ML20151S908
| ML20151S908 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/02/1998 |
| From: | Curry D External (Affiliation Not Assigned) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUM2-PPNR-1964, NUDOCS 9809090105 | |
| Download: ML20151S908 (21) | |
Text
- .
I
~
PARSONS Daniel L Curry, Vice President. Nucles Services Parsons Energy & Chemicals Group Inc.
2675 Morgantown Road a Reading, Pennsylvania 19607 * (610) 855-2360 + Far (610) 855-2602 September 2,1998 g
Docket No. 50-336 Parsons NUM2-PPNR-1964-L U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Millstone Nuclear Power Station Unit No. 2 Independent Corrective Action Verification Procram (ICAVP)
. Gentlemen:
This letter transmits summaries of telephone conferences between Parsons Power Group Inc., the U. S.
Nuclear Regulatory Commission, NNECo and August 4, August 6, August i1, August 13, August 18, August 20, August 25, and August 27,1998.
Please call me at (610) 855-2366 if you have any questions.
fl Sincerely, II N
674 Daniel L. Curry Parsons ICAVP Project Director DLC:djv Attachments Telephone Conference Notes for August 1998 gh cc:
E. Imbro (2)- USNRC J. Fougere - NNECo R. Laudenat - NNECo Rep. Terry Concannon - NEAC Project Files 9809090105 9009027 PDR ADOCK 05000336 P
PDR PPNR19M. doc
I DATE:
8/4/98 PURPO5iE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
Unit 1 Impacts on Millstone Unit 2
Parsons Requested DRs for Discussion LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Joe Fougere Eric Benner Wayne Dobson Ray Necei Gordon Chen Dave Bajumpaa Richard Boyd Peter Talbot Dan Wooddell Bob Skwitz Colin Patton Ron Jackson Trent Powers Fred Mattioli Greg Tardif 1.
Topic : Single Failure assumptions of the ARV n stem for Chapter 14 transient analyses (Gordon Chen) - (Continuation of Topic # 2 from 7/30/98)
Background : For the analyses of Loss of No :. ' % water (E-6855-595-1, Rev. 0 ) and Small Break LOCA ( M2-EV-98-0070, Rev.0 ), the single failure of the AFW system is based on the failure of one AFW pump. He AFW flow is available to both Steam Generators through control valves FW-43A and FW-43B, with values provided by the Proto-Power calculation ( 97-ENG-02053-M2, Rev. 2 ). The control valves are opened by AFW initiation signal.
Question :
a) If one of the AFW control valves, RV-43A or RV-43B, were to fail closed on AFW initiation, then the resultant AFW flow is available to only one Steam Generator. Please identify what justifies control valve failure as being bounded by the AFW pump failure case?
Discussion: NNECo indicated the singlefailure ofthe AFIVcontrol valve, FIV-43A or FIV-43B, was not included in the safety analyses. A DR will be generated to initiate the evaluation ofthe impact to the affected analyses.
2.
Topic: Unit 1 impacts on Millstone Unit 2. (Rort Smith) -(Continuation of Topic # 3 from 7/30/98)
Question:
a) Based on the recent announcement regarding Unit I what is NNECo's plan for addressing those Unit I features / functions for which Millstone Unit 2 has taken credit for operation?
Discussion:. Unit 1 is still a licensedplant and will be maintained within its Tech. Specs. Theformal interface plan between Unit 2 and Unit ] will continue to be maintained. Based on this, the ICA VP will assume that Unit ] will continue toprovidefeaturesfunctionsfor which Millstene Unit 2 has taken creditfor.
PAGE 1
\\.
.~
l CONFERENCE NOTES Aygust 4,1998 3.
. Topic: IPEEE and IPE Site Flooding. (Ron Smith)-(Continuation of Topic # 4 from 7/30/98)
Questions:
a) What is the Millstone procedure (s), similar to that used for the floor drain features covered in MP 2701J, that cover inspection and repair of all plant features that are taken credit for mitigation of site flooding for both IPEEE and IPE. Features of concern are building seals for the structures such as the
. EBFS, duct banks and other building penetrations.?
Discussion:.. Otherprocedures that address this issue are SP-2665 rev 4 which covers inspection of buildingfloodgates anddoors, and ONP-514A, rev. 7 which addresses preparationsfor natural events.
NNECo described designfeatures used to mitigate siteflooding such as building seals, etc. and stated normal operations rounds wouldidentify ifany ofthese items were allowing leakage.
4.
Topic: DR. (Trent Powers)
Background:
Parsons requested topic to discuss the DRs listed below. So far there has not been resolution on the issues described below. This discussion should focus on if agreement can be obtained. Otherwise. Parsons suggests the item (s) be referred to the NRC for resolution.
DRs for Discu aion:
a) DR-0036 - Item #1 of DR - Parsons does not concur that SP 21136 satisfies the requirement to verify 2-SI-659 and 260 fail open on loss of air to the valve operator.
Action:.. Parsons willprovide NNECo with its response, NNECo will review the response and inform Parson ifthis DR should be sent to the NRCfor resolution.
b) DR-0046 - Items # 1&2 - Not addressed in M2-PR101-0222EM Rev l-data appears to still be missing in Section 6.8.4.
