ML20154J007

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Forwards Addl Info Re Inservice Insp & Testing Program. Addition of Emergency Diesel Generator Auxiliary Sys Into Inservice Insp & Testing Program Will Be Implemented by 860430.Eight Oversize Drawings Encl
ML20154J007
Person / Time
Site: Millstone Dominion icon.png
Issue date: 02/28/1986
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Thadani A
Office of Nuclear Reactor Regulation
Shared Package
ML20154J011 List:
References
A05353, A5353, B12010, TAC-60876, NUDOCS 8603100433
Download: ML20154J007 (24)
v • d • e


Text

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HARTFORD. CONNECTICUT 06141-0270 k

L J [.Z ((.'"*C" (203) 66s-5000 February 28,1986 Docket No. 50-336 A05353 B12010 Office of Nuclear Reactor Regulation Attn:

Mr. Ashok C. Thadani, Director PWR Project Directorate #3 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 our December 31,1985 letter (I) Northeast Nuclear Energy Company (NNECO) advised the staff that NNECO would place the emergency diesel generator (EDG) auxiliary systems into the Millstone Unit No. 2 Inservice Testing Program.

Accordingly, NNECO hereby submits additional information pertaining to the Millstone nit No. 2 Inservice inspection and Testing Progrpm as submitted June 27, 1985(, August 30, 1985(3), and December 16,1935t41 Attachment No. I provides valve and pump listings and requests for relief which incorporate the EDG auxiliary systems into the Inservice Inspection and Testing Program. Three updated sets of plant boundary diagrams for the added systems have been included to assist your Staff in their review of this submittal.

NNECO plans to implement this addition to the Inservice Testing Program by April 0 1986 in accordance with relief granted by the Staff on October 31, 1985(5., Therefore, a response concerning Staff acceptability is requested as soon as possible, but no later than April 30,1986.

(1)

J. F. Opeka letter to A. C. Thadani, dated December 31, 1935.

(2)

3. F. Opeks letter to E. 3. Butcher, dated June 27, 1935, submitting the Millstone Unit No. 2 Inservice Inspection and Testing Program for the second ten-year inspection interval.

.k (3)

3. F. Opeka letter to E. J. Butcher, dated August 30,1985.

(4)

3. F. Opeka letter to A. C. Thadani, dated December 16,1985.

(5)

H. R. Denton letter to 3. F. Opeka, dated October 31, 35.

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. Pursuant to the requirement of 10CFR170.12(c), enclosed is the application fee of $150.00.

Additionally, NNECO offers comments on the supplemental safety evaluation provided by the Staff in their October 31, 1985(5) letter as provided in Attachment No. 2.

We trust you will find the enclosed information and comments satisfactory by April 30,1986.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

-/

/tk J. F. Opeke U

Senior Vice President

.1

Docket No. 50-336 Attachment No.1 Millstone Nuclear Power Station, Unit No. 2 Additional Information concerning the Inservice Inspection and Testing Program l

February,1986

Relief Request In-Service Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED VALVES: 2-FO-67A; 67B; 67C; 67D and 2-FO-85A; 85B; 85C; 85D.

CATEGORY: C CLASS: Noncode Class Valves TEST REQUIREMENT: Article IWV-3521 - Check valves shall be exercised at least once every three months. Article IWV-3522(b) - Valves that are normally closed during plant operation and whose function is to open, shall be tested by proving that the disk moves promptly away from the seat when flow through the valve is initiated.

RELIEF REQUESTED: Relief from all testing is requested.

BASIS FOR RELIEF: There is no instrumentation on the piping or associated pumps and tanks. Thus, there is no way to verify that the valves open on demand.

ALTERNATE TESTING: The clean oil system will be monitored during diesel engine operation to assure satisfactory performance.

/

Relief Request In-Service Test Program (IWV)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil AFFECTED VALVES:

2-FO-79; 80, 2-DG-91A; 91B; 92A, 92B, 27A; 27B; 95A;

/

95B and 96A; 96B.

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 10 seconds or less, or 10 percent of the specified limiting stroke time for full stroke times longer than 10 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 stroke times less than 0.5 seconds.

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.

