ML20202D930
| ML20202D930 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/26/1986 |
| From: | Eselgroth P, Florek D, Wink L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20202D883 | List: |
| References | |
| 50-354-86-27, NUDOCS 8607140250 | |
| Download: ML20202D930 (14) | |
See also: IR 05000354/1986027
Text
{{#Wiki_filter:. . . U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-354/86-27 Docket No. 50-354 License No. NPF-50 Licensee: Public Service Electric and Gas Company 80 Park Plaza Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station, Unit 1 Inspection At: Hancocks Bridge, New Jersey Inspection Conduct
- May 19-30) 1986
Inspectors: . . % D'. Florek Lead Reactor Engineer f da
- ?
//n/p <4s B4 t. Winii, Rp64 tor Engineer date Approved by: [[f/ [ MP. Eselgrotbf/Ahief, Test Programs Section, date / OB, DRS Inspection Summary: Inspection on May 19-30, 1986 (Inspection Report No. 50-354/86-27) Areas Inspected: Routine, unannounced inspection of the power ascension test program, technical specification surveillance activities for operational condition 2, independent measurements and evaluations, QA/QC interfaces, licensee action on previous inspection findings and tours of the facility. Results: One violation was identified for implementing temporary procedures prior to the required review and approval (see Section 4). NOTE: For acronyms not defined refer to NUREG 0544 Handbook of Acronyms and Initialisms. 8607140250 860709 ' PDR ADOCK 05000354 0 PDR
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l DETAILS 1.0 Persons Contacted Public Service Electric and Gas Company (PSE&G)
- J. Carter, Startup Manager
G. Chew, Power Ascension Results Coordinator G. Conner, Operations Manager G. Daves, Senior Engineer, Operations
- R. Donges, Licensing Engineer
- M. Farshon, Power Ascension Manager
- J. Fischer, Quality Control (QC) Supervisor
B. Forward, Power Ascension Administration
- S. Funsten, Instrument and Control (I&C) Supervisor
- A. Giardino, Manager Station Quality Assurance (QA)
- R. Griffith, Principal QA Engineer
- P. Krishna, Assistant to the General Manager
- S. LaBruna, Assistant General Manager
- M. Metcalf, Principal QA Engineer
L. Neuman, Senior Nuclear Shift Supervisor J. Montgomery, Maintenance Surveillance Coordinator S. Riggle, QA Engineer E. Riley, Senior Nuclear Shift Supervisor
- J. Rucki, Maintenance Engineer
E. Rush, I&C Surveillance Coordinator W. Ryder, Operations Surveillance Coordinator
- R. Salvesen, General Manager, Hope Creek Operations
- W. Schell, Power Ascension Technical Director
W. Schultz, Manager QA Programs and Audits M. Trum, Senior Nuclear Shift Supervisor U.S. Nuclear Regulatory Commission
- D. Allsopp, Resident Inspector
- R. Borchardt, Senior Resident Inspector
The inspector also contacted other members of the licensee's staff including senior nuclear 'iift supervisors, reactor operators, test engineers and other members of the technical staff.
- Denotes those present at the interim exit meeting on May 23, 1986.
- Denotes those present at the exit meeting on May 30, 1986.
2.0 Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (354/86-24-02) Performance of power ascension tests in conformance with administrative procedures. As discussed in Section 3.3 the inspector reviewed the approved test results packages
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covering initial fuel loading. The licensee had identified and evaluated a number of administrative non-compliances which occurred during initial fuel loading. Deficiency Report HPA-86-005 was issued to document these non-compliances and institute corrective actions. The root cause of the . problem was identified as a lack of procedural understanding on the part ' of test personnel. To address the root cause the licensee is implementing an augmented training program for test personnel and has committed to completing this program prior to the start of heatup testing. Pending completion of this training program, and subsequent interviews with test personnel, this item remains unresolved. 3.0 Power Ascension Test Program (PATP) l 3.1 References
Regulatory Guide 1.68, Revision 2, August 1978, " Initial Test Programs for Water-Cooled Nuclear Power Plants", 2 i ANSI N18.7 - 1976, " Administrative Controls and Quality l Assurance for the Operational Phase of Nuclear Power Plants", !
