B12232, Forwards Addl Info Re Inservice Testing of Emergency Diesel Generator Auxiliary Sys Revised Relief Request & Pump/Valve Tables,In Support of Review of Inservice Testing Program. Response to NRC 860723 Questions Also Encl

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Forwards Addl Info Re Inservice Testing of Emergency Diesel Generator Auxiliary Sys Revised Relief Request & Pump/Valve Tables,In Support of Review of Inservice Testing Program. Response to NRC 860723 Questions Also Encl
ML20214M303
Person / Time
Site: Millstone Dominion icon.png
Issue date: 08/29/1986
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Thadani A
Office of Nuclear Reactor Regulation
References
A05353, A5353, B12232, TAC-60876, NUDOCS 8609110049
Download: ML20214M303 (32)


Text

O O General Offices

l August 29,1986 l

Docket No. 50-336 A05353 B12232 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director .

PWR Project Directorate (i8 Division of PWR Licensing - B U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel Generator Auxiliary Systems In a letter dated December 31,1985(l), Northeast Nuclear Energy Company (NNECO) informed the NRC Staff that the emergency diesel generator (EDG) auxiliary systems at Millstone Unit No. 2 would be included in the Inservice Testing Program (IST). In a letter dated February 28,1986, NNECO provided the NRC Staff with additional information regarding IST of EDG auxiliary systems, including valve and pump listings and requests for relief from certain ASME code requirements.

The NRC Staff conducted ageliminary review of the above stated program and in a letter dated May 6,1986ui, provided interim approval of the relief requested in Reference (2). This interim approval was granted for six (6) months from the date of Reference (3) or until the NRC Staff completed its detailed review of this program, whichever comes first. To support this detailed review, NNECO is hereby transmitting additional (attached) information. Attachment (1) consists of revisions to the relief request and the pump and valve tables submitted in Reference (2). Attachment (2) provides a detailed response to questions that were informally communicated to NNECO by the NRC Staff.

(1) 3. F. Opeka letter to A. C. Thadani, dated December 31,1985.

(2) 3. F. Opeka letter to A. C. Thadani, dated February 23,1986.

(3) A. C. Thadani letter to J. F. Opeka dated May 6,1986.

O 8609110049 860829 PDR ADOCK 05000336 g\%

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We trust that this information is responsive to your request.

Very truly yours, 4

NORTHEAST NUCLEAR ENERGY COMPANY

. F. C A

3. F. OpeV U Senior Vice President

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.e e Docket No. 50-336 Attachment No.1 Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel GeneratorAuxiliary Systems ;.

Revised Relief Request and Pump / Valve Tables August,1986

5 i Relief Request No. P-1 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED PUMPS: Engine-Driven Fuel Oil Pumps f

T5ST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any devia-tions determined shall be compared with the limits given in Table IWP-3100-2andthespecifiedcorrectiveactiontaken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

, (5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with

, the limits given in Table IWP-3100-2 and take specified corrective l action.

BASIS FOR RELIEF: The basis for relief is (paragraph numbers match those above):

(1) During diesel generator operation, system resistance cannot be varied. There is no provision for throttling or fuel control beyond that inherently provided by operation of the loaded diesel generator. Attempts to vary system resistance would degrade the performance of the diesel generator.

(2) There are no instruments to measure fuel flow or fuel pump differ-ential pressure. The supply to the pump is an elevated storage tank. Only fuel pump discharge pressure is available at the engine. Discharge pressure of this positive displacement pump is affected by the cleanliness of the downstream fuel oil filter.

, (3) As noted above, there is no inlet pressure monitoring ability. The l diesel fuel oil supply tank normally operates within a six-inch level range. Thus, static suction pressure is essentially constant.

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s i Inadequate inlet pressure would be identified by low pump discharge pressure or inability.of the diesel generator to achieve Technical t

Specification load carrying requirements.

l (4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to i

allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential

alternative, monitoring of the housing temperature does not provide j meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

!' (6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-l related pump testing. The pump discharge pressure is low (< 30 1 psig), thus the acceptable range (per Table IWP-3100-2) is less

than 4 psig. Normal system variations can exceed this range

} without impacting diesel generator operability.

ALTERNATE TESTING
Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator j will be operated at a fixed, procedurally specified Icad. All  !

readingg will be taken after the generator has been essentially stable at this load for at least 15 minutes.

l (2) Measure pump discharge pressure when the engine is operating, as

, described in (1) above.

i (3) The fuel oil supply tank will be maintained in the normal level l range during testing.

(4) Proper operation of the engine lubrication system will be verified ,

I during the test.

i j (5) No alternative testing is proposed.

! (6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which l allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

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Relief Request No. P-2 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2

, SYSTEM: Lube Oil

AFFECTED PUMPS
Engine-Driven Lube Oil Pumps TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured i flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any devia-  ;

tions determined shall be compared with the limits given in Table IWP-

3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

i (3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

! (5) The requirement to measure and record bearing temperature.

l-(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective i action.

r BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match i

those above) l (1) During diesel generator operation, system resistance cannot be

varied. There is no provision for lube oil flow control beyond that inherently provided by operation of the loaded diesel genera-I tor. Attempts to vary system resistance could cause failure of the

{ diesel generator.

j (2) There are no instruments to measure lube oil flow or pump differen-

tial pressure. The supply to the pump is the engine sump. Sump i

level is closely controlled to manufacturer's requirements. Sump level is monitored as part of routine diesel generator operation.

The principal vital measurement is lube oil pressure within the engine.

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) 1 (3) As noted above, there is no inlet pressure monitoring ability.

Sump level is closely controlled. Routine monitoring of sump level or Icw pump discharge pressure would identify reduced inlet head.

(4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low (4 30 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 4 psig. Normal system variations can exceed this range without impacting diesel generator operability, f ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings-will be taken after the generator has been essentially j stable at this load for at least 15 minutes.

1 (2) Measure engine oil pressure when the engine is operating as described in (1) above.

(3) The lube oil sump will be maintained in the normal level range during testing.

(4) Proper operation of the engine lubrication system will be verified during the test.

(5) No alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

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% t Relief Request No. P-3 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Jacket Water Cooling AFFECTED PUMPS: Engine-Driven Jacket Water Cooling Pumps 1 TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

l (1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

(5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective action.

BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match those above)

(1) During diesel generator operation, system resistance cannot be varied. There is no provision for throttling or cooling water flow control beyond that inherently provided by operation of the loaded diesel generator. Attempts to vary system resistance could cause j failure of the diesel generator.

I (2) There are no instruments to measure cooling water flow or pump differential pressure. The supply to the pump is an elevated, atmospheric pressure expansion tank. Only pump discharge precsure is available at the engine.

l (3) As noted above, there is no inlet pressure monitoring ability.

( Expansion tank level is controlled. Routine monitoring of expan-sion tank level, increase in engine temperatures, or low pump j discharge pressure would identify reduced inlet head.

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(4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress, bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and ccoling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low ( < 34 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 4 psig. Normal system variances can exceed this range without impacting diesel generator operability.

ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings will be taken after the generator has been essentially stable at this load for at least 15 minutes.

(2) Measure pump discharge pressure when the engine is operating as described in (1) above.

(3) The expansion tank level will be maintained in the normal level range during testing.

(4) Proper operation of the engine lubrication system will be verified during the test.

(5) No alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

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Relief Request No. P-4 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Cooling AFFECTED PUMPS: Engine-Driven Air Cooling Pumps T5ST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure' or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

(5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective l action.

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! BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match those above)

~

(1) During diesel generator operation, system resistance cannot be i varied. There is no provir'03 'or throttling or cooling water flow control beyond that inhecta:37 rovided by operation of the loaded diesel generator. Att n; a t< ary system resistance could degrade performance of the dies 1 gea,.stor.

(2) There are no instruments to measure cooling water flow or pump differential pressure. The supply to the pump is an elevated, atmospheric pressure expansion tank. Only pump discharge pressure is available at the engine.

l l (3) As noted above, there is no inlet pressure monitoring ability.

Expansion tank level is controlled. Routine monitoring of expan-sion tank level, increase in engine temperatures, or low pump discharge pressure would identify reduced inlet head. ,

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}i (4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress, bearing temperature monitoring must be continu-

, ous, rather than periodic. Failing bearings often exhibit fluctua-tions between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded dierel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low (< 11 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 1.5 psig. Normal system variations can exceed this range without impacting diesel generator operability.

ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings will be taken after the generator has been essentially stable at this load for at least 15 minutes.

(2) Measure pump discharge pressure when the engine is operating as described in (1) above.

l (3) The expansion tank level will be maintained in the normal level j range during testing.

l (4) Proper operation of the engine lubrication system will be verified l

during the test.

(5) No. alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

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Relief Request No. P-5 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil (Clean Oil Return to Diesel Supply Tanks)

AFFECTED PUMPS: Clean Oil Pumps TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED
Relief is requested from measuring and recording all required parameters.

BASIS FOR RELIEF: There is no instrumentation which can be used to measure inlet pressure, differential pressure, or flow. There are no accessible bearings. The unit is mounted on the diesel engine structure precluding meaningful vibration measurements. There is no separate lubrication supply to the units.

This portion of the fuel oil systems coosist of two cross-connected 9.5 gallon tanks, each equipped with a clean oil return pump. This system operates intermittently to return clean fuel leakage to the fuel supply tank. Only one pump is required for operation. The redundant pump provides reasonable assurance that diesel generator operability will be maintained. Routine operator observation of the system during diesel generator operation would identify any system failure.

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ALTERNATE TESTING
No specific testing will be conducted. Routine observation of the system during diesel generator operation will provide needed assurance of operability.

