U-600583, Forwards Measures Taken to Control Initial Test Program Activities Deferred Past Fuel Load.Appropriate Reviews & Controls Exist to Prevent Performance of Deferred Activities from Adversely Affecting Other Activities
| ML20195E744 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/03/1986 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-600583, NUDOCS 8606090211 | |
| Download: ML20195E744 (7) | |
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'U-600583 L30-86 ( 06 -03 )-L 1A.120 ILLINDIS POWER 00MPANY CLINTON POWER STATION, P.O. BOX 678. CLINTON, ILLINOIS 61727 June 3, 1986 Docket No. 50-461 ERIORITY Rcutirl, Mr. James G. Keppler cr o_nm Regional Administrator L_L i ~~
Region III pre 3 +/
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,1_C f U. S. Nuclear Regulatory Commission 799 Roosevelt Road L
b, k. l-Glen Ellyn, Illinois 60137 FI Subj ect :
Clinton Power Station Management of Activities Deferred Past Fuel Load
Dear Mr. Keppler:
In Illinois Power Company (IP) Letter U-600469, " Initial Test Program Activities Projected for Completion After Fuel Load", to Mr. H. R. Denton, Director of Nuclear Reactor Regulation, dated March 12, 1986, IP requested to defer some preoperational tests and included the technical justification for these deferrals.
Illinois Power has reviewed the deferred preoperational tests and believes that these tests can be completed after Fuel Load without placing undue burden on startup personnel and plant operators.
The measures taken to control the deferred activities are described in the attachment.
These measures will assure that the deferred activities are planned and scheduled in conformance with the needs of startup and power ascension of Clinton Power Station (CPS).
Appropriate reviews and controls exist to prevent performance of the deferred activities from adversely affecting other activities.
The controls include the initial planning of the activities, a review by the Project Control Center (PCC) and Plant Staff of the effect on startup tests and routine Main Control Room (MCR) activities, specific approval of these activities by the Director of Plant Operations, and a daily briefing of the MCR operators.
Sufficient manpower and resources will exist to perform the deferred activities and sufficient management controls for the deferred activities will be in place.
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U-600583 L30-86( 064)3 )-L 1A.120 If you have any questions concerning this information, please contact me or Frank Spangenberg of my staff.
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all-Vice President TLR/kaf Attachment cc:
R. M. Bernero, Director, Division of BWR Licensing Dr. W. R. Butler, Director, BWR Project Directorate No. 4 B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Illinois Department of Nuclear Safety
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Attachment to U-600583 Measures Taken By Illinois Power Company to Control Activities Deferred Past Fuel Load at Clinton Power Station I.
Introduction Construction of Clinton Power Station (CPS) is essentially complete and preoperational testing is about 90% complete.
Illinois Power Company (IP) intends to defer some of the remaining activities that are not essential to the safe conduct of fuel loading or low power testing until after Fuel Load.
The purpose of this report is to describe the measures IP will use to control activities deferred past Fuel Load to ensure that: (1) the activities are performed at the proper time and in the proper sequence to support the safe startup and operation of CPS; and (2) performance of the activities will not adversely impact the safety of concurrent activities related to startup and operation of CPS.
II.
Management Controls for the Deferred Activities A.
Plant Manager Reporting to the Vice President - Nuclear is the Plant Manager who is in charge of the Plant Staff and has responsibi-lity for operation of CPS.
After Fuel Load, in order to establish a single line of authority to ensure that activities will be performed in accordance with clear and consistent direc-tions, the Plant Manager will have responsibility for controlling all activities in the plant, including activities performed by other groups.
As a result, the Plant Manager is knowledgeable of the activities being performed in the plant and has sufficient authority to halt or defer performance of those activities in order to protect any ongoing startup and power ascension work.
Thus, the Plant Manager has direct control over the number of workers, their work assignments, and their work locations.
In addition, the Assistant Manager of Startup will report to the Plant Manager to ensure that startup activities are under centralized control.
f B.
