NRC Generic Letter 1983-20
{e ~jW's4 -_ _ ; -.----------- -'.May i, 1983TO ALL OPERATING REACTOR LICENSEES AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:
SUBJECT: INTEGRATED SCHEDULING FOR IMPLEMENTATION OF PLANT MODIFICATIONS(GENERIC LETTER 83-20)On May 3, 1983 the Comnission issued Amendment No. 91 (Enclosure 1) tothe Duane Arnold Energy Center (DAEC) operating license. This amendmentincorporates a license condition which approves Iowa Electric Light andPower Company's "Plan for the Integrated Scheduling of Plant Modificationsfor the Duane Arnold Energy Center."The Nuclear Regulatory Comnission's statement of policy and planningguidance for 1983 endorses' the concept of establishing implementationschedules for new and existing requirements which reflect the importanceof the safety requirement to the public health and safety and the licensee'sability to complete the necessary engineering, evaluation and design.Enclosure 1 represents the first step towards development of an industry-wide program to establish realistic schedules for implementation of safetyimprovements, both utility-initiated and NRC-required, -at operathng- reactors.Enclosure 1 is provided for your information and possible use. Althoughthis enclosure represents an approach which is acceptable at present tothe NRC, other approaches may be acceptable and will be considered ifyou elect to adopt such a plan.Please contact your Project Manager if you have any questions on this matter.
Sincerely,Darrell G. Eisenhut, DirectorDivision of Licensing8305090659 Office of Nuclear Reactor RegulationV.
Enclosure:
As Statedcc: w/enclosureSee Next Page .I 4. _~UNITED STATESNi._LEAR REGULATORY COMMISSIO._4 i WASHINGTON, D. C. 20555flay 3, 1983Docket No. 50-331Mr. Lee LiuPresident and ChiefExecutive OfficerIowa Electric Light and Power CompanyP. 0. Box 351Cedar Rapids, Iowa 52406
Dear Mr. Liu:
The Commission has issued the enclosed Amendment No. 91 to FacilityOperating License No. DPR-49 for the Duane Arnold Energy Center (DAEC).This amendment incorporates a license condition in response to yourapplication dated November 12,.1982, as revised in subsequent discus-sions between the NRC and your staff.-This license condition requires Iowa Electric Light and Power Company(IELP) to follow its "Plan for the Integrated Scheduling of PlantModifications for the Duane Arnold Energy Center" (the Plan) and theterms therein for modifying the schedules. The revised Plan has beendiscussed with your staff and is enclosed as Attachment 1 of Enclosure 2to this letter.Iowa Electric's Integrated Scheduling Program has been the subject ofextensive discussions between the NRC and your staff in an effort todefine an acceptable approach for implementation of this unique programto establish realistic schedules for modification of the Duane Arnoldfacility. Iowa Electric is to be commended for its initiative indeveloping such an integrated program for scheduling safety modificationsat the DAEC. We hope that the resultant improved control and manage-ment of available resources will facilitate more systematic and timelyimplementation of such modifications.We believe these discussions have been most productive and, as noted inthe enclosed evaluation of your proposed program, conclude that yourprogram is acceptable. However, the implementation of this program re-presents only the first step towards development of an industry wideprogram to assure that necessary safety issues are implemented in atimely fashion at all operating reactors. As experience is gained withyour program and that of others, program changes may be necessary toincorporate additional or modified features which will enhance programeffectiveness and assure timely implementation of safety issues. As fMr. Lee Liu. -.2-discussed with your staff, in view o-! recent staff actions and thenecessity of awaiti-ng final staff review in a number ofoareas, theschedules contained in your Novembe- 12, 1982 application may requiresome revisions.Copies of the Program Evaluation and Notice of Issuance are also en-closed.incerely,hbL reectorDivision of LicensingOffice of Nuclear Reactor Regulation
Enclosures:
