IR 05000440/2002002

IR 05000440/2002-002, Fristenergy Nuclear Operating, Co, Perry Nuclear Power Plant, Unit 1, Perry, Oh, Inspection on 02/1/-03/31/2002, Related to Procedures & Records. No Violations Noted

ML021070238
Person / Time
Site:	Perry
Issue date:	04/11/2002
From:	Christine Lipa NRC/RGN-III/DRP/RPB4
To:	Campbell G FirstEnergy Nuclear Operating Co
References
IR-02-002
Download: ML021070238 (19)

Text

ril 11, 2002

SUBJECT:

PERRY NUCLEAR POWER PLANT NRC INSPECTION REPORT 50-440/02-02

Dear Mr. Campbell:

On March 31, 2002, the NRC completed an inspection at your Perry Nuclear Power Plant. The enclosed report documents the inspection findings which were discussed on April 3, 2002, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No findings of significance were identified.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Christine A. Lipa, Chief Branch 4 Division of Reactor Projects Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 50-440/02-02

See Attached Distribution DOCUMENT NAME: G:\PERR\perr 2002-02 drp.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII NAME LCollins CLipa DATE 4/ /02 4/ /02 OFFICIAL RECORD COPY

REGION III==

Docket No: 50-440 License No: NPF-58 Report No: 50-440/02-02 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant, Unit 1 Location: P.O. Box 97 A200 Perry, OH 44081 Dates: February 18, 2002, through March 31, 2002 Inspectors: Ray Powell, Senior Resident Inspector John Ellegood, Resident Inspector Approved by: Christine A. Lipa, Chief Branch 4 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000440-02-02; on 02/18-03/31/2002; First Energy Nuclear Operating Company; Perry Nuclear Power Plant, Resident Inspection Report.

This report covers a 6-week routine inspection. The inspection was conducted by resident inspectors. No findings of significance were identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at: http://www.nrc.gov/NRR/OVERSIGHT/index.html. Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violations.

A. Inspection Findings No findings of significance were identified.

B. Licensee Identified Violations No findings of significance were identified.

Report Details Summary of Plant Status: The plant began the inspection period with Unit 1 at 100 percent power. The unit remained at 100 percent power until February 21, 2002, when the plant reduced power to approximately 70 percent for special testing to identify the approximate location of a leaking fuel rod. After locating the leaking fuel rod, the plant adjusted control rod configuration to insert a control rod to suppress the flux in the leaking fuel rod. Power was returned to 100 percent power on February 28. Aside from periodic power reductions to support surveillances, the plant remained at 100 percent power for the remainder of the inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R04 Equipment Alignment (71111.04Q)

.1 Division 2 Emergency Diesel Generator (EDG)

a. Inspection Scope The inspectors conducted a partial alignment walkdown of the Division 2 EDG, a risk significant system, to evaluate its readiness while the Division 1 train was out of service for planned maintenance. The inspectors used licensee valve lineup instructions (VLIs)

during the walkdown and used selected portions of system electrical, fuel oil, lubricating oil, and starting air drawings to accomplish the inspection. The walkdown included selected switch and valve position checks, review of associated effective operating procedures, and verification of electrical power to critical components. Finally, the inspectors evaluated other elements, such as material condition, housekeeping, and component labeling. The documents used for the walkdown are listed in the attached List of Documents Reviewed.

b. Findings No findings of significance were identified.

