ML20199D776

Requests Assistance in Conducting Review of Encl Util 860228 Submittal Re Placement of safety-related Emergency Diesel Generator Auxiliary Sys Under Inservice Testing Program.Srp & STS Should Be Used in Determining Acceptance Criteria

ML20199D776
Person / Time
Site:	Millstone
Issue date:	03/17/1986
From:	Thadani A Office of Nuclear Reactor Regulation
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
TAC-60876, NUDOCS 8603240349
Download: ML20199D776 (2)

Text

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, . .Y Docket No. 50-336 March 17,1986

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MEMORANDUM FOR: Richard W. Starostecki, Director Division of Reactor Projects Region I FROM: Ashok C. Thadant, Director PWR Project Directorate #8 Division of PWR Licensing-B Office of Nuclear Reactor Regulation

SUBJECT:

REQUEST FOR REGIONAL REVIEW - MILLSTONE 2 Your assistance is requested in conducting a review of the enclosed submittal from Northeast Utilities dated February 28, 1986. The product expected as a result of your review is a completed safety evaluation. 'Your reviewer should use.the Standard Review Plan (SRP) and the Standard Technical Specifications (STS) as guidance in determining acceptance criteria, recognizing, of course that, for operating reactors, the criteria in these documents are not require-

.ments.

In accordance with NRR Office Letter No. 44, each safety evaluation performed by a technical division shall have'a separate SALP input provided. For purposes of these reviews, the Regional personnel involved are considered part of the technical divisions. . Therefore, we are requesting that your forwarding memo .

randum contain a SALP input for each safety evaluation performed. TAC number 60876 has'been opened for your use.

This submittal from Northeast Utilities was in response to our October 31, 1985 request that the safety-related EDG auxiliary systems be placed under the in-service testing program. The Safety. Evaluation enclosed with our October 31, 1985 request granted relief from ASME Section XI, Subsections IWP and IWV for the testing of safety-related EDG auxiliary systems until April 30, 1986. As

. discussed with Don Caphton, who was the reviewer, a Safety Evaluation completion date of April 15, 1986 for this current submittal may not be possible.

. Subsequent discussions with Don Haverkamp indicate that an interim approval is possible by April 15, 1986 with final approval provided later. We request that the final approval be provided by August 1, 1986 to coincide with the completion of the. review of the second 10 year in-service testing program.

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Please notify me as soon as possible if these corpletion dates are acceptable to you. Any contact with the licensee on this review effort or any additional information deemed necessary should be obtained thrcugh the NRR project manager.

The project manager for this plant is D. B. Osborne and he can be reached at 492-8186 (FTS).

/s/

Ashok C. Thadani, Director PWR Project Directorate *8 Division of PWR Licensing-B Office of Nuclear Reactor Regulation

Enclosure:

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P O BOX 270 HARTFORD. CONNECTICUT 06141-0270 L L J Z. .C.C. (203) 665-5000 February 28,1986 Docket No. 50-336 A05353 B12010 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director PWR Project Directorate #8 Division of PWR Licensing - B U. S. Nuclear Regulatory Commission Washington, D. C. 20535 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 Progrgm as submitted June 27, 1985(2 , August 30, 1985(3), and December 16, 1985N1 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 30,1986 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 31,1985.

(2) 3. F. Opeka letter to E. J. Butcher, dated June 27, 1985, submitting the Millstone Unit No. 2 Inservice Inspection and Testing Program for the second ten-year inspection interval. .

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

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

(5) 5.

H. R. Denton letter to 3. F. Opeka,jated October 31,1

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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, 1983(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 NUCI. EAR ENERGY COMPANY '

3. F. Opeka hbk U Senior Vice President O

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Docket No.30-336 Attachment No.1 Millstone Nuclear Power Station, Unit No. 2 Additional Information concerning the Inservice Inspection and Testing Program 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 thrcugh the valve is initiated.

RELIEF REQUESTED: Relief from all testing is requested.

RASIS 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.

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t 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.