Attachment D lists Cavitating Venturi in Table of Contents but is not attached to stress report. Attachment F Interface Information memo in TOC but not in report. Data from Stress Problems 25 & 100 not included in anchor loading tabulations on Section 6.12, pages 42
& 43.
Adlon:.. NNECo agrees the DR response didnotprovide all ofinformation. They willprovide a supplementalDR response. Parsons willholdits comment for the additionalinformation.
c) DR-0048 -Item #6 - M2PR101-222EM Rev 1 dated 3-18-1998 does not resolve item 6. 27 of the 34 supports listed on pages 36 thru 40 of section 6.12 show that design loads exceed the design loads listed on the support drawings. No explanation of this has be identified.
Action: NNECo agrees the DR response didnotprovide allofinformation. They willprovide a supplemental DR response. Parsons will holdits commentfor the additionalinformation.
PAGE 2
CONFERENCE NOTES Argust 6,1998 DATE:
. 8/6/98 PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
- 1. Containment High Range Radiation Monitors - PDCR 2-116-80 2.
Parsons Requested DRs for Discussion LIST OF ATTENDEES:
NNECo NRC NEAC Persons Joe Fougere Enc Benner Wayne Dobson Bob Skwirz Trent Powers Greg Tardif Amrit Kaptish Rich Ewing Norbert Carte 1.
Topic: Containment liigh Range Radiation Monitors - PDCR 2-116-80 (Amrit Kaptish / Ken Mayers)
Background:
Rockbestos coaxial cable RSS-6-104 was bought and used in the above Modification package.
Rockbestos letter dated July 28, 1981 from G.G. Littlehales to NUSCO Quality Assurance Manager confirmed that Rockbestos coaxial cables RSS-6-100 through RSS-6-112 may be subject to failures at temperatures above 230 F. Rockbestos advised NUSCO not to use these coaxial cables in an emironment where they may be subject to temperatures above 230* F.
In their above referenced letter, Rockbestos confirmed that testing and qualification of modified prototype cables was expected by November,1981.
NUSCO Letter No. GEE-81-657, dated August 10,1981 from J. S. Nicosia to R. M. Kacich also informed their Licensing about the Rockbestos coaxial cable RSS-6-104 problem that was used at NUSCo's three operating Units.
NUSCo's Inter Office Memo from Ralph Bates to Mark Bates dated 2/24/82 stated that the four cables listed in Reference GEE-81-992 have been replaced and the associated containment high radiation monitors RM8240 and RM8241 have been placed in ser ice.
There are no documents in the PDCR package that indicate what replacement coaxial cable was supplied and installed in this modification.
Questions:
a) What replacement coaxial cable was supplied by Rockbestos and under what documents (Purchase Order etc.)?
b) What are the Specifications of the replacement coaxial cable, i.e., the emironment (temperature, pressure, humidity, radiation etc.) for which it is suitable?
Response: Rockbestos cable RSS-6-104-108) wasprocuredper NNECo Specification #SP-GEE-34 and Purchase Order #808659. The specifications ofthis cable have been put into EQR 121-01 (draft). The cable has been tested to 345*F,122.4 psig,100% relative humidity, chemical spray and 171 Mega RAD. It is goodfor Containmentfor 402 days post-accident. It meets or exceeds requirements ofMP2.
2.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
PAGE 1
_. = _. _.. _ - --.
CONFERENCE NOTES August 61998 DRs for Discussion:
a) DR-0499 - Motor H.P. Discrepancy Between Calculation and Installed MOV'S (Trent Powers)
This DR was discussed on a previous conference, at which Parsons agreed it could be closed. We are in the i
process of closing this DR and want to clarify the final disposition. We agree that the current plant
]
configuration matches the current design basis, (i.e. Calculation 97-ENG-01840E2, Rev.01, dated 2-23-98).
However, this calculation was dated 2/23/98. At CMP complete it appears that the calculation of record, (PA84-063-0714-GE, Rev. O, Change 01) used a A.C Motor Performance Curve for a 5.3 hp motor when the plant had a 6.6 hp motor installed. NNECo's last written response identified this as non-discrepant.
l Discussion:.. For the calculation PA84-063-0714-GE, Rev. O, Change 01 done in 1990, the 5.3 hp curve was used because NNECo was not able to obtain a curvefor a 6 hp motor. The calculation used a l
locked rotorfactor to accountfor the difference between 5.3 and 6 hp. It wasjudged that this approach was acceptable because the thermal overload sizing only affected an alarmfunction. The calculation, however does not document thefactor or why it is used. NNECo andParsons agreed this will be closed as a level 4 DR since the calculation was deficient in documenting its assumptions. No corrective action is needed as this calctdation has been superseded.
i
[
I f
f I
h I
t
}
I
[
I t '.
PAGE 2 1
-. ~ - -. -
CONFERENCE NOTES A gust 11,1998 DATE:
8/11/98
{
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
- 1. Discrepancies in Calculation MP2CRANC "MP2 Control Room Cabinets Anchorage Evaluation"
- 2. Parsons Requested DRs for Discussion 3.
Parsons Requested DRs for Discussion LIST OF ATTENDEES:
NNECo NRC NEAC Parsor.