Hope Creek Generating Station (HCGS) Technical Specifications,
April 11, 1986,
HCGS Final Safety Analysis Report (FSAR), Chapter 14, " Initial j Test Program",
HCGS Safety Evaluation Report, Chapter 14, " Initial Test Program",
Station Administrative Procedure, SA-AP.ZZ-036, Revision 3, " Phase III Startup Test Program", l
Specification NEB 0 23A4137, Revision 0, " Hope Creek Startup Test Specification" and -
HCGS Power Ascension Test Matrix, Revision 3 , 3.2 Overall Power Ascension Test Program Discussion l The inspector held discussions with the Power Ascension Manager, Power
Ascension Technical Director and other members of the PATP staff to determine the status of testing, test results evaluation and test ' procedure reviews. The inspector determined that, with the exception ' of the initial criticality testing sequence, all open vessel testing , had been completed and test results evaluation was proceeding smoothly. i
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4 . 4 i The licensee indicated that plans were being made to shift the initial criticality testing sequence from Test Condition Open Vessel to Test Condition Heatup and that a revision to the procedure was in process to allow initial criticality to be performed in Operational Condition 2. The inspector witnessed portions of the licensee's Technical Review Board discussions on the revision to the initial criticality procedure TE-SU.ZZ-041, Full Core Shutdown Margin Demonstration. The inspector also witnessed portions of the Technical Review Boards final review and comment resolution of the completed test TE-SU.KE-032, Fuel Load- ing. During this review, the inspector observed the dispositioning of t6,e Quality Assurance comments. Findings No unnacceptable conditions were noted. 3.3 Power Ascension Test Results Evaluation Scope The power ascension test results listed in Attachment A were reviewed for the attributes identified in Inspection Report 50-354/86-24. Discussion Except as discussed below, all tests listed in Attachment A were tech- nically reviewed and discussed in Inspection Report 50-354/86-24. --TE-SU.ZZ-011, Chemical and Radiochemical Pre-Fuel Load Test The inspector reviewed the approved test results package and varified that all acceptance criteria were satisfied. Two results deficiencies were identified for balance of plant systems and properly disposition- ed. --TE-SU.ZZ-173, NSS Systems Piping Thermal E<pansion Sensor Data The inspector reviewed the approved test results package. This test contained no acceptance criteria and only obtained baseline data against which the subsequent thermal expansion of the main steam and recirculation systems would be evaluated. Findings No unacceptable conditions were identified.
. . 5 4.0 Surveillance Test Activities Scope The inspector reviewed the surveillance procedures listed in Attachment B to ascertain whether the licensee is conforming with technical specifica- tions for operational condition 2 to support initial criticality. The inspector reviewed selected procedures to determine if the procedures sa- tisfied technical specification requirements, reviewed selected completed surveillance procedures, witnessed performance of selected surveillance procedures and also reviewed the computer based surveillance log to ascer- tain that the surveillance procedures were completed. Discussion The inspector focused on surveillance procedures under the responsibility of the I&C and Operations Departments. Specific findings on each are dis- cussed. Operations Department During review of the completed Operations Department surveillance procedures relating to inservice testing the inspector noted that the operations de- partment was utilizing temporary procedures (TE) to perform surveillance activities (Attachment B lists nine such TE procedures). Furthermore, the inspector noted that the licensee was utilizing the On-the-Spot Change (OSC) method to approve use of the procedure in the field. The inspector specifically addressed surveillance procedure OP-TE.EE-101 to assess the licensee method in the use of OSC to approve temporary procedures for use in the field to satisfy surveillance requirements. The licensee administrative procedures SA-AP.ZZ-001, Preparation of Sta- tion Procedures and Procedure Revision, Revision 6 dated February 4, 1986 and SA-AP.ZZ-032, Review and Approval of Station Procedures and Procedure Revision, Revision 3 dated February 4, 1986 describe the use of temporary procedures and on-the-spot changes. Per these procedures, an On-the-Spot Change (OSC) is a procedure revision that is implemented temporarily pending review and approval by the normal revision process. Also, an OSC shall not alter the intent of a procedure and shall only be used in situa- tions where a critical station activity would be delayed by the normal revision process. The administrative procedures indicate that a Temporary Procedure is expected to be used only one time to accomplish or support a specific work order; for use during unusual plant conditions; or when a temporary modification is installed and requires deviations from approved system operating procedures. - - - - - - - - -
