ML20195D793
| ML20195D793 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/10/1998 |
| From: | Curry D External (Affiliation Not Assigned) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUM2-PPNR-2152, NUDOCS 9811180161 | |
| Download: ML20195D793 (118) | |
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PARSONS Daniel L Curry, Vice Presicent fluclear Services Parsons Energy & Chemicals Group Inc.
2675 Morgantown Road + Reading. Pennsylvania 19607 * (610) 855-2300
- Fu (610) 655 2602 November 10,1998 Docket No. 50-336 Parsons NUM2-PPNR-2152-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 Program UCAVP)
Gentlemen:
This letter transmits summaries of telephone conferences between Parsons Power Group Inc., the U. S.
Nuclear Regulatory Commission, NNECo and NEAC on Oct.1, Oct. 5, Oct. 6, Oct. 7, Oct. 8, Oct.13, Oct.14, Oct.15, Oct.16, Oct.19, Oct. 20, Oct. 21, Oct. 22, Oct. 23, Oct. 26, Oct. 26, Oct. 27, Oct. 28, Oct. 29, and Oct. 30,1998.
Please call me at (610) 855-2366 if you have any questions.
Sincerely,
(?%
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Daniel L. Cuny f'
Parsons ICAVP Project Director'-
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Attachments t
cc:
E. Imbro (2)- USNRC J. Fougere - NNECo Rep. Terry Concannon - NEAC Project Files R. Laudenat - NNECo e\\
9811100161 991110'
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PDR PPNR2152 doc
w t-a CONFERENCE NOTES DATE: 10/1/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DR-0155
- 2. DR-0724 3.
DRs, Parsons requested topic to discuss DRs 4.
DRs, NNECo requested topic to discuss DRs LIST OF ATTENDEES:
NNECo NRC l NEAC Parsons Bob Byrnes George Mc Govern Eric Benner none Mike Akins Dale Pruitt Charles Chace Ray Necci Eric Blocher Ron Smith Cris Cristallo Tien Nguyen Wayne Dobson Dan Wooddell Bob Crittenden Tom Prvhoda Trent Powers Jon Winterhalter Joe Fougere Greg Tardif Gary Komosky Bob Skwirz
~
Fred Mattioli
- 1. Topic: DR-0155 (Dan Wooddell) (Rescheduled from 9/30/98 teleconference)
Background:
DR-0155, Jtem No.1, identifies that Procedure EN 2!221 allows check valves to be reclassified to a lower priority in the event there are no problems discovered during the inspection. Once a valve is assigned a Priority of 4, no further inspections or reviews are required.
Questions:
a) How are changes to piping flow (flow rates and flow stability), resulting from changes in operating methods or modifications, considered when performing pre-inspection resiews?
b) Where is this documented?
Discussion:
NNECo and Parsons agree that Procedure EN 21221 should be revised. Here have been no Priority 3 or higher valves assigned to Priority 4. Therefore the design / licensing basis has not been impacted. NNECo will issue a CR to revise the procedure. Upon receipt of the CR number, Parsons will close this DR as a Significance Level 4.
- 2. Topic: DR-0724 (Milt Capiotis)
Background:
NUs response to this DR indicates that Calculation W2-517-860-RE was revised to take into account the new steam generators and the cavitating venturis. However, the purpose of this calculation is not clear.
Page 61D of the calculation states: "It is acceptable that the Terry Turbine does not supply sufficient condensate to cool the RCS with one SG operable to 300*F, because a Station Blackout Event is not postulated with a concurrent seismic event in the licensing basis of MP2. His indicates that with a single failure there will either be two steam generators available or at least one motor driven AFW pump available in conjunction with the Terry Turbine (reference 18)."
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Question:
a) What is the pmpose of calculation W2-517-860-RE, Rev. 3? Is the purpose of this calculation to demonstrate satisfactory performance of the turbine driven AFW pump, stictly under SBO conditions?
b) What calculations demonstrate the ability of the turbine driven AFW pump to support the Chapter 14 accident analysis, with degraded steam conditions?
c) Caledation W2-517-860-RE, Rev. 3 includes a reference to calculation T-02258-S2, "MP2 Cooldown/ CST Analysis Data," for decay heat values. Do these decay heat values envelope those used in the Chapter 14 accident analyses?
)
Response
This topic has been rescheduled to the 10-6-98 teleconference.
- 3. Topic: DRs (Entire Topic rescheduled from 9/29/98.)
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0603 "EBFS Charcoal Cooling Discrepancies."(Dom Ramos) Continued from 9/29/98.
Parsons would like to discuss the difTerence in Significance Level deternunation. Parsons issued as a Level 3, NU response as PREVIOUSLY IDENTIFIED Condition.
Item 1: Charcoal Cooling Calculation 97-EBF-01955-M2 states that a minimum of 45 CFM of air is required for charcoal cooling. The calculation recognizes that this quantity is theoretical and recommended a higher flow rate to ensure uniform flow across the filter face and to ensure no channeling or axial airflow. De calculation did not specify a recommended cooling air quantity. No other document was found that i
provides this information. The DR noted that 45 CFM is equivalent to a filter face velocity of 0.21 FPM. The industry standard, ERDA 76-21, recommends a face velocity of 8 to 10 FPM. The point is for charcoal cooling, theoretical values are very informative but have no practical values.
Here is no test that measures the airflow rate through the EBFS charcoal cooling tie-in duct and there is no document that provides the recommended or the accepted airflow value. Thus, there is no document that demonstrates proper cooling of the charcoal filters as committed in the FSAR.
NU's response referenced calculations 1K21-11,1K21-13,98-EBF-02377-M2 and 97-EBF-01955-M2; and FSARCR 98-MP2-94. None of these documents indicates pre-discovery of the icoe.
Item 2: FSAR & Calculation Discrepancies NU response states minor editorial omission does not justify revising the calculation. Calculation 97-EBF-01955-M2 stated that it supports licensing, but indicated that a change document is not l
applicable. A change document should have been identified since the calculation results differ from those stated in the FSAR. His is not a minor editorial omission.
b) DR-0501," Calculation 98-EBF-02377M2 Discrepancy."(Dom Rarnos) Continued from 9/29/98.
Parsons issued as a Level 3. NU response as CONFIRMED SIGNIFICANCE LEVEL 4.
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Parsons agrees in part with the corrective action to revise calculation 98-EBF-02377M2 by supplementing it with calculation 97-EBF-01555-M2. This corrective action is considered partial l
because both calculations do not demonstrate the expected flow rate through the chsrcoal cooling tie-in duct. With no testing for the actual flow rate through the tie-in duct, adequate charcoal cooling as stated in the FSAR can not be assured.
Response
a) NNECo requested that this topic be rescheduled for a future teleconference pending their
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transmittal of additional information.
b) NNECo requested that this topic be rescheduled for a future teleconference pending their transmittal of a calculation.
If Parsons still has concerns after reviewing the new information, they should raise these topics again.
- 4. Topic: DRs (Entire Topic rescheduled from 9/29/98. Text amplified 9-30-98.)
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0538, (Charles Chace, Tien Nguyen, Bob Byrnes, N) (Dan Wooddell, Dale Pruitt, P)
Follow-up Response.
Items 1,2B,3B,5,7,8 and 9 are open. Items 2A,3A,4 and 6 are considered non-valid by Parsons.
Item 7 (only)is considered " pre-discovered" by QA audit report A60607 and ACR Ml-96-0614.
Item 1 Use of a 2500 ft-lb. max range torque wrench tester for a calibration check oflow range torque wrenches is appropriate, but using this tester for actual calibrations, as described in the discrepancy report, would be inappropriate practice. It is our practice that calibrations are done by the Metrology Lab, which does have a low range cell, using the 4:1 criteria, (with specific exceptions as described later). Upon investigation, we determined that some lower range wrenches were calibrated in this manner, which is inconsistent with our practice.
Our procedures are being revised to conform with ASME and the Federal Specification, which defines 4% accuracy for torque wrenches.
Since an instruction to zero the tester is already included in the procedure, this proposed change to make zero a data point will not be done.
Significance Level: 4, since the 2500 ft. Ib. Tester is intended to be used for calibration of torque wrenches in the 500 to 2000 psi range; and for cal. check of any range wrenches before use. Its inadvertent use with lower range wrenches has been limited. This is not a not programmatic issue.
Item 2. Part B - Non-discrepant (Position changed) Millstone will continue to exercise torque wrenches. This is in accordance with ASME B107.14M-1994, paragraph 5.2.4(d). This requires all torque wrenches to be operated three times at 50% of maximum capacity before beginning a calibration.
Item 3. Part B - Response does not address justification of reference standard to M&TE cal ratios of less than 4:1. Quotes IEEE 498-1980, "..The rationale for deviating from these requirements must bejustified and documented."
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Non-discrepant (because we do have rationale) To assure that the overall accuracy ratio of the reference standard to plant equipment is satisfactory, procedure WC-8 provides instructions for approval of those cases where a calibration ratio of 4:1 cannot be achieved, but where the instrument will be dedicated for a specific use. A justification is written for each such case and submitted to Design Engineering for approval. The justification must then be submitted to SORC for approval. This process is defmed in the Topical Report, Section 12.2.2, and is documented on WC-8, Attachment 5.
NOTE: If this were a discrepant issue, then we should claim pre-discovery based on the following: Memo MS-F-96-110 for the Nuclear Receiving Group; Memo MS-F-96-119 for Component Engineering Senices.
Item 5 Parsons disagrees that cal is IAW manufacturer's procedures:
Manufacturer's procedure for DMM QA-094I shows that the manufacturer specified two precisely known reference points for each function and range.
Concur with this discrepancy. Will revise procedure MTE-1120, " Digital Multimeter Calibration," to direct two point calibrations. Added new assignment to CR M2-98-1551; AR 98010755-07, " Revise Calibration procedure ICI101 A or generate a new procedure for QA-0941, Solartron, Model 7151 to include two reference inputs for each function and range as recommended by manufacturer.
We specified acceptance criteria tolerance for digital calibrator QA-1008 at the 0.010 VDC cal point, outside the specified tolerance. Non-discrepant - Tien ran cal on Transmation Model 1040; tolerance works out perfect.
Significance Level 4, since (1) applies to specific instruments, rather than programmatic; (2)
Instruments were calibrated per an industry accepted practice, even if the recommendations of a specific manufacturer were overlooked.
Item 7 Corrective action #4 commits to issuance of a briefing sheet to emphasize proper sign out and sign in of M&TE. The issue has already been published in To The Point; and the more detailed brief for the first line supenisors was submitted on 9/9/98.
Level 4; as stated by Parsons, this is minor in nature, since procedures are in place, but compliance needs to be enforced.
Schedule of corrective actions for CR M2-98-1551:
Action 1 - complete Action 2 - Direction to zero instrument is already in procedure. Will recommend closure of this actior, based on instructions and standard practice.
Action 3 - Will cancel this assignment, since procedure is consistent with ASME B107.14M Action 4 - Complete, not yet recorded in AITTS; briefing sheet submitted.
Action 5 - Intent of Met Lab is to take ownership of procedure and write new procedure for torque wrenches with appropriate acceptance criteria; presently scheduled for 11/11/98.
Action 6 - Complete, not yet recorded in AITTS: procedure revised to include "unless otherwise specified by manufacturer."
Item 8 Need measures to ensure that CR M2-98-1551, Corrective Actions 5 and 6 are modified to conform with the 7-23-98 teleconference between NNECO and Parsons:
(5) Torque wrench calibration accuracies will be changed to 4% Procedure C-MP-715A is being revised to this criteria. Exceptions will only be allowed in a manner similar to that described above in the response to Item 3.
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l (6) Torque wrench calibration accuracies will be deleted from WC-8 and replaced with "unless specified by the manufacturer. WC-8, Rev. 3 (p. 33), in accordance with GGG-W-686D, has been revised to read: "All torque wrenches are +/- 4% in either direction, unless otherwise geS &d."
i Procedure C-MP-715 A (',tep 2.3.2) will be revised to state torque wrench accuracy requirements as i
defmed in GGG-W-686D and amended by the results of the program desenbed below:
As an interim measure to ensure proper accuracy of torque wTenches, users have been instructed to only take out torque wrenches that are appropriate for the assigned task. Going forward, the Site Metrology Lab will take ownership of procedure C-MP-715A and write a new calibration procedure for torque wrenches. This effort is defmed by CR M2-98-1500, corrective actions 04 and 05, and tracked by AR 98010434. Assignment 04 states " Compile a list of M&TE equipment that contains the accuracy, range and emironmental information pertaining to each type and model of M&TE being issued." Assignment 05 states, " Assemble and maintain a specification sheet for each type and model of M&TE that contains the basis information for the accuracy, range and application of the M&TE issued." Both of these assigiunents have due dates of 12/31/99. The Site Metrology Group is the l
Owner of these CRs, who are also the personnel that provided the clarification to Parsons in the i
previous telecon.
Because of this effort, extent of condition of other M&TE calibration procedures to check accuracy allowances will not be done under CR M2-98-1551.
Level 4 based on likelihood ofimpact. When our review of M&TE is complete, it is expected that any cases were the lower criteria applies will be supported by manufacturer's specifications. Calibration has been consistent with program requirements, and program is only be upgraded.
Item 9 Non-Discrepant: Pressure Gauge QA-0335 cal record states that the gauge was calibrated to the nearest 1/10 psi, but the maximum resolution is 1 psi. Model Number for Pressure Gauge QA-0210 is not available.
Reviewed calibration sheet for ')A-335; accuracy is written on the form as "+/- 0.1% of fs accuracy." Since this is a 0-250 psi gauge (not 0-3000), the minor divisions are 0.25 psi (verified in field), and 1/2 minor division = 0.125 psi. All the readings on the data sheets are expressed in 1/8 psi increments, written as decimals, i.e. 99.875. This method of recording calibration data is in common use at Millstone, and is understood by calibration personnel.
[ Looked at QA-0355; this is a 0-3000 psi gauge with +/- 5 psi minor division.] This recording practice applies to QA-0210, minor div. O. I psi,1/2 minor = 0.05;(model # not found).
Response
l NNECo will investigate and provide follow-up information for DR ltems No.1,2B,3B, and 5. Items No. 7 and 8 were determined to be Confirmed Level 4 discrepancies. Item No. 9 was determined to be Non-Discrepant.
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b) DR-0395, (Bob Crittenden, N) (Wayne Dobson, P)
Follow-up Response.
NU would like to further discuss Parsons response to item 2 as stated below. NU disagrees with Parsons conclusion. It is NU's contention that neither the LB or DB was violated and that this is a Level 4 Discrepancy.
Parson's " Comment on NNECo Response"-
Item 2. The subject is a violation of Specification SP-ME-668. NNECo states this is a level 4 discrepancy as it is an inconsistency between documents of an editorial nature. Parsons disagrees with this conclusion. The piping specification is a design input document and s design basis document for the PDCR that installed the valves. Writing a PDCR and installing a plant modificction that violated the piping specification is a failure to address the design basis of the plant in makmg a plant modification. The PDCR that installed the valves did not meet the design basis of MP2. Therefore this is a level three discrepancy. The fact that the valves were installed by an approved PDCR indicates a breakdown in the design change control process. A modification that violates a design basis document should not have been approved and installed. Implied in the NNECo response is the belief that the wafer type butterfly valves are technically acceptable. If this proves to be tme, the system may be operable but the valves do not meet the design basis as defined in Specification SP-ME-668.
Parsons agrees with the proposed corrective action of determining the technical acceptability of butterfly valves in the subject piping class and issuing a DCN for SP-ME-668. Ifit is determined that the butterfly valves are not acceptable, NNECo's procedures would require corrective actions for the installed valves.
Response
NNECo says that the specification is not the LB or DB but only the EDB (engineering design basis) to which they are not committed. Parsons disagrees and believes that when considering the installation of valves that don't comply with the spec., an evaluation must be performed. No evaluation was performed. NNECo suggested that this DR be considered as UNRESOLVED.
c) DR-0409, (Bob Crittenden, N) (Wayne Dobson, P)
Follow-up Response.
NU would like to further discuss Parsons response to Item 1 as stated below. NU believes it was prediscovered and would like to provide additional clarification.
Parsons's " Comment on NNECo Response"
- 1. NU concluded that item I was a "previously identified condition" because "During the preparation phase for conversion from CTP to Passport, which culminated on September 6,1997, it was recognized that this CCN (which calculated an instrument span of 0-327" H2O) was not valid because it did not have all the required approval signatures; it was not entered into Passport."
Documentation in the ICAVP review file does not support this statement. A Passport printout dated 12/22/97 from the ICAVP review file, indicates that CTP identified an active CCN 01 with calculation 2-ENG-078. A later Passport printout dated 8/19/98, (also attached) confirms that this CCN is no longer in CTP. At the time Parsons was performing its review, which was after the CMP Page 6 of 8 mm
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complete date, it appears NNECo had not identified that CCN 01 had not been properly approved and removed it from CTP.
NU would like to further discuss Parsons response to Item 2 as stated below. NU disagrees with Parsons conclusion. It is NU's contention that neither the LB or DB was violated and that this is a Level 4 Discrepancy.
Parson's "Conunent on NNECo Response":
- 2. NU's response does not address the technical adequacy of calculation 2-ENG-078 rev. I without CCN 01. The fact that Revisions 0 and I of the calculation contained unsupported assumption statements does not mean that Revision 1 of the calculation is correct without CCN 01. Calculation revision 1 assumed that "The density of the borated water is...the same as that of plain water" while CCN 01 assumed " SIT water is assumed to be equal to 1.01"; Which is correct? Parsons concem was not whether the density difference of borated water was addressed in the Assumptions section of 3
the two calculations but whether the less conservative assumption to treat 1700 ppm borated water like plain water under elevated temperature and pressure was correct. Correct SIT levels are important to safety and a 3 inch plus difference in level instrument span from one assumption to another may be significant. Failure to verify assumptions is inconsistent with the intent of ANSI N45.2.11.
Response
- 1. Parsons will close this item as Non-Discrepant.
- 2. NNECo accepts this item as a confirmed SL 4. Parsons will close.
d) DR-0651 (Fred Mattioli, Tom Pryhoda, N) (Frank Cobb, P)
' Initial Response.
NU believes that this discrepancy is the same as DR-585. NU would like Parsons to explain the differences.
Response.
Parsons explained that DR-0651 addresses the absence of a review for seismic qualification of the j
dampers replaced by the modification.
e) DRs-0158 and -0269 (Greg Tardif, N) (Mark Fitzgerald, P) i NU has rewnsidered its position on the subject DR's. NU will take these as confirmed DRs.
Response
l NNECo will accept DR-0158 as a SL 3 and has issued CR M2-97-2375. DR-0269 is accepted as a 2
discrepancy (not Previously Discovered). NNECo is still investigating whether it is SL 3 or 4.
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f) DR-0541 (Farid Elsabee, Fred Matioli, N) (Joe Groncki, P)
Follow-up Response.
NU would like to further discuss Parsons response as stated below. NU would like to present further discussion regarding the technical methods used and the acceptability of their methodology.
Parson's " Comment on NNECo Response" The fonnulae used by NNECo in their proposed corrective action are not applicable in calculating tank skirt allowables in the case of T8A and T8B. Both the elephant foot and diamond shape buckling mode evaluations are to be used as part of the " Tanks and Heat Exchangers Review" found in Section 7 of the Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment, Rev. 2. Section 7.3.1 of the GIP states in part, "The type of vertical tanks covered by the screening guidelines are large, cylindrical tanks whose axis of symmetry is vertical and are supported on their flat bottoms, directly on a concrete pad or a floor."
Since Boric Acid Tanks T8A and T8B are supported on skirts, with their bottoms raised off the concrete floor, the evaluation techniques of Section 7 (including the elephant foot and diamond shape buckling analysis) do not apply. Section 7.5 of the GIP specifically identifies vertical tanks supported on skirts as an outher to the screening guidelines. Section 7.5 goes on to suggest Reference 26 (EPRI Report NP-5228, Revision 1, " Seismic Verification of Nuclear Plant Equipment Anchorage," Volume 4, " Guidelines for Tanks and Heat Exchangers") as a possible means of resolving this type of outlier.
Resp..sc.
This topic rescheduled to the 10-6-98 teleconference.
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PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs:
DR-0483, DR-0536, DR-0752, DR-0734, DR-0200 and DR-0190, and DR-0056 LIST OF ATTENDEES:
l l
NNECo NRC NEAC Parsons Bill Cuslunan Fred Mattioli Eric Benner none Eric Blocher Trent Powers Joe Fougere Greg Tardif Dan Curry Ron Smith George Howard Harold Thompson Wayne Dobson Jon Winterhalter Ron Jackson Bob Skwitz John Hilbish
- 1. Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0483 Diesel Generator Air Start Solenoids (Wayne Dobson)
This discussion is based on Parsons understanding of the following valve change-out time line for valves 2-DG-95A&B and 2-DG-96A&B:
1976 - PDCR 2-35-76 installed model # WPHT8300B58RF.
1985 - NCR 285-054 installed model # 206-381-2RF without engineering approval.
l 1993 - NCR 293-167 unknown what it did. CR M2-98-1642 states this NCR replaced 2-DG-l 95A, but did not say what it was replaced with. This NCR does not show up in the NCR log provided to Parsons last year.
1993 - NCR 293-170 replaced 2-DG-95B with model # 212630IF.
???? - An unknown mechanism change 2-DG-96A&B to model # 2126311RF.
