IR 05000423/1997210

Insp Rept 50-423/97-210 on 980105-0206.Violations Noted. Major Areas Inspected:Effectiveness of Configuration Mgt Program,Effectiveness of Sargent & Lundy Review of Sys Objectives & Quench & Recirculation Spray Sys

ML20216G016
Person / Time
Site:	Millstone
Issue date:	04/03/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216F963	List: IR 05000423/1997210 ML20216F960 ML20216F984
References
50-423-97-210, NUDOCS 9804170311
Download: ML20216G016 (34)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION I

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Report No.:  !

50-423/97-210 Docket No.: 50-423 '

License No.: NPF-49 Licensee: Northeast Nuclear Energy Company Facility - Millstone Unit 3 - -

Location: Millstone Nuclear Power Station 156 Rope Ferry Road Waterford, Connecticut 06385 Dates: January 5 - 16 and January 26 - February 6,1998

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I Inspectors: James Luehman, ICAVP, Leader, Sub-Team 3A, i

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Special Projects Office l

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Stephen Tingen, Special Projects Office Michael Shylamberg, Mechanical Engineer, Contractor *

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James Lievo, I&C Engineer, Contractor *

Ray Cooney, Electrical Engineer, Contractor *

Andrew du Bouchet, Mechanical Engineer, Contractor *

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• Contractors from Parameter, In Approved by: Peter Koltay, ICAVP, Leader, Team 3

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Special Projects Office l Office of Nuclear Reactor Regulation l l

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9804170311 980403 i PDR ADOCK 05000423 '

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SUMMARY I

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Millstone Nuclear Power Station Inspection Report 50-423/97-210 From January 5 through 16 and from January 26 through February 6,1998, a team from the j U.S. Nuclear Regulatory Commission (NRC) Special Projects Office (SPO), Office of Nuclear Reactor Regulation (NRR), conducted a functional inspection at Millstone Nuclear Power Station Unit 3. Following the 3 weeks of inspection at Unit 3, the team spent a week in Chicago, Illinois, at the offices of Sargent and Lundy (S&L), the Unit 3 Independent Corrective Action Verification Program (ICAVP) contracto This inspection represents one of the many facets of the NRC's oversight of the ICAVP. Within that context, the purpose of this inspection was to assess the effectiveness of the Configuration Management Program (CMP) implemented by Northeast Nuclear Energy Company (NNECO),

the licensee for Millstone Unit 3, as well as the effectiveness of S&L's review of the 15 Tier 1 systems. In order to accomplish these objectives, the team focused its inspection on the quench and recirculation spray systems, as well as the emergency diesel generator sequencer and a portion of the plant's emergency ventilation syste During the onsite portion of the inspection, the team identified three violations and a number of other findings. Individually and in aggregate, these findings were considered minor and of low safety significance. Overall, the team found that the material condition.of the inspected systems to be goo When the team departed the site, the licensee still had a significant amount of work to complete for the RSS, including operator training and a number of modification The team determined that S&L's assessments were generally thorough and acceptable. Based on its onsite inspection of specific focus areas such single-failure and ongoing modifications, the team requested that S&L augment their review to include: (1) single-failure vulnerability of electrical control circuits that have inputs from redundant trains, as a result of the SCLRS fan circuitry problem identified by the team; (2) a review by the Systems Review Group of DRs written by the Operations and Maintenance Review Group, and DRs associated with temporary modifications to determine whether there were any design weaknesses being resolved by temporary modifications or operator workarounds (DRs MP3-070 and 0747 are examples of DRs that should have received such an integrated review), and (3) structural calculations for fans 3HVR*FN12A&B (the team identified that review of these components had inadvertently not been performed by S&L) and (4) structural steel component support calculations that had not been reviewed due to a miscommunication between review groups within S&L. The l augmented reviews did not identify additional issue Although there were modifications ongoing in the RSS system, the team was able to review a substantial portion of the RSS design including some of the modifications completed during this outage. Based on the results of the team's independent design review, the team's assessment l of the S&L implementation of Tier 1, and the relatively small number of confirmed level 3 !

Discrepancy Reports identified to date by S&L, preliminary indications are that the NNECO's Configuration Management Plan (CMP) was generally effective in identifying and correcting

' nonconformances with the plant's design and licensing bases. While the team identified issues !

not discovered by the CMP or by S&L the safety significance of the findings was low. This l provides confidence that other issues, should any be discovered, would likely be of low significanc I

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1 Introduction i

L From January 5 through 16 and from January 26 through February 6,1998, a team from the

! U.S. Nuclear Regulatory Commission (NRC) Special Projects Office (SPO), Office of Nuclear l Reactor Regulation (NRR), conducted a functional inspection at Millstone Nuclear Pcwer Station Unit 3. Following the 3 weeks of inspection at Unit 3, the team spent a week in l Chicago, Illinois, at the offices of Sargent and Lundy (S&L), the Unit 3 Independent Corrective

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This inspection represents one of the many facets of the NRC's oversight of the ICAVP. Within that context, the purpose of this inspection was to assess the effectiveness of the Configuration

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Management Program (CMP) implemented by Northeast Nuclear Energy Company (NNECO),- -

the licensee for Millstone Unit 3, as well as the effectiveness of S&L's review of systems l deemed to be within the scope of the CMP and S&L's oversight. In order to accomplish these objectives, the team focused its inspection on the quench and, recirculation spray systems, as well as the emergency diesel generator (EDG) sequencer and a portion of the plant's

!- emergency ventilation syste .1 Background l

As part of verifying the licensee's implementation and execution of the Millstone CMP, the NRC committed to review a system within the scope of the CMP, that had not been reviewed by S&L as wel! as a system that had been reviewed by both by the licensee (under the CMP) and S&L.

l The results of the first or "out of scope" inspection are documented in NRC Inspection Report 423/97-206, dated December 5,1997. This inspection report documents the findings and results of the second or "in scope" inspection. In conducting this inspection, the team focused on the quench and recirculation spray systems, as well as the EDG sequencer and a portion of the plant's emergency ventilation system, as discussed in the remainder of this repor .2 Descriotion of Systems and Safetv Functions

' The quench spray syrtsm (QSS) operates during accident conditions, when actuated by a containment depressurization signal. When actuated, the two independent QSS pumps take a i suction on the tefueling water storage tank (RWST) and discharge that water through spray j rings located at the top of the containment. Thus, QSS sprays cold borated water into the ;

upper regions of the containment to help reduce containment pressure and temperature during I a design-basis acciden The recirculation spray system (RSS) also operates during accident conditions when actuated by a containment depressurization signal. In the case of the RSS, however, system operation i is delayed approximately 11 minutes in order to allow for the accumulation of sufficient water in the containment sump to support RSS pump operation. Once system operation begins, two trains of two pumps and heat exchangers take suction on the containment sump and spray the containment through a set of spray rings separate from those used by the QSS. The water !

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sprayed by the RSS contains trisodium phosphate that is mixed from large baskets that are located on the containment floor, into the water that flows to the containment sump. The trisodium phosphate aids in removing fission products and ensures that the equilibrium pH of the accident water is maintained in an acceptable range. A series of three screens of l

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decreasing diameters protects the containment sump itself from debris that might otherwise affect RSS operatio During an accident, inW.or coolant system injection is initially supplied from the RWS However, when the RWST reaches certain predetermined points, the reactor coolant system

- injection is replaced by injection from the containment sump through the RFS pumps to the high-head charging and safety injection pumps. The QSS subsequently stops spraying the .

containment leaving the RSS to perform that function. After the switchover to RSS, the ~

recirculation flow is initially directed into the cold legs of the reactor coolant system. However, this flow later shifts to the reactor coolant system hot legs. Along with the RSS spray, the coolant recirculation paths described above will provide long-term cooling of the reactor in the post-accdont environmen _

in addition to the RSS, the team reviewed the EDG sequencer used in Millstone Unit 3. This sequencer is a solid-state electronic device which, through a series of relay contacts, properly sequences the required loads onto the EDG in the event an accident occurs coincident with a loss of normal and altemative electrical power to the plant's accident mitigation equipmen Finally, the team reviewed a portion of the emergency ventilation system used in Millstone Unit 3. Specifically, that portion consisted of two sets of fans and filters, which together ensure that areas of the plant outside the containment that may be highly contaminated following an accdont, are brought to, and maintained at, a negative pressure with respect to surrounding areas, and that releases from such arets are filtered. During an accident, the first set of fans and filters takes air from potentially contaminated areas of the auxiliary building, such as the charging pump cubicles, and discharges it through charcoal filters located in the auxiliary building. Similarly, the second set of fans and filters, which makes up the supplementary leak collection and release system (SLCRS), takes air from areas such as the engineered safety features (ESF) building and containment enclosure building and discharges it though separate charcoal filter .3 Insoection Scone and Methadalaav in conducting the Millstone Unit 3 in scope inspection, the team used Inspection Module g3801 ss its inspection approach. In addition, because the inspection was intended to assess S&L's performance in implementing their NRC-approved ICAVP audit plan and the effectiveness of the licensee's CMP, the team emphasized system ded. n, including modifications, and the appropriate translation of the design and licensing bases into operations and surveillance activitie After completing three weeks of inspection at Millstone Unit 3, the team spent one week at the

' S&'L offices in Chicago, Illinois, the ICAVP independent contractor for Millstone. The purpose

of that review was to ascertain the adequacy of S&L's review of the "in scope" systems. The team's review of work concentrated on those systems and portions of systems reviewed during the team's onsite inspection. The team compared its onsite findings with the deficiency reports

. (DRs) generated by the contractor. Additionally, the team assessed the DR quality, classification, and the licensee's response to the DR. The team also evaluated S&L's assessment of programmatic areas, such as fire protection and environmental qualificatio .

