ML20138B011

Rev 2 to Special Project Plan Spp 1028, Fuel Load Achievement

ML20138B011
Person / Time
Site:	Perry
Issue date:	11/20/1985
From:	Kline J, Shuster C, Stead F CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20138B000	List: ML20138B011 PY-CEI-NRR-0418, Provides Addl Info on Overall Mgt Commitment & Involvement in Control of Plant Activities Through Initial Licensing & Power Ascension Program to Full Power Operation.Issuance of OL for Unit 1 Requested for 851219
References
SPP-1028, NUDOCS 8512120174
Download: ML20138B011 (25)

Text

THE CLEVELAND ELECTRIC ILLUMINATING COMPANY PERRY NUCLEAR POWER PLANT SPECIAL PROJECT PLAN 1028 Fuel Load Achievement REVISION: 2 EFFECTIVE DATE: November 20, 1985 PROJECT DIRECTOR: h Frank R. Stead, Manager, Nuclear Engineering Dept.

APPROVED: W Man , Perry Plant Technical Dept.

APPROVED:

Mana P rry(Plant Operations Dept.

APPROVED:

/ n [A "d e',,

Manager, Nuc1 par Construction Dept.

APPROVED: h b 6 Manager, Nuclear Engi eering Dept.

APPROVED: A M Man [ger, Nuclear' Quality Assurance Dept.

8512120174 051210 PDR A ADOCK 05000440 PDR I -

SPP 1028 Rsv. 2 Pags 1 of 8 SPECIAL PROJECT PLAN 1028 -

FUEL LOAD ACHIEVEMENT

1.0 INTRODUCTION

The Manager, Nuclear Engineering Department has been designated Fuel Load Achievement Manager (FLAM). In this capacity the FLAM will advise the Vice President, Nuclear Operations Division, and initiate action to assure that existing organizations and programs achieve their objectives.

A working group with technical and management expertise in this area has been established to assist the Fuel Load Achievement Manager. Their charter is to accomplish the following:

Create and maintain one list of completion items as a vehicle to drive to fuel load.

Recommend a list of systems necessary for fuel load and identify potential deferral items.

Provide positive assurance that systems, areas, and programs needed for fuel load are ready to fulfill their intended function.

Provide recommendations to management for achieving fuel load.

Recommend actions necessary to focus resources on priority areas a.d eliminate unnecessary and redundant efforts.

See that action plans are developed and executed to achieve fuel load.

Fuel Load will be achieved by existing organizations using approved procedures and practices as described in the FSAR, the Quality Assurance Plan, and associated implementing documents.

2.0 PURPOSE

'This plan describes the methods for focusing project resources to achieve Unit 1 initial fuel load and establishes a special organizational element j to make recommendations and to monitor and report status.

3.0 SCOPE This plan applies to activities and organizations contributing to the completion of systems, areas and programs necessary to achieve Unit 1 initial fuel load. Priorities will be recommended or concurred with by the Fuel Load Achievement Manager and communicated through existing planning and scheduling documents.

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SPP 1028 Riv. 2 Piga 2 of 8

4.0 REFERENCES

4.1 Perry Operations Procedure 0502, "Special Project Plans."

4.2 Plant Administrative Procedure 0305, " Safety Evaluations."

4.3 PNPP Quality Assurance Plan.

4.4 Plant Administrative Procedure 0205, " Operability of Plant Systems."

4.5 Final Safety Analysis Report Section 14.2.10.

5.0 RESPONSIBILITIES 5.1 Fuel Load Achievement Manager (FLAM)

. Monitor critical activity completion, set priorities and initiate actions through the existing project organization to assure fuel load is achieved on schedule. .

. Make recommendations to facilitate Fuel Load Achievement to the Project Managers.

. Manage implementation of this Special Project Plan.

. Provide overall direction to the Fuel Load Achievement working group.

. Make decisions and facilitate resolution of problems experienced by the Fuel Load Achievement Working Group.

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5.2 Fuel Load Achievement Group Chairman

. Direct the day-to-day implementation of this special Project Plan.

. Manage the Fuel Load Achievement Working Group.

. Establish methods to provide Project management with status information that is complete, aceurate and timely.