1. Amendment No. 91 to DPR-492. Program Evaluation3. Noticecc w/enclosures:See next pageO..
.Mr: 1.ed LiuIowa Electric Light & Power Companycc:Mr. Jack Newman, EsquireHarold F. Reis, EsquireLowenstein, Newman, Reis and Axelrad1025 Connecticut Avenue, N. W.Washington, D. C. .20036Office for Planning and Procramming523 East 12th StreetDes Moines, Iowa 50319Chairmian, Linn CountyBoard of SupervisorsCedar Rapis, Iowa 52406!owa Electric Light & Power CompanyATTN: D. L. MineckP. 0. Box 351Cedar Rapids, Iowa 52406U.S. Environmental Protection AgencyRegion VII OfficeRegional Radiation Representative324 East 11th StreetKansas City, :issouri 64106U.S. Nuclear Regulatory CommissionResident Inspector's OfficeRural Route 1Palo, Iowa 52324James G. KepplerRegional Administrator, Region IIIU.S. Nuclear Regulatory Commission799 Roosevelt RoadGlen Ellyn, IL 60137 UNITED STATESC> .NUCLEAR REGULATORY COMMISSIONWASHINGTON. D. C. 20555ZIOWA ELECTRIC LIGHT A POWER COMPANYCENTRAL JUWA > COOPERA;+/-VECORN BELT K ER COOPERATIVEDOCKET NO. 50-331DUANE ARNOLD ENERGY CENTERAMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 91License No. DPR-491. The Nuclear Regulatory Commission (the Commission) has found that:A. The application for amendment by Iowa Electric Light and PowerCompany, et al, dated November 12, 1982 complies with the standardsand requirements of the Atomic Energy Act of 1954, as amended(the Act), and the Commission's rules and regulations set forthin 10 CFR Chapter I;B. The facility will operate in conformity with the application,the provisions of the Act, and the rules and regulations of theCommission;C. There is reasonable assurance (i) that the activities authorizedby this amendment can be conducted without endangering the healthand safety of the public, and (ii) that such activities will beconducted in compliance with the Commission's regulations;D. The issuance of this amendment will not be inimical to the commondefense and security or to the health and safety of the public;andE. The issuance of this amendment is in accordance with 10 CFR Part51 of the Commission's regulations and all applicable requirementshave been satisfied.
-2 -2. Accordingly, the license is amended by addina a new paragraph 2.C(6)to read as ofolows:2.C(6) i. The "Plan for the Integrated Scheduling of Plant Modificationsfor the Duane Arnold Energy Center" (the Plan) submitted onNovember 12, 1982 (as revised) is approved.a) The Plan shall be followed by the licensee from and afterthe effective date of this amendment.b) The licensee is required to maintain current revisionsof, and provide reports regarding, schedules associatedwith the Plan in accordance with the terms of thePlan and failure to do so shall constitute a violationof this license condition.c) Changes to dates for completion of items identified inSchedule B do not require a license amendment. Datesspecified in Schedule A shall be chanced only in accor-dance with applicable NRC procedures. Failure tocomplete items listed in the ;chedules in accordancewith dates there specified shall not consititute aviolation of this license condition but may constitutea violation of any regulations, orders or licensecondition imposing such date.2. This license amendment shall be effective until May 3,1985, subject to renewal upon application by the licensee.3. This license amendment is effective as of the date of issuance.FOR THE E AR REGULATORY COMMISSIONDomenic B. Vassa1 CifOperating Reactors Branch #2Division of LicensingDate of Issuance: May 3, 1983 at s UNITED ST ATESNL` '-EAR REGULLATORY COMMISSIOPWASHINGTON, 0. C. 20-551-
- INTEGRATED SCHEDULING PROGRAMEVALUATION BY THE OFFICE Qn NUCLEAR REACTOR REIGULATIONSUPPORTING AMENDMENT ND. c- -9 FACILITY LICENSE NO. DPR-49IOWA ELECTR:: LIGHT AND POWER COMPANYDUANE ARNOLD ENERGY CENTERDOCKET NO. 50-3311.0 IntroductionBy letter dated May 28, 1982, Iowa Electric Light and Power Company(IELP) submitted a request (initial submittal) for approval of afive-year integrated program for implementing self-imposed and NRC-imposed modifications of the Duane Arnold Energy Center (DAEC).The basic objective of Iowa Electric's (the licensee) program is toenable the utility to obtain better control and management ofavailable resources and to perform required activities in a mannerwhich would enhance plant safety by (1) improved control of safetyrelated modifications and (2) more prompt implementation of thesemodifications.On August 11 and August 12, 1982, a meeting was held with IELP and its contractor,Technology for Energy Corporation (TEC), to obtain additional information regardingIELP's submittals and discuss in further detail the licensee's program. Thismeeting focused on discussing points identified in a preliminary review of thelicensee's proposed program and obtaining additional information regarding thedetails of the methodologies and assumptions used in developing the IELP programto determine the reasonableness of the schedules proposed by the licensee.As a result of these discussions, the licensee simplified and streamlinedits submittal. Iowa Electric requested in a November 12, 1982 applicationthat a requirement-to follow its "Plan for the Integrated Scheduling of PlantModifications for the Duane Arnold Energy Center" (the Plan), which wassubmitted with the November 12, 1982 application, be added as a conditionof the operating license for the DAEC.Further discussions between the NRC and IELP identified additional areas wherefurther clarification of and revisions to Iowa-Electric's November 12, 1982submittal were desirable. The licensee agreed to revise its Plan (Attachment 1)accordingly in response to staff conments.2.0 Program DescriptionThe program developed by Iowa Electric utilizes a computerizedscheduling technique which integrates the engineering, procurement,and installation of planned NRC required modifications, and resultantplant operator