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1. Unit 3 Quench Spray, Recirculation Spray, and Ventilation inspection Boundaries The team reviewed the QSS bounded by valves 3QSS*AOV28,3SIL*V1,3QSS*V983, 3QSS*V985, 3CHS*V316, 3CHS*RV85108, 3SFC*V49, 3CHS*RV8510A, 3RSS*V990, 3RSS*V991,3QSS*TK1 (RWST).

The team reviewed the RSS, including the containment sump structure, screens, vortex suppressor, trisodium phosphate baskets, the four RSS pump seal water systems (primary grade water system not included) bounded by valves 3RSS*V25, 3SIL*MV8804A/B, 3SIL*8809A/B, 3SIL*RV8856A/B, 3RHS*MV8716A/B, 3RHS*HCV606/607, 3RHS*FCV618,619, 3 SSP *SOV25A/B,3SWP*MOV54A/B/C/D, and 3SWP*EJ8 DIE /F/ ~ ' ~

The' team reviewed the SLCRS from the QSS and RSS pump room cubicles to ths stack, which includes charcoal filter banks 3HVR*FLT3A/B and fans 3HVR*FN12A/B. The reviewed portion of the auxiliary building ventilation system (ABVS) included the two ABVS filter banks (3HVR*FLT1 A/ B), the associated suction fans (3HVR*FN6A/B), and the charging and reactor plant component cooling water pump area ventilation supply and discharge fans, (3HVR*FN13A/B and 3HVR*FN14A/B).

The team reviewed electrical components in the system boundaries back to the motor control

, center (MCC), as well as the EDG sequencer. The team also reviewed ventilation to the electrical switchgear rooms and ESF building MCCs, which is required to maintain room temperatures within design operating conditions for electrical components within the scope of the inspection. Finally, the team inspected instrumentation within the system boundaries back to the initiating componen .0 Mechanical Quench and Reciredl=hn Sorav Systems 2.1.1 Scope of Review The mechanical engineering revienu was aimed primarily at verifying that the quench and recirculation spray systems were capable of accomplishing their design functions, meeting all y applicable codes, standards, regulatory requirements, meeting all licensing basis commitments; L operated consistent with their design bases, and tested in a manner that accurately reflects their condition and their ability to perform their intended safety functions. The interfacing and supporting systems including the service water, sealing and lubrication, instrument air, and ventilation systems were also incorporated into the revie .1.2 Findings (a) Maximum Value of the Acceptance Criteria for the Pump in-Service Testing (IST)

The team reviewed the IST procedure SP 3606.1, for the QSS and RSS pumps and compared the test results and acceptance criter's to the vokses used in the system calculations. The test results were conservatively enveloped by the system calculations, similarly, the minimum pump acceptance criteria was also conservative. However, the maximum pump acceptance criteria exceeded the values used in the system calculations by 3 - 5 percent. Use of * higher"

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acceptance enteria would make the results of the switchover and not positive suction head available (NPSHJ design calculations nonconservative. The review of the completed surveillances for RSS and QSS pumps appear to indicate that the pumps performance exhibited a good agreement with the design calculations. However, should these pumps be subjected to any maintenance evolutions, which could make them develop a higher head (without exceeding the maximum allowable values), then the results of the affected calculations could become nonconservative. The team noted to the licensee that absence of a connection between the maximum acceptance criteria, and the maximum allowable design values could result in a loss of configuration control. The licensee agreed to ensure that adequate procedural controls were in place to evaluate pump performance following any maintenance .

against relevant design criteria.

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This is identified as inspection Followup Item (IFl 423/97-210-01).

(b) Calculation US(B)-295, Revision 6; "RWST Draw-down Rates and Switch Over Levels" The review of this calculation identified that the conclusions of this calculation were based in part on the assumption that "..10 minutes are a reasonable time to achieve full switch over" (Assumption No. 2) and that "...one RHR pump continues to run for additional 2 minutes" before it was secured by the operator (Assumption No. 5). The team questioned whether the assumptions were verified by the emergency operation procedure training. The licensee informed the team that the calculation is being revised to change these assumptions to 25 and 5 minutes, respectively. The calculation revision was not provided for the team's review before completion of inspection, hence, the team could not review the effect of these changes on the results of the calculation and on the design of QSS and RSS systems. However, the revised calculation will be sent to S&L for revie This is identified as an inspection Followup item (IFl 423/97-210-02). Sunclementarv Leak Collection and Rel==== System (SLCRS) and Auvil!=rv Builclina Ventilation

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2.2.1 Scope of Review The ventilation system reviewed by the team consists of two sets of fans and filters (SLCRS and the emergency portion of the auxiliary ventilation). Together, these fans and filters ensure that areas of the plant outside the containment that may be highly contaminated post-accident are brought to, and maintained at, a negative pressure with respect to surrounding areas, and that releases from those areas are properly filtere .2.2 Findings (a) Potential for Wetting SLCRS Charcoal Filters, 3HVR*FLT 3A&B, due to Fire Protection System Leakage in reviewing the interactions between the SLCRS and fire suppression system, the team identified the potential for the SLCRS charcoal filters (3HVR*FLT3A&B) to become wet as a result of leakage from valves in the fire system, thus reducing the efficiency of the charcoal filters. The fire suppression system components were designed as quality assurance Category

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2 and 3 components (nonsafety-related) for isolation of the fire suppression system from the SLCRS pressure boundary envelope. However, the review of the piping and instrumentation diagram (P&lD) 1279-EM-146C-14 identified a potential pathway for the water around the i_ normally closed manual isolation valves of th6 fire system through check valves.

, The team also verified that the licensee was aware of previous instances of leakage through I these check valves. When the check valves leak, the only barrier between the pressurized fire

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water system and the charcoal filters is the solenoid pilot actuated deluge valve. Leakage through deluge valve or failure of this valve in the open position, along with the preexistent condition of check valve leakage, could lead to an undetectable wetting of the charcoal filter Following discussions with the team, the licensee addressed this concem by issuing condition - - --

report (CR) M3-98-0484. The corrective actions recommended by this CR included verifying the leak tightness of the check valve This is identified a violation of 10 CFR Part 50, Appendix B, Criterion XVI, for inadequate l corrective action (VIO 423/97-210-03).

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' Elecincal l Quanch Sorav. Raeirmidian Sorav. and Verdildian

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3.1.1 Scope of Review

, The team used a vertical slice approach to review the power supply from 4.16-KV buses 34C

! and 34D to the QSS, RSS, and SLCRS components fed from the 4.16-KV and 480 volt buses to ensure that the power supply is adequate for all QSS, RSS, and SLCRS loads, with regard to

! capacity, voltage available at the required buses, and cable capacity. Another goal was to verify that coordination ensures that the fewest number of devices are tripped in the event of any postulated fault.

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3.1.2 Findings-(a) ' Auxiliary Building Ventilation Fan Circuitry Design Weakness

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In reviewing the diagrams for fans 3HVR*FN14A/B and fans 3HVR*13 A/B (12179 ESK4SD, SSE,6SF, ano 6SG), the team noted that after a loss of power the circuitry design was such L that the potential existed for both fans to try to start and subsequently trip each other off. The licensee responded by issuing CR M3-98-0233. ' Both fans, shutting down after a loss of power would result in each of the fans again attempting to start when power is restored, thereby,

. shutting themselves down again. The cycle could repeat until one fan successfully started, or

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the thermal overload devices in the fan circuits tripped. Even if after a cycle or two, one train was successful in restarting, the delay in the SLCRS achieving a required pressure of a negative 0.4 inches of water could adversely impset accident assumption ,-

Subsequent to issuing the CR, the licensee provided additiona' data concoming a similar

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comment by the NRC resident inspector in 19g3. At that time, a test was run and the licensee j concluded that the flow switches would not reset before power was restored allowing a fan to restart; consequently, the licensee did not modify the circuit. The team's concem relates to the l

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repeatability of the flow switches to reset, since there is no surveillance of those switches. The licensee is considering either setting up a surveillance program to address the team's concern, or modifying the circuitry to eliminate any possibility of fan cycling as described abov This is identified as a violation of 10 CFR Part 50, Appendix B, Criterion lil, for inadequate design control (VIO 423/97-210-04).

(b) Inconsistency in IE Motor Design Requiremerm FSAR Section 8.3.1.1.4.6a requires that, unless otherwise stated, safety-related motors must be able to start at 70 percent of rated voltage. The team questioned the difference between the calculated voltage (80 percent) and the FSAR (70 percent).- The licensee responded that it recently issued a ,w calculation (8910-01542E3), which uses the worst-case minimum voltage possible at the MCC feeding the motor-operated valve. The licensee also issued action request (AR)97021088-09 to modify the FSAR to reflect that, while the valves had not been demonstrated to operate at 70 percent of rated voltage, they had been shown to be able to operate at the lowest voltage they could experience under worst-case design conditions. The team found this to be an acceptable resolutio .2 Emeroency Diesel Generatar i and Raanancer 3.2.1 Scope of Review The EDG sequencer is a solid-state device that provides relay contact outputs to shed loads, blocks appropriate manual starts and trips, and subsequently loads the plant's safety buse Operation of the sequencer is defined on Logic Diagrams 12179-LSK-24-g.4A through 9.4 During the inspection, the team compared several sheets of the logic diagrams to elementary diagrams for QSS and RSS pumps, in addition, the team compared the testing logic shown on the logic diagrams with the related surveillance procedures (SPs) 3448E11-EGLS, Auto Test Train A; SP 3448E31 Train A Sequencer Actuation Logic Test; and Sequencer Train A Actuation Timer Tes .2.2 Findings The sequencer logic is consistent with the description in Section 7.3 of the FSA .0 instrumentation and Control Quench and Racirmiatinn Sorav 4.1.1 Scope of Review

For the QSS and containment RSS, the team selected a sample of initiating signals  !

