ML20199F772

Transmits Summaries of 971106,11 & 13 Telcons Between NRC, Nneco & Neac Re Independent Corrective Action Verification Program Listed Procedures

ML20199F772
Person / Time
Site:	Millstone
Issue date:	11/18/1997
From:	Curry D External (Affiliation Not Assigned)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9711250010
Download: ML20199F772 (11)

Text

.

A PARSONS

. Denial L Curry, vee henwnt. tem S mes Parens Energy & ChemicWs Group loc.

2675 Mo'Dantown Road

• Read <ng Pennsytvania 19607 * (610) 855 2366

• Far (610) 8% 2602 November 18,1997 Docket No. 50 336 Parsons NUhi2 PPNR-0800-L U.S. Nuclear Regulatory Commission -

Attention: Document C(.itrol Desk Washington, D.C. 20555 hiillstone Nuclear Power Station Unit No. 2 IDdsPEndent Corrective Action VeriGcation Proaram (ICAVP)

Gentlemen:

This letter t.ansmits summaries of telephone conferences between Parsons Power Group inc., the U. S.

Nuclear Regulatory Commission, NNECo and NEAC on November 06, November iI and November 13, 1997. The purpose of these telephone conferences were as follows: November 6 - Procedure AOP 2579A, Pressurizer Level Control, Nuclear Oversight Perfomiance Evaluation, Design Basis Accidents, Flow Ehment Maintenance, Cable Tray Splice Plates, Diesel Engine Air Start Distributors, and integ,ated Leak Rate Test: November 11 - Procedure AOP 2579A,ilELB Sprinkler Interaction, Calc. PA91-004-276E2, PI-07, Initial Design Deficiencies, Proedure SP 2735 - Rev 4, and SQUG; November 13 - PDCE htP2-88-011, hiOV's 2-CS-16.l A and 2-CS 16.1B (Implementation of GL Rw 10), SP 2602A, PES-97 003, Engineering Self Assessment of Development, Revision and Control of FS AR Changes and Equipment Lists, h1EPL Request for a deleted PhthtS component, PDCR 2-025 86, Control Room Air Conditioning System Suction Pressure Switch Cat Out Setpoint, ASN1E Oh! Code, and Emergency Diesel Generator Str tor and Rotor.

Please call me at (610) 855 2366 if you have any questions.

i g () C Sincerely, c?nt & W q Daniel L. Curry ,

Parsons ICAV" Project Director DLC:djv ,

Attachment, l. Telephone Conference Notes from November 6,1997

2. Telephone Conference Notes from November 11,1997

3. Telephone Conference Notes from November 13,1997 cc: E. Imbro (2) . USNRC J. Fougere - NNECo

11. Eichenholz - USNRC Rep. Terry Concannoi. - NEAC R. Laudenat - NNECo Project Files 9711250010 9711tg r PDR ADOCK 05000336 P pg

. o u . . PPNR0800 doc

ADMINISTRATIVE CONFERENCE NOTES November 6,1997

. j

, PURPOSE: Administrative telephone conference with NNECo, NRC , NEAC and i Parsons to discuss:

o Procedure AOP 2579A e Pressurlier imel Control.

• Nuclear Oversight Performance Evaluation e Design Basis Accidents-  !

e Flow Element Maintenance  !

. Cable Tray Splice Plates e Diesel Engine Air Start Distributors

.. Integrated Leak Rate Test List of Attendees:

NNEco_ _NRC NEAC Parsons Joe Fougere Manager, ICAVP Steve Wayne Reynolds Dobson Fred Mattioli Supenisor, MP2 ICAVP Mike Akins Steve Wainio Supervisor - Design Engineering R.L nornas Debbic liersey Operations D. Laughman l'arvey Decman Supenisor Tc:hnical Support Fag C. R. Tracy Steve Stadnick Engineer - Technical Support Eng. A. J.

O'Connor Ralph Dates Engineer - Technical Support Eng. John Strange Ken Fox Supenisor Design Engineering D. L Wooddell Walt licinig E igineer - Nuclear Oversight Ray Crandall Sapenisor- Radiological 1, Procedure AOP 2579A (A. O'Connor)

D ACKGROUND: Procedure AOP 2579A " Fire Protection for llot Standby Appendix "R" Fire Area R l" Rev.6 Step 4.13.3.6. b. requires an operator to " VERIFY OPEN or, if necessary, MANUALLY OPEN RWST Outlet Motor Operated Valve,2-CS 13.1B", (a.k.a. IIV 3011).

