Implementation of Integrated Schedules for Plant Modifications (Generic Letter No. 85-07)

                                UNITED STATES
                           WASHINGTON, D. C. 20555

                                 May 2, 1985



          (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. 


                              Hugh L. Thompson, Jr., Director 
                              Division of Licensing 
                              Office of Nuclear Reactor Regulation 

As stated 

                                 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-

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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. 

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