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Relief Request No. P-6 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Intake AFFECTED PUMPS: Diesel Generator Turbo-chargers TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from measuring and recording all required parameters.

BASIS FOR RELIEF: This self-contained unit has no instrumentation. It is cooled and lubricated by the engine auxiliaries. It has no controls as the correlated action of the turbine and blower is entirely automatic.

The sole measure of turbo-charger performance is the ability of the diesel generator to develop rated output.

ALTERNATE TESTING: None under this program. The diesel generator load handling ability is tested in accordance with Technical Specification requirements.

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Relief Request No. P-7 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: All Diesel Generator Engine-Driven Pumps AFFECTED PUMPS: All Pumps TEST REQUIREMENT: Article IWP-4510, at least one displacement vibration amplitude (peak-to-peak composite) shall be read during each inservice test.

RELIEF REQUESTED: Relief is requested from taking vibration measure-ments directly on these pumps.

BASIS FOR RELIEF: Meaningful vibration measurements cannot be taken on engine-mounted pumps. The overall engine vibration completely overwhelms any vibration generated by the pump. Thus, vibration measurements on these units would not identify potential or actual degradation of the pump. Vibration monitoring of the engine casing can provide information which would allow assessment of the overall engine performance and operability.

ALTERNATE TESTING: No alternative testing of the pumps is proposed.

Vibration measurements will be taken on the diesel engine during inser-vice tests.

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Relief Request No.'/-1 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil (Clean Oil Tank Discharge to Diesel Oil Supply Tank)

AFFECTED VALVES: 2-FO-67A, 67B, 67C, 67D, 85A, 85B, 85C, and 85D CATEGORY: C CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3521 - Check valves shall be exercised at least once every three months.

RELIEF REQUESTED: Relief is requested from all operational testing.

BASIS FOR RELIEF: There is no instrumentation on the piping or associ-ated pumps and tanks. Thus, there is no way to verify, with an opera-tional test, that the valves operate on demand. This portion of the fuel oil system of each diesel generator consists of two tanks, two pumps, and four check valves (Drawing 25203-26010). These two tanks (capacity 9.5 gallons each) are cross-connected through normally open valves 2-FO-69 and 2-FO-70. Failure of any one of these check valves to open would not affect diesel operability since the redundant pump and piping flow path would provide adequate return capacity. Failure of any one check valve to close would not affect diesel generator operability since the redundant check valve in each line provides backup capability.

Further, even if both check valves in one line simultaneously failed, the only effect would be to allow the return piping to the diesel storage tank to drain to the clean oil tanks when the affected pump was secured. The quantity of oil held by the piping is less than 10 percent of the tank c'apacity. The positive displacement transfer pump in the piping with the failed check valves would sufficiently restrict flow that accumulated diesel fuel in the clean oil tanks could still be pumped to the diesel supply tank.

ALTERNATE TESTING: One valve of each type and size will be disassembled and inspected each refueling outage.

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O e Relief Request No. V-2 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED VALVES: 2-FO-79, 2-FO-80 CATEGORY: B CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3413(b) - The stroke time of all power operated valves shall be measured to the nearest second,for stroke times ten seconds or less,or 10 percent of the specified limiting stroke time for full stroke times longer than ten seconds whenever such a valve is full stroke tested.

RELIEF REQUESTED: Relief is requested from measuring stroke time of these valves.

BASIS FOR RELIEF: These thermally fused quick acting valves have stroke times of less than one second. Measurement of these times provides no realistic information for evaluation of valve condition.

ALTERNATE TESTING: The valves will be stroke tested as required by Article IWV-3412. The valves will be monitored during stroke testing to assure closure occurs in less than two seconds. Valves which do not close within two seconds will be considered inoperable.

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Relief Request No. V-3 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Starting System AFFECTED VALVES: 2-DG-91A, 91B, 92A, 92B, 95A, 95B, 96A, 96B, 27A, and 27B CATEGORY: B CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3413(b) - The stroke time of all power operated valves shall be measured to the nearest second for stroke times ten seconds or less,or 10 percent of the specified limiting stroke time for full stroke times longer than ten seconds, whenever such a valve is full stroke tested.

RELIEF REQUESTED: Relief is requested from measuring stroke time of these valves.

BASIS FOR RELIEF: These valves have no visible operating parts. There are no system instruments which monitor their operation. Thus, there is no way to measure the stroke time of the valves. Further, the actual stroke time of these valves is very short (less than one second) and measurement of stroke time would provide no realistic information for evaluation of valve condition.

The function of these valves is to admit starting air to the diesel engine and to stop air application when the engine is operating. The Unit 2 Technical Specification requires that the diesel generator

" starts from ambient condition and accelerates to Jt90 percent of rated speed and to 2 97 percent of rated voltage in di20 seconds." If these valves do not travel fu.1.1 stroke,,or operate slowly, the diesel will not meet the overall operability test. Thus, reliance on this overall operability test is appropriate to demonstrate prompt valve operation.

ALTERNATE TESTING: Once per quarter, each valve will be tested to assure proper operation by verifying the diesel generator meets the overall operability (starting) requirements of the Unit 2 Technical Specification when started using only one tank and one air start valve train.

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  • v mgr ;7 IWP PIMP TABI.E N Speed inlet Differential .

Bearing Pump Control Pressure Pressure . Flow Vibration Lubrication Temperature Frequency Puel Oil System Fuel Oil Pump A variable

  • RRfP-1 RRfP-1 RRfP-1 RRfP-7 RRIP-1 RRfP-1 Quarterly ,

Tuel 011 Pump B Variable

  • RRfP-1 RRfP RRfP-1 RRfP-7 RRfP-1 RRfP-1 Quarterly 1.ube Oil System P48A Lube Oil Pump Variable
  • RRfP-2 RRfP-2 BRfP-2 RRfP-7 RRfP-2 RRfP-2 Quarterly P48B Lube 011 Pump Variable
  • RRfP-2 RRfP-2 RRfP-2 RRfP-7 RRfP-2 RRfP-2 . Quarterly Jacket Cooling Water System P49A Conling Pump Variable
  • RRfP-3 RRfP-3 RRIP-3 RRfP-7 RRfP-3 RRIP-3 Quatrerly P49B Cooling Pump variable
  • RRfP-3 RRfP-3 RRfP-3 RRIP-7 RRfP-3 RRfP Quarterly Air Cooling System P127A Air Cooler Coolant Pump Variable
  • RRIP-4 RRfP-4 RRfP-4 RRfP-7 RRfP-4 RRfP-4' Quarterly P127B Air Cooler Coolant Pump Variable
  • RRfP-4 RRIP-4 RRfP-4 RRfP-7 RRfP-4 RRfP-4 Quarterly.

Clean Oil System P128A - Clean 011 Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRIP-5 Quarterly P128B - Clean Oil Pump Fixed RRfP-5 RRfP-5 kRfP-5 RRfP-5 RRfP-5 RRfP-5 Quarterly P128C - Clean 011 Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRIP-5 Quarterly.

P128D - Clean Oil Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 Quarterly Turbo-charmers Diesel Generator A Turbo-chargers Variable ** RRf6 RRf6 RRf6 RRf6 RRf6 RRf6 -

Diesel Generator B Turbo-chargers variable ** RRf6 RRf6 RRf6 RRf6 RRf6 RRf6 -

  • Varies with engine speed.
    • Varies with engine power.

RRix = Rellef Requested. (x = Relief Request No.)

Sheet I af b TABLE IW DIESEL AIR STARTING SYSTFM (DASS)

Class / Valve Normal Test Belief Test Y21ve Number Category Function Size Type Actuation Position Required Requested Alternate 2-DC-27A */B Air Bleed Cutoff th" SOV SO 0/ Fall Closed Q/Ft V-3 Note 3 2-DC-275 */B Air Bleed Cutoff th" SOY SO 0/ Fail Closed Q/Ft V-3 Note 3 2-DG-29A */C Check 2" CK - C Q - -

2-DC-298 */C Check 2" CK -

C Q - -

2-DC-29C */C Check 2" CK -

C Q - -

2-DC-29D */C Check 2" CK -

C 0 - -

2-DC-30A */B Startirg Air Isolation th" Clobe M O None - -

Passive 2-DC-308 */B Starting Air Isolation th" Clobe M 0 None - -

Passive 2-DC- YC */5 Starting Air Isolation 1" Clobe M 0 None - -

Passive 2-DC-30D */B Starting Air Isolation I" Clobe M 0 None - -

Passive 2-DC-31A */B Starting Air Tank Isolation 2" Clobe P O None - -

Parnive 2-DC-318 */5 Starting Air Tank Isolation 2" C10be M O None - -

Passive 2-DC-31C */5 Starting Air Tank Isolation 2" Globe M O None - -

Tassive 2-DC-31D */B Starting Air Tank Isolation 2" Clobe M 0 None - -

Passive 2-DC-32A */C Check Valves - Internals 2" None - -

None - -

Removed 2-DC-328 */C Check Valve - 2nternals 2" None - -

None - -

Removed 2-DC-32C */C Check Valve - Internals 2" None - -

None - -

Removed 2-DC-32D */C Check Valve - Internals 2" None - -

None ' - -

Removed 2-DC-35A */C Charging Air Inlet l\" Check - C Q - -

Check Valve

  • Noncode Class Valven.

Note 3 - Stroke Test only - Verify Diesel Meets Tech. Spec. Start Limits.