OUESTION:

1- Valve 2 CS-13.1B, is located approximately 12 feet above the floor in the RWST pipe chase.

There are no platforms or ladders permanently installed to enable access and operation of the valve. Ilow does the operator gain access to the val e to perform the required operations?

RESPONSE: Note: all of these procedures are in the process of being revised. There is an installed ladder above the valve. The operator uould use this ladder and then step on to the pipe to gain axess to the valve. Shift manager permission is needed to step on piping.

2- For normal operations, the RWST pipe chase requires monitoring prior to entry, to assure there is no accumulation of flammable gases. Radioingical monitoring of the arca is also required prior to granting access. During the course of responomg to an Abnormal Operating Procedure, is the operator required to perform the normal monitoring procedures prior to entering the area, or are they permitted to bypass the monitoring requirements?

Discussion e Normal monitoring procedures are followed since use of this valve is only needed approximately 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> after the fire.

. The purpose of the valve and whether or not it is subject to spurious operation needs to be confirmed by NNECo. This will be followed-up in the next conference.

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ADMINISTRATIVE CONFERENCE NOTES Nmemher 6,1997

, 3. What training is given to the operators who may be called upon to operate this vahc in an Appendix R scenario.

RESPONSE: No specific training is given to operators on this valve. Generic training is provided on how to open/close valves and the controls on stepping on piping.

2. Pressurlier Les el Control. (L Strange)

The Loss Of Fecdwater Flow Accident Analysis assumes that pressurizer level is at 65% + 2%

uncertainty at the time the accident occurs. The pressurizer level control program generates a .

maximum setpoint of 65%. Is there a calculation which shows that this control loop will control to within 2% of the setpoint?

RESPONSE: There is no calculation. Millst,nc i.a: procedures to calibrate the instruments.

3. Nuclear Oversight Performance Evaluation (D. Wooddell) -

What is an Nuclear Oversight Performance Evaluation, (NOPE)? What is their charter? We found reference to this in a MOV surveillance and overhaul procedure.

Discussion e The Nuclear Oversight Department prov:Jes QA/Q and daily mersight of work performed. NOPE refers to what the Nuclear Oversight Department does.

• - The MOV procedures are unusual by calling out the Nuclear Oversight Department activitics. Normally Work Planning will list exceptions to oversight, otherwisc eser> thing gets oversight.

4. Design Hails Accidents (George Zagursky) is e concurrent carthquake and LOCA a design basis accident for Millstone Unit 27 We luwe seen soma documentation which indicates that this combination is not a design basis accident, and some docementation which indicates it is. For example FSAR chapter 6. page 6.1-4. mid-page talks about a "... maximum hypothetical carthquake, combined with the rupture of a reactor coolant pipe are considered in the design of the engineered safety features."

RESPONSE: A concurrent carthquake and LOCA is NOT a design basis accident for Millstone Unit 2. The FSAR chapter 6 is only discussing how loads are combined for structural anal) sis.

5. Flow Element Maintenance (Daniel Laughman)

Does Millstone have a preventive maintenance cycle in place to examine flow clements for wear?

In general the edge of ti.c internal diameter is critical and a change in shape will aller the element's accuracy. IC243P is the Preventive Maintenance Program but this procedure is the overall controlling procedure and does not contain the details we are looking for on this subject.

Discussion e There is no maintenance cycle. The CMP walked down nast flow clements. This is

- documented in a Enginecting Record of Correspondence ERC-97-085. The t)ws of problems found were plates in backwards and plates too thin for the max. flow and therefore they deform. No wcar problems were found.-

• The walkdow n looked at flow clements both in place and removed for inspection.

6. Cable Tray Splice Plates (Roger Mauchline).

Cable tray splice plates are used to provide shear and momem capability for continuity of tray s across supports and for cantilever of trays past supports. What splice plates were used on Millstone 2 and what documentation is available to show that they have the required shear and moment capability?

Discussion

• Bechtel Spec. 7604-E-49, Section 5, Design Requirements identifies the requirements to which the plates were procured and installed.

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ADMINISTRATIVE CONFERENCE NOTES November 6,1997 .