- . .- -. -. . _- . . . - . ..- e e . 6 The administrative procedures describe the approval process for an OSC to be a review and concurrence by a supervisor from the procedure's origina- ting department and approval by the Nuclear Shift Supervisor prior to implementation and within 14 days of implementation the OSC shall be approved as a procedure revision. This entails review by a Station Quali- fied Reviewer (SQR) and approval by the Department Manager. For station procedures, the administrative procedures identify the approval process j as a review by a Station Qualified Reviewer and procedure approval by th l Department Manager prior to implementation. l The licensee began the practice of using an OSC to implement a temporary i procedure based on a memorandum from the Operations Managar to the Opera- tions Supervisors on February 11, 1985, and had been using this exten- ' sively since then and was currently in use. l The inspector expressed concern that the licensee was using temporary i procedures approved as an OSC and was not folicwing the administrative l procedure for review and approval of a station procedure. The representa- tive example selected by the inspector (OP-TE.EE-101) was approved as an OSC on April 25, 1986, performed on April 25, 1986 and as of May 22, 1986 , had not completed the required SQR review and Department Manager Approval. ! Other temporary procedures processed in a similar manner include OP-TE. AB-102, OP-TE.BC-101, OP-TE.BC-105, OP-TE.BE-101, OP-TE.JE-008, 1 OP-TE.AE-102, OP-TE.SE-101 and OP-TE.BF-101. ! The inspector noted the licensee commitment in FSAR Section 13.5.2.1.5 that temporary procedures require the same revies and approval process as l other plant procedures including independent review. Furthermore, tech- l nical specification 6.8.2 requires that procedures for surveillance and l test activities of safety related equipment shall be reviewed and approved prior to implementation. The technical specification requires a review by ' either the SORC or a designated Station Qualified Reviewer and approval by the Department Manager. The licensee's ac.ivities related to the use of temporary procedures to satisfy surveillance requirements, by imple- i menting the procedure with only the approvals required by an OSC, with the ' SQR and Department Manager review after the fact, is contrary to the requirements contained within technical specification 6.8.2 and is j considered a violation (354/86-27-01). i Following the identification of this item, the licensee immediately stop- ped the practice of implementing temporary procedures via the methodology l l of an OSC. The licensee will also review the backlog of the completed ! surveillance procedures implemented via a temporary procedure that have ! not yet completed the SQR and Department Manager approval. This affected l approximately 60 surveillance tests. The inspector concluded from the l review of the nine "as-run" temporary procedures utilized to satisfy tech- ! nical specifications, that the procedures appeared to address the surveil- i lance requirements in the technical specifications. The licensee also ' indicated that a modification to the administration procedure would also be made to make it clear that temporary procedures require the same level of review and approval as normal plant procedures prior to implementation. i i . _ _ _ _ _ _ , ... _ - _ _ _.___., __ . _ _ _ _ _ _ . _ _ _ _ _ . . _ . . _ , _ , . _ _ _ , _ , _ _ _ _ _ _ _ . , _ _ - _ _ . . _ . . _ , _ _ _ ~ ,
. . 7 Following identification of the problem the inspector discussed the con- cern with Quality Assurance representatives. QA had identified a similar concern during review of procedure OP-TE.KJ-007 and issued a corrective action request (CAR) dated April 25, 1986 with a reply requested May 9, 1986. QA issued the CAR since among other things, the procedure was not approved prior to release to the field by the Department Manager as required per the administrative procedures. The responding organization, Operations, requested an extension to May 23, 1986. The licensee action to the CAR will also be assessed in the response to the violation identified above. Even though the OSC methodology was not appropriate for