Joe Fougere Eric Henner Colin Patton Bob Skwitz Don Marks Fred Mattioli Trent Powers Bob Weth Roger Mauchline Tom Moore Bob Moyer Farid Elsabee Dan Wooddell Vere Joseph Richard Boyd Roy Terry Harold Thompson
)
1.
Topic: DR-0133 - Discrepancies in Calculation MP2CRANC "MP2 Control Room Cabinets Anchorage Evaluation"(Roger Mauchline)
Background:
We would like some clarfication of Response M2-lRF-02275 on DR-0133 Questions:
1 a) On page 3 bulleted item: Please explain "7 anchor locations". The MP2 CRANK calculation p.18 shows 3 anchors per side of cabinet, which would give a total of 9 anchor locations for a line-up of three cabinets.
b) On page 4, bulleted item: Is the 1.375" eccentricity based on an assumed location of the cabinet on the 6" channel or an "as built" location?
Response
a) Number ofanchor locations clarifled.
b) NNECo will walkdown the cabinet to verify weldplacements.
2.
Topic: DRs i
Background:
Parsons requested topic to discuss the DRs listed below.
I DRs for Discussion:
a) DR-0346, Service Water Pump "C" Repair Package (Larry Collier) Item #3 - We need an explanation of the NNECo response. The documents we have state that the depth ofone cavity is 1 % inches and the depth of the other cavity is 1 inch. The response to this discrepancy did not state if the material thickness at the first point of repair would accommodate the 1 % inch excavation. Also, NU did not at all address d
the 2 repair cavity which was recorded as 1 inch. Base on this we do not understand NNECo's interpretation of the repair documents.
PAGE 1
. ~.
CONFERENCE NOTES A gust 11,1998 Response: Deferred to 8/1M8.
3.
. Topic: DRs
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-056 ' PRT Member: Bob Weth and Vere Joseph. Follow-up Response. NU to present information to show j
that LB is met and to provide clarification of FSAR statements.
b) DR-359 PRT Member: Farid Elsabee, Roy Terry, Harold Thompson. Discuss items 1 &2 Response.
i Clarification of Topic 3.
Response
a) NNECo willprovide afollow-up response which shows that Aux Feedinitiation during increasing power l
between 20 and 25% with an A TWS event is already boundedin an existing evaluation ofsystem performance.
i b) NNECo willprovide afollow-up response which explains how Unit 2 is protectedfrom conditions related to a i
possible cask drop.
1 i
]
1
)
i l
1 I
PAGE 2 l1 i
_ _ - ~ _ - =
CONFERENCE NOTES Acgust 13,1998 DATE:
8/13/98 PURPONE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Document Status and Program Planning l
- 2. Accident Analysis Tracking i
- 3. NNECo Requested DRs for Discussion LIST OF ATTENDEES:
NNEco NRC NEAC Parsons j
Joe Fougere Eric Benner Richard Boyd Bob Skwirz Don Marks Fred Mattioli
~
Ron Smith Hugh McKenney Rich Glaviano Rich Ewing ClitIMarks I
Ron Jackson Clark Tracy Norbert Carte Ken Mayers Zack LaPlante John Ililbish Greg Tardif i
1.
Topic: Docwnent Status and Program Planning (Ron Smith)
Background:
The following information is needed to allow Parsons to develop program resiew plans utilizing a sampling approach.
Questions: Please provide completion dates or the dates when the following documents will be made available to Parsons:
I a) EQ Program Manual-EQ program manual is not undergoing revision and the current revision is Rev 3..
'l b) SP-EE-352-Willinclude the EQ reports and will be issued when program is done.
c) SP-EE-332---&'31/98 d) Appendix R Compliance Report-lG'15/98 e) Appendix R AOPs-10'15/98 f) Appendix R Manual Action Evaluations-/G'15/98 g) Unit 2 Fire Hazards Analysis Report-10'15/98 i
h) A listing of all EQ Test Report Assessments and EQ Qualification Reports-Millstone to provide list and schedulefor issue ofeach via e-mail to Ron Smith.
Note:
Appendix R items can not be released in stages.
Response: Indicated above in italics.
2.
Topic: Accident Analysis Tracking (Ron Smith)
Background:
N/A PAGE1
m CONFERENCE NOTES Aygust 13,1998 Questions:
- a) Please describe how NNECo is tracking and resolving changes resulting from the revised accident analysis from the current analysis of record.
b) - Are these changes identified.and tracked in your corrective action program?
Response
a) Millstone uses the DCM ERCpr>cessfor controlling inputs to accident analysis from engineering.
{
Vendor analysis changes are al.;a handled through the FSARCR process. Millstone performs a review ofthe vendor analysisfor acceptance which is done to a procedure. Thisprocedure does not have aformal review i
checklist process. Set point changes would be handled through the coordination eforts with engineering. If i
an analysis results in changing input values, this is handled by engineering via the issue of a revised ERC.
For none numerical changes such a added manual actions these art handled through and informalprocess.
l b) NotApplicable.
i l
3.
Topic: DRs i
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-553 PRT Member: Ron Jackson, Bo Pokora. Follow-up response. NU to present information to show i
that Steam Driven AF Pump Room doesn't require emergency light units.
b) DR-508 PRT Member: Norbeit Carte. Discussion of Drawings 25203-28400 & 25203-28402 Sht. D12A l
k Discussion:
a) NNECo will send DR response to Parsons.
i b) The centralissue ofthe DR was claroped andNNECo willsupply a response.
i 1
l-I'
)'
(
u 1
I 1
s PAGE 2 I
CONFERENCE NOTES
)
Argust 18 1998 9
DATE:
8/18/98 PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
I 1.