In addition, diesel engine starts will be monitored to assure the engine starts within designated time limits.

s

Relief Request #1 In-Service Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Fuel Oil, Lube Oil and Jacket Water Cooling AFFECTED PUMPS: Diesel Engine Fuel Oil Pumps Lube Oil Pumps Jacket Water Cooling 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 recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity.

RELIEF REQUESTED: Relief is requested from the requirement to establish reference values of flow and differential pressure. Relief is requested from the requirement to measure and record flow and differential pressure readings. Relief is requested from the requirement to measure inlet pressure.

BASIS FOR RELIEF: These pumps are engine-driven. There is no instru-mentation installed on the diesel engine which will provide this information.

All bearings are internal to the engine and are lubricated by the engine lubrication system. No individual monitoring is possible.

ALTERNATE TESTING: Measure pump discharge pressure while the diesel engine has been running at an essentially constant, procedurally specified load for at least fif teen minutes. Compare these values to reference pump discharge pressure values obtained under the same conditions.

Relief Request #2 In-Service Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Diesel Engine Air Cooling AFFECTED PUMPS: Diesel Engine Air Cooling 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 recorded as directed in this subsection. Each measured test quantity shall then be compared with the reference value of the same quantity.

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. The unit is engine driven. All bearings are internal to the engine and are lubricated by the engine lubrication system. No individual monitoring is possible.

ALTERNATE TESTING: The diesel engine air intercooler outlet temperature will be monitored to verify that the air cooling system is operatinc properly.

Relief Request #3 In-Service Test Program (IWP)

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Diesel Engine Clean Oil AFFECTED PUMPS: Diesel Engine Clean Oil Pumps TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied until either the measured differential pressure of 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.

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. The units have no accessible bearings. The unit is mounted on the diesel engine structure.

No meaningful vibration readings can be taken. There is no separate lubrication supply to the unit.

ALTERNATE TESTING: The clean oil system will be monitored during diesel engine operation to &Jsure satisfactory performance.

m

Relief Request #4 In-Service Test Program (IWP)

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

RELIEF REQUESTED: No vibration measurements will be taken.

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.

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

Vibration measurements will be taken on the diesel engine during in-service tests.

1 0

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FLTL CIT. STSTEM (TOS)

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Velve Normal Tast Relisf Txt valve Number Caterory Function Sire Type Actuation Pasition Required Requested Alternate 2-FO-11

  • /B Fuel Oil Supply Tank Isolation 1\\"

Cate M

0 None Passive 2-FO-12

  • /B F.ael Oil Cross-Connect 1\\*

Gate M

LC None Passive 2-FO-14

  • /C Fuel Oil Check

!\\"

CK C

Q 2-FO-17

  • /B Fuel Oil Pump Isolation 15" Gate M

0 None Passive 2-FO-27

  • /3 Fuel Oil Supply Tank 1\\"

Gate M

0 None Passive Isolation 2-FO-29

  • /C Fuel 011 Check 1\\"

CK

. C Q

2-FO-33

  • /8 Fuel Oil Pump Isolation 1\\*

Gate M

0 None Passive 2-FO-65A

  • /3 Clean Oil Storage Tank 3/4" Cate

-M O

None Passive Inlet Isolation 2-FO-658

  • /B Clean Oil Storage Tank 3/4" Cate M

0 None Passive Inlet Isolation 2-FO-65C

  • /B Clean Oil Storage Tank 3/4" Cate M

0 None Passive Inlet Isolation 2-FO-653

  • /B Clean Oil Storage Tank 3/4" 3 ate M

O None Passive Inlet Isolation 2-FO-66A

  • /B Clema Oil Storage Tank 3/4" Gate M

0 None Passive Inlet Isolation 2-FO-603

  • /3 Clean Oil Storage Tank 3/4" Cate M

0 None Passive Inlet Isolation 2-FO-6ec

  • /B Clean Oil Storage Tank 3/4" Cate M

0 None Passive Inlet Isolation 2-IV-66D

  • /B Cleaa Oil Storage Tank 3/4" Cate M

0 None Passive Inlet Isolation 2-FO-67A

  • /C Cleam oil Transfer Pump 3/4" CK C

Q Discharge Check 2-FO-678

  • /C Clean Oil Transfer Pump 3/4" CK C

Q Eischarge Check

  • Noncode Class Valves.