6.0 PLAN IMPLEMENTATION The Fuel Load Achievement Special Project Plan will ensure the completion of: 1) plant systems; 2) plant areas; and, 3) programs necessary to achieve fuel load sud support low power testing. To meet the objective of timely completion, the following actions will be initiated in each of the areas identified:

1. Identifying the systems, areas and programs which will be required at Fuel Load to meet Technical Specification operability require-ments, meet regulatory requirements and support scheduled testing activities and operating conditions.

SPP 1028 Rsv. 2 Page 3 of 8 l 2. Determining the completion status of any remaining work associated with these priority systems, areas and programs.

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3. Focusing management attention and project resources on the remaining ,

work' associated with these priority areas.

4. Providing systematic verification that the required work for each ,

system, area and program is completed, i 5. Recommending for PPOD/PPTD Managers' and PORC approval the work that i may be deferred based on technical requirements and the potential I impact on future work completion.  !

Final approval of systems, areas and programs required for fuel load and  ;

4 the deferral of any work associated with these items will be made by the  ;

Managers PPOD/PPTD with PORC concurrence on safety systems. The Nuclear Safety Review Committee will provide an independent overview of this ,

process and, where necessary, provide recommendations to the FLAM. All i other activities associated with this Special Project Plan will.be accomplished using existing plant programs or additional controls which are established as management prerogative.  ;

i 6.1 Systems Completion Identification of the S'ystems needed to achieve fuel load will be accomplished as follows:

A list of systems required to be declared operable prior i 6.1.1

to fuel load will be prepared by the FLAM for the approval I of the PPOD/PPTD Managers. This list will include all

, systems and subsystems required by the PNPP Technical

' Specifications to be operable for Fuel Load. This list ,

will also identify those systems required by Technical i

Specifications to be operable for each facet of the sub- )

sequent low power testing. Safety systems required to

! support completion of scheduled testing activities but not j required by Technical Specifications will also be identi-

fled. PORC concurrence with these listings will be

required prior to fuel load.

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{ Nonsafety systems required to support plant activities i

during and immediately subsequent to fuel load will also i be identified and submitted for approval by the PPOD/PPTD l Managers, i The FLAM will provide to the Vice President, Nuclear j Operations Division, each of the plant system lists and make recommendations for adjustments to the plant com- -

plation priorities and schedules. .

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SPP 1028 R:v. 2 Pega 4 of 8 6.1.2 A System Operability Verification (SOV) checklist (Attach-ment 1) has been developed to provide for a systematic evaluation of a system's completion status in the follow-ing areas:

a. Construction

b. Testing

c. Design / Licensing

d. Procedures

e. Programmatic Items

f. Open Paperwork

g. System Configuration Completion of the SOV checklist will culminate in a declaration of system operability in accordance with PAP-0205, " Operability of Plant Systems." The PPOD/PPTD Managers will designate which systems will require com-pletion of the SOV checklist. If a system is not so designated, only the requirements of PAP-0205 are appli-cable.

6.1.2.1 A Responsible Engineer (RE) will be assigned by the Managers PPTD/PPOD to complete the SOV checklist for each designated system. The FLAM will designate a responsible General Supervising Engineer who will countersign with each of the REs for completion of the section for which that GSE is responsible. The GSE signing for the section will designate the name or title of a cognizant engineer who will assist each of the REs in the area under his cognizance and who will countersign with RE for that step. The cognizant engineer will advise and assist each responsible engineer in verifying completion of each step in the SOV checklist.

6.1.2.2 The RE and Cognizant Engineer signatures for I each section will indicate that the work identified on that section of the checklist has been completed or listed on the MDL with the appropriate restraint code in accordance with PAP-1103. The restraint code shall be determined by the RE subject to review by the FLAM.

6.1.2.3 The Responsible Engineer with the Section GSE's g approval may make pen and ink additions, deletions or clarifications to any step in the

k SPP 1028 R v. 2 Paga 5 of 8

. specific system's checklist. The reasons for the change will be made a permanent part of that s'y stem's checklist.

6.1.2.4 Disagreements between the RE and cognizant engineer will be resolved by the GSE responsible for the SOV checklist section. The FLAM will provide final resolution regarding completion of any step of the SOV checklist.