DR Level Clarification 2.
Parsons Requested DRs for Discussion
- 3. NNECo Requested DRs for Discussion LIST OF ATTENDEES:
NNECo NRC NEAC Panons
_ Joe Fougere Eric Benner Trent Powers l
Bob Skwitz Don Marks Tom Moore Jon Winterhalter Farid Elsabee Ken Mayers -
Greg Tardif Larry Collier Rich Laudenat Roger Mauchline i
Bob Weth Dan Cardinale i
Norbert Carte Larry Wigley Stan Du Brut Mike Akins Rod Peterson Dan Curry Kahin Anglin Eric Blocher Bill Cushman
-1.
Topic: DR Level Clarification (Trent Powers)
Background:
DR-0606 and DR-0070 are exampics of a difference of severity level classification. Parsons issued these DRs as Level 3. The NNECo response was that the issues are confirmed Level 4.
Question: Parsons would like to discuss the criteria for classification of Level 3 vs. Level 4 Severity Levels for FSAR changes. It is Parsons' position that when there are conflict between the FSAR and documents such as calculations, and the corrective action results in an FSAR change (e.g. FSAR was incorrect and calculation was correct) that this represents a change to the licensing bases of the plant. Parsons considers FSAR changes that are editorial in nature (e.g. misspelled words, clarifying discussion that does not change values of numbers, etc.) as Level 4 issues. The above DRs contain issues that we do not classify as editorial in nature.
l
Response
a) 'DR-0606: NU agreed that this is a level 3 with a status of "Open, pending completion ofcorrection action "
b) DR-0070: Items 1 &2 deferred to 8/20/98.
2.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0346, Senice Water Pump "C" Repair Package (Larry Collier) Item #3 - We need an explanation of the NNECo response. The documents we have state that the depth of one cavity is 1 % inches and the depth of the other cavity is 1 inch. The response to this discrepancy did not state if the material thickness at the first point of repair would accommodate the 1 % inch excavation. Also, NU did not at all address PAGE 1
l CONFERENCE NOTES AYgust 18,1998 the 2"d repair cavity which was recorded as 1 inch. Base on this we do not understand NNECo's interpretation of the repair documents, b) DR-210, Non-conformance ofInstrument P102B-1 to Requirements of RG 1,97 (Dan Cardinale) To fully understand the NNECo response to this DR, Parsons discussed this issue with NRC NRR (Mr. Barry Marcus).
Parsons would like to relate the results of this discussion as it pertains to resolution of DR-210. During the discussion, NRC stated that the M2 configuration (RCS pressure) was accepted for design bases for everything except ATWS transient. NRC believed NNECo committed to evaluate upgrade of RCS pressure
' instrument and would evaluate / approve bases for ATWS transient based upon that submittal. NNECo made that submittal in early 1998 and NRC approved configuration for ATWS transient in SER dated April,1998.
Response
I a) _ Item # 3 closed as a S L 4. Items 1 & 2 deferred to 8/2W98. ;
b) Closed as non. discrepant because NUdiscoveredprior to CMP complete (NU tofax CR: m2 0609). [ Note: Parsons will take the LB/DB issue up with the NRC.]
3.
Topic: DRs
Background:
NNECo requested topic to discuss the DRs listed below.
Questions:
- a) DR-508, Absence of Calc to Support Compliance with RG 1.11 (Kent Russell). PRT Member: Norbert Carte, Stan Du Brul. Initial Response. NU to discuss requirements for bases docmnentation.
b) DR-0133 (Roger Mauchline)(Continued from 8/11/98). NU to' discuss results from cabinet walkdown to verify weld placements.
Response
a) NNECo will send a response.
b) Based on measurements taken in a walkdown, DR-133 is non-discrepant. NNECo will fax the walkdown results to Parsons.
4 i
i PAGE 2
1 U,
CONFERENCE NOTES I
August 20,1998 DATE:
8/20/98 4
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
I 1.
Parsons Requested DRs for Discussion j
- 2. Status and Schedule 3.
NNECo Requested DRs for Discussion LIST OF ATTENDEES:
1 NNECo NRC NEAC Pa sons Joe Fougere Eric Benner Wayne Dobson j
Bob Skwitz Jo.m_ Nakein Don Marks Fred Mattioli Jon Winterhalter John Calderone Dan Wooddell Ken Moore Larry Collier
)
Geoff Neate Tom Fleming Dan Van Duyne Trent Powers I
Chris Scully Gary Jackson Ken Lanham Dan Curry Ron Jackson Colin Patton Peter Talbot Dom Ramos Sing Chu Dan Cardinale Bob Weth Dick Boyd John Kapinos Ron Smith Bill Cushman Rich Laudenat i
Vere Joseph Tom Moore i
Norbert Carte Roy Terry 1.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below, i
DRs for Discussion:
a) DR-0316, Service Water Pump "C" Repair Package (Larry Collier) Except Item #3.