l FUEL CIL SYSTEM (FOS)

C1cas/

Vs1va N2rmal Tazt R211sf T.,gt valve Number Category Function Sire Type Actuation Position Required Requested Alternate

  • 2-FO-67C
  • /C Clean Oil Transfer Pump 3/4" CK C

Q X

Discharge Check 2-FO-67D

  • /C Clean Oil Transfer Pump 3/4" CK C

Q X

Discharge Check 2-FO-68A

  • /B Clean Oil Transfer Pump 3/4" Cate M

0 None Passtve Discharge Isolation 2-FO-68B

  • /B Clean Oil Transfer Pump 3/4" Cate M

0 None Passive Discharge Isolation 2-FO-68C

  • /5 Clean Oil Transfer Pump 3/4" Cate M

0 None Passive Discharge Isolation 2-FO-683

  • /B Clean 011 Transfer Pump 3/4" Cste tt 0

None Passave 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

0 Non-Passive 2-FO-71

  • /C Fuel Oil Relief 5"

Re1 C

SRV 2-FO-72

  • /C Fuel 011 Relief

\\"

Re1 C

SRV 2-FO-79

  • /B Fire Shutoff 1\\"

Cate Thermally 0

Q K

Note 2 Fused 2-FO-80

  • /B Fire Shutoff 1\\"

Cate Thermally 0

Q X

Note 2 Fused 2-Fu-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 X

Discharge Check l

2-FO-853

  • /C Clean 011 Transfer Pump 3/4" CK C

Q X

Discharge Check 2-FO-85C

  • /C Clean 011 Transfer Pump 3/4" CK C

Q X

Discharge Check 2-FO-85D

  • /C Clean Oil Transfer Pump 3/4" CK C

Q X

Discharge Check Note 2: Stroke Test only, No Stroke Time Measurement.

  • Noncode Class Valves.

1 l

y______

DIESEL AIR STARTING SYSTEM (DASS)

Clas:/

Valva Normal Txt Relitf Trt Valve Number Cittfory Function Sirt Type Actuation P wition Requircd Riquert'd Alternate 2-DG-27A

  • /3 Air Bleed Cutoff IS" SOV SO 0/ Fail Closed Q/Ft 2-W 27B
  • /B Air Bleed Cutoff 1\\"

SOV SO 0/ Fail closed Q/Ft 2-DG-29A

  • /C Check 2"

CK-C Q

2-DG-29B

  • /C Check 2"

CC C

Q 2-DG-29C

  • /C Check 2"

CK C

Q 2-DG-29D

  • /C Check 2"

CK C

Q 2-DG-30A

  • /B Starting Air Isolation 1\\"

Clobe M

0 None Passive 2-DG-305

  • /B Starting Air Isolation 1\\"

Globe M

0 None Passive 2-DG-30C

  • /B Starting Air Isolation IS" Globe M

0 None Passive 2-DG-30D

  • /B Starting Air Isolation 1\\"

Globe M

0 None Passive 2-DG-31A

  • /3 Starting Air Tank Isolation 2"

Clobe M

0 None Passive 2-DG-31B

  • /B Starting Air Tank Isolation 2"

Globe M

0 None Passive 2-DG-31C

  • /B Starting Air Tank Isolation 2"

Globe M

0 None Passive 2-DG-31D

  • /B Starting Air Tank Isolation 2*

Globe M

0 None Passive 2-DG-32A

None Removed None 2-DG-32B

None None Removed 2-DG-32C

None Removed None 2-DG-32D

None None Removed 2-DG-35A

  • /C Charging Air Inlet IS" Check C

Q Check Valve

  • Noncode Class Valves.

DIESEL AIR STARTING SYSTEM (DASS)

C1 css /

Valv2 Nzrmal Test R211sf Tmt VnIve Number Crtecory Tunction Size Tvpe Actuatio9 Position Required Requested Alternate.