Item 1 - Currently installed 2-DG-95A valve (ASCO model 206-381-2RF) does not meet system design differential pressures.
NUresponse: Previously Discovered. RIE 96-0453.
Parsons Comment: CR M2-98-1642 which was written by NU to investigate this DR does not support the conclusion of previously discovered. Section 2. Immediate corrective action taken, states there was no indication of prediscovery. The DR response package contains a copy of RIE l
96-0453, which approves an equivalent replacement for ASCO model 206-381-2RF, but the l
response package contains nothing to indicates that NU previously identified the installed valve in l
the plant is deficient. What is NU's basis for previously discovered? NCR #, or CR #, or UIR #..
Item 2 - Drawings and PMMS not updated to reflect current valves in 2-DG-96A&B.
l NU response: Agree, But this is level 4 discrepancy.
Parsons Comment: Additional information is needed before Parsons can agree this is level 4 discrepancy. The DR identified that current documentation Parsons could find would Page 1 of 4 M98L90$ das
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indicate 2-DG-95A and 2-DG-96A&B should be ASCO model 206-%l-2RF, but a walkdown found ASCO model 2126311RF.
How and when did the 2-DG-96A&B valves get changed out?
Item 3 - The 1985 NCR 2085-054 which installed the ASCO model 206-381-2RF (that did not meet system design differential pressures), was an " ADMIN" change that did not receive Engineering review.
NU response: Non-discrepant because in 1976, PDCR 2-35-76 (which installed the valves which NCR 2085-054 replaced) " modified the EDG air start scheme to it present configuration and includes a safety evaluation."
Parsons Comment: There must be a miscommunication because we haven't a clue what the NU response has to do with the discrepancy identified in item #3.
Discussion:
Item 1: This was tabled at NNECo's request pending further investigation.
NNECo continued discussion on this topic item on 10-6-98: PIR 2-93-247 was written in response to an NOV. Subsequently, AWO M2-95-10135 was written to change the valves.
Item 2: 2-DG-96A and B were replaced via AWOs M2-95-10133 and 10130, respectively.
Item 3: Parsons will close this item as a Significance Level 4.
b) DR-0536 Improper Change Process for B LPSI Motor Heater Replacement (Wayne Dobson)
-Item 1 - Currently installed 2-DG-95A valve (ASCO model 206-381-2RF) does not meet system design differential pressures.
NUresponse: Previously Discovered.
Parsons Comment: We agree that the motor heaters not being installed to design requirements was previously identified. However, that was not the discrepant issue of this DR. Items 1 and 2 were written against the corrective actions done in 1997 to resolve the non-conforming heaters that were installed in 1983. Our understanding of the corrective actions are as follows:
- An AWO was used to install two 300 watt straight heating elements which replaced one 600 watt circular element.
A DCN was issued to revise drawings to reflect the new configuration.
He NU response stated a design change control process was not needed because the heating elements were purchased from the original manufacturer and was a like for like replacement. If this was a like for like replacement, why were the drawings changed? It is Parsons position that this replacement should have been done under a design change control process like a RIE.
Discussion:
Parsons agrees that this item was previously identified and will close.
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c) DR-0752 (Richard Boyd)
This DR deals with differences between the FSAR and the new Siemens Chapter 14 Analyses.
NU response is that these will be corrected and because these are new analyses the issue is Non-Discrepant.
Parsons concurs with the response but to close this DR the CR which tracks these issues is required.
i Discussion:
After lengthy discussion, Parsons will table this topic pending their discussion with the NRC regarding this and other ongoing analyses and programs.
l-b) DR-0734 (Richard Boyd) l This DR addresses safety class boundaries for the AF system. The issue here is the boundaries on the i
main steam to the Terry Turbine of the TD driven AF pump. To meet the conditions of a system l
boundary, there is either a closed valve, a valve capable of automatic closure, or the loss of the l
boundary will not affect the safety function of the system.
Item 1:
l This deals with the loss of steam through a line to a steam trap. This line is not considered in l
Calculation W2-517-860-RE which addresses steam flow to the turbine under various operating conditions. The calculation considered steam losses from the non-QA portions of piping in the branch connections to other steam traps because they were assumed to fail following a seismic event.
NUs response to this item is that the steam losses due to this would add no value to the calculation l
and referenced page 61 of the calculation containing an ' Analysis of Conservatisms' to support this statement. However, this reference has been inappropriately interpreted to mean that losses i
due to the seismic portion of the steam trap lines are not credited in the calculation, and therefore this provides a conservative assessment of the required critical flow.
This reference in fact means that pressure losses, and therefore flow reduction because of the length of the line, is not considered in the case ofloss for a small branch line connecting to the 4" l
main !ine. This does not mean that no losses from the line are considered. The calculation modelal the loss as an orifice off the main pipe run.
In additioo, NU responded that because the line to the trap is downstream of the line to the turbine there is obviously no effective steam loss to the trap that would otherwise be available for work to the Terry Turbine.
Item 2:
l l
Parsons agrees with NUs response that the failure of the Terry Turbine exhaust line will not affect l
the performance of the turbine, and that the line is non-safety related.
Discussion:
l item 1: NNECo will review the calculation and raise the issue at a future date. The 10-1-98 topic for DR-0724, which was deferred, will be addressed together with this question.
Item 2: Parsons agrees with NNECo's response regarding this topic.
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CONFERENCE NOTES DATE: 10/5/98. Rev. O TlME: 2:0J o.m.
e) _ DR-0200 and DR-0190 (Trent Powers)
DR-0200 is currently at MP2, DR-190 is at Parsons. Both have been downgraded to S.L. 4 issues and could be closed with a CR number. Parsons proposes that a CR # be discussed so that both of this DRs can be closed based upon the discussion.
Discussion:
WNECo's position regarding DR-0200 is that the nozzle loads were considered and this is non-discrepant and no CR was issued.
DR-0190 is a SL 4 and will be corrected by CR M2-98-2165, e) DR-0056 (Trent Powers)
This DR has had two responses and previously been the subject of an extended telecon discussion.
It is Parsons' opinion that FSAR section 7.9.4.2 remams mconsistent with the way instnunentation is calibrated in SP 2402Q. The second NNECo response, and the earlier telecon discussion have not resolved this inconsistency. Parsons believes that the second NNECo response to this DR prosided sufficient justification to classify any FSAR change as a clarification (editorial change).
If further discussion cannot achieve a agreement that FSAR section 7.9.4.2 should be clarified, then
- Parsons proposes that this issue be placed in Unresolved status.
Discussion:
NNECo will accept this DR as a SL 4 and will be corrected by CR M2-98-1892, 1
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CONFERENCE NOTES DATE: 10/6/98, Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs:
DR-0169, DR-0647, DR-0251, DR-0291, and DR-0395 LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Prasad Bandaru Greg Tardif Eric Benner none Eric Blocher Trent Power <
Bill Cushman Harold Thompson Dick Diederich Jon Wintshalter Keith Deslandes Bob Skwirz Wayne Dobson Joe Fougere Bob Weth Ken Gabel Fred Mattioli Gary Jackson i
- 1. Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0169 Technical Justification for Bechtel Specification 7604-MS-66 (Ken Gabel) l This DR addresses the lack of backup qualifications for the MS-66 criteria utilized to specify tubing design.
NU Response: The TE provides appropriate retrievable MS-66 design qualification documentation.
Issue reported by DR identified a Non-Discrepant condition.
Parsons Response Based on the development and submittal of TE-M2-EV-98-0148 and other l
engineering assessments, Parsons deems the MS-66 criteria technically acceptable as an initiating l
design guidance document. The development of and position taken that the TE serves as design qualification documentation represents actions taken to address a lack of design basis backup. The t
I lack of design basis backup is a discrepant condition. It is purposed that the original Significance Level 3 designation be changed to a 4 and the DR closed based on the actions taken.
Discussion:
NNECo will accept DR-0169 as a confirmed SL 4 and Parsons will close on that basis.
b) DR-0647 (Dick Diederich)
This DR relates to water flow from a failed safety iniection pump mechanical shaft seal.."ollowing l
the 9/24 teleconference discussion of this topic (9/30), NU faxed some correspondence with l
Durametallic to Parsons to provide further support for the smaller flow rate used in resolsing CR M2-l 97-0761.
l The CR Evaluation Report referred to correspondence and telephone conversations with Durametallic l
dated 5/15/97 and 52797. The Evaluation Report was dated 5/20/97.
The NU/Durametallic interchange provided by fax took place in February and March of 1998.
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Question: Parsons does not understand how this information could impact an analysis which had been completed nine months before the exchange took place.
Discussion:
The interpretation of flow rate conservatism was discussed. NNECo will investigate the Licensing Basis leakage events such as those in FSAR Table 6.3-1 and raise this topic in a future telephone conference.
(This topic was discussed again on 10/7/98 and Parsons agreed that the issue is Non-Discrepant.
NNECo will provide additional documentation by fax addressing the 3 gpm rate and the rate in the May 27,1997 internal memo.)
c) DR-0251 (Gary Jackson)
Parsons disagrees with NU disposition of this DR being a Level 4. Section 5.8.4 is being changed and a " Regulatory Commitment Change Request"is being processed to revise and clarify NU response to Question 5.23 and the AEC" SE to properly reflect the design and engine: ting basis for MP2 on this subject.
Parsons considers this to be a change to the Licensing Basis and considers this a Level 3.
Discussion:
NNECo requested that this topic be rescheduled to the 10-7-98 telephone conference.
d) DR-0291 (Gary Jackson)
Parsons considers this to be a Level 4 discrepancy due to the inconsistencies and differences between the analysis isometric drawings and the as-built condition.
Discussion:
NNECo accepts DR-0291 as a SL 4 and has issued CR M2-98-2183 to disposition the issue. Parsons will close the DR on that basis.
e) DR-0395 (Trent Powers)
Follow up to 10/1/98 discussion: Since this DR was discussed as being put in Unresolved status, Parsons wishes to have the following included as to the difference with NNECo on the resolution of this DR. This item will not require additional discussion unless there are questions by NNECo.
Specification SP-ME-668, for piping class HCD, does not provide for the use of butterfly valves.
However, PDCR 2-043-93 installed 2 wafer type butterfly valves. He PDCR referenced Specification SP-ME-668, but contained no type of evaluation, either in the safety evaluation or elsewhere, that discussed the acceptability of the use of these type valves as being compliant with B31.1 or GDC-1.
Parsons recognizes that Specifications can be changed without regulatory approvals and that Millstone uses them as criteria that has been " pre-approved" to demonstrate compliance with design and license requirements. Parsons also agrees that criteria contained within these specifications can be changed by PDCRs after evaluating the technical acceptability of the change.
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TIME: 2:00 p.m.
1 For DR-0395, the issue that remains unresolved is that the PDCR did not contain any discussion of the acceptability of these butterfly valves in the proposed application or any discussion that these j
valves satisfied MP2 design and licensing basis requirements. Parsons' position is that, since the l
application is variant with an issued specification referenced by the PDCR, the PDCR should have
(
specifically addressed the compliance of this valve application to the design and licensing basis within the body of the PDCR, or in its safety evaluation. Parsons does not consider that the PDCR was silent on this issue, and yet approved by PORC, to be sufficient to demonstrate compliance to the design and licensing basis.
Discussion:
NNECo agrees with the discussion without change. Parsons will revise the response and resubmit the DR.
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DATE: 10/7/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs:
l DR-0748 and DR-0251
- 2. DRs, NNECo requested topic to discuss DRs:
DR-0042 LIST OF ATTENDEES:
I NNECo NRC NEAC Parsons l
Kalvin Anglin Ron Jackson Eric Benner none Eric Blocher Ken Mayers Prasad Bandaru Fred Mattioli Dick Boyd Trent Powers Phil Cushman Greg Tardif Dick Dicderich Ron Smith Joe Fougere Harold Thompson Wayne Dobson Dan Wooddell K'Chebe Grace Bob Skwirz John Hilbish Jon Winterhalter George Howard Bob Weth Garv Jackson
- 1. Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0748 (John Archer)
NNECo has dispositioned DR-0748 as a Non-Discrepant condition even though a change to a design basis specification SP-M2-EE-0012 has been formulated. Why is this not a discrepancy since a design basis document was changed?
Discussion:
NNECo will accept DR-0748 as a confirmed SL 4. Since the specification has been resised to Rev. 2, the correction has been implemented. No other action is required.
b) DR-0251 (Gary Jackson) (Rescheduled from 10-6-98)
Parsons disagrees with NU disposition of this DR being a Level 4. Section 5.8.4 is being changed and a " Regulatory Commitraent Change Request"is being processed to revise and clarify NU response to Question 5.23 and the AEC" SE to properly reflect the design and engineering basis for MP2 on this subject.
Parsons considers this to be a change to the Licensing Basis and considers this a Level 3.
Discussion:
NNECo will accept DR-0251 as a confirmed SL 3 and Parsons will close on that basis. CR M2 l 0329 was issued.
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- 2. Topic: DRs
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0042 (K'Chebe Grace, N) (Gary Jackson, P)
Iteml Discrepancy: Follow-up Response.
. Thermal movements are not documented within the pipe stress analysis.- Thermal movements at the HPSI and LPSI pumps have been input into the ME101 computer model based on the movements provided on the analysis isometrics isometric (Dwg. No. 25203-20224 Sh. 20 - Sh. 25). But, no reference as to the source or calculation of the thermal movements is presented in the calculation references. Calculation IC10-1, "HPSI Pump Nozzle Movements" dated 9/20/71 prosides pump movements for the normal and operating temperatures. The Maximum temperature movements are not supplied on the drawings. Calculation number 1C10-1 should be provided in the list of references.
Parsons ' " Comment on NNECo Response:" The identified CR's do not specifically address pipe thermal movements. Therefore, DR-0042 will remain open until calculations are received showing the
{
i inclusion of the proper reference for thermal movements.
NU would like to further discuss Parsons response to Item I stated above. NU would also like to l
include information presented in specification SP-M2-ME-030, Revision 00 in the discussion.
Discussion:
NNECo will accept DR-0042 as a confirmed SL 4 and Parsons will close on that basis.
CR M2-98-2883 was issued.
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CONFERENCE NOTES l
DATE: 10/8/98, Rev. O TlME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs:
I DR-0788, DR-0411, DR-0211, DR-0781, DR-0714, DR-0101, DR-0026, l
DR-0082, and DR-0294 2.
DRs, NNECo requested topic to discuss DRs:
DR-0541 l
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Kalvin Anglin Greg Tardif Eric Benner none Jonh Archer Ken Mayers i
Bill Cushman Bob Skwitz Eric Blocher Trent Powers Farid Elsabee Dick Boyd Dale Pmitt Joe Fougere Dom Cardinale Dom Ramos Ron Jackson Wayne Dobson Ron Smith Fred Mattioli John Hilbish Dan Wooddell Tom Pryhoda Gary Jackson Jon Winterhalter
- 1. Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0788 "EBFS-FSAR Discrepancies" (Dom Ramos)
Parsons issued as Level 3. NNECo response as Previously Identified.
Parsons would like to discuss the basis for classifying items 1 through 5 as Previously identified.
Parsons agrees with NU that item 6 is not discrepant.
Discussion:
NNECo requested this topic deferred to an unspecified date.
b) DR-0411 "EBFS-Dampers 2-EB-60 and 2-EB-61 Single Failure During AEAS Operation" (Dom Ramos)
During the August 20,1998, NNECo stated that further technical analysis will be provided to support the response to this DR (Telecon item 1.e). What is the status of this action item?
Discussion:
NNECo said this analysis is still open. It will be completed prior to restart. NNECo will retain the j
DR in " Follow up" status in their database.
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c) DR-0211 (Dominic Cardmale)
DR-0211 discussed the quality level downgrading of HPSI flow transmitters. NNECo responded stating the issue was Pre-Discovered by UIR-2712, and that AR 97014806 was tracking the upgrade of SP-M2-EE-0012 to show the correct design category.
The RG L97 design category is tied to the issue of MEPL quality evaluations. Eval CD-1409 downgrued these instruments to non-QA. MEPL evaluation CD-3120 later upgraded these devices to QA. NNECo Specification SP-ST-ME-944, Section 5.4.2 and Figure 7.7, requires preparation of a NCR or a CR when components are upgraded. The NCR attached to MEPL Eval CD-3120 is unnumbered and has little information included. Without a controlled number, the NCR in EVAL-CD-3120 can not be tracked.
Questions:
1.
Has an NCR number been assigned to evaluate the upgrading of the HPSI flow instruments identified in DR-021I? If so, what is the number and what is the current status of the NCR?
2.
If an NCR is not assigned, how will the necessary evaluation of the upgraded components be tracked?
- 3. Will the results of the evaluation for upgrade be retrievable through an NCR number, or the MEPL-EVAL CD number?
Discussion:
NCR 2-97-468 was prepared and NNECo will fax a copy to Parsons. Parsons will review the NCR and will close the DR if they concur with the NCR.
d) DR-0781 (Trent Powers)
Parsons wishes to discuss the difference in Significance Levels assigned to this DR. Parsons assigned as SL 3 for the periodic testing of 2-AC-11, NNECo assigned SL 4.
The difference in SL assignment appears to be due to whether 2-AC-11 is required to be tested periodically. Parsons believes that periodic testing of 2-AC-11 is required. As stated in the DR, SP 2613H, Rev 7, contained a matrix (Attachment 9) of the Facility 2 ESAS Actuation Relays and components actuated by these relays. Relay K602D is listed as actuating 2-AC-11 and 2-AC-20 and a not indicates that data is to be recorded in OPS Form 2605H-1. OPS Form 2605H-1 does not list 2-AC-II, but hsts 2-AC-20.
The NNECo response stated that no surveillance procedures that periodically verify damper 2-AC-1 I will close on a CIAS can be found, but stated that 2-AC-1 I was tested following implementation of PDCR 2-32-84.
Parsons does not concur that the one time testing of 2-AC-1 I satisfies the requirements for testing of 2-AC-11. FSAR Section 6.7.2.1 states that "The enclosure building filtraticn system is tested periodically to assure the negative pressure is maintained within the EBFR;" Section 6.7.4.1 states
" purge isolation dampers are tested periodically...;" and Section 6.7.4.2 states that " Individual components of the enclosure building are tested to ensure performance." Parsons believes that these FSAR statements provide the basis for periodic testing requirements of 2-AC-11. Since that periodic testing has not been documented in any surveillance procedure, this is considered to be a SL 3 issue.
Discussion:
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NNECo will accept DR-0781 as a confirmed SL 3. CR M2-98 2760 will correct.
e) DR-0714 (Dale Pruitt)
The discrepancy identified various switches classified as non-qualified devices located in Class IE circuits. NNECo specified these devices for an upgrade to QA Category I addressed by MP2-CD-3223. -In the conclusion for the response to the DR, NNECo states "These components are all fully qualified and were supplied with the Emergency Diesel package." Contrary to this, two work orders classified as non CAT-1 (M2-91-12859 and M2-91-12860) installed replacement switches for LS-8795 and LS-8796 per PDCR 2-086-91 which considered these switches not to be quality items. (See Section 3.6 of the PDCR).
Questions:
- 1. What is the basis for the statement that all these devices are fully qualified?
- 2. Has an NCR or condition been written that addresses these non-quality installations?
- 3. Has MP-CD-3223 been finalized?
Discussion:
- 1. The devices were qualified based upon the original installation.
- 2. The MEPL program does not require an NCR to be written until the evaluation is complete.
- 3. No. But it will be finalized prior to restart.
NNECo will investigate further and provide a CR number to Parsons proving "presious identification." Parsons will hold off responding to this DR pending future discussion to be initiated by NNECo.
f) DR-0101 (Trent Powers)
Parsons has reviewed the NNECo response to this DR and does not concur that the issues identified in the DR are Non-Discrepant. However, the NNECo response details a series of revisions of changes to SP-M2 EE-0012, resolution of some classifications with MEPL 3063 and completion of ESAR-PRGM-97-032.
Parsons proposes to close this DR as Previously Identified.
Discussion:
NNECo agreed that DR-0101 has been Previously Identified. Parsons will close.
DR-0026 was also discussed as Previously Identified instead of non-discrepant. NNECo agreed and Parsons will close.
g) DR-0082 (Gary Jackson)
Ref: Item 2, No. 3 Parsons concurs with NU's conclusion of this concern based on the issuance of NU Specification SP-M2-ME-030. This specification satisfies the configuration management concerns identified in Page 3 of 5 M981005 doc
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[
Parsons' previous response. However, since this specification was originated as a response to a l
previous DR (DR-0088) and is considered beyond the cut-off date for CMP discovery complete, i
Parsons considers this to be a Level 4 discrepancy. This DR can be closed, based on the completion of the specification.
Discussion:
Parsons will close DR-0082 as a SL 4. No funher corrective action is required, i
h) DR-0294 (RogerMauchline) l Ref: NNECo Response (M2-DRT-00294) '
Please supply Parsons with a photograph that clearly shows at least one weld of the six welds attaching LAR Sample No. 3 to the underside of the floor. The photograph copies of the support details in M2-DRT-00294 are not clear.
i Discussion:
NNECo will send a photograph within a few days.
- 2. Topic: DRs
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0541 (Farid Elsabee, Fred Matioli, N) (Joe Groncki, P)
Follow-up Response NU would like to further discuss Parsons response as stated below. NU would like to present further discussion re6arding the technical methods used and the acceptability of their methodology.
1 Parsons * " Comment on NNECo Response:" He formulae used by NNECo in thei' proposed r
corrective action are not applicable in calculating tank skirt allowables in the case of T8A and T8B.