6.1.3 The RE will identify and list on the MDL all uncompleted l work required to make his system operable as soon as possible after beginning the SOV checklist.

6.1.3.1 The RE will meet with personnel responsible for completing this work and obtain commitments for completion. The completion commitment date will be listed on the MDL if the item is required for fuel load. ..

6.1.3.2 The FLAM will provide guidance and assistance to i

the RE in establishing appropriate priorities

for work completion.

6.1.3.3 The RE shall provide, or request assistance in obtaining, timely resolution of technical issues and clarification of regulatory requirements affecting his system. The RE shall request guidance / assistance from the FLAM or Managers PPOD/PPTD whenever necessary to meet scheduled completion of his system.

6.1.3.4 The FLAM or his designee shall periodically review each of the SOV checklists in progress to ,

verify satisfactory progress in completion of the SOV and shall provide guidance and assis-tance where necessary.

3 6.1.4 The RE will maintain the SOV Checklist and use the MDL to track work required for fuel load and work being deferred past fuel load. Work may not be deferred if the deferral

will prevent the system or subsystem from meeting the operability requirementy of PAP-0205 as applied to the activities to be performed at the next milestone. The FLAM and RE will review the MDL prior to presentation to  !

the Manager PPOD/PPTD for approval of the deferrals.

The FLAM may develop additional criteria to be used by the RE in determining which work items may be recommended for deferral. The FLAM or his des.!gnee will periodically review items being considered for deferral to ensure these criteria are being properly and consistently implemented.

SPP 1028 Rev. 2 Page 6 of 8 6.1.5 The RE with the assistance of the cognizant engineers will provide justification to the Managers PPOD/PPTD for the items in each system which are being recommended for deferral. This will include the identification of the plant completion milestone which will require completion of the deferred work.

6.1.5.1 Items being recommended to the PORC for deferral shall be evaluated in accordance with the requirements of PAP-0305. If a safety evaluation is required, the PORC review will be obtained during the review of the SOV checklist or earlier at the discretion of the FLAM.

6.1.5.2 Each RE and GSE involved in completing system operability checklists will receive training and be designated to perform Safety Evaluations in accordance with the requirements of PAP-0305.

6.1.6 SOV Checklist Section VI, "Open Documentation," will be completed after Sections I, II, III, IV and V. The RE ,

J will sign this section based on his determination that all work required for fuel load is complete.

6.1.7 SOV Checklist Section VII, " System Configuration," will be completed by a Unit Supervisor or Shift Supervisor. The System Responsible Engineer's signature is not required in s

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Section VII.

6.1.7.1. The SOV Checklist may be approved by the Managers PPOD/PPTD in accordance with Sections 6.1.4 and 6.1.5 prior to the completion of Section VII of the checklist. However, the system will not be declared operable until the SS OR US completesSection VII and signs the SOV Checklist Coversheet.

6.2 Areas Completion 6.2.1 The FLAM shall identify appropriate criteria and develop a i list of plant areas required to be complete to support fuel load and subsequent low power testing. This list shall be approved by the Managers PPOD/PPTD prior to fuel load.

6.2.2 An area readiness checklist (Attachment 2) has been developed to provide for a systematic evaluation of area completion in the following areas:

a. Fire Protection

b. Housekeeping .

c. Area Deficiencies

,- w - r SPP 1028 v - Rtv. 2 Page 7 of 8

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.- This checklist will he expanded to include any special requirs nen'.syf the part;tv.ular area being made ready.

6.2.3 A responsible individual will be assigned ~to complete the area readiness checklist. This individual will have primary responsibility for ensuring all itema on the checklist are verified and that any remaining work is completed. Operations and/or maintenance shall concur

_ ?' with area readiness prior to fuel load.

6.3 Programs Completion Programs or activities of a programmatic nature with a potential for impacting fuel load shall be investigated and evaluated under the direction _of the Fuel Load Achievement Manag2r. A list of these programs shall be complied and the status updaced in accordance with

, Section 7.0. Recommendations for improvement should be forwarded to f- '

s the resp w ible manager or general supervisor.

