures:
As stated 4SummaryIn summary, the staff views the development of living schedules at operatingreactors to be a worthwhile endeavor that can provide positive benefits toboth the industry and the NRC, and with a good-faith joint effortbelieve that any potential pitfalls can be overcome. We stand ready to workwith each of you on a voluntary basis to develop plant-specific living schedulesfor 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 withregard to your operating reactors. You may have additional concerns thatwarrant 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 ingeneral or its application on your facility(s) in particular. You are requestedto 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 andBudget under clearance number , which expires .Commentson burden and duplication may be directed to the Office of Managementand Budget, Reports Management, Room 3208, New Executive Office Building,Washington, D. C. 20503.Thank you for your cooperation.
Sincerely,Darrell G. Eisenhut, DirectorDivision of LicensingOffice of Nuclear Reactor Regulation*See Previous Concurrence iArDL ORB-2
- AD/OR
- II"Do OELD '/ \JHannon:mcs DVassallo GLainas DGEisenhut C f4l ,,v%-9/ /84 9/ /84 9/ /84 9/ /84 /0/7S4 ENCLOSURE 1Formal License AmendmentFrom the regulatory standpoint, the intent of the formal license conditionis to confirm an agreement showing good faith on the part of the licensee andthe NRC in assuring satisfactory schedules for implementing necessary plantmodifications. These schedules are subject to change for good cause and withprior notification.' It is not intended, nor would it be appropriate, for theNRC to become involved in the licensee's financial planning and funding processesfor these plant improvements.Program ImplementationAs a minimum, the schedule should include all NRC-initiated plant modifications,whether mandated, (as in a rule, regulation, or order) or committed to by thelicensee (originating in a generic letter or IE Bulletin, for example).As part of the licensing review, the project manager will determine that theschedule scope is adequate. The extent to which a licensee wishes to includeadditional items not directly associated with plant modifications initiated bythe NRC, such as region inspection follow-up items or engineering analysisactivities, is purely a matter of the licensee's discretion and overall goalsfor their program.Licensee-initiated plant changes would only appear on the schedule as necessaryto permit an overall understanding as to how they are being integrated withthe NRC initiatives. For example, a licensee modification initiative that canbe installed independent of ongoing NRC work, required activities would not beexpected nor'need to appear on the integrated schedule at all. Further, if thelicensee found it necessary to revise a schedule for one of their plant bettermentmodifications, and the schedule could be revised without impacting the completiondate for NRC required activities, prior notification with written follow-up wouldbe unnecessary, even though the item did appear on the integrated schedule. Itshould be clear that the regulatory intent of the license amendment is to provideassurance that NRC required activities are scheduled and completed at the plantconsistent with an optimum utilization of resources under the constraintsapplicable to the specific licensee.Regional review of the program implementation would be geared to confirmingthat the program plan is carried out as approved. The schedule including thecompletion date may be changed as provided for in the plan. The plan describesthe framework for revising the schedule.Utility-Sponsored ProjectsFrom the regulatory standpoint, one of the fundamental underlying benefitsof adopting a preplanned, structured management approach to implementingplant changes is the added assurance that utility sponsored "plant better-ment" projects will have an opportunity to be scheduled and completed, alongwith NRC-initiated activities in the appropriate order of priority. The MPCdoes not intend to regulate the schedule for implementation of utility-sponsored
&41..-2projects, but rather to permnt an orderly process for such work to be scheduled andperformed. It appears that both regulatory and utility interests will beserved by the successful Integration of these two components, and we plan tomake every effort to ensure that the integrated scheduling process is structuredso that the Inclusion of licensee plant betterment projects will be viewed asa strong incentive rather than an impediment to utility cooperation.Prioritization MethodologyAlthough the staff generally uses some form of risk-cost benefit ratio methodologyfor the prioritization of new issues, we understand that a utility's prioritizationof existing requirements will be based on other factors (including safety) thatmay result in a different perception of relative Importance at a specific plant.This is precisely why we have not tried to prescribe a prioritization methodologyfor plant-specific application. It is here that we feel the utility should beleft to its own devices; no one else knows the plant better than the people whooperate it. Whatever methodology is best suited to an individual licensee isappropriate and will be considered.Practical ApplicationAs a result of our close work with Iowa Electric and Power Co. in connection withits integrated schedule plan, we have found it unnecessary to issue ConfirmatoryOrders for modifications addressed in Supplement 1 to NUREG-0737, including theSPDS, Control Room Design Review, Regulatory Guide 1.97, Emergency OperatingProcedures, and Emergency Response Facilitie I< .;14ENCLOSURE 2RESPONSE FORMAT -GENERIC LETTER 85-PLANT NAME:UTILITY:I.