approval of tempo- rary procedures, the inspector was also concerned about the tracking of the OSC approval process. The inspector noted that the formal OSC appro- val for OP-TE.EE-101 had exceeded 14 days. The licensee representative from the Operations Department indicated that they had several OSC appro- vals for temporary procedures that had exceeded the 14 days requirement for formal approval. The inspector reviewed the method for tracking OSCs in the Operations Department and noted that tighter controls on the 14 day clock were required and the licensee representative also agreed. This item will also be tracked under the corrective action to be taken for the above violation. The inspector also reviewed the practice of using temporary procedures and OSC in other departments (Maintenance, Reactor Engineering, and Instrument and Control) and did not observe the deficiencies found in the Operations Department. M_SIV Testing During inspector's review of OP-TE.AB-102 he questioned the technical ade- quacy of the methodology used to calculate the Main Steam Isolation Valve (MSIV) closure time. Whereas the acceptance criteria was consistent with the technical specification (3-5 seconds), the methodology utilized only determined the time from switch actuation until the closed limit switch was actuated. Based on review of the preoperational test data, the closed limit switch may in fact be representative of only 90% closed. Thus the measured stroke time were not corrected to obtain full closure time. The actual limit switch position is being determined to support MSIV stroke time determination for the power ascension tests and will be utilized to provide a correcticn factor to the surveillance procedure. Inspector re- view of the MSIV stroke times determined in OP-TE.AB-102 appeared accept- able when a conservative correction factor is applied except for the out- board MSIV B which had a measured time of 4.9 seconds. This item will be considered unresolved pending licensee applying the appropriate correction factor (354/86-27-02).
__ _ - - _ - _ - _ _ ______ . - _ _ _ . _ _ _ _ _ . _ __ _ _____ _ ___ _ r . i . j 8 l . l In addition, the inspector expressed concern about correction factors to j be applied to compensate for the MSIV stroke time " hot versus cold". The l inspector indicated that further discussion would occur after tests per- l formed on the MSIVs during the power ascension program, f j RHR Surveillances { The inspector did a cross check of the RHR system inservice surveillance tests to support the RHR primary containment isolation valves listed in ' l Table 3.6.3-1 of the technical specifications. The inspector noted that RHR Suppresion Pool Return Valves HV-F011A and HV-F0118 were not included in the surveillance procedures. The licensee indicated that these valves are no longcr considered remote manual valves since the steam condensing mode of RHR is no longer part of the plant design and should be relocated to the "other valve" part of Table 3.6.3-1 of the technical specifications. 4 The licensee P&ID's indicated the valve to be lock closed, tagged and power removed from the operator. Inspector field observation concluded that the valve was locked closed and tagged. The licensee also indicated a techni- cal specification change would be made to place these valves in the proper ' section of Table 3.6.3-1. Pending the technical specification change, this will remain an unresolved item (354/86-27-03). 1 i Operations Findings $ As discussed above, one violation was identified for not properly approv- ing temporary procedures prior to use to perform surveillance test activi- ties. Two unresolved items were identified for MSIV closure times and l Technical Specification changes for RHR containment isolation valves. 3 I&C Department i ! The inspector focused on the actual performance of specific I&C procedures to assess procedural adequacy, personnel performance and equipment oper- ability. Ir addition, the inspector reviewed the in place controls for i documenting and processing procedure revisions, including On-The-Spot Changes (OSC), and for documenting and resolving equipment deficiencies. The inspector determined that the surveillance procedures released for i
field performance were adequate to satisfy technical specification require- ments. The I&C department was found to have a comprehensive system for tracking OSCs and insuring review and approval in accordance with admint- 1 strative procedures and technical specifications. Deficiencies in proce- i dures identified during field performance were evaluated for generic app 11- l cability and the information obtained was used during revisions to similar ,
procedures. l 4 i !