(containment depressurization actuation and safety injection), control functions (pump and valve controls), and monitoring / status functions (pursuant to Regulatory Guide (RG) 1.97, ;

" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs i Conditions During and Following an Accident," and RG 1.47, " Bypassed and Inoperable Status indication for Nuclear Power Plant Safety Systems"). The team reviewed selected setpoint calculations, logic diagrams, elementary diagrams, test loop diagrams, instrument installation l l

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details, and supporting documents. In addition, the team physically inspected selected instrument installations, such as the containment sump level instruments, the radiation monitors for the service water discharge from the RSS heat exchangers, selected SLCRS instrumentation, and control room / relay room instrumentation. The team also reviewed the licensee's RSS DCR M3-g7045, "RSS Pump Restriction Orifices to Prevent Suction Line Flashing," Revision O. This DCR included design modifications to the RSS miniflow valve control circuits. Parts of this modification were in progress during the inspectio .1.2 Findings (a) Containment Recirculation Spray Miniflow Valve Control Circuit and Flow Measurement

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The team identified two concems related to the miniflow valve control circuit. The first concem related to th6 vulnerability of the miniflow control circuit to cycling. If a false low-flow signal was postulated, the miniflow control circuit, as configured after the RSS modification, would cycle the valve open and closed until the operator detected and corrected the condition. Cycling of these valves may result in an unacceptable reduction of flow. During this cycling, the thennal overload protection for the valve motor would be bypassed. A manual bypass feature for controlling the valve was provided in the control room, but the team concluded that the operator might not detect the cycling and take control of the valves in a timely fashion under accident conditions. Consequently, the team was concemed that a postulated common-mode failure such as the plugging of the flow elements could result in cycling of the valves and possibly failure of the valve motor To address the concem about the potential cycling of tne valves and the qualification of the type of flow element used (as discussed below), the licensee committed to modify the control circuit such that postulated plugging of the flow element during an accident would not result in opening the miniflow valves and consequently diverting the flo The initially inadequate design of the circuit, which allowed the potential for cycling the valves represents another example of the violation of 10 CFR Part 50, Appendix B, Criterion 111 (VIO 423/g7-210-04).

The second concern related to the quaZeation of the Annubar@ flow element for controlling and monitoring RSS flow during recirculation with entrained particulate and debris following a loss-of-coolant accident (LOCA) , if the primary element was to become blocked or plugged, this would appear as a low differential velocity head, which could result in opening the miniflow bypass valve and diverting RSS flow for two of the four RSS pumps. In addition, the licensee uses this flow element to satisfy commitments to RG 1.g7 for a Type D, Category 2, variable, for all four pumps. A Type D variable is needed to assess the operation of an individual safety system, and an instrument supporting a Category 2 variable must have qualification .

commensurate with the required functio !

l The team agreed with the licensee that the flow element used at Millstone 3 does have design j features intended ta preclude or minimize intrusion of particulate matter and plugging of the flow l

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element. The ports on the flow element are used to sense velocity head, so partial blocksge of the flow ports may not affect the functioning of the instrument. The element also incorporates a leading edge intended to divert particulate matter away from the ports. Nevertheless, the licensee was unable to retrieve a definition for the post-accident fluid / solid composition or l

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qualification test data of these design features during the inspection. The vendor's evolution of the product line suggested to the team that the element can become plugged under certain conditions. In addition, the installed instrument is never tested under these post-accident conditions. Therefore, the team could not draw a conclusion about qualification of the type of flow element for this application. However, as discussed above, the licensee has modified the circuitry for the valves and currently these instruments do not perform safety-related function (b) Vulnerability of Redundant Process Radiation Monitors (RSS Service Water) to Flooding The team reviewed the background shielding and design features for protecting the redundant radiation detectors used to detect post-accident leakage into the service water system and 10 CFR Part 100 releases from the RSS heat exchanger. The redundant detector assemblies -

share a common concrete pit located outside the engineered safety features building near the RWST. The top of the pit is just above grade, and is protected by a concrete cover. The team requested that the licensee explain how the redundant detectors and connections would be protected from water intrusion from rain or melted snow or ice. Drawings showed a neoprene seal between the cover and the top of the pit, and a 2-inch drain line from the bottom of the pit to the inside the ESF building. Discussions with the licensee indicated that there had been past instances of flooding of the pit, which indicated to the team that the seal and drain provisions were not effective. The licensee also indicated that the sealing compound had been applied to the cover in the past, but that this activity was apparently not stipulated in maintenance /

surveillance procedures goveming the detectors. The licensee issued CR M3-98-0496 to address this conce This issue is identified as inspection Followup item (IFl 423/97-210-05) Structures and Supports Pinino Stress and Pine Sunoort Calculationg 5.1.1 Scope of Review The team reviewed Piping Stress Analysis 12179-NP(F)-X7923, " Containment Spray and Quench Spray Piping," Revision 2; Piping Stress Analysis 12179-NP(B)-163-FA,

'Waterhammer Analysis of Recirculation Spray System," Revision 3; and associated RSS pipe supports 3-RSS 4-PSST-452, -455, and 3-RSS-4-PSR157. In conducting this review, the team sought to confirm that NNECO prepared the calculations in accordance with licensing and design bases for Millstone Unit 3. Specifically, the licensing basis is documented in FSAR Chapters 3.7 and 3.9, while the design basis is documented in SDP-RSS-01361M3, " Stress Data Package," Revision 4, NETM-44; " Pipe Stress Analysis Criteria Document," Revision 2, NETM-45, " Pipe Support and Duct Support Design Criteria Document," Revision 1, and MRPM 14, " Criteria Document for QSS/RSS/SI Piping . Reconciliation," Revision Pipe Stress Analysis 12179-NP(F)-X7923 addresses the piping from the discharge nozzles of recirculation spray pumps 3RSS*P1 A-D to the inlet nozzles of the RSS heat exchangers 3RSS*E1 A-D. The calculation incorporates the orifice plates added between the pump discharge nozzles and expansion joints 3RSS*EJ1 A-D, the as-built orientation of the expansion

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joints, and the addition of the miniflow lines to trains C and D.' Pipe Stress Analysis 12179-NP(F)-X7923 also incorporates the fluid transient loads for the piping subsystem, as documented in Pipe Stress Analysis 12179-NP(B)-163-F .1.2 Findings Pipe Stress Analysis 12179-NP(F)-X7923 combines the piping seismic inertia and fluid transient loads by the square root of the sum of the squares (SRSS) instead of by the absolute su By contrast, FSAR, Table 3.9B-11, used for the analysis of Class 2 and Class 3 RSS/QSS/SI piping, specifies that these load components should be summed absolutely. Similarly, FSAR, Table Q210.36-2, used for the design of QSS pipe supports, specifies that these load

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specification used for the Millstone piping analysis, NETM 44, Table 4-5, specifies the absolute sum of these load components for piping analysis. However, Section 4.1.4.3.5 of that design specification permits seismic and waterhammer piping loads to be combined by SRS Additionally, another design specification NETM-45, Tables 3.5-2 and 3.5-5, specifies the absolute sum of these load components for pipe support design. Again, another section of that design specification (3.7.2.2) permits seismic and waterhammer pipe support loads to be combined by SRSS. The NRC's technical staff supported the team's conclusion that combining seismic and waterhammer loads using SRSS was a technically acceptable approac However, the FSAR needs to be clarified to acknowledge the use of that approac This is identified as an Inspector Followup item (IFl 423/97-210-06). Enniament Saismic and Natural Phenomena Omatifiewinn Raaarts and Enniament Support Calculations 5.2.1 Scope of Review -

The team reviewed the seismic / structural documents for recirculation spray pump 3RSS* P1C, 3RSS*E1C, expansion Joint 3RSS*EJ1C, and MOVs 3RSS*MOV20C and 3RSS*MOV23C. In the SLCRS, the team reviewed the seismic / structural documents for fan 3HVR*FN12A; charcoal filter 3HVR*FLT 3A; damper 3HVR*AOD44B; and the containment enclosure building (which forms part of the SLCRS boundary). The team reviewed the relevant equipment design specifications, vendor drawings, and seismic qualification reports. For floor-mounted equipment, the team also reviewed the equipment support and anchorage drawings and calculations. For in-line equipment, the team checked the acceleration limits for the valves, as well as the load and displacement limits and the as-built orientation for the expansion joint. The licensing basis for the seismic qualification of equipment and supports is documented in FSAR Sections 3.7, 3.8, and 3.9. The design basis is documented in NETM-34, " Structural Design Criteria," Revision .2.2 Findings (a) Vendor and Licensee Assumptions Seismic Differ with Regard to Seismic Qualification of the RSS Heat Exchanger The Joseph Oat Corporation Report No. TM-332, seismically analyzes the RSS heat exchanger for a Faulted vertical acceleration of 0.55 g. Addendum 2, of Design Specification (DS)

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I No. 2214.803-020, permits the use of a 0.55 g vertical acceleration for the safe shutdown

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earthquake if the vendor can demonstrate that the heat exchangers have a fundamental

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frequency greater than 33 Hz in the vertical direction. The Joseph Oat report assumes that the heat exchanger shell is rigid in the vertical direction, but Calculation No.12179-NM(S)-748 CZC-004 does not confirm the vertical rigidity of the heat exchanger primary support. FSAR Section 3.78.3.9 requires consideration of relative support displacements for multiply-supported )

I structures. However, the Joseph Oat report does not qualify the heat exchangers, and

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Calculation No.12179-NM(S)-748-CZC-004 does not qualify the heat exchanger supports for

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the containment structure lateral displacements attributable to the accident temperature and pressure conditions or the safe shutdown earthquake. To address these concems, the licensee j issued CR-M3-98-0204 and prepared calculation change notices (CCNs) for Calculations N .,

12179-NM(S)-748-CZC-004 and 12179-NM(B)-570-HBG. However, the licensee's CCNs_ did not evaluate the heat exchanger supports for the lateral displacements attributable to the safe shutdown earthquake. The licensee committed to revise the calculation before plant restar This is an Unresolved item pending NRC review of the licensee's revised calculation (URI 423/97-210-07).