.2 Reactor Core Isolation System (RCIC)

a. Inspection Scope The inspectors conducted a partial alignment walkdown of the RCIC system, a risk significant system, to evaluate its readiness while the High Pressure Core Spray (HPCS)

system was declared inoperable due to the problems associated with the condensate storage tank suction check valve. The inspectors used licensee VLIs and system drawings during the walkdown. The walkdown included selected switch and valve position checks and verification of electrical power to critical components. Finally, the inspectors evaluated other elements, such as material condition, housekeeping, and

component labeling. The documents used for the walkdown are listed in the attached List of Documents Reviewed.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05Q)

a. Inspection Scope The inspectors walked down the following areas to assess the overall readiness of fire protection equipment and barriers:

• Fire Areas ESW-1a and ESW-1b, Emergency Service Water (ESW) Pumphouse

• Fire Area 1CC-3a, Division 2 Switchgear Room Emphasis was placed on the control of transient combustibles and ignition sources, the material condition of fire protection equipment, and the material condition and operational status of fire barriers used to prevent fire damage or propagation.

The inspectors looked at fire hoses, sprinklers, and portable fire extinguishers to verify that they were installed at their designated locations, were in satisfactory physical condition, and were unobstructed. The inspectors also evaluated the physical location and condition of fire detection devices. Additionally, passive features such as fire doors, fire dampers, and mechanical and electrical penetration seals were inspected to verify that they were in good physical condition. The documents listed at the end of the report were used by the inspectors during the assessment of this area.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12Q)

a. Inspection Scope The inspectors reviewed the licensee's implementation of the maintenance rule requirements to verify that component and equipment failures were identified and scoped within the maintenance rule and that select structures, systems and components were properly categorized and classified as (a)(1) or (a)(2) in accordance with 10 CFR 50.65. The inspectors reviewed station logs, maintenance work orders, selected surveillance test procedures, and a sample of Condition Reports (CRs) to verify that the licensee was identifying issues related to the maintenance rule at an appropriate threshold and that corrective actions were appropriate. Additionally, the inspectors reviewed the licensees performance criteria to verify that the criteria adequately monitored equipment performance and to verify that licensee changes to performance criteria were reflected in the licensees probabilistic risk assessment.

During this inspection period, the inspectors reviewed:

• Emergency Closed Cooling Water (ECCW) System

• Fuel System

• HPCS The problem identification and resolution CRs reviewed are listed in the attached List of Documents Reviewed.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)

a. Inspection Scope The inspectors reviewed the licensees evaluation of plant risk, scheduling, configuration control, and performance of maintenance associated with planned and emergent work activities, to verify that scheduled and emergent work activities were adequately managed. In particular, the inspectors reviewed the licensees program for conducting maintenance risk assessments to verify that the licensees planning, risk management tools, and the assessment and management of on-line risk were adequate. The inspectors also reviewed licensee actions to address increased on-line risk when equipment was out-of-service for maintenance, such as establishing compensatory actions, minimizing the duration of the activity, obtaining appropriate management approval, and informing appropriate plant staff, to verify that the actions were accomplished when on-line risk was increased due to maintenance on risk-significant structures, systems, and components. The following specific activities were reviewed:

• The maintenance risk assessment for work planned for the week beginning February 25, 2002. This included work involving adjustment of the Division 1 EDG govenor and subsequent post maintenance testing.

• The maintenance risk assessment for work planned for the week beginning March 11, 2002. The work week included planned HPCS unavailability for capacitor replacement and post-maintenance testing. The inspectors also reviewed the additional activities added to the week due to emergent problems associated with the HPCS condensate storage tank suction check valve.

• The maintenance risk assessment for work planned for the week beginning March 25, 2002. The work week included planned RCIC unavailability for train outage activities and post-maintenance testing.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope The inspectors selected CRs related to potential operability issues for risk significant components and systems. These CRs were evaluated to determine whether the operability of the components and systems was justified. The inspectors compared the operability and design criteria in the appropriate sections of the Technical Specifications (TSs) and Updated Safety Analysis Report (USAR) to the licensees evaluations to verify that the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors verified that the measures were in place, would work as intended, and were properly controlled. Additionally, the inspectors verified, where appropriate, compliance with bounding limitations associated with the evaluations. The inspectors reviewed:

• the licensees evaluation of the potential loss of ECCW inventory during isolation of the Nuclear Closed Cooling System due to time-delay relay tolerances on ECCW operability