2-DG-43

  • /B Starting Air Cross-Connect 25" Gate M

C None Passive to Station Air 2-DG-44

  • /B Starting Air Cross-Connect 25" Cate M

C None Passive to Station Air 2-DG-45

  • /B Starting Air Cross-Connect 25" Gate M

C None Passive to Station Air 2-DG-46

  • /B Starting Air Cross-Connect 24" Cate M

C None Passive to Station Air 2-DG-47

  • /B Starting Air Cross-Connect 25" Globe M

C None Passive 1

2-DG-45

  • /B Starting Air Cross-Connect 25" Globe M

C None Passive

)

2-DG-54

  • /C Starting Air Tank Relief 5"

Re1 Self C

SRV 2-DG-55

  • /C Starting Air Tank Relief 5"

Re1 Self C

SRV 2-DG-56

  • /C Starting Air Tank Relief 5"

Re1 Self C

SRV 2-DG-57

  • /C Starting Air Tank Relief 5"

Rel Self C

SRV

(

2-DG-86A

  • /B Starting Air Isolation 1\\"

Cate M

ID None Passive 2-W 86B

  • /3 Starting Air Isolation 15" Cate M

10 None e

Passive 2-DG-87A

  • /B Starting Air Isolation' 15" Cate M

10

"-e Passive 2-DG-87B

  • /B Starting Air Isolation 1\\"

Gate H

10 None Passive 2-DG-SSA

  • /3 Sorting Air Bleed Isolation 15" Cate M

10 None Passive l

2-DG-8&B

  • /B Starting Air Bleed Isolation 15" Cate M

10 None Passive 2-DG-91A

  • /B Air Start 1\\"

AOV A0 C/ Fail Open Q/Ft X

Note 2 2-DG-91B

  • /8 Air Start 15" ADV AD C/ Fail Open Q/Ft X

Note 2 j

2-DG-92A

  • /B Air Start ik" ADV AO C/ Fail Open Q/Ft X

Note 2 2-DG-92B

  • /B Air Start 1\\"

ADV AO C/ Fail Open Q/Ft X

Note 2

  • Noncode Class Valves.

Eote 2: Strokt Test Only. No Stroke Time Measurement.

r DIESEL AIR fTARTING SYSTDI (DASS)

Class /

V:1ve Normal T=t Relirf Test valve Number Cat tory Function Sizi Type Actuation Pmition Required Requested Alternate.

2-DG-35B

  • /C Charging Air Inlet 1("

Check C

Q Check Valve 2-DG-35C

  • /C Charging Air Inlet 1(*

Check Check Valve C

Q 2-DG-35D

  • /C Charging Air Inlet 1("

Check C

Q Check Valve 2-DG-93A

  • /C Starting Air Actuation Bleed

\\"

3-Way Self C

Q 2-DG-938

  • /C Starting Air Actuation Bleed k"

3-Way Self C

Q 2-DG-94A

  • /C Starting Air Actuation Bleed k"

3-Way Self C

Q 2-DG-9J.B

  • /C Starting Air Actuation Bleed k"

3-Way Self C

Q 2-DG-95A

  • /B Air Start Solenoid k"

SOV So C/ Fail C en Q/Ft P

2-DG-95B

  • /B Air Start Solenoid

(*

SOV SO C/ Fail Open Q/ft 2-CG-96A

  • /B Air Start Solenoid

\\"

SOV SO C/ Fail Open Q/Ft 2-DG-963

  • /B Air Start Solenoid k"

S07 S0 C/ Fail Open Q/Ft i

i 1

I i

  • 5oncode Class Valves.

l i

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DIESEL LUBE CIL SYidM (DL ]OS C1ces/

Valva Normal Taet Reli f Tzt V*In Number citerary Function Size Type Actuation Position Required Requested Alternate 2-DG-51A

CK C

Q 2-DG-513

CK C

Q 2-DG-65

  • /C Safety Relief Re1 C

SRV 2-DC-66

  • /C Safety Relief Re1 C

SRV 2-DG-71A

  • /(Note 1) Lube Oil Temperature Control 4"

3-Way System None 2-DG-718

  • /(Mote 1) Lube Oil Temperature Control 4*

3-Way System None Note 1: Control valves are except f rom testing per paragraph IW1200, et the ASl2 Section II, BP&V. Code 1980 Edition, including the Winter 1981 Addenda.