- b) ~ DR-0070, (Jon Winterhalter) Items 1 &2.
c) DR-0221 - Two issues were initially presented: 1) Leak Testing of 2-SI-659 and 2-SI-660, and 2) Fail position of these valves described in SP 21136.
The CRs mentioned in the NU response for item I are all post 6/30/97, although the 7/3/97 date for M2 1248 is sufHciently close to discuss prior discovery. The response references also ACR 7394 and that this ACR was addressing the leak testing concern via TRMCR 96-2-5. Is this a correct understanding of the NU response?
For item 2, the response addresses dates that are all in 1998. Prior discovery is based upon a draft resision to SP 2616A dated 5/28/97. The topic Parsons wishes to address here is what documentation needs to have been in place at CMP complete to support a statement of previous discovery.
I PAGE 1
-. _. -.. _ -..- -- -. - - -.-, ~.
CONFERENCE NOTES Acgust 20,1998 d) DR-0086 - Parsons has reviewed the second NU response and wishes to discuss those portions of the response pertaining to FSAR sections 5.8.3.2.2 and 5.8.4. Base issue is the assumption that the vertical structural elements can be considered rigid.
c) DR-0411. "EBFS-Dampers 2-EB-60 and 2-EB41 Single Failure During AEAS Operation": (Dom Ramos) l item 1. Case 1 NU states that the EBFS is fully capable of fulfilling the system function of producing 0.25 in wg. within one minute after an EBFAS even if damper 2-EB-60 or 2-EB-61 fails to close. No justification was provided to substantiate the statement. This is the issue being raised by the DR.
Item 1. Case 2: Please clarify the second paragraph that states: "It is true...."
Item 2:. Nojustification was provided to the claim that there is no deficiency, thus no CR is required.
. NU is requested to review the results of calc. 97-EBF-02000-M2, Rev 1 as they are re!r/snt to the resolution of this DR.
f) ' DR-0517 - Parsons considers the 1% rule defined by NU as setting an industry precedent. As such Parsons is -
prepared to classify this DR as " Unresolved",
. g) DR-0223 - TMR-084 seems to calculate the combined dead weight and thermal stress at 26.8% of minimum yield strength for SB-166 material, in access of the allowable of 20% Parsons does not understand why this is considered acceptable.
h) DR-0300.- Parsons wishes to discuss the previously identified statement as being a generic trend discrepancy in CR-97-0829.
.i) ' DR-0175 - Parsons wishes to discuss requirements for qualification of valves to 3g's and the bases for this requirement. -
- j) - ~ DR-0569 - Parsons wishes to discuss the following: Current requirements on MF 2?01J-92F require an L
inspection every 2 years and does not appear to have been done. (Level 4 item). Item 2 of the DR addresses surveillance requirements for fire dampers that may not be properly implemented since the deletion of MF 2701J-92H.
k) DRs 0046 & DR-0048 - These are Level 4 DRs for which Parsons has comments on the 2nd NU response.
Parsons wishes to address the rationale for continuing these Level 4 discussions in light of more recent guidance for the resolution of Level 4 DRs.
j i
~ 1). DR-210; (Dan Cardinale) Follow-up from 8/18/98 with regard to CR: M2-96-0609.
i Discussion:
a) Parsons agrees that item # 1 is a SL 4. Item # 2 was deferred to 8/25/98.
b) NU agrees that this is a SL 3 and will take appropriate corrective action. [ Note: In light ofthis conference, Parsons willre-classify DR-71from a SL 4 to a S L 3.]
c) Parsons agrees that the DR-221 items were previously discovered and that the DR will be closed as a S L 4.
(
d) NNEco will send additional technical evaluation documentation.
c) VNECo willprovidefurther technical analysis.
7 i-
. i) Parsons will submit DR-517 to the NRCfor resolution.
g) Deferredto 8/25/98.
f L
h) Closed as non-discrepant.
i) Parsons will evaluate stress curves and will revise DR-175 accordingly.
j). Item # 1: NNECo willresearch damper classification andprovide a response. Item # 2: NNECo willprovide afollow-up response.
k) Deferred to 825/98.
~
l) NNECo clanfed the issue as being previously identified.
4 PAGE 2 D
a n
.________.m_._
m_
(
- CONFERENCE NdTES August 20,1998 t
l 2.
Topic: Status and Schedule. ' (Ron Smith) l L
Background:
N/A-i-
t:
(Questions:
- a) What is the schedule for providing the schedule of program documentation for EQ and Appendix R as J
discussed in the 8/17 Status meeting at NNECo?
)
b) What is the status of the out processing procedures that Parsons is to follow for personnel badged at Unit 27.
i, (For example: Do these people need whole body counts?)
j:
c)f What is the status of Parsons request for maintaining badges of site walkdown personnel beyond 21 days 1
without badging in? (Note: Parsons has requested that key personnel badges remain active beyond the current -
- 21 day limit.)-
i r
~
.~
l;
Response
a) Appendix R date is now end ofNovember. Program is being discussed with the NRC and Senior Millstone management. ' EQ dates are being faxed to H'ayne Dobson. Ihe prst group of deliverables is early September. These documents will be in the QA drap status.
b) Hhole body count is not required to badge outfrom Millstone. Joe will sendformsfor out processing of Parsons currently badgedpersonnel.
'~
t c) Badgedpersonnel going beyond 21 days between badging in the plant will not result in loss ofsite access.