• the licensees evaluation of the impact of the failure of the ESW pump A discharge vacuum breaker on ESW operability

• the licensees evaluation of the failure of the A train of heating, ventilation, and cooling for the divisional batteries and switchgear rooms on battery and switchgear operability b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope The inspectors evaluated the following post-maintenance testing activities for risk significant systems to assess the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written; and equipment was returned to its operational status following testing. The inspectors evaluated the activities against TS, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications. In addition, the inspectors reviewed CRs associated with post-maintenance testing to determine if the licensee was identifying problems and entering them in the corrective action program. The specific procedures and CRs reviewed are listed in the attached List of Documents Reviewed. The specific post-maintenance activities evaluated included:

• Division 1 Diesel Generator Load Reject Test following planned maintenance on the diesel govenor

• Reactor Pressure Vessel Low Level 3 and High Level 8 Reactor Protection System/

Residual Heat Removal Shutdown Isolation Logic Testing following agastat relay replacement

• HPCS System Flow Rate Low Channel Calibration and Functional Check following capacitor replacement b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors observed surveillance testing or reviewed test data for risk-significant systems or components to assess compliance with TS, 10 CFR Part 50 Appendix B, and licensee procedure requirements. The testing was also evaluated for consistency with the USAR. The inspectors verified that the testing demonstrated that the systems were ready to perform their intended safety functions. The inspectors reviewed whether test control was properly coordinated with the control room and performed in the sequence specified in the surveillance instruction, and if test equipment was properly calibrated and installed to support the surveillance tests. The procedures reviewed are listed in the attached List of Documents Reviewed. The specific surveillance activities assessed included:

• Control Rod Exercises

• ESW Pump A and Valve Operability Test

• RCIC System Flow Monitoring Test b. Findings No findings of significance were identified.

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope The inspectors observed the control room simulator, the technical support center, and the emergency offsite facility during an emergency preparedness drill conducted on March 20, 2002. The inspection focused on the ability of the licensee to appropriately classify emergency conditions, complete timely notifications, and implement appropriate protective action recommendations in accordance with approved procedures.

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES (OA)

4OA1 Performance Indicator (PI) Verification (71151)

a. Inspection Scope The inspectors reviewed reported fourth quarter 2001 data for the High Pressure Injection System Unavailability PI using the definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 2. The inspectors reviewed station logs, monthly safety system unavailability hour logs, and selected surveillance procedures to verify the accuracy of the licensees data submission.

b. Findings The inspectors determined that the licensees use of managed restoration instructions during safety system surveillance testing was not consistent with the guidance provided in NEI 99-02. The NRC endorsed guidance provided criteria for excluding planned unavailable hours during testing, including:

• the test configuration is automatically overridden by a valid start signal or the function can be promptly restored either by an operator in the control room or by a dedicated operator stationed locally for that purpose

• restoration actions must be contained in a written procedure, must be uncomplicated (a single action or a few simple actions), and must not require diagnosis or repair

• credit for a dedicated local operator can only be taken if they are positioned at the proper location throughout the duration of the test for the purpose of restoration As stated in NEI 99-02, the purpose of the guidance was to allow licensees to take credit for restoration actions that are virtually certain to be successful during accident conditions. The guidance did, however, caution that under stressful chaotic conditions simple multiple actions may not be accomplished with virtual certainty.

The inspectors reviewed the restoration instructions provided in licensee surveillance procedures SVI-E22-T1200, HPCS Pump Discharge Pressure - High (Bypass) Channel Functional For 1E22-N651, Rev. 3 and SVI-E22-T1202, HPCS System Flow Rate -

Low (Bypass) Channel Functional For 1E22-N656, Rev. 3 against the NEI 99-02 guidance. Both procedures required the installation of an instrumentation and control (I&C) calibration unit and the racking out of the HPCS pump breaker. Accordingly, restoration actions were required by an I&C technician, a plant operator at the HPCS pump breaker, and a control room operator. Actions by the control room operator and the plant operator at the pump breaker were procedurally required to be coordinated to prevent an inadvertant pump start during the transient response due to the restoration activities.