Project Control Center In addition to its normal management controls, IP has established a Project Control Center (PCC) to coordinate the performance of activities by the various IP organizations associated with completion of construction and testing necessary for Fuel Load.
IP will continue to utilize the PCC after Fuel Load to ensure that the deferred activities are properly coor-dinated with the other activities associated with startup and operation.
In general, the functions of the PCC consist of the following:
Attachm:nt to U-600583 Continuously display and track cesting, testing support, the maintenance and engineering required to support testing, and deficiencies associated with plant systems and areas.
Expedite the work and tests scheduled for those systems and areas.
This includes coordinating the various support efforts required to resolve restraints to work, and coordinating resolutions to interference problems between work and test activities.
Ensure that necessary engineering changes are expeditiously processed by the Nuclear Station Engineering Department and, if work is required, that the work document is expeditiously approved by the appropriate departments.
These functions will assure that performance of the deferred activities and the other activities associated with startup and operation will be properly managed and controlled.
The PCC includes one or more representatives from each of the following organizations:
Construction, Startup, Plant Maintenance, Plant Operations, Engineering, Purchasing, Scheduling and Outage Management and Licensing.
These representatives coordinate the activities of their respective organizations to support the functions of the PCC.
C.
Scheduling and Outage Management Department In order to facilitate the transition of Clinton Power Station from construction to operation, a new department of Scheduling and Outage Management was established.
The Manager-Scheduling and Outage Management is responsible for the following activities:
Coordinate and prepare schedules for all nuclear departments in support of the Integrated Milestone Plan.
Manage and direct the actions of the maintenance support contractor in support of the Plant Manager.
Coordinate outage planning and preparation.
Support the Plant Manager during scheduled and forced outages to ensure timely and efficient completion of all work.
Manage and staff the Project Control Center. '
Attechm nt to U-600583
-In support of the Project Control Center, the Manager-Scheduling and Outage Management has established a special task force of planning and scheduling personnel to perform the detailed scheduling of Startup Phase Testing, surveillances, deferred maintenance activities, and deferred Preoperational and Acceptance Testing.
These planners work with engineers from other IP organizations to develop detailed schedules and lists of schedule restraints for each system.
D.
Plant Completion Group The Plant Completion Group (PCG) was formed under the-Manager - NSED to strengthen engineering support of construction, startup and maintenance activities.
The purpose of the PCG is to provide a transition of the resident engineering and procurement engineering activities from Baldwin Associates to IP in support of plant startup.
E.
Site-Wide Statusing System The Site-Wide Statusing System (SWSS) is a consolidated tracking system of the various work documents listed by responsible department and milestone completion date.
For example, the SWSS identifies the status of open Construction Work Requests (CWR), Nonconformance Reports (NCR), Field Problem Reports (FPR), Maintenance Work Recuests (MWR), NRC inspection open items, plant modifications and startup testing punchlist items.
Completion milestones have'been assigned to each of the open items (i.e., Fuel Load, Initial Criticality, 5% Power, Commercial Operations, or First Refueling Outage).
The SWSS provides a comprehensive tracking mechanism of work on plant systems and areas.
The SWSS is a source of information for the PCC in tracking _overall project completion.
F.
Initial Criticality Preparation After Fuel Load, IP will stop plant operations to conduct additional operator refresher training on the simulator in preparation for Initial Criticality and low power' testing and to complete a final management operational readiness assessment.
f During this pause, work and testing required to be completed prior to Initial Criticality will continue.
IP will use this period to assure that the approach to Initial Criticality and low power testing is deliberate and cautious.
III. Planning and Scheduling of the Deferred Activities The project schedule consists of a hierarchy of schedules.
This hierarchy includes the following levels:
Level I:
The Integrated Milestone Schedule (IMS) is a Level I Schedule of major project milestones which form the basic schedule framework for planning and Attachmsnt to U-600583 integrating project engineering, procurement, maintenance, construction, startup, operation, and quality activities.