_Not badging in does not present a major problem until such time as the individuals go beyond 120 days.
Parson will notify Joe when personnel are coming to the site and have the requiredpaperwork ready to expedite plant re-activation ofun-escorted access.
13.
' Topic: DRs.
Background:
NNECo requested topic to discuss the DRs listed below.
. Questions:
. a) DR-056; (Colin Patton). PRT Member: Bob Weth, Vere Joseph, J. Kapinos. Follow-up to previous ATWS
' discussion. NU to present additional information.
l b) DR-531; (Tom Flemming). PRT Member: Norbert Carte. Initial Response - NU is looking for basis of
- Parsons statement in " Current Design Specification / Classification" section, (last statement), which reans, I
"...which by definition requires QA Category I classification".'
Response
a) NNECo willsubmit a revised response.
b) Parsons clarified the basisfor the Category 1 interpretation ofSeismic Category 1.
L, PAGE 3
,~,
m
/
CONFERENCE NOTES Azgust 25,1998 DATE:
8/25/98 PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Parsons Requested DRs for Discussion j
2.
Proposed Tech Spec Change for AFW Analytic ~al Limit 3.
Proposed Tech Spec change for Condensate Storage Tank Volume 4.
ACR 05584
- 5. NNECo Requested DRs for Discussion LIST OF ATTENDEES:
NNECo NRC NEAC Persons Fred Mattioli Peter Koltay Wayne Ibbson Norm Hanley Don Marks Steve Stadnick Dick Boyd Norbert Carte Trent Powers
)
Ed Foster Eric Blocher
]
Josh Spalter Larry Collier Bob Weth Clark Tracy Prem Godha Gary Jackson Bob Lawrence Rich Glaviano Dan Van Duyne Ken Mayers i
Greg Tardif Gordon Chen Dave Bajumpaa Mike Short Bob Skwirz i
1.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below, l
DRs for Discussion-a) _ DR-0223 -(T. Lee) [ Continued from 8/20/98.] TMR-084 seems to calculate the combined dead weight and thermal stress at 26.8% of minimum yield strength for SB-166 material, in access of the allowable of 20%.
Parsons does not understand why this is considered acceptable.
I b) DRs 0046 & DR-0048 -(Powers) [ Continued from 8/20/98.] These are Level 4 DRs for which Parsons has comments on the 2nd NU response. Parsons wishes to address the rationale for continuing these Level 4 discussions in light of more recent guidance for the resolution of Level 4 DRs.
l c) DR-0179 - (Jackson) - Parsons wishes to discuss the process by which nozzle loads are evaluated against allowable loads and to understand how AR97002778 can be credited for Presious Identification.
d) DR-03% (Colin Patton) - Parsons wishes to discuss NNECo's response to DR-0396, Procedure Biennial
- Resiews Generic Discrepancy. Specifically, NNECo's response states that this should be a significance level j
4 DR. Tecimical specification 6.8.2.c requires procedures to be reviewed periodically as set forth in l
administrative procedures. How does failure to update procedure references, as required by DC-1 and DC-2, satisfy this technical specification requirement?
f e). DR-269 -(Jack Lawton for C. Segar)- Parsons wishes to discuss NU's proposed Corrective Actions.
PAGE 1 i
i CONFERENCE NOTES August 25 1998 0
Discussion:
P' arsons agrees that DR-223 is a S.L. 4 and will close the DR basedon the content ofthe W23/98 conferen a) call where NU acknowledged that CE was cognizant ofthe limit issue.
b) Deferred to S/27 98.
l c) Parsons will review DR-200 and respond on 8/27/98.
\\
d) Deferred to W27/98.
1 e) ESAR on Fuse Controlis the NUprior discovery vehicle. NU will add corrective action plan to the CR and send a copy to Parsons.
I 2.
Topic: Proposed Tech Spec change for AFW Analytical limit does not meet the analyzed condition. (Dick Boyd)
References:
1.
Siemens Calculation EMF-98-015, Rev. 0, June 1998, " Millstone Unit 2 Loss of Normal Feedwater Flow Transient With Reduced Auxiliary Feedwater Flow" j
2.
NNECo letter B17190, " Proposed Revision to Technical Specification Reactor Protection and Engineered Safety Features Trip Setpoints," dated July 21,1998PORC meeting #2-96-309
Background:
The Tech Spec change specified in the letter states the new analytical limit as 5% of Narrow Range SG level. The analysis referenced used a value of 10% of Narrow Range.
I Question:
I a) What allows the new tech spec limit to be lower than the analyzed condition?
Response: The analyticallimitfor theilFWinitiation is 5% ofnarrow range with a ' harsh ' environment and is 10% of narrow range for ' normal' operating, from 25203-ER-98-0044-1. Because the harsh environment uncertainty plus the harsh environment analytical limit is greater than the non-harsh environment uncertainty plus the non-harsh environment analyticallimit the trip setpoint and allowable setpoint are based on the harsh envirvnment analyticallimit. This results in the trip setpoint being 26.8% of narrow range and the allowable setpoint being 25.2% ofnarrow range (see calc 92-030-1254E2, Rev 01, 4/17/98).
- 3. Topic: Proposed Tech Spec change for Condensate Storage Tank (CST) volume does not include the losses through valve 2-CN-241 (hotwell makeup valve) (Dick Boyd)
References:
1.