  • 5cacode Class Valves.

r --

ATR COOLING SYSTEM (ACS)

Clacc/

Valys Normal Tast Relief Test Valve Number Caterary Tunction Size Type Actuation Position Required Requested Alternate 2-DG-3A

CK C

Q 2-DG-3B

CK C

Q 2-DG-19A

Q 2-DG-198

CK C

Q 2-DG-69A

  • /(Note 1) Air Cooling Temperature 4"

3-Way System None Control 2-DG-698

  • /(Note 1) Air Cooling Temperature 4"

3-Way System None Control Note 1:

Control valves are exempt from testing per paragraph IW1200, of the-ASS Section XI, BP&V. Code 1980 Edition, including the Winter 1981 Addenda.

  • Noncode Class Valves.

r JACKET CLOLING SYSTDt UCS)

Cices/

Valva Normal Tast Raliaf V-Ive Number Crtsriry Function Size Type Actuation Position Required Requested Alternate *-

  • est 2-DG-14A

CE C

Q 2-DG-14B

CK C

Q 2-DG-70A

  • /(Note 1) Jacket Cooling Tearperature 6"

3-Way System None Control 2-DG-708

  • /(Note 1) Jacket Cooling Temperature 6"

3-Way System None Control 2-DG-75A

  • /B Turbo Charger Cooling 1*

Gate M

O None Passive Isolation 2-DG-753

  • /B Turbo Charger Cooling 1"

Cate M

O None Passive Isolation 2-DC-76A

  • /B Turbo Charger Cooling 1"

Cate 11 0

None Passive Isolation 2-DG-76B

  • /B Turbo Charger Cooling 1"

Cate

-M 0

None Passive Isolation 7-DG-77A

  • /B Turbo Charger Cooling 1"

Cate M

O None Passive Isolation 2-DG-775

  • /B Turbo Charger Cooling 1"

Cate M

0 None Passive Isolation Note 1:

Control valves are exempt from testing per paragraph IW1200, of the ASS.Section II, BP&V. Code 1980 Edition, including

_ the Winter 1981 Addenda.

  • Noacode Class Valves.

IEP PDfP TABLR Flow Speed Inlet Differential Bearing Pump Resistance Control Pressure Pressure Flow Vibration Lubrication Temperature Frequency Fuel Oil System Iuel 011 Pump A Fixed Variable

  • RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Fuel 011 Purp B Fixed Variable
  • RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Lebe Oil System L.SA Lube Oil Pump Fixed Variable
  • RRf1 RRf1 RRf1 RRf4 ERf1 RRf1 Quarterly P45 Lube Oil Puzy Fixed Variable
  • RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Jecket Cooling kater System P 9A Cooling Pump Fixed Variable
  • RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly F495 Cooling Pump Fixed Variable
  • RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Air Cooling System P127A Air Cooler Coolant Pump Fixed Variable
  • RRf2 RRf2 RRf2 RRf6 RRf2 RRf2 Quarterly P127B Air Cooler Coolant Pump Fixed Variable
  • ERf2 RRf2 RRf2 RRf4 RRf2 RRf2 Quarterly Clean Oil System P1:SA - Clean ott Pump Fixed Fixed RRf3 RRf3 RRf3 RRf3 RRf3 RRf3 Quarterly P12SB - Clean Oil Pump Fixed Fixed ERf3 RRf3 RRf3 RRf3 RRf3 RRf3 Quarterly P12SC - Clean Oil Pump Fixed Fixed Raf3 RRf3 RRf3 RRf3 RRf3 RRf3 Quarterly F1283 - Clean oil Pump Fixed Fixed ERf3 ERf3 RRf3 RRf3 RRf3 RRf3 Quarterly
  • Varies with engine speed.

RRfz = Relief Requested. (x = Relief Request No.)

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c- -

l LEGEND FOR VALVE TESTING Exercise valve full stroke for operability every three (3)

Q months.

If applicable, take stroke time measurements and compare to the stroke time limiting value per Section XI, Article IWV-3410.

Exercise valve part stroke for operability every three (3)

QP months.

Exercise valve full stroke for operability during cold shutdowns.

QCS If applicable, take stroke time measurements and compare to the stroke time limiting value per Section XI, Article IWV-3410.

Exercise valve part stroke for operability during cold shutdowns.