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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 fifteen minutes. Compare these values to reference pump discharge pressure values obtained under the same conditions. e 4

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

Emergency Diesel Generator Auxiliary Systems Millstone Unit 2 SYSTEM: Diesel Engine Air Cooling 1

1 AFFECTED PUMPS: Diesel Engine Air Cooling Pumps

_ TEST REQUIREMENT: Article IWP-3100, the resistance of the system shall be varied unti .. either the measured differential pressure or the measured flow rate equtis 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 teorerature will be monitored to verify that the air cooling system is operating properly, t

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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 assure satisfactory performance.

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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.

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FUEL OTL SYSTEM (Fos)

Class / Valve Normal Test valve Wimmber Cateaory Function Stae Type Belief Test Actuation Position Required Bequested Alternate 2-FO-11 */B Fuel Oil Supply Tank Isolation 1\" Cate M 0 None - --

Passive 2-FO-12 */3 Fuel 011 Cross-Connect 1b" Cate M LC None - -

Passive 2-FO-14 */C Fuel Oil Check 3%" CK -

C Q - -

2-FO-17 */B Fuel 011 Pump Isolation 1%" Cote M 0 None - -

Passive 2-FO-27 */B Fuel Oil SupP ly Tank I* Cate M 0 None - .

Passive Isolation 2-FO-29 */C Fuel 011 Check 1)" CK -

. C Q - -

2-FO-33 */B Fuel Oil Pump Isolation 1\" Cate M 0 None - -

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

Passive Inlet Isolation 2-FO-658 */B Clema 011 Storage Tank 3/4" Cate M 0 None - -

Passive Inlet Isolatten 2-FO-65C */3 Clean Oil Storage Tank 3/4" Cate M 0 None - -

Passive talet Isolation 2-FO-65D */3 Clean Oil Storage Tank 3/4" Cete M o None - -

Passive talet Isolation 2-FO-66A */3 Clese Oil Storage Tank 3/4" cate M 0 None - -

Passive Inlet Isolation 2-FO-66B */B Clean 011 Storage Tank 3/4" Cate M 0 Nooe - -

Passive Inlet Isolation 2-FO-64C */B Clema Oil Storage Tank 3/4" Cate M 0 None - -

Passive Inlet Isolation 2-FO-66D */3 Cless 011 Storage Tsak 3/4" Cate M 0 None - -

Passive Inlet Isolation 2-FO-67A */C Clema 011 Transfer Pump 3/4" CK -

C Q X -

Discharge Check 2-FO-678 ' */C Cleas 011 Transfer Pump 3/4" CK - C Q X -

Discharge Check

• Noacede Class Velves.

FUEL OIL SYSTEM (TOS)

Class / Valve valve Numt er Normal Test Relief Catenary Function Size Type Actuation Position Required Test Requested Alternate 2-FO-67C */C Clema 011 Transfer Pump 3/4" CK -

C Q X Discharge Check -

2-FO-67D */C Clema 6.! Transfer Pump 3/4" CK -

C Q X Discharge Ched .

2-FO-68A */B Clean 011 Transfer Pump 3/4" Gate .M 0 None Passtwe Discharge Isolatton 2-FO-688 */5 Clean 011 Transfer Pump 3/4" Cate Passive M 0 .None - -

Discharge Isolation 2-FO-68C */B Clean 011 Transfer Pump 3/4" Cate M 0 Passive Discharge Isolation None - -

2-FO-68D */B Cleas 011 Tressfer Pump 3/4" Cate M 0 Paestre Discharge Isolation None -

2-FO-69 */5 Cless 011 Cross-Connect 3/4" Cate M 0 Mone Passive -

2-FO-70 */B Clema 011 Cross-Connect 3/4* Cate M 0 None Passive - -

2-FO-71 */C Tuel 011 Relief 5" Re1 -

C SRV - -

2-F0-72 */C Fuel Oil Relief \" Re1 -

C SRV - -

2-FO-79 */5 Fire Shutoff t l\" Cate Thermally 0 Q X Note 2 Fused 2-F0-80 */B Fire Shutoff l\" Cate Therme11y 0 Q X Note 2 Fused 2-FO-84 */B Fuel 011 Cross-Cenmect l\" Cate M 1.C None Passive - -

2-FO-85A */C Clema 011 Transfer Pump 3/4" CK -

C Discharge Check Q X -

2-FO-855 */C Cleaa 011 Transfer Pump 3/4" CK -

C Q X Discharge Check -

2-FO-85C */C Clese 011 Transfer Pump 3/4" CE -

C Discharge Check Q X -

2-FO-85D

~

• /C Cleen 011 Transfer Pump 3/4" CK -

C Q X Discharge Check -

Note 2: Stroke Test Daly, No Stroke Time Measurement,

• Noacode Class Valves.