Sheet 1 ef TABLE IWV DIESEL ATR STARTING SYSTDI (DASS)

Class / Valve Normal Test Relief Test ,

VS1ve Number Category Function Size Type Actuation Position Raquired Requested Alternate 2-DC-43 */B Starting Air Cross-Connect 2" Cate M C None 2 - -

Passive to Station Air 2-DC-44 */B Starting Air Cross-Connect 2" Cate M C None - -

Passive to Station Air 2-DG-45 */B Starting Air Cross-Connect 2* Cate M C None - -

Passive to Station Air ,

2-DC-46 */B Starting Air Cross-Connect 2\" Cate M C None - -

J Passive to Station Air 2-DC-47 */B Starting Air Cross-Connect 2\" Clobe M C None - -

Passive 2-DC-48 */5 Starting Air Cross-Connect 2\" Clobe M C None - -

i Passive 2-DC-54 */C Starting Air Tank Relief \" Re1 Self C SRY - -

2-DC-55 */C Starting Air Tank Relief "

Re1 Self C SRV - -

2-DC-56 */C Starting Air Tank Relief Re1 Self C SRV - -

2-DC-57 */C Starting Air Tank Relief Re1 Self C SRV - -

2-DC-86A */B Starting Air Isolation l\" Cate M LO None - -

j Passive 2-DC-86B */5 Starting Air Isolation 1\" Cate M LO None - -

Passive 2-DC-87A */B Starting Air Isolation 1" Cate M LO None - -

Passive 3

2-DC-878 */B Starting Air Isolation 1\" Cate M LO None - -

Passive 2-DC-88A */B Starting Air Bleed Isolation l\" Cate M LO None - -

Passive j 2-DC-885 */B Starting Air Bleed Isolation 1" Cote M LO None - -

Passive 2-DC-91A */B Air Start 1\" A0V AO C/ Fail Open Q/Ft V-3 Note 3 2-DC-918 */B Air Start l\" A0V A0 C/ Fall Open Q/Ft V-3 Note 3 2-DC-97A */B Air Start l\" AOV Ao C/ Fall Open Q/Ft V-3 Note 3 2-DC-92B */B Air Start l\" AOV A0 C/ Fall Open Q/Ft V-3 Note 3 (Nonende Class Valves.

Note 3: Stroke Test only. Verify Diesel Pects Tech. Spec. Start Limits.

i

4 Sheet b sf 0 TABLE TWV DIESEL AIR STARTINC SYSTEN (DASS)

Class / Valve Norsel Vilve Number Category Function Test Relief Test

Size Type Actuation Position Required Requested Alternate 2-DC-355 */C Charging Air Inlet ik" '

. Check -

C Q -

Check Valve -

4 1 2-DC-35C */C Charting Air Inlet ik" Check -

C Q =

Check Valve -

2-DC-35D */C Charging Air Inlet l\" Check -

C Q -

] Check Valve -

2-DG-93A */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-93B */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-94A */C Starting Air Actuation Bleed  %" 3-Way Self C Q - -

2-DC-948 */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-95A */B Air Start Solenoid \" SOV SO C/ Fail Open Q/Ft V-3 Note 3 2-DC-955 */B Air Start Solenoid \" SOV 50 C/ Fall Open Q/Ft V-3 4 Note 3 l 2-DC-96A */B Air Start Solenoid \" SOV SO C/ Fall Open Q/Ft V-3 Note 3 2-DC-96B */B Air Start Solenoid \" SOV So C/ Fall Open Q/Ft V-3 Note 3 i

l i

1 i

i i

i fNoncode Class Valves.

Note 3 - Stroke Test only - Verify Diesel Meets Tech. Spec. Start Limits.

I w

t

Sheet af TABLE IWV JACEFT C001.INC STSTM (JCS) class / Valve Normal Test Valve Ntaber Category Function Relief Test -

Size Type Actuation Position Required Requested Alternate 2- W 14A */C Check Valve 6" CK -

C '

Q - -

2- W l45 */C Check valve 6" CK -

C Q - -

2-DG-70A */(Note 1) Jacket Cooling Temperature 6" 3-Way System -

None - -

Control 2- W 705 */(Note 1) Jacket Cooling Temperature 6", 3-Way System -

None - -

Control 2- W 75A */B Turbo Charger Cooling 1" Cate M O None - -

Pasalve Isolation 2- W 75B */B Turbo Charger Cooling 1" Cate M O None - -

Passive Isolation 2-DC-76A */B Turbo Charger Cooling 1" Cate M O Mone - -

Passive Isolation 2-DC-76B */B Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation 2-DC-77A */8 Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation 2- W 77B */B Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation Note 1: Control valves are creept from testing per paragraph IW1200 of the ASME Section II. BP&V. Code 1980 Edition including the Winter 1981 Addenda.

  • Noncode Class Valves.

Sheet [ cf TA31.E IW e

AIR C0f1 LING SYSTDE (ACS)

Claos/ Talve Normal Test Relief Test valv,Mumber

  • Cateaory Functice Size Type Actuation Position Required Requested Alternate 2-DC-3A */C Check Valve 4" CK - C Q s - -

2-DC-38 */C Check Valve 4" CE - C Q - -

2-DC-19A */C Check Valve lh" CK - C Q - -

2-DC-195 */C Check Valve l\" CK - C Q - -

2-DC-69A */(Note 1) Air Cooling Temperature 4"

  • 3-Way System - None - -

Control 2-DC-695 */(Note 1) Air Cooling Temperature 4" 3-Way System -

None - -

Control Note I: Control valves are exempt free testing per paragraph IWI24 of the ASME Section II, BP&Y. Code 1980 Edition, including the Winter 1981 Addenda.

  • Moncede class Talves.

O

.m. . _ _ _ _ _ ...._m... . _ - . . - _ . . _ _ _ _ . _ . . _ . . . _ . . ._ ________..__._..___.__,.._._-..m s _ _ _ _ . . . . _ . _ . __

i Sheet I cf . ,;

} TABLE YUV 1

l DIESEL 123E Olt SYSTDI (DLOS)

Class / Valve Normal Test Relief Test '

  • Valve N eber Cateacry Function Stre Type Actuation Position Required Roguested Alternate I

4 2-DC-51A */C Check Valve l\" CK -

C Q s - -

l j 2-DG-515 */C Check valve 1\" CE - C Q - -

1 2-DC-65 */C Safety Relief \" Bel -

C SRV - -

! 2-DG-66 */C Safety Zelief \" Re1 -

C SRV - -

2-DC-71A */(Wote 1) Labe 011 Temperature Control 4" ' 3-Way System -

None - -

2-DC-718 */(Wote 1) Lebe 011 Temperature Control 4" 3-Way System -

None - -

i i

1 Y

4 1

i i

1 I

i -

4 7

i .

.t i

4 t

i r

j Note 1: Control valves are esempt from testing per paragraph IWV1200, j of the ASME Section II, BP&V. Code 1980 Edition, including 1 the Winter 1981 Addenda.

1 1

  • Noncede Class Valves.

i i j

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1 I

Sheet 7 ef b '

TAPLF IW P FITI. 011. SYSTDt (FOS) .

Yalve Normal Test Relief Test Class / Required Requested Alternate valve Leber Catererv Function Stre Type Actuation Position 1" Cate M 0 None - -

2-F0-11 */B Fuel Oil Supply Tank Isolation Passive 1" Cate M 1.C None - -

2-FO-12 */B Fuel Oil Cross-Connect Passive Band Pump Discharge Check 1" CK - C Q 2-FO-13 */C Fuel Oil Check CK - C Q 2-FN14 */C l\"

1\" Cate M 0 None - -

2-FO-17 */B Fuel Oil Pump Iso?ation Passive Fuel Oil Supply Tank Cate M 0 None - -

2-FO-27 */B l\"

Passive Isolation Hand Pump Discharge Check 1" CK - C Q 2-FO-28 */C Fuel Oil Check 1" CK C Q

  • /C 2-FO-29 1\" Cat e M O None - -

2-FO-33 */B Fuel Oil Pump Isolation Passive 3/4" Cate M 0 None - -

2-FO-65A */B Clean Oil Storage Tank Passive Inlet Isolation 2-FO-65B */B Clean Oil Storage Tank 3/4" Cate M 0 None - -

Passive Inlet Isolation Clean 011 Storage Tank 3/4" Cate M O None - -

2-FO-65C */B Passive Inlet Isolation 3/4" Cate M O None - -

2-FO-65D */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" Cate M O None - -

2-TO-66A */B Clean Oil Storage Tank Passive Inlet Isolation Clean Oil Storage Tank 3/4" Cate M 0 None - -

2-FO-66B */B Passive Inlet Isolation 3/4" Cate M 0 None - -

2-FO-66C */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" Cate M O None - -

2-FO-66D */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" CK - C Q V-1 Note 4 2-FO-67A */C Clean Oil Transfer Pump Discharge Check Clean Oil Transfer Purp 3/4" CK - C Q V-1 Note 4 2-FO-67B */C Discharge Check

  • Noncode Class Valves.

Sheet b cf b TABt.E TWV ,

FITL 011. SYSTFM (FOS) .

