IR 05000423/1985051

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Insp Rept 50-423/85-51 on 850819-23,26-29,0903-06 & 09-13. No Violation Noted.Major Areas Inspected:Preoperational Test Program,Including Witnessing of ESF Tests
ML20138G161
Person / Time
Site: Millstone 
Issue date: 10/18/1985
From: Eselgroth P, Marilyn Evans, Finkel A, Van Kessel H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138G129 List:
References
50-423-85-51, NUDOCS 8510250417
Download: ML20138G161 (13)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-423/85-51 Docket No.

50-423 License No. CPPR-113 Priority Category

Licensee:

Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3

Inspection At: Waterford, Connecticut

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l Inspection Conducted: August 19-23, August 26-29, Sept. 3-6, & Sept 9-13, 1985 Inspectors:

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y K. F.g an Kessel,d[ factor Engineer date

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W/eAss-A. E. Finkel, Reactor Engineer date W O ftcro

/oh6 /85 M. A. Evans, Reactor Engineer date Approved by:

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, g P. (f/Eselgroth, N ef, Test Programs date

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Section, 08, DRS

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Inspection Summary:

Inspection on August 19-23, August 26-29, September 3-6, and September 9-13, 1985 (Inspection No. 50-423/85-51)

Areas Inspected: Routine unannounced inspection of the preoperational test program, including witnessing of Engineered Safeguards Features (ESF) Tests, Reactor Plant Component Cooling Water Pump Performance Test (3CCP* PIA), Normal Service Station Transformer Test (T3349 PA-002), and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test run of Emergency Diesel Generator (EDG) Unit A; test results evaluation of 5 completed

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tests; assessment of EDG-status; assessment of the Controlotron measurement applications. The inspection involved 184 hours0.00213 days <br />0.0511 hours <br />3.042328e-4 weeks <br />7.0012e-5 months <br /> on site by three NRC region l

based inspectors.

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i DETAILS

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1.0 Persons Contacted l

Northeast Nuclear Energy Company (NNECo)

A. Andreae, QC Supervisor R. Bradley, Startup Engineer M. Brown, I&C Supervisor

  • J. Crockett, Superintendent Millstone 3 D. Dickerson, Startup Engineer E. Fries, Startup Engineer
  • M. Gentry, Assistant Startup Supervisor N. Hulme, Startup Engineer

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W. A. Loweth, Startup Engineer D. Miller, Jr., Startup Manager f

Northeast Utilities Service Company (NUSCo)

i B. Carlson, Project Engineer

  • E. J. LaWare, Engineering Technologist, QA j
  • K. W. Gray, Staff Assistant B. Kaufman, Project Engineer

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  • L. J. Nadeau, Project Engineer

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P. A. O'Connell, NCQA Engineer

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B. Nichols, Project Engineer J. Rhodes, Project Engineer Stone and Webster Engineering Corporation (SWEC)

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W. Matejek, Project Advisory Engineer

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i Westinghouse Electric Company C. Callaway, Startup Lead Engineer U.S. Nuclear Regulatory Commission (USNRC)

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  • R. J. Summers, Project Engineer

2.0 Licensee Actions on Previous Inspection Findings

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j 2.1 (0 pen) Unresolved Item, " Fuel Oil Filters of EDGs as a Fire Hazard" (423/85-25-01)

Reference

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(1) Inspection Report 50-423/85-25, issued August 22, 1985 l

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Discussion A Design Deficiency Report (DDR 550) was issued to address the problem.

It was determined that the present location of the filter was selected by the designer to minimize pressure losses in the fuel oil system.

Reloca-tion, however, has not been ruled out as an option. Other options are being considered including spray shields. The inspector will continue to follow the corrective actions taken by the licensee on this item.

2.2 (Open) Unresolved Item, " Identification of parts for EDG - Fuel Oil Filters" (423/85-43-02)

References:

(1) Inspection Report 50-423/85-25, issued August 22, 1985 (2) Inspection Report 50-423/85-43 Scope The fuel oil filter parts had design deficiencies which were corrected by the manufacturer (Nugent).

The objective of the inspection (see ref. 1)

was to verify that the identification of the new modified components was maintained throughout purchasing, storage, and installation.

Discussion The licensee has now firmly established that the required part identifi-cation does not exist.

Identification of the new parts via a manufac-turer's drawing is being pursued with the manufacturer (Nugent). The licensee has agreed to tie this information in with the Plant Maintenance Management System (PMMS) to assure positive identification in the future.

The inspector will continue to follow corrective action by the licensee on this item.