retraining requirements, with Iowa Electric's. own requirements for plant modifications, mainternance, refueling,and operations. The computer model used by the licensee identifiescritical paths and considers the interrelationships apong projectsand the constraints imposed by engineering support and site manpowerlimitations. The program proposed by the licensee appears to becapable of adapting schedules in the event of unforeseen delays inprocurement or installation, strikes, changes in fuel cycle schedules,etc. In addition, the program has considered the necessity ofcoordinating plant modifications with revisions to plant operatingprocedures and operator retraining.The licensee's program, as originally presented, proposed implementationdates as program goals and provided for semi-annual reporting to theNRC of utility progress with regard to implementation of each of theNRC required items and identification of project schedule slippages.One critical assumption made in the IELP proposed program is that "NRCwould not require additional plant modifications during its five yearperiod." However, Iowa Electric has incorporated into its programcurrently proposed NRC requirements which are likely to be approved forimplementation on operating reactors. Proposed requirements (or re-quirements planned but not finalized, such as an upgraded suppressionpool temperature monitoring system) were included for implementation inthe IELP program in anticipation of NRC requirements for these items.In addition, the licensee assumed for purposes of its program that theguidance contained in SECY 82-111 concerning Emergency Response Facilitieswould become requirements.Iowa Electric indicated in its May 28, 1982 submittal some of the boundaryconditions associated with its program. For example, the program assumesin-house engineering support of some 50 personnel, which necessitateddeferral of several lower priority design intensive work items. A peaksite day-shift manpower loading of some 555 personnel (1985) was set basedon worker efficiency, craft availability, and effective management ofthese resources on-site.The assumed in-house engineering support of 50 personnel does not includesome 148,000 man-hours of engineering support outside of IELP'sflechanica-l/Nuclear Engineering Department during the five-year periodof interest. Assuming approximately 1800 man-hours per work year,this is equivalent to an average of about 17 additional man-years peryear over the five year period.Although not specifically accounting for future new requirements (otherthan those currently envisaged in its present proposed program) theutility's program is structured so that additional required plantmodifications can be integrated into the overall program to identifythe impact of such new requirements on the overall schedule.
-3 -The Plan submitted by the licensee ;-ntifies two categories of modificationsSchedule A identifies schedules for r-r:ifications established by existing Ruleor Order. Schedule B identifies sch jles for completion of:1) regulatory items (of either g'neric or plant specific nature) identifiedby NRC which would result -.- either a) plant modifications, b) procedurerevisions, or c) changes to facility staffing requirements and which havean implementation date committed to by Iowa Electric, and;2) items perceived by IELP as prospective NRC requirements, and;3) all'major DAEC tasks resulting from mandates of agencies other thanNRC and IELP initated system upgrades for availability improvement.3.0 Evaluation3.1 ImDlementationSince any major new requirements could result in significant schedulemodifications, IELP suggested in its initial submittal that this program notbe implemented by Oeder or License Condition. Rather, the licensee suggestedthat it "report semi-annually to the NRC as to its progress with regard tothe NRC required items, and as to any slippage which threatens to delaycompletion of such items beyond the goals specified...'Such a program would not provide for sufficient accountability and leaveNRC with no means of having assurance that NRC-identified regulatory issues aresatisfied insofar as completion dates are concerned, short of revokinc approvalof the program and subsequent issuance of Orders. In subsequent discussionswith licensee representatives, they indicated that an Order or LicenseCondition would be acceptable, provided that this Order or License Con-dition made provisions in some fashion for flexibility in- the event thatcertain requirements could not be done in a timely fashion due to circum-stances beyond Iowa Electric's control. New requirements would be incor-porated into the licensee's program after appropriate implementaion dateshave been established.The licensee's November 12, 1982, submittal (as revised) incorporates an applicationfor amendment to incorporate a license condition requiring that Iowa Electricfollow the Plan and permitting the licensee to make changes to the Plan andits schedules for certain category of items in accordance with the provisionsof the Plan. We have reviewed the licensee's Pl-an and have determined that:1) Chances to schedules for completion of modifications imposed by Rule orOrder (Schedule 'A' completion dates) will continue to be sought through theexemption or Order-date extension process (For example, Iowa Electric's existinorequest for exemption from the schedular requirements of 10 CFR 50.44 regardinghydrogen recombiner capability.) 2) Schedules for completion of other modifications(Schedule 'B' completion dates) are identified and provisions aremade in the Plan to require the utility to provide the NRC with prior writtennotification of changes to schedule B completion dates to provide the opportunityfor further explanation or discussion of such changes. 3) Provisions are made