(b) Lower Values used in SLCRS Fan Seismic Qualification than in Design Specification The design of the support for skid-mounted SLCRS fan 3HVR*FN12A documented in Calculation No.12179-NP(B)-Z545J-1289, uses lower g-values to seismically qualify the fan than the minimum g-values allowed by DS 2176.430-141. The DS permits the vendor to qualify the fan to 4.4 g horizontal and 1.10 g vertical, if the vendor can demonstrate that the fan has a fundamental frequency greater than 10 Hz. Buffalo Forge Report No. ME 82-915 documents a fundamental frequency of 30 Hz for the fan and qualifies the fan for the permissible 4.4 g horizontal and 1.10 g vertical seismic loads. However, Calculation No.12179-NP(B)-Z545J-1289 uses 0.75 g horizontal and 0.7 g vertical to design the connecting support between the skid-mounted fan and the embedment plates. Additionally, the licensee has not documented the qualification of the embedded plates for the imposed fan support load To address these concerns, the licensee issued CR-MP3-981183, it is their intention to justify changing the DS values and provide a calculation that qualifies the embedment plates. The team's review of the issues indicates that the licensee appears to have adequate bases for making these change This is an Unresolved item pending NRC review of the justification for changing the DS values and the embedment plate calculation (URI 423/97-210-08).

(c) Inadequate Documentation of Enclosure Building Qualification for Design Basis Wind FSAR Section 3.8.4 states that the wind speed design requirement for the containment enclosure building is 115 mph. The team reviewed DS No. 2190-371-442, " Category 1 Metal Siding," Addendum 2, and determined that this document did not contain a calculation the demonstrate that the containment enclosure building was designed to withstand 115 mph winds. As a result of this finding, the licensee issued AR 98001890 to track the completion of a formal calculation following startup. During the inspection, the licensee completed a preliminary calculation to demonstrate that the containment enclosure building could withstand 115-mph winds, i l

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' Operations 6.1 - Recirenlation Sorav Svstem. Quench Sorav. and Sunniamental I ==k Co!Iaction Release Svatem Emeroenev. Abnormal. and Ooeratino Praredures f 6.1.1 Scope of Review The team evaluated emergency, abnormal, and normal operating procedures; plant technical specifications; Technical Requirements Manual (TRM); FSAR description; accident analysis; and annunciator response procedures related to the QSS, RSS, and SLCR A --

6.1.2 Findings - - - - - - -- - -

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(a) Iriadaan=*a RSS Pumo Sen! Hand Tank Fill Pranadure OP 3306, " Containment Recirculation Spray System," Revision 7, provides instructions for filling the seal head tanks RSS pumps A, B, C, and D . The procedure instructs the operator to open RSS pump inboard seal valve 3RSS*V38 (pump A), 3RSS*V39 (pump B), 3RSS*V40 (pump C), -

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or 3RSS*V41 (pump D), to vent the applicable seal head tank if containment vacuum prevents the diaphragm in the seal head tank from repositioning. The team identified that opening an RSS pump inboard seal valve results in communication between the containment atmosphere and the ESF building atmosphere. The licensee issued CR M3-98-0305 as a result of this findin Table 1.8-1 of the FSAR states that the licensee complies with RG 1.141, " Containment Isolation for Fluid Systems," Revision 0, with one exception. On the RSS, the only closed system outside containment, vent / drain valves, and branch connection valves, are not locked closed. RG 1.141 endorses ANSI N271-1976, " Containment isolation Provisions for Fluid Systems." Section 3.6.7(1) of ANSI N271-1976 states that if a closed system outside containment is used as one of the two containment is' olation barriers for an ESF system,~ the closed system shall not communicate with the outside atmosphere. The team concluded that opening an RSS pump inboard seal valve (3RSS*V38, 3RSS*V39, 3RSS*V40, or 3RSS*V41)

is contrary to the requirement specified in Section 3.6.7(1) of ANSI N271-197 TS 6.8.1.s " Procedures and Programs," requires that written procedures be established, implemented, and maintained in accordance with RG 1.33, Appendix A, Revision 2, dated February 1978. The applicable portions of that standard include procedures for operating the emergency core cooling system (ECCS) and containment cooling system The failure of OP 3306 to maintain the RSS as a closed system outside of containment was ,

identified as a violation of TS 6.8.1.a (VIO 423/97-210-09). l l

(b) Inadequate Procedural Guidance for Entering TS 3. l i

, Steps 4.14 and 4.15 of OP 3314A, " Auxiliary Building Heating, Ventilation, and Air -

Conditioning," Revision 21, provides instructions for operators on shifting trains of operating I charging and reactor plant component cooling water (RPCCW) pump area ventilation fans  ;

3HVR*FN13A/B and 3HVR*FN14A/B These instructions are used when testing a train of fans l following maintenance. Steps 4.14 and 4.15 contains a note that states that when restoring l

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the A or B train of charging and the RPCCW pump area ventilation to an operable status, placing the 3HVR*FN14A or 3HVR*FN14B fans in the "off" position does not require entry into TS 3.0.3. The note instructs the operator to remain at the ventilation panel to manually start the !

fan placed in the off position if the fan being tested in the other train fails to automatically star The team concluded that it is inappropriate to substitute manual operator action for an ,

automatic safety function and declare the system operable. In this case, it is appropriate to l enter TS 3.0.3 when both trains of charging and RPCCW pump ventilation fans are not in the 4 automatic mode of operation. The licensee issued CR M3-98-0616 as a result of this findin l TS 6.8.1.s requires that written procedures be established, implemented and maintained in

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accordance with RG 1.33, Appendix A, Revision 2, dated February.1978. -The applicable portions of that standard includes procedures for operating the ECCS component The failure of OP 3314A to require operators to enter TS 3.0.3 when both trains of charging and RPCCW pump ventilation fans are not in the automatic mode of operation is another example '

of a violation of TS 6.8.1.a (VIO 423/97-210-09).

(c) Technical Specification and Technical Requirements Manual Inconsistencies TS 3.5.2 states that two independent ECCSs shall be available, and that each subsystem shall include one operable RSS heat exchanger and one operable RSS pump. By contrast, Section 3TRM-3.6.2.2 of the TRM defines an RSS subsystem as two operable recirculation pumps and two operable heat exchangers. The team concluded that the licensee's definition of an RSS subsystem was inconsistent and noted several other examples in the TRM where the RSS system and subsystems were used inconsistently. The licensee stated that these inconsistencies would be addressed during the transition to improved Standard Technical Specifications scheduled to.begin in 1999. Discussions with operators indicated that the most limiting condition imposed on any system, sut, system, or train govemed the operation of the unit. In this case, two operable RSS pumps and heat exchangers per train is the most limiting I condition and are required to be operable before entering Mode (d) inconsistent RSS Seal-Head Tank Level Annunciator Response Procedures During the review of annunciator response procedures, the team identified inconsistencies in the required responses for RSS seal head tank low level alarms. OP 3353.MB28, " Main Board 2B Annunciator Response," Revision 0, requires that operators secure the applicable RSS pump on receipt of a r,eal head tank low-level alarm. However, the procedure instructs operators not to secure the applicable RSS pump if a containment depressurization actuation (CDA) is present. The team noted that there are accident conditions, core cooling, and containment cooling, after the CDA signal clears, that require an RSS pump to operat The licensee stated that EOPs take precedence over annunciator response procedures, and operators would not secure an RSS pump if the pump was needed for any core cooling or containment cooling accident condition. The team acknowledged that it was unlike!y that annunciators would be followed (in lieu of EOPs) during an accident (either with a CDA signal present or after it clears). Nonetheless, the annunciator responses for certain equipment are inconsistent with expected plant operation and should be correcte l i

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This issue is another example of the problem detailed in the out of scope inspection and is being tracked as one example of VIO 423/97-206-1 .2 Ooerator Trainina 6.2.1 Scope of Review The team evaluated the RSS operator training modules associated with the system flow modifications specified by DCR M3-9704 '

6.2.2 Findings

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The team reviewed training modules C98109C, " Plant Design Changes," Revision 0, and C98117C, " Plant Design Changes," Revision, O. The training involved a combination of classroom and simulator training. The team found that the classroom training adequately addressed system modifications. However, the team identified several concems associated

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with the simulator training. Initially, the licensee planned to combine crews of operators during 1

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the simulator training, but changed this plan during the inspection, and was in the process of training crews individually on the simulator. The team noted that a draft revision of EOP 35 ES-1.3, " Transfer to Cold-Leg Recirculation," was used to train operators, and the training simulator had not yet been fully modified to reflect the new design change. At a meeting with the licensee on February 19,1998, regarding the overall readiness of the RSS for plant operation, the NRC team raised the issue of whether all crews had been trained on the RSS modifications using the updated simulator. The licensee has committed to respond to this issue before entering Mode Verification of training of the operators on the simulator after updating with all RSS modifications is identified as an inspection Followup item (IFl 423/97-210-10).