. Both the elephant foot and diamond shape buckling mode evaluations are to be used as part of the
" Tanks and Heat Exchangers Review" found in Section 7 of the Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment, Rev. 2. Section 7.3.1 of the GIP states in part, "The type of vertical tanks covered by the screening guidelines are lange, cylindrical tanks whose axis of symmetry is vertical and are supported on their flat bottoms, directly on a concrete pad or a
- floor "
Since Boric Acid Tanks T8A and T8B are supported on skirts, with their bottoms raised off the concrete floor, the evaluation techniques of Section 7 (including the elephant foot and diamond shape buckling analysis) do not apply. Section 7.5 of the GIP specifically identifies vertical tanks supported on skirts as an outlier to the screening guidelines. Section 7.5 goes on to suggest Reference 26 (EPRI Report NP-5228, Revision 1, " Seismic Verification of Nuclear Plant Equipment Anchorage." Volume 4, " Guidelines for Tanks and Heat Exchangers") as a possible means of resohing this type of outlier.
Discussion:
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NNECo explained that the EPRI procedure was used instead of the GIP procedure for this tank.
NNECo will prepare another CCN to the calculation to provide clarification. The existing CR M2-98-1819 will be amended to cover the CCN.
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CONFERENCE NOTES DATE: 10/13/98. Rev. I TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs:
DR-0785, DR-0106, DR-0353, DR-0629, DR-0294, DR-0327, DR-0753, DR-0350, DR-0618, DR-0511, and DR-0313 2.
DRs, NNECo requested topic to discuss DRs:
DR-0296, DR-0071, DR-0078, DR-0200, DR-0061, and DR-0569 LIST OF ATTENDEES:
NNECo NRC NEAC Parsons j
Sing Chu Fred Mattioli Eric Benner none Mike Akins John Hilbish Bill Cushman Ray Necci John Nakoskv Jonh Archer Roger Mauchline Dan Van Duvne Chris Scully Eric Blocher Ken Mayers Farid Elsabee Bob Skwirz Dick Boyd Trent Powers Joe Fougere Greg Tardif Dick Cronk Ron Smith Bob Lawrence Bob Wcth Marc Grammes Dan Wooddell Ken Lanham Joe Groncki Jon Winterhalter
- 1. Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0785 (Trent Powers)
Parsons wishes to discuss the difference in Significance Levels assigned to this DR. Parsons classified as a SL 3, NNECo as a SL 4. Subject of the DR is wire bundle separation less than 6" in at least two places in the rear section of control room board C05.
SP-M2-EE-0016 requires a muumum 6" separation where feasible, use of noncombustible barriers or conduit when not feasible.
NNECo DR response states that this was prediscovered via control room walkdown as a corrective action per ACR-8761 and documented in EWD M2 07E0001-044. The NNECo technical evaluation for EWD M2-97E0001-044 concluded that there was not a discrepancy, but NNECo stated in DR response that CR M2-98-2722 has been written to re-evaluate the Engineering disposition in the technical evaluation.
Parsons does not understand why NNECo states: "..that the engineering evaluation was inadequate and the requirement for the CR driven re-evaluation is considered a Significance Level 4."
Discussion:
Parsons requested that this to, ac be tabled pending internal discussion.
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b) DR-0106 (Trent Powers)
Parsons wishes to discuss the difference in Significance Levels assigned to this DR. Parsons classified as a SL 3, NNECo as a 4. Parsons concurs that items 2,3, and 4 of this DR can be properly classified as SL 4 issues.
For Item 1, FT-5277A&B, NNECo's DR response states that " Low points and slope in the horizontal portions of sensing lines, from root to drain valves, for FT-5277A, and FT-5277B will be corrected as a maintenance item before restart via a approved Design Change Notice DM2-00-0054-98 (see attachments) by reclamping or rerouting to be consistent with drawing 25203-28408 sheet 977. The restored layout will be in compliance with drawing 25203-28402 sheet G-1, " General Instrument Installation Notes."
The NNECo response also discusses current practices and proposed future calibration procedure enhancements that reduce or eliminate potential for air induction into the tubing lines.
Parsons does not consider the rerouting of this tubing to be a minor " maintenance item" when Design Change Notices are used as the basis for the work. Drawing 25203-28402, Sh F02 establishes a 1"/ft minimum slope requirement. Walkdowns confirmed that the tubing has low points and other portions of the lines when the slope requirement is not satisfied.
Parsons agrees that the corrective action proposed for this DR is appropriate but considers the DR to be SL 3 based upon the field changes being made to bring the field condition into compliance with slope requirements.
Discussion:
Parsons requested that this topic be tabled pending internal discussion.
c) DR-0353 (Trent Powers)
A portion of this DR addresses the 8" HCD-6 overflow pipe not being seismically qualified. This piping is directly over all four conduits that contain the circuits for the RWST level transmitters, where failure of the piping could damage all four level circuits. Implementation of the GlP program required potential interactions due to failure be considered as part of the seismic verification walkdown. The screening evaluation worksheets for the RWST level transmitters did not address the potential interaction of the overflow pipe.
He NNECo response to this item was that this DR is non-discrepant since a field inspection by an experienced seismic / structural engineer verified that this piping satisfies the criteria in MS-35 and was not likely to damage the four ESF channels of the RWST level circuits l>cated below.
The response also stated that the GIP implementation for these level trasmitters reviewed potential interactions from the transmitters tc. the first conduit support only. The response goes on to state that even when II/I reviews of cable trays and conduits are performed, documentation of such a review on the SEWS was not necessary.
The response also states: "Since the transmitters are located in a weather enclosure adjacent to the RWST and are thus protected from interaction with the overflow line, unacceptable seismic 11/1 interactions were not deemed realistic."
Parsons believes that FSAR section 5.8.4 defines the basis for addressing 11/1 interactions, both for initial plant construction and subsequent modifications to the plant. Since the piping has been walked l
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i CONFERENCE NOTES DATE: 10/13/98, Rev.1 TIME: 2:00 p.m.
down and verified to be unlikely to cause a 11/1 concern, Parsons proposes that this DR be reduced to a SL 4 issued for the lack of documentation of the II/I review.
Discussion:
Parsons will close as Non-Discrepant.
d) DR-0629 " Conflicting Information Presented in Final Safety Analysis Report"(Marc Grammes) -
Parsons issued the DR as Significance Level 3. NNECO responded to the DR as a Confirmed Level
- 4. Parsons would like to discuss the basis for Significance Level 4.
Discussion:
I NNECo agreed to accept as Conformed SL 3 and Parsons wil.1 close on that basis.
1 e) DR-0294 (RogerMauchline)
Additional questions on NU Response (M2-DRT-00294) to DR-0294:
i The original LAR sample size by Vectra was 4. From M2 DRT-00294 the sample size has apparently been expanded to 16. In view of the fact that two supports did not pass the LAR requirement for capacity, please discuss the following issues:
- 1. Is LAR sampling complete in finding all worst case examples?
2.
If not complete what further sampling is being done?
- 3. If complete, what actions are being taken to insure that all supports with similar configurations to those not passing the LAR are acceptable.for seismic loads?
Comment only: If the proposed modifications tie the floors together, consider the possible effect of load in the supports from differential floor movements.
Discussion:
- 1. Yes
- 2. N/A 3.
100 percent sampling NNECo will E-mail photograph today.
f) DR-0327 (Trent Powers)
Parsons wishes to discuss the Previously Identified classification of this DR. It is unclear to Parsons how the specific issue of this DR would have been identified within UIR 473 and AR 970103R5-02.
AR 97010385-02 recommend the evaluation of breaker sizing and feeder cable from the inverter to the outgoing feeder cables of the Vital Instrumentation Panels VA10, VA20, VA30, and VA40.
Parsons believes that AR 97010385-02 would not have identified the issue being raised in DR-0327.
The issue being raised by Parsons concerns cables downstream of the outgoing feeder cables from the VA panels and have different cable numbers.
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Discussion:
1 NNECo will send a copy of the Technical Evaluation M2-EV-98-0124. Parsons will resiew it and decide if the DR can be closed as SL 4.
g) DR-0753 (Ken Mayers)
NNECo's disposition response indicates that the discrepancy is only a documentation error. CR M2-98-2746 recommends re-wiring as required to correct the discrepancy.
Based upon NNECo's walkdown, what is the planned NNECo corrective action associated with this discrepancy?
NNECo requested that this topic be deferred to 10-14-98.
h) DR-0350 (Ken Mayers)
In CR M2-98-1450 "Reportability Determmation" NNECo states that "Thus the critical Tech Spec j
limit (the volume of water between the two alarms) is not affected."
Is the low alarm the method of surveillance used to guarantee the RWST nummum Tech Spec Volume?
How does an operator correlate indicated level in percent to volume?
NNECo requested that this topic be deferred to 10-14-98.
i) DR-0618 (Ken Mayers)
. This DR addressed three issues (1) the " seal in" error on drawing 25203-28150 sheet 3, (2) failure to test the reset of the ESAS sequencer timer when SIAS signal is received after an LNP, and (3) the mode of operation for item (2) is not described in the FSAR. Parsons agrees with NNECo's response and disposition to items (1) and (2). This question is concerned with item (3).
For item (3), NNECo's response indicated that for this vintage of FSAR, that the reset of the j
sequencer when SIAS is received after an LNP is sufficiently described in FSAR Section 8.3.3.1, 7.3 and FSAR Figure 7.3-3.
j Since Figure 7.3-3 is the only document that demonstrates / describes this feature and since FSAR Figure 7.7-3 is drawing 25203-28150 sheet 3, why does NNECo believe this is NON-DISCREPANT and not a SIGNIFICANCE LEVEL 3 discrepancy?
NNECo requested that this topic be deferred to 10-14-98.
j) DR-0511 (Ken Mayers)
NNECo's corrective action is to add a note to the affected drawings indicating that " Seismic tubing run must keep 18 inches from other lines except the first vertical tubing run connected to the pressurizer condensate tee for PT-102A, (B), (C), (D)."
- 1. How will adding the note to the drawing as stated in the corrective action resolve the discrepancy that still will exist between the revised drawing and MS-67?
discrepancy?
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NNECo requested that this topic be deferred to 10-14-98.
k) DR-0313 (Trent Powers)
Parsons wishes to address the difference in Significance Levels assigned to this DR. Parsons has assigned as SL 3, NNECo as SL 4. Parsons still considers this to be an SL 3 discrepancy since it constitutes an incorrect basis for demonstrating compliance with the event acceptance criteria.
NNECo requested that this topic be deferred to 10-14-98.
- 2. Topic: DRs
Background:
NNECo requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-02% (Bob Lawrence, Dan VanDuyne, N) (Roger Mauchline, P)
Discussion Points:
- 1. Acknowledge an error was made in the Calculation submitted with IRF-01714 (wrong sign used).
NU has issued Revision 03.
- 2. The values for hanger loads used by Parsons in their calc. were taken from sheet 9 of i1 of Book I of 6. Explain the reason NU used more rigorous values.
- 3. Explain that the NU cale shows the loads are within the design basis.
4.
If necessary, discuss the various Rev levels in Books 1 through 6.
- 5. Note that the connection plates with 4 side weld configuration have also been evaluated in Rev.
03.
- 6. Accept as Significance Level 4 DR (Not outside LB/DB) - Request Closure Discussion:
NNECo will send the revised calculation. Parsons will review it and determine if the DR can be closed as a SL 4.
b) DR-0071 Condensate Storage Tank (Fred Mattioli, N) (Jon Winterhalter, P)
This DR discusses three issues. The first being an elevation error discovered in the FSAR; the second i
issue deals with soil bearmg pressure; and the third deals with a mat thickness item.
T Parsons has agreed with the response for Item 1.
Parsons does not agree with the response provided in Item 2.
Parsons has agreed with the response provide for Item 3.
NNECo would like to discuss closing this DR as a CONFIRMED LEVEL 4.
NNECo would like to close item two to the actions being performed under DR-0070. DR-0070 is updating the section of the FSAR regarding soil pressure. This action is the same as required for DR-0071.
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Discussion:
Parsons will close this DR as SL 4 since the DR-0070 corrective action encompasses the correction of this discrepancy.
^
c) DR-0078 FSAR/ FHA Incorrect Appendix R Exemption References (Fred Mattioli, N) (Trent Powers, P)
This DR discusses three issues. Item 1 and 3 have been accepted by Parsons. Item 2 was not accepted. Parsons stated, "Since we have not received this information in a CR or other acceptable tracking mechanism, it will remain open."
NNECo would like to discuss closing this DR. Within the first response, AR numbers tracking this work was provided. AR's used from AITTS is the tracking mechanism.
Discussion:
NNECo will provide the CR or other parent document of the listed ARs d) DR-0200 Nozzle Load Evaluations - Aux Feedwater and HPSI Pumps (Fred Mattioli, K'Chebe Grace, N) (Joe Groncki, P)
NNECo would like to discuss closing this DR as a CONFIRMED LEVEL 4. NNECo has reviewed Parsons response and has agreed that this can be closed as a SL 4.
Discussion:
Parsons agrees with closing this DR as a Confirmed SL 4. No other action required.
c) DR-0061 (Bob Weth, N) (Dan Wooddell, P)
Purpose for conference call is the closure of DR based on the following.
1 All items for this DR are closed with the exception ofitem l A.
2.
For item l A, CR M2-98-3042 has been issued to provide the corrective action to resise procedure MP 2703Al1 prior to the next turbine driven AFW Pump disassembly to add steps to identify the "As Found" and the "As Left" measurements. We will prepare and transmit to Parsons a CONFIRMED SIGNIFICANCE LEVEL 4 IRF delineating this position. Note that this position is in accord with the Parsons "Second Comment on NNECo Response" for this DR.
Discussion:
Parsons agrees with SL 4 and will close..
f) DR-0569 (Bob Weth, N) (Dan Wooddell, P)
Purpose for this conference call is the closure of DR based on the following:
CR M2-98-3043 has been issued to provide the corrective action to:
- 1. Verify that the evaluation per A/R #97024786 will result in Volume Dampers 2-EB-1 A,2-EB-IB,2-EB-lC, and 2-EB-9 being classified, inspected and tested a.s QA, CAT I dampers.
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- 2. For the Fire Dampers, the corrective action plan will document the criteria which requires the testing of Fire Dampers (including 2-EB-131,2-EB-157,2-EB-158,2-HV-251, and 2-HV-252) under flow conditions and revise the applicable maintenance form 2701J as required. We will prepare and transmit to Parsons a CONFIRMED SIGNIFICANCE LEVEL 4 IRF delineating this position.
Discussion:
Both items arc closed to the same CR as Confirmed SL 4.
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TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
l 1.
DRs, Parsons requested topic to discuss DRs:
)
DR-0753, DR-0350, DR-0618, DR-0511, and DR-0313 2.
DRs, NNECo requested topic to discuss DRs:
DR-0744, DR-0006, DR-0019, DR-0160, DR-0235, and DR-0684 3.
DRs, Parsons requested topic to discuss DRs:
DR-0033, DR-0694, DR-0795, DR-0759, DR-0701, DR-0654, DR-0617, DR-0620, DR-0470, DR-0337, and DR-0127 LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Bill Aiken Fred Mattioli Eric Benner None Mike Akins John Hilbish Bob Carritte Kav Necci John Nakoskv John Archer Dave Lengel Norbert Carte Tom Prvhoda Eric Blocher Roger Mauchline Sing Chu Greg Tardif Dick Boyd Ken Mayers Bill Cushman Bob Skwirz Juan Cajigas Trent Powers Joe Fougere Bob Weth Gordon Chen Dom Ramos Mark Gravell Rich Glaviano Ron Smith Dan Hundlev Marc Grammes Dan Wooddell Ron Jackson Joe Groncki Jon Winterhalter
- 1. Topic: DRs (Leftovers from 10-13-98)
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0753 (Ken Mayers)
NNECo's disposition response indicates that the discrepancy is only a documentation error. CR M2-98-2746 recommends re-wiring as required to correct the disciepancy.
Based upon NNECo's walkdown, what is the planned NNECo corrective action associated with this discrepancy?
Discussion:
Parsons will close as SL 4 pending review of CR backup documentation.
b) DR-0350 (Ken Mayers)
In CR M2-98-1450 "Reportability Determination" NNECo states that Thus the critical Tech Spec limit (the volume of water between the two alarms) is not affected."
Is the low alarm the method of surveillance used to guarantee the RWST minimum Tech Spec Volume?
How does an operator correlate indicated level in percent to volume?
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Discussion:
Parsons will review the procedure and raise issue later.
c) DR-0618 (Ken Mayers)
This DR addressed three issues (1) the " scal in" error on drawing 25203-28150 sheet 3, (2) failure to test the reset of the ESAS sequencer timer when SIAS signal is received after an LNP, and (3) the mode of operation fbr item (2) is not described in the FSAR. Parsons agrees with NNECo's response and disposition to items (1) and (2). This question is concerned with item (3).
For Item (3), NNECo's response indicated that for this vintage of FSAR, that the reset of the sequencer when SIAS is received after an LNP is sufficiently described in FSAR Section 8.3.3.1, 7.3 and FSAR Figure 7.3-3.
Since Figure 7.3-3 is the only document that demonstrates / describes this feature and since FSAR Figure 7.7-3 is drawing 25203-28150 sheet 3, why does NNECo believe this is NON-DISCREPANT and not a SIGNIFICANCE LEVEL 3 discrepancy?
Discussion:
NNECo will accept as a SL 3 and Parsons will close accordingly, d) DR-0511 (Ken Mayers)
NNECo's corrective action is to add a note to the affected drawings indicating that " Seismic tubing run must keep 18 inches from other lines except the first vertical tubing run connected to the pressurizer condensate tee for PT-102A. (B), (C), (D)."
How will adding the note to the drawing as stated in the corrective action resolve the discrepancy that still will exist between the revised drawing and MS-67?
Since a document must be changed, why does NNECo believe this is a SL 4 and not a SL 3 discrepancy?
Discussion:
NNECo will perform Engineering Evaluation and raise topic later.
e) DR-0313 (Trent Powers)
Parsons wishes to address the difference in Significance Levels assigned to this DR. Parsons has assigned as SL 3, NNECo as SL 4. Parsons still considers this to be an SL 3 discrepancy since it constitutes an incorrect basis for demonstrating compliance with the event acceptance criteria.
Discussion:
NNECo will accept as a SL 3 and Parsons will close.
I i
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- 2. Topic: DRs
Background:
NNECo requested topic to discus' the DRs listed below.
s DRs for Discussion:
l a) DR-0744 (Tom Pryhoda, N) (Frank Cobb, P)
J Parsons says we misinterpreted the prerequisite test requirements in ANSI N510 for the RG 1.52 l
compliance that we agreed to in our T/S.
NU's position is MP2 was not a RG plant and we selected portions of RG 1.52 to use for acceptance criteria in testmg our charcoal filters.
NU acknowledge the prerequisite tests validate the subsequent test results and we will perfonn these tests following any future mod to the filtration systems, but for now we are takmg exception from the
" guidance"in RG 1.52. NU explained this clearly in the TRM.
NNECo requested this topic to be rescheduled to 10-20-98. See 10-20-98 notes.
b) DR-0006 (Greg Tardif, N) (Dan Wooddell, P)
Confirmed SL4 in "Pendmg" status. NU requests closure of this DR.
Discussion:
Parsons will close as a SL 4.
c) DR-0019 (Greg Tardif) (Dick Cronk, P)
Confirmed SL4 in "Pending" status. NU requests closure of this DR.
Discussion:
,1 FSARCR is not completed. CR M2-98-1892 was written. Parsons will close as SL 4.
d) DR-0160 (Greg Tardif, N) (Trent Powers, P)
NU has re-evaluated the metlaj of " Pre-Discovery" and has concluded that this DR should be closed as a Confirmed Significance ImJ 4 DR.
Discussion:
Parsons closed this DR on 9-16-98 as Previously Discovered.
c) DR-0235 (Greg Tardif, N) (Dick Cronk, P)
' NU has re-evaluated the method of" Pre-Discovery" and has concluded that this DR should be closed as a Confirmed Significance Level 4 DR.
Discussion:
CR M2-98-2883 was written. Parsons will close as SL 4.
f) DR-0684 (Tom Pryhoda, N) (Frank Cobb, P)
DR deals with a partially tumed over but still open design modification.
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Parsons says our retest method of a damper is insufficient to prove it works during an unlikely but possible fan lineup.
NU told Parsons the mod is still open. NU had the damper factory modified and tested and sent the test results. Parsons says this still doesn't prove it will close with the main exhaust fan running. NU has a future test planned that will answer this question. In the meantime, Parsons wants:
An analysis that the damper actuator has sufficient torque to close the damper against the running fan and A copy of our revised post mod test (for the open DCR) that explains conditions required for successful completion NU has a proposed corrective action. NU would like to present a revised retest method to Parsons.
NNECo requested this topic to be rescheduled to 10-20-98. See 10-20-98 notes.
3.
Topic: DRs
Background:
Parsons requested topic to discuss the DRs listed below.
DRs for Discussion:
a) DR-0033 HPSI Degraded Pump Curve (Gordon Chen, Rich Glaviano)
The initial Parsons response concurred with the NNECo determination th:1 ftem '. is appropriately classified as PREVIOUSLY IDENTIFIED BY NNECo - CLOSED and that Item 2 L NON-DISCREPANT. The initial response classified item 3 as OPEN pending further information from NNECo regarding incorporation of accident analysis design inputs into the plant sun cillance procedures for HPSI Pump testing.
