Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
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
widespread industry participation in helping to place the priority for
modifications at individual plants so as to permit a well founded
integration of implementation 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 info ming
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
requirements reflecting relative priorities should be established for
each power reactor licensee."
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The NRC is not able to support the effective management of safety-related
modifications and optimize the allocation of 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 LiS 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, Jr., Director
Division of Licensing
Office of Nuclear Reactor Regulation
Enclosures:
As stated
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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,
ever though the item did appear on the integrated schedule. Tt 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 chances 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
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projects, but rather to permit 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 license 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.