-4 -in the Plan for incorporating new or anticipated regulatory items intoSchedules A and B as these requirements are identified by NRC and/or formalizedby Rule or Order. The licensee's proposal to incorporate a condition into theDAEC operating license which requires Iowa Electric to follow the Plan providesan appropriate mechanism to assure that NRC is informed as to whether requiredsafety modifications are performed in a timely manner. At the same time, thePlan provides a suitable mechanism for changes to completion dates (due tounforseen circumstances) for modifications not imposed by Rule or Order andfor keeping the NRC informed of such changes. Thus, the'degree of flexibilityneeded to assure effective program implementation is provided while at thesame time assuring that NRC's responsibilities are not compromised.Numerous modifications, principally NUREG-0737 items, not specificallyidentified in the IELP program initially submitted, were considered by thelicensee as part of its "base load' of work requirements and grouped togetheras one or two line items in its forecasted work requirements. The licenseeidentified in its November 12, 1982 submittal each planned NRC-requiredmodification as an individual line item for inclusion in the implementingvehicle.Semi-annual reports of utility progress towards meeting NRC required modifica-tions would be provided as proposed by the licensee.Findings:The proposal by Iowa Electric to add a license condition requiring the utilityto follow the Plan provides a suitable mechanism for implementation of IELP'sintegrated plan. Completion dates imposed by Rule or Order are unaffected bythe lowa Electric proposal. As new requirements are identified and/or formalizedby the NRC provisions are made in the Plan to incorporate these into Schedule Aor B, as appropriate. Provisions are made in tne Plan to permit the licenseeto develop new dates for other modifications (Schedule B) and to keep theNRC informed of such changes.Each planned NRC required modification is individually identified in the Schedules.3.2 Prooosed SchedulesAttachments 2 and 3 provide Iowa Electric's revision of its initially proposedschedule to include dates for completion of all presently known IELP-planned andNRC-required modifications over the next five years.For modifications imposed by Rule or Order (other than the schedule requirementsof the Interim Hydrogen Control Rule) the utility proposes completion byrequired dates.With respect to NUREG-0737 items, the utility also proposes completion of allNUREG-0737 items originally scheduled for completion by 1/1/82 before startupfrom its 1983 refueling outage as required by Crder issued on March 14, 1983.This is acceptable in view of the responsible efforts demonstrated by thelicensee and the unforeseen circumstance responsible for the delay. The licenseehas shown that adequate compensatory measures are in place. The followingdiscusses the acceptability of other completion dates proposed by IELP in itsprogram.
-5 -W ith respect to items-covered by SECY -i-l, schedules were developed beforethese items were approved by the Comer: ion for implementation on operatingreactors. In view of the responsible :orts demonstrated by the licensee,and the lead times necessary for b-cc;ng, procurement, and installations of thesework items, the schedules propcs d by IELP appear reasonable.Other NRC-identified modifications whose proposed completion datesextend as late as 1986 are essentially limited to modifications associatedwith the issue of "Control of Heavy Loads." The licensee is conductingan extensive evaluation of this issue to determine the need formodifications to make the DAEC polar crane single-failure proof,demonstrating its responsible effort towards resolution of this issue.As a compensatory action until modifications to this crane (if any) arecompleted, Iowa Electric has made procedural revisions and improvements toprovide an increased level of safety. We find that the necessity forconducting detailed engineering evaluations of potential modifications to thecil-r cra .<iuies a 1985 schedule for these modifications.Certain schedules for completion of modifications to the Duane Arnold facilityare keyed to completion of required NRC staff reviews that would result in sub-sequent approvals. For example, the schedule for certain modifications re-quired by 10 CFR 50.48 is determined by the date of completion of thestaff review. In addition, certain modifications which will be necessaryto satisfy the licensee's proposed radiological effluent technical speci-fications, have been proposed to be completed by the licensee on a scheduledetermined by completion of the staff review of this issue. Completion datesfor such items are identified in Attachment 3. In view of the necessity ofawaiting completion of staff reviews on these issues, this is acceptable.Finally, it is recognized that with issuance of Generic Letter 82-33 pertainingto SECY 82-111, the schedules contained in the November 12, 1982 applicationmay require some revisions. Additionally, the licensee is awaiting final staffaction on the review of Iowa Electric's exemption requests associated withAppendix R requirements. However, a schedule update will be provided inaccordance with the terms and provisions of the Plan.FindingsThe completion dates for modifications proposed by the licensee in its November 12,1982 submittal show IELP's responsible efforts towards satisfying. NRCrequirements. Where the dates proposed by the licensee extend more thanabout three years in the future, initial action will have been taken bythe licensee to provide a high level of safety. Modifications whichextend into 1986 or 1987 are of such a nature that full compliancecould not reasonably be expected to be attained much sooner. Dates forcompletion of modifications not yet determined due to the necessity ofawaiting staff approval will be included in the licensee's plan afterthe requisite staff reviews are complete.