The second NNECo response identifies that Action Request AR 98008632, initiated April 4,1998, will confirm the required design basis information for the HPSI (and other) pumps is integrated into the IST Program / procedures thereby assuring that the acceptance criteria is bounded by the design basis requirements. Note: AR 98008632 defmes the NNECo response to Information Notice 97-90, "Use of Non Conservative Acceptance Criteria in Safety-Related Pump Surveillance Tests." This AR seems to be the only document clearly linking accident analyses HPSI design inputs to the plant surveillance test program. Thus, Parsons views this issue as Discrepant (Level 3) h rsons views the AR98008632 assigned action as appropriate to resolve the issue.
Parsons recommends disposition as CONFIRMED LEVEL 3 - CLOSED.
Discussion:
This topic was discussed on 10-15-98. NNECo will accept this DR as a SL 3. CR M2-98-1431.
b) DR-0694 Fuel Handling Accidents (Juan Cajigas, Dave Lengel, Rich Glaviano)
Item 1 -lodine Decontamination Factor NU responded that this item is Non-Discrepant. WCAP-7828 was cited as the basis for this conclusion. Parsons believes the item is discrepant and Significance Level 4 applies.
The existing analysis identifies that the assumptions are in accordance with RG 1.25. The RG 1.25 decontamination factor of 100 is based on a water depth "between the top of the fuel rods and the fuel pool surface of 23 feet." The guide further indicates that for " water depths less than Page 4 of 12 M981014. doc l
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23 feet, the iodine decontammation factors will be less than those assumed in this guide and must be calculated on an individual case basis using assumptions comparable in conservatism to those of this guide." Therefore, in accordance with the RG 1.25 requirements, NU needs to prepare an engineering evaluation / calculation tojustify using a DF of 100 with less than 23 of water depth available. This evaluation may make use of WCAP-7828 if the assumptions used in the WCAP-7828 and any others used in the evaluation are shown " comparable in conservatism" to those used in RG 1.25. NU would need to document this approach in the appropriate fuel handling accident calculations in order to comply with the RG 1.25 requirements.
An assembly can be damaged by falling onto another assembly. NNECo lacks an analysis to prove othenvise. Thus, the DF afforded by the minimum required water level needs to be addressed for this condition.
Based on the above, Parsons considers this item as a Significance Level 4 discrepancy.
Item 2 - Missinn/Inadeauate Justification for Number of Damaced Fuel Rods (FHA in the SFP)
NU responded that this item is Non-Discrepant. The NU position is that the Millstone Unit 2 Licensing Basis for the Fuel Handling Accident in Containment assumes that 14 fuel pins (one row) fail. The bases provided is memo #RAC-98-289. In this memo, it is stated the NRC accepted NNECo's position on 14 damaged rods. Also, in Siemens' memo RIW:97:020, Siemens states that their recent evaluation concluded that the number of rods damaged by the drop of a SPC fuel assembly is bounded by previous analysis.
Parsons believes the item is discrepant and Significance Level 4 applies. This DR item is addressing the lack of a calculation / evaluation that supports the assumption that only 14 pins would be damaged. The memos referenced do not provide any additionaljustification for the assumption. In fact, memo #RAC-98-289 states "This impact is assumed to result in one row of the rods in the assembly being breached."(page 1 of 4,last sentence). The Siemen's memo appears to ratio conditions from the FSAR (which does not have an analytical basis). The lack of a calculation / evaluation to support the analysis and the FSAR wording is the issue of this DR item.
Since this information does not exist, Parsons considers this item as Discrepant, Significance Level 4. (Lack of documentation to support licensing bases.)
Item 3 - Non-Uniform Mixing (Fila Inside Containment)
NU responded that this item is a Significance Level 4 discrepancy. Three CR's (CR M2-98-0507, CR M2-98-2494, and CR M2-98-2814) were written to address this issue. AR 98017440-04 was written to correct the operating procedure (OP 2314B). Technical Evaluation M2-EV-98-0186 was performed and a new calculation (M2FHAIC-02701R2) was prepared to address this issue.
Parsons considers this item to be a Significance Level 3 discrepancy. The technical evaluation indicated that one fan was not sufficient to provide uniform mixing within containment. In fact, it went on to say that the one fan operation configuration did not meet the intent of the licensing basis. Additionally, on 9-11-98, the significance level of CR M2-98-2494 was changed from a 2 to a 1 because this issue was determined to be reportable.
Since this issue is considered reportable by NNECo, and since the intent of the licensing bases is not met, Parsons considers this item as a Significance Level 3 discrepancy.
Two Other items for Discussion on thii lissue:
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He technical evaluation identifies that during the purge mode, all the air mixing will effectively occur in the upper containment elevations (above 38' elevation) which accounts for approximately 2/3 of the total containment volume. Parsons concurs with this assessment conclusion. However, the evaluation goes on to use the entire containment volume in determining air change rates.
Parsons considers this to be non-conservative as there is no forced ventilation in the lower containment regions since the CAR fans are not required to operate during refueling. The air change rate, due to natural circulation alone, in the lower ponion of containment will be much less than that calculated in the evaluation.
The new calculation, M2FHAIC-02701R2, utilizes inputs which have been identified as discrepant in DR-0814. NNECo should consider the impact of DR-0814 resolution on this new calculation and revise if necessary.
I Item 4 - Release Point and Filter Efficiencies - Spent Fuel Cask Dron Accident Parsons concurs with the NNECo conclusion that this item is a Significance Level 4 discrepancy.
Luumu.
Item 1:
From 10-15-98 call, Confirmed SL 4.
Item 2:
From 10-15-98 call, Confirmed SL 4.
Item 3:
Confirmed SL 3.
Item 4:
Confirmed SL 4.
c) DR-0795 AFW Response Time Testmg (Gordon Chen, Rich Glaviano)
The NNECo response states that AFAIS response time issues were identified as a result of the reviews initiated in response to Generic Letter 96-01. Cited is Report MPR-1816, dated April 1997, which documents the review of ESAS circuitry. This review was undertaken to ensure all ponions of the electrical circuitry required to fulfill a Technical Specification requirement were covered within a surveillance procedure and that surveillances are performed within the frequency required by the Technical Specifications. Consequently, the time response issues identified in the report, where appropriately addressed, fall within the "Previously Discovered" Category. A review of the DR issues follows:
- 1. Delay time of the SG Level instrument loop The Engineering Evaluation M2-EV-98-106 in response to AR 97028779-06 does not identify the need to correct SP 2604P to include (or otherwise account for) the response time of the actuation circuit (SG level through Auto Start annunciators). The response time measurement of Ref. 5 is started from the AFW Auto Start signal indicated by the annunciator. The results of Ref. 5 are transcribed to SP 2604P for total AFAIS response time calculation.
As indicated in M2-EV-98-106, page 17, the logic circuit from the transmitter to the annunciator are incorporated into the I&C procedures tracked by AR 97010071-05. Review of this AR item indicates the corrective actions were completed by revision of SP 240lNA/NB/NC/ND issued on l
9/12/97. However, these procedures only include response time for test of the RPS circuits, no*.
l the AFW circuits.
l The AFAIS logic circuit response time test cannot be identified. Also, the current SP 2604P, Rev.
7, directs transcription of the logic circuit response time from SP 2403H (superseded by SP i
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r 2403HA/HB/HC/HD). These procedures do not include the AFAIS logic circuit response time test.
Resolution: Discrepant as Significance Level 3.
- 2. ' Time for the AFW pump to develop desired flow / pressure -
De Engineering Evaluation M2-EV-98-106 in response'to AR 97028779-06 provides guidance to include AFW pump run up time in the AFAIS response time test.
- Resolution: Previously Identified - Closed
- 3. Time for the valves to stroke open-The Engmeering Evaluation M2-EV-98-106 in response to AR 97028779-06 provides guidance to include AFW valve opening time in the AFAIS response time test.
I Resolution: PreviouslyIdentified-Closed
- 4. Document Discrepancy Per Reference 7, the FW-43A/B blue lights indicate the valve leaving the closed seat. The Reference 8 schematic drawings show the blue lights indicate a full open FW-43A/B valve position..ne discrepancies between Ref. 7 and Ref. 8, regarding blue light indication for valve position of FW-43A and FW-43B, are not addressed by this response.
'i Resolution: Level 4 Document Discrepancy.
This topic was rescheduled to 10-15-98. See 10-15-98 notes.
I d) DR-0759 LOFW Analysis (Rich Glaviano)
NU has concluded that the issues reported in DR-0759 have identified a CONFIRMED
- SIGNIFICANCE LEVEL 4 condition (Item 5) which requires correction.
NNECo has provided a qualitative assessment of the impact of each item on the analysis results. If there were significant SG inventory available for the limiting case, this kind ofevaluation may be sufficient. ~While, individua'ly each contri'outor may be small, the cumulative effect has not been j
quantified. With the minimal (~1100 lbm/SG) calculated inventory, a more rigorous assessment is appropriate. Further comments are prosided below-Item 1 - RCS Flow assumed at TS muumum value j
NU Response NU has conduded that this item is not a discrepant condition. The LNFF event is a relatively long term, quasi steady-state event. The heat transfer rate from the primary to the secondary systems, and therefore the steam flow out of the steam generators, is controlled by decay heat and by RCS pump heat. Using a nominal plant flow of 387,000 GPM would result in a slightly higher primary to secondary heat transfer coefficient. Because the total heat transfer rate is set by decay heat and RCS pump heat, and because the secondary system temperature is fixed at the Main Steam Safety Valves' (MSSV's) opening setpoint, increasing the primary to secondary heat transfer coefficient would only cause a small change in the primary system temperatures. His would not impact the total heat transfer rate to the secondary system.
Parsons Comment:
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A higher RCS flow rate would promote increased heat transfer from the fuel and RCS metal into the RCS. The energy, along with RCS internal energy (Tave), would more readily transfer into the secondary system.
NU Response:
The LNFF analysis used the Technical Specification minimum RCS flow rate of 360,000 GPM.
Using the Technical specification minimum RCS flow raises the average primary coolant temperature (Tave). A higher Tave maximizes the energy stored in the primary system and the energy that must be removed by steam flow out of the secondary system. Therefore, it was conservative to use the minimum RCS flow for the LNFF analysis.
Parsons Comment:
The higher Tave is a result of energy not being transferred into the secondary, which should be non-conservative.
Item 2 - 500 Tubes per SG assumed oluned NU Response:
NU has concluded that this item is not a discrepant condition. The impact of changes in the steam generator heat transfer area due to difference in the steam generator tube plugging would be similar to the changes in RCS flow rate explained in Item 1 above. The increase in heat transfer area would only cause a small change in the pnmary system temperatures during the transient, and would have no significant impact on the total energy transferred to the secondary. However, changes in the heat transfer area would not affect the initial primary system temperatures or the attendant stored energy in the primary system coolant. Therefore, the level of steam generator tube plugging assumed in the analysis will not have a significant impact on the results of the analysis.
Parsons Comment:
When SG level is low, the number of tubes available for heat transfer will become a factor. Agree j
the contribution may be small, but should be quantified due to the low minimum SG inventen.
Item 3 - MS Bvnass and ADV's assumed not to operate NU Response:
NU has concluded that this item is not a discrepant condition. The LNFF analysis did not take credit for the Main Steam Bypass Valves or the ADV's. It was conservative not to credit the bypass and dump valves because it maximized the transient secondary pressures. Maintaining higher steam generator pressures minimizes the capacity of the Auxiliary Feedwater (AFW) system, which is the critical parameter in determining if the steam generators dry out.
Parsons Comment:
Competing effects: lower steam pressure (lower Tsat) increases SG inventory boiled off, lower steam pressure enables increased AFW flow. Is there a sensitivity analysis or calculation which supports higher SG pressure as the limiting condition?
l NU Comment:
Additionally, the energy removed by flow out of the steam generators does not depend on whether the flow is through the bypass and/or dump valves or the safety valves because the enthalpy of the Page 8 of 12 M981014. doc
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steam is approxunately constant over the pressure range covered by the steam bypass or safety valve setpoints.
Parsons Comment:
Concur that steam enthalpy -(BTU /Lbm) is approximately constant over this range.
Item 4 - MSSV Biasinn and Flow Canacity NU Response l
- NU has concluded that this item is not a discrepant condition. ' As explained in the response to l.
Item 3, the capacity of the AFW system is the critical parameter in determining if the steam l
generators dry out.
Parsons Comment:
- Concur similar to item 3. Likely bounded by item 3. Non-Discrepant.
NU Response Changing the flow capacity of the valve only changes the amount of time it is open; it does not change the total steam flow rate out of the valve.
Parsons Comment:
Concur that there are slight changes in timing, not in total quantity of steam released. Non-Discrepant.
Item 5 - AFW Flow Control Valve Sinole Failure NU Response This item is discrepant. Condition Report (CR) M2-98-2bu4 (attached) has been written. There is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.
Parsons Comment:
Concur Significance Level 4.
NNECo requested that this topic be rescheduled to 10-15 98. See 10-15-98 notes.
c) DR-0701 (John Archer)
NNECo has dispositioned DR-0701 Item 1 as not a discrepant condition because if NNECo deternunes that if some components have little or no maintenance performed on them, then there is little or no reason to have them in PMMS.
I Question: How does NNECo account for components in Class IE circuits such as motors and switches that are quality related SSCs per FSAR Appendix 1 A, Criterion 1 if they are npt posted in PMMS? In addition, is this Item I issue not related to Item 2 of DR-0701 in which NNECo has p
prepared CR M2-98-2840 and referenced CR M2-98-1676 that addresses lack of component qualification?
Question: NNECo also implied that there was no need to include hand switches (HS-4192A,B,C,D),
j mentioned in the previous question, in PMMS. From a consistency standpoint, since other hand switches (such as HS-4188C,D,E,F) are included in PMMS; why are these not included?
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l l
For Item 3 of DR-0701, NNECo has stated that the resolution of M2-DRT-00756 is applicable to this l
DR-0701 regarding the instrumentation scismic issue applicability of TE M2-EV-98-0110 to non SSEL components.
l Question: Since the NNECo referenced 9/10/98 telephone conference call did not conclude an I
agreement on the applicability of TE M2-EV-98-0110 to non SSEL components how can a seismic l
resolution be dispositioned?
Question: NNECo has responded that the identified components would not have required any specific seismic qualification. Can NNECo determine if there is a mechanism, such as St N (Seismic l
Qualification Reports), that can appropriately and briefly document salient facts r ated to the seismic qualification assessment ofindicator lights, hand switches, the governor motor, au resistors so that they can be dispositioned in a formalized manner?
For Item 3 of DR-0701, it has been determined that only one side of the blue lights are physically connected.
Question: Since the physical plant configuration does not agree with the design basis, why is the assigned significance a level 4 instead of a level 3?
This topic was rescheduled to 10-15-98. See 10-15-98 notes.
f) DR-06S4 (Ken Mayers)
NNECo's response provides justification of your position with respect to using a pressure switch downstream of the DG FO shutoff valve to indicate the valve has inadvertently closed. Further, NNECo has indicated that SP 2669A, as part of PEO rounds, verifies the oil pressure exceeds 5 psig of the gauge panel. Normal inlet pressure with the fuel oil storage tank at its Tech Spec limit is approximately 10 psig.
- 1. Assuming that the valve inadvertently goes closed trapping the downstream pressure at 10 psig, how does the operator know that the valve is closed?
- 2. With the valve closed, what is the time for the pressure to bleed down to the alarm set point of 3 psig and what is the leakag,: mechanism that will consistently assure this?
3.
If the valve inadvertently closes and the valve seat is leaking, how is the valve closure detected?
4.
This valve is critical to EDG operation, what testing is done to demonstrate that inadvertent I
closure is quickly detected?
NNECo requested that this topic be rescheduled to 10-15-98. See 10-15-98 notes.
g) DR-0617 (Mayers) l NNECo's response stated that IEEE 279 does not specify how the IEEE 279 requirement - "If the protective action of some part of the system has been bypassed or deliberately rendered inoperative for any purpose, this fact shall be continuously indicated in the control room" is to be satisfied. NNECo further stated that "The Millstone 2 design satisfies the requirement by making use of the blue status light. The fact that the blue light goes out on an abnormal or bypassed condition is the continuous indication in the control room. The operators are trained that the lights are on under " safe" conditions and that when the lights are off there is an " unsafe" or override condition." Following an ESF actuation, whenever the operator moves the control switch to the " safe" position, the override feature is actuated.
Page 10 of 12 M981014 doc
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DATE: 10/14/98. Rev. O TIME: 2:00 p.m.
- 1. Assuming a HPSI pump is running and the operator initiates override, what is the status of the blue light lit when the operator moves the switch to the safe position?
2.
Assuming that the operator has overridden the HPSI pump and precedes to stop it, Parsons agrees that the blue light will not be lit. Assume at a later time, the pump is manually restarted and the blue light is lit again.
- 3. How is IEEE 279 continuous bypass indication requirement met for this condition?
Discussion:
NNECo will review DR-0617 together with DR-0634 and raise the topic in the future.
h) DR-0620 (Topic continued from 9-29-98 teleconference)(Dom Ramos)
Parsons issued as Level 3. NU response as NON-DISCREPANT.
The issues raised by the DR are applicable to the system regardless of DCR M2-97008. According to 6/16/98 conference notes, topic #3, the DCR is comp'ete except for testing. ICAVP decided to include the DCR because its date is within " CMP complete", it is a new document, and its review would be a good CMP indicator.
Revising the DCR safety evaluation and other associated documents at the last stage of the DCR, even though it is still not totally complete, is a weakness in the process and is not a valid reason for categorizing the DR issues as NON-DISCREPANT.
Parsons has received and reviewed the supplementary documents (M2-IRF-02853) to NU's initial response to the DR (M2-IRF-02721). Parsons would like to discuss the documents because they do not contain information that would resolve the two issues identified by the DR.
Discussion:
NNECo will review zone boundaries and discuss again.
i) DR-0470 ( Ken Mayers)
NNECo's response stated that a walkdown of HS-3015 (HPSI pump P-41B) concluded that the wiring from the switch canister ". is orange, the color identified in FSAR section 8.7.3.1, Table 8.7-4 for a channel 5 vital circuit and not red (color code for channel I vital circuit) as identified in a Parson's walkdown."
As denoted in DR-0470, the correct color should be orange. Parsons walked down this circuit on three occasions. The last time was,7/30/98, following the receipt of NNECo response indicating that this is non-discrepant. This third walkdown was done with two individuals and a photograph was taken. All visual walkdowns reported that the cable was " red" The photograph taken on 7/30/98 shows the wire as " red" Because switch HS-3014 (HPSI channel Z1 " red" pump P41-A) is located in close proximity, a mistake in identifying the cable could have been made.
Could NNECo re-confirm the cable color from the canister on the back of control switch HS-3015?
l Discussion:
Parsons will close as Non-Discrepant.
j) DR-0337 (Ken Mayers)
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Based upon the additional information provided by NNECo, Parsons agrees that the NRC accepted the electrical isolation capability of Foxboro model 2AO-L2C-R as a qualified isolation device and this item is considered closed. These question are concemed with the EATON isolators.
- 1) Test data (ER-7218) from CCI on model EATON 6N548 analog isolator, demonstrated electrical isolation testing. There were abnormalities observed at 120 VAC (a 3% of scale for 100ms) and at 500 VAC (E 6% of scale for 40 ms and 8% of scale for 40ms). EATON discussed these abnormalities in section 1.0 but categorized the magnitude as 3%. No conclusion in the body of the report is noted other than the testers conclusion in the test notes that states "I feel this is not a problem." These analog isolators are used with various process inputs in the ESAS cabinets.
Did NNECo evaluate and document the abnormalities to conclude that the impact is conservative with respect to the process loop (s) effected?
l What is the basis that concludes that these isolators are qualified?
- 2) NNECo stated that Eaton module 6N336 bistable was supplied with a Certificate of Compliance (C&C) stating that ".. modules supplied meet system design requirements of original specification 7604-480, including IEEE 279-1971, IEEE 308-1970, IEEE 323-1971 and IEEE 344-1975." The NNECo PO did reflect this requirement.
l l
Eaton certified on the C&C that the isolators ". have been manufactured, inspected, tested l
and prepared for shipment in accordance with all specification and standards described in our Quality Assurance Manual QCM-2." Further, Eaton states " The supplied material will not invalidate the qualification of the equipment originally supplied under NUSCO purchase order
- 881661."
l How does NNECo conclude that the Eaton C&C supports the NNECo statement in the response?
I Discussion:
l
- 1) NNECo will fax the C&C for the component.
- 2) Parsons will close the DR as Non-Discrepant pending review of the C&C.
k) DR-0127 (Ken Mayerr.)
NNECo's response provided ths additional requested infonnation. Based upon this information, the following clarifications are requested:
- 1. In the revised calculation why isn't the 1/4 inch measurement uncertainty identified in the referenced ER-98-0044 Rev 1 included?
- 2. SP2402D Rev 11 is the current SG Narrow Range Level Transmitter calibration procedure. Does CR-M2-98-2729 (AR97028700) track the required revisions to this procedure due to the new calibration spans and RPS/AFAIS set points?
l Discussion:
- 1) Parsons will review.
- 2) Procedure was revised and was in Oscar as of 10-4-98.