l' Maintenance Scone of Review The team evaluated the technical manuals prepared by the RSS and QSS pump vendors, conducted an in-depth system walkdown, and evaluate SLCRS maintenance in accordance with RG 1.52, " Design, Testing, and Maintenance Criteria for Post- Accident Engineered Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-water-Cooled Nuclear Power Plants," Revision 2, dated March 1978. In addition, the team reviewed work requests and condition reports for the following components:

e containment RSS pumps 3RSS*P1 A, B, C, and D e containment RSS heat exchangers 3RSS*E1 A, B, C, and D e SLCRS filter banks 3HVR*FLT3A and B e SLCRS Fans 3HVR*FN12A and B i

e QSS pumps 3QSS*P3A and B

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4 Findings Review of the work history for the containment RSS heat exchangers (3RSS*E1 A, B, C, and D)

l indicated that the service water side of the heat exchangers is scheduled to be flushed quarterly to remove marine growth accumulated in the dead leg leading to each heat exchanger. These flushes are performed while the unit is operating and the appropriate TS action statement j entered when a heat exchanger is declared inoperable. The team reviewed the Millstone Unit 3 Maintenance Rule Basis Document 3306, " Recirculation Spray System Maintenance Rule,"

Revision,2, and verified that the licensee was not recording the length of time the RSS was unavailable while these flushes are performed

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The team also noted that two of the RSS Maintenance Rule safety functions, containment cooling and fission product removal are classified as not risk significant. Therefore, the licensee is not recording and tracking the amount of time the RSS was unavailable during the

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flush. The team questioned why the RSS containment cooling and fission product removal safety functions are not risk significant. The licensee issued CR M3 98-0462 to address the

. risk significance determination for the RSS containment cooling and fission product removal function This is identified as inspector Followup Item (IFl 423/97-210-11).

- Surveillance Technical SascificMion Surveillance and inservice Pumo and Valve Testina 8.1.1 Scope of Review The team reviewed the surveillance procedures that implement RSS, QSS, and SLCRS TS j Surveillance Requirements 4.6.1.2.d,4.6.2.1.a.1,4.6.2.1.d,4.6.2.2.s ,b, c, and e,4.6.6. .6.6.1.b.1, 2, and 3,4.6.6.1.c,4.6.6.1.d.1, 2, and 3,4.5.5, and 4.7.4.s . In addition, the team performed walkdowns of the 3B&D RSS pumps, the QSS pumps, and RSS/QSS components in containment including the containment sump screens and sump level monitors.-

8.1.2 Findings TS 4.6.6.1.b.3 requires the licensee to verify a SLCRS flow rate of 7600 cfm to 9800 cfm when tested in accordance with ANSI N510-1980, " Testing of Nuclear Air-Cleaning Systems." In particular Section 8.3.8 of that standard states that the acceptance criteria for flow shall be within t 10 percent of system design flo The team was unable to verify that the system flow rate was tested at * 10 percent of design flow because of inconsistencies between the required SLCRS flow rates. Drawing 12179-EM-148E-12 stated that the design flow rate is 9500 cfm, while FSAR Sectio,16.2.3.3, stated that the design flow rate is 8500 cfm and SP36141.1, "SLCRS Operability Test, Train A," Revision 10, stated that the design flow rate is 8700 cfm. The licensee issued CR M3-98-0433 as a result of this finding. The licensee had previously identified the inconsistencies associated with SLCRS design flow rates, but did not identify that these inconsistencies created a conflict with

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AIiSI NS10-1980 test requirements. The team did verify that the SLCRS flow rates were tested in accordance with the TS surveillance requirement Inteorated Assessment of the RecirmMon Sorav System

' During the' inspection, the team reviewed the numercus design changes that have been made to the RSS since the plant last operated. Those changes included (1) installation of system flow orifices and the associated capping of RSS spray nozzles, (2) installation of baffle plates in the RSS heat exchangers, (3) repositioning of the pump vortex suppressors to a lower-level in the containment sump, (4) installation of vent lines on the RSS pump casings, (5) installation of recirculation capability for RSS pumps C and D, and (6) installation of fill and vent lines for the thermal expansion loops in the crossover piping to charging and safety injection. Additionally,-

the team partially reviewed a number of modifications to system operation which, at the time of the inspection, were proposed but were either not yet approved or installed. Those

modifications included reauthorizing an RSS direct injection path (an original design feature of the system that was modified to a contingency action prior to initial plant operation) and extending the assumed switchover time from injection to cold-leg recirculation from 10 to 25 minute The licensee has done extensive evaluation of each of the above modifications. However, the team could find no integrated assessment of all of the modifications, and their impact on operator training, plant / system risk models, or the assumptions of computer codes and analysis ;

methods used in the approved system design. The team's concern about the need for an i overall assessment of the cumulative impacts of the modifications was heightened by the failure of the newly installed vent line on the 3A RSS pump on January 14,1998. The event review team and its thorough report on this issue, were considered by the NRC inspection team to be a ,

notable strength. However, given that the licensee failed to properly account for the possibility

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i of such vibration, the fact that modifications had also decreased the normal pump flow rate .

(causing the pumps to operate further away from the point of best efficiency, thereby, !

. increasing the potential for additional pump-induced vibration), and the fact that the team had already raised questions regarding another modification (the change to the MOV-38 valves), the team concluded that an overall assessment was necessar Based on the teams's concems, the licensee agreed to prepare a documented overall system '

assessment. In a letter dated February 3,1998, the NRC formally requested that the licensee submit such an assessment on the docket. The licensee provided its integrated assessment in a letter February 16,1998. This is being reviewed by NRC as part of an ongoing review of the RSS system and will be addressed outside the ICAVP inspection proces .0 Evaluation of Saroent and Lundv (S&L) Activi.titt The team's review did not encompass all Tier 1 systems reviewed by S&L, but concentrated on the systems and portions of systems selected for the NRC "in scope" review (QSS, RSS, ventilation and EDG sequencer) as described in Section 1 of this repor In assessing the quality of S&L's review, the team fist compared its onsite findings with the discrepancy reports (DRs) generated by S&L. The team evaluated the DR quality, classification, and the response of the licensee to the DR, where available. The team verified that all components within the system boundaries, were reviewed by all necessary S&L

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disciplines. Finally, the team checked to ensure that programmatic areas, such as fire protection and environmental qualification, had received an acceptable review. The team noted that the number of DRs written by the S&L reviewers on the systems encompassed by the NRC onsite inspection scope, exceeded the number of findings by the inspection team. This is attributed to the significantly greater resources in terms of personnel and time, expended by S&L. The team observed that S&L had identified many issues that were similar to those identified by the tea ]

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Based on its onsite inspection of specific focus areas such single-failure and ongoing l

modifications, the team requested that S&L augment their review to include: (1) single-failure i vulnerability of electrical control circuits that have inputs from redundant trains, as a result of the SCLRS fan circuitry problem identified by the team (see Section 3 of this report); (2) a l

review by the Systems Review Group of DRs written by the Operations and Maintenance Review Group, and DRs associated with temporary modifications to determine whether there were any design weaknesses being resolved by temporary modifications or operator J

workarounds (DRs MP3-070 and 0747 are examples of DRs that should have received such an integrated review), and (3) structural calculations for fans 3HVR*FN12A&B (the team identified that review of these components had inadvertently not been performed by S&L).

The team determined that a group of calculations for structural steel component supports such as the RSS heat exchangers was not reviewed by S&L. Specifically, while the review of calculations to support seismic qualification of components was assigned to one review group, and calculations for the design of imbedded plates that secure such components to the floors and walls were assigned to another review group, neither group was tasked with the review of calculations that qualify the acceptability of structural steel connecting the components to the embedded plates. Subsequently, S&L identified the missed calculations and completed the review. No problems were identified with the calculations and the subject steel support Additionally S&L completed a quality assurance verification and determined that the review process did not miss any other calculations associated with any Tier 1 system The team noted that the DRs were generally prepared on a discipline basis and had not received a multi-discipline review and therefore did not benefit from the synergism that could be imparted by other technical disciplines. In response to the team's observation S&L committed to perform a system-based, multi disciplined review of the confirmed discrepancy reports (DRs)

to identify potential programmatic issues and to assure that appropriate consideration by each review discipline is used in characterizing each DR. The team noted that no programmatic issues were apparent in the areas assessed by the tea While the team identified issues not discovered by S&L the safety significance of the findings identified by the team was low. This provides confidence that other issues, should any be discovered, would likely be of low significanc .0 Entrance and Exit Meetinas Upon arriving onsite, the team conducted an entrance meeting to formally brief the licensee on the scope and duration of the inspectio After completing the onsite inspection, the team conducted an exit meeting with the licensee on February 24,1998, that was open for public observation. During the exit meeting, the team

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leader presented the results of the inspection. The team leader subsequently answered questions conceming the inspection at a public meeting held at the East Lyme Community Center, East Lyme, Connecticut, on March 4,1998. Appendix B presents a partiallist of persons who attended the entrance and exit . _ . -

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A-1 Appendix A List of Violations, Unresolved items, and inspector Followup items This report categorizes the inspection findings as violations (VIO), unresolved items (URIs), or inspector followup iterris (IFI), in accordance with Chapter 610 of the NRC inspection Manua A violation is a matter about which the Commission has determined that there is enough information to conclude that a violation of a legally binding requirement has occurred. A URI is a matter about which the Commission requires more information to determine whether the issue

' in question is acceptable or constitutes a deviation, nonconformance, or violation. The NRC may issue enforcement action resulting from its review of the identified URIs. An IFl is a matter for which additional information is needed that was not available during the inspectio Item Number Finding Type Section Title