This schedule is developed by the Manager-Nuclear Planning and Support and approved by the Vice President.
Level II:
The Level II Schedule is an integrated project summary schedule of engineering, procurement, maintenance, construction, startup, and quality activities which expands the detail of the Level I Schedule.
A computerized scheduling program, called the Project Resource Evaluation Management Information System (PREMIS), is used by the Director-Nuclear Program Scheduling to analyze the Level II Schedules.
Input for this analysis is provided by various IP Departments and from more detailed Level III Schedules.
Level III:
Level III Schedules are developed to further expand the activities of the Level II l
Schedules.
These schedules are used to prepare the l
more detailed daily work plans to be implemented prior to Fuel Load.
The special task force under the Manager-Scheduling and Outage Management has. prepared a Level III Schedule for completing each system.
Level III Schedules have also been prepared for the l
completion of area construction.
The schedule to complete deferred activities provides for an orderly progression of work and allows for sufficient time to accomplish each activity (including lead time).
IP realizes that changes in the schedule may be necessary as startup progresses in order to account for unexpected occurrences or changes in the l
durations for certain activities.
Accordingly, the schedule will be reviewed periodically and adjusted as necessary to allow sufficient time for the safe and proper performance of activities.
IV. Resource Sufficiency to Complete the Deferred Activities The Startup Group will provide assistance to Plant Staff during startup testing.
The personnel in this group will either leave the project or become part of the site staff once commercial operation begins.
IP has sufdicient manpower to perform both the deferred I
activities and other activities associated with startup and power l
ascension of CPS.
Cont::act personnel will be retained to perform remaining activities, as necessary.
This will assure tnat sufficient personnel are available to perform the deferred activities and Plant Staff will not be diverted from their normal activities during startup and power ascension. -
Attachm:nt to U-600583 V.
Reviews and Controls for the Deferred Activities IP will specifically control the deferred activities so as to minimize the potential for an activity being interfered with or adversely affected by' concurrent activities.
A review of how the scheduled " deferred activities affect ongoing startup tests and routine Main Control Room activities will be performed by the PCC and Plant Staff.
Specific approval for the performance of these activities at the scheduled time by the Director of Plant Operations or his principal assistant, the Supervisor of Plant Operations, under the auspices of the Plant Manager, will be required.
Finally, a daily briefing of the Main Control Room operators will identify these activities prior to their occurrence.
These controls will minimize the risk that concurrent performance of the activities may interfere with or adversely affect each other.
Particular attention will be given to tasks involving the Main Control Room such that there will be minimum interference between startup personnel and plant operators.
Controlled access will be maintained so that Control Room congestion will be minimized throughout the power ascension program.
In particular, the Shift Supervisor has the authority to stop any activities that divert attention from assuring that safe and reliable control is maintained within the Main Control Room
" Horseshoe".
This authority has been reemphasized by the issu-ance of a Plant Manager Standing Order.
The Shift Supervisor delegates the authority to stop activities to a Control Room operator in the event the Shift Supervisor is not present in the Main Control Room.
In this regard, licensed operators have responsibility for the scope and depth of all activities (includ-ing number of personnel) accomplished in the " Horseshoe".
However, the Shift Supervisor will maintain ultimate responsibi-lity for the safe performance of these activities.
VI.
Conclusions IP has established measures for controlling activities deferred past Fuel Load.
These measures will assure that the deferred activities are planned and scheduled in conformance with the needs of startup and power ascension of CPS.
Appropriate reviews and controls exist to prevent performance of the deferred activities from adversely affecting other activities.
Sufficient manpower and resources exist to perform the deferred activities and sufficient management controls for the deferred activities will be in place.
Consequently, there is reasonable assurance that the activities can be deferred without adversely affecting the safety of CPS.
Reference Illinois Power Letter U-600469, D. P. Hall to H. R. Denton,
" Initial Test Program Activities Projected for Completion After Fuel Load," dated March 12, 1986. -