ML20207P779: Difference between revisions

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| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 18
| page count = 18
| project = TAC:63576
| stage = Other
}}
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Latest revision as of 16:50, 5 December 2021

Forwards Current Integrated Schedule for Restart & Power Ascension Activities.Schedule Incorporates Consolidated Schedular Info on Both Interaction Activities.Updates Will Be Provided Twice Per Month.W/One Oversize Graph
ML20207P779
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 01/07/1987
From: Gahm J
PUBLIC SERVICE CO. OF COLORADO
To: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-87012, TAC-63576, NUDOCS 8701200205
Download: ML20207P779 (18)


Text

,

h Public Service-  :=a 16805 WCR 19 1/2, Platteville, Colorado 80651 January 7, 1987 Fort St. Vrain Unit No. 1 P-87012

@ ($ m iIN Regional Administrator Region IV U. S. Nuclear Regulatory Commission NOV - 9 l% ,

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 - -

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Attention: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Docket No. 50-267

SUBJECT:

FSV Restart and Power Ascension Schedule

REFERENCE:

PSC letter, Brey to Berkow, dated 12/12/86 (P-86666)

Dear Mr. Gagliardo:

Attached is Public Service Company of Colorado's (PSC) current integrated schedule for Fort St. Vrain (FSV) restart and power ascension activities. The referenced PSC letter submitted a NRC-PSC Restart Interaction Schedule that included a Power Ascension Plan, item 6, and a Startup Issue Identification and Completion Schedulo, Item 9. The FSV Restart and Power Ascension Schedule (Attachment 1) incorporates consolidated schedular information on both of these NRC-PSC interaction activities.

Attachment 1 is a schedule for all of the identified activities that are required for the NRC EQ Audit, Startup/ Plant Criticality, and Power Ascension to P 2*. . Attachment 2 is a brief narrative description of the scope of each line item activity shown on Attachment 1.

0701200205 870107 '

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P-87012 January 7, 1987 Attachments 'I and 2 represent detailed internal PSC schedular information and are not intended to create, change, or delete previous PSC commitments to the NRC. PSC will provide updates to the attached schedule twice per month for the duration of the current outage.

If you have any questions concerning the information provided herein, please contact Mr. M. H. Holmes at (303) 480-6960.

Very truly yours, J. W. Gahm Manager, Nuclear Production JWG/SWC/ paw Attachments cc: Director of Nuclear Reactor Regulation Attn.: Mr. H. N. Berkow, Director Standardization and Special Projects Directorate i

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t' FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS

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. I FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item'l (4200) "EQ Outage Work Required for the NRC Audit." This item represents plant outage modification and maintenance activities that are required cs a result of the EQ program and which must be completed prior to the 1/26/87 NRC EQ Audit (Item 63,4022).

This item is subdivided into four scheduling categories for statusing accuracy. The four categories are: CN/CWP work, CCT's/FT's, SSR work, PMT's. These categories are furthur defined by Items 2 (4202), 3 (4204), 4 (4206) and 5(4208) respectively.

Item 2 (4202) "CN/CWP Work (EQ Audit)" represents that portion of the plant modification work (Change Notice / Controlled Work Procedure) that is required by the EQ program which must be completed prior to the NRC Audit (Item 63, 4022).

Item 3 (4204) "CCT's/FT's (EQ Audit)" represents the post modification cold checkout testing and functional testing activities (CCT's/FT's) associated with the modification activities of Item 2 (4202).

Item 4 (4206) ~ "SSR Work (EQ Audit)" represents that portion of plant preventive and corrective maintenance activities (SSRs) performed on EQ equipment which must be completed prior to the NRC Audit (Item 63,4022).

> Item 5 (4208) "PMT's (EQ Audit)" represents the post maintenance testing activities (PMT's) associated with the

,s maintenance activities of Item 4 (4206).

Item 6 (4220) "EQ Outage Work Required for Non-Nuclear Dryout."