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423/97-210-01 IFl 2.1.2(a) Max acceptance value for pump IST 423/97-210-02 IFl 2.1.2(b) Change of switchover time from 10 to 25 minutes 423/97-210-03 VIO 2.2.2(a) Violation for inadequate corrective action 4?.3/97-210-04 VIO 3.2.1(a) Violation for inadequate design control 4.1.2(a)

423/97-210-05 IFl 4.1.2(b) Vulnerability of rad monitors to flooding -

423/97-210-06 IFl 5.1.2(a) - Updating of FSAR on use of SRSS modeling 423/97-210-07 URI 5.2.2(a)' Review of revised calculation for RSS cooler 423/97-210-08 URI 5.2.2(b) Review of justification for design value & embed calculation 423/97-210-09 VIO 6.1.2(a) . Violation for inadequate procedures 6.1.2(b)

423/97-210-10 IFl 6.2.2(a) Verification of operator training on RSS mods 423/97-210-11 IFl 7.2(a) Risk significance of RSS functions

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B 'i Appendix B Entrance & Exit Meeting Attendees NAME ORGANIZATION Richard Laudenat NNECO-lCAVP Patricia Loftus Regulatory Affairs *

Philip DiBenedetto Recovery Oversight *

Paul Grossman Engineering

- - Denny Hicks MP3 Director * -

Joe Fougere Mgr ICAVP Martin Bowling MP2 Harry Miller MP2 Gil Olsen MP3*

Eugene Imbro NRC/ Deputy Director ICAVP/SPO+

James Luehman NRC/ICAVP/SPO Haroid Eichenholtz NRC/lCAVP Site Coordinator +

Michael Schlyamberg NRC/ Contractor *

Andrew du Bouchet NRC/ Contractor *

Stephen Tingen NRC/ICAVP SPO*

James Lievo NRC Contractor *

Ray Cooney NRC Contractor *

Tony Ceme NRC Senior Resident inspector Beth Korona NRC Resident inspector *

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C-1 Appendix C List of Documents Reviewed PROCEDUREFi Emeroency Ooeratina Procedures EOP 35E-1, Loss of Reactor or Secondary Coolant, Rev.14 EOP 35E-3, Steam Generator Tube Rupture, Rev.13

_ .Ooeratina Procedures _

OP 3261, Response to Door inoperability, Rev. 2 OP 3314A, Auxiliary Building Heating, Ventilation and Air Conditioning, Rev. 21 OP 33141, SLCRS Train A, Rev. 2 OP 3353.MB28, Main Board 28 Annunciator Response, Rev. O OP 3353.MB1D, Main Board 1D Annunciator Response, Rev. 2 OP 3353.MB2A, Main Board 2A Annunciator Response, Rev 1 OP 3306, Containment Recirculation Spray System, Rev. 7 OP 3309, Quench Spray System, Rev.12 3260B-1, Locked component Checklist, Rev. 3 Surveillance Procedures SP 3448.E11 R3 EGLS auto test Train A SP 3448 E31 R5 Diesel Sequencer Logic Test SP 3448 E51 R3 Diesel Sequencer Train A Actuation Timer Test SP 3464 A.1 (sec 4.3) Sequencer start of Emergency Gen A SP 36141.1, SLCRS Operability Test, Train A, Rev.10 SP 36141.2, SLCRS Charcoal Filter Bypass Leakage Test, Train A,B, Rev. 3 SP 3712F, SLCRS Filter Assembly Heater Surveillance Test, Rev 3 SP 36141.3, SLCRS Negative Pressure Verification, Train A,B, Rev. 5 SP 31105, Containment Quench Spray Header Nozzle Flow Test, Rev. 5 SP 3609.4, Containment Quench Spray Valve Verification, Rev. 2 SP 3609.1, Containment Recirculation Spray System Valve Lineup Verification, Rev. 8 SP 3606.1, Containment Recirculation Pump 3RSS*P1 A Operational Readiness Test, Rev.10 SP 3626.2, Sentice Water Valve Lineup Verification, Rev.10 SP 3606.4,18 Month Sequencer Response Time Test, Rev. 4 SP 3110.6, Containment Recirculation Spray Header Nozzle Flow, Rev. 5 SP 3606.10, TSP Storage Basket Volume Check, Rev. O SP 3647A.17, Train A ESF with LOP Test, Rev 10 SP 3647A.18, Train B ESF w;th LOP Test, Rev 10 SP 36128.4, Type C LLRT, Penetration No.110, Rev 2 Maintenance Procedures 01M-44-1 A, Containment Recirculation Pumps, 3RSS-P1 A,B,C,D, Rev. 4

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C-2 OIM-144-1D, Air Conditioning Units 3 HQV* ACUS 1A/B,2A/B, Re Procedure 3306, Recirculation Spray System Maintenance Rule, Rev. 2 SPROC 96-3-07,3RSS*E1A/B/C/D Flush Procedure, Re Miscellaneous Procedures EMD-82-07, Rev 1, Dynamic Analysis of Fluid Transients Utilizing NUPIPE-SW (ME-110)

EMTR-616, Rev 0, Stiffness Representation of Supports, Anchors, and Restraints for Pipe Stress Analysis and Pipe Support Design Amplified Response Spectra Summary index for MP3, Rev 9

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NETM 28, Rev 0, Millstone Nuclear Power Station Unit 3 - Surface Mounted Baseplates .

Retained by Richmond inserts and Hilti Anchor Bolts NETM 34, Rev 1, Structural Design Criteria for Northeast Utilities Service Company Millstone -

Unit 3 NETM 41, Rev 1, Procedure for the Qualification and Cataloguing of Embedded Plates With Headed Anchors NETM 44, Rev 2, Pipe Stress Analysis Criteria Document NETM 45, Rev 1, Pipe Support and Duct Support Design Criteria Document NETM 49, Rev.1, Procedure for Verification / Resolution of Equipment Nozzle Loads and Valve Accelerations - Millstone Nuclear Power Station - Unit 3 NETM 59, Rev 0, Millstone Nuclear Power. Station Structural Final Load Verification Program ESF013T, Introduction to Engineered Safety Features, dated May 8,1996 ESF013C, Engineered Safety Features, dated May 8,1996 S98102L, Simulator / Exam Guide Approval Sheet, Plant Design Change Workshop, Rev. O C98109C, Plant Design Changes, Rev. O C98117C, Plant Design Changes, Rev. 0

' DRAWINGS 12179-C.I.-RSS-19, Sheets 1,2, Rev 3, Fabrication Installation Control Drawing, ASME -

Section Ill, Code Class 2 12179-EP-79N-8, Rev 8, Containment Recirculation and Quench Spray Piping, E.S.F. Building -

Sheet 8 12179-EP-79M-8, Rev 8, Containment Recirculation and Quench Spray Piping, E.S.F. Building

- Sheet 7 D-30329, Rev 8. Temp Flex Company 10" Expansion Joint Assembly 12179-EV-308-6, Rev 6, Containment Recirculation Pump Casing Support - Sheets 1 and 2

, 25212-29164 Sheet 108, Rev 1, General Arrangement Nuclear 1202 Valve C-4352, Rev 3, Henry Pratt Nuclear Mark ll Valve HB Operator SMB000 Motor Replaceable Packing Bonnet E2-9274, Rev H, Buffalo Forge 730 L-21 Fan Assembly, Arrangement No. 4 12179-BZ-545J-137-2, Rev 2,3 Sheets, Ventilation and Air Conditioning - Auxiliary Building -

Duct Support Details B253-5905, Rev E, CVI Corporation General Arrangement - Supplementary Leak Collection and Release System - 3HVR*FLT 3A/3B 14388, Rev F, American Warming and Ventilating Inc. - DAA-P-7402 Damper w/ Ext. Linkage -

Q - Dampers 14389, Rev D, American Warming and Ventilating Inc. - Johnson 3244 & 3246 Series Actuators

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C-3 12179-EV-16A-5, -16B-5,16C-5, Rev 5, Recirculation Cooler Support & Restraints 5518 Rev 7, Joseph Oat & Sons - Recirculation Cooler - 36" 1.D. x 42'-0" O. A. H. - Assembly Details ,

5521, Rev 7, Joseph Oat Corporation - Outline Drawing for 36 3/4" x 42'-0" O. A. Recirculation Cooler 12179-EE-1 A, Rev 19, Main One Line/ Phasing Diagram 12179-EE-1K - IN 4.16 KV One Line

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l 12179-EE-1U, Rev 14,480 volt One Line Diagram bus 32T & 32U i 12179-EE-1W, Rev 12,480 volt One Line Diagram bus 32R &32W 12179-EE-1EF, Rev 12,480 volt One Line Diagram bus 32X & 32Y 12179-EE-1 AD, Rev 28,480 voit One Line Diagram (MSS 3A1 & 3B1)

12179-EE-1 AH, Rev 28,480 volt One Line Diagram (MCC 1A4)

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12179-EE-1AJ, Rev 28,480 volt One Line Diagram (MCC 1B4)

12179-EE-1AQ, Rev 28,480 volt One Line Diagram (MCC 3A2 & 3B2)

12179 ESK- 6SB 3HVR* FN6A,3HVR*AOD 20A 12179 ESK- 6SC 3HVR*FN6B,3HVR*AOD 20B 12179 ESK- 6AEC 3HVR* MOD 28A,28B 12179 ESK- 7DG 3HVR*AOD44A,44B 12179 ESK- 6SD - 6SG 3HVR*FN13/14A&B 12179 ESK- 5DG 3QSS*PP3A&B 12179 ESK- SCP 3RSS*PP1B 12179 ESK- 5CN 3RSS*PP1B 12179 LSK 24-9.4A thru 9.4Z 1279-EM-112C-21, Piping and Instrumentation Diagram, Low Pressure Safety Injection / Containment Recirculation ,