Class / falve Normal Test Relief Test -

Valv. Jumher Cateeory Function Size Type Actuation Position Required Requested Alternate 2-FO-t7C */C Clean 011 Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-67D */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-68A */B Clean Oil Transfer Purp 3/4" Cate M 0 None - -

Passive Discharge Isolation 2-FO-688 */B Clean Oil Transfer Pump 3/4" Cate M 0 None - -

Passive Discharge Isolation 2-FO-6AC */B Clean 011 Transfer Pump 3/4" Cate M o None - -

Passive Discharge Isolation 2-FO-68D */B Cleso 011 Transfer Pump 3/4" Cate M o None - -

Passive Discharge Isolation 2-FO-69 */B Clean Oil Cross-Connect 3/4" Cate M 0 None - -

Passive 2-FO-70 */B Clean Oil Cross-Connect 3/4" Cate M O None - -

Passive 2-FO-71 */C Fuel 011 Relief \" Re1 - C SRV - -

2-FO-72 */C Fuel Oil Relief \" Re1 - C SRV - -

2-FO-79 */B Fire Shutoff 1" Cate Thermally 0 Q V-2 Note 2 Fused 2-FO-80 */5 Fire Shutoff l\" Cate Thermally 0 Q V-2 Note 2 Fused 2-FO-84 */B Fuel 011 Cross-Connect 1" Cate M LC None - -

Passive 2-FO-85A */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85B */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85C */C Clean 011 Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85D */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check Note 2: Stroke Test only, Verify Stroke Time 2 Secends.

Note 4: Disansemble and inspect one valve of each size and type, each refueling outage.

  • Woncode Class Valves.

Docket No. 50-336 Attachment No. 2 Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel Generator Auxiliary System l

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1

[

i r

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i August,1986 l

s o .

ATTACHMENT 2 RESPONSE TO NRC CONCERNS EXPRESSED IN A MEETING WITH NORTHEAST UTILITIES REPRESENTATIVES JULY 23, 1986 ITEMS 1.A. 1.B.2, 1.C.1 COMMENT - The program's "IWP Pump Table" specifies Relief Request No. 1 (RR #1) for two items, lubrication and bearing temperature, however, RR #1 does not cover these items.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEMS 1.B.1, 1.C.2 COMMENT - The IWP Pump Table lists the flow resistance as " fixed,"

however, (temperature control valves) appear to provide variable hydraulic resistance. What is the basis for designating the system as fixed flow resistance?

RESPONSE - This information is no longer relevant to the program.

It has been deleted from the table. It's inclusion was based on earlier versions of the ASME Code which allowed variations in monitoring parameters for fixed resistance systems. The currently invoked ASME Code does not allow this distinction.

ITEM 1.C.3 COMMENT - What is the safety-related function of the EDG turbo-charger 2

, RESPONSE - The turbo-charger provides increased combustion air to the engine to facilitate cylinder cooling and scavenging. This increases the available power from the engine and improves efficien-cy. Though diesel engines are capable of operating without turbo-chargers, it is unlikely that this engine could develop full design power (as required by the Technical Specification) if the turbo-chargers were inoperable. As requested, a specific relief request has been submitted for these units.

t ITEM 1.C.4 COMMENT - Whct is the safety-related function of the electric motor-driven Jacket Coolant Pump P88A and P88B?

RESPONSE - These pumps have no safety-related function. They are provided to assist in maintaining engine temperatures to minimize temperature stresses during engine start. This minimizes the wear and tear on the engine during testing. The engine is capable of meeting all startup and operational requirements with this pump out of service.

Attachment 2.1 i

i

. , _ _ - . . _ _ _ . . _ _ . , , , , . _ . ~ - - . . . - , - _ _ . . _ , . . - _ . _ - _ _ _ _ . _ - . . ~ , - -- - -

ITEM 1.D COMMENT - The alternate testing proposed (for the Air Cooling Pamps) is to monitor DG engine air intercooler outlet air tempera-ture. The relief request (RR #2) has no direct measurements being made to directly assess component operability nor proposed action ranges. Provide your basis to show that the component operability testing being performed is demonstrating operational readiness of these pumps.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting..

ITEM 1.E COMMENT - Relief Request No. 3 lacks specificity regarding what paraments are to be monitored and action ranges to be taken.

Revise the relief request to provide specificity.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 1.F COMMENT - Describe any investigation and proposed modifications that are planned or have been made to improve that inservice component testing of these pumps.

RESPONSE - Evaluation of testing techniques and test data is ongoing. Procedures and techniques are being refined to better meet test objectives. No system modifications are planned. The testing required by Technical Specifications and the testing proposed herein is adequate to fully assure the required diesel generator reliability.

, ITEM 2. A. (1)

COMMENT - Check valves 2-FO-67A, B, C, D, and 2-FO-85A, B, C, and D are designated Category C and the relief request requested relief from all testing. This relief request does not provide alternate testing acceptable to the staff or a technical basis for not testing or providing suitable alternate testing of the valves. The staff normally does not grant the requested relief. The staff will consider alternate methods for determining the condition of each valve, for example, a sampling program of mechanical disassembly of like valves of the same type, size, and manufacturer. Provide your revised relief request showing a suitable alternative testing method.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

, Attachment 2.2

.,. . _ _ . _ - , _ _ _ _ . - _ , . - - - - - . . - . ~ _ _ _ _ _ _ . - - _ . _ _ - _ _ -

5 * .

ITEM 2.A.(2)

COMMENT - Check valves 2-FO-13 and 2-FO-28 are not listed in the program. Will failure of one of these valves result in a reduction of fuel oil flow to the diesel?

RESPONSE - Failure of these valves is not expected to result in a significant reduction of fuel oil flow because of the hand priming pump design. However, these valves have been added to the program listing to clarify their status.

ITEM 2.A.(3)

COMMENT - The relief request titled " Fuel Oil" appears to include valves from other systems as well.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.B. (1)

COMMENT - The legend for valves 2-DG-27A and 2-DG-27B does not clearly indicate that a limiting stroke time is required.

NOTE: The NRC staff has identified rapid-acting power-operated valves as those which stroke in two seconds or less. Relief from the trending requirements of Section XI (paragraph IWV-3410(C))

will be given for these valves since variations in stroke times will be affected by slight variations in the response times of the personnel performing the tests. However, the staff does require that the licensee assign a maximum limiting stroke time of two seconds,to these valves in order to obtain this code relief.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

1 ITEM 2.B. (2)

COMMENT - Why aren't valves 2-DG-29A, B, C, and D, and 2-DG-35A, B, C, and D classified as Category AC and subjected to periodic leak testing? A failure of a starting air tank could compromise the redundant tank's air supply if these valves leak.

RESPONSE - Article IWV-2200(A) identifies as Category A: " Valves for which seat leakage is limited to a specific maximum amount in the closed position of fulfillment of their function."

These valves do not have, nor need to have, a specific maximum leak limit. The valve is tested to verify it strokes properly (Catego-ry C test). In the event a starting air tank failed, low pressure alarms would immediately alert Operations personnel. Even if these

. valves failed to close and operators took no corrective action, only one diesel generator would be inoperative. Plant operation is allowed for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with one diesel generator inoperable. Thus, Attachmert 2.3

6 = .

while not a desirable situation, high levels of leakage (or total failure) of these valves does not unduly jeopardize safe operation of the plant. Designation of these valves as Category C is appro-priate.

ITEM 2.B.(3)

COMMENT - Relief is requested from stroke time measurements, however, the footnote does not provide a technical basis for the relief requested (reference NOTE above). There is no relief request basis provided.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.B.(4)

COMMENT - The legend used does not clearly indicate that a limiting stroke time is required for the air start solenoid valves (reference NOTE above).

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.C. (1) and 2.D COMMENT - What is the basis for not including relief valves 2-DG-67, 68, 63, 64, 81A, and 81B in the program?

RESPONSE - These low capacity thermal relief valves are not in-stalled for operating system protection. These valves are in piping normally vented to atmosphere. Their sole function is to provide temponent overpressure protection when the components are i isolated. Leakage through these valves would be detected (in the absence of operator action) by the expansion tank low level alarm, '

just as any other system leak would be. Since they are not rele-vant to the safe operation of the system, they were not included in the testing lists.

ITEM 2.E COMMENT - Your February 28, 1986 letter, Attachment 2 response stated that the air supply to the service water valves is not safety-related, however, the air operated service water valves are designed to fail in a position which will allow the safety-related system to fulfill its safety-related function. Note: Testing of the service water valves was not incorporated in your response.

Describe your inservice testing being performed on Service Water Valves FV6341, 6342, 6389, and 6397. Does this testing verify that the valves will fail in the position which will allow the safety-related system to fulfill its safety-related function? If not, what other testing verifies this?

A I

Attachment 2.4

o n. o -

RESPONSE - These valves are included in the approved Inservice Inspection Program for Code Class 1, 2, and 3 Components for the Second Ten-Year Interval. They are stroke tested, timed, and failure mode tested each quarter This assures the valves fail in the position which will allow ths safety-related system to fulfill its function.

l l

i Attachment 2.5

>

Text

O O General Offices

l August 29,1986 l

Docket No. 50-336 A05353 B12232 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director .

PWR Project Directorate (i8 Division of PWR Licensing - B U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel Generator Auxiliary Systems In a letter dated December 31,1985(l), Northeast Nuclear Energy Company (NNECO) informed the NRC Staff that the emergency diesel generator (EDG) auxiliary systems at Millstone Unit No. 2 would be included in the Inservice Testing Program (IST). In a letter dated February 28,1986, NNECO provided the NRC Staff with additional information regarding IST of EDG auxiliary systems, including valve and pump listings and requests for relief from certain ASME code requirements.

The NRC Staff conducted ageliminary review of the above stated program and in a letter dated May 6,1986ui, provided interim approval of the relief requested in Reference (2). This interim approval was granted for six (6) months from the date of Reference (3) or until the NRC Staff completed its detailed review of this program, whichever comes first. To support this detailed review, NNECO is hereby transmitting additional (attached) information. Attachment (1) consists of revisions to the relief request and the pump and valve tables submitted in Reference (2). Attachment (2) provides a detailed response to questions that were informally communicated to NNECO by the NRC Staff.