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o CONFERENCE NOTES 1
DATE: 10/15/98. Rev.1 TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
- 1. DRs, Parsons requested topic to discuss DRs (rescheduled):
DR-0620, DR-0795, DR-0759, DR-0701, DR-0654, and DR-0127
- 2. DRs, Parsons requested topic to discuss DRs:
DR-0804, DR-0189, DR-0188, DR-0251, DR-0712, DR-0782, DR-0294, and DR-0230
- 3. DRs, NNECo requested topic to discuss DRs:
DR-0538, DR-0046, DR-0048, DR-0059, DR-0339, DR-0673, and DR-0361 LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Kalvin Anglin Ron Jackson Eric Benner Teny John Archer Gary Jackson Bob Byrne Fred Mattioli John Nakosky Concannon Eric Blocher John Hilbish Norbert Carte Ray Necci.
Dick Boyd Ken Mayers Charlie Chace Tien Nguyen Juan Cajigas Ron Smith i
Sing Chu Tom Prvhoda Rich Glaviano Dan Wooddell
)
Bill Cushman Bob Skwirz Joe Groncki Jon Winterhalter Dan Van Duvne Steve Stadnick Farid Elsabec Greg Tardif Joe Fougere Roy Terry i
K'Chebe Grace Jim Wheeler
- 1. Topic: (Parsons' Items Continued or Rescheduled from 10-14-98) a) DR-0620 (Topic continued from 9-29-98 teleconference)(Dom Ramos)
Parsons issued as Level 3. NU response as NON-DISCREPANT.
The issues raised by the DR are applicable to the system regardless of DCR M2-97008. According to 6/16/98 conference notes, topic #3, the DCR is complete except for testing. ICAVP decided to include the DCR because its date is within " CMP complete,"it is a new document, and its review would be a good CMP indicator.
Revising the DCR safety evaluation and other associated documents at the last stage of the DCR, even though it is still not totally complete, is a weakness in the process and is not a valid reason for categorizing the DR issues as NON-DISCREPANT.
Parsons has received and reviewed the supplementary documents (M2-IRF-02853) to NU's initial response to the DR (M2-IRF-02721). Parsons would like to discuss the documents because they do not contain information that would resolve the two issues identified by the DR.
Discussion:
This topic was rescheduled to 10-16-98. See the 10-16-98 notes.
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b) DR-0795 AFW Response Time Testing (Gordon Chen, Rich Glaviano)
The NNECo response states that AFAIS response time issues were identified as a result of the reviews initiated in response to Generic Letter 96-01. Cited is Report MPR-1816, dated April 1997, w:hich
(
documents the review of ESAS circuitry. This review was undertaken to ensure all portions of the l
clectrical circuitry required to fulfill a Technical Specification requirement were covered within a surveillance procedure and that surveillances are performed within the frequency required by the Technical Specifications. Consequently, the time response issues identified in the report, where appropriately addressed, fall within the "Previously Discovered" Category. A review of the DR issues follows:
1.
Delay time of the SG Level instrument loop The Engineering Evaluation M2-EVo98-106 in response to AR 97028779-06 does not identify the need to correct SP 2604P to include (or otherwise account for) the response time of the actuation circuit (SG level through Auto Start annunciators). The response time measurement of Ref. 5 is started from the AFW Auto Start signalindicated by the annunciator. The results of Ref. 5 are transcribed to SP 2604P for total AFAIS response time calculation.
As indicated in M2-EV-98-106, page 17, the logic circuit from the transmitter to the annunciator are incorporated into the I&C procedures tracked by AR 97010071-05. Review of this AR item indicates the corrective actions were completed by revision of SP 240lNA/NB/NC/ND issued on l
9/12/97. However, these procedures only include response time for test of the RPS circuits, not l
the AFW circuits.
l The AFAIS logic circuit response time test cannot be identified. Also, the current SP 2604P, Rev.
l 7, directs transcription of the logic circuit response time from SP 2403H (superseded by SP 2403HA/HB/HC/HD). These procedures do not include the AFAIS logic circuit response time test.
Resolution: Discrepant as Significance Level 3.
- 2. Time for the AFW pump to develop desired flow /pressme The Engineering Evaluation M2-EV-98-106 in response to AR 97028779-06 provides guidance to include AFW pump run up time in the AFAIS response time test.
Resolution: Previously Identified - Closed
- 3. Time for the valves to stroke open The Engineering Evaluation M2-EV-98-106 in response to AR 97028779-06 provides guidance to include AFW valve opening time in the AFAIS response time test.
Resolution: Previously Identified - Closed
)
4.
Document Discrepancy l
Per Reference 7, the FW-43A/B blue lights indicate the valve leaving the closed seat. The Reference 8 schematic drawings show the blue lights indicate a full open FW-43A/B valve position. The discrepancies between Ref. 7 and Ref. 8, regarding blue light indication for valve position of FW-43A and FW-43B, are not addressed by this response.
Resolution: Level 4 Document Discre,,ancy.
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Discussion:
Rescheduled to 10-19-98. See the 10-19-98 notes.
i c) DR-0759 LOFW Analysis (Rich Glaviano)
NU has concluded that the issues reported in DR-0759 have identified a CONFIRMED SIGNIFICANCE LEVEL 4 ccndition (Item 5) which requires correction.
l NNECo has provided a qualitative assessment of the impact of each item on the analysis results. If l
there were significant SG inventory available for the limiting case, this kind of evaluation may be l
sufficient. While, individually each contributor may be small, the cumulative effect has not been quantified. With the muumal (~1100 lbm/SG) calculated inventory, a more rigorous assessment is appropriate. Further comments are provided below:
Item 1 - RCS Flow assumed at TS minimum value NU Response:
l NU has concluded that this item is not a discrepant condition. The LNFF event is a rehtively long term, quasi steady-state event. The heat transfer rate from the primary to the secondary cystems, and therefore the steam flow out of the steam generators, is controlled by decay heat and by RCS j
pump heat. Using a nominal plant flow of 387,000 GPM would result in a slightly higher priteary to secondary heat transfer coefYicient. Because the total heat transfer rate is set by decay heat and RCS pump heat, and because the secondary system temperature is fixed at the Main Steam Safety l
Valves' (MSSV's) opening setpoint, increasing the primary to secondary heat transfer coefficient l
would only cause a small change in the primary system temperatures. This would not impact the l
total heat transfer rate to the secondary system.
l Parsons Comment:
A higher RCS flow rate would promote increased heat transfer from the fuel and RCS metal into the RCS. The energy, along with RCS internal energy (Tave), would more readily transfer into the secondary system.
I NU Response:
(
The LNFF analysis used the Technical Specificadon minimum RCS flow rate of 360,000 GPM.
Using the Technical specification minimum RCS flow raises the average primary coolant temperature (Tave). A higher Tave maximizes the energy stored in the primary system and the energy that rnust be removed by steam flow out of the secondary system. Therefore, it was conservative to use the minimum RCS flow for the LNFF analysis.
Parsons Comment:
The higher Tave is a result of energy not being transferred into the secondary, which should be non-conservative.
Item 2 - 500 Tubes per SG assumed olucced NU Response:
i NU has concluded that this item is not a discrepant condition. The impact of changes in the steam generator heat transfer area dae to difference in the steam generator tube plugging would be l,
similar to the changes in RCS flow rate explained in Item 1 above. The increase in heat transfer Page 3 of 15 M981015. doc
CONFERENCE NOTES DATE: 10/15/98, Rev.1 TIME: 2:00 p.m.
area would only cause a small change in the primary system temperatures during the transient, and would have no significant impact on the total energy transferred to the secondary. However, changes in the heat transfer area would not afTect the initial primary system temperatures or the attendant stored energy in the primary system coolant. Therefore, the level of steam generator tube plugging assumed in the analysis will not have a significant impact on the results of the analysis.
Parsons Comment:
When SG level is low, the number of tubes available for heat transfer will become a factor. Agree the contribution may be small, but should be quantified due to the low minimum SG inventory.
Item 3 - MS Bvoass and ADV's assumed not to onerate NU Response:
NU has concluded that this item is not a discrepant condition. The LNFF analysis did not take credit for the Main Steam Bypass Valves or the ADV's. It was conservative not to credit the bypass and dump valves because it maximized the transient secondary pressures. Maintaining higher steam generator pressures minimizes the capacity of the Auxiliary Feedwater (AFW) system, which is the critical parameter in determining if the steam generators dry out.
Parsons Comment:
Competing effects: lower steam pressure (lower Tsat) increases SG inventory boiled off, lower steam pressure enables increased AFW flow. Is there a sensitivity analysis or calculation which supports higher SG pressure as the limiting condition?
NU Comment:
Additionaily, the energy removed by flow out of the steam generators does not depend on whether the flow is through the bypass and/or dump valves or the safety valves because the enthalpy of the steam is approximately constant over the pressure range covered by the steam bypass or safety valve setpoints.
Parsons Comment:
Concur that steam enthalpy (BTU /Lbm) is approximately constant over this range.
Item 4 - MSSV Biasine and Flow Capacity NU Response:
NU has concluded that this b a is not a discrepant condition. As explained in the response to item 3, the capacity of the AN system is the critical parameter in determining if the steam generators dry out.
Parsons Comment:
Concur similar to item 3. Likely bounded by item 3. Non-Discrepant.
NU Response:
Changing the flow capacity of the valve only changes the amount of time it is open; it does not change the total steam flow rate out of the valve.
Parsons Comment:
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w CONFERF.NCE NOTES DATE: 10!!5/98. Rev.1 TIME: 2:00 p.m.
Concur that there are slight changes in timing, not in tcital quantity of steam released. Non-Discrepant.
Item 5 - AFW Flow Control Valve Sinale Failure NU Response:
This item is discrepant. Condition Report (CR) M2-98-2804 (attached) has been written to provide the corrective action to prepare a new calculation to document the ability of the AFW system to mitigate the affect and consequence of a AFW flow control valve (FW-43 A/B) single failure.
Parsons Comment:
Concur with the proposed action.
NU Response:
If one of the valves were to fail, the affected steam generator would eventually dry out.
Auxiliary Feedwater flow would not be restored to the affected steam generator to avoid the thermal shock of supplying cold AFW to a hot steam generator. The unaffected steam generator alone easily has the capacity to remove decay heat and RCS pump heat. With the full capacity of three (two motor-driven and one steam-driven) AFW pumps available to the unaffected steam generator, it would be able to maintain the plant in a safe shutdown condition.
Parsons Comment:
Parsons reviewed Calculation 97-ENG-02053, Rev. 2, " Millstone Point Unit 2 Auxiliary Feedwater System Flow Analysis." The calculation was prepared by Proto-Power Corporation.
Appendix B provides AFW flow values for numerous cases. The following cases were reviewed:
Case 3A: 2 MDAFP's - 5% degraded at 1030 psia (Total SG flow = 384 GPM)
Case 4A: 2 MDAFP's - 1 SG isolated,1 SG at 1030 psia (SG flow = 324 GPM)
Case 4D: 3 AFW pumps - 1 SG isolated,1 SG at 1030 psia (SG flow = 362 GPM)
With one SG isolated, the AFW flow P., the operable SG, in both 2 pump and 3 pump operating combinations, is less that me total AFW flow to the SGs when 2 MDAFP's are feeding both SG's. Thus, the total SG inventory with I flow path operable will be less than the total SG inventory with both SG's operable at any given point in time.
SPC analyzed the 2 MDAFP's feeding both SG's (Case 3A). The 2 MDAFP case analyzed by SPC showed a muumum SG inventory of approximately 3350 Lbm per SG (approx 6700 Lbm total) at approximately 30 minutes. This was the limiting case for RC Pumps operating.
From the discussion above, it is reasonable to conclude that had SPC analyzed the single SG case, the total inventory would be less than 6700 Lbm at the 30 minute point in the analysis (without operator action).
Since the minimum level in the operable SG hac not been determined, and may be less than calculated for the limiting event with RCP's operating, it is not possible to conclude that the licensing basis is assured.
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l NU Response
\\
i As such there is no effect on the license or design basis, therefore NU has concluded this to be J
- a Significance Level 4 issue.
Parsons Comment:
Parsons views this as Significance Level 3 pendmg reanalysis results.
1 Discussion:
Rescheduled to 10-19-98. See the 10-19-98 notes.
d) DR-0701 (John Archer)
NNECo has dispositioned DR-0701 Item I as not a discrepant condition because if NNECo deternunes that ifsome components have little or no maintenance performed on them, then there is little or no reason to have them in PMMS.
Question: How does NNECo account for components in Class lE circuits such as motors and l-switches that are quality related SSCs per FSAR Appendix 1 A, Criterion 1 if they are nol posted in PMMS7 In addition, is this Item I issue not related to item 2 of DR-0701 in which NNECo has -
prepared CR M2-98-2840 and referenced CR M2-98-1676 that addresses lack of component qualification?
1 Question: NNECo also implied that there was no need to include hand switches (HS-4192A,B,C,D),
l mentioned in the previous question, in PMMS. From a consistency standpoint, since other hand sv itches (such as HS-4188C,D,E,F) are included in PMMS; why are these not included?
'/or item 3 of DR-0701, NNECo has stated that the resolution of M2-DRT-00756 is applicable to this DR-0701 regarding the instrumentation seismic issue applicability of TE M2-EV-98-0110 to non i
SSEL components.
Question: Since the NNECo referenced 9/10/98 telephone conference call did not conclude an agreement on the applicability of TE M2-EV-98-0110 to non SSEL components how can a seismic resolution be dispositioned?
Question: NNECo has responded that the identified components would not have required any specific seismic qualification. Can NNECo determine if there is a mechanism, such as SQRs (Seismic Qualification Reports), that can appropriately and briefly document salient facts related to the seismic qualification assessment ofindicator lights, hand switches, the governor motor, and resistors so that they can be dispositioned in a formalized manner?
For item 3 of DR-0701, it has been determined that only one side of the blue lights are physically cm&.
Question: Since the physical plant configuration does not agree with the design basis, why is the assigned significance a level 4 instead of a level 3?
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j Discussion:
)
Parsons requested this topic be tabled for further study.
l i
e) DR-0634 (Ken Mayers)
NNECo's response provides justification ef your position with respect to using a pressure switch downstream of the DG FO shutoff valve to indicate the valve has inadvertently closed. Further, NNECo has indicated that SP 2669A, as part of PEO rounds, verifies the oil pressure exceeds 5 psig l
of the gauge panel. Normal inlet pressure with the fuel oil storage tank at its Tech Spec limit is l
approximately 10 psig.
- 1.. Assuming that the valve inadvertently goes closed trapping the downstream pressure at 10 psig, l
how does the operator know that the valve is closed?
- 2. With the valve closed, what is the time for the pressure to bleed down to the alarm set point of 3 psig and what is the leakage mechanism that will consistently assure this?
j l
- 3. If the valve inadvertently closes and the valve seat is leaking, how is the valve closure detected?
l 4.
This valve is critical to EDG operation, what testing is done to demonstrate that inadvertent closure is quickly detected?
Discussion:
I NNECo will look into drawings / manuals for flow path and send to Parsons.
I f) DR-0127 (Ken Mayers)
NNECo's response provided the additional requested information. Based upon this information, the following clarifications are requested:
- 1. In the revised calculation why isn't the i 1/4 inch measurement uncertainty identified in the referenced ER-98-0044 Rev 1 included?
- 2. SP2402D Rev 11 is the current SG Narrow Range Level Transmitter calibration procedure. Does l
CR-M2-98-2729 (AR97028700) track the required revisions to this procedure due to the new calibration spans and RPS/AFAIS set points?
Discussion:
l NNECo will send the Engineering Report and the Specification or provide reference to Parsons to find in our files.
i l
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l 2.
Topic: Parsons' Items a) DR-0804 (Trent Powers)
Parsons wishes to discuss the difference in Significance Level assignments for this DR. Parsons
)
classified as SL 3, NNECo as SL 4. At issue is facility I and facility 2 cable touching in a pull box for PT-5281 and PT-5289. Requirements of SP-M2-EE-0016 are that these cables do not touch.
Parsons recognizes that the pts are non safety related, but that is not considered to be a basis for mr.kmg this a SL 4. The significance of this issue is that facility I and facility 2 cable can be routed in Z1 and Z2 trays, thus potentially cross connecting these channels.
Discussion:
1 NNECo will accept as SL 3. CR M2-98-2921 was written.
i b) DR-0189, item 2; DR-0188, Item 2 and DR-0251, Item 3 (Gary Jackson)
For the above DR's, all three items address the same issue of cut-off frequencies and SRSS modal response summation. Each DR was written for a separate piping analysis.
Item 3 of DR-0251 was agreed upon during the conference call on 10/7/98 to be a Significance Level 3 DR.
- Parsons suggest DR-0188, item 2, and DR-189, item 2, both be rolled into the CR issued for DR-251 (CR M2-98-0329) and be closed on this basis.
If this is acceptable, DR-0189 can be closed.
DR-0188 was issued to NU the early part of September. Item 2 of this DR can be closed. NU would
' still be required to address the issue ofitem 1 of this DR.
Discussion:
DR-0188 Parsons will close as is.
DR-0189 Item 1 close as SL 4.
Item 2: Closed DR-0251 Close as SL 3.
c) DR-0712 (John Archer)
The following items, which have retained the original DR-0712 identification numbers need clarification for Parsons to respond:
1.A.2 NNECo has confirmed that the diode leads' did not have heat shrink tubing as a separation barrier. NNECo has committed in its DR-0712 Response to correct this situation (M2-98-2759). A l
review of M2-98-2759, however, indicated that a simply a "MEPL evaluation, and determination of l
installed separation and color code is in accordance with SP-M2-EE-0016" would be performed.
There was no provisions in CR M2-98-2759 that a physical change would be made by NNECo to correct the plant's configuration and remedy the separation concern. Because a physical plant change Page 8 of15 M981015. doc 1
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is required to comply with the design and licensing basis, why has this been assigned by NNECo a significance level of 4, instead of 3?
1.B. NNECo's response stated that heat shlink tubing has provided the appropriate separation barrier for the Acopian Power Supplies for the Z5 cables. ICAVP agrees that heat shrink tubing was used for the Z5 channel cable, however, adjacent cables are showing a green cable (which) signifies channel Z3 being run in a bundle with both the red cable channel 21 for X-1113A and also with the yellow cable channel Z2 for X-1113B instrument power supplies. The NNECo response did not address this specific cable separation issue. Can NNECo provide additional insight into this green cable issue as to why a green cable is used in this area?
Issue 2. Seismic Oualification in response to ICAVP concern related to the seismic qualification of the Foxboro Spec 200 devices PA-102A,B,C,D; PAX-102A,B,C,D, the NNECo response included Foxboro Type Test Report QOAACI1 Rev. A, cover page, which is the Test report for Foxboro N-E10 Series Transmitters.
Transmitters are not the issue being addressed by DR-0712. As a result, no seismic qualification justification has been provided by NNECo for the Foxboro Spec 200 devices PA-102A,B,C,D; PAX-102A,B,C,D. Did Parsons receive the correct information?
Issue 4. Diode Ouality Classification
- 4. In CR M2-98-2759 NNECo in response to this confirmed level 3 discrepant condition committed to a PMMS identification, MEPL evaluation, and deternunation ifinstalled separation and color code is in accordance with SP-M2-EE-0016. As denoted in DR-0712, ICAVP was also concerned about the quality level to which the diodes were procured. Since the procurement issue was not addressed by NNECo, does NNECo plan on addressing this procurement quality issue as well?
Discussion:
Rescheduled to 10-16-98. See the 10-16-98 notes.
d) DR-0782 (John Archer)
NNECo's response for DR-782 included supporting information from the high energy line break / safe shutdown equipment interaction calculation, TRENCHES 1414M2, Rev. O. This calculation stated that the steam line that would interact with CST level transmitter LT-5292 is not postulated to break.
This is based on the System Resolution SR-1 premise that the steam "line operates as a HEL less than 2 percent of the normal operation of that system may be treated as a moderate energy line. Therefore, the postulation ofjets and/or whips of these lines is not required."
- 1) What is the basis of the premise of 2 percent since it was not included as an assumption or a design input?
- 2) Since the interaction calculation deals with jet impingement and pipe whip, what NNECo l
consideration is given to a pipe break impact in this area that causes an elevated temperature and humidity condition which could affect LT-5282 and possibly LIS-54897 Discussion:
Parsons will close as non-discrepant.
4 l
e) UM-UD4 (Koger Mauchline)
I Page 9 of 15 M981015. doc l
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We have reviewed photographs of LAR sample 4 and cannot confirm the existence of welds. The photographs do show discoloration of the metal deck such as would be produced by welding. We saw these same discolorations during the ICAVP inspection but were unable to see welds even with the aid of binoculars and a flashlight. Please take a close-up photo showing at least one of the actual welds.
Discussion:
Rescheduled to 10-16-98. See the 10-16-98 notes.
l l
f) DR-0230 (GaryJackson)
Parson: concurs with NU's disposition that by applying the 1.3 SIF for thermal stress conditions at the subject nodes would not affect the conclusion of acceptability. However, this calculation should be updated to document those analysis nodal points requiring a 1.3 SIF so that these factors are included in the next revision of this analysis. Therefore, this DR will be downgraded to a Level 4.