-6-Based upon our review of the information contained in IELP's submittals, thedates proposed by th6 licensee in its November 12, 1982 application.appearreasonable.4.0 SummaryBased on the considerations addressed herein, we find that:1) The proposal by Iowa Electric that its plan be implemented by aLicense Condition requiring the utility to follow the Plan isacceptable.2) The licensee's proposal that changes to implementation dates imposedby existing Rule or Order will continue to be sought through theexemption or order date extension process is acceptable.3) Schedules for new requirements should be established for the DAEC on aplant specific basis.4) Based upon our review of the dates proposed by the licensee in its November 12,1982 submittal, the dates proposed by the licensee appear reasonable.5.0 Environmental ConsiderationWe have determined that the amendment does not authorize a changein effluent types or total amounts nor an increase in power leveland will not result in any significant environmental impact. Havingmade this determination, we have further concluded that the amendmentinvolves an action which is insignificant from the standpoint ofenvironmental impact and, pursuant to 10 CFR 551.5(d)(4), that anenvironmental impact statement, or negative declaration and environ-mental impact appraisal need not be prepared in connection with theissuance of this amendment.6.0 ConclusionWe have concluded, based on the considerations discussed above, that:(1) because the amendment does not involve a significant increase inthe probability or consequences of an accident previously evaluated,does not create the possibility of an accident of a type differentfrom any evaluated previously, and does not involve a significantreduction in a margin of safety, the amendment does not involve asignificant hazards consideration, (2) there is reasonable assurancethat the health and safety of the public will not be endangered byoperation in the proposed manner, and (3) such activities will beconducted in compliance with the Commission's regulations and theissuance of this amendment will not be inimical to the commondefense and security or to the health and safety of the public.Date: May 3, 1983Principal Contributor: Kenneth T. Eccleston Plan for the Inter-_ ed Schedul'na of PlantMod ficat_ ons f the Du-ane Arnol! Frnerag enterI. IntroductionIowa Electric Light and P?-:-r Company (CIELP) has developed acomprehensive procram whi-- will enable the Company toeffectively manage imple.:-tation of certain modificationswhich have been requ4re.. or proposed by, the NRC, as wellas other measures tc. enhance plant safety and reliabilitywhich have been identified by the Company. A description ofthe program, identified as "Integrated Program for Modifica-tion of the Duane Arnold Energy Center (DAEC)," was submit-ted to the NRC on May 28, 1982, by Iowa Electric letter LDR-82-0140.This program was developed to coordinate and schedule allnecessary work at the DAEC, whether mandated by NRC oridentified by IELP and others. The program objectives areto (1) conform to regulatory requirements; (2) providesufficient lead times for modifications; (3) minimizechanges for operators; (4) assure training requirements arefulfilled; (5) effectively manage financial and humanresources; and (6) specify the framework for changes todeveloped schedules.This program reflects that fiscal and manpower resourcesare finite and that a limit on the onsite manpower is neces-sary. The procram integrates all presently planned work atDAEC over a nominal five year period to ensure that in-dividual tasks are effectively scheduled and coordinated.It provides a means for new-requirements to be accommodatedtaking into account schedule and resource constraints.The purpose of this document is to describe the plan used toimplement the program (the "Plan"). It describes how theprogram functions, mechanisms for changing the Plan andupdating it, and the interactions of NRC and licensee staffsunder the Plan, and its associated schedules.II. Summary of Program DevelopmentThe program is based on a computer generated listing of over600 items of prioritized work. The listing takes intoaccount projections for budgets and site manpower andengineering support requirements for five years, on an item-by-item basis covering all plant modification activities.It represents a total DAEC work list and commitment listwhich is regularly mddified and updated to meet changingconditions, including new NRC regulatory requirements. Thefinal product of this program is the development of schedulesas discussed below.