(1) 3. F. Opeka letter to A. C. Thadani, dated December 31,1985.

(2) 3. F. Opeka letter to A. C. Thadani, dated February 23,1986.

(3) A. C. Thadani letter to J. F. Opeka dated May 6,1986.

O 8609110049 860829 PDR ADOCK 05000336 g\%

p ,

PCR

. _. __ . - . . - _ . _ . - . . . . _ . . ~ . .. .- .

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We trust that this information is responsive to your request.

Very truly yours, 4

NORTHEAST NUCLEAR ENERGY COMPANY

. F. C A

3. F. OpeV U Senior Vice President

? Attachment J

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.e e Docket No. 50-336 Attachment No.1 Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel GeneratorAuxiliary Systems ;.

Revised Relief Request and Pump / Valve Tables August,1986

5 i Relief Request No. P-1 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED PUMPS: Engine-Driven Fuel Oil Pumps f

T5ST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any devia-tions determined shall be compared with the limits given in Table IWP-3100-2andthespecifiedcorrectiveactiontaken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

, (5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with

, the limits given in Table IWP-3100-2 and take specified corrective l action.

BASIS FOR RELIEF: The basis for relief is (paragraph numbers match those above):

(1) During diesel generator operation, system resistance cannot be varied. There is no provision for throttling or fuel control beyond that inherently provided by operation of the loaded diesel generator. Attempts to vary system resistance would degrade the performance of the diesel generator.

(2) There are no instruments to measure fuel flow or fuel pump differ-ential pressure. The supply to the pump is an elevated storage tank. Only fuel pump discharge pressure is available at the engine. Discharge pressure of this positive displacement pump is affected by the cleanliness of the downstream fuel oil filter.

, (3) As noted above, there is no inlet pressure monitoring ability. The l diesel fuel oil supply tank normally operates within a six-inch level range. Thus, static suction pressure is essentially constant.

P-1.1 l

- - - - . ._ - _ -- - _ _ - _ - _ = = _ _ . - _ - _ _ - - . - _

s i Inadequate inlet pressure would be identified by low pump discharge pressure or inability.of the diesel generator to achieve Technical t

Specification load carrying requirements.

l (4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to i

allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential

alternative, monitoring of the housing temperature does not provide j meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

!' (6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-l related pump testing. The pump discharge pressure is low (< 30 1 psig), thus the acceptable range (per Table IWP-3100-2) is less

than 4 psig. Normal system variations can exceed this range

} without impacting diesel generator operability.

ALTERNATE TESTING
Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator j will be operated at a fixed, procedurally specified Icad. All  !

readingg will be taken after the generator has been essentially stable at this load for at least 15 minutes.

l (2) Measure pump discharge pressure when the engine is operating, as

, described in (1) above.

i (3) The fuel oil supply tank will be maintained in the normal level l range during testing.

(4) Proper operation of the engine lubrication system will be verified ,

I during the test.

i j (5) No alternative testing is proposed.

! (6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which l allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

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I P-1.2 l

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, , _ . . . - _ _ , . ._ _ _ -_m_ ,___ _ __ _.._,,,.________.._,_m._,__,,

. ._- _ .- . -.- .- - . . __ . . _ _ _ . - _ . ~ . - - . - .

T 1

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Relief Request No. P-2 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2

, SYSTEM: Lube Oil

AFFECTED PUMPS
Engine-Driven Lube Oil Pumps TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured i flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any devia-  ;

tions determined shall be compared with the limits given in Table IWP-

3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

i (3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

! (5) The requirement to measure and record bearing temperature.

l-(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective i action.

r BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match i

those above) l (1) During diesel generator operation, system resistance cannot be

varied. There is no provision for lube oil flow control beyond that inherently provided by operation of the loaded diesel genera-I tor. Attempts to vary system resistance could cause failure of the

{ diesel generator.

j (2) There are no instruments to measure lube oil flow or pump differen-

tial pressure. The supply to the pump is the engine sump. Sump i

level is closely controlled to manufacturer's requirements. Sump level is monitored as part of routine diesel generator operation.

The principal vital measurement is lube oil pressure within the engine.

i t

P-2.1 i

f I

) 1 (3) As noted above, there is no inlet pressure monitoring ability.

Sump level is closely controlled. Routine monitoring of sump level or Icw pump discharge pressure would identify reduced inlet head.

(4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low (4 30 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 4 psig. Normal system variations can exceed this range without impacting diesel generator operability, f ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings-will be taken after the generator has been essentially j stable at this load for at least 15 minutes.

1 (2) Measure engine oil pressure when the engine is operating as described in (1) above.

(3) The lube oil sump will be maintained in the normal level range during testing.

(4) Proper operation of the engine lubrication system will be verified during the test.

(5) No alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

P-2.2 L

% t Relief Request No. P-3 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Jacket Water Cooling AFFECTED PUMPS: Engine-Driven Jacket Water Cooling Pumps 1 TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

l (1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

(5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective action.

BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match those above)

(1) During diesel generator operation, system resistance cannot be varied. There is no provision for throttling or cooling water flow control beyond that inherently provided by operation of the loaded diesel generator. Attempts to vary system resistance could cause j failure of the diesel generator.

I (2) There are no instruments to measure cooling water flow or pump differential pressure. The supply to the pump is an elevated, atmospheric pressure expansion tank. Only pump discharge precsure is available at the engine.

l (3) As noted above, there is no inlet pressure monitoring ability.

( Expansion tank level is controlled. Routine monitoring of expan-sion tank level, increase in engine temperatures, or low pump j discharge pressure would identify reduced inlet head.

l P-3.1 l

l

i .

(4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress, bearing temperature monitoring must be continuous rather than periodic. Failing bearings often exhibit fluctuations between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded diesel generator are more susceptible to influences of ambient conditions and ccoling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low ( < 34 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 4 psig. Normal system variances can exceed this range without impacting diesel generator operability.

ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings will be taken after the generator has been essentially stable at this load for at least 15 minutes.

(2) Measure pump discharge pressure when the engine is operating as described in (1) above.

(3) The expansion tank level will be maintained in the normal level range during testing.

(4) Proper operation of the engine lubrication system will be verified during the test.

(5) No alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

P-3.2

i .

Relief Request No. P-4 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Cooling AFFECTED PUMPS: Engine-Driven Air Cooling Pumps T5ST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure' or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from the following requirements:

(1) The requirement to vary the resistance of the system until flow or differential pressure reference values are achieved.

(2) The requirement to measure and record flow and differential pres-sure readings.

(3) The requirement to measure inlet pressure.

(4) The requirement to verify proper lubricant pressure for this pump.

(5) The requirement to measure and record bearing temperature.

(6) The requirement to compare deviations from reference values with the limits given in Table IWP-3100-2 and take specified corrective l action.

t

! BASIS FOR RELIEF: The basis for relief is: (paragraph numbers match those above)

~

(1) During diesel generator operation, system resistance cannot be i varied. There is no provir'03 'or throttling or cooling water flow control beyond that inhecta:37 rovided by operation of the loaded diesel generator. Att n; a t< ary system resistance could degrade performance of the dies 1 gea,.stor.

(2) There are no instruments to measure cooling water flow or pump differential pressure. The supply to the pump is an elevated, atmospheric pressure expansion tank. Only pump discharge pressure is available at the engine.

l l (3) As noted above, there is no inlet pressure monitoring ability.

Expansion tank level is controlled. Routine monitoring of expan-sion tank level, increase in engine temperatures, or low pump discharge pressure would identify reduced inlet head. ,

P-4.1 l__

i .

}i (4) This pump is engine-driven and lubrication requirements are met by the engine lubrication system. No instrumentation is provided to allow individual unit monitoring. Proper operation of the engine lube oil system assures proper lubrication of the unit.

(5) Bearings for this pump are inaccessible for measurement. In addition, experience has shown that to be effective in identifying bearing distress, bearing temperature monitoring must be continu-

, ous, rather than periodic. Failing bearings often exhibit fluctua-tions between normal and abnormal temperatures. Further, one potential alternative, monitoring of the housing temperature, does not provide meaningful monitoring of bearing temperature since the housing temperature is significantly less responsive to bearing metal temperature changes.

(6) Reference values for the auxiliary systems of a loaded dierel generator are more susceptible to influences of ambient conditions and cooling water temperatures than normally experienced in safety-related pump testing. The pump discharge pressure is low (< 11 psig),

thus the acceptable range (per Table IWP-3100-2) is less than 1.5 psig. Normal system variations can exceed this range without impacting diesel generator operability.

ALTERNATE TESTING: Proposed alternate testing is: (paragraph numbers match those above)

(1) In lieu of varying system flow and resistance, the diesel generator will be operated at a fixed, procedurally specified load. All readings will be taken after the generator has been essentially stable at this load for at least 15 minutes.

(2) Measure pump discharge pressure when the engine is operating as described in (1) above.

l (3) The expansion tank level will be maintained in the normal level j range during testing.

l (4) Proper operation of the engine lubrication system will be verified l

during the test.

(5) No. alternative testing is proposed.

(6) Pump discharge pressure will initially be compared to the limits for differential pressure specified in Table IWP-3100-2. If experience shows these ranges cannot be met, range limits which allow the pump to fulfill its function will be specified as allowed by Article IWP-3210.

j l

P-4.2 l

l

Relief Request No. P-5 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil (Clean Oil Return to Diesel Supply Tanks)

AFFECTED PUMPS: Clean Oil Pumps TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED
Relief is requested from measuring and recording all required parameters.