Discussion:
NNECo will clarify in calculation. CR M2-98-2882 was written to correct. Confirmed SL 4.
l
- 3. Topic: NNECo's items a) DR-0538 Responses for Closure (Charlie Chace, N) (Dan Wooddell, P)
Item 1:
Use of a 2500 ft-lb. max range torque wrench tester for a calibration check oflow range torque wrenches is appropriate, but as described in the discrepancy report and as confirmed by our j
investigation, use of this tester to calibrate lower range wrenches is inappropriate practice. It is our practice that calibrations are done by the Metrology Lab, which does have a low range cell, using the 4:1 criteria. Upon, which is inconsistent with our practice.
In our previous telecon on 10/1/98, we stated that we would review calibrations completed to verify that none of these resulted in wrenches being out-of-cal. Parsons stated that even if this is true, we still have this record, which they consider a Level 3 condition.
Attached is the cal record for QA 2578 (2500 lb tester). This record shows that of the 40 wrenches calibrated with the tester during the period in question,15 have since been recalibrated using a cell with a more appropriate range for individual torque wrench. All of these were found to be in satisfactory calibration. Note that this is not a selected sample, but a record of wrenches scheduled for recalibration.
Our procedures are being revised to conform with ASME and the Federal Specification, which defines 4% accuracy for torque wrenches.
Since an instruction to zero the tester is already included in the procedure, this proposed change to make zero a data point will not be done.
Significance Level 4: Since the use of this tester to calibrate low-range wrenches is contrary to our policy and we have performed corrective actions we concur that this is a discrepant condition, but Page 10 of 15 M981015. doc l
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l since the tester has a proven record uten measured against lower range test cells, there is no impact i
either on the program or on individual calibrations.
Item 2. Part B:
l Millstone will exercise torque wrenches in accordance with ASME B107.14M-1994, paragraph 5.2.4(d). This requires all torque wrenches to be operated three times at 50% of maximum capacity before beginning a calibration.
This item was assigned for further action during the 10/1/98 telecon. Since our present practice conflicts with ASME (we exercise at 100% twice) and ASME conflicts with GGG-W-686D, we must state what we really intend to do. We must also state how this relates to the observed activity to i
determine significance level.
1 Millstone intends to conform strictly with the ASME requirements. This requires a revision to WC-8, with the proper references to ASME. The MET Lab will soon take ownership of C-MP-716B, which will be re-written as a MET procedure. A new work process will be implemented May 1 of 1999, and supporting procedures must be in place before this date. A new AR # has been issued under CR M2-98-1551 to track this issue.
Significance Level 3: Since program requirements as stated in the present procedures are unclear.
Item 3, Part B - Response does not address justification of reference standard to M&TE cal ratios of less than 4:1. Quotes IEEE 498-1980, "..The rationale for deviating from these requirements must be justified and documented."
To assure that the overall accuracy ratio of the reference standard to plant equipment is satisfactory, procedure WC-8 provides instructions for approval of those cases where a calibration ratio of 4:1 cannot be achieved, but where the instmment will be dedicated for a specific use. In resision 2 of WC-8, ajustification is written for each such case and submitted to Design Engineering for approval.
The justification was then submitted to SORC for approval. This process is defined in the Topical Report, Section 12.2.2, and is documented on WC-8, Attachment 5. In Revision 3 of WC-8 the MET Engineer performs the review and must consult with Design Engineering. SORC approval is still required.
In the 10/1/98 telecon, Parsons noted that WC-8, section 1.14 allows us to buy off on ratios as low as 1:1. We agreed to investigate this question. Attached is a chart showing where the 4:1 ratio is applied. WC-8, Section 1.14 is for use by the Work Planner in selecting the proper M&TE. Since the 4:1 requirement is implemented at c level before this activity, the Note at step 1.14.2 is somewhat misleading and may be deleted in a future resision.
Significance Level: Non-discrepant, since the requirement is properly defined and implemented.
NOTE: The 4:1 issues was investigated by QAS in 1996, with discrepancies documented in ACR M l-96-0614. These discrepancies were further described in Memo MS-F-96-110 for the Nuclear Receiving Group; and Memo MS-F-96-119 for Component Engineering Services. Programmatic aspects stated in WC-8 were not found to be discrepant.
Item 5 Parsons disagrees that cal is IAW manufacturer's procedures:
Manufacturer's procedure for DMM QA-0941 shows that the manufacturer specified two precisely l
known reference points for each function and range.
Concur with this discrepancy. Will revise procedure MTE-1120, " Digital Multimeter Calibration," to 1
direct two point calibrations. Added new assignment to CR M2-98-1551; AR 98010755-07, " Revise Page 1I of 15 M981015. doc
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Calibration procedure ICI101 A or generate a new procedure for QA-0941, Solartron, Model 7151 to include two reference inputs for each function and range as recommended by manufacturer.
In our discussion of extent of condition, Parsons brought up QA-935, Fluke 45, DC voltage; the required 90 VDC is not sown on the cal sheet. They also mentioned QA-930, Model 50A DC voltage.
From our investigation of this question, we concur that there are several instruments which do not implement all manufacturer's recommendations for calibration. We are currently in the process of upgrading procedures. Part of this effort requires a review of manufacturer's recommendations.
'Ihese recommendations are being incorporated where it is appropriate to do so.
Significance Level 4, (1) applies to specific instruments, rather than programmatic; (2) Instmments were calibrated per an industry accepted practice, even if the recommendations of a specific manufacturer (or a few manufacturer's) were overlooked.
((Graphics not included))
The requirement for Standard to M&TE is established by IEEE 498, as described in WC-8 Section 1.1.
The Work Planner is required to select M&TE with an accuracy at least equal to the instrument to be calibrated, as stated in WC-8, Section 1.14.
Discussion:
Item 1 Parsons will close as Confirmed SL 4. CR M2-98-1551 was written.
Item 2, Part 3 Parsons will close as a Confirmed SL 3.
Item 3, Part 3 Parsons will close as a Confirmed SL 4.
Item 5 This item rescheduled to 10-16-98. See the 10-16-98 notes.
b) DR-0046 (Geoff Neate, N) (Gary Jackson, P)
Issue: Prob #101 Input Data referenced from other source documents is inconsistent with source data.
NU second response: Calculation M2-PR101-0222EM was sent to Parsons for review.
Parsons reply:
Upon review of the calculations Parsons had comments conveyed to NU via conference call 8/4/98.
a) Items #1 & 2 Not addressed in M2-PR101-0222EM Rev 1 - data appears to still be missing in Section 6.8.4.
b) Attachment D lists Cavitating venturi in table of Contents but is not attached to stress report.
l c) Attachment F Interface information memo in TOC but not in report.
d) Data from Stress Prob. 25 & 100 not included in anchor loading tabulations on Section 6.12, pages 42 & 43.
NU follow up position:
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NU IRF0-02570 is being written to address Parsons comments as follows:-
a)~ See data from Stress Prob. 25 & 100 t
1 b) Enclosed, see attachment 1, this IRF c) Enclosed, see attachment 2, this IRF d) CCN-1 to calc.M2-PR101-0222EM Rev.1 is issued to resolve total loads on Support anchors 513019 (pt. 610) & 513001 (pt 235) see a**h-t 3.
Discussion:
his topic rescheduled to 10-19 See the 10-19-98 notes.
E
\\
s c) DR-0048 (GeoffNeate, N) (Gary Jackson, P)
Calculation discrepancies and omissions in Prob # 101.
NU second response: Calculation M2-PR101-0222EM was sent to Parsons for review.
Parsons reply:
Upon review of the calculations Parsons had comments conveyed to NU via conference call 8/4/98:
Item #6 - M2PR101-222EM Rev. I 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 been identified.
NU follow up position:
NU 1RF0-02571 is being wTitten to address Parsons comments as follows:
CCN-1 to calc. M2-PR101-0222EM Rev.1 is issued to resolve Pipe support reconciliation of the affected load changes.
Discussion:
This topic rescheduled to 10-19-98. See the 10-19-98 notes.
d) DR-0059 (Norbert Carte, N) (Joe Groncki, P)
Parsons accepts this as a Level 4 - NU will put in bin CR.
Discussion:
This topic rescheduled to 10-19-98. See the 10-19-98 notes.
e) DR-0339 (Norbert Carte, N) (Ken Mayers, P)
The PDCRs reference PA 80-168, which has been previously provided in response to M2-RAI-00458 on 11/26/97. Is this the reference which Parsons is looking for?
. Discussion:
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This topic rescheduled to 10-19-98. See the 10-19-98 notes.
l f) DR-0673 (George Howard, N) (Dick Boyd, P)
The following is NU's proposed response to Parsons rejection of the initial response. NU maintains i
that the issues are non-discrepant.
Parsons Issue 1:
NU's response states that a fire concurrent with the loss of the CST is a " dual failure" and outside of the MP2 design basis. Parsons disagrees. A " dual failure" would involve the simultaneous failure of two safety related components to perform their safety function. This event involves the coincident occurrence of a fire with operation of a specific item of equipment out of senice or under testing within plant Tech. Spec. limits. As discussed in ANSI /ANS-51.1-1983, the probability of a fire is 10-1/ reactor-year (PC-2) and the probability of the CST out of senice is considered normal operation j
(PC-1). Thus the probability of this coincident occurrence is quite high: 10-1/ reactor-year. Also, the Safety Functional Requirement 2.4.3.7 (Appendix R) specifically identifies this safety function to supply the AFW system with water from the Fire Water system during an Appendix R event.
NU's Response to Issue 1:
For the Appendix R scenario, the CST is available to provide water to the AFW system for several hours following the event and provide sufficient cooling to cool the plant. During an Appendix R l
cooldown, natural convection flow in the primary plant is assumed and cooldown is achieved by bleeding from the steam generators. The time for a plant cooldown is extended and a switch to the Fire Protection System (FPS) is achieved following depletion of the CST inventory.
Factors to be considered when AFW is being supplied with water from the Fire Protection System.
First, the use of the Fire Protection System is used following depletion of the CST. This is considered to occur several hours following an event when AFW flow is low. The required flow is well below 600 gpm. Second, the piping between the FPS and the AFW system is sized to provide a minimum pressure drop from the discharge of the FPS pumps to the AFW piping connection. Third, the FPS l
has three 50% capacity pumps, each with a rated capacity of I800 gpm. The largest design basis demand for the fire water system is a 2700 gpm deluge of the MP-2 transformer yard. With this demand, two FPS pumps could supply the FPS and also support the AFW system.
None of the accident scenarios for MP-2 assume a loss of the CST. Per the TS, if the minimum level is unavailable and cannot be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the plant is required to be in a hot shut-down condition within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Parsons Issue 2:
NU's response states that the combination of an upset condition with a loss of the CST is a " dual failure." As discussed above, a " dual failure" would involve the simultaneous failure of two safety related components to perform their safety function. This event involves the coincident occurrence of an upset event (such as LONF which doesn't involve a single active failure) with operation of a l
specific item of equipment out of senice or under testing within plant Tech. Spec. limits. Taking the LONF event (Case 3C) from calculation 97-ENG-02053-M2 for example, the AFW flow at 900 psia SG pressure would be 808 gpm. As discussed in ANSI /ANS-51.1-1983, the probability of a LONF is 10-l/ reactor-year (PC-2) and the probability of the CST out of senice is considered normal operation (PC-1). Thus the probability of this coincident occurrence is quite high:
10-1/ reactor-year.
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NU's Response to Issue 2:
As stated, the CST is considered to be available for DBA scenarios. 'Ihe high AFW flow rates to the SG's are primarily associated with a MSLB and for both the Chapter 10 and 14 analysis. It should also be noted that the most severe period occurs within the first 66 minutes following the accidents and then the plant is considered to be in recovery with decay heat removal being the primary objective.
Shifting suction of the AFW pumps from the CST to the FPS would occur several hours following an accident. Decay heat removal requirements following an accident would require an AFW flow ofless than 200 gpm for both SG's about ten hours following an accident. This type of flow requirements would not challenge the FPS to support flow to the AFW system.
Discussion:
This topic rescheduled to 10-19-98. See the 10-19-98 notes.
I g) DR-0361 (Charlie Chace, N) (Dick Boyd, P)
Note that this should be addressed concurrently with DR-684 DR-0361 states two problems.
PDCR MP2-041-95 stated that a flow balance test of the containment purge system would be conducted as a post-modification test. No documentation was found to support this.
Drawing 25203-29644 was not updated to show revised flow data.
NU responded that the was non-discrepant, stating that the test data was contained in AWO M2 09452. It further stated that a DCN had been issued against the drawing, and this was properly documented in GRITS.
'Ihis response was rejected, stating that the AWO did not contain documentation of a flow balance test, and also stating that the drawing required flow data that was not updated.
DR-0412 also addressed this issue, noting that an airflow measurement had been taken as part of PDCR MP2-041-95, the results of which were outside the acceptance criteria of EN 21063A, Rev. 2.
'Ihis was accepted as a Level 3 discrepancy, and documented on CR M2-98-1335.
A corrective action of CR M2-97-0986 requires flow balancing and testing of the purge supply system. AR 97013083-05 is being linked to CR M2-98-1335 (MODE 4 requirement).
Discussion:
This topic rescheduled to 10-19-98. See the 10-19-98 notes.
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PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
- 1. DRs, Parsons requested topic to discuss DRs (rescheduled):
DR-0620, DR-0712, and DR-0294
- 2. DRs, NNECo requested topic to discuss DRs:
DR-0538, DR-0046, DR-0048, DR-0059, DR-0339, DR-0673, DR-0361, DR-0674, DR-0316, and DR-0615 LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Kalvin Anglin George Howard Peter Koltay none John Archer Ken Mayers Bob Byrne Ron Jackson John Nakosky Eric Blocher Dom Ramos Norbert Carte Fred Mattioli Dick Boyd Ron Smith Charlie Chace Ray Necci Gary Jackson Dan Wooddell Mike Champagne Tom Prvhoda Cris Cristallo Greg Tardif Bill Cushman Harold Thompson Farid Elsabee Chris Scully Joe Fougere Bob Skwirz
- 1. Topic: (Parsons' Items Continued or Rescheduled from 10-14-98) a) DR-0620 (Topic continued from 9-29-98 teleconference) (Dom Ramos)
Parsons issued as Level 3. NU response as NON-DISCREPANT.
The issues raised by the DR are applicable to the system regardless of DCR M2-97008. According to 6/16/98 conference notes, topic #3, the DCR is complete except for testing. ICAVP decided to include the DCR because its date is within " CMP complete,"it is a new document, and its resiew would be a good CMP indicator.
Revising the DCR safety evaluation and other associated documents at the last stage of the DCR, even though it is still not totally complete, is a weakness in the process and is not a valid reason for categorizing the DR issues as NON-DISCREPANT.
Parsons has received and reviewed the supplementary documents (M2-IRF-02853) to NU's initial response to the DR (M2-IRF-02721). Parsons would like to discuss the documents because they do not contain information that would resolve the two issues identified by the DR.
Discussion:
NNECo will follow up.
Page 1 of 10 M981016. doc
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b) DR-0712 (John Archer)
The following items, which have retained the original DR-0712 identification numbers need clarification for Parsons to respond:
1.A.2 NNECo has confirmed that the diode leads' did not have heat shrink tubing as a separation l
barrier. NNECo has committed in its DR-0712 Response to correct this situation (M2-98-2759). A review of M2-98-2759, however, indicated that a simply a "MEPL evaluation, and deternunation of j
installed separation and color code is in accordance with SP-M2-EE-0016" would be performed.
There was no provisions in CR M2-98-2759 that a physical change would be made by NNECo to correct the plant's configuration and remedy the separation concern. Because a physical plant change is required to comply with the design and licensing basis, why has this been assigned by NNECo a significance level of 4, instead of 37 l.B. NNECo's response stated that heat shrink tubing has provided the appropriate separation barrier for the Acopian Power Supplies for the 25 cables. ICAVP agrees that heat shrink tubing was j
used for the Z5 channel cable, however, adjacent cables are showing a green cable (which) signifies channel 23 being mn in a bundle with both the red cable channel Z1 for X-1113A and also with the yellow cable channel 22 for X-1113B instmment power supplies. The NNECo response did not address this specific cable separation issue. Can NNECo provide additional insight into this green cable issue as to why a green cable is used in this area?
Issue 2. Seismic Oualification In response to ICAVP concern related to the seismic qualification of the Foxboro Spec 200 devices PA-102A,B,C,D; PAX-102A,B,C,D, the NNECo response included Foxboro Type Test Report QOAACI1 Rev. A, cover page, which is the Test report for Foxboro N-E10 Series Transmitters.
Transmitters are not the issue being addressed by DR-0712. As a result, no seismic qualification justification has been provided by NNECo for the Foxboro Spec 200 devices PA-102A,B,C,D, PAX-102A,B,C,D. Did Parsons receive the correct information?
Issue 4. Diode Ouality Classification
- 4. In CR M2-98-2759 NNECo in response to this confirmed level 3 discrepant condition committed to a PMMS identification, MEPL evaluation, and determination ifinstalled separation and color code is in accordance with SP-M2-EE-0016. As denoted in DR-0712, ICAVP was also concemed about the quality level to which the diodes were procured. Since the procurement issue was not addressed by l
NNECo, does NNECo plan on addressing this procurement quality issue as well?
uiscussion:
l 1.A.2 NNECo will follow up.
i l
1.B Non-discrepant.
l Issue 2 NNECo will send evaluation of contact chatter.
l Issue 4 NNECo will address the procurement quality issue.
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c) DR-0294 (Roger Mauchline)
We have reviewed photographs of LAR sample 4 and cannot confirm the existence of welds. The photographs do show discoloration of the metal deck such as would be produced by welding. We saw these same discolorations during the ICAVP inspection but were unable to see welds even with the aid l
of binoculars and a flashlight. Please take a close-up photo showing at least one of the actual welds, i
Discussion:
There are no welds. CR M2-98-3098 was written. NNECo will follow up with a calculation.
l
- 2. Topic: NNECo's Items a) DR-0538 Responses for Closure (Charlie Chace, N) (Dan Wooddell, P)
Item 5 Parsons disagrees that cal is IAW manufacturer's procedures:
Manufacturer's procedure for DMM QA-0941 shows that the manufactiner specified two precisely known reference points for each function and range.
Concur with this discrepancy. Will revise procedure MTE-1120, " Digital Multimeter Calibration," to direct two point calibrations. Added new assignment to CR M2-98-1551; AR 98010755-07, " Revise Calibration procedure ICI101 A or generate a new procedure for QA-0941, Solartron, Model 7151 to include two reference inputs for each function and range as recommended by manufacturer.
In our discussion of extent of condition, Parsons brought up QA-935, Fluke 45, DC voltage; the required 90 VDC is not sown on the cal sheet. Hey also mentioned QA-930, Model 50A DC voltage.
From our investigation of this question, we concur that there are several instruments which do not implement all manufacturer's recommendations for calibration. We are currently in the process of upgrading procedures. Part of this effort requires a review of manufacturer's recommendations.
These recommendations are being incorporated where it is appropriate to do so.
Significance Level 4, (1) applies to specific instruments, rather than programmatic; (2) Instruments were calibrated per an industry accepted practice, even if the recommendations of a specific manufacturer (or a few manufacturer's) were overlooked.
((Graphics not included))
The requirement for Standard to M&TE is established by IEEE 498, as described in WC-8 Section 1.1.
he Work Planner is required to select M&TE with an accuracy at least equal to the instrumem to be calibrated, as stated in WC-8, Section 1.14.
Discussion:
This topic was discussed on 10-19-98. NNECo will accept this DR as a SL 3. CR M2-98-1551.
b) DR-0046 (Geoff Neate, N) (Gary Jackson, P) i Page 3 of 10 M981016. doc
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Issue: Prob #101 Input Data referenced from other source documents is inconsistent with source data.
NU second response: Calculation M2-PR101-0222EM was sent to Parsons for review.
Parsons reply:
Upon review of the calculations Parsons had comments conveyed to NU via conference call 8/4/98.
a) Items #1 & 2 Not addressed in M2-PR101-0222EM Rev 1 - data appears to still be missing in Section 6.8.4.
b) Attachment D lists Cavitating venturi in table of Contents but is not attached to stress report.
c) Attachment F Interface information memo in TOC but not in report.
d) Data from Stress Prob. 25 & 100 not included in anchor loading tabulations on Section 6.12, pages 42 & 43.
NU follow up position:
NU IRF0-02570 is being written to address Parsons comments as follows:
a) See data from Stress Prob. 25 & 100 b) Enclosed, see attachment 1, this IRF c) Enclosed, see attachment 2, this IRF d) CCN-1 to cale.M2-PR101-0222EM Rev.1 is issued to resolve total loads on Support anchors 513019 (pt. 610) & $13001 (pt 235) see attachment 3.
Discussion:
Parsons agreed that this DR is a SL 4.
c) DR-0048 (Geoff Neate, N) (Gary Jackson, P)
Calculation discrepancies and omissions in Prob # 101.
NU second response: Calculation M2-PR101-0222EM was sent to Parsons for resiew.
Parsons reply:
Upon review of the calculations Parsons had comments conveyed to NU via conference call 8/4/98:
Item #6 - M2PR101-222EM Rev. I 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 been identified.
NU follow up position:
NU IRF0-02571 is being written to address Parsons comments as follows:
CCN-1 to calc M2-PR101-0222EM Rev.1 is issued to resolve Pipe support reconciliation of the l
affected load changes.
l l
Discussion:
l Page 4 of 10 M981016. doc m
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4 Parsons agrees that this DR is a SL 4.
d) DR-0059 (Norbert Carte, N) (Joe Groncki, P)
Parsons accepts this as a Level 4 - NU will put in bin CR.