-2 -III. Schedulinz-,_on cr 5et~c- of the complete wcrk listing, Iowa Electricdetermined that detailed and integrated schedules wererequired for the major work items. Upon completing thecomprehensive listing of major work items, the tasks wereorganized into Schedules A and B using critical path methodology(CPM) for selected work items. CPM schedules identify critical pathsin the work effort for each task, which in turn, enables prompt ad-aptation of schedules to meet contingencies such as strikes, delaysin procurement or installation or modification of ftuel cycle schedules.Both Schedules are briefly described below:Schedule A -Schedule B -All items which have imple-mentation dates mandated by NRCrules, orders, or license con-ditions.Regulatory items (of either ageneric or plant specific nature)identified by NRC which have im-plementation dates committed toby Iowa Electric and which wouldresult in either a) plant modi-fications, b) procedure revisions,or c) chances in facility staf-fing requirements; oritems perceived by Iowa Electricas prospective NRC requirements; ormajor DAEC tasks resulting from mandatesof agencies other than NRC and IELP-initiatedsystem upgrades for availability improvement.Schedule A dates may be modified only with the priorapproval of NRC, in accordance with existing NRC procedures.Changes in Schedule B dates require written notification toNRC as described in Section V. Schedules A and B, takentogether, provide a basis for assessing the overall effectsof changes to schedules and a departure point for discussionbetween NRC and the licensee regarding such changes, as dis-cussed below.IV. Schedule ModificationsAn important aspect of Iowa Electric's planning effort isthe recognition that the attached schedules will need to be
-3 -rmodifies at times to reflect changes in reculatory re-cirements, to acconmodate those activities that IowaElectrlc :,nds necessary t: ir-m--ve -la.nt eff ciency anozreliability, and to take -_o account delays resulting fromevents beyond IELP's cor -1. I is important that theprocedure used by Iowa ELectric for changing the schedulesbe documented.*/ In ¢-dition, the NRC must play a role inthe oversight of the scheduling process (and must, in fact,judge the acceptability of proposed date changes in ScheduleA). Accordingly, it is important that the NRC's role, andthe interaction between the NRC and IELP, be clearly defined,as discussed below.V. IELP ResponsibilitiesThe integrated schedule requires that IELP monitor theprogress of all work undertaken, manage its activities tomaintain the schedule, and act promptly to take necessaryactions when a schedule change is needed.A. Periodic UDdatingIELP will upda.te Schedules A and B semi-annually and submit therevised schedules to NRC, beginning six months following NRCconcurrence in the Plan. In addition to updating the schedules,!ELP will:° Summarize progress in implementingNRC requirements concerning plantmodificationsO Identify changes since the lastreporto Summa-ize the reasons for schedulechanges associated with regulatoryrequirements.B. Changes to SchedulesChanges to the schedules may arise from a variety of reasons,such as new work activities; modifications in the scope of*/ Schedules A and B will contain sufficient detail toidentify those items with completion dates keyed tofuel cycle outages. In such cases, a change in outageperiod shall not be considered a schedule change.
-4 -scheduled work; probiems in delivery, procurement, etc.;chances in NRC rules and regulations; or other NRC or IELPactions.Where it is necessary to add a new work item or to change the schedulefor an item, the following general guidance will be utilized to theextent appropriate:Assess the priority of the work itemand its safety significance* Schedule the new or changed item toavoid rescheduling other items, ifit can be reasonably achievedAlter Schedule B items before ScheduleA itemso Select a schedule for the new or changeditem which will help in maintaining anoptimum integrated program of work.As noted above, no changes will be made in Schedule Awithout prior NRC approval. Should a change become neces-sary, it will only be proposed after Iowa Electric hasdetermined that rescheduling of non-NRC required work itemseither will not significantly assist in maintaining ScheduleA without change; or that the safety, cost or schedulepenalties from rescheduling non-NRC required work sig-nificantly outweigh the change in a Schedule A completiondate.Iowa Electric will inform the NRC Project Manager