7.0 STATU RkPORTING

'7 ,1'

.- Project Completion Status

, o Status lists of all activitics, (such as outstanding commitments, open NRC findings, open nonconformance reports, etc.) nhall be combined into one overall list that accurately depicts'the status of work that must be performed before specified milestones (for example: fuel load, criticality, 5% power, compintion' ef power ascension, or first refueling outage). This list should be updated weekly, or more frequently if required. The FIN! vill provide status lists to appropriato project management.

7.2 System, Area, Program Status s .

( The status of system, area'and program completion should be reported to the Fuel I,oad Achievement Group Chairman on a routine basis and compared to projected Schedules and objectives. Any activity behind scheduleshould,bef.nva.,stigatedandcorrectiveacticastaken.

- sq .r 8.0 REVI'HONS f

.- Revisions to this special project plan shall be prepared, reviewed .

-%- " approved, and distributed in the same manner as the original plan.

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,m Revisions to the system operability verification checklist andI the area completion checklistwy be performed as described in Step 6.1.2.3.

% n s, 9'. 0 QUAI {TY ASSURANCE AUDITS ,,

This special project plan monitors, coordinates and reports upon line t programs which contain quality verification; therefore, quality assurance -

m audits of sthis plan are not required.

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SPP 1028 Rav. 2 Page 8 of 8 10.0 TRAINING Responsible Engineers, Responsible GSEs and assigned cognizant engineers and other personnel designated by the Fuel Load Achievement Manager j should be trained in the following:

Responsibilities Reporting Requirements Methods for resolving conflicts Overview of plan PAP-0205, " Operability of Plant Systems" PAP-0305, " Safety Evaluations" Guidelines for Work Deferral 11.0 PLAN TERMINATION This special project plan will terminate on a system basis after declara-tion of system operability or when directed by the Vice President, Nuclear Operations Division. Specific work items coordinated and tracked by this plan will continue to completion in accordance with the approved procedure for that activity. These items will be tracked to completion.

Documentation compiled to support recommendations to PORC, as part of this special project plan, shall be forwarded to and retained by PORC in accordance with approved procedures for PORC activities.

12.0 ATTACHMENTS

1. System Operability Checklist, Revision 0.

2. Area Completion Checklist, Revision O. ,

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DW237/J/10/rmk

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Rsvision 2 i

ATTACHMENT 1 SPECIAL PROJECT PLAN 1028

, r FUEL LOAD . ACHIEVEMENT d

SYSTEM OPERABILITY VERIFICATION CHECKLIST System Name r ..

The outstanding work associated with this system has been identified and is listied on the Master Deficiency

( List. -Deferral of this work until the scheduled completion milestone has been evaluated and found acceptable.

e.

Manager, PPOD j

)

f i

Manager, PPTD

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System has been declared operable in accordurce '

with the requirements c PAP-0205.

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Unit Supervisor e <  ?

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A, Revision 2, November 20, 1985 l

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Rsvision 2 System Operability Verification Checklist System:  :  :

The System Responsible Engineer and the assigned Cognizant Engineer for each of the areas listed below have verified completion of work on system listed above. Work on this system which has not been completed is identified on a list attached to this checklist. These items have been scheduled for com-pletion prior to the plant completion milestone identified next to each item and are recommended for deferral until that time. Work items being recom-mended for deferral have been reviewed in accordance with PAP-0305, " Safety ,

Evaluations."

System Responsible Engineer

• Completion Area General Supervising ..

Engineer j I. Construction II. Testing III. Design / Licensing i

IV. System Procedures V. Programmatic Items VI. Open Documentation i

• PPTD Technical Section i

. Pags 1 Rsv. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Cognizant

• System RE Engineer I. Construction Completion:

1. Construction Turnover exceptions which are specific to this system have been completed or are listed on the MDL with the appropriate restraint code.

2. N-5 Packages for Piping systems have been completed or are listed on the MDL with the appropriate ..

restraint code.