DIESEL AIR STARTING SYSTEM (DASS)

~ . Class / Valve Valve Number Catenery Function Normal Test Relief Test Size Type Actuation Posities Required .

Requested Alte rnate 2-DG-274 */3 Air Bleed Cutoff 15" SOV. SO 0/ Fall Closed Q/Ft - -

2-DG-278 */B Air Bleed Cutoff 15" SOV SO 0/ Fail Closed Q/Ft - -

2-DG-29A */C Check 2" CK' -

C Q - -

2-DG-298 */C Check 2" Cf -

C Q - -

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

C Q - -

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

C Q - -

6 2-DG-30A */S Starting Air Isolation . T5* Globe M 0 Passive None - -

2-DG-305 */3 Starting Air Isolation l\" Clebe Passive M 0 None - -

2-DG-30C */5 Starting Air Isolation Passive 15" Globe M 0 None - -

2-DG-3cD */S Starting Air Isolation Passive th" Globe 19 0 None - -

2-DG-31A */5 Starting Air Tank Isolation 2" Clobe Passive M 0 None - -

2-DG-315 */B Startleg Air Tank Isolation ..

Passive 2" Clobe M 0 None - -

2-DG-31C */5 Starting Air Task Isolation 2" Clobe Passive M 0 Nome - -

2-DG-31D */S Starting Air Tank Isolation 2" Globe M 0 Passive None - -

2-DG-324 */C Check Valves - Internals 2" Nome - -

Removed None - -

2-DG-323 */C Check Valve - Internals 2" Nome - -

Removed None - -

2-DG-32C */C Check Valve - Internata 2* None - -

itemoved None - -

e 2-DG-32D */C Check Valve - Jeteraala 2" None - -

Removed None - -

2-DG-35A */C Charging Air Inlet '

ll" Check -

C Check Valve Q -- -

• Noncode Class Valves.

• DIESEL AIR STARTING SYSTEM (DASS)

Class / Valve Normal valve Number Catenary Function Test- Relief Test size Type Actuation Position Required Requested Alternate 2-DG-43 */5 Starting Air Cross-Comaect 2\" Cate M C Wome = =

Passive to Station Air 2-DG-44 */3 Starting Air Cross-Connect 25" Cate M C None -

Passive to Station Air 2-DG-45 */B Starting Air Cross-Connect 25" Cate M C e

Passive None - -

to Station Air 2-DG-46 */5 Starting Air Cross-Connect 2%" Cate M C None - -

Passive to Station Air 2-DG-47 */3 Starting Air Cross-Cocoect 25" Globe M C None - -

Passive .

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2-DG-48 */3 Starting Air Cross-Comaect 2\" Globe M C Nome Passive .- -

2-DG-54 */C Starting Air Tank Relief 5" Re1 Self C SRV - -

2-DG-55 */C Starting Air Tank Relief \" ^ Rel Self C SRV - -

2-DG-56 */C Starting Air Tank Relief \" Re1 Self C SRV - -

2-DG-57 */C Starting Air Tank Relief Re1 t

\" Self C SRV - -

2-DG-86A */5 Starttag Air Isolation 1\" Cate M LO * .