QPCS l

Exercise valve full stroke for operability during refueling.

QR If applicable, take stroke time measurements and compare to the i

l stroke time limiting value per Section XI, Article IWV-3410.

f I

l j,

QPR Exercise valve part stroke for operability during refueling.

Visually observe, at least once every two years, actual valve P1 position to confirm that remote valve position indications i

I accurately reficct valve operation.

lL

~

Remove actuator power f rom valves with fail-safe actuators to FT confirm that the valve travels to its fail-safe position every three (3) months.

Leak test valve per Section XI, Article IWV-3420, or applicable LT relief request.

Leak test valve in conformance with the criteria specified in LLRT Appendix J of 10CFR50.

I Test safety and relief valves per Section XI, Article IWV-3510.

SRV Remove actuator power from valves with fail-safe actuators to FTCS confirm that the valve travels to its fail-safe position during cold shutdowns.

Docket No. 50-336 Attachtnent No. 2 Millstone Nuclear Power Station, Unit No. 2 Comments on October 31,1985 Supplemental Safety Evaluation February,1986 u.

NRC Comment:

The system testing being done by the licensee did not measure stroke time. The following valves should be exercised / timed to the requirements of IWV-3410.

FV 6341 (2-SW-231 A)

FV 6342 (2-SW-231B)

FV 6389 (2-SW-39A)

FY 6397 (2-SW-39B)

Resolution:

These valves have been included in the service water valve section of the second 10-year Inservice Inspection and Testing Program. Valves 2-SW-39(A&B) were included in the first 10-year Inservice Inspection and Testing Program.

NRC Comment:

The following relief valves were not being testing. These valves should be tested to meet IWV-3510.

PSV 7016 (2-FO-71)

PSV 7017 (2-FO-72)

PSV 8952 (2-DG-54)

PSV 3953 (2-DG-55)

PSV 3997 (2-DG-65)

PSV 3973 (2-DG-66)

PSV 3743 (2-DG-31 A)

PSV 3744 (2-DG-31B)

Resolution:

All of the above valves except 2-DG-31(A&B) are included in the enclosed submittal. In addition, valves 2-DG-56 and 2-DG-57 are also included in the submittal. Valves 2-DG-31(A&B) are thermal reliefs, not system relief valves.

These valves are not installed as operating system protection.

Their only function is to protect the piping during the time it is isolated from the expansion tank, thus these valves are not required to be tested.

NRC Comment:

The following check valves were not being testing for seat leakage. The valves should be tested to meet IWV-3420.

2-FO-14 2-FO-35C 2-FO-35 D 2-FO-67A 2-FO-67B 2-FO-29 2-FO-67C 2-FO-67 D 2-FO-35A 2-FO-35B 2-DG-29A 2-DG-29B 2-DG-29C 2-DG-29D 2-DG-35A 2-DG-35B 2-DG-35C 2-DG-35 D Resolution:

Seal Leakage testing is not required for any of these valves. The ASME boiler and pressure vessel code, Section 11, Article IWV-2200(a) states:

i

" Category A - Valves for which seat leakage is limitted to a specific maximum amount in the closed position for fulfillment of their function."

None of the listed valves are required to limit leakage to a specific amount to fulfill their function. Their function is to prevent gross backflow during off-normal conditions. These valves are included in the test program as Category B and Category C valves and will be tested as such.

l

NRC Comment:

The following thermally fusable valves were not being exercised. The valves should be exercised per IWV-3410.

2-FO-79 2-FO-80 Resolution:

These valves are included in the enclosed submittal. Relief is requested from measurement of stroke time since the closing time is less than 0.5 seconds.

NRC Comment:

Valve FO-70 should be position verified per IWV-3300.

Resolution:

Article IWV-3300 is not applicable to this manually operated gate valve. Article IWV-3300 states:

" Valves with remote position indicators shall be observed at least once every 2 years to verify that valve operation is accurately indicated."

The valve is included in the submittal but no testing is required.

NRC Comment:

The Staff further concludes that the (air supply to EDG service water valves) should be included in the IST program.

Resolution:

The air supply to the service water valves is not a safety-related system and is not included in the test program. All air operated valves are designed to fall to a position which will allow the safety related system to fulfill its safety related function.

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