.. * = -- NNECo has not found anything that documents the plates have the required shear and -

moment capability beyond the Bechtel Spec. Millstone is currently as-building splice

-plates. 3

7. Diesel Engine Air Start Distributors (D. Wooddell) -

is the Emergency Diesci Engine equipped with One (1) or Two (2) Air Start Distributors?.-

= RESPONSE: Each Emergency Diesci Engine is now equipped with One (1) air start distributor.

' Until approximately one year ago, the "B" dicscl, w hich originally came from Detroit Edison in 1977 had two air start distributors.

8. Integrated Lenk Rate Test What procedure was used to perform the last Millstone Unit 2 integrated leak rate test type "A"? We found !/ 21208 in Worldview, but it is marked as " canceled", and we can not find -

another pmcedure.

' RESPONSE: SP-21208 was last used in June 1995. In Oct.1996 is was canceled and it will not be used again until approximately 2004. Before that date it will resised and updated.

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ADMINISTRATIVE CONFERENCE NOTES Nm ember i1,1997

, PURPOSE: Administrative telephone conference with NNECo, NRC , NEAC and Parsons to discuss:

• Procedure AOP 2579A e llELH Sprinkler interauio e Calc. PA91004 276E2 e PI-07 e Initial Design Deficiencies e Procedure SP 2735, Rev. 4

• SQUG List of Attendees:

NNECo- NRC NEAC Parsons Joe Fougere Manager, ICAVP Steve Reynolds Wayne Dobson Fred Mattioli Supenisor MP2 ICAVP Samir Serhan Rich Ewing Supenisor - Design Kevin D'nouza Engineering Jim Diluca Design Enginecting Ri:h Schmchl Nabil Juraydini Design Engineering Hill Jones Ron Smith Nayam Shah Clark Tracy Andrew O'Connor Candace Segar Dill Meek John Townsend Graham Leitch John Lambright John Garrick

1. Procedure AOP 2579A (A. O'Connor)

Follow up from 11/6/97: NNECo to confinn what is the purpose of the RW3T Outlet hiotor Operated Valve,2-CS 13.1 B", (a.k.a. HV 301 l) in relation to AOP-2579A, i.e. when does an operator need to

" VERIFY OPEN or, if necessary, h1ANUALLY OPEN RWST Outlet hiotor Operated Valve?

RESPONSE: his valve is used for make-up inventory after cool down, which is 24-37 hours aller the event. It is subject to spurious activation and thus the need to confirm it is open.

2. IIELB Sprinkler Interaction (From I116/97 EQ Conference)

The llELB Sprinkler Actuation are not two separate events being postulated concurrently. The llELB causes the Fire Sprinkler system to initiate and as such is a secondary effect of the event. It is not an unrelated event. Please provide a copy of the h12 internal response to the recent NRC IN on the subject.

Dircussion I, NNECo has not found a response to info Notiec 94-12. NNECo can provide its response to SOER 85-05

3. Calc. PA91-004-276E2 (W. Jones)

This is a continuation of conference calls on i1/3 & 11/4/97, regarding Specifications SP-EE-344, SP-EE-390 and this calculation.

MCKQROUND.

A fraction of the load shown against h1CCs is reflected back to the load center that feeds them in calculation PA91-004-276E2.

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ADMINISTRATIVE CONFERENCE NOTES -

Nmember 11,1997

. For example: MCC B 'or Nermal Full Load on RSST, except Mode 4 -

hiedal Mgdd hiedd hLode 4 (at 363k

• B625" Max Amps - 589,4 (Att. I, p.39) 560.2 (Att. IV, p.39) 595 (Att.~ Vil, p.39) 239.2 (Att X, p.

"22F 862L" Max Amps-29.2 (Att. I, p.9) 27.6 (Att. IV, p.9) 29.5 (Att. Vll, p.10) _ 121,5 (Att. X, SP EE 344 data only shows the MCC loads as on or off- it does not show different diversity / demand factors for discreet loads in cach mode. Note also that the "B62S" listing and "22F-862L" listing is different for cach mode.

Also, Calculation 96-ENG-01528E2 shows " Continuous Running Load" of 450.8A for MCC B62.

QQESTION:

1. Ilow were the MCC loads on each Load Center derived from the tabulation of both discreet and total MCC loads shown in calculation PA91-004-276E2?

RESPONSE: DCN DM2 S-0847 94 written arjainst SP344 addresses this question.