3. N-5 Packages for Hangers have been completed or are listed on the MDL with the appropriate restraint code.

4. DELETED - Bulletin 79-14 evaluations have been completed.

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• Designated by the Responsible GSE for this Section.

t i __ __ _ , - . , , ---- - - - - - - ~ - - - - - - - - ~ ~

Pags 2 Rsv. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Cognizant

• System RE Engineer II. Testing Completion:

1. Test Program Review Committee (TPRC) results approval has been obtained for the following:

a. Preoperational/ Acceptance Tests (STE)

b. Completed Test exceptions and addenda (STE)

c. Test exceptions and addendum not completed are listed on the MDL with the appropriate restraint code.

(STE)

2. Management Procedure Review Team follow-up actions completed or are listed on the MDL with the appropriate restraint code.

3. Commitments identified during commit-ment search (DG-33) are satisfied or listed on the MDL with the appropriate restraint code.

4. Nuclear Test Section Field Questions have been answered or listed on*the MDL with the appropriate restraint code.

(STE)

5. Required System As-Built composite drawings have been approved and issued or are listed-on the MDL with the appropriate restraint e code.

• Designated by the_ Responsible GSE for this Section.

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Paga 3 Rsv. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Cognizant

• System RE Engineer II. Testing Completion (Continued):

6. Setpoint Methodology Program - the effect of instrument accuracy on acceptance criteria has been evaluated and required actions completed or listed on the MDL with the appropriate restraint code.

7. IC&R Testing has been completed or listed on the MDL with the appropriate

, restraint code. .

(STE)

• Designated by the Responsible GSE for this Section.

Paga 4 4

1 Rsv. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST 4

System:  :  :

Cognizant

• System RE Engineer t

III. Design /Licensina:

1. Human Factors evaluations (NED)

! specific to this systaa have been completed. Required actions completed or listed on the MDL with the appropriate restraint code.

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2. NRR Issues specific to this system >

are resolved and required actions completed or listed on the MDL with ..

the appropriate restraint code.

3. Commitment Tr'acking System open

, items have been reviewed by the System Engineer. Completed commitments closed and required actions completed or listed on j- the MDL with the appropriat.e restraint code.

4. DELETED - Remaining Bulletins and Circulars are tracked on the Regional Enforcement Action / Concern Tr.acking System. .

l S. DELETED - Remaining IE Items are tracked on Regional Enforcement i- Action / Concern Tracking System.

6. Open Deficiency Analysis Reports (DAR) have been evaluated and corrective actions affecting this system have been completed or listed on the appropriate '

i restraint code.

i 7. Open Engineering Design Deficiency.

Reports (EDDR) evaluated for impact on this system. Open EDDRs affecting this system are listed on the MDL

-with the appropriate restraint code.

• Designated by the Responsible GSE for this Section.

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Page 5 Rev. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

4 Cognizant

• System RE Engineer III. Design / Licensing (Continued):

8.a All required design data and sub-sequent change documents (ECNs, FVAs, FDIs, and FDDRs), required j for this system have been issued and completed or are listed on the MDL with the appropriate restraint code.

8.b FCRs and DCPs required for this system have been issued and completed or are listed on the MDL with the appropriate restraint code.

. 9. Fire Protection issues specific to this system have been resolved and work completed or listed on the MDL with the appropriate restraint code.

10. DELETED - Nuclear Safety Review Com-mittee items are covered elsewhere on this checklist.

• Designated by the Responsible GSE for this Section.

Page 6 Rsv. 2 I l

l SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Cognizant

• j System RE Engineer I IV. System Procedures:

Y.

1. System Operating-Instructions are

' approved, available and reflect current plant configuration.

a. SOI i

b. ELI

c. VLI

d. ONI

, e. ARI

2. Periodic Test Instructions available 3

ard current or listed on the MDL with the appropriate restraint code.

3. Survsillance Instructions available and current or listed on the MDL with the appropriate restraint code.

4 4. Special Project Plan 501 - Procedure review for commitments has been I completed for the procedures required for this system. Commitments have i been verified as incorporated or listed on the Commitment Tracking 4 . System.

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• Designated by the Responsible GSE for this Section.

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Pags 7 Rav. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Cognizant

• System RE Engineer V. Programmatic Items:

1. System Calibrations Complete per the NTS/ PPD Program and the Instrument Calibration Program has been reviewed by the System Engineer and is in effect for this system.

