ML20132C569
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DISTRIBUTIO'l:
Docket flo. 50-412 g S,2C G84 orig PSRB R/F DHFS R/F (2)
DLZiemann GRiiazetis TABecker 11E':0RAf!DU:1 FOR: Thomas M. flovak, Assistant Director for Licensing -
FROM: William T. Russell, Deputy Director Division of Human Factors Safety
SUBJECT:
SAFETY EVALUATI0ff REPORT I!!PUT BEAVER VALLEY PO!1ER STATION UtilT 2 CHAPTER 14 - IllITIAL TEST PROGRA!!
Duquesne Light Company's description of its initial test program and response to Tt!I Action Plan Item I.G.1 for the Beaver Valley Power Station Unit 2 initial test prngram has been reviewed through Amendnent 8 to the FSAR. Our Chapter 14 Safety Evaluation Report input is enclosed. At the suggestion of the Pft, the enclosed SER is a mark-up of the DSER, which is in the CRESS werd processing system. Although some of the items noted in the DSER have been closed, there still remains a number of items which require additional information from the applicant.
The review of the Beaver Valley Power Station Unit 2 Initial test program is being performed with assistance from Battelle Pacific florthwest Laboratories' personnel. -
flo SALP input is included because there has b'een no interaction with the applicant since the DSER SALP evaluation.
Richard Becker, Senior fluclear Systems Engineer (X29689), is the PSRB reviewer for the Beaver Valley Power Station Unit 2 initial test program.
Questions regarding this evaluation should be directed to him. The reviewer is not aware of any " Differing Professional Opinions" for the initial test program.
h .c'. e' E' n.e By aM u 7. L ..ir,I, William T. Russell, Deput/ Director Division of Hunan Factors Safety
Enclosure:
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14 IAITIAL TEST PROGRAM The Beaver Valley Unit 2 startup and test program is established to adminis-tratively and technically control all testing activities, from completion of construction and to power level escalation testing. The startup and test program provides documented assurance that the plant's structures, systems, and components will operate in compliance with their design criteria in a manner that does not endanger the health and safety of the public, plant personnel, or plant equipment.
To the extent practicable, plant operating and emergency procedures are tested and evaluated during the execution of this program. The startup and test pro-gram also assists in the training of plant operating and maintenance personnel by.providing them with hands on experience in the operation and maintenance of plant equipment, utilizing plant procedures.
To facilitate a systematic approach in conducting the startup and test program, the program has been divided into three major phases: (1) construction proof test, (2) preoperational test, and (3) initial startup test.
The construction proof test phase includes pre-installation and post-installation testing of individual structures, systems, and components under the jurisdic-tion of a construction startup group. The prime objective of this phare is to verify that construction activities associated with the respective strictures, systems, or components have been completed and documented. Another function is to verify that the components within the system can be put into operation safely. The testing requirements associated with this phase verify installa-tion integrity and component and system functional characteristics, and ensure that the structures, systems, and components are ready for pre-operational testing. These tests, in general, include instrument calibration, electrical continuity and insulation resistance measurements, pump and motor rotation and vibration checks, and hydrostatic testing, cleaning, and flushing.
h7/20/84 14-1 BEAVER VALLEY 2 'ER SEC 14
o The pre-operational test phase normally begins af ter construction proof testing on individual components and systems or subsystems is completed and jurisdic- l tional control has been turned over to the operations startup g'roup. This phase includes the tests required to demonstrate that structures, systems, and components perform satisfactorily and that they are ready to support fuel loading and the initial startup testing. During the pre-operational, test phase, two types of tests are performed: pre-operational tests and system operability verification (SOV) tests. The pre-operat;onal tests are performed on safety related structures, systems, or components in accordance with Section XI of Appendix B of 10 CFR 50. The S0V tests are performed on structures, systems, or components that are not classified as safety related.
Although these two types of tests are similar in scope, the administrative processing of the tests and results may be different. Where practicable, testing during the preoperational testing phase will be performed under system design conditions. Tests for which system design conditions are not practicable or cannot be simulated will be performed as close to design conditions as possible and the test acceptance criteria will be adjusted accordingly.