This item represents that portion of the plant outage modification and maintenance activities that are not required to be complete prior to the NRC Audit but must be complete to allow for non-nuclear dryout of the core. This activity includes some EQ associated work identified as not having to be complete prior to the NRC Audit (Item 63, 4022) but which must be complete prior to PSC certifying EQ (Item 58,4027).

This item is subdivided into five categories for statusing accuracy. The five categories are: CN/CWP work, CCT's/FT's, SSR work, PMT's, and surveillances.

These categories are further defined by Items 7 (4222), 8 (4224), 9 (4226),10 (4228) and 11 (4230) respectively.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 7 (4222) "CN/CWP Work (Non-Nuclear Dryout)" represents plant modification work (Change Notice / Controlled Work Procedure) equipment and systems required for non-nuclear core dryout (Item 12,4004).

Item 8 (4224) "CCT's/FT's (Non-Nuclear Dryout)" represents the post modification cold checkout testing and functional testing activities (CCT's/FT's) associated with the modification activities of Item 7 (4222).

Item 9 (4226) "SSR Work (Non-Nuclear Dryout)" represents plant preventive and corrective maintenance activities (SSR's) performed on equipment and systems required for non-nuclear core dryout (Item 12,4004).

Item 10 (4228) "PMT's (Non-Nuclear Dryout)." This item represents the post maintenance testing activities (PMT's) associated with the maintenance activities of Item 9 (4226).

Item 11 (4230) "Surveillances (Non-Nuclear Dryout)." This item represents plant surveillance test'ing activi' ties performed on equipment and systems required for non-nuclear core dryout (Item 12,4004).

Item 12 (4004) "Non-Nuclear Dryout" represents that period when the plant conditions allow for non-nuclear dryout of the core. The duration of this period is dependent upon the moisture level in the core, and plant systems available.

Item 13 (4240) "EQ Outage Work Required for Startup (Reactor Critical)." This item represents the balance of the plant outage modification and maintenance activities that are required to be complete prior to plant criticality. This activity includes some E.Q.

associated work identified as not having to be complete prior to the NRC Audit (63, 4022) but which must be complete prior to PSC certifying EQ completion (item 58, 4027).

These activities are non-EQ related. This item is also subdivided into five scheduling categories for statusing accuracy. The five categories are: CN/CWP work, CCT's/FT's, SSR work, PMT's and surveillances.

These catagories are further defined by items 14 (4242), 15 (4244), 16 (4246), 17 (4248), 18 (4230) respectively.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 14 (4242) "CN/CWP Work (Reactor Criticality)" represents plant modification work (Change Notice / Controlled Work Procedure) on equipment and systems required for reactor criticality (Item 25,4006).

Item 15 (4244) "CCT's/FT's (Reactor Criticality)" represents the post modification cold checkout testing and functional testing activities (CCT's/FT's) associated with the modification activities of Item 14 (4242).

Item 16 (4246) "SSR Work (Reactor Criticality)" represents plant preventive and corrective maintenance activities (SSR's) performed on equipment and systems required for reactor criticality (Item 25,4006).

Item 17 (4248) "PMT's (Reactor Criticality)." This Item represents the post maintenance testing activities (PMTs) associated with the maintenance activities of Item 16 (4246).

Item 18 (4230) "Surveillances (Reactor Criticality)." This item represents plant surveillance testing activities performed on equipment and systems required for reactor criticality (Item 25,4006).

Item 19 (4008) "EES Vent Installation Outage" represents the planned plant outage period for the installation of the EES 6" vent lines on the main steam line. The purpose of this outage is to perform the plant modifications required by the Safe Shutdown Cooling Technical Specification change using fire water for cooling.

Item 20 (4026) " Power Ascension Schedule Development / Submittal (Rise to Power)." This activity includes the development of the plant's rise to power schedule.

Item 21 (4056) "EQ Required NCR Closures (NCR Log)." This item includes the identification, generation, disposition and QA approval of non-conforming conditions associated with the EQ related equipment. All EQ related non-conformance reports (NCR's) must be closed-out prior to PSC certifying to the NRC that the EQ program is complete (Item 58,4027).