1279-EM-115A-23, Piping and Instrumentation Diagram, Quench Spray & H2 Recombiner l 1279-EM-146C-14, Piping and Instrumentation Diagram, Fire Protection 1279-EM-148A-26, Piping and Instrumentation Diagram, Reactor Plant Ventilation 1279-EM-148C-14, Piping sind Instrumentation Diagram, Reactor Plant Ventilation 1279-EM-148D-F, Piping and Instrumentation Diagram, Reactor Plant Ventilation 1279-EM-153A-22, Piping and instrumentation Diagram, Containment Structure Ventilation '

12179-EK-14A, Rev 5, Containment Vacuum & Leakage Monitoring 12179-EK-514001, Rev. 2, 3LMS*PT934 12179-EK-514003, Rev. 2,3LMS*PT936  :

12179-EK-514004, Rev. 2, 3LMS*PT937 12179-EK-512059, Rev. 2, 3RSS*FT388 12179-EK-526057, Rev. 2, 3RSS*FT38A 25212-28876, Sh. 3, Rev. 2, 3LMS*PT935 12179-EM-112C, Rev. 21, Low Pressure Safety injection / Containment Recirculation 12179-EM-115A, Rev. 23, Quench Spray and Hydrogen Recombiner 12179-EM 148A, Rev. 26, Reactor P; ant Ventilation

- 12179-EM-148B, Rev.17, Reactor Plant Ventilation 12179-EM-148E, Rev.12, Reactor Plant Ventilation 12179-LSK-22-1A, Rev. 6,11/29/97, Auxiliary Building Pienum to Stack FN-6A 12179-LSK-22-1G, Rev. 7,5/17/95, Auxiliary Building Supply FN-14B 12179-LSK-22-1H, Rev. 9,11/29/97, Auxiliary Building Exhaust FN-13A/B 12179-LSK-22-1R, Rev. 7,7/25/97, SLCRS Exhaust FN-12A/B 12179-LSK-22-1V, Rev. 7,11/29/97, Auxiliary Building Plenum to Stack FN-6A 12179-LSK-22-1W, Rev. 6,11/29/97, Auxiliary Building Plenum to Stack FN-6B i

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i C-4 12179-LSK-22-1AA, Rev. 4,11/3/97, Auxiliary Building Supply FN-14A 12179-LSK-27-11A-L, Rev.10,10/26/97, Containment Recirculation Spray System 12179-LSK-27-12A-F, Containment Recirculation Spray System 12179-LSK-27-18A C, Containment Depressurization Actuation 25212-28457 Sheet 8, Rev. 9,6/12/87, Logic Diagram, Containment Recirculation, and DCN DM3-00-1567-97 page 15, Rev. ESK-5CN, Rev.13, 3/11/94, Containment Recirc Pump 3RSS*P1 A 12179-ESK-5CP, Rev.14, 5/6/97, Containment Recirc Pump 3RSS*P1B 12179-ESK-5CR, Rev. ii, Containment Recirc Pump 3RSS*P1D 12179-ESK-5DG, Rev.12,1/12/95, Quench Spray Pump 3A 12179-ESK-5DH, Rev.11,6/13/86, Quench Spray Pump 3B

. 12179-ESK4LD-Q,-RSS - - - - -- - - - - -- -- -

12179-ESK-6LS, Rev.10,8/16/95, Quench Spray Header isolation SQSS*MOV34A 12179-ESK4LT, Rev. 9, 8/95, Quench Spray Header isolation 3QSS*MOV34B 12179-ESK-6AEC, Rev. 4,1/23/87, MOD 28A/B 12179-ESK4AFE, Rev. 5,5/18/97, Auxiliary Building Filter 3HVR*FLT1A 12179-ESK4AFF, Rev. 4, Auxiliary Building Filter 3HVR*FLT1B 12179-ESK4AFL, Rev. 8, 5/24/95, RSS Miniflow 3RSS*MOV38A 12179-ESK-6AFM, Rev. 8,5/24/95, RSS Miniflow 3RSS*MOV38B 12179-ESK4AHB, Rev. 4,11/19/86, Interlocks j 12179-ESK-6SB-G, Auxiliary Building 12179-ESK4SK, Rev.10,10/4/94, SLCRS Exhaust FN-12A 12179-ESK4SL, Rev.11,1/12/98, SLCRS Exhaust FN-128 12179-ESK-7ACP, Rev. 4, 5/24/93, Interlocks 12179-ESK-7QZ, Rev. 8, Interlocks 12179-ESK-7VM, Rev. 9, 9/17/96, Test 12179-ESK-7VN, Rev. 8, 3/21/97, Test 12179-ESK-10GJ, Rev. 8,12/28/93, Annunciator HVR07 12179-ESK-10KN, Rev.11,5/6/95, Annunciator 2582 12179-ESK-10KQ, Rev.12,4/18/95, Annunciator 1128 12179-ESK-10KS-W, Rev. 15,12/4/96, Main Control Boad Annunciator 12179-ESK-10KW, Rev.12,6/5/95, Annunciator input List 1838-1844, RG 1,47 Bypass Indicators - MB ESK-10LB, Rev. 8, 6/8/90, ESF Status - Annunciator 2161 25212-32001 Sheet 6AFL, Rev. 8,8/24/95, Elementary Diagram 480 V MC Containment Recire Pump Miniflow Valve (3RSS*MOV38A), and DCN DM3-00-1685-97 Page 22, Rev. LMS-934-1-4, Test Loop Diagram, Containment pressure 12179-3LMS-935-1-4, Test Loop Diagram, Containment pressure 12179-3LMS-936-14, Test Loop Diagram, Containment pressure 12179-3LMS-937-1-4, Test Loop Diagram, Containment pressure 12179-3HVR-088A, Rev. 2, Test Loop Diagram, 3HVR*FE88A&B 12179-3QSS-056A, Rev. 3, Test Loop Diagram, SQSS*TK1 Level Control & Status 12179-3RSS-038A, Rev. 3, Test Loop Diagram, RSS Flow 12179-EE-1BF(30081), Rev.,120 Vac Panel 3VBA*PNL-VB1 12179-EE-1BG(30082), Rev. ,120 Vac Panel 3VBA*PNL-VB2 S&W DWG. NO.12179-EM-133B-34, Service Water S&W DWG. NO.12179-EM-152A-C, ESF and MSV Buildings Ventilation

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C-5 CALCULATIONS 12179-NP(F)-X7923, Rev 2, Containment Spray and Quench Spray Piping - ESF Building, ASME lil, Class 2 Pipe 12179-NP(B)-163-FA, Rev 3, Waterhammer Analysis of Recirculation Spray System 12179-NP(B)-Z79B-452, Rev 1, Design of Pipe Support: 3-RSS-4-PSST-452 12179-NP(F)-Z798-455, Rev 0, CCN 1, Design of Pipe Support: 3-RSS-4-PSST-455 12179-NP(F)-Z798-157, Rev 3, CCN 3, Design of Pipe Support: 3-RSS-4-PSR157 SDP-RSS-01361M3, Rev 4, Containment Recirculation Spray System Stress Data Package

. NC270(CALC), Rev 2, Senior Flexonics Inc. Expansion Joint Design Calculations '

12179-NM(B)-182-HBC, Rev 4, Containment Recirculation Pump Supports / Restraints 12179 C48.1, Rev 2, Containment 3RSS*P1A, P1B, P1C, P1D Pump Support.Embedmonts 12179-SEO-C48.1, Rev 2, Containment Recirculation Pump Support 3RSS*P1 A, P1B (ESF Building) P1C, P1D Recalculation of Bearing Stress for E&DCR F-J4017 12179-NM(S)-748-CZC 001, Rev 0, CCN 3, Nozzle Evaluation of the Containment Recirculation Pump 3RSS*P1A to *P1D 2214.802-044(M044), Add 2, Mcdonald Engineering Analysis Company Report ME 696 -

Seismic - Stress Analysis of Containment Recirculation Pumps 2214.802-044, Add 6, Seismic Analysis 74F31440 of Recirculation Pump Motors 12179-NM(S)-699-CZC, Rev 0 Technical Justification for E&DCR PJ-7153 Mounting Details for 3 RSS-MOV 23A, B, C and D 2382-200-164 (M164), Rev 2, Henry Pratt Addendum I to Stress Report for 12" NMKil W/SMB0002/H1BC 2362-200-164 (M164), Rev 0, Henry Pratt Stress Report for 10"NMKil w/SMB0002-HOBC -

Nuclear Class 2 Per Section lil, ASME Boiler and Pressure Vessel Code 2545J-1289, Rev 0, Design of Duct Support: 3-HVR-2-DSA 1289 ME 82-915, Rev 0, Ruffalo Forge Seismic Analysis of Fans 3HVR*FN12A, HVR*FN12B HC-1188, Add 2, Hissong Consultants Seismic Stress Analysis of Filter Units 3HVR-FLT-1A/1B, 2A/2B & 3A/3B 80271-301, Rev C, American Warming and Ventilating Inc. - Seismic Qualification of Damper Assemblies 12179-NM(B)-165-HBB, Rev 3 (Superseded) Calculations for Recirculation Spray Cooler Support and Restraints 12179-NM(S)-748-CZC-004, Rev 3, Support and Restraint Design for Containment Recirculation Coolers 3RSS*E1A-D 2214.803-020, Rev 1, Joseph Oat Corporation Seismic Analysis of Recirculation Cooler 12179-NM(S)-748-CZC-004, Rev 3, Add 2, Support and Restraint Design for Containment Recirculation Coolers 3RSS* eta, B, C & D 12179-C749.4, Rev 0, Equipment Support Embedmont Check - 3RSS*E1C - CFSK 749B-E40 (ESF Building)