The initial startup phase begins with the preparation for fuel load and extends through operation at rated power and warranty demonstrations. The initial startup lest phase is divided into three areas: fuel loading testing, post-loading testing, and criticality testing. Testing is performed during this phase of the program to (1) ensure that fuel loading is accomplished in a safe manner (2) confirm the reactor nuclear design basis (3) demonstrate that the plant responds to transients as designed (4) ensure that the plant can be safely brought to sustained rated power operations The staff's review of FSAR Chapter 14 concentrated on the administration of the test program and the completeness of the preoperational and startup test 07/20/84 14-2 SEAVER VALLEY 2 c ER SEC 14
abstracts. The review included the SER-CP; the FSAR; licensee event report summaries for operating reactors of similar design to identify potentially serious event and chronic or generic problems, Standard Technical Specifica-tions, NUREGs-0660, -0694, and -0737; and startup test reports for other simi-lar type plants. The review followed SRP 14.2.
The staff's review included verification of the following features of the initial test program:
(1) The applicant will develop test procedures using input from the NSSS ven-
- dor, the architect-engineer, its engineering staff, and equipment sup-pliers and contractors. Operating experiences at similar plants will be factored into the development of the test procedures.
(2) The applicant will conduct tests using approved test procedures. Adminis-trative controls will cover (a) the completion of test prerequisites, (b) the completion of necessary data sheets and other documentation, and (c) the review and approval of modifications to test procedures. The applicant has stated that administrative procedures will also cover implementat, ion of modification o,r repair requirements identified as being required by the tests and any necessary retesting.
(3) The applicant will review the results of each test for technical adequacy and completeness by review groups including the NSSS vendor and architect-engineer as appropriate. Preoperational test results will be reviewed before fuel loading and the startup test results from each test condition or power level will be reviewed before proceeding to the next test condi-tion or power level.
(4) The applicant will use normal plant operating and emergency operating procedures in performing the initial test program, thereby verifying the correctness of the procedures to the extent practicable.
(5) The schedule for conducting the initial test program allows adequate time to conduct all preoperational and startup tests. Preoperational test P
14-3 EEAVER VALLEY 2 :ER SEC 14 (33/20785)
(( h .,-(:, .l The app $icant has made a number of changes to the initial test program as a result of our questions. Examples of these changes follow:
(1) expanded FSAR Figure 14.2-3 to provide an index of system operability verification, preoperational, and startup tests; (2) increased the testing for the instrument air preoperation test to provide for testing of both a sudden and gradual loss of pressure on each individual valve; (3) expanded testing to include simultaneously closing all MSIV's at 100% power; (4) expanded testing to demonstrate that the air flow paths of quench and recirculation spray nozzles overlap water flow test paths for pumps; (5) included a verification that a manual trip will remove power from the reactor trip breaker undervoltage coil and energize the shunt trip coil; (6) modified station blackout test to assure loss of power is maintained long enough for plant conditions to stabilize.
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j procedures will be available for NRC regional personnel review at least 60 days before scheduled implementation. Startup test procedures will be !
available for review not less than 60 days before the scheduled fuel ;
loading date.
(6) An abstract of each test is presented in FSAR Chapter 14. The staff veri-fied that there are test abstracts for those structures, systems, components, and design features that: (a) will be used for shutdown and cooldown of the reactor under normal, transient, and accident conditions and for main-taining the reactor in a safe shutdown condition for an extended period of time; (b) will be used for establishing conformance with safety limits or limiting conditions for operation that will be included in the facility .
technical specifications; (c) are classified as engineered safety ~ features or will be relied on to support or ensure the operations of engineered safety features within design limits; (d) are assumed'to function or for which credit is taken in the accident analysis of the facility, as de-scribed in the FSAR; or (e) will be used to process, store, control, or limit the release of radioactive materials.
(7) The test objectives, prerequisites, test methods, and acceptance criteria for each test abstract are in suificient detail to establish that the functional adequacy of the structures, ' systems, components, and design features will be demonstrated.
(8) Exceptions to RG 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants," Revision 2, are identified and adequately justified.
The staff was unable to verify all of the above and therefore additional information was requested from the applicant (letter from G. W. Knighton to E. J. Woolever dated October 20, 1983). A meeting with the applicant was held on Januar 12 Eh', c d5I &[et Y Y h h, 1984 d?tY ? kst to discuss the issues-.