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. W 9 Personnel performing surveillance procedures appeared qualified for the tasks involved. When difficulties were encountered during the performance of procedures the technicians were quick to obtain any required engineering assistance to resolve the problems. Trouble shooting appeared to be a well thought out evolution. Equipment trouble identified during surveillance procedure performance is effectively documented and resolved by use of the deficiency reporting (DR) system. I&C Findings No unacceptable conditions were identified. 5.0 Scram Discharge Volume Valves The inspector reviewed a recent licensee equipment failure that occurred to one of the scram discharge line drain valves. The drain valve is a 2 inch Hammel Dahl valve. A portion of the bolt that holds the coupling halves together (that join the actuator shaft to the valve stem) sheared off at the point where the bolt also connects the manual engaging mechan- ism to the coupling halves. The coupling halves did not appear to be se- parated, however, and the valve appeared to be automatically operable. The licensee investigation into the failure determined that the manual actuation mechanism was not in the neutral posit' to permit unimpeded automatic action. When the valve handwheel pos' .on indicated a neutral position, the sliding scale was aligned such t' t it indicated neutral, but was partially engaged. The licensee corre.tive action included obtain- ing a new mechanism, assuring neutral position and providing a lock wire to lock the manual handwheel in the neutral position. This failure was addressed in GE SIL-422 dated May 13, 1985. The inspector also noted that a related failure, caused by the manual mechanism not being in the neutral position, occurred at another plant and the corrective action there also included periodic visual observation of the correct alignment and coupling which is being considered by the licensee. The inspector also discussed with licensee personnel whether any procedures or practices existed at Hope Creek to preclude an RPS actuation that occur- ed at another plant where maintenance on the scram discharge volume vent and drain line air header resulted in the scram discharge volume filling up and caused an RPS actuation on high instrument volume water level. This occurred while the unit was shutdown. The licensee indicated that no procedure was specifically prepared for that type of maintenance on the air header. Their tag out procedure would require them to assess the out of service equipment and potential affects and require three levels of review prior to actual work, the last of which is the senior licensed oper- ator. This was acceptable to the inspector. \\ - - - - - -
. . 10 6.0 Independent Measurements and Verifications The inspector performed multiple independent measurements and verifications during the witnessing of I&C surveillance functional tests, channel cali- brations, sensor calibrations and sensor response time testing. The in- spector's measurements and verifications agreed with those of the licensee. 7.0 QA/QC Interfaces The inspector observed acceptable QA involvement in the I&C surveillance program including the implementation of mandatory witnessing of the cali- bration of safety related equipment. QA involvement in the Operations Surveillance Program is discussed in Section 4.0. 8.0 Tours of the Facility In the course of witnessing I&C surveillance activities the inspector made tours of various areas of the facility to observe work in progress, house- keeping and cleanliness controls. No unacceptable conditions were identified. 9.0 Unresolved Items Unresolved items are matters about which more information is required in order to determine whether they are acceptable, an item of noncompliance or a deviation. Unresolved '.tems disclosed during the inspection are discussed in Section 4.0. 10.0 Exit Interview A the conclusion of the site inspection on May 30, 1986, an exit meeting was conducted with the licensee's senior site representative (Denoted in Section 1.0). The findings were identified and previous inspection items were discussed. At no time during the inspection was written material provided to the li- censee 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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, V j ATTACHMENT A