2.3 (0 pen) Unresolved Item, " Valve Position Indication Problems" (423/85-02-01)

References (1) SWEC status report, " Valve Position Indication Problems", dated September 13, 1985 (2) Inspection Report 50-423/85-43 Discussion According to reference (1), good progress has been made to date.

The objective is to solve all of the problems prior to the Hot Functional Test.

The inspector will continue to follow the corrective action taken by the licensee on this item.

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3.0 Preoperational Test (POT) Program

3.1 Test Witnessing I

Scope Selected steps of the following Engineered Safety Features (ESF) related

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preoperational tests were witnessed by the inspector:

31NT-2003, "ESF Without Loss of Normal Power", Rev. 1, approved

August 24, 1985 i

3 INT-2004, "ESF With Loss of Offsite Power", Rev.1, approved

August 24, 1985

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T3346AP003, " Emergency Diesel Generator (EDG) - A Licensing Test,"

Rev. O, approved October 15, 1984

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and the following other preoperational test:

i T3347BA002, " Normal Station Service Transformer (NSST)", identified

as 15G

    • % Rev. O, approved March 5, 1985

Test witnessing by the inspector included observations of:

Overall crew performance.

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Use of latest revised and approved procedure by test personnel. '

t Designation of one person in charge of conducting the tests.

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Availability of sufficient test personnel to perform the tests,

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Coverage of test prerequisites.

  • Use of acceptance criteria to evaluate test results.

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I Verification that plant supporting systems are in service.

  • In-service status of calibrated special test equipment required by

the test procedure.

Adherence to the test requirements of the test procedure during the

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j Timely and correct action by test personnel during the performance

of the tests.

Data collection for final analysis by test personnel.

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The inspector independently verified readings of system parameters during the tests.

j Discussion l

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In test 3 INT-2003, signals a're generated at the containment pressure

transmitters to simulate a Safety Injection Signal (SIS), a Main Steam

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Isolation Signal (MSI) and a Containment Depressurization Actuation Signal

(CDA). The two safeguard trains (Orange and Purple) are tested indepen-i dently for the three signals. Before and after valve position lists are

included in the procedure as Appendices. The inspector witnessed the j

initiating steps for each of the three signals and, independently veri-fied the correct actuation of alarms and controls on the main control panels. The inspector also verified the correct valve position before and after the individual actuation signals. A number of controls and valves did not respond correctly to the signals.

Each of these items were identified in the course of processing the appendices.

Test changes and

"UNSATS" (unsatisfactory items) were written up by the test engineers directing the tests. All of these Test Changes and UNSATS were collected j

by the inspector for review.

The test itself went smoothly. No major

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problems, which would invalidate the test, were encountered, j

Test 3 INT-2004, initially, was aborted due to improper functioning of relays af ter initiation of the loss of offsite power (LOP). The test, however, was repeated successfully after corrective actions were completed. The inspectors witnessed the CDA/ LOP test for train A (Orange). The data points of T3346AP005 were found to be in accordance

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with the test procedure. These test data were sampled on a three hour l

basis over an eight hour period. All observed test results were found to be within specified criteria.

Test T3346AP003, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run for EDG-A, was successfully accomplished

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on August 27/28, 1985.

The inspector independently tock periodic read-

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ings on the EDG-A panels during the test period. No problems or upsets

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were noted. The procedure, however, has not been completed. The con-

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secutive 35 starts and stops on the EDG have not been completed yet.

l These test steps will be done after the Hot Functional Test.

l Test T3347BA002 on the Normal Station Service Transformer (NSST) was successfully accomplished. The inspector witnessed steps 7.11.1 through

7.11.7 of the procedure including th,e initial energization of the NSST

Unit B (15G-35B). No problems were' encountered.

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Findings Test results observed by the inspector indicated that acceptance criteria had been met for those portions of the test that had been witnessed.

No l

f tems of noncompliance were identified.

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1 3.2 Test Result Evaluation

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Scope The test procedures listed in ATTACHMENT A were reviewed to verify that adequate testing was accomplished in order to satisfy regulatory guidance

and licensee commitments and to ascertain whether uniform criteria were being applied for evaluating completed preoperational tasts in order to assure their technical and administrative adequacy.

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Discussion

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The test results were reviewed for:

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Test changes,

Test exceptions.

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j Test deficiencies.

  • Acceptance criteria.

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Performance verification.

  • a Recording of conduct of test.

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QC inspection records.

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System restoration to normal.

  • Independent verification of critical steps or parameters.

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Identification of test personnel.

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Verification that the test results have been approved.