Item 22 (4059) "Startup NCR Closures (NCR Log)." This item includes the identification, generation, disposition and QA approval of non-conforming conditions that will prohibit plant criticality (Item 25, 4006) if not closed out.

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FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 23 (4082) " Power Ascension per OPOP's (i.e. valve line ups)."

This item includes the performance of the various activities included in the Overall Plant Operating Procedures) OPOP's applicable to taking the plant critical and increasing power from zero to P2%.

Item 24 (4083) " Core Performance Testing." This item includes the activities related to verifying reactor core segment three design margins and performance characteristics.

Item 25 (4006) " Plant Criticality / Nuclear Dryout/R.0. Training Starts." represents that period of time when plant conditions and regulatory constraints allow for plant criticality and nuclear dryout of the core. The duration of this period is dependent upon the moisture levels in the core, plant systems available and other regulatory constraints. This activity also includes Reactor Operator Training Starts.

Item 26 (4009) " Steam Generator 6" Design, Material Procurement and Pre-fabrication." This item represents the pre-outage activities for the planned plant outage (Item 19, 4008) for the 6" vent modification. This preparation includes the planning, design, procurement and pre-fabrication necessary to support the plant 6" vent modification activity during the plant outage.

Item 27 (4085) " Complete Vent Outage Plan and Preparation Work (Including Material)." This item represents the pre-outage preparation for the planned outage of (Item 19, 4008) for outage work that is not related to the 6" vent modification (Item 26,4009) activity.

Item 28 (4012) " Power Ascension to Pl%" represents the period of time starting with the 6" vent modification completion, and extending through plant operation at an elevated power level based on the existing Safe Shutdown Cooling Technical Specifications.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 29 (4013) " Power Ascension to P2% and Continued Operation" represents the period of time after plant operation at Pl% (Item 28, 4012) when the plant conditions and regulatory restraints will allow for an elevated plant power level governed _by the new Safe Shutdown Cooling Technical Specifications.

Item 30 (4086) " Safety Related Equipment Walkdown First Phase, Operability." This item represents the walkdown activity, engineering analysis, and initiation of maintenance activities to address generic maintenance issues that were identified during the EQ walkdown.

Item 31 (4087) " Safety Related Equipment Walkdown Second Phase, Plan Development." This item includes the development of a long term program plan to systematically perform a plant walkdown to verify the as-built condition, name plate data, and identi fying possible program and procedure changes to enhance the maintained condition of plant equipment, thereby improving plant operability.

Item 32 (4302) " Preventive Maintenance Program (First Phase)." This item includes the development of PM program controls and implementation of vendor recommended and EQ required preventive maintenance activities.

Item 33 (4139) " Ongoing Activity Plan Development." The ongoing activity plan is a master plan and schedule of the various activities and programs that are being implemented at FSV. These various activities are not a constraint to plant startup.

Item 34 (4011) "SLRDIS Technical Specification Submittal / Review and Approval by NRC" includes the SLRDIS Tech. Spec.

change preparation and submittal to the NRC. This activity also includes the NRC review and approval period. When this item is complete, then the SLRDIS Emergency Procedure revisions can be issued (Item 35, 4322).

Item 35 (4322) " Release SLRDIS Emergency Procedures." This item involves the " issue for use" of the Emergency Procedure revisions that were required by SLRDIS.

These procedure revisions cannot be " issued for use" until NRC approval of the SLRDIS Tech. Spec. These procedures must be " issued for use" prior to SLRDIS activation /SPRDS Deactivation (Item 37,4010).

FSV RESTART AND POWER ASCENSION SCHE 0VLE LINE ITEM DESCRIPTIONS Item 36 (4007) "SLRDIS Design and Construction." This activity includes the plant design and modification activity required to install SLRDIS and the follow-up testing of this system. When this activity is complete along with Items 35 (4322) and 34 (4011), then SLRDIS can be activated (Item 37,4010).