2. Ilow were Continuous Running Loads shown in Calculation 96-ENG-01528E2 derived and in what document are they derivui?

3. Are there specific input Data / Records for a particular Caic, available?

RESPONSE: Attachment E & F of DCN DM2 S-0847-94 provides tabulation of MCC loads and design inputs.

4. Does SC Calc. PA91-004-286E2 or any other Calc. reflect the same input /information as does the 276 Calc.

RESPONSE: Data input is within the AC system model and MCC system model. For example the short circuit calculation uses the AC system model, the voltage profile calculation uses the AC sys and MCC sys. model

4. Pl.07 (D. Ramos)

Did Millstone prepare a PI 07 review for EBFS (sys # 2314G)?

Did Millstone prepare a PI-07 review for the Emerg. Diesel Generator Ventilation System?

RESPONSE: Yes, FDFS (sys # 2314G) was a wave 2 system, and the Emerg. Diesel Generator Ventilation System was a wave 3 system. These systems havejust recently been completed and the PI-07 will be sent to Parsons next week.

5. Initial Design Deficiencies (Ron Smith)

Part of Tier I includes a review of previous design deficiencies identified by the architect / engineer before initial operation that were to be corrected aRer initial startup. Typically, Bechtel will provide the uti'ity with a turnover list containing open items that need to addressed after startup. We would like ti. discuss what Bechtel provided to Millstone and what type of closure documentation would have been generated so we can prepare an RAI to obtain this type ofinformation.

RESPONSE: So far NNECo has ordy been able to find a Bechtel memo, M-NP2-566 dated 10/8/75

- regarding Unit 2 Open items. NNECo can provide this memo along with documentation of closure.

6. Procedure SP 2735, Rev. 4 (D. Wooddell)

- Procedure SP 2735, Rev. 4, Change No. 2 Step 4.2.3, specifies replacing the 'A' Diesel Generator fuel injection pump crosic. sleeves every 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />.

A. Why are erosion sleeves a problem specific to the 'A' diescl?

B, llow is the 'B' diesel different?

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ADMINISTRATIVE CONFERENCE NOTES-

- November 11,1997 -

..  ?-

,- RESPONSE: A 10CFR21 was issued on l1/8/96 regarding erosion problems with front header fuel pump designs. The "A" dicsci has a front header design. He "B" diesel has a rear header fuel pump

-- design and is not subject to the same problem. AR 96035585 discusses this issue.

7. SQUG ( R. Schmcht) .

1. Was a revised Generic Ruggedness Spectra defined for Motor Control Centers (Function After and Function During) subsequent to that which is included in the GIP?-_

RESPONSE: Noc

2. B61480V MCC BUS B61 (22 IF)- Which section of the GIP addresses the reduction factors associated with the anchorage evaluation?

Discussion

1. De reduction factor is discussed in section 4.4.2 which refers to Appendix C

2. The median centered response spectra for the Aux building is ONLY applicable for the A-46 program.

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ADMINISTRATIVE CONFERENCE NOTES Nmember 13,1997

, PURPOSE: Administrative telephone ennference with NNECo, NRC , NEAC and Parsons to discuss:

. PDCE MP2-88-Oll e MOV's 2-CS-16.l A and 2-CS 16.lB (Implementation of GL 8910)

• SP 2602A

• PES 97 003, Engineering Self Assessment of Development, Revision, and Control of FS AR Changes and Equipment Lists

• MEPL Request for a deleted PMMS component)

• PDCR 2 025 86 e Control Room Air Conditioning System Suction Pressure Switch Cut Out Setpoint

• AMSE OM Code

. Emergency Diesel Generator Stator and Rotor List of Attendees:

NNECo NRC NEAC Parsons Joe Fougere Manager, ICAVP John Wayne Dobson Nakoski Fred Mattioli Supenisor, MP2 ICAVP Rich Dan Wooddell McInt>Te Rick Bonner Supenisor - Operations Larry Collier Phil thggins Engineer - MP2 Design Engineering candace Segar Paul Collette Supenisor - DGign Engineering Clark Tracy Steve Stadnick Engineer - Technical Support Eng. Knct Rare!!