2. DELETED - Completion of required surveillance testing is covered by SOV Checklist Item VII.6.

3. Repetitive Planned Maintenance Program for this system has been ...

reviewed by the System Engineer and is in effect.

4. DELETED - PPMIS review is now SOV Checklist Item VI.2.

5. Vendor advisories affecting this system have been evaluated and required actions completed or listed on the MDL with the appropriate restraint code.

6. _Qutstanding Set Point Change Requests have been resolved or listed on the MDL with the appropriate restraint code.

7. Outstanding Nonconformance Reports affecting this system have been closed or listed on the MDL with the appropriate restraint code.

8. Outstanding Condition Reports

' affecting this_ system have been closed or listed on the MDL with the appropriate restraint code.

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• Designated by the Responsible GSE for this Section.

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Pegs 8 Rev. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

System RE VI. Open Documentation:

1. SOV Checklist Sections I, II, III, IV and V have been completed. The attached MDL identifies remaining work items affecting this system.

These MDL Items have been evaluated per SPP 1028 Sections 6.1.4 and 6.1.5; have been assigned appro-priate restraint codes; and are being recommended to PORC for-deferral. .

System RE

2. PPMIS has been reviewed for maintenance / repair items. Items which could effect system operability have been closed.

System RE i

• Designated by the Responsible GSE for this Section.

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Pags 9 Rev. 2 SYSTEM OPERABILITY VERIFICATION CHECKLIST System:  :  :

Shift Supervisor or Unit Suocrvisor VII. System Configuration:

1. Material Foreign Item and Lifted Leads and Jumpers:

a. Log reviewed and unnecessary items removed.

b. Operations Program approval for MFI/LL&J items to remain in system. Includes review for operational impact.

c. Tag Audit / System search for orphan tags.

d. Temporary Power removed or included in the LL&J Program.

3. Safety (Danger) Tags:

( a. Logs reviewed and unnecessary tagouts removed.

b. Remaining tags approved under ,

operating program.

c. Tag audit.

4. Electrical and Valve lineups have been completed. (Required by PAP-0205, Section 6)

5. Technical Specification Limiting Condition for Operations Log reviewed.

• Designated b'y the Responsible GSE for this Section.

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ATTACHMENT 2 i

SPECIAL PROJECT PLAN 1028 FUEL LOAD ACHIEVEMENT AREA READINESS CHECKLIST Area:

Manager, PPOD l e

Manager, PPTD i

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Pags 1 I

AREA READINESS CHECKLIST I. HOUSEKEEPING Responsible Engineer

1. Temporary Equipment Protection removed (last).

2. Temporary Equipment (scaffolding, tools, hoses, cables, etc.) removed unless identified with a current orange tag.

3. Area posted (Cleanliness Zone and requirements) in accordance with PAP-0204.

4. Area cleared of debris, equipment wiped down and swept.

5. Floor drains clear and strainers in place.

II. FIRE PROTECTION

1. Fire doors in' stalled and labeled.

2. Manual firefighting equipment is in fire stations and extinguishers are in place.

3. Fire seals are completed.

4. Fire walls ar'e complete.

5. Pyrocrete complete.

6. Appendix R work is complete in the area.

III. HARDWARE

1. Seismic Clearance Violations

a. Completed--Deficiencies corrected or included on the attached list and recommended for deferral. Work being deferred has been evaluated for poten-tial impact on cost / schedule.

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Paga 2

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AREA READINESS CHECKLIST Responsible Engineer

2. Raceway Spacing Violations

a. Completed--Deficiencies corrected or included on the attached list and recommended for deferral. Work being deferred has been evaluated for potential impact on cost / schedule.

3. LCK REAP

a. Completed--Deficiencies corrected or included on the attached list and recommended for deferral.