Discussion:
New DCR M2-98-2883 was prepared to correct drawing.
e) DR-0339 (Norbert Carte, N) (Ken Mayers, P)
The PDCRs reference PA 80-168, which has been previously provided in response to M2-RAI-00458 on 11/26/97. Is this the reference which Parsons is looking for?
Discussion:
NNECo will identify the referenced page.
f) DR-0673 (George Howard, N) (Dick Boyd, P)
The following is NU's proposed response to Parsons rejection of the initial response. NU maintains that the issues are non-discrepant.
Parsons issue 1:
NU's response states that a fire concurrent with the loss of the CST is a " dual failure" and outside of the MP2 design basis. Parsons disagrees. A " dual failure" would involve the simultaneous failure of two safety related components to perform their safety function. His event involves the coincident occurrence of a fire with operation of a specific item of equipment out of senice or under testing within plant Tech. Spec. limits. As discussed in ANSI /ANS-51.1-1983, the probability of a fire is 10-1/ reactor-year (PC-2) and the probability of the CST out of senice is considered normal operation
~
(PC-1). Thus the probability of this coincident occurrence is quite high: 10-1/ reactor-year. Also, the Safety Functional Requirement 2.4.3.7 (Appendix R) specifically identifies this safety function to supply the AFW system with water from the Fire Water system during an Appendix R event NU's Response to Issue 1:
For the Appendix R scenario, the CST is available to provide water to the AFW system for several hours following the event and provide sufficient cooling to cool the plant. During an Appendix R I
cooldown, natural convection flow in the primary plant is assumed and cooldown is achie r.d by bleeding from the steam generators. He time for a plant cooldown is extended and a switch to the Fire Protection System (FPS) is achieved following depletion of the CST inventory.
I Factors to be considered when AFW is being supplied with water from the Fire Protection System.
i First, the use of the Fire Protection System is used fc!!owing depletion of the CST. This is considered to occur several hours following an event when AFW flow is low. The required flow is well below 600 gpm. Second, the piping between the FPS and the AFW system is sized to proside a minimum pressure drop from the discharge of the FPS pumps to the AFW piping connection. Bird, the FPS Page 5 of 10 M981016. doc
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has three 50% capacity pumps, each with a rated capacity of 1800 gpm. The largest design basis demand for the fire water system is a 2700 gpm deluge of the MP-2 transformer yard. With this demand, two FPS pumps could supply the FPS and also support the AFW system.
None of the accident scenarios for MP-2 assume a loss of the CST. Per the TS, if the minimum level is unavailable and cannot be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the plant is required to be in a hot shut-down condition within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Parsons Issue 2:
NU's response states that the combination of an upset condition with a loss of the CST is a " dual l
failure." As discussed above, a " dual failure" would involve the simultaneous failure of two safety related components to perform their safety function. This event involves the coincident occurrence of an upset event (such as LONF which doesn't involve a single active failure) with operation of a specific item of equipment out of service or under testing within plant Tech. Spec. limits. Taking the LONF event (Case 3C) from calculation 97-ENG-02053-M2 for example, the AFW flow at 900 psia SG pressure would be 808 gpm. As discussed in ANSI /ANS-51.1-1983, the probability of a LONF is 10-1/ reactor-year (PC-2) and the probability of the CST out of senice is considered normal operation (PC-1). Thus the probability of this coincident occurrence is quite high:
10-1/ reactor-year.
NU's Response to Issue 2:
As stated, the CST is considered to be available for DBA scenarios. The high AFW flow rates to the SG's are primarily associated with a MSLB and for both the Chapter 10 and 14 analysis. It should also be noted that the most severe period occurs within the first 66 minutes following the accidents and then the plant is considered to be in recovery with decay heat removal being the primary objective.
Shifting suction of the AFW pumps from the CST to the FPS would occur several hours following an accident. Decay heat removal requirements following an accident would require ar AFW flow ofless than 200 gpm for both SG's about ten hours following an accident. This type of flow requirements would not challenge the FPS to support flow to the AFW system.
Discussion:
Issue 1 Was tabled for NNECo to consider information.
Issue 2 NNECo response accepted, non-discrepant.
g) DR-0361 (Charlie Chace, N) (Bill Clemenson, P)
Note that this should be addressed concurrently with DR-0684.
DR-0361 states two problems.
PDCR MP2-041-95 stated that a flow balance test of the containment purge system would be conducted as a post-modification test. No documentation was found to support this.
Drawing 25203-29644 was not updated to show revised flow data.
NU responded that the was non-discrepant, stating that the test data was contained in AWO M2 '
09452. It further stated that a DCN had been issued against the drawing, and this was properly documented in GRITS.
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l His response was rejected, stating that the AWO did not contain documentation of a flow balance test, and also stating that the drawing required flow data that was not updated.
i DR-412 also addressed this issue, noting that an airflow measurement had been taken as part of PDCR MP2-041-95, the results of which were outside the acceptance criteria of EN 21063A, Rev. 2.
This was accepted as a Level 3 discrepancy, and documented on CR M2-98-1335.
j A corrective action of CR M2-97-0986 requires flow balancing and testing of the purge supply system. AR 97013083-05 is being linked to CR M2-98-1335 (MODE 4 requirement).
I Discussion:
l Lis topic was discussed on 10-19-98. This DR will be closed as SL 4.
h) DR-0674 (George Howard, Harold Thompson, N) (Dick Boyd, P)
Parsons issue 1:
NU's response to the subject DR states that failure of the pressure regulating valves is not a credible scenario. Parsons disagrees. Since these are Non-Category 1 valves, they must be assumed to fail in the most adverse position. For example, a seismic event could cause the regulating valves to fail in the wide open position at the same time that makeup to the CST is required. A single active failure of
)
(1) breather valve or (1) rupture disk to function must also be assumed in coping with this event.
However, (3) of the (4) safety devices can be relied on to cope with the overpressure event.
NU's response states that the breather valves and rupture disks are sized to pass the full open capacity of the nitrogen regulators, per PDCR 2-9-79-92. Having reviewed PDCR 2-79-92, we could find no reference to documentation to support this statement. What is the basis of this statement?
NU's Pa=aanee to Parsons issue 1:
NU's initial response did e.gl state that the failure of the pressure regulating valves was not a credible scenario, but that the overpressurization of the CST due to a pressure regulating valve failure is not credible.
Conceming the reference for the statement in the NU response alluding to the sizing of the breather valves and rupture disks, the first paragraph of Page B2 of 25 ( NEO 3.03 ) of PDCR 2-79-92 Rev 0 states the following:
' " The relief capacity and blow down characteristics of each of the breather salves and rupture disks are 100% of the worst case in surge and out surge conditions. Each of these relief protection devices j
are to be procured, tested, and installed to QA Category I requirements.
j his is also clearly stated in the technical evaluation.
Parsons Issue 2.
Parsons disagrees with NU's response The density of air at STP conditions is = 0.07528 lb/ft3 et D
= 0.1506 lb / ft3 as stated in NU's response. Using the correct density, the air inflow for drawdown is 21,344 scfh. Adding the 6,000 scfh for inbreathing due to ambient cooling results in a required i
vacuum inflow of 27,344 scfh. Therefore, the sizing of the breather valves and rupture disks at 28,000 scfh is acceptable, however the calculation still requires resision.
NU's Resoonse to Parsons Issue 2:
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NU concurs with Parsons value of air density at STP, As stated in the initial response, Calculation 17272.02-ME(B)-002 will be revised utilizing the correct density and specific gas constant for air.
Parsons Issue 3:
Parsons agrees with NU's response Use of the design values in lieu of the actual setpoints is slightly conservative in calculating mass flow required.
NU's Response to Parsons issue 3:
No comment required Discussion:
Issue 1 Parsons will review calc. and discuss 10-19-98. (10-19-98 discussion deferred per NNECo request.)
Issue 2 NNECo agrees Confirmed SL4.
Issue 3 Non-discrepant.
i) DR-0316 (Bob Lawrence, N) (Gary Jackson, P)
Parsons's u.
.. cats on NNECo's response to DR-0316:
s Parsons has reviewed attached Calculation M2401033-1600 C2 and has the following comments:
- 1) The calculation does not address the adequacy of the two 3/4" Hilti bolts through the vertical leg of the 6"x4" support angle (Item 7 on Hanger Drawing 401033A). The ICAVP limited analysis.
indicated significant tension and shear loads in these anchor bolts.
- 2) The " footprint reactions" determmed on page A5 of Attachment A are not the same as the " actual loads" use en pagu 71 of Attachment E. It is not evident how these two attachments apply to each other. No sketch of the model used to Attehment A is provided to clarify where the loads are applied.
His DR will remain open as a Significance Level 3 pending the satisfactory resolution of the comments raised.
Resolution of Parson's qp_mments on NNECo's resoonse to DR-0316:
- 1) Attaclunent E of the Calculation M2401033-1600-C2 has addressed the two 3/4" Hilti bolts through the vertical leg of the 6"x4" support angle (Item 7 on Hanger Drawing 401033A). Refer to page 2 of Attachment E for the baseplate model and pages 30 to 67 of Attachment E for STRUDL analysis "PL57.09B' ' MILLSTONE 2, file: PL57.09B, MK NO 401033, BASE PLATE'.
Sheet 6 of 6 of calculation M2401033-1600-C2 states that Base plate stiffness and allowables used in the master calculation 'PROBLO57-01653-C2' were derived from of Attachment E. The final analysis for anchor bolts on sheet 6 of 6 takes into account of actual embedments of anchor bolts that results in higher allowable loads.
(Note: The nine support was analyzed usinn a coupled model of pioing and pipe supports in the master
~
Galgulation.)
- 2) ne " Footprint Loads" shown on page A5 are the highest loads for all load cases combined from master calculation 'PROBLO57-01653-C2' page F3?s.
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The " actual loads used on page 71 of Attachment E are the actual loads from load cases 1044,1047 and 1048 from master calculation 'PROBLO57-01653-C2' page F339). Per page 6 of calculation this new run with " actual loads" was made because the base plate I.R. from master calculation on page A4 showed failure due to program conservatism.
Baseplate models are shown on pages 1,2 & 3 of Attachment E of the pipe support calculation and the STRUDL model for the support is shown on page 10 of Attachment C of the master calculation
'PROBLO57-01653-C2'.
CONCLUSION:
- 1) Pipe Support Calculation has addressed the two 3/4" Hilti bolts and the maximum bolt interaction l
is 0.86<l.0 (refer to page 6 of the calculation). The baseplate and bolts for pipe support 401033 are l
qualified. No further action is required.
- 2) Explanation is provided for the ' footprint Load' and ' actual loads' and the documents (pages) used for explanation are as referenced. No further action is required.
NU has concluded that the issues reported in DR-316 has identified a NON-DISCREPANT condition.
nice...ino.
NNECo will get clarification of model loads.
j) DR-0615 (George Howard, Chris Scully, N) (Bill Clemenson, P) i ne issues related to DR-615 were discussed during conf call on 9/29/98 and addressed in IRF 02787.
The following is a reiteration of that conversation and the IRF.
DR-0615 issue:
Discrepancies were identified in Evaluation M2-EV-96041, Rev. O, "A EDG Ventilation System F38A, Failed Air Flow Test." This evaluation supported OD MP2-264-96 for operability of the A EDG.
NU oosition:
he OD was closed with the implementation of DCR M2-97005 which corrected the A train degraded flow condition. LB/DB is met with the release of DCR M2-97005 based on Sat. test results for the A train. THERE IS NO DEGRADED FLOW CONDITION SO THE OD WAS CLOSED.
To address the DR-615 issues, Rev 1 to the Evaluation was issued which voided / deleted the evaluation since it is no longer required to support the CLOSED OD.
He followup DR raises questions on a voided / dele _tgd Evaluation and do not have to be further addressed. AGAIN THE LB/DB IS MET WITH THE CLOSURE OF THE OD DUE TO THE l
ACCEPTABLE TEST RESULTS OF DCR 97005. This is a historical issue.
Discussion:
l This topic was discussed on 10-19-98. NNECo will place this DR in follow up status pending completion of the related DR-0611.
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PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs (rescheduled):
DR-0679, DR-0202, DR-0795, and DR-0759 2.
DRs, NNECo requested topic to discuss DRs:
DR-0426, DR-0269, DR-0274, DR-0289, DR-0573, DR-0630, DR-0704, DR-0773, DR-0795, DR-0172, DR-0455, DR-0515, and DR-0104 LIST OF ATTENDEES:
I NNECo NRC NEAC Parsons Prasad Bandaru Fred Mattioli Eric Benner none Eric Blocher Ken Mayers l
Joe Fougere Ray Necci John Nakosky Dick Boyd Dom Ramos Maria Tien Nguyen Bill Clemenson Ron Smith Gharakhanian Greg Tardif Dick Diederich Jon George Howard Harold Thompson Wayne Dobson Winterhalter Ron Jackson Bob Weth Rich Glaviano Dan Wooddell Vere Joseph 1.
Topic: Parsons' Items a) DR-0679, LPSI Pump Minimum Recirculation Flow Too Low to Protect the Pump (Wayne Dobson)
NUresponse: The issues identified in this DR were discovered by NU, however per the ICAVP protocol these issues must be accepted as a confirmed level 4 discrepancies since discovery occurred after the CMP cutoff date.
Parsons Comment:
l Technical Issues: There appears to be inconsistency in the documentation provided with the DR response. Memo TS2-97-530 dated 12/15/97 correctly characterizes the following issues:
When centrifugal pumps are operated at flows significantly less than design flow this leads to erosion, unstable head-flow characteristics, and failures of pump internals, seals, and thrust bearings.
These effects can develop appreciably prior to any effects on pump performance, i.e. extended e
operation at low flow can progressively damage a pump with no evidence from performance testing until eventual failure, Flow rates are generally provided in the vendor technical manual and are required minimum flows.
e The memo summarizes the vendor recommended recirculation flow rates originally contained in memo SE-93-633. The short term flow rate for the LPSI pump is 250 gpm.
Parsons does not agree that Calculation 97-122, Rev 2 demonstrates that the minimum LPSI pump recirculation flow is above the vendor required flow values after 3 minutes ofoperation. In fact, this calculation confirms there is a potential problem since the calculated value is only 112.1 gpm.
The response also states that the current IST procedures in concert with the changes being implemented to ensure that the pumps are operated in accordance with the vendor recommendations are sufficient to Page1of11 M981019. doc
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monitor any pump degradation. This is a nice statement, but please explain the basis for why NU believes this to be true, given the TS2-97-530 memo which stated the effects of not meeting minimum l
flow requirements can develop appreciably prior to any effects on pump performance, i.e. extended l
operation at low flow can progressively damage a pump with no evidence from performance testing until eventual failure.
Significance Level - We do not understand why NU considers this to only be a level 4 discrepancy.
l What is the ICAVP protocol which indicates NU must accept this as a level 4 discrepancy?
I Parsons believes the NU response has confirmed this is a level 3 discrepancy. While Calculation 97-l 122 Rev 2 supports the conclusion that the LPSI system design can provide required flows in the non-I recirculation mode, it also shows that after three minutes, the recirculation mode does not meet the vendor recommended minimum flow of 250 gpm for up to three hours which can lead to both pumps failing.
The response also indicates that at the time of CMP complete, the LPSI pump vendor minimum flow l
recommendations had not been translated into operation procedures. This is a level 3 discrepancy as the licensing basis requirements of GL83-28 specify that vendor information be referenced or incorporated in plant instructions and procedures.
Discussion:
NNECo will table until documentation is located.
b) DR-0202 MSSV Accumulation (Rich Glaviano)
DR-0202 was discussed with NNECo on August 28. Parsons concurred with the technical resolution.
The NNECo response classified the DR as Non-Discrepant. Since corrective actions, in the form of reanalyses using the correct design values were performed, Parsons feels the DR should be classified as Previously Identified by NNECo (closed).
Discussion:
NNECo agrees with Previously Identified.
c) DR-0795 AFW Response Time Testing (Gordc.n Chen, Rich Glasiano)
The NNECo response states that AFAIS response time issues were identified as a result of the reviews initiated in response to Generic Letter 96-01. Cited is Report MPR-1816, dated April 1997, which documents the review of ESAS circuitry. This review was undertaken to ensure all portions of the electrical circuitry required to fulfill a Technical Specification requirement were covered within a surveillance procedure and that surveillances are perfonned within the frequency required by the Technical Specifications. Consequently, the time response issues identified in the report, where appropriately addressed, fall within the "Previously Discovered" Category. A review of the DR issues follows:
1.
Delay time of the SG Level instrument loop The Engineering Evaluation M2-EV 98-106 in response to AR 97028779-06 does not identify the need to correct SP 2604P to include (or otherwise account for) the response time of the actuation circuit (SG level through Auto Start annunciators). The response time measurement of Ref. 5 is Page 2 of 11 M981019. doc
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started from the AFW Auto Start signal indicated by the annunciator. The results of Ref. 5 are transcribed to SP 2604P for total AFAIS response time calculation.
As indicated in M2-EV-98-106, page 17, the logic circuit from the transmitter to the annunciator are incorporated into the I&C procedures tracked by AR 97010071-05. Review of this AR item indicates the corrective actions were completed by revision of SP 240lNA/NB/NC/ND issued on 9/12/97. However, these procedures only include response time for test of the RPS circuits, not the AFW circuits.
The AFAIS logic circuit response time test cannot be identified. Also, the current SP 2604P, Rev.
7, directs transcription of the logic circuit response time from SP 2403H (superseded by SP 2403HA/HB/HC/HD). These procedures do not include the AFAIS logic circuit response time test.
Resolution: Discrepant as Significance Level 3.
- 2. Time for the AFW pump to develop desired flow / pressure The Engineering Evaluation M2-EV-98-106 in response to AR 97028779-06 provides guidance to include AFW pump run up time in the AFAIS response time test.
Resolution: Previously Identified - Closed
- 3. Time for the valves to stroke open The Engineering Evaluation M2-EV-98-106 in response to AR 97028779-06 provides guidance to include AFW valve opening time in the AFAIS response time test.
Resolution: Previously Identified - Closed 4.
Document Discrepancy Per Reference 7, the FW-43A/B blue lights indicate the valve leaving the closed seat. The Reference 8 schematic drawings show the blue lights indicate a full open FW-43 A/B valve position. The discrepancies between Ref. 7 and Ref. 8, regarding blue light indication for valve position of FW-43A and FW-43B, are not addressed by this response.
Resolution: Level 4 Document Discrepancy.
Discussion:
- 1. Confirmed SL 4. CR M2-97-0683 issued.
- 2. Previously Identified - Closed 3.
Previously Identified - Closed Level 4 Document Discrepancy 4.
d) DR-0759 LOFW Analysis (Rich Glaviano)
NU has concluded that the issues reported in DR-0759 have identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition (Item 5) which requires correction.
NNECo has provided a qualitative assessment of the impact of each item on the analysis results. If there were significant SG inventory available for the limiting case, this kind of evaluation may be sufficient. While, individually each contributor may be small, the cumulative effect has not been l
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quantified. With the minimal (~1100 lbm/SG) calculated invertory, a more rigorous assessment is appropriate. Further comments are provided below:
Item 1 - RCS Flow assumed at TS minimum valm NU Response:
NU has concluded that this item is not a discrepant condition. He LNFF event is a relatively long term, quasi steady-state event. He heat transfer rate from the primary to the secondary systems, and therefore the steam flow out of the steam generators, is controlled by decay heat and by RCS pump heat. Using a nominal plant flow of 387,000 GPM would result in a slightly higher primary to secondary heat transfer coefficient. Because the total heat transfer rate is set by decay heat and RCS pump heat, and because the secondary system temperature is fixed at the Main Steam Safety Valves' (MSSV's) opening setpoint, increasing the primary to secondary heat transfer coefficient would only cause a small change in the primary system temperatures. This would not impact the total heat transfer rate to the secondary system.
Parsons Comment:
A higher RCS flow rate would promote increased heat transfer from the fuel and RCS metal into the RCS. The energy, along with RCS internal energy (Tave), would more readily transfer into the secondary system.
NU Response:
The LNFF analysis used the Technical Specification minimum RCS flow rate of 360,000 GPM.
Using the Technical specification minimum RCS flow raises the average primary coolant temperature (Tave). A higher Tave maximizes the energy stored in the primary system and the energy that must be removed by steam flow out of the secondary system. Therefore, it was conservative to use the minimum RCS flow for the LNFF analyMs Parsons Comment:
The higher Tave is a result of energy not being transferred into the secondary, which should be non-conservative.
Item 2 - 500 Tubes per SG assumed olueced NU Response:
NU has concluded that this item is not a discrepant condition. The impact of changes in the steam generator heat transfer area due to difference in the steam generator tube plugging would be similar to the changes in RCS flow rate explained in item 1 above. The increase in heat transfer area would only cause a small change in the primary system temperatures during the transient, and would have no significant impact on the total energy transferred to the secondary. However, changes in the heat transfer area would not affect the initial primary system temperatures or the attendant stored energy in the primary system coolant. Therefore, the level of steam generator tube plugging assumed in the analysis will not have a eignificant impact on the results of the l
analysis.
Parsons Comment:
When SG level is low, the number of tubes available for heat transfer will become a factor. Agree the contribution may be small, but should be quantified due to the low minimum SG inventory.