liarvey Becman Supenisor Technical Support Eng. Don Marks Dan llundley Engineer - MP2 Design Engineering Mark Fitzgerald Roger Eisner Engineer Technical Support Eng. Kevin D'souza Norm Sacco Supenisor - MP2 Design Engineering Ken Fox Supenisor - MP2 Design Engineering Barbara Wilkens Manager - Program Engineering Standards Jim Petrosky Supenisor - Program Eng. Standards

1. PDCE MP2-88-011 (Candace Segar)

D ACKGROUNE In section 4.0 under implementaticn, PDCE MP2-88-Ol i states that "the work associated with design change will be completed using a QA three page AWO. Unit 2 maintenance will be perfonning the work." Under Section 5.0 Administrative impact - AWO number is M2-82-11748 is identified. Ilowever, it appears that this AWO is for an annual PM per procedure 270IJ-7.

QUESTIOR What work order was used to replace the motor for valve 2-SI-412 for PDCE MP2-88-011, and what documents the MOV testing after this design change was implemented?

Discussion

1. Note: The AWO number M2-82-11748 reference above should be M2 11748.

The PDCE is difficult to read and the "7" looks like a "2"

2. PDCE MP2 88-01I was actually implemented with AWO M2 88-00870 and MM7-13865. The PDCE is incorrect. NNECo has written CR M2-97-2613 to correct this.

2. MOV's 2-CS-16.l A and 2-CS-16.lB (Kevin D'souza)

Calc. # PA-063-071GE Rev.0, M2 Thermal Over Load Relays for MOV's 2-CS 16.l A and 2-CS-16.1B, identifies the motor as 5.3 IlP. Field verification iden+ified the motor as 6.6 H.P.

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4 ADMINISTRATIVE CONFERENCE NOTES ,

Nm' ember 13,1997 .

1s there a modi 6 cation that installed the 6.6 li.P. motor, or a more recent calculation that addresses a 6.6 ll.P. motor?

Discussion -

1. A modification installed the 6.6 ll.P. motor. NNECo walkdown confirmed that a 6.6 11.P. motor is installed. There are many modi 6 cations associated with MOVs, NNECo has not identified which one replaced the motor.

'2. CR M2-97 2619 has been written to address the fact that the calculation was not revised.

3. Millstone Unit 2 is currently implementing GL 89 10. - Walkdowns and calculations are being done to validate motor and TOL sizing for 52 valves. NNdCo had not yet Eotten to this MOV. The effort is schedule to be complete the 1st quarter of 1998.

4. A new calculation is being prepared that will contain the results ofimplementing GL 8910. It is 97 ENG-01840E2

3. SP 2602A (Mark Fitzgerald)

Procedure SP 2602A, " Reactor Coolant Leakage" contains a prerequisite of steady state conditions. What is the definition of steady state conditions that Millstone uses?

Discussion

1. Millstone dermes steady state as no power maneuvers. Millstone Unit 2 does not have any specific criteria on allowable variations of temperature, pressure, etc. during the duration of the test. He plant computer records these variables during the test and performance of the calculation.

4. PES97-003, Engineering Self Assessment of Development, Revision, and Control of FSAR Changes and Equipment Lists IDon Mark _s)

Ik.kground: PES97-003; Assessment of the Development, Revision, and Con:rol of FSAR Changes and Equipment Lists, Attachment 2 (Equipment Lists) lists 23 recommendations.

Each recommendation has a place for an associated AR.!, but in our copy of PES97-003 all of the AR h are blank.

Quntio.o llave ARs been prepared for these recommendations yet? If yes, what are the AR numbers?

Discussion

1. Yes ARs have been prepared and are tracked by one CR, however these numbers were not available during the conference. NNECo will provide the numbers during a

-administrative ca!! to Parsons.

5 MEPL Request for a deleted PMMS component (Don Marks)

- [kkatost As part of the Tier 3 review of MEPL classification downgrades (from Catl=Y

. to Catl=N), we asked for, and NNECo provided a download from the MEPL Change Log (RAl-0296). Subsequently RAl-0497 asked for MEPL documentation for the components comprising the "MEPL Downgrade Sample"(MDS). One of the components on the MDS was 2-ilV-3270 (i.e., three two seven oh). Unfortunately on the RAI this component was listed incorrectly as 2 IIV-3270 (i.e., three two seven zero). The RAI response noted that it was not pospble to identify the above component. Subsequent Parsons research discovered that neither PAGE2

a - 94 , em e+- 4 6 n-i- - + s L y au,-- -- b-4 ADMINISTRATIVE CONFERENCE NOTES Nmember 13,1997

, version of the component identification number is in the current NNECo PMMS ID database.