Item 37 (4010) "SLRDIS Activation /SPRDS Deactivation." This activity involves the activation of-SLRDIS and the deactivation of the existing SPRDS. This activity ccnnot be implemented until Items 34 (4011), 35 (4322), 36 (4007) are completed.

Item 38 (4057) "NCR History Review for EQ Impact." This issue involves the review of closed out Non-Conformance Reports associated with EQ related equipment. This engineering review will identify and respond to any NCR disposition that could potentially be in conflict with the new EQ basis.

Item 39 (4016) " Complete EQ Procedural Effort." This activity involves the EQ program controls development, revisions and approvals. A system of procedures are being established to implement the ongoing EQ program at FSV in accordance with the upper level administrative controls and guidelines (Item 42, 4308). When this activity is complete, the EQ program will be established allowing a portion of the EQ MCAR (Ittn56,4122) to be closed out.

Item 40 (4015) " Complete EQ Training Ef fort (Except Make-up)." This activity involves the EQ training effort necessary to establish the appropriate knowledge level for the personnel that will maintain the EQ program at FSV.

Item 41 (4328) " Complete Make-up EQ Training." This activity provides make-up classes for those personnel that could not attend the original EQ training courses of Item 40 (4015).

Item 42 (4308) " Final Approval of Level 1 Policy and Procedure G-16."

This activity involves the development and approval of the upper tier EQ Policy, Guideline and Program Procedure. These documents define the scope of the EQ program and the system of administrative procedures that implement the EQ program at FSV (Item 39, 4016).

These documents will be submitted to the NRC in the EQ Audit Module Submittal (Item 60, 4021).

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 43 (4017) " Complete SMAP-27 Binder Reviews (EQ)." This activity includes the maintenance review of the EQ binders, in accordance with SMAP-27, to incorporate the EQ maintenance and surveillance requirements into the plant working procedures.

Item 44 (4314] " Binder Document Updates and Telecon Resolution."

This activity involves the incorporation of document changes to the EQ- binders as a result of the third party EQ audit. This activity also includes replacing vendor telecons with letters to the vendor requesting verification of the information in the telecons.

Item 45 (4018) " Finalize MEL." This item represents the final design document approvals for establishing the EQ Master Equipment List. The MEL will be submitted to the NRC in the EQ Audit Module Submittal (Item 60,4021).

Item 46 (4023) " Finalize EQ Binder CN's." This activity includes the final engineering and administrative approval of the EQ Binder Change Notice (CN) document.s to incorporate these documents into the controlled design document system. When this activity is finalized, Item 43 (4017) can be completed.

Item 47 (4019) " Finalize Temperature Profiles - Reactor Building."

This issue involves the final engineering analysis required for the development and approval of the post HELB environment temperature profiles for the Reactor Building.

Item 48 (4020) " Finalize Temperature Profile - Turbine Building."

This issue involves the final engineering analysis required for the development and approval of the post HELB environment temperature profiles for the Turbine Building.

Item 49 (4310) "NRC issue SER on Profile." This activity includes the NRC review and approval of the post HELB environmental profiles for the Reactor and Turbine Building and the development and issuance of the NRC's Safety Evaluation Report on this issue.

Item 50 (4054) " Update 0 & M Library (EQ Related)." This issue involves the controlled vendor manual program developed in response to Generic Letter 83-28 and the implementation of this program for the EQ related vendor manuals. This activity is an input to the EQ Maintenance Review SMAP-27 (Item 43, 4017).

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 51 (4312) "SMAP-25 Review / Final SSR Closure." This activity represents the EQ review performed on all EQ related Station Service Requests (SSR's) to ensure that the EQ basis has been maintained during normal maintenance activities.

Item 52 (4080) " CADS Walkdown Closure." This activity involves the closeout of the EQ walkdown documentation.

Maintenance deficiencies were identified during the walkdown generating Corrective Action Data Sheet (CADS) which are closed out when the associated SSR work has been completed.