BASIS FOR RELIEF: There is no instrumentation which can be used to measure inlet pressure, differential pressure, or flow. There are no accessible bearings. The unit is mounted on the diesel engine structure precluding meaningful vibration measurements. There is no separate lubrication supply to the units.

This portion of the fuel oil systems coosist of two cross-connected 9.5 gallon tanks, each equipped with a clean oil return pump. This system operates intermittently to return clean fuel leakage to the fuel supply tank. Only one pump is required for operation. The redundant pump provides reasonable assurance that diesel generator operability will be maintained. Routine operator observation of the system during diesel generator operation would identify any system failure.

l

ALTERNATE TESTING
No specific testing will be conducted. Routine observation of the system during diesel generator operation will provide needed assurance of operability.

P-5.1 l

Relief Request No. P-6 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Intake AFFECTED PUMPS: Diesel Generator Turbo-chargers TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corresponding reference value. The test quantities shown in Table IWP-3100-1 shall then be measured or observed and record-ed as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity. Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and the specified corrective action taken.

RELIEF REQUESTED: Relief is requested from measuring and recording all required parameters.

BASIS FOR RELIEF: This self-contained unit has no instrumentation. It is cooled and lubricated by the engine auxiliaries. It has no controls as the correlated action of the turbine and blower is entirely automatic.

The sole measure of turbo-charger performance is the ability of the diesel generator to develop rated output.

ALTERNATE TESTING: None under this program. The diesel generator load handling ability is tested in accordance with Technical Specification requirements.

P-6.1

Relief Request No. P-7 Inservice Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: All Diesel Generator Engine-Driven Pumps AFFECTED PUMPS: All Pumps TEST REQUIREMENT: Article IWP-4510, at least one displacement vibration amplitude (peak-to-peak composite) shall be read during each inservice test.

RELIEF REQUESTED: Relief is requested from taking vibration measure-ments directly on these pumps.

BASIS FOR RELIEF: Meaningful vibration measurements cannot be taken on engine-mounted pumps. The overall engine vibration completely overwhelms any vibration generated by the pump. Thus, vibration measurements on these units would not identify potential or actual degradation of the pump. Vibration monitoring of the engine casing can provide information which would allow assessment of the overall engine performance and operability.

ALTERNATE TESTING: No alternative testing of the pumps is proposed.

Vibration measurements will be taken on the diesel engine during inser-vice tests.

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P-7.1 L

Relief Request No.'/-1 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil (Clean Oil Tank Discharge to Diesel Oil Supply Tank)

AFFECTED VALVES: 2-FO-67A, 67B, 67C, 67D, 85A, 85B, 85C, and 85D CATEGORY: C CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3521 - Check valves shall be exercised at least once every three months.

RELIEF REQUESTED: Relief is requested from all operational testing.

BASIS FOR RELIEF: There is no instrumentation on the piping or associ-ated pumps and tanks. Thus, there is no way to verify, with an opera-tional test, that the valves operate on demand. This portion of the fuel oil system of each diesel generator consists of two tanks, two pumps, and four check valves (Drawing 25203-26010). These two tanks (capacity 9.5 gallons each) are cross-connected through normally open valves 2-FO-69 and 2-FO-70. Failure of any one of these check valves to open would not affect diesel operability since the redundant pump and piping flow path would provide adequate return capacity. Failure of any one check valve to close would not affect diesel generator operability since the redundant check valve in each line provides backup capability.

Further, even if both check valves in one line simultaneously failed, the only effect would be to allow the return piping to the diesel storage tank to drain to the clean oil tanks when the affected pump was secured. The quantity of oil held by the piping is less than 10 percent of the tank c'apacity. The positive displacement transfer pump in the piping with the failed check valves would sufficiently restrict flow that accumulated diesel fuel in the clean oil tanks could still be pumped to the diesel supply tank.

ALTERNATE TESTING: One valve of each type and size will be disassembled and inspected each refueling outage.

4 e

V-1.1

O e Relief Request No. V-2 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED VALVES: 2-FO-79, 2-FO-80 CATEGORY: B CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3413(b) - The stroke time of all power operated valves shall be measured to the nearest second,for stroke times ten seconds or less,or 10 percent of the specified limiting stroke time for full stroke times longer than ten seconds whenever such a valve is full stroke tested.

RELIEF REQUESTED: Relief is requested from measuring stroke time of these valves.

BASIS FOR RELIEF: These thermally fused quick acting valves have stroke times of less than one second. Measurement of these times provides no realistic information for evaluation of valve condition.

ALTERNATE TESTING: The valves will be stroke tested as required by Article IWV-3412. The valves will be monitored during stroke testing to assure closure occurs in less than two seconds. Valves which do not close within two seconds will be considered inoperable.

V-2.1

Relief Request No. V-3 Inservice Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Air Starting System AFFECTED VALVES: 2-DG-91A, 91B, 92A, 92B, 95A, 95B, 96A, 96B, 27A, and 27B CATEGORY: B CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3413(b) - The stroke time of all power operated valves shall be measured to the nearest second for stroke times ten seconds or less,or 10 percent of the specified limiting stroke time for full stroke times longer than ten seconds, whenever such a valve is full stroke tested.

RELIEF REQUESTED: Relief is requested from measuring stroke time of these valves.

BASIS FOR RELIEF: These valves have no visible operating parts. There are no system instruments which monitor their operation. Thus, there is no way to measure the stroke time of the valves. Further, the actual stroke time of these valves is very short (less than one second) and measurement of stroke time would provide no realistic information for evaluation of valve condition.

The function of these valves is to admit starting air to the diesel engine and to stop air application when the engine is operating. The Unit 2 Technical Specification requires that the diesel generator

" starts from ambient condition and accelerates to Jt90 percent of rated speed and to 2 97 percent of rated voltage in di20 seconds." If these valves do not travel fu.1.1 stroke,,or operate slowly, the diesel will not meet the overall operability test. Thus, reliance on this overall operability test is appropriate to demonstrate prompt valve operation.

ALTERNATE TESTING: Once per quarter, each valve will be tested to assure proper operation by verifying the diesel generator meets the overall operability (starting) requirements of the Unit 2 Technical Specification when started using only one tank and one air start valve train.

V-3.1 l _ _ _ _ _ __ . _ _ . _ _ . . - . . .-- - _

_ _ _ . _ . . ..__.__...m. . . ___

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  • v mgr ;7 IWP PIMP TABI.E N Speed inlet Differential .

Bearing Pump Control Pressure Pressure . Flow Vibration Lubrication Temperature Frequency Puel Oil System Fuel Oil Pump A variable

  • RRfP-1 RRfP-1 RRfP-1 RRfP-7 RRIP-1 RRfP-1 Quarterly ,

Tuel 011 Pump B Variable

  • RRfP-1 RRfP RRfP-1 RRfP-7 RRfP-1 RRfP-1 Quarterly 1.ube Oil System P48A Lube Oil Pump Variable
  • RRfP-2 RRfP-2 BRfP-2 RRfP-7 RRfP-2 RRfP-2 Quarterly P48B Lube 011 Pump Variable
  • RRfP-2 RRfP-2 RRfP-2 RRfP-7 RRfP-2 RRfP-2 . Quarterly Jacket Cooling Water System P49A Conling Pump Variable
  • RRfP-3 RRfP-3 RRIP-3 RRfP-7 RRfP-3 RRIP-3 Quatrerly P49B Cooling Pump variable
  • RRfP-3 RRfP-3 RRfP-3 RRIP-7 RRfP-3 RRfP Quarterly Air Cooling System P127A Air Cooler Coolant Pump Variable
  • RRIP-4 RRfP-4 RRfP-4 RRfP-7 RRfP-4 RRfP-4' Quarterly P127B Air Cooler Coolant Pump Variable
  • RRfP-4 RRIP-4 RRfP-4 RRfP-7 RRfP-4 RRfP-4 Quarterly.

Clean Oil System P128A - Clean 011 Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRIP-5 Quarterly P128B - Clean Oil Pump Fixed RRfP-5 RRfP-5 kRfP-5 RRfP-5 RRfP-5 RRfP-5 Quarterly P128C - Clean 011 Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRIP-5 Quarterly.

P128D - Clean Oil Pump Fixed RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 RRfP-5 Quarterly Turbo-charmers Diesel Generator A Turbo-chargers Variable ** RRf6 RRf6 RRf6 RRf6 RRf6 RRf6 -

Diesel Generator B Turbo-chargers variable ** RRf6 RRf6 RRf6 RRf6 RRf6 RRf6 -

  • Varies with engine speed.
    • Varies with engine power.

RRix = Rellef Requested. (x = Relief Request No.)

Sheet I af b TABLE IW DIESEL AIR STARTING SYSTFM (DASS)

Class / Valve Normal Test Belief Test Y21ve Number Category Function Size Type Actuation Position Required Requested Alternate 2-DC-27A */B Air Bleed Cutoff th" SOV SO 0/ Fall Closed Q/Ft V-3 Note 3 2-DC-275 */B Air Bleed Cutoff th" SOY SO 0/ Fail Closed Q/Ft V-3 Note 3 2-DG-29A */C Check 2" CK - C Q - -

2-DC-298 */C Check 2" CK -

C Q - -

2-DC-29C */C Check 2" CK -

C Q - -

2-DC-29D */C Check 2" CK -

C 0 - -

2-DC-30A */B Startirg Air Isolation th" Clobe M O None - -

Passive 2-DC-308 */B Starting Air Isolation th" Clobe M 0 None - -

Passive 2-DC- YC */5 Starting Air Isolation 1" Clobe M 0 None - -

Passive 2-DC-30D */B Starting Air Isolation I" Clobe M 0 None - -

Passive 2-DC-31A */B Starting Air Tank Isolation 2" Clobe P O None - -

Parnive 2-DC-318 */5 Starting Air Tank Isolation 2" C10be M O None - -

Passive 2-DC-31C */5 Starting Air Tank Isolation 2" Globe M O None - -

Tassive 2-DC-31D */B Starting Air Tank Isolation 2" Clobe M 0 None - -

Passive 2-DC-32A */C Check Valves - Internals 2" None - -

None - -

Removed 2-DC-328 */C Check Valve - 2nternals 2" None - -

None - -

Removed 2-DC-32C */C Check Valve - Internals 2" None - -

None - -

Removed 2-DC-32D */C Check Valve - Internals 2" None - -

None ' - -

Removed 2-DC-35A */C Charging Air Inlet l\" Check - C Q - -

Check Valve

  • Noncode Class Valven.