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re ma w I of the4i tems id'entif ied ing 'm :-19 cd tr, the initial test program described in the FSAR (as amended through Amendment A) will meet SRP 14.2 and, 67/20'/8 14-4 BEAVER VALLEY 2 . SEC 14
'10.dFR 50.34(b)(6)(iii), which requires inclusion of plans for pre perational
' testing an,d , initial operations in the FSAR; 10 CFR 50, Appendix B, Sectier XI, which requires a test program to ensure that all testing requirbd to derr.onstrate that structures, systems, and components will perform satis'factorily in service is identified and performed in accordance with written test procedures that incorpor, ate the requirements and acceptance limits contained in applicable ,
design documents; and NUREG-0737, Item I.G.1, which requires additional testing and training during the initial test program.
This review and evaluation was performed with the assistance of Battelle
/ Pacific Northwest Laboratories' personnel. ,
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l TABLE 14-1 OPEN ITEMS - INITIAL TEST PROGRAM RAI*
QUESTION STATUS NUMBER 640.9 FSAR Subsection 14.2.12.6.4, Shutdown from Outside the Control Room and Verification of the Potential for Cold Shutdown, should include test initiation with the turbine generator in operation.
640.14 FSAR Subsection 14.2.12 test abstracts should include specific sources of acceptance criteria.
640.16 FSAR Table 1.10-1 should be revised to provide specific reference i
- to where the testing and training requirements of NUREG-0737, l
Item I.G.1, are addressed.
640.18 FSAR Subsection 14.2.12 test abstracts should be modified to demonstrate that capacities of pressurizer PORVs and main steam li'ne atmospheric dump valves are consistent with the accident analysis assumptions for both minimum and maximum valve capacities.
l 640.19 Discrepancies exist between the classification of certain test abst'racts in FSAR Subsection 14.2.12 and FSAR Figure 14.2-3.
640.20 FSAR Subsection 14.2.12 test abstracts should be modified to I
ensure that the accumulator isolation valves can open under maximum differential pressure conditions.
640.23 FSAR Subsection 14.2.12.6.5, Verification of Plant Performance Following Turbine Trip Coincident with Loss-of Offsite Power at load, should be modified to secure appropriate sections of the Safeguards Area Ventilation which are ac powered.
640.25 Provide assurance that adequate drainage for the fire protection system is provided to preclude flooding and that adequate testing is included for nozzles serving indoor facilities.
640.26 (1) demonstrate proper operation of the isolated phase duct cooling system under fully loaded conditions; (2) demonstrate that Class 1E dc loads necessary for safe shutdown are operable at minimum de voltages and (3) demonstrate full load testing of vital bus inverters, t
640.27 FSAR Subsection 14.2.12.55.1, Emergency Diesel Generator System Test, should be modified to demonstrate proper operation during complete loss of load.
i 640.30 Justify the apparent exceptions to Regulatory Guide 1.68, Appendix A, of the following: (1) Reactor Vessel Internal Inspection (1.a.3, 4.s, 5.p); (2) leak detection systems outside of containment (1.j.7); (3) monitoring of atmospheric parameters in containment leakage monitoring system (1.j.22); (4)' testing of containment humidity monitors in containment vacuum system (1.j.22);(5)testin power (5.s); and (6)gtesting of condenser hotwell of gaseous andlevel liquidcontrol radwaste system at systemsatpower(5.c.c).
640.31 Clarify the use of System Operability Verification (SOV) tests l , during both the Preoperational and Startup test phases.
- Request for Additional Information e
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emet BEAVER VALLEY - UNIT 2 l
TER INPUT THROUGH AMENDMENT 8 (9/84) l The following items are the TER input for the Beaver Valley-2 l
l-Initial Plant Test Program through FSAR Amendment 8 (9/84).
L
'Itsm Description 640.9 FSAR Subsection 14.2.12.6.4 (Shutdown from outside the Control Room and Verification of the Potential for Cold Shutdown) should include test initiation with the turbine generator in operation, or further technical justification should be provided for not performing this test in accordance with RG 1.68.2, Initial Startup Test Program to Demonstrate Remote Shutdown Capability for
, Water Cooled Nuclear Power Plants.