The inspectors identified that the restoration instructions contained several deviations from the NEI 99-02 guidance, specifically:

• NEI 99-02 required that the safety function be promptly restored. The inspectors noted that, as stated in the restoration instructions, the licensee considers a safety system to be available if the safety function can be restored within 10 minutes of the control room order to do so. The inspectors acknowledged that the guidance does not quantify prompt, but concluded that 10 minutes was in excess of reasonable bounds.

• NEI 99-02 required that dedicated operators be stationed locally throughout the duration of the test. The licensees procedures required the operators to be in the vicinity.

• NEI 99-02 required restoration actions to be uncomplicated (a single action or a few simple actions). The inspectors observed that the licensees restoration instructions were four pages in length, contained eight notes and two caution statements, and required actions at three separate locations including coordinated actions by two of the stations. The inspectors concluded the restoration actions did not meet the intent of the NEI 99-02 uncomplicated requirement.

• NEI 99-02 required restoration actions to be virtually certain of success. The inspectors determined that the licensees restoration actions, performed during the initial stages transient response, did not have a success probability nearly equal to one and therefore did not meet the virtually certain criteria.

The inspectors concluded that time spent in the testing configuration required by SVI-E22-T1200 and SVI-E22-T1202 should have been reported to the NRC as planned safety system unavailability hours. The inspectors reviewed the issue with licensee management and concluded that the restoration approach used in SVI-E22-T1200 and SVI-E22-T1202 was not unique to those procedures. Since the number of procedures, and systems, affected by the misapplication of NEI 99-02 guidance has yet to be determined, the inspectors could not yet determine if a performance indicator threshold would have been crossed. As a result, the inspectors considered this issue an Unresolved Item (URI) (URI 50-440/02-02-01). The licensee has entered the issue in their corrective action program as CR 02-0946.

4OA6 Meetings Exit Meeting The inspectors presented the inspection results to Mr. Guy Campbell, Site Vice President and other members of licensee management at the conclusion of the inspection on April 3, 2002. The licensee acknowledged the findings presented. No proprietary information was identified.

KEY POINTS OF CONTACT Licensee G. Campbell, Vice President-Nuclear B. Boles, Operations Manager G. Dunn, Manager, Regulatory Affairs D. Gudger, Supervisor, Compliance T. Lentz, Manager, Design Engineering K. Ostrowski, Director, Nuclear Services Department D. Phillips, Manager, Plant Engineering T. Rausch, Director, Nuclear Maintenance Department W. Kanda, General Manager, Nuclear Power Plant Department R. Strohl, Superintendent, Plant Operations LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-440/02-02-01 URI Safety System Unavailability Hours During Surveillance Testing Closed None

LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Condition Report ECCW Emergency Closed Cooling Water EDG Emergency Diesel Generator ESW Emergency Service Water FENOC FirstEnergy Nuclear Operating Company HPCS High Pressure Core Spray I&C Instrumentation and Control NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission PI Performance Indicator RCIC Reactor Core Isolation Cooling SDP Significance Determination Process SVI Surveillance Instruction TS Technical Specifications URI Unresolved Item USAR Updated Safety Analysis Report VLI Valve Lineup Instruction