Item 53 (4094) "EQ CN Approval Memo's/ Follow-up Activities." This issue involves Work Review Committee approval of CN document packages which required additional follow-up actions by NED. These follow-up actions are documented on memo's from the Station Manager to NED managers.

Item 54 (4306) " Completion of ED-103 Reviews." This activity involves the engineering review of plant modification Change Notice and Controlled Work Procedure documents to ensure that the EQ basis of equipment has been maintained during the modification activities. ED-103 is the Engineering Design Procedure used to control this activity.

Item 55 (4304) " Final CN/CWP P.O. Reviews." This activity involves the engineering review of purchase order documentation associated with the EQ modification (CN/CWP) activities, to ensure that the purchasing requirements meet the requirements set forth in the EQ binders.

Item 56 (4122) "EQ MCAR Closure." This issue involves the closecut of MCAR 85-001 which was generated by QA as a result of insufficient EQ program controls. This item will be resolved and closed out with the completion of Items 57 (4050), and 39 (4016).

Item 57 (4050) "Close EQ Related CAR Items." This activity involves the disposition and QA approval of EQ related Corrective Action Requests. This activity consists of EQ related CARS that must be complete before the EQ MCAR 85-001 (Item 56, 4122) can be closed out, and additional EQ CAR items not tied to the MCAR close-out.

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FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 58 (4027) "EQ Completion Certification Letter." This item represents the PSC generated letter cartifying to the NRC that the FSV EQ program has been substantially implemented and meets the requirements of 10CFR50.49.

Item 59 (4300) " Resolution of Audit Findings." This activity involves the resolution of any audit findings resulting from the NRC EQ Audit (Item 63,4022).

Item 60 (4021) "EQ Audit Module Submittal." This item represents the PSC submittal to the NRC of the key EQ program documents necessary for the NRC Audit preparation.

This submittal is to be made prior to the NRC EQ Audit (Item 63, 4022) in accordance with the NRC EQ Audit Module.

Item 61 (4320) "PSC Audit Prep." This activity represents the final preparation for the NRC EQ Audit, including trial audits, presentation preparation, security clearances and facilities for the NRC inspectors.

Item 62 (4025) "NRC I & E Region IV PEP and Pre EQ Audit Meetings."

This item represents the scheduled NRC/PSC meeting at Region IV to discuss the PEP status and EQ Audit preparations.

Item 63 (4022) "NRC I & E EQ Audit / Findings." This activity represents the NRC EQ Audit scheduled for 1/26/87 and the identification of audit findings to PSC. Audit finding resolutions will be initiated on a daily basis upon the identification of any finding.

Item 64 (4024) "NRC EQ Audit Evaluation and Staff Review." This item represents the NRC activity, post EQ Audit, to assess the FSV EQ program success, and to prepare staff recommendations to the Commission for plant startup.

Item 65 (4028) "NRC Commissioner's Meeting." This item represents the NRC Commissioner's meeting to assess the FSV progress of resolution to EQ and other regulatory and management issues and to obtain NRC's approval for plant startup.

Item 66 (4316) "NRC Lag Time until Perm'ission to Restart is Granted."

This item represents the period of time required for any final NRC/PSC interactions and for issuance of documentation of NRC approval of FSV startup.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 67 (4039) " Safe Shutdown Cooling Flowpath - Pl% Submittal."

This item represents the technical evaluation of power operation that can be supported by the Safe Shutdown Cooling flowpaths and the existing Tech. Specs.

Item 68 (4040) " Safe Shutdown Cooling With EES Only." This activity involves the reanalysis with reliance upon EES

( Eco n omi z e r- Ev a p o ra to r-S up e rhe a te r) sections only to achieve Safe Shutdown Cooling.

Item 69 (4041) " Reheater Elimination Analysis (Tech. Spec.)." This activity documents the Safety Analyses and submits the License amendment request necessary to eliminate the reheaters from the licensing basis at P2% power level to achieve Safe Shutdown Cooling.