640.14 FSAR Subsection 14.2.12 test abstracts should include specific sources of acceptance criteria.
l 640.16 FSAR Table 1.10-1 should be revised to provide specific reference to where the testing and training requirements l of NUREG-0737, Item I.G.1, are addressed.
640.18 sAR Subsection 14.2.12 test abstracts should be l
.nodified to ' demonstrate that capacities of pressurizer !
PORVs and main steam line atmospheric dump valves are l consistent with the accident analysis assumptions for both minimum and maximum valve capacities. I 640.19 Discrepancies 5 exist between the classification of i certain test abstracts in FSAR Subsection 14.2.12 and FSAR Figure 14.2-3. The following test abstracts should be classified as stated.
Test Section Number ,
Description '
Type 14.2.12.16.2 Reactor Coolant System Sampling for Core Load IST 14.2.12.17.1 Turbine Plant Sampling System SOV 14.2.12.31.2 Plant Operation Following Loss of FW Heater IST 14.2.12.54.1 Normal AC Power Distribution System SOV 14.2.12.63.1 Engineered Safety Features Equip.
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14.2.12.68.1 Aux. & Waste Handling Bldg. HVAC SOV '
14.2.12.69.2 Misc. Sec. Plant HVAC Systems SOV 14.2.12.70.1 Condensate Polishing Bldg. HVAC Systems SOV 640.20 FSAR Subsection 14.2.12 test abstracts should be modified to ensure that the accumulator isolation valves can open under the maximum differential pressure conditions of zero RCS pressure and maximum expected accumulator precharge pressure, or technical justification to RG 1.79, Preoperational Testing of Emergency Core Cooling Systems for Pressurized Water Reactors, should be provided in FSAR Table 1.8-1.
640.23 FSAR Subsection 14.2.12.6.5 (Verification of Plant Performance Following Turbine Trip Coincident with Loss-of-Offsite Power at Load) should be modified to secure appropriate sections of the Safeguards Area Ventilation System which are ac powered to simulate loss of ac conditions during the 2-hour turbine-driven auxiliary feedwater pump test. Also, acceptance criteria (2) should be rewritten as it currently is unclear.
640.25 (1) FSAR Question 410.24 does not necessarily address flooding caused by automatic and/or manual fire protection (water) systems. Provide assurance that adequate drainage is provided to preclude flooding.
(2) .FSAR Subgection 14.2.12.50.2 (Wet Pipe and Deluge Sprinkler System Test) should be modified to verify that nozzles serving indoor facilities are air-flow tested and that these tests overlap the water flow tests.
640.26 (1) FSAR Subsection 14.2.12.53.1 (Main Generator and Transformer Auxiliaries Test) or other test abstracts should be modified to demonstrate proper operation of the isolated phase bus duct cooling system under fully loaded conditions.
(2) FSAR Question 430.11 deals with the Class lE ac system. I Demonstrate that Class lE de loads necessary for safe shutdown are operable at minimum de voltage.
(3) FSAR Subsection 14.2.12 has yet to be modified to add full load
. testing of vital bus inverters.
640.27 FSAR Subsection 14.2.12.55.1 (Emergency Diesel Generator System Test) should be modified to demonstrate proper operation during complete loss of load or technical justification should be provided for exception to RG 1.108, Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants.
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3 640.30 The following items regarding conformance with Regulation Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants, Appendix A, should be addressed:
(1) Provide technical justification as to why FSAR Subsection 14.2.12.8.11 (Reactor Vessel Internals Inspection) has been deleted. This test is used to provide conformance with Regulatory Guide 1.20, Comprehensive Vibration Assessment Program, as stated in FSAR Table 1.8-1 and FSAR Subsection 3.9N.2.4 (1.a.3, 4.s, 5.p).
(2) FSAR Subsection 14.2.12 test abstracts should be modified to address leak detection systems located outside of containment (1.j.7).
(3) FSAR Subsection 14.2.12.14.1 (Containment Leakage Monitoring System) should specify which atmospheric parameters are monitored (1.j.22).
(4) FSAR Subsection 14.2.12.13.1 (Containment Vacuum System Test) or other appropriate test abstract should include testing of containment humidity monitors (1.j.22).