  • In all of the reviewed procedures there are no entries for QC/QA parti-

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cipation. This item was discussed with the two QA/QC units participating in the preoperational test program i.e. NUSCO-QA and NNECO-QA/QC.

NUSCO-QA pointed out that they have a member on the PORC/JTG committee which reviews the report for completeness of internal evaluation.

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In addition, both NUSCO-Q/A and NNECO-QA/QC perform in process and post test surveillances. NUSCO-QA does their surveillances after the test while NNECO-QA does in process surveillances. The inspector has been following these QA efforts on the POT program by reviewing a number of

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surveillances on each inspection trip.

For further details see section 4 of this report. The inspector had no further questions on this item.

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'a A r. umber of "UNSATS',' and test changes in the reviewed test reports do not

have any entries for retest results, completion of repairs, or evaluations l

for retest. A specific example is UNSAT 3142 of procedure T3308-P001.

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Retesting requirements are another item of concern.

If a component was

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disqualified for. participation in an integrated test, it may be judged

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satisfactory by the test engineer to continue the integrated test.

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that is the case, what kind of retest will be done for that component, i.e.

phase 1 or phase 2 test? Both of the above questions need further dis-cussionwitht%' licensee.

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No other, items of concern were identified within the scope of review.

Findings a

The items of concern, identified above, have been assigned as Unresolved i

Items:

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Recoiding of retest results, completion of repairs, and evaluations

for retest (423/85-51-01).

Definition of retest requirements for UNSATS and test changes found

during integrated and phase 2 tests (423/85-51-02).

No violations or deviations were identified within the scope of the review.

i 3.3 Emergency D esel Generator (EDG) Status Both EDGs have satisfactorily completed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test runs.

The 35 con-secutive starts and stops, however, were not included yet in these test runs (T3346AP003 and 4). These tests will be completed after the Hot t

Functional Test.

l The brush holder support problem appears to be resolved with the instal-lation of the modified design support bars.

In this design modification, particular attention was paid to the fatigue aspect determined to be the cause of th,e experienced support failures.

l High delta P readings were experienced on the lube oil strainer of EDG-A during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run (prerequisite) for 3 INT-2004.

Problems, however,

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were resolved and the test was continued.

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Dirt problems with the fuel-oil systems of the EDGs appear to be resolved.

The inspector explored the possibility of other causes for the experienced fuel oil pump failures. Oil viscosity aspects were discussed with the responsible test engineer.

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3.4 Hot Functional Test (HFT) Status

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Preparations for RCS heat up cperations were started on September 6, 1985. The actual start of this RCS heat up, however, is currently scheduled for mid-October.

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Valve line ups for all the systems used in the HFT have started. Many UNSATS have to be processed before all of the prerequisites and initial conditions for the HFT can be satisfied.

3.5 Reactor Protection System (RPS) Test Status It was noted by the inspector that the POT procedures for RPS testing, T3406-P and T3409-P, had been deleted.

These tests are mandatory tests for NRC witnessing. Discussions with the licensee revealed that these test procedures will be replaced by surveillance type procedures namely:

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Station Procedure SP3446F31, " Refueling SSPS Tests", Rev. O, in

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typing.

Station Procedure SP3446811, " Solid State Protection System (SSPS)

Operational Test", Rev. O, approved 9-11-85.

Discussions with the licensee revealed that the existing procedures had to be revised anyway because of the licensee's decision to pursue NRR approval for n-1 loop operation. Two additional reactor trips were introduced to satisfy the n-1 loop operation.

The whole RPS system was modified to satisfy the n-1 logic.

Since these tests are mandatory for NRC witnessing, the NRC is to be notified in sufficient time before the start of the test. The licensee committed to do so.

The first RPS tests are currently scheduled to start in October.

Since these tests will be done in accordance with station procedures (not preoperational test procedures), the initial test will yield baseline data which will be recorded in the Plant Maintenance

Management System (PMMS).

4.0 QA/QC Interface Scope The participation of NUSCO-QA and NNECO-QC/QA in the review and recording of test result evaluations was reviewed and evaluated by the inspector.

The objective of this inspection was to determine that adequate coverage was provided by the two groups for test result evaluations.

Discussion It was noted during the test results evaluations of this inspection (see paragraph 3.2) that there were no entries for QC/QA in the test records.

NUSCO-QA pointed out that the PORC/JTG committee has a NUSCO-QA member.

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This member participates in the evaluation of the test results.

In addi-tion NUSCO-QA performs audits on the completed tests.