Note 3 - Stroke Test only - Verify Diesel Meets Tech. Spec. Start Limits.

Sheet 1 ef TABLE IWV DIESEL ATR STARTING SYSTDI (DASS)

Class / Valve Normal Test Relief Test ,

VS1ve Number Category Function Size Type Actuation Position Raquired Requested Alternate 2-DC-43 */B Starting Air Cross-Connect 2" Cate M C None 2 - -

Passive to Station Air 2-DC-44 */B Starting Air Cross-Connect 2" Cate M C None - -

Passive to Station Air 2-DG-45 */B Starting Air Cross-Connect 2* Cate M C None - -

Passive to Station Air ,

2-DC-46 */B Starting Air Cross-Connect 2\" Cate M C None - -

J Passive to Station Air 2-DC-47 */B Starting Air Cross-Connect 2\" Clobe M C None - -

Passive 2-DC-48 */5 Starting Air Cross-Connect 2\" Clobe M C None - -

i Passive 2-DC-54 */C Starting Air Tank Relief \" Re1 Self C SRY - -

2-DC-55 */C Starting Air Tank Relief "

Re1 Self C SRV - -

2-DC-56 */C Starting Air Tank Relief Re1 Self C SRV - -

2-DC-57 */C Starting Air Tank Relief Re1 Self C SRV - -

2-DC-86A */B Starting Air Isolation l\" Cate M LO None - -

j Passive 2-DC-86B */5 Starting Air Isolation 1\" Cate M LO None - -

Passive 2-DC-87A */B Starting Air Isolation 1" Cate M LO None - -

Passive 3

2-DC-878 */B Starting Air Isolation 1\" Cate M LO None - -

Passive 2-DC-88A */B Starting Air Bleed Isolation l\" Cate M LO None - -

Passive j 2-DC-885 */B Starting Air Bleed Isolation 1" Cote M LO None - -

Passive 2-DC-91A */B Air Start 1\" A0V AO C/ Fail Open Q/Ft V-3 Note 3 2-DC-918 */B Air Start l\" A0V A0 C/ Fall Open Q/Ft V-3 Note 3 2-DC-97A */B Air Start l\" AOV Ao C/ Fall Open Q/Ft V-3 Note 3 2-DC-92B */B Air Start l\" AOV A0 C/ Fall Open Q/Ft V-3 Note 3 (Nonende Class Valves.

Note 3: Stroke Test only. Verify Diesel Pects Tech. Spec. Start Limits.

i

4 Sheet b sf 0 TABLE TWV DIESEL AIR STARTINC SYSTEN (DASS)

Class / Valve Norsel Vilve Number Category Function Test Relief Test

Size Type Actuation Position Required Requested Alternate 2-DC-355 */C Charging Air Inlet ik" '

. Check -

C Q -

Check Valve -

4 1 2-DC-35C */C Charting Air Inlet ik" Check -

C Q =

Check Valve -

2-DC-35D */C Charging Air Inlet l\" Check -

C Q -

] Check Valve -

2-DG-93A */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-93B */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-94A */C Starting Air Actuation Bleed  %" 3-Way Self C Q - -

2-DC-948 */C Starting Air Actuation Bleed \" 3-Way Self C Q - -

2-DC-95A */B Air Start Solenoid \" SOV SO C/ Fail Open Q/Ft V-3 Note 3 2-DC-955 */B Air Start Solenoid \" SOV 50 C/ Fall Open Q/Ft V-3 4 Note 3 l 2-DC-96A */B Air Start Solenoid \" SOV SO C/ Fall Open Q/Ft V-3 Note 3 2-DC-96B */B Air Start Solenoid \" SOV So C/ Fall Open Q/Ft V-3 Note 3 i

l i

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i fNoncode Class Valves.

Note 3 - Stroke Test only - Verify Diesel Meets Tech. Spec. Start Limits.

I w

t

Sheet af TABLE IWV JACEFT C001.INC STSTM (JCS) class / Valve Normal Test Valve Ntaber Category Function Relief Test -

Size Type Actuation Position Required Requested Alternate 2- W 14A */C Check Valve 6" CK -

C '

Q - -

2- W l45 */C Check valve 6" CK -

C Q - -

2-DG-70A */(Note 1) Jacket Cooling Temperature 6" 3-Way System -

None - -

Control 2- W 705 */(Note 1) Jacket Cooling Temperature 6", 3-Way System -

None - -

Control 2- W 75A */B Turbo Charger Cooling 1" Cate M O None - -

Pasalve Isolation 2- W 75B */B Turbo Charger Cooling 1" Cate M O None - -

Passive Isolation 2-DC-76A */B Turbo Charger Cooling 1" Cate M O Mone - -

Passive Isolation 2-DC-76B */B Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation 2-DC-77A */8 Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation 2- W 77B */B Turbo Charger Cooling 1" Cate M 0 None - -

Passive Isolation Note 1: Control valves are creept from testing per paragraph IW1200 of the ASME Section II. BP&V. Code 1980 Edition including the Winter 1981 Addenda.

  • Noncode Class Valves.

Sheet [ cf TA31.E IW e

AIR C0f1 LING SYSTDE (ACS)

Claos/ Talve Normal Test Relief Test valv,Mumber

  • Cateaory Functice Size Type Actuation Position Required Requested Alternate 2-DC-3A */C Check Valve 4" CK - C Q s - -

2-DC-38 */C Check Valve 4" CE - C Q - -

2-DC-19A */C Check Valve lh" CK - C Q - -

2-DC-195 */C Check Valve l\" CK - C Q - -

2-DC-69A */(Note 1) Air Cooling Temperature 4"

  • 3-Way System - None - -

Control 2-DC-695 */(Note 1) Air Cooling Temperature 4" 3-Way System -

None - -

Control Note I: Control valves are exempt free testing per paragraph IWI24 of the ASME Section II, BP&Y. Code 1980 Edition, including the Winter 1981 Addenda.

  • Moncede class Talves.

O

.m. . _ _ _ _ _ ...._m... . _ - . . - _ . . _ _ _ _ . _ . . _ . . . _ . . ._ ________..__._..___.__,.._._-..m s _ _ _ _ . . . . _ . _ . __

i Sheet I cf . ,;

} TABLE YUV 1

l DIESEL 123E Olt SYSTDI (DLOS)

Class / Valve Normal Test Relief Test '

  • Valve N eber Cateacry Function Stre Type Actuation Position Required Roguested Alternate I

4 2-DC-51A */C Check Valve l\" CK -

C Q s - -

l j 2-DG-515 */C Check valve 1\" CE - C Q - -

1 2-DC-65 */C Safety Relief \" Bel -

C SRV - -

! 2-DG-66 */C Safety Zelief \" Re1 -

C SRV - -

2-DC-71A */(Wote 1) Labe 011 Temperature Control 4" ' 3-Way System -

None - -

2-DC-718 */(Wote 1) Lebe 011 Temperature Control 4" 3-Way System -

None - -

i i

1 Y

4 1

i i

1 I

i -

4 7

i .

.t i

4 t

i r

j Note 1: Control valves are esempt from testing per paragraph IWV1200, j of the ASME Section II, BP&V. Code 1980 Edition, including 1 the Winter 1981 Addenda.

1 1

  • Noncede Class Valves.

i i j

I o

1 I

Sheet 7 ef b '

TAPLF IW P FITI. 011. SYSTDt (FOS) .

Yalve Normal Test Relief Test Class / Required Requested Alternate valve Leber Catererv Function Stre Type Actuation Position 1" Cate M 0 None - -

2-F0-11 */B Fuel Oil Supply Tank Isolation Passive 1" Cate M 1.C None - -

2-FO-12 */B Fuel Oil Cross-Connect Passive Band Pump Discharge Check 1" CK - C Q 2-FO-13 */C Fuel Oil Check CK - C Q 2-FN14 */C l\"

1\" Cate M 0 None - -

2-FO-17 */B Fuel Oil Pump Iso?ation Passive Fuel Oil Supply Tank Cate M 0 None - -

2-FO-27 */B l\"

Passive Isolation Hand Pump Discharge Check 1" CK - C Q 2-FO-28 */C Fuel Oil Check 1" CK C Q

  • /C 2-FO-29 1\" Cat e M O None - -

2-FO-33 */B Fuel Oil Pump Isolation Passive 3/4" Cate M 0 None - -

2-FO-65A */B Clean Oil Storage Tank Passive Inlet Isolation 2-FO-65B */B Clean Oil Storage Tank 3/4" Cate M 0 None - -

Passive Inlet Isolation Clean 011 Storage Tank 3/4" Cate M O None - -

2-FO-65C */B Passive Inlet Isolation 3/4" Cate M O None - -

2-FO-65D */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" Cate M O None - -

2-TO-66A */B Clean Oil Storage Tank Passive Inlet Isolation Clean Oil Storage Tank 3/4" Cate M 0 None - -

2-FO-66B */B Passive Inlet Isolation 3/4" Cate M 0 None - -

2-FO-66C */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" Cate M O None - -

2-FO-66D */B Clean Oil Storage Tank Passive Inlet Isolation 3/4" CK - C Q V-1 Note 4 2-FO-67A */C Clean Oil Transfer Pump Discharge Check Clean Oil Transfer Purp 3/4" CK - C Q V-1 Note 4 2-FO-67B */C Discharge Check

  • Noncode Class Valves.