(5) FSAR Subsection 14.2.12 test abstracts should include testing of condenser hotwell level control system at power or technical justification should be taken to RG 1.68 (5.s).
(6) FSAR Figure 14.2-3 should be modified to ideatify testing of sgaseous gnd liquid radwaste systems at power (5.c.c).
640.31 FSAR Subsection 14.2.1.2 states that System Operability Verification (SOV) tests are performed as part of the Preoperational Test Phase.
However, the following SOV tests are to be accomplished partially or completely during the Initial Startup Test Phase. These tests should either be designated as Initial Startup Tests, or FSAR Subsections 14.2.1.2 and 14.2.1.3 should be rewritten to clarify the use of SOV tests during both the Preoperational and Initial Startup Test phases.
Section Number Description 14.2.12.7.3 Verification of Performance Calculation 14.2.12.17.1 Turbine Plant Sampling System 14.2.12.28.2 Condensate Polishing System Capability 14.2.12.30.1 Feedwater Heater Drain System Test 14.2.12.33.1 Automatic S.G. Level Control Test 14.2.12.36.2 Turbine Overspeed Trip Test 14.2.12.38.1 Moisture Separ. & Reheat Control System 14.2.12.39.1 Turbine Stretch Test 14.2.12.44.2 Cooling Tcuer Performance Test
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14.2.12.57.1 Plant Communications Test 14.2.12.63.2 Fuel, Decont. Bldg. & Pipe Tunnel HVAC 14.2.12.71.1 Loose Parts Monitoring System Test S
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6 BEAVER VALLEY - UNIT 2 Status of Responses to NRC Ouestions Through Amendment 7 (7/84)
--I t e m Description 640.9 FSAR Subsection 14.2.12.6.4 (Shutdown from Outside the Control Room and Verification of the Potential for. Cold Shutdown) should include test i ni ti ati on with the turbine generator in operation, or further technical justification should be provided for n o t.- performing this test in accordance with RG 1.68.2, Initial Startup Test Program to Demonstrate Remote Shutdown. Capability for Water Cooled Nuclear Power Plants. Also,1part of-test method (2) regarding staffing levels and test.; durati on< appears to have been inadvertently deleted.
It should-be reinstated.
640.14 1FSAR Subsection 14.2.12 test abstracts should include specific sources of acceptance criteria.
640.16 FSAR Table ~ 1.10-1 should be revised to provide specific reference to
-where the testing and training requirements of NUREG-0737, Item I.G.1, are addressed.
- 640.18 FSAR Subsection 14.2.12 test abstracts should be modified to demonstrate that capacities of pressurizer PORVs and main steam line atmospheric dump valves are consi stent with the accident analysis assumptions for both minimum and maximum valve capacities.
640.19: Discrepancies exist between the cl assi f i ca ti on of certain test abstracts in FSAR Subsection 14.2.12 and FSAR Figure 14.2-3. The-following test abstracts should be classified as stated.
Test Section. Number Description Type l 14.2.12.16.2 Reactor Coolant System Sampling for Core Load IST l- '14.2.12.17.1 Turbine Plant Sampling System SOV l 14.2.12.31.'2 Plant Operation Following Loss of FW Heater IST ;
L 14.2.12.54.1 Normal AC Power Distribution System SOV j l' . 14.2.12.63.1 Engineered Safety Features Equip. HVAC IST
[ 14.2.12.68.1 -Aux. & Waste Handling Bldg. HVAC SOV 14.2.12.69.2 Misc. Sec. Plant HVAC Systems- SOV i
.14.2.12.70.1 . Condensate Polishing Bldg. HVAC Systems SOV i Wa \
640.20 -FSAR Subsection 14.2.12 test abstracts should be' modified to ensure 4 'a that-the accumulator isolation valves can open under the maximum
, differential pressure -conditions .of zero RCS pressure and maximum expect *nd accumul ator precharge pressure, or technical justification 4-t cr . RG 1.79, Preoperational Testing of Emergency Core Cooling Systems
, for Pressurized Water Reactors, should be provided in FSAR Table 1.8-1.
