Darlington NGS Integrated Implementation Plan (IIP) Change Control Process Principles

Transcription

1 RETENTION: P ASSOCIATED AR: November 7, 2014 File No.: CD#: NK P NK38-CORR MR. F. RINFRET Director Darlington Regulatory Program Division Canadian Nuclear Safety Commission P.O. Box Slater Street Ottawa, ON K1P 5S9 Dear Mr. Rinfret: Darlington NGS Integrated Implementation Plan (IIP) Change Control Process Principles The purpose of this letter is to submit, for CNSC acceptance, the Integrated Implementation Plan (IIP) Change Control Process Principles (Attachment 1). While changes to the IIP are not planned, the breadth and complexity of the work could require some ongoing refinement. In the case where changes may be necessary, these variances would be managed in accordance with these IIP Change Control Process Principles. The attached describes the principles to be used between the CNSC and OPG to manage potential changes to IIP commitments. In addition, the principles for reporting the progress on IIP work are outlined in the attached. Based on these principles, OPG will prepare and provide to the CNSC by March 31, 2015, a formal process for the control, justification and documentation of any changes to the IIP as required by CNSC Regulatory Document RD-360 Life Extension of Nuclear Power Plants. A Regulatory Management Request (REGM) will be initiated to track this action. Ontario Power Generation Inc., This document has been produced and distributed for Ontario Power Generation Inc. purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written permission of Ontario Power Generation Inc. Associated with OPG-STD-0031, Correspondence Standards OPG-TMP-0007-R004 (Microsoft 2007)

2 Mr. F. Rinfret NK38-CORR CNSC acceptance of the lip Change Control Process Principles is requested by December 19, If you have any questions, please contact Mr. Imtiaz Malek, Director, Nuclear Safety - Refurbishment Engineering at , extension 5668 or imtiaz.malek@opg.com. Sincerely, Dietmar Reiner Senior Vice President Nuclear Projects Ontario Power Generation Brian Duncan Senior Vice President Darlington Nuclear Ontario Power Generation Attach. cc: Mr. A. Ling - CNSC (Darlington) OPG-TMP-0007-R004 (Microsoft 2007) Page 2 of 2

3 ATTACHMENT 1 IIP Change Control Process Principles

4 Attachment 1 - IIP Change Control Process Principles Principle 1: Principle 2: There will be no intent (goals or objectives) changes to IIP scope as accepted by the Commission. Prior CNSC approval/concurrence for implementing non-intent changes to the IIP or delays in the IIP schedule for IIP commitments is required. Requests by OPG for non-intent changes or delays to the IIP schedule will include documented reasons for the proposed change including impact to safety, overall impact to schedule and compensatory or mitigating measures where required. Exception: Although executing On-Line IIP work with high priority will be in place at all times, only by exception, emergent work may take precedence. In such cases, IIP On-Line work would be rescheduled into the next cycle with no further delays and will not require prior CNSC approval/concurrence. These delays will be reported annually in the IIP Progress Report. This only applies where the IIP scheduled date will be missed. Timely Change Requests (if Required) Principle 3: Written request for approval/concurrence of any proposed non-intent changes to the IIP or delays to the IIP schedule for EA related IIP commitments or IIP commitments scheduled in a Refurbishment Outage or Non-Refurbishment Outage will be provided to the CNSC in a timely manner; CNSC response to these requests is expected in a timely manner. Change Requests (if Required) Principle 4: Written request for approval/concurrence of any proposed non-intent changes to the IIP or delays to the IIP schedule for IIP commitments that are not associated with EA or outage work activities will be provided in an Change Request (e.g. in October), with the expectation that the CNSC will respond in a timely manner. These change requests will include any IIP changes for work activities which will not be completed in the reporting year and any known changes to work activities beyond the reporting year. IIP Progress Report Principle 5: An IIP Progress Report will be prepared to summarize the status of IIP work activities, IIP Line Items and Change Requests for the reporting year (January through December). IIP work activities and line items will be identified as A - 1

5 Complete by OPG when all work has been completed to satisfy the requirements and Closed once concurrence from CNSC is obtained. The report may also request closure of completed work for the reporting year. The IIP Progress Report will be provided to the CNSC in the first quarter of the following year (i.e., March). The first IIP Progress Report will be provided in March 2016 for the 2015 reporting period (see Figure 1); IIP Progress Reports will include the following information where applicable: 1. IIP work or IIP Line Items identified as Complete. 2. IIP work activity completion references. 3. IIP work or IIP Line Items identified as Closed. 4. IIP changes that are pending CNSC approval/concurrence. 5. On-Line IIP schedule delays resulting from emergent work. 6. Previously agreed changes to IIP work activity schedule Licence 2015 Licence Change Hearing Hearing Request 2016 Change Request Change Request Change Request Change 2017 Request IIP Figure 1: Schematic IIP of IIP Change IIP IIP Requests IIP & IIPProgress IIP Reporting IIP Progress Report Progress Report Progress Progress Report Report Progress Progress Report Progress Report Progress Report Progress Report Report Report Vacuum Building Outage Unit 4 Outage Unit 1 Outage Unit 3 Outage Unit 2 Refurbishment Outage Licence Hearings IIP Progress Report Change Requests Timely Requests A - 2