4. Area Completion List / Structural MDL items completed. List exceptions on attached sheet.

5. Complete following items:

a. Architectural Finish work (ceiling tile, wallboard, etc.)

b. Painting

1. Nuclear coatings completed (Y/N) 2.

OSHA painting

3. Architectural painting complete.

6. Groundstraps installed (equipment, cable trays, and conduit).

7. Insulation completed.

8. System preoperational/ acceptance tests of:

a. Airlocks

b. Emergency lighting 8

DW237/H/16/rmk l

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l THE CLEVELAN D ELECTRIC ILLU MIN ATIE G COMPAN Y MEM0RAHDUM TO V. Concel ROOM FROM F. R. Stead DATE November 27, 1985 '

System RE PHONE 5267 ADOM E210 SUBJECT Deferral Criteria Special Project Plan 1028, " Fuel Load Achieve m ent", Sections 6.1.3 and 6.1.4 state

, that the Fuel Load Achievem ent Manager "will provide guidance and assistance to the RE in establishing appropriate priorities for work completion". In addition, the FL A M "m ay develop additional criteria to be used by the RE in determining which work items m ay be recom mended for deferral".

The guidelines listed in this memo are to be used for setting priorities and selecting work items to be deferred past each completion milestone. In accordance with SPP 1028, deferralite m s are subjeet to review by the FL A M and approval by the P O R C.

Syste ms required to be operable for fuelload (m ode 5), initial criticality (m ode 2) and prior to exceeding 5 % power have been identified (Memo: From: M. D.

Lyster/J. J. Waldron, To: All Managers, Dated: N ove m ber 11,1985). This list of required systems was based upon Surveillance Test Requirements, Periodic Test Requirem ents, Security Surveillance requirem ents, Technical Specification Requirem ents or the need for the system to support a required system. Where this list identifies partial syste m requirem ents, the Syste m Engineer should use the guidelines in this memo to help deter.mine which items are required and which m ay be deferred.

All preoperational test activities which may be deferred past fuelload and the required com pletion milestone have been identified. These ite ms include syste m defmals in the October 11 letter to the N R C, test exceptions listed in the Nove mber 2,1985 letter to the N R C, and Test Exception M DL ite ms as discussed with the N R C resident inspector. A list of the test ite ms approved for deferralis available from the NTS Ad min. Group.

The following guidelines are to be used to select work items to be completed prior to and after fuelload and to select the appropriate completion milestone. The guidelines are applicable to all plant syste ms, areas and programs:

L An item must be com pleted if:

a) Required to m ake the syste m operable in accordance with the definition of operability in P AP-0205; or, - '

b) Required by Technical Specifications (Unless a Tech Spec exemption has been obtained from the N RC based upon unique conditions associated with power ascension testing); or, c) Required to successfully complete Surveillance or Periodic Test Require m ents; or, d) Required to m eet regulatory requirements such as fire protection, equipm ent qualification, seismic design criteria, etc., for a required syste m or component, unless an exemption has not been obtained; or, e) Required to be operable to support the operation of a required syste m or ,

to support fuelload, scheduled testing or other scheduled 6... .olution '

during or im mediately following fuelload, l

,. O IL An ite m m ay be deferred if:

a) Not needed du: to plant conditions prior to the c :,m pletion milestone (e.g. no fission product activity or decay heat); or, b) Not requird to m eet regulatory requirements prior to the com pletion milestone; or, c) Not required to m ake the syste m operate as designed or to m eet Technical Specification require m ents; and, d) Cannot be performed because necessary conditions can be established only later in the power ascension program; or, e) Deferral does not pose a safety hazzard to personnel or equipm ent.

IIL Deferred work activities shall:

a) Be achievable prior to the proposed completion milestone; and, b) Be listed on the M DL with the appropriate restraining code; and, c) Be evaluated for the need for compensatory action with all compensatory actions listed on the M D L with the appropriate restraint code; and, d) Be evaluated for the cost / schedule impact of completing work prior to versus after the proposed milestone.

Special Project Plan 1028, Section 6.1.5.1 requires that ite m s being recom m ended to P O RC for deferralshall be evaluated in accordance with the requirem ents of P AP-0305. This is not intended to require that an individual P AP-0305,

" Applicability Check" be completed for each M DL item. Ite ms m ay be grouped at the discretion of the syte m engineer and a single " applicability check" perform ed.

If a safety evaluation is required for any item included in the group, a separate safety evaluation should be perform ed for each ite m, or logical grouping of ice m s.

cc: Site M anagers All GS O/GSEs FLAG Members

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