Calc 97 CST-01999-M2, Rev. O, "MP2 CST loventory Evaluation" 2.
NNECo letter B16902 " Proposed Revision to Technical Specifications, Condensate Storage Tank and Atmospheric Steam Dump Valves," dated 8/4/98 i
i-
Background:
The Tech Spec change specified in the letter states the new CST Volume as 165,000 gallons. Tlus is 159,000 gallons required for Loss of Offsite Power and for Station Blackout, PLUS 6,000 gallons margin. The calculation for CST volume identified a loss ofinventory to the condenser through valve 2-CN-241 of 25, 993 gallons. This loss is not identified in the volume specified for the Tech Spec.
PAGE 2 l
l
CONFERENCE NOTES A gust 251998 0
The valve is a control valve which requires local manual action to close (EOP-2540D). Until the time of its
,. closure, evaluated at 30 minutes, the valve allows CST inventory to flow to the condenser. The valve receives no safety grade signal and is not currently isolated on AFW initiation.
Questions:
a) What change allows this valve to be considered closed such that it's loss to the condenser need not be considered in CST volume requirements?
Response: 'the TS change is based on eliminating the problem of losing CST inventory through valve 2-CN-2412. Therefore, Calc 97 CST-01999 has been revised and is now Rev.1. TS Amdt 63 required operator action in 20 minutes to take action to maintain CSTinventory ifCST reaches its low level. A technical evaluation is documentedin Af2-EV-98-0135, Rev. O, which evaluates three methods ofmeeting this requirement: 1) relocate suction piping of valve 2-CN-241 to a level above the minimum inventory requiredfor AFW; 2) meet single failure requirements; and 3) credit operator action. No PDCR has been written but the TSproposed change is based on the passive approach ofchanging thepiping.
4.
Topic: ACR05584. (ClarkTracy)
Background:
ACR 05584 was initiated 10/30/95. The issue was that procedure SP 21136, issued in 1979, required 2 HPSI pumps to be powered from the same EDG. This would cause excessive loads on the EDG if a Loss of Normal Power and a Loss of Coolant Accident occurred. As part of the " Causal Factors and Corrective Action Plan" (Form RP4-7 Rev 1), section 2 states: "The plant operating philosophy at the time the Insersice Inspection Procedure was generated (1979) time frame permitted alignment of two pumps to one facility. The PORC approved procedure had been in use for a long period of time. This condition or event is a very subtle condition that is not readily apparent to the normal procedure reviewer. The effectiveness of the oversight groups in this case is not applicable because the procedure was approved quite a long time ago and these particular groups do not go back and review documents that have been in use. They typically only review nciv documents."
Questions:
i a) How does this statement reflect the requirements of Technical Specification 6.8.2 and DC 17 1
Response: AfP2 stated that currently all active procedures,old or new, are covered by the biennial review process as definedin DC-1 and DC-3. This adequately addresses the concern that oldprocedures do not receive reviews as impliedin the review packagefor ACR 05584.
5.
Topic: DRs 4
si
Background:
NNECo requested topic to discuss the DRs listed below.
I DRs for Discussion:
a) DR-700 -[ Dale Pruitt] PRT Member: Norbert Carte, Ed Foster. Initial response. NU System Engineer to discuss operation of Terry Turbine.
b) DR-202 -[ Rich Glaviano) PRT Member: Norbert Carte, Joshua Spalter. Follow-up respcuse. 7iscussion by NU regarding modeling of safety valves.
PAGE 3
~. _ -.. - _.
. _ _ _. _ - _... _. _ _.. _ _. _... _ _... =. _
p.
,eF, CONFERENCE NOTES Agust 25,1998 s
c) DR-346 - [ Larry Collier] Follow-up response. Discussion of extent of condition sample.
l l
i t
Discussion:
. a) NU to sendfollow-up response to correct vendor manual reference..
I l
.l b) Parsons will review information provided in the conference and respond to NU on 8/27/98..
c) NU to sendfollow-up response based on the 8/25/98 conference.
l 4
t l
l I
i L
1 i
j i
i l
PAGE 4
E CONFERENCE NOTES August 27,1998 DATE:
8/27/98 PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Parsons Requestei DRs for Discussion
- 2. Single Failure Analysis of Minimum Flow Recirculation Check Valves
- 3. MOVATS Testing of SI Valves i
4.
DR-0269 Concerns j
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Joe Fougere John Nakoski Teny Concannon Larry Collier Fred Mattioli Don Marks Bob Skuirz Dom Ramos Greg Tardif Rich Glaviano Rich Laudenat Colin Patton Ken Moore Trent Powers Norbert Carte Bill Chalfant Stephen Rovin Lloyd Baird Josh Spalter Madison Long 1.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0559, "EBFS Missing Fire Dampers" (Dom Ramos): Parsons needs to clarify that the required corrective action is tied to Appendix R final evaluation. The NU response for action completion date may need to change.
i b). DRs 0046 & DR-0048 -(Powers) [ Continued from 8/25/98.] These are Level 4 DRs for which Parsons has comments on the 2nd NU response. Parsons wishes to address the rationale for continuing these Level 4 discussions in light of more recent guidance for the resolution of Level 4 DRs.
c) DR-0262 (Larry Collier): Parsons would like to discuss closure of DR-0262 as a difference in documents.