Passive Esse - '-

2-DG-863 */3 Starting Air Isolation l\" Cate M la y, . ,

Passive 2-DG-87A */B Starting Air Isolation' 15" Cate H 10 None - -

• Passive 2-DG-873 */B Startlag Air Isolation li" Cate M. 10 Nome '- -

Passive 2-DG-88A */3 Starting Air Sleed Isolation 15" Cate M 1.0 Nome - -

h' Passive 2-DG-885 */B Starting Air Bleed Isolation 1\" Cate M I,0 Nome - -

Passive 2-DG-91A 4/B Air Start '1\" A0V AO C/ Fall Open Q/Ft X Note 2 2-DG-913 */4 Air Start 15" AOV AO C/ Fail opea X

{ Q/Tt Note 2 h 2-DG-92A */B Air Start li" AOV AO C/ Fail Opea Q/tt X Note 2 2-DG-925 */3 Air Start 1\" A0V AO C/ Fall Opea Q/Ft . X Note 2

• Noncode Class Valves.

Note 2: Stroke Test Daly. No Stroke Time Measurement.

BTESEl, AIR STARTING SYSTEM (DASS)

Class / Valve Catemory Tunction Normal Test Relief Test *

. Valve Number Stae Type- Actuatise Position Required Requested Alternate 2-DG-353 */C Charging Air Inlet ik" Check -

C Check Valve Q - -

2-DG-35C */C Charging Air Inlet ik" Check -

C Q Check Valve - -

2-DG-35D */C Charging Air Inlet ik" Check -

C Q Ct.eck Valve - -

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

2-DG-945 */C Starting Air Actuation Bleed k" 3-Way Self C Q - -

2-DG-95A */B Air Start Selenoid k"- SOV SO C/ Tail Open Q/Tt - -

2-DG-958 */S Air Start Selenoid k" SOV S0 C/ Tail Opes Q/Tt - -

2-DG-964 */B Air Start Solenoid k" SOV S0 C/ Tail Opea Q/Tt - -

2-DG-968 */S Air Start Solemote \" SOY S0 C/ Tail Opea Q/Tt - .

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• Noncode Class Valves.

• DIESEL LUBE OIL SYSTEN (Dtos)

Class / Valve Velve Number Normel -

Test Relief Test Catenery Function Stae Type Actuation Position Reeutred Reguested Alternate, 2-p;-51A '*/C Check Valve, 1%" CE - C q -~ .-

2-DC-515 */C Check Valve 1* CE - C Q - -

2-DG-65 */C Safety Relief  %" Ret -

C SRV - -

2-DC-66 */C Safety Reliet  %" Ret -

C SRV - -

2-DG-71A */(Note 1) Lube Oil Temperature Control 4" 3-Way System -

None' - -

2-DG-715 */(Note 1) Lube Oil Temperature Control 4* 3-Way System -

None - -

• e Not e 1: Control valves are esempt from testing per paragraph IW1200, of the AS.T Section X1, SP&V. Code 1980 Edition, including the Vinter 1981 Addeeds.

• Weecode Class Valves.

• AIR COOLING SYSTEN (ACS)

Class / Valve Normal Test Relief . Test valve Weber Catemory Function Size Type Actestion position Reemired Requested - Alternate 2-DG-3A */C Check Valve 4" CK -

C Q .- -

2-DG-38 */C Check Valve 4" CK -

C Q - -

2-DG-19A */C Check Valve Ig* CK -

C Q - -

2-DG-198 */C Check Valve 1%" CK -

C Q - -

2-DG-69A */(Wote 1) Air Cooling Temperature 4" 3-Way Systee - None - -

Control ,

2-DG-698 */(Wote 1) Air Coolias Temperature 4" 3-Way System -

None - -

Control s

Note la Control valves are esempt f rom testing per paragraph IW1200, of the ASPE Secties II Sp&V. Code 1930 Edition, lacluding the Winter 1981 Addenda.

• Noacode Class Valves.

?

JACEET COOLING STSTEN (JCS)

Class / Valve .

