ML20202D930

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Insp Rept 50-354/86-27 on 860519-30.Violation Noted: Temporary Procedures Implemented Prior to Required Review & Approval.Power Ascension Test Results & List of Surveillance Procedures Encl
ML20202D930
Person / Time
Site: Hope Creek PSEG icon.png
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)
v • d • e


See also: IR 05000354/1986027

Text

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                               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
                   #?             <4s                                   //n/pB4
                   t. Winii, Rp64 tor Engineer                             date
    Approved by:
                MP. Eselgrotbf/Ahief, Test Programs Section,
                                                                       [[f/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
                                 '
 0     ADOCK 05000354
                       PDR

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                                           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

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                               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

2 

                                                                      Programs for Water-Cooled Nuclear Power Plants",
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
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                                                 determine the status of testing, test results evaluation and test

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                                                 procedure reviews. The inspector determined that, with the exception

, of the initial criticality testing sequence, all open vessel testing i 

                                                 had been completed and test results evaluation was proceeding smoothly.

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        .,__-...--_-_.m         ._-_, ,..,,__, ___ _,, .._. ,. _,_,                    _....__.__m__-_-,.,.--,,_..,_r..                       _,_m.   , - -.   , ,-.,.--..-. ._-__-,.,,_-.7__v__._.-.

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       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.

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                                                          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.
  - _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _                           ____ -    _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _   _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

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                     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

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                    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-

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                    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-

l ped the practice of implementing temporary procedures via the methodology 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.

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    . _ _ _ _ _ _ ,    ... _ - _ _ _.___., __      . _ _ _ _ _ _ . _ _ _ _ _ . . _ . . _ , _ , . _ _ _ , _ , _ _ _ _ _ _                        _ . , _ _ - _ _ . . _ . . _ , _ _ _ ~ ,

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   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).

              __ _                    - - _ - _ - _ _ ______   .   - _ _ _ . _ _ _  _             _ _       . _ __ _ _____ _ ___
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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.

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            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-

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            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,

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            this will remain an unresolved item (354/86-27-03).
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
            Technical Specification changes for RHR containment isolation valves.

l 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

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        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.
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  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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 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 

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                             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
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                                    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)

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 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)

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