Clarification in the procedure would close tids out as a Significance Level 4 DR.
d) DR-0396 - (Colin Patton) [ Continued from 8/25/98.] Parsons wishes to discuss NNECo's response to DR-0396, Procedure Biennial Resiews Generic Discrepancy. Specifically, NNECo's response states that tids should be a significance level 4 DR. Technical specification 6.8.2.c requires procedures to be resiewed periodically as set forth in administrative procedures. How does failure to update procedure references, as required by DC-1 and DC-2, satisfy this technical specification requirement?
l c) DR-0710 (Larry Collier): Parsons would like to discuss closure of DR-0710 u an inconsistency in the ISI program w hich does not identify the 3 zones taking credit for the zone drawings in lieu of having ISI Boundary drawings. Clarification of this matter would close this out as a Significance Level 4 DR..
f) DR-202 (Rich Glaviano): Parsons will respond to information provided by NU in the 8/25/98 conference.
PAGE 1 l
4 J
CONFERENCE NOTES Argust 27,1998
, g) D,R 0179 (Gary Jackson): Parsons will respond to information provided by NU in the 8/25/98 conference.
. h) Parsons has not yet received initial responses (as of 8/21) for the following preliminary Severity Level 3 DRs that have DR numbers less than 300. Parsons wishes to discuss if NU has received these or if there is additional information required before NU prepares a response for #s: 30, 77,106,116,128,155,163,203, 212,213,216,239,194.
Discussion:
a) Will be closed as a SL 4. Appendix R Evaluation will be completedprior to restart. The missingfire damper issue will be resolvedprior to restart and not prior to RF-013 restart.
b) Parsons andNUagreed on closureprocessfor SL 4s which were SL 3s. Andfor DRs with a status of OpeWDisagree, the decision was to continue the current process.
c) Closedas a SL 4. NU willfollow-up with a CR # on 9/1/98.
d) Parsons will close DR-396 as SL.4.
e) Parsons will close DR-710 as SL 4 in light ofCR M2 97-02133.
t) Parsons will close DR-202 as non-discrepant.
g) Deferred 9/8/98.
h) NNECo supplied status ofDR response process.
2.
Topic: Single Failure Analysis of Minimum Flow Recirculation Check Valves (Rich Olson)
Background:
FSAR section 6.3.4.1 states (page 6.3 10, item h.): "The safety injection system have (sic) been designed to meet the single failure criterion."
FSAR section 6.3.4.1 states (page 6.3-12): "There is no undue risk to the health and safety of the public from the failure of a single active component during the injection mode of operation or from a single failure of any passive or active component during the recirculation mode of operation."
FSAR section 6.3.4. I states (page 6.3-12) that the following assumptions were used in performing the failure modes analysis:
- b. Only one active failure is considered for the injection mode and only one passive or active failure is considered for the recirculation mode.
- c. Failures of check and stop valve internals are credible during the recirculation mode of operation.
Questions:
a) Is there an evaluation of the event: single passive failure (open) of a minimum flow recirculation check valve during the recirculation mode of operation?
Response: Deferred to 9/1/98.
3.
Topic: MOVATS Testing of SI Valves. (Larry Collier)
Background:
Regarding 2-SI-616,2-SI-617,2-SI-626,2-SI-627,2-SI-636,2-SI-637,2-SI-646 and 2-SI-647.
Questions / Discussion: Would like to discuss recent MOVATS testing, or if not recently tested, any proposed MOVATS testing:
a) When was MOVATS testing performed or when will it be performed?
PAGE 2
i r
, go.
<?,
CONFERENCE NOTES.
AYgust 27,1998 b) - How was functional Delta P achieved across these valves just prior to test?
c) R6 cords and results of open to close, if already tested.
d) Process of trimming (throttling) valves during test e) How the valves are trimmed (throttled) when using AOP-25527 f) ' Records ami results of trimming (throttling) test of valves.
Response
a) MOVIS testing has already been performed on valves 2-51-616, 2-SI-626, 2-SI-636, and 2-S1-646.
. b) l Using system pressure.
C) Results ofopen to close were satisfactory.
d) Not a requirement but testing these valves to the approximate throttle position is an enhancement to the MOVA TStestingprocess c) Will be presented at a later time, week of8/31/98 t) Will be presented at a later time, week of8/31/98.
4.
Topic: DR 0269 Concerns (Jack Lawton)
Background:
CR No. M2-971699 corrective action plan item: Verify that all currently installed safety related :
fuses conform to ' controlled' design documents prior to restart.
Questions / Discussion:
a) How is verification of currently installed safety related fuses accomplished? What are the " controlled design documents
- used to perform this verification?
b) _ How was the Master Fuse List developed - calculations, vendor information, walkdowns?
!4 c) The ESAR did not identify any calculation discrepancies, as identified in the DR. Part of the response to the
' DR should have addressed this issue.
d) The DR states that a corrective action will be added to the CR to replace the listed fuses. Is any evaluation -
going to' be performed to determine if the incorrect fuses could have a potentially adverse impact on the associated circuits and penetrations?
i Response: Deferredto 9/1/98.
lp i
4 i
j
- PAGE 3
~
_ -,