Item 70 (4324) "EES Transient Analysis." There are other accidents / transients evaluated in the FSAR which rely on the EES for decay heat removal besides Safe Shutdown Cooling with firewater. This . item involves reanalysis of these accidents / transients to verify that the decay heat removal options in the FSAR are adequate for power operation at the P2% power level.

The results of these analyses will be scheduled for submittal to the NRC to support operation at the P2%

power level.

Item 71 (4326) " Wrong Loop Dump Analysis." This item involves reanalysis of the steam generator tube leak with wrong loop dump accident scenario. The reanalyses will include all available options for this accident.

Documentation of the results of the analyses will be submitted to the NRC to support operation at the P2%

power level.

Item 72 (4062) "NRC Review and Approve SSC APP-R Flowpath." This activity involves the NRC review of PSC Safe Shutdown Cooling submittals involving reheater elimination analysis, EES cooling capability, and FSAR accident reanalysis. This activity also includes NRC review and approval of Pl% and P2% power levels.

Item 73 (4038) " Implement Revised RERP Accountability." This activity includes the staff augmentation of the revised RERP Accountability program. This item is an NRC Commitment to be completed prior to plant startup.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 74 (4318) " Review / Revise Emergency Procedure for APP-R." This activity includes review of the existing Emergency Procedure to reflect the Shutdown Cooling paths identified in _P SC's Appendix- R submittals.

Appropriate revision or preparation of new. procedures is also included.

Item 75 (4045) " Firewater on Emergency Feedwater Header". This item involves testing to ensure that the Firewater Spool Piece for the Emergency Feedwater Header can be installed within the required time designated in the FSAR and Tech. Specs.

Item 76 (4046) Deleted Item 77 (4047) " Review PEP Commitments for Constraints to Startup."

This item represents the management improvements and performance enhancements being undertaken by PSC (PEP, SALP, TRM, QEP) to emphasize their importance to plant restart and future operations.

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FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS ,

Item 78 (4030) "QA EQ Monitoring." This item involves a review of .

selected areas of plant activities such as testing, TCR's, SSR's, CWP's, procedural updates, training, etc, for the purpose of verifying the completion of activities which may effect startup.

Item 79 (4034) " Emergency Diesel Generator Near Term Fix (CN-1622F)."

This activity involves a design change in the source point of DC control power to the undervoltage protection system on the 480 VAC essential buses, which initiates EDG start upon loss of voltage. The change in the source point was from the DC bus direct to the DC control power automatic throwover scheme in each of 480 VAC switchgear units.

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Item 80 (4330) "EDG Elect. Ind. & DC Cnti Pwr Mod Submittal." 'This activity involves preparing a PSC submittal to the NRC to address the EDG Independence and the DC Control Power Single Failure Issues. The PSC submittal includes an indepth engineering evaluation on.the EDG independence and an assessment of the results. In addition, the submittal contains commitments associated with design changes and tests to resolve short and long term issues on the DC Control Power System. All commitments include a well defined schedule. All of the above items are in response to discussions held with the NRC staff on August 14 and December 9, 1986.

FSV RESTART AND POWER ASCENSION SCHEDULE LINE ITEM DESCRIPTIONS Item 81 (4332) "NRC -approval of EDG Power Mode Submittal". This activity involves the NRC review and approval of the-submittal identified in Item 80, (4330). The key issues requiring approval prior to restart are:

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1. Manual capabilities exist to energize the associated 480 VAC essential buses from at least one EDG set for a postulated single failure in the permissive control logic circuitry.
2. Paralleling of the two redundant EDG sets is precluded for a single failure in the permissive control logic circuitry.

3 '. Demonstrate through testing the operability of DC control power automatic throwaver feature in each 480 VAC essential swutchgear unit and feeder breaker protective coordination.

Item 82 (4334) " Perform Critical Evaluation of SS and SRO." This activity includes all efforts involved with the development and implementation of an evaluation process for SSs and SR0s.