whenserious consideration is given to requesting a change inSchedule A. When IBLP determines that a change in ScheduleA is necessary, it will submit a written request for NRCapproval in accordance with applicable procedures.Work items in Schedule B may be rescheduled or work itemsmay be added to Schedule B by Iowa Electric without NRCapproval; however, IELP will inform the NRC Project Managerwhen serious consideration is given to changing the schedulefor or adding an item in Schedule B.In addition, at least 30 days (unless otherwise agreed to by theNRC Project Manager or unless circumstances beyond IELP's control arisewithin 30 days of the scheduled date) before IELP adopts a
-5 -change for an iter in Schedule £ (as define; in Section III above),it will provide the NRC writter notification thereof, includingthe reasons therefor and any c7-pensatory actions instituted. Ifnot provided 30 days in advanc- such notification will be providedby IELP as promptly as practi.< le. NRC may request further explanationor discussion concerning sucr. :nange. In this event, discussions willbe initiated with the Nr' Zroject Manager. However IELP changes inscheduled dates will be effective unless subsequently modified by IELP.VI. NRC ReviewAs pointed out in Section V.B above, changes to the sched-ules are inevitable. Action required by NRC is discussedbelow:A. Iowa Electric Originated Changes1. upon receipt from IELP of a request for modi-fication of Schedule A, NRC will act promptly(consistent with resource availability and priorityof other work) to consider and decide on the re-quest in accordance with applicable procedures.2. If the request for a modification of Schedule Ais denied, NRC shall promptly inform Iowa Elec-tric and provide the reasons for denial.3. NRC consideration of IELP changes in non-Schedule Aitems is covered by V.B.B. NRC Oricinated Chances (Schedule A)It is recognized that formal NRC regulatory actionsmay: (1) impose a new regulatory recuirement with a fixeddate or (2) establish a firm date for a previously identi-fied regulatory requirement. In taking any such action theNRC, to the extent consistent with its overall regulatoryresponsibilities and, unless public health, safety, or interestrequire otherwise, will take into account the impact of suchaction on IELP's ability to complete effectively the itemson Schedules A, and B, and, in consultation with IELP,will try to minimize such impact. Although any formalregulatory action taken by the NRC will be effective inaccordance with its terms without inclusion in Schedule A,the NRC and IELP recognize the desirability of incorporatingsuch action into Schedule A, particularly in order toincorporate at the same time any other appropriate changesin the total integrated schedule program. Accordingly, oncesuch formal regulatory action is taken (or earlier, if
-6 -practica.le), the NRC will provide IELP a reasonable op-portunity to propose overall changes in the total integratedschedule program which would most effectively accommodatesuch requirements. Any resulting changes in items inSchedule A will be approved by NRC in accordance withestablished procedures, and will thereupon be reflected in arevised Schedule A submitted by IELP. IELP will inform theNRC of any resulting changes in Schedule B in accordancewith Section V. above.C. New NRC Issues (Schedule B)The NRC may, from time to time, identify new regulatoryissues which may result in a) plant modifications, b) procedure'revision or development, or c) changes in facility staffingrequirements. For issues as to which NRC requests schedulinginformation, these issues may be included in Schedule B in accordancewith the date commitment developed in discussions between IELP and theNRC staff. As for the case of NRC-originated changes to Schedule Aitems, the NRC will -provide-IELP a reasonable opportunity to proposeoverall changes in the total integrated schedule program which wouldmost effectively accommodate such issues. Any resulting changes inintegrated program schedules will thereupon be reflected in a re-vised Schedule B submitted by IELP.VII. modifications to the PlanThe licensee and the NRC recognize that the Plan itself mayrequire future modifications. Accordingly, IELP will draftproposed modifications and submit a license amendmentappolication for approval of the proposed changes. Thechanges will be made effective upon amendment issuance byNRC.