INTENT
IONSa- ..A. Intend to work with the staff to develop anILSB. Have reservations that must be resolvedbefore developing ILSC. Do not presently intend to negotiate anILS with the staffD. Plan to implement an informal ILS onlyII. STATUSA. If you answered I.A above:1. Have you settled on a method forthe work at your plant(s)?prioritizingi-Circle One:YesNoIf yes, select best description:Engineering judgementAnalytic Hiearchy processRisk based analysisCost-benefit analysisOther (please describe) _ _ .If no, provide estimated datefor selecting a methodology:-Da-teorIf not presently available, provide estimateddate for scheduling the selection of amethodology:I ;2. What is your estimated date for making asubmittal to the NRC-orIf not presently available, planned date forscheduling a submittal to the NRC Ii I!:1 @f- --,.4B. If you answered I.B above:4I1.- Please explain your reservations on separate sheet(s)or provide your schedule for supplying an explanationSee separate sheet(s)orSeparate submittal scheduled for2. If available to meet with the staff to discuss yourconcerns, propose a time frame for such a meeting andprovide a contact that can make arrangementsContact/Time Frame_Phone Number_C. If you answered I.C(Date)1. Would you be willingdevelopment of an ILSCircle One:to meet with the staff to discuss thefor your facility(s)?YesNoIf yes, propose a time frame for such a meeting and providea contact that can make arrangements.ContactTime FramePhone NumberIf no, any constructive comments you have would be appreciated.III. ADDITIONAL ITEMSPlease make any suggestions you may have as to how a utility sponsoredavailability/reliability project might be credited for plant safetyenhancement. Provide additional constructive comments as appropriat LIST OF RECENTLY ISSUED GENERIC LETTERSGENERICLETTER NO. -SUBJECT DATE84-17 Annual Meeting to Discuss Recent Develop-ments Regarding Operator Training,Qualifications and Examinations 7/3/8484-18 Filing of Applications for Licenses andAmendments 7/6/8484-19 Availability of Supplement 1 to NUREG-0933'A Prioritization of Generic Safety Issues" 8/6/8484-20 Scheduling Guidance for Licensee Submittalsof Reloads that Involve Unreviewed SafetyQuestions 8/20/8484-21 Long Term Low Power Operation in PWR's 10/16/8484-22 Not used84-23 Reactor Vessel Water Level Instrumentationin BWRs 10/26/8484-24 Clarification of Compliance to 10 CFR 50.49Environmental Qualification of ElectricalEquipment Important to Safety for Nuclear 1Power Plants 12/27/8485-01 Fire Protection Policy Steering CommitteeReport 1/9/8585-02 Staff Recommended Actions Stemming From NRCIntegrated Program for the Resolution ofUnresolved Safety Issues Regarding SteamGenerator Tube Integrity 4/15/8585-03 Clarification of Equivalent Control Capacity 1/28/85For Standby Liquid Control Systems85-04 Operator Licensing Examinations 1/29/8585-05 Inadvertent Boron Dilution Events 1/31/8585-06 Quality Assurance Guidance for ATWSEquipment that is not Safety-Related 4/16/8585-07 Implementation of Integrated Schedules 5/02/85for Plant Modifications I'iMay 2, 1985-2-The NRC is not able to support the effective management of safety-relatedmodifications and optimize the allocation of resources without the full supportand cooperation of the individual utility and plant management. To make thetransition 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 wemust approach the problem in a spirit of Joint cooperation. We stand readyto work with each of you on a voluntary basis to develop plant-specific livingschedules for your operating reactors. Our intentions in some of the broadareas of consideration relative to the implementation of integrated schedulesare 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 mayhave additional concerns that warrant discussion or alternative approaches thatyou would want us to consider. Please feel free to contact the assigned NRCProject Manager to request a meeting with our staff to discuss the concept ingeneral or its application on your facility(s) in particular. We wouldappreciate receiving a response within 60 days that uses the format providedas Enclosure 2 to this letter.Thank you for your cooperation.
Sincerely,Original Signed byHuh a7 L. T hnni psn, Jr,Hugh L. Thompson, Jr., DirectorDivision of LicensingOffice of Nuclear Reactor Regulation
Enclosures:
As stated*SEE PREVIOUS CONCURRENCEORAB:DL ORB#2:DL* AD/OR:DL* OELD* DLJHannon:mcs DVassallo GLainas GCunningham HThompson9/ /84 9/24/84 9/25/84 10/22/84 4/lo/858504290442 Ig. Sf .-4-SummaryIn summary, the staff views the development of living schedul at operatingreactors to be a worthwhile enl1eavor that can provide positi benefits toboth the industry and the , t ;C --^ and with a good-fait joint effortbelieve that any potential pitfalls can be overcome. We and ready to workwith each of you on a voluntary basis to develop plant- ecific living schedulesfor 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 withregard to your operating reactors. You may hay additional concerns thatwarrant 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 ingeneral or its application on your facility ) in particular. You are requestedto 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 andBudget under clearance number , which expires .Commentson burden and duplication may be di ected to the Office of Managementand Budget, Reports Management, R m 3208, New Executive Office Building,Washington, D. C. 20503.Thank you for your cooperatio
Sincerely,Darrell G. Eisenhut, DirectorDivision of LicensingOffice of Nuclear Reactor RegulationDL B-2 DL OELDJHannon:mcs Vasallo G s OGEisenhut9/ /84 / 9t/84 9 /J84 9/ /84 9/ /84I .I*.