Sheet b cf b TABt.E TWV ,

FITL 011. SYSTFM (FOS) .

Class / falve Normal Test Relief Test -

Valv. Jumher Cateeory Function Size Type Actuation Position Required Requested Alternate 2-FO-t7C */C Clean 011 Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-67D */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-68A */B Clean Oil Transfer Purp 3/4" Cate M 0 None - -

Passive Discharge Isolation 2-FO-688 */B Clean Oil Transfer Pump 3/4" Cate M 0 None - -

Passive Discharge Isolation 2-FO-6AC */B Clean 011 Transfer Pump 3/4" Cate M o None - -

Passive Discharge Isolation 2-FO-68D */B Cleso 011 Transfer Pump 3/4" Cate M o None - -

Passive Discharge Isolation 2-FO-69 */B Clean Oil Cross-Connect 3/4" Cate M 0 None - -

Passive 2-FO-70 */B Clean Oil Cross-Connect 3/4" Cate M O None - -

Passive 2-FO-71 */C Fuel 011 Relief \" Re1 - C SRV - -

2-FO-72 */C Fuel Oil Relief \" Re1 - C SRV - -

2-FO-79 */B Fire Shutoff 1" Cate Thermally 0 Q V-2 Note 2 Fused 2-FO-80 */5 Fire Shutoff l\" Cate Thermally 0 Q V-2 Note 2 Fused 2-FO-84 */B Fuel 011 Cross-Connect 1" Cate M LC None - -

Passive 2-FO-85A */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85B */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85C */C Clean 011 Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check 2-FO-85D */C Clean Oil Transfer Pump 3/4" CK - C Q V-1 Note 4 Discharge Check Note 2: Stroke Test only, Verify Stroke Time 2 Secends.

Note 4: Disansemble and inspect one valve of each size and type, each refueling outage.

  • Woncode Class Valves.

Docket No. 50-336 Attachment No. 2 Millstone Nuclear Power Station, Unit No. 2 Inservice Testing of Emergency Diesel Generator Auxiliary System l

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ATTACHMENT 2 RESPONSE TO NRC CONCERNS EXPRESSED IN A MEETING WITH NORTHEAST UTILITIES REPRESENTATIVES JULY 23, 1986 ITEMS 1.A. 1.B.2, 1.C.1 COMMENT - The program's "IWP Pump Table" specifies Relief Request No. 1 (RR #1) for two items, lubrication and bearing temperature, however, RR #1 does not cover these items.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEMS 1.B.1, 1.C.2 COMMENT - The IWP Pump Table lists the flow resistance as " fixed,"

however, (temperature control valves) appear to provide variable hydraulic resistance. What is the basis for designating the system as fixed flow resistance?

RESPONSE - This information is no longer relevant to the program.

It has been deleted from the table. It's inclusion was based on earlier versions of the ASME Code which allowed variations in monitoring parameters for fixed resistance systems. The currently invoked ASME Code does not allow this distinction.

ITEM 1.C.3 COMMENT - What is the safety-related function of the EDG turbo-charger 2

, RESPONSE - The turbo-charger provides increased combustion air to the engine to facilitate cylinder cooling and scavenging. This increases the available power from the engine and improves efficien-cy. Though diesel engines are capable of operating without turbo-chargers, it is unlikely that this engine could develop full design power (as required by the Technical Specification) if the turbo-chargers were inoperable. As requested, a specific relief request has been submitted for these units.

t ITEM 1.C.4 COMMENT - Whct is the safety-related function of the electric motor-driven Jacket Coolant Pump P88A and P88B?

RESPONSE - These pumps have no safety-related function. They are provided to assist in maintaining engine temperatures to minimize temperature stresses during engine start. This minimizes the wear and tear on the engine during testing. The engine is capable of meeting all startup and operational requirements with this pump out of service.

Attachment 2.1 i

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ITEM 1.D COMMENT - The alternate testing proposed (for the Air Cooling Pamps) is to monitor DG engine air intercooler outlet air tempera-ture. The relief request (RR #2) has no direct measurements being made to directly assess component operability nor proposed action ranges. Provide your basis to show that the component operability testing being performed is demonstrating operational readiness of these pumps.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting..

ITEM 1.E COMMENT - Relief Request No. 3 lacks specificity regarding what paraments are to be monitored and action ranges to be taken.

Revise the relief request to provide specificity.

RESPONSE - Pump relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 1.F COMMENT - Describe any investigation and proposed modifications that are planned or have been made to improve that inservice component testing of these pumps.

RESPONSE - Evaluation of testing techniques and test data is ongoing. Procedures and techniques are being refined to better meet test objectives. No system modifications are planned. The testing required by Technical Specifications and the testing proposed herein is adequate to fully assure the required diesel generator reliability.

, ITEM 2. A. (1)

COMMENT - Check valves 2-FO-67A, B, C, D, and 2-FO-85A, B, C, and D are designated Category C and the relief request requested relief from all testing. This relief request does not provide alternate testing acceptable to the staff or a technical basis for not testing or providing suitable alternate testing of the valves. The staff normally does not grant the requested relief. The staff will consider alternate methods for determining the condition of each valve, for example, a sampling program of mechanical disassembly of like valves of the same type, size, and manufacturer. Provide your revised relief request showing a suitable alternative testing method.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

, Attachment 2.2

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ITEM 2.A.(2)

COMMENT - Check valves 2-FO-13 and 2-FO-28 are not listed in the program. Will failure of one of these valves result in a reduction of fuel oil flow to the diesel?

RESPONSE - Failure of these valves is not expected to result in a significant reduction of fuel oil flow because of the hand priming pump design. However, these valves have been added to the program listing to clarify their status.

ITEM 2.A.(3)

COMMENT - The relief request titled " Fuel Oil" appears to include valves from other systems as well.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.B. (1)

COMMENT - The legend for valves 2-DG-27A and 2-DG-27B does not clearly indicate that a limiting stroke time is required.

NOTE: The NRC staff has identified rapid-acting power-operated valves as those which stroke in two seconds or less. Relief from the trending requirements of Section XI (paragraph IWV-3410(C))

will be given for these valves since variations in stroke times will be affected by slight variations in the response times of the personnel performing the tests. However, the staff does require that the licensee assign a maximum limiting stroke time of two seconds,to these valves in order to obtain this code relief.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

1 ITEM 2.B. (2)

COMMENT - Why aren't valves 2-DG-29A, B, C, and D, and 2-DG-35A, B, C, and D classified as Category AC and subjected to periodic leak testing? A failure of a starting air tank could compromise the redundant tank's air supply if these valves leak.

RESPONSE - Article IWV-2200(A) identifies as Category A: " Valves for which seat leakage is limited to a specific maximum amount in the closed position of fulfillment of their function."

These valves do not have, nor need to have, a specific maximum leak limit. The valve is tested to verify it strokes properly (Catego-ry C test). In the event a starting air tank failed, low pressure alarms would immediately alert Operations personnel. Even if these

. valves failed to close and operators took no corrective action, only one diesel generator would be inoperative. Plant operation is allowed for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with one diesel generator inoperable. Thus, Attachmert 2.3

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while not a desirable situation, high levels of leakage (or total failure) of these valves does not unduly jeopardize safe operation of the plant. Designation of these valves as Category C is appro-priate.

ITEM 2.B.(3)

COMMENT - Relief is requested from stroke time measurements, however, the footnote does not provide a technical basis for the relief requested (reference NOTE above). There is no relief request basis provided.

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.B.(4)

COMMENT - The legend used does not clearly indicate that a limiting stroke time is required for the air start solenoid valves (reference NOTE above).

RESPONSE - Valve relief requests have been revised and upgraded to clarify this and other areas discussed at the meeting.

ITEM 2.C. (1) and 2.D COMMENT - What is the basis for not including relief valves 2-DG-67, 68, 63, 64, 81A, and 81B in the program?

RESPONSE - These low capacity thermal relief valves are not in-stalled for operating system protection. These valves are in piping normally vented to atmosphere. Their sole function is to provide temponent overpressure protection when the components are i isolated. Leakage through these valves would be detected (in the absence of operator action) by the expansion tank low level alarm, '

just as any other system leak would be. Since they are not rele-vant to the safe operation of the system, they were not included in the testing lists.

ITEM 2.E COMMENT - Your February 28, 1986 letter, Attachment 2 response stated that the air supply to the service water valves is not safety-related, however, the air operated service water valves are designed to fail in a position which will allow the safety-related system to fulfill its safety-related function. Note: Testing of the service water valves was not incorporated in your response.

Describe your inservice testing being performed on Service Water Valves FV6341, 6342, 6389, and 6397. Does this testing verify that the valves will fail in the position which will allow the safety-related system to fulfill its safety-related function? If not, what other testing verifies this?

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Attachment 2.4

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RESPONSE - These valves are included in the approved Inservice Inspection Program for Code Class 1, 2, and 3 Components for the Second Ten-Year Interval. They are stroke tested, timed, and failure mode tested each quarter This assures the valves fail in the position which will allow ths safety-related system to fulfill its function.

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