12179-CFSK-7498-E40, Rev 0, Qualification of Embedded Plate Mllstone 3 Emergency Generatorloading and starting KVA NL-038 Rev 2 Voltage Profile Station Service NL-040 REV 1 Undervoltage Protection Scheme relay settings MP3 NL-042GE Rev 2 MP3 Degraded Protection Scheme relay settings MOV8910-01542E3 Rev 0 89-10 MOV Electrical Sizing 12179-195E Verify cable selection for 6.9 & 4.16 KV loads 12179-67E & 74E Maximum cable length for continuous duty motors 12179-64E Cable sizes for MOV feeders

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C-6 Calculation 12179-US(B)-253, Revision 5, " Documentation of LOCTIC Data Deck for Millstone Unit # 3 LOCA" Calculation US(B)-295, Revision 6; *RWST Draw-down Rates and Switch Over Levels Calculation 12179-US(B)-312, Revision 0, " Degraded Quench Spray Flow for Containment Integrity Analysis'

Calculation 12179-US(B)-342, Revision 2. " Recirculation Spray Heat Exchanger UA's - Spray &

LHSI roe culation mode Calculation 0307 AUS(B)-361-0, Revision 0, " Containment Recirculation System (RSS) and Safety injection System Hydraulic Analysis" Calculation 03075-US(B)-362-0, Revision 0, " Containment Recirculation System (RSS) Suction Hydraulic Analysis including insulation Debris Transport, Water Holdup, and Available

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Calculation 12179-P(R)-1096, Revision 0, CN 2, " Summary of QSS System One and Two (3GSS*P3A,B) Pump Operation w/ varying RWST Level & Containment Pres * I Calculation 610P(R)," Pressure Drop Across 3RSS-R039A-B" Calculation 12179-US(B)-249, " Determine Maximum Water Level Inside Containment Following LOCA" WCAP-10991, Westinghouse Setpoint Methodology for Protection Systems - Millstone Nuclear Power Station Unit 3,24 Month Fuel Cycle Evaluation, (T.P. Williams, J. R. Reagan, R. Tuley) Revision 5, August 1997 (pressurizer pressure /SI initiation and containment depressurization actuation from containment pressure).

NSP-101-RSS, 3RSS*FT38A, B - Setpoint for Miniflow Recirculation Line Operation of 3RSS*MOV38A,B, Revision 1,10/17/9 B03-01232 E3, RWST Level Interlock Channel Calibration, Revision 00 and CCN 1, 12/13/0 US(B)-225, Quench Spray Header Fill Time, Rev. 6 1 PLANT DESIGN CHANGE REQUESTS I DM3-00-0613-97, Rev 0, install 4 Inch Recirculation Line Between 3RSS*P1C Suction and Discharge Lines M3-97063, Rev 0, RSS Expansion Joint / Support Modifications M3-97042, Rev 0, Addition of RSS*P1C,D Test Recirculation Lines and Ultrasonic Flowrate Transducers for 3RSS*P1 A,B,C,D Recirculation Lines .

M3-97045, Rev B, RSS Pump Restriction Orifices to Prevent Suction Line Flashing l DM3-02-1178-97 3HVR*FNSA wiring  !

DM3-05-1178-97 3HVR*FN6A,6B sealin circuit l DM3-08-1178-97 3HVR*FN6A,6B added time delay I DM3-S-0256-96 correct workaround i DCN DM3-S-574 94, " Containment Sump Wide Range Level Indicators Protective Shrouds,"

May 25,199 PDCR MP3-94-154, Rev. O, and DCN DM3-S-874-94, SLCRS Boundary Differential Pressuro l Indicating System i SPECIFICATIONS NU Specification SP-M3-lC-022, Rev. O,6/6/97, " Millstone 3 Design Basis to Respond to Regulatory Guide 1.97.*

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l Specification No. 2190-371-442(C442), Category 1 Metal Siding, Addendum 2 l

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C-7 Specification No. 2214.602-040, Quench Spray Pump, Re . LICENSING DOCUMENTS FSAR, Chapter 5,6, and 15 Engineered Safety Features I FSAR Section 1.8, 9.2.1, 7.3,7.5,7.6,9.4,1 ' Millstone Unit 3 Technical Specifications and TRM OTHER DOCUMENTS / MANUALS REVIEWED -

SP-ME-572, Rev 2, Piping Classes for Millstone Nuclear Power Station Unit 3 - QA Category I 3DBS-NSS-003, Rev 0, Design Basis Summary for the Containment Recirculation Spray . -

System MRPM 14, Rev 1, Criteria Document for QSS/RSS/SI Piping Reconciliation - Millstone Unit 3 2280.000-149 (M149), Add 1 to Rev 13, Piping Engineering and Design ASME lil, Code Class 1,2, and 3 - ANSI B31.1, Class 4 2332.910-669 (M669), Add 3, Metallic Expansion Joints 1 2214.802-044, Rev 1, Specification for Containment Recirculation Pumps - ASME Code, )

Section lil, Class 2 (M044)

OlM-044-001 A, Rev D, Containment Recirculation Pump i

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SP-ME-784, Rev 1, Henry Pratt Functional Qualification Program for Power Operated Safety Related Active Butterfly Valve Assemblies - Report Number: D-99925-09

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2362.200-164, Add 1, Butterfly Valves - Flanged and Wafer Type  !

2176.430-141, Rev 3, Add 1, Specification for Centrifugal Flow Fans I 2170.430-065, Rev 1, Specification for Special Filter Assembles

2472.900-594, Add 1, Air and Motor Operated Air Dampers  ;

2214.803-020(M020), Add 5, Containment Recirculation Coolers j

- OlM-020-001A, Rev B, Con,tainment Recirculation Coolers l Engineering Evaluation M3-EV-97-0302, " Comparison of LOCA Profiles *

Evaluation M3-EV-970314, " Evaluation of RSS Heat Exchanger inlet and Outlet Pressure * ,

MPR Associates Report MPR-1864, " Millstone Unit 3 - The Effect of Trapped Air on Startup of l RSS Pumps Afte'r a LOCA"

3DBS-NSS-002, Rev. O, 5/23/97, Quench Spray System 3DBS-NSS-003, Rev. O, 5/27/97, Containment Recirculation Spray System i 3DBS-BOP-004, Rev. O,7/23/97, Heating, Ventilating, and Air Conditioning Systems Dieterich Standard, Inc. Letter from Greg Dubbe, Application Engineer, to Bob Bumham, Northeast Utilities, subject: Plugging information, dated January 21,1998 (includes attached Dietrich Standard, Inc. Technical Brief addressing plugging of Annubars) ,;

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D-1 Appendix D List of Acronyms ABVS auxiliary building ventilation system ANSI American National Standards institute AR action request CCN calculation change notice CDA containment depressurization actuation CFR Code of FederalRegulations CMP _

Configuration Management Plan , _ _ ,

CR condition report DCR design change request DR deficiency report DS design specification ECCS emergency core cooling system EDG emergency diesel generator EOP emergency operating procedure 1 ESF engineered safety feature l FSAR Final Safety Analysis Report

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ICAVP Independent Corrective Action Verification Program IFl Inspection Followup item l

LOC loss-of-coola'nt' accident  !

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l l MCC motor control center i MOV motor-operated valve

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NNECO Northeast Nuclear Energy Company i NPSH4 not positive suction head available l NRC U.S. Nuclear Regulatory Commicsion NRR Office of Nuclear Reactor Regulation (NRC)

OP operating procedure P&lD piping and instrumentation diagrams PDR Public Document Room (NRC)

QA quality assurance QSS quench spray system

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D-2 RG Regulatory Guide 1 RPCCW reactor plant component cooling water RSS recirculation spray system RSST reserve station service transformer RWST refueling water storage tank l

S&L Sargent and Lundy j SLCRS supplementary leak collection and release system SPO Special Projects Office (NRC/NRR)

SRSS square root of the sum of the squares SSFI safety system functional inspection

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TRM' TechnicalRequiremen~t's Manual TS Technical Specification URI unresolved item VIO violation i

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• ' ( In:pecti:n R: port 50-423/97-210 bistribution for letter to M. L. Bowling - Dated April 3,1998

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Distribution w/ enclosures:

Region i Docket Room (with ngpy of concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC File Center (with Original concurrences)

SPO R/F NRC Resident inspector OE (2)(EA Packages Only)

W.Axelson, ORA (Inspection Reports)

S. Collins E. Imbro S. Reynolds E-Mail

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W. Travers W.Lanning M.Callahan, OCA B. McCabe, OEDO P. McKee 2:Fi .. !

P. Kottay * A

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{d J. Luehman S.Tingen 6 73 %

$ i }n j J. Nakoski MO ,

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D. Mcdonald j '

S. Dembek  %$p3 'h, J. Andersen D.Screnci, PAO gy 53 o-

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Inspection Program Branch (IPAS)

B. Jones, PIMB/ DISP l

l l l

l l DOCUMENT: A:JLUEHMAN.M3 l

OFFICE ICAVP:SPO TechE ICAVP ICAVP DD:lCAVP NAME JLuehMsJr PKoltay , SReynolds Elmbrb DATE I/3dd 3/19/98 ' 3/

H U / / /NI 9[

OFFICE D:SPO NAME WTravers DATE / /

OFFICIAL RECORD COPY