Attachment 2Siltllllt Aa)J4t6attMJA'.l lOU I HG Sch"MK Idl h H l oEl Plant Unique AII&ylislI ,., i pllvigtL (LlI'q i i f i c Li onApp. R Alternate *ShutdownNUIR dG-073/I,) 3 11. 1? j~g ki-.llIelertnce '1I8. 1( I 'I. t .9 I I, I(i) [l 0 ll Jf; -Al11f&AL L I I A A IA A i I I A I A -, t A --,FL CCLE I fU (L(L CYCtl O IFUU -cUc I aa9-Ll(Note I I*x_U_k--U-Ich,,lr l. 11 C l' IuIer I.t I'II( " OI t. Db ted Harth IJ. 1911te .r &It C. I .nyt 10B1 If0 tL.* t d t*.: ' y itl % J It* a1.--r wI h end of *I euue..I Wj *Ite JC.II /0lllI A 41"'8 '
Attachment 3 . 384 8ts 81A I I A I ALW I ACA S U. ~ FU(L EVELI I IUrL CYCL( U fULL. CYCLE I -LSriiS PJIGRADL)CLASS A teXII ICRU N4ULI& CMRt IN(.* bINate IIArf I --*HA,1011,11W ULi COW1.LU( (Note 2)(WIAgkuU1r Xi IJV(4 I VINI H9 (Note 3)B'f~ Is; ---4 lCumpdlet wilth exception of approval of lechnical Specification (hange)(1'I AI II I 14I 1 14 14I~ p MyII 10 1,*H4Al N (other than ALT. shutdowd) (Note 4)s:.PaIIIIIG 0111a) I.C.1 IEO1"s*sDv Loiig Terii Mods *MA, I i ( 0~l.H----- -- ---- _ _ --l'H( I Wfil \/_PAOC W HI N I A140 I NhS IAt IA I I 014 U RIA(I i~I u:IM II 1IIIG ( HAHI ( t Attachment 3 page 2 of 2SCIIIUC C aasI 11.3* .A04I I A.atAI EL________ *_ _ *_*___X______,___ _e_*_____a______._,__,_c._._ _.,_.___IIli)I AM SIFUll CYCLE 1 I~~4FULL CVCL[ B. c~jl-. FULL CWCL( 9CNSIiRUCr [Al/PP COMLIF'UR FACILIJYRICI)CATE VAX CLMiPUJIfRUPGRADE PLAHCF PROMSI COflPUFRA (PPC)II .[ I1WOJ-lfCAJIONSVleatSIMtOtATOR (POINI JAI )RPS (AAAMO~j CRIP) (POr(NTIAL)----- -!IsI GNINSTALL14)I t I .It IIM tlm 11 %'#l i U Itl AI IWW I HirCh 1 983 Is susnce of DAEC IIlcentIt'j---.Lieti IAjmitcat Ion iubiultted Au-just 29. 19)9 with later revlstoniII ii.aiii ) ,w~ti o to be Is nMont ts fol lowing NICC Approval ofItd,,,ltal Slitt.111ctiIon chainge.hlite Z.~D~~~ based upon IL~P iub4414tal. flossl sahedule Is dcependenItupon hIRC review Anid ipproval of submiattAl.Plate J. 1t,r-hl,.I shows 4inly Ihmose siodIfIcatIons resolved for (tAIC. Ft4naI.sb.,e dtgorndetait upon 14MC/l10. ftuslutiun of outsta OWta issues.k.I4 To be completed 9 month$ after, N1RC acts onexemp)1tionl request.Il,-te F All ,..tk S 3...irtc3I r-ctjp pircure..w t,. told lIn stat Ietloi ofs-, .' t.,v iwilid ie. Cr-aime 111tsit ar iul itling Cr jne Des ign(i. .I s ie hte I liob d with. enda of relued I.I. outa89l..11.'0111:1 3 10 4. a,
,; 7590-01UNITED STATES NUCLEAR REGULATORY COMMISSIONDOCKET NO. 50-331IOWA ELECTRIC LIGHT .AND POWER COMPANY, ET ALNOTICE OF ISSUANCE OF AMENDMENT TO FACILITYOPERATING LICENSEThe U. S. Nuclear Regulatory Commission (the Commission) has issuedAmendment No. 91to Facility Operating License No. DPR-49 issued to IowaElectric Light and Power Company, Central Iowa Power Cooperative, and CornBelt Power Cooperative, which revises the License for operation of theDuane Arnold Energy Center, located in Linn County Iowa. The amendment iseffective as cf its date of issuance.The amendment incorporates a license condition requiring the licenseeto follow its "Plan for the Integrated Scheduling of Plant Modifications forthe Duane Arnold Energy Center."The application for the amendment complies wtth the standards andrequirements of the Atomic Energy Act of 1954, as amended (the Act), and theCommission's rules and regulations. The Commission has made appropriatefindings as required by the Act and the Commission's rules and regulationsin 10 CFR Chapter I, which are set forth in the license amendment. Priorpublic notice of this amendment was not required since the amendment doesnot involve a significant hazards consideration.The Commission has determined that the issuance of this amendment willnot result in any significant environmental impact and that pursuant to10 CFR 51.5SN)(4) an environmental impact statement or negative declarationand environmental impact appraisal need not be prepared in connection withissuance of this amendment.
IFor f urtler details with. respect. this act-.^ see (1) the applicationfor Lend..nt dated mve.ber 12, 1-S2_2) -ed-Pen: No. 91 to License No.DPR-49, and (3) the Coamission's rea Ed Program Evaluation. All of these iteemnsare available for public inspection at the Co-mission's Public Document Room,1717 H Street, N. W., Washington, D.C. and at the Cedar Rapids Public Library,426 Third Avenue, S.E., Cedar Rapids, Iowa 52401. A copy of items (2) and (3)may be obtained upon request addressed to the U.S. Nuclear Regulatory Commission,Washington, C.C. 20555, Attention: Director, Division of Licensing.Dated at Bethesda, Maryland, this 3rd day of May 1983.FOR THE NUCLEAR REGULATORY COMMISSIONVernon L. Rooney, Acting C efOperating Reactors Branch 12Division of Licensing