f Power Ascension Test Results Reviewed 1 i TE-SU.ZZ-011 Chemical and Radiochemical Pre-Fuel Load Test, Results Approved j May 22, 1986 . TE-SU.KE-032 Fuel Loading, Results Approved May 27, 1986 ' 2 TE-SU.KE-033 Full Core Verification, Results Approved May 17, 1986 i i TE-SU.BF-051 Control Rod Drive Functional Testing (Post Fuel Load) Results l Approved May 28, 1986 j TE-SU.BF-052 Scram Testing of Selected Control Rods, Results Approved
May 17, 1986 ^ TE-SU.BF-053 Control Rod Drive System Friction and Scram Testing at Zero ! Reactor Pressure, Results Approved May 28, 1986 l 1 TE-SU.SE-061 SRM Signal-To-Noise Radio and Minimum Count Rate Determination, ! Results Approved May 17, 1986 i TE-SU.ZZ-173 NSS Systems Piping Thermal Expansion Sensor Data, Results Approved May 22, 1986 , 1
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i . . ATTACHMENT B Surveillance Procedures KEY: PR = Procedure Reviewed for Technical Specification Compliance VC = Verified Test Complete Via Surveillance Log CT = Completed Test Results Reviewed SW = Surveillance Witnessed IC-CC.AB-001 Main Steam - Division 1 Main Steam Line Flow (VC,CT) IC-CC.BB-009 Nuclear Boiler - Division 1 Drywell Pressure (VC,CT) IC-CC.BB-027 Nuclear Boiler - Division 1 Low Reactor Vessel Level (3) Trip (VC,CT) IC-CC.BB-034 Reactor Protection - Division 4 High Drywell Pressure (VC,CT) IC-CC.BE-017 Core Spray Surveillance (SW) IC-CC.FC-001 RCIC - Division 2 Steam Line Flow (PR,CT,SW) IC-CC.SB-015 Reactor Protection - Division 2 Suppression Chamber Water Temperature (CT) IC-CC.SK-008 RWCU - Division 4 Steam Leak Detection Temperature Switch (PR,CT,SW) IC-CC.SM-003 NSSS System A, Logic C Low Condenser Vacuum (PR,CT,5W) IC-FT.AB-001 Main Steam - Division 1 Main Steam Line Flow (PR,VC-monthly) IC-FT.AB-033 Main Steam - Safety Relief Valve Position Indication (PR) IC-FT.BB-001 Nuclear Boiler - Division 1 Reactor Vessel Level Trips 1,2,8 (PR) IC-FT.BB-009 Nuclear Boiler - Division 1 High Drywell Pressure (PR) IC-FT.BB-014 Nuclear Boiler - Division 2, Logic B Core Spray Permissive and SRV Low-Low Set (PR,CT,5W) IC-FT.BB-015 Nuclear Boiler - Division 1, Channel A1/A, Low Reactor Vessel Level (3) Trip (PR) IC-FT.BB-019 Nuclear Boiler - Division 1, Channel A1, High Drywell Pressure (PR) IC-FT.BB-023 Nuclear Boiler - Divison 1, Channel A1, High Reactor Pressure (PR)
i . . Attachment B 2 IC-FT.SE-007 Nuclear Instrumentation System - Channel C IRM (PR,CT,5W) IC-FT.SE-015 Nuclear Instrumentation System Division 3 - Channel C APRM (PR,CT,SW) IC-FT.SM-011 NSSSS - Division 3, Reactor Vessel Level (Trip 1,2) (SW) IC-SC.AB-001 Main Steam - Division 1 Main Steam Line Flow (CT) IC-SC.BB-086 Nuclear Boiler - Division 1 Reactor Level ATWS (PR,CT,SW) IC-SC.BB-098 Nuclear Boiler - Division 4 Reactor Level RCIC (CT) IC-TR.BB-094 Nuclear Boiler - Division 2 Low Reactor Level Sensor (3) Trip (PR,CT,SW) OP-ST.BB-002 Suppression Pool Spray Valves (VC-Monthly) OP-ST.BC-003 Suppression Pool Cooling Valves (VC-Monthly) OP-ST.BH-001 Standby Liquid Control (VC-Monthly) OP-ST.GS-002 Drywell/ Suppression Pool Purge Valves (PR) OP-ST.GS-003 Reactor Building / Suppression Pool Vacuum Breakers (PR) OP-ST.GS-004 Suppression Pool /Drywell Vacuum Breakers (PR,VC-monthly) OP-ST.GS-005 Containment Recombiner Functional Test (PR) OP-ST.GV-001 FRVS Operability (PR,VC-Monthly) OP-ST.SF-002 RSCS Operability (PR) OP-ST.SF-003 RPS Manual Scram (PR, VC-monthly) OP-ST.SV-001 Remote Shutdown (VC-monthly) OP-ST.ZZ-003 Secondary Containment Integrity (VC-monthly) OP-TE.AB-102 MSIV Closure Time (PR,CT) OP-TE.AE-102 Feedwater System Valves Cold Shutdown Inservice Test (CT) OP-TE.BC-101 RHR System A Valves Inservice Test (CT) OP-TE.BC-105 RHR Valves Cold Shutdown Inservice Test (CT)
. . Attachment B 3 OP-TE.BE-101 Core Spray System A Valves Inservice Test (CT) OP-TE.BF-101 CRD System Valves Inservice Test (CT) OP-TE.EE-101 Torus Water Cleanup System Valves Inservice Test (CT) OP-TE.JE-008 Diesel Fuel Oil Transfer Pumps (CT) OP-TE.SE-101 TIP System Valves Inservice Test (CT) }}