Certain completed POTS are selected beforehand for examination in a program designed to l

achieve optimum coverage for available qualified personnel. A re-evalua-tion of this program has been initiated to consider the coverage provided by the NRC. The inspector obtained a copy of the existing program.

NNECO-QC does in-process surveillances but does not get involved in test results evaluation. Their reports on their surveillances, however, do t

appear in the test records.

In continuation of the assessment of QA/QC involvement with the POT program, the inspector reviewed the surveillance reports as listed in Attachment B.

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All of these surveillances are related to the ESF tests.

The review of the surveillance reports indicated good coverage of the ESF tests.

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Findings

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No violations or deviations were noted in the review of the surveillance reports.

j 5.0 Independent Inspection and Measurement 5.1 Controlotron Flowmeter References (1) Inspection report 50-423/85-43

Scope The objective of this inspection.was to (continue to) determine if this

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flowmeter could yield reliable and repeatable results for both stainless I

and carbon steel piping installations.

Discussion The inspector discussed the Controlotron application for the service water system with NUSCO-Engineering. The instrument is located in the discharge structure near an exposed elbow of the service water piping which is mostly underground piping.

Readings in that location have been inconsistent and unacceptable. Measurements appear to be different depending on what pump

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is being used or what mounting axis is used for the sensing elements.

It is felt that this instrument cannot provide a good water velocity average for the cross section of the pipe because of asymmetrical velocity profiles.

These profiles are different for operation of different pumps and also change when the axis of the sensing elements is changed. A solution tc this problem has not been found to date.

This particular problem demon-

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strates that there are applications of the Controlotron where this instru-

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ment does not yield acceptable results regardless of good installation per vendor instructions. The inspector will continue to follow this item of concern in future inspections.

i When the pumps are all done the same way, the phase 2 test for the system

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will be repeated to determine if adequate flow rates can be obtained for

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all of the system consumers. The inspector will continue to follow this l-

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unresolved item to its successful conclusion.

Findings The item of concern identified above, has been assigned as Unresolved Item (423/85-51-03).

6.

Exit Interview At the conclusion of the site inspection on September 13, 1985, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1).

The findings were identified and previous inspection ite.r were discussed.

At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensee representatives during this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.

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Attachment A 50-423/85-51 Test Result Evaluation (TRE)

Proc. No.

Title Rev.

Approval Date T3316AP002 S2condary Hydro

Jan. 9, 1985 T3308-P001 HPSI Flcw Balance Test

Dec. 14, 1984 T3321DA Feed Pump Drive Lube Oil

Dec. 4, 1984 T3314GP Intak? Structure Ventilation 0 July 2, 1984 3 INT 2005 Reactor Cavity Seal Ring

March 1, 1985

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Attachment B 50-423/85-51 NUSCO-QA Reviewed Surveillance Reports Report No.

Title Approval Date NUSCO-QA 1C3741 ESF w/o Loss of Normal Power.(L.O.P.)

8/21/85 TC3745 ESF w/o L.O.P. - Trouble Shooting 8/22/85 TC3746 ESF w/o L.O.P.

8/21/85 TC3752 ESF w/o L.O.P. - Test Instrumentation 8/22/85 TC3759 ESF w/o L.0.P.

8/23/85 TC3748 ESF w/o L.O.P. - Test Changes.

8/22/85 TC3766 Instrument Calibration Testing 8/27/85 TC3773 ESF w/o L.O.P.

8/28/85 TC3756 ESF w/o L.0.P.

8/26/85

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TC3776 ESF w/o L.0.P.

8/29/85 TC3777.

ESF w/o L.O.P. - Test Changes 8/29/85 TC3778 ESF w/o L.O.P.

8/29/85 TC3779 ESF w/o L.0.P. - Test Changes 8/28/85 TC3781 ESF with L.0.P. - Diesel Start and Sequential 9/3/85 Loading TC3782 ESF with L.0.P.

9/3/85 TC3787 ESF with L.0.P.

'B' Diesel Operation 9/4/85 TC3788 ESF. with L.0.P.

9/4/85 TC3789 ESF with L.O.P. - Major Equipment Energizing 9/4/85-TCS791 ESF with L.0.P.

9/4/85 TC3806 ESF with 'L.0.P.

9/6/85

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Report No.

Title Approval Date NUSCO-QA S85-103 ESF with Loss of Normal Power (LOP)

9/11/85

- Pump Walkdown

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S85-104 ESF with LOP - Main Board Surveillance 9/11/85 585-106 ESF with LOP - Test #4 9/10/85 S85-105 ESF with LOP - Test #3 9/5/85 585-102 ESF with L.0.P.

9/11/85

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