LIST OF DOCUMENTS REVIEWED 1R04 Equipment Alignment Drawing 302-0352 Standby Diesel Generator Fuel Oil System March 15, 2001 VLI-R45 Division 1 & 2 Diesel Generator Fuel Oil System May 23, 1995 (Unit 1), Rev. 4 Drawing 302-0351 Standby Diesel Generator Starting Air, Rev. W July 27, 2000 VLI-R44 Division 1 & 2 Diesel Generator Starting Air June 8, 1988 System (Unit 1), Rev. 4 Drawing 302-0353 Standby Diesel Generator Lube Oil Sys, Rev. P July 27, 2000 VLI-R47 Division 1 & 2 Diesel Generator Lube Oil System March 3, 1989 (Unit 1), Rev. 4 Drawing 302-0354 Standby Diesel Generator Jacket Water System, July 27, 2000 Rev. P VLI-R46 Division 1 & 2 Diesel Generator Jacket Water March 2, 1989 System (Unit 1), Rev. 3 VLI-E51 Reactor Core Isolation Cooling System (Unit 1), September 27, Rev. 3 1988 Drawing 302-0631 Reactor Core Isolation Cooling System, Rev. Z March 22, 2001 1R05 Fire Protection Drawing E-023- Fire Protection Evaluation - Units 1 and 2 March 1991 034 Emergency Service Water Pumphouse - Plans and Sections Drawing D-926- Emergency Service Water Pump House Floor, March 27, 1978 005 Equipment and Roof Drains Drawing E-023- Fire Protection Evaluation - Units 1 and 2 Control September 2001 011 Complex and Diesel Generator Building Plan - El.

620-6" USAR Section Fire Area 1CC-3a 9A.4.4.3.1.1 USAR Section Fire Area ESW-1a 9A.4.6.1 USAR Section Fire Zone ESW-1b 9A.4.6.2 CR 02-0872 Concern Regarding Functionality of ESW Pump March 21, 2001 House Floor Drains

1R12 Maintenance Rule Implementation CR 01-0261 Loose Middle Bolt on Snubber Clamp January 24, 2001 CR 01-0430 ECC A Controller Found in Manual February 6, 2001 CR 01-0817 PTI-P42-P0010 Loop A System Leakage February 24, 2001 CR 01-1715 ECC-B Surge Tank Valve 1P42-F0668 Out of April 2, 2001 Position CR 01-2684 Relief Valve Removed From 0P42F543C Failed July 10, 2001 As-Found Testing CR 01-3359 Offgas Noble Gas Sample Results Have September 18, Increased Since the End of August 2001 CR 01-4171 Latent Issues Review - P42 - ECCW to NCCW December 4, 2001 Leakage CR 01-4257 Latent Issue Review Recommendations December 13, 2001 CR 02-0421 Xe 133 Increased on Off Gas Pretreatment February 9, 2002 Sample CR 02-0500 Xe-133 Value Following Down Power Was February 17, 2001 Greater Than Established Criteria CR 02-0570 Investigations for Having Control Rod 18-15 For February 25, 2002 Remainder of Cycle System Health Emergency Closed Cooling Water System Status 1st Quarter 2001 Report Report System Health Emergency Closed Cooling Water System 2nd Quarter 2001 Report Status Report System Health Emergency Closed Cooling Water System 3rd Quarter 2001 Report Status Report System Health Emergency Closed Cooling Water System Status 4th Quarter 2001 Report Report System Health Fuel System Status Report 1st Quarter 2001 Report System Health Fuel System Status Report 2nd Quarter 2001 Report System Health Fuel System Status Report 3rd Quarter 2001 Report System Health Fuel System Status Report 4th Quarter 2001 Report