S 640.23 FSAR: Subsection 14.2.12.6.5 (Verification of Plant Performance
'Following Turbine Trip Coincident with Loss-of-Offsite Power at Load) shoul d be modified to secure appropriate sections of the Safeguards Area Ventilation System which are ac powered to simul ate loss of ac econditions during the 2-hour turbine-driven auxiliary feedwater pump test. Also, acceptance criteria (2) should be rewritten as it currently is unclear.
640.25 (1) FSAR 'puestion 410.24 does not necessarily address flooding caused by automati c and/or manual fire protection (water) systems. Provide assurance that adequate drainage is provided to preclude flooding.
.(2) FSAR Subyection 14.2.12.50.2 1(Wet- Pipe and Deluge Sprinkler System Test) should be modified to verify that nozzles. serving indoor facilities are air-flow tested and that these tests overlap the water flow tests.
640.26- (1)- FSAR Subsection 14.2.12.53.1 (Main Generator and Transformer Auxiliaries Test) or other test abstracts should be modified to demonstrate proper operation of the isolated phase bus duct cooling system under fully loaded conditions.
(2) FSAR Ouestion 430.11 deals with the Class 1E ac system.
Demonstrate that Class 1E de loads necessary for_ safe shutdown are operable at minimum dc voltage.
-( 3 ) FSAR Subsection 14.2.12 has yet to be modified to add full load testing of vital bus inverters.
640.27 FSAR Subsection.14.2.12.55.1 -(Emergency Diesel Generator System Test)
- should be modified to demonstrate proper operation during complete
' loss of- load o? technical justification should be provided for
- exception to RG !.108. *eriodic Testing of Diesel Generator Units
'Used as Unsite Electric" Power Systems at Nuclear Power Plants.
640.30 The following items regarding conformance with Regulation Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Pl ants, Appendix A,.should be addressed:
(1) Provide technical justification as to why FSAR Subsection 14.2.12.8.11 (Reactor Vessel- Internals Inspection) has been
-deleted, fi h i s test- is used to provide conformance with
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'.. . ' Program,- as ' stated in FSAR Table 1.8-1 and FSAR Subsection
,3.9N.2.4 (1.a.3, 4.s, 5.p).
1 (2) hSAR Subsection 14.2.12 test abstracts should be modified to i address; leak detection systems located'outside of containment (1.j.7).
- (3) FSAR Subsection 14.2.12.14.1 (Containment Leakage Monitoring
. System) should specify which atmospheric parameters are-monitored (1.j.22).
-(4) FSAR Subsection 14.2.12.13.1 (Containment Vacuum System Test) or other appropriate test abstract should include testing of containment humidity monitors (1.j.22).
(5) FSAR Subsection 14.2.12 test abstracts should include testing of condenser hotwell level control system at power or technical justification should be taken to RG 1.68 (5.s).
(6) FSAR Figure 14.2-3 should be modified to identify testing of gaseous and liquid radwaste systems at power (5.c.c).
640.31 FSAR Subsection 14.2.1.2 states that System Operability Verification
<^. ( S OV.) tests Are performed as part of'the Preoperational. Test, Phase.
However, the following~SOV tests are to be accomplished partially or completely during the Initial Startup Test Phase. These tests should l either be designated as Initial Startup Tests, or FSAR Subsections 14.2.1.2 and'14.2.1.3 should be rewritten to clarify the use of SOV tests during both the Preoperational and Initial- Startup Test
( phases.
[ Section Number Description
- . 14.2.12.7.3 Verification of Performance Calculation 14.2.'12.17.1 Turbine Plant Sampling System l 14.2.12.28.2 Condensate Polishing System Capability
[ 14.2.12.30.1 Feedwater Heater Drain System Test 14.2.12.33.1 Automatic S.G. Level Control Test
-14.2.'12.36.2 Turbine Overspeed Trip Test
, 14.2.12.38.1 Moisture Separ. & Reheat Control System 14.2.12.39.1 Turbine Stretch Test 14.2.12.44.2 Cooling Tower Performance Test
'14.2.12.57.1 Plant Communications-lost 14.2.12.63.2 Fuel. Decont. Bldo. & Pipe Tunnel HVAC 14.2.12.71.1 Loose Parts Monitoring System Test 1