Ilowever, the former version (i.e., three two seven oh) was in the Change Log and in the ACCESS download of PMMS (supplied to Parsons in the lata June /carly July time frame).

The research uncovered 9 additional components which were on the Change Log and were once part of PMMS ID, but are now not in PMMS-ID (2 IIV-3130; 2 liv-3150; 2-liv.

3160; 21IV-3250; 2 IIV-3260; 21IV-3280; 2CNDR45; 11S 8306; and iIS-8312).

Glution: What happened to each of these components?

Please explain:

e the use of the " Status" Celd in PMMS; e the meaning of the allowable values (0; R; S; and X);

e the use or non use of these values as they apply to the at>ove components; e- which value, if any, is used for components deleted from the PMMS database for administrative (i.e., non-intent changes) reasons; e how con 6guration trace-ability is maintained for:

e components deleted from PMMS, e components which are re-numbered.

Discussion

1. There is nothing that controls how PMMS treats equipment that is removed from the

> plant. - Millstor,e has the option ofleaving the equipment ID number in PMMS and using the " Status" field to indicate that it has been rer.ioved froin the plant, (i.e. R,S,or X), or they can remove the ID number from the active database. For the examples identified above, PDCR 2 92-057 removed all of the items except 2CNDR45.

Millstone chose to remove these ID numbers fium the active database. That is why Parsons could no longer find them in PMMS.

2, Starting in April of this year, when ID numbers are removed from the active database they are still maintained in a historical Ole. Tir historical file has information regarding when, why, and who removed the ID number. One needs access to the ID DATABASE of PMMS in order to see the historical file.

3. When components are re-numbered this infonnation is also maintained in the historical file. A field associated with new ID number will identify any MEPL associated with the old ID number that is applicable the to part.

6. PDCR 2-025-86 (Wade Russell)

Was PDCR 2 325 86 which was to install a reference leg for CST level indication, canceled or only partially installed?

RESPONSE: This PDCR was implemented however, PDCR 2 79-92 removed the reference leg when the CST was changed to a pressurized tank.

7. Control Room Air Comlitioning System Suction Pressure Switch Cut Out Setpoint (Laadal Powers) -

Daqkgg_und; The setpoint of the suction pressure switch PS-9968A for compressor F22A and i

switch PS 99688 for compressor F22B in the Control Room Air Conditioning System was reduced to 10 PSI by PDCR NO. MP2-66 95, Rev. No. O. No calibration procedure is referenced on the PDCR. We are trying to determine if this setpoint change was reflected in afTected documents. PMMS references drawing 25203 26027, sheet 0003 for these switches.

Compressors F22A and F228 are on this drawing, but not the cut out switches.

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ADMINISTRATIVE CONFERENCE NOTES '

. November 13,1997

. - What document (s) provide the setpoint for these switches? (i.e. how does the plant know the '

current setpoint for these switches and how is it maintained?)

e drawings

• vendor manual .

e calibration procedure Discussion -

1, -_'Ihis setpoint has several change packages associated with it. The above PDCR, a SCR and most recently a DCR M2-96-006. In addition there is an AR 96-029548, Currently, this setpoint change package is still open.

2. During the discussion NNECo was not able to identify any information fiom the setpoint change packages regarding station documents that needed to be updated as a result of the setpoint change.

3. There is a station BOP procedure that typically contains pressure switch setpoints.

NNECo will follow-up on u hat that procedure is.

8. AMSE OM Code (D. Wooddell)

CR No M2-97-2325, Section 1.2, references OMa 1988, Part 10, during the determination of valves 2-FW-32A/B safety related functions. Does this mean that Millstone Unit 2 committed to the ASME OM Codes? If so, which ones?

RESPONSE: NNECo is in the process of upgradii.g the IST program. It is scheduled to be complete prior to Mode 4. They will be committing to the 1989 ASME Section XI.

Millstone Unit 2 3rd ten year cycle will start when the plant starts up.

9. Emergency Diesel Generator Stator and Rotor (D. Wooddell)

Does Millstone have a procedure for removal, inspection, and replacement of the Emergency Dic>cl Generator stator and rotor?

RESPONSE: No, Millstone has not had to perform that activity.

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