System Health High Pressure Core Spray System Status Report 1st Quarter 2001 Report System Health High Pressure Core Spray System Status Report 2nd Quarter 2001 Report System Health High Pressure Core Spray System Status Report 3rd Quarter 2001 Report System Health High Pressure Core Spray System Status Report 4th Quarter 2001 Report PAP-1125 Monitoring the Effectiveness of the Maintenance April 4, 2001 Program Plan, Rev. 6 Logs Plant Narrative Logs 01/01/01 - 3/31/02 NUMARC 93-01, Nuclear Energy Institute Industry Guideline for Revision 2 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 1R13 Maintenance Risk Assessments and Emergent Work Evaluation Week 2, Period 5 Forecast Risk Profile February 25, 2002 Week 4, Period 5 Forecast Risk Profile March 11, 2002 Week 6, Period 5 Forecast Risk Profile March 25, 2002 CR 01-4213 DG Load Reject Assessment for Electrical December 10, 2001 System Perturbations Calculation PSA- Diesel Load Reject Test - Relative Risk December 18, 2001 010 Evaluation SVI-R43-T1327 Division 1 Standby Diesel Generator Functional February 13, 2001 Test, Rev. 5 PAP 1924 On-Line Safety Assessment and Configuration November 30, 2000 Risk Management, Rev. 2 1R15 Operability Evaluations CR 01-4171 Latent Issues Review - P42 - ECCW to NCCW December 4, 2001 Leakage CR 02-0568 ESW A Pump Vacuum Breaker 1P45F0502A February 25, 2002 Not Seating With Pump Running CR 02-0840 Degraded Hydomotor 0P47F0045A Has Failed March 20, 2002 TS 3.7.1 Emergency Service Water Systems, Divisions 1 and 2

TS 3.7.10 Emergency Closed Cooling Water System 1R19 Post-Maintenance Testing SVI-B21-T0034-A RPV Low Level 3 and High Level 8 PRS/RHR December 5, 1990 Shutdown Isolation, Rev. 4 Problem Solving Agastat Relay Testing Methodology in Question March 20, 2002 Plan Summary CR 02-0686 Senior Resident Query March 8, 2002 CR 02-0828 Test Methodology For Replacement of Safety March 19, 2002 Related Relays SVI-R43-T1317 Diesel Generator Start and Load Division 1, December 6, 2000 Rev. 9 SVI-R43-T1327 Division 1 Standby Diesel Generator Functional February 13, 2001 Test, Rev. 5 SVI-E22-T1202 HPCS System Flow Rate - Low (Bypass) December 4, 1989 Channel Functional For 1E22-N656, Rev. 3 WO 00-002900- Capacitor C25 Suspect to Failure 000 WO 01-017499 Replace Normally Energized Agastat Relays 1C71A-K006A, 1C71A-K046A, and 1C71A-K044A During Performance of Surveillance Instruction SVI-B21-T0034-A WO 01-013637- Readjust (Fine Tune) EGA Govenor Dynamics 000 For Div 1 DG For Optimum Performance 1R22 Surveillance Testing SVI-C11-T1003-A Control Rod Exercise (Part 1), Rev. 3 March 27, 2001 SVI-P45-T2001 ESW Pump A and Valve Operability Test, Rev. 4 SVI-E51-T0339 RCIC System Flow (Remote Shutdown November 6, 1992 Monitoring) Channel Calibration for 1E51-N003, Rev. 2 TS 3.1.3 Control Rod Operability TS 3.7.1 Emergency Service Water Systems, Divisions 1 and 2

1EP6 Drill Evaluation Perry Nuclear Power Plant Emergency March 20, 2002 Preparedness Drill Scenario 4AO1 Performance Indicator Verification NEI 99-02 Regulatory Assessment Performance Indicator November 2001 Guideline, Rev. 2 Logs Plant Narrative Logs 01/01/01 - 12/31/01 Logs Monthly Safety System Unavailability Logs January-June, 2001 CR 02-0946 NRC Concern On Perrys Use of Managed March 28, 2002 Restoration As It Relates To The PIs SVI-E22-T1200 HPCS Pump Discharge Pressure - High December 4, 1989 (Bypass) Channel Functional For 1E22-N651, Rev. 3 SVI-E22-T1202 HPCS System Flow Rate - Low (Bypass) December 4, 1989 Channel Functional For 1E22-N656, Rev. 3 SVI-E22-T2001 HPCS Pump and Valve Operability Test, Rev. 10 February 16, 2001 16