Valve Number Catenary Normal Test Function Size Type Relief Test Actuation Position Required Nequested Alternate 2-DG-l&A */C Check Valve 6" CE -

C Q - -

2-DG-l&B */C Check Val e 6" CK -

C Q - -

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

None Control - -

2-DG-708 */(Note 1) Jacket Cooling Temperature 6* 3-Way ' System -

None Control - -

2-DG-75A */3 Turbo Charger Cooling I" Cate It O Mone 4

Passive Isolation - -

2-DG-753 */B Turbo Charger Cooling 1" Gate M O Passive Isolation None - -

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

2-DG-765 */3 Turbo Charger Cooling la Cate .M O None Passive Isolation 2-DG-77A */3 Turbo Charger Cooling 1" Gate M O None Passive Isolation 2-DG-773 */B Turbo Charger Cooling I" Cate M O None Passive Isolation e

o Note la Control valves are esegt from testing per paragraph IW1200, of the ASE Secties XI. SPEV. Code 1980 Edition, including

. the Winter 1981 Addenda.

• Noacode Class Valves.

l IWP PUMP TAB 12 Flow. Speed Inlet Differential Bearing Pump Resistance Control Pressure Pressure Flow Vibration ~ I.ubrication Temperature Frequency Fuel Oil System Fuel Oil Pump A Fixed Variable

• RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Fuel Oil Pump B Fixed Variable

• RRft RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly I.ube 011 Systee P48A Lube 011 Pump Fixed Variable

• RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly P48B 1.ube Oil Pump Fixed variable

• RRf1 RRf1 RRf1 RRf4 RRf1 RRf1 Quarterly Jacket Coolina '

Water Systra P49A Coohng Pump Fixed Variable

• RRf1 RRf1 RRf1 RRf6 RRf1 RRf1 Quarterly P49B Cooling Pump Fixed variable

• RRf1 RRf1 RRf1 RRf4 RRft- RRf1 Quarterly Air Coolina Systee P127A Air Cooler Coolant Pump Fixed Variable

• RRf2 RRf2 RRf2 RPf4 RRf2 RRf2 Quarterly P1278 Air Cooler Cedant Pump Fined variable

• RRf2 RRf2 RRf2 RRf4 RM2 RRf2 Quarterly Clean Oil System P128A - Clean Oil Pump Fixed Timed RRf3 RRf3 RRf3 RRf3 RRf3 RRf3 Qua rterly P1285 - Cleas 011 Pump Fined Fixed RRf3 RRf3 RRf3 RRf3 RRf3 RRf3 Quarterly P128C - Clean Oil Pump Fixed Fixed RRf3 RRf3 RRf3 RRf3 . RRf3 RRf3 Quarterly .

F128D - Clema Oil Pump Fixed Fixed RRf3 RRf3 RRf3 RRf3 RRf3 RRf3 Quarterly

• Varies with engine speed.

RRfx = Relief Requested. (a a Relief Request No.)

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n LEGEND FOR VALVE TESTING l

Q - Exercise valve full stroke for ope'rability every three (3) months. If applicable, take stroke time measurements and compare to the stroke time limiting value per Section XI, Article IWV-3410.

QP - Exercise valve part stroke for operability every three (3) months.

_QCS

- Exercise valve full stroke for operability during cold shutdowns.

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

QPCS - Exercise valve part stroke for operability during cold shutdowns.

QR - Exercise valve full stroke for operability during refueling.

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

QPR -

Exercise valve part stroke for operability during refueling.

PI -

Visually observe, at least once every two years, actual valve position to confirm that remote valve position indications accurately reflect valve operation.

_ ~ - . - - - -

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

6 LT - Leak test valve per Section XI, Article IWV-3420,-or applicable relie'f request.

LLRT - Leak test valve in conformance with the criteria specified in ,

Appendix J of 10CFR50.

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

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

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

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-89A) FV 6397 (2-SW-89B)

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-89(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 8953 (2-DG-55)

PSV 8997 (2-DG-65) - PSV 8978 (2-DG-66)

PSV 8743 (2-DG-81 A) PSV 8744 (2-DG-81B)

Resolution:

All of the above valves except 2-DG-81(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-81(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-85C 2-FO-85D 2-FO-67A 2-FO-67B 2-FO-29 2-FO-67C 2-FO-67D 2-FO-85A 2-FO-85B 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: ,

" Category A - Valves for which seat leakage is limitied to a sp(cific 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 daring off-normal conditions. These valves are included in the test program as Category B and Category C valves and will be tested as such.

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-y 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 0.3 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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