Item 3 - MS Bvoass and ADV's assumed not to operate Page 4 of 11 M981019. doc l
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NU Response:
NU has concluded that this item is not a discrepant condition. The LNFF analysis did not take l
credit for the Main Steam Bypass Valves or the ADV's. It was conservative not to credit the l
bypass and dump valves because it maximized the transient secondary pressures. Maintaining higher steam generator pressures minimizes the capacity olthe Auxiliary Feedwater (AFW) system, which is the critical parameter in deteimining if the steam generators dry out.
Parsons Comment:
Competing effects: lower steam pressure (lower Tsat) increases SG inventory boiled off; lower steam pressure enables increased AFW flow. Is there a sensitivity analysis or calculation which supports higher SG pressure as the limiting condition?
NU Comment:
Additionally, the energy removed by flow out of the steam generators does not depend on whether i
the flow is through the bypass and/or dump valves or the safety valves because the enthalpy of the steam is approximately constant over the pressure range covered by the steam bypass or safety valve setpoints.
Parsons Comment:
1 Concur that steam enthalpy (BTU /Lbm) is approximately constant over this range.
Item 4 - MSSV Biasing and Flow Capacit.y NU Response:
NU has concluded that this item is not a discrepant condition. As explained in the response to Item 3, the capacity of the AFW system is the critical parameter in determining if the steam
)
generators dry out.
Parsons Comment:
lo Concur similar to item 3. Likely bounded by item 3. Non-Discrepant.
NU Response:
Changing the flow capacity of the valve only changes the amount of time it is open; it does not change the total steam flow rate out of the valve.
Parsons Comment:
Concur that there are slight changes in timing, not in total quantity of steam released. Non-Discrepant.
Item 5 - AFW Flow Control Valve Single Failure NU Response:
l This item is discrepant. Condition Report (CR) M2-98-2804 (attached) has been written to provide the corrective action to prepare a new calculation to document the ability of the AFW system to mitigate the affect and consequence of a AFW flow control valve (FW-43 A/B) i single failure.
i C
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Parsons Comment':
Concur with the proposed actica.
NU Response:
If one of the valves were to fail, the affected steam generator would eventually dy out.
Auxiliary Feedwater flow would not be restored to the affected steam generator to avoid the thermal shock of supplying cold AFW to a hot steam generator. The unaffected steam generator alone easily has the capacity to remove decay heat and RCS pump heat. With the full capacity of three (two motor-driven and one steam-driven) AFW pumps available to the unaffected steam generator, it would be able to maintain the plant in a safe shutdown condition.
Parsons Comment:
Parsons reviewed Calculation 97-ENG-02053, Rev. 2, " Millstone Point Unit 2 Auxiliary Feedwater System Flow Analysis." The calculation was prepared by Proto-Power Corporation.
Appendix B provides AFW flow values for numerous cases. The following cases were reviewed:
Case 3A: 2 MDAFP's - 5% degraded at 1030 psia (Total SG flow = 384 GPM)
Case 4A: 2 MDAFP's - 1 SG isolated,1 SG at 1030 psia (SG flow = 324 GPM)
Case 4D: 3 AFW pumps - 1 SG isolated,1 SG at 1030 psia (SG flow = 362 GPM)
With one SG isolated, the AFW flow to the operable SG, in both 2 pump and 3 pump operating combinations, is less that the total AFW flow to the SGs when 2 MDAFP's are feeding both SG's. Thus, the total SG inventory with I flow path operable will be less than the total SG inventory with both SG's operable at any given point in time.
SPC analyzed the 2 MDAFP's feeding both SG's (Case 3A). The 2 MDAFP case analyzed by SPC showed a minimum SG inventory of approximately 3350 Lbm per SG (approx 6700 Lbm total) at approximately 30 minutes. This was the limiting case for RC Pumps operating.
From the discussion above, it is reasonable to conclude that had SPC analyzed the single SG case, the total inventory would be less than 6700 Lbm at the 30 minute point in the analysis (without operator action).
Since the minimum level in the operable SG has not been determined, and may be less than calculated for the limiting event with RCP's operating, it is not possible to conclude that the licensing basis is assured.
NU Response:
As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.
Parsons Comment:
l Parsons siews this as Significance Level 3 pending reanalysis results.
l l
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l Discussion:
Items 1,2, and 3 Individual items may be non discrepant, however, cumulative effect may not be.
NNECo will investigate prior to restart. Each item is SL 4.
]
Item 4 -
Non Discrepant Item 5 Calculation will be performed. NNECo will place in follow up status. No forecast for calculation completion.
CR M2-98-2804 covers Items 1,2, and 3.
- 2. Topic: NNECo's Items l
l a) DR-0426 (Tom ?ryhoda, N) (Ken Mayers, P)
NU to present technical responses to seven items previously rejected by Parsons regarding Calc 97EBF-02000M2.
Discussion:
Tabled by NNECo.
b) DR-0269 (Bill Cushman, N) (Dick Cronk, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
y Discussion:
NNECo accepts as Confirmed SL 3. CR M2-98-3047.
l' c) DR-0274 (Greg Tardif, N) (Dick Cronk, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
Discussion:
Parsons agrees that this DR is a SL 4. Will close; corrective action complete.
d) DR-0289 (Bill Cushman, N) (Dick Cronk, P)
NU has recaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
i Discussion:
NNECo accepts as a confirmed SL 3. CR M2-98-1067 was written.
i 4
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e) DR-0573 (Ron Jackson, N) (Dick Cronk, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
Discussion:
NNECo accepts as Confirmed SL 3. CR M2-98-3047 was issued.-
f)! DR-0630 (Ron Jackson, N) (Dick Cronk, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
l Discussion:
NNECo accepts as Confirmed SL 3. CR M2-98-3047 was issued.
g) DR-0704 (Norbert Carte, N) (Ken Mayers, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
Discussion:
NNECo accepts as Confinned SL 3. CR M2-97-2751 was issued.
h) DR-0773 (Ron Jackson, N) (Ken Mayers, P)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
Discussion:
Item 3 NNECo accepts as Confirmed SL 3. CR M2-97-0680 was issued.
i) DR-0795 (Ron Jackson)
NU has re-evaluated the initial response regarding " Pre-Discovery." NU will accept as a " Confirmed" DR. Discussion will focus on Significance Level as proposed by NU.
Discussion:
See Item 1.c) above for notes on this DR.
' j) - DR-0172: USI A-46 FSAR Requirements (Farid Elsabee, Sing Chu, N) (Joe Groncki, P)
NNECo has concluded that this item is NON-DISCREPANT.
NNECo intends to further clarify the FSAR to indicate MP2 has adopted the USI A-46 (GIP) methodology as the method for verifying the seismic adequacy of mechanical and electrical equipment within the scope of equipment covered by the GIP after final issuance of A-46 Completion Report and l
receipt of Staff acceptance of such report (NRC plant-specific SER). Therefore NNECo does not agree that a FSARCR is required prior to issuance of the NRC plant specific SER. The MP2 A-46 Program is in the final phase of A-46 outliers resolution. NNECo has met all the documentation requirements set forth by GL 87-02 by way of docketed correspondences with the Staff. Previous Page 8 of 11 i
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docketed letters to the NRC signified that MP2 is an A-46 Licensee and that Licensing Bases for components in the SSEL were evaluated under provisions of GIP-2. Therefore FSAR revision during the interim of the A-46 program is not necessary.
NNECo wishes to reiterate that equipment not on the SSEL, the original seismic design basis requirements, detennined from original plant construction or modification files, are technically still the l
current design and licensing bases. NNECo does not claim that the A-46 program is the " qualification basis" for such equipment.
The statement mde in technical evaluation M2-EV-98-0110 "the application of the USI A-46 program and conclusions may be logically extended to identical and demonstrably similar safety related, or for this matter commercial grade, plant equipment to those on the SSEL" is followed by "to provide a level of assurance of seismic adequacy and [a level of assurance for ] conformance with MP2 licensing basis [and its intent]." Again, as indicated above, this does not provide a qualification basis but simply a level of as:,urance of the seismic adequacy in light of the missing qualification documentation. Should NNECo want to provide a full A-46 review for such equipment, which would automatically require a 50.59 safety evaluation at the present time, the phrase " demonstrably similar" would automatically require a comparison and a walk-down. Even identical equipment would still require a walk down for anchorage and a 11 over I review, which are required by the GIP, in addition to an evaluation of the appropriate caveats.
By virtue of the completion of the USI A-46 program:
a) Equipment on the MP2 SSEL is adequately designed to safely shutdown the plant after a design basis seismic event.
b) MP2 will be in compliance with the requirements of GDC-2 and will satisfy the purpose of the NRC regulations relevant to seismic adequacy of equipment (including 10CFR Part 100) and applicable to identified equipment.
Discussion:
Deferred at NNECo's request. Date TBD.
k) DR-0455: Seismic Qual. of Manually Operated valves 2-CN-24,25,99,100 (F. Elsabee, S.Chu, N)
(Dick Boyd, P)
NNECO has concluded that this item is Sig. 4. The lack of seismic justification as described in this DR is considered administrative in nature. Parsons concluded this item Open Level 3 discrepancy.
NNECO wishes to discuss changing this DR significance level from Level 4 to Non-Discrepant.
Upon further research it was concluded that the Manually Operated Valves 2-CN 24, -25, -99 and -
100 are indeed in the A-46 Safe Shutdown Path. Review of the colored P&lD concluded these valves were part of the A-46 program, the reason that they are not in the SSEL is because they were screened out during the development of the SSEL. The GIP Rev. 2 allow inherently rugged or seismically insensitive components such as manual valves and simple check valves be screened out. Therefore, the issue described in DR-0455 is determined to be Non-Discrepant.
Dhcussion:
Deferred at NNECo's request. Date TBD.
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- 1) DR-0515: AITV Modification PDCR 2-123-82, Seismic II/I concerns (F. Elsabee, S.Chu, N) (Joe Groncki, P)
NNECo has concluded that this item is Non-Discrepant. Parsons reduced this item to Sig. 4.
NNECo wishes to reiterate that the Non-Safety Related terminal boxes and conduits located in the Turbine Bldg. are adequately mounted for seismic class 11 components. They were installed by following industry practice therefore is adequate for position retention. NEO 5.19 " Seismic Qualification Review" has not been in effect during the 1982 PDCR implementation. Guideline from MS-35 does not required documentation of positive condition. Upon receipt of DR-0515, NNECo performed a walkdown and verified the PDCR installation met Seismic 11/1 Licensing Bases.
Therefore, no corrective action is necessary and this issue remains Non-Discrepant.
Discussion:
Rescheduled to 10-22-98. See 10-22-98 notes.
m) DR-0104: HELB Pressure-Temperature Model Deficiencies Regarding lack of HVAC (R. Terry, S.Chu) (Bill Clemenson, P)
NNECo has concluded that this item is Previously Identified. Parsons concluded this item Open Level 3 discrepancy.
NNECo wishes to point out that in the MP2 Short Term assessment of HELB issues (Ref. Internal Memo GMB-90-R-413) NU established long term corrective actions to be completed under a comprehensive HELB Reconstitution Effort. In the list of recommendations the following items are provided:
1.
Emironmental communication paths need to be reviewed and assessed. (Ref. Section 4.9)
- 2. Address ductwork integrity under HELB Pressurization effects to ensure that no new communication paths are created as a result of ductwork failures. (Ref. section 4.7)
The HELB program was initiated in 1994 and set up as a series of phased steps to logically cover all aspects of High Energy Line Break event (postulation, mitigation, and consequences). In phase 3, the compartmental input was developed and the conservative assumption to neglect ventilation ducts, thereby maximizing temperature and pressure effects in the area of the break, was adopted. The subsequent evaluation of structural elements and intervening ductwork between harsh and mild emironments was scheduled for completion in phase 6 (Note: phase 6 was incorporated into phase 5 in May 1998). Since phase 6 was not initiated until early 1998, Parson's comment (September 1997) that HVAC flow paths had not been addressed is correct. However, the comment was made against and ongoing program which fully recognized the requirement to address this issue.
HVAC ducts and their potential to allow interaction between harsh and mild emironments has now been addressed following the completion of analyses providing the associated temperature and pressure profiles. The documents that address this issue have previously been prosided to Parsons and are listed below for information:
- 1. TE No. M2-EV-98-0150, Rev. O,"MP2 Turbine Building HELB Pressurization Effects on Ducts Communicating with Unit 1 Area," dated August 22,1998.
2.
TE No. M2-EV-98-0178, Rev. O, "High Energy Line Break (HELB) Pressurization Effects on HVAC Ducts in the Auxiliary Building," dated September 19,1998.
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]
- 3. Calculation HELBDUCT-02676C2, Rev.0, " Pressure Differential Effect Study - Structural Evaluation for HVAC Components," dated September 19,1998.
i Based on the above discussion and the fact that the HELB Program was an ongoing effort at the time of Parson's comment, the original conclusion that this is a Previously Identified condition remains unchanged.
Discussion:
This topic was discussed 10-20. NNECo will accept as a SL 3. CR M2-97-1633 covers the Turbine Building and CR M2-97-2188 covers the Auxiliary Building.
i l
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, CONFERENCE NOTES DATE: 10/20/98. Rev. O TlME: 2:00 n.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons requested topic to discuss DRs (rescheduled):
DR-0744, and DR-0684
- 2. DRs, NNECo requested topic to discuss DRs:
DR-0738, DR-0172, DR-0756, DR-0597, DR-0646, DR-0599, DR-0709, l
DR-0590, DR-0403, and DR-0422 I
LIST OF ATTENDEES:
l NNECo NRC NEAC Parsons Kalvin Anglin Fred Mattioli Eric Benner ~
none Eric Blocher Ron Smith Pmsad Bandaru Ray Necci Gene Imbro Dick Boyd Yonic Tamayo John Bemis Mike O'Meara John Nakosky Dan Cardinale Norbert Carte Tom Prvhoda Frank Cobb Jim DiLuca Chris Scully Dan Curry Joe Fougere Greg Tardif Wayne Dobson l
Wadie Gergos Ben Yazbek Ken Mayers Ron Jackson Dom Ramos l
- 1. Topic: NNECo's Items i
l a) DR-0744 (Tom Pryhoda) (Frank Cobb)
Parsons says we misinterpreted the prerequisite test requirements in ANSI N510 for the RG 1.52 compliance that we agreed to in our T/S.
NU's position is MP2 was not a RG plant and we selected portions of RG 1.52 to use for acceptance criteria in testing our charcoal filters.
NU acknowledge the prerequisite tests validate the subsequent test results and we will perform these tests following any future mod to the filtration systems, but for now we are taking exception from the
" guidance"in RG 1.52. NU explained this clearly in the TRM.
Discussion:
Tabled for NNECo review.
b) DR-0684 (Tom Psyhoda) (Frank Cobb)
DR deals with a partially turned over but still open design modification.
Parsons says our retest method of a damper is insufficient to prove it works during an unlikely but possible fan lineup.
NU told Parsons the mod is still open. NU had the damper factory modified and tested and sent the test results. Parsons says this still doesn't prove it will close with the main exhaust fan running. NU has a future test planned that will answer this question. In the meantime, Parsons wants:
An analysis that the damper actuator has sufficient torque to close the damper against the running fan and Page 1 of 8 M981020. doc
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A copy of our revised post mod test (for the open DCR) that explains conditions required for e
successful completion NU has a proposed corrective action. NU would like to present a revised retest method to Parsons.
Discussion:
NNECo will place this in follow up status. CR M2-98-3134 was written to review testing-requirements.
- 2. Topic: Parsons' Items a) DR-0738 & EDG Air Start Licensing Dasis (Bill Clemenson)
References:
- 1. DCR M2-97005 l
- 2. Safety Evaluation S2-EV-97-0019, DCR M2-97-005
- 4. UIR 2767'
- 5. DR-738
Background:
DCR M2-97005 removed the outside air dampers from the EDG Emergency HVAC system. These i
dampers were originally designed to remain closed during winter operation until the EDG rooms reached a preset minimum temperature. The dampers would then modulate open as required. This temperature control function was handled by a local TIC. With the removal of these dampers, this mode of EDG room temperature control for winter operation was deleted.
The Safety Evaluation for this modification addresses the impact of this change in winter temperature control in section 2.1.2.2 as follows:
"The only concern is the impact on diesel room nummum air temperature when the damper is eliminated. This concem has been addressed in a calculation (97-ENG-01767-M2, Rev 01) with the conclusion that the room can be maintained at or above the minimum design basis minimum temperature of 55'F."
Subsequent to the issuance of 97-ENG-01767-M2, Rev 1, NU issued UIR 2767 to address a deficiency with this calculation on EDG Room Temp. UIR 2767 stated, "The calculation did not investigate the scenario where the diesel starts and before it reaches operating temperatures stops or is intentionally stopped by the operator. In this case the fan will keep runnmg until turned off by the operator. A large amount of cold intake air may reduce the room temperature sufficiently that the 55*F temperature will not be maintained."
UIR actions included issuance of A/R 97021816-02 to evaluate this scenario for winter operation.
The UlR was closed with the following statement;
" Determined Ventilation perf. after DG fail to start does not require further evaluation /
l resolution. See low temp calculation 97ENG-01767-M2, Rev.l."
l After review of UIR 2767, Parsons issued DR-738 which stated that there was no record of how NU f
addressed the issue raised in UIR 2767, that the reference to 97ENG-01767-M2 was not applicable, Page 2 of 8 M981020. doc
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that this calculation was issued prior to discovery of this issue, and that the cale does not address the scenario described in UIR 2767.
NU has responded that this is a non-discrepant condition and that the MP2 LB and DB does not l
require the EDG to restart if the initial EDG start failed. Additionally, NU states that the reference to l
calc 97ENG-01767-M2 is correct as literally stated.
Topics for Discussion 1.
EDG Air Start Licensing Basis. UIR 2767 identified a scenario where an EDG has a false start during an accident (LOP) and then Operations attempts to restart at a later time during the accident but the EDG rooms would be below 55'F. Is it NU's position that the MP2 LB does not l
require the EDG to be capable of more than one air start during an accident condition? How many starts is the EDG air system designed to provide for each EDG?
2.
Inadequate Safety Evaluation. Review of S2-EV-97-0019 indicates it does not adequately address the scenario identified in UIR 2767. The SE relies solely on calc 97-ENG-01767-M2 to address the PDCR's impact on the HVAC systems winter operational requirements (Sections 1.1 &
2.1.2.2). As NU stated in their response to DR-738, "This calculation (97-ENG-01767-M2) does not resolve or address the issue in the UIR."
It is Parsons opinion that DCR M2-97005 has increased the possibility of an EDG malfunction and that the SE has not addressed this issue adequately.
3.
Inappropriate closure of UIR 2767. Final Disposition of UIR 2767 (Section 5) states that the EDG restart issue, "does not require further evaluation / resolution See low temp cale. 97ENG-Ol767-M2, rev.1." It is Parson's position that this fmal disposition of the subject UIR is misleading and incorrect. Though NU is correct in responding that the referenced calculation does exist, this referenced cale does not address the issue raised in the UIR. The UIR appears to have been closed without performing the actions stated in the UIR disposition.
Discussion:
Discussed on 10-21-98. Parsons will close this DR as a SL 4. CR M2-98-2880 was issued.
b) DR-0172: USI A-46 FSAR Requirements (Farid Elsabee, Sing Chu, N) (Joe Groncki, P) Address this DR with DR-0756 (below)
NNECo has concluded that this item is NON-DISCREPANT.
NNECo intends to further clarify the FSAR to indicate MP2 has adopted the USI A-46 (GIP) methodology as the method for verifying the seismic adequacy of mechanical and electrical equipment within the scope of equipment covered by the GIP after final issuance of A-46 Completion Report and receipt of Staff acceptance of such report (NRC plant-specific SER). Therefore NNECo does not agree that a FSARCR is required prior to issuance of the NRC plant specific SER. The MP2 A-46 Program is in the fmal phase of A-46 outliers resolution. NNECo has met all the documentation requirements set forth by GL 87-02 by way of docketed correspondences with the Staff. Presious l
docketed letters to the NRC signified that MP2 is an A-46 Licensee and that Licensing Bases for l
components in the SSEL were evaluated under provisions of GIP-2. Therefore FSAR revision during the interim of the A-46 program is not necessary.
NNECo wishes to reiterate that equipment not on the SSEL, the original seismic design basis requirements, determined from original plant construction or modification files, are technically still the current design and licensing bases. NNECo does not c aim that the A-46 program is the " qualification basis" for such equipment.
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The statement made in technical evaluation M2-EV-98-0110 "the application of the USI A-46 program and conclusions may be logically extended to identical and demonstrably similar safety related, or for this matter commercial grade, plant equipment to those on the SSEL"is followed by "to provide a level of assurance of seismic adequacy and [a level of assurance for ] conformance with MP2 licensing basis [and its intent]." Again, as indicated above, this does not provide a qualification basis but simply a level of assurance of the seismic adequacy in light of the missing qualification documentation. Should NNECo want to provide a full A-46 review for such equipment, which would automatically require a 50.59 safety evaluation at the present time, the phrase " demonstrably similar" would automatically require a comparison and a walk-down. Even identical equipment would still j
require a walk down for anchorage and a 11 over I review, which are required by the GIP, in addition to an evaluation of the appropriate caveats.
By virtue of the completion of the USI A-46 program:
a) Equipment on the MP2 SSEL is adequately designed to safely shutdown the plant after a design basis seismic event.
b) MP2 will be in compliance with the requirements of GDC-2 and will satisfy the purpose of the NRC regulations relevant to seismic adequacy of equipment (including 10CFR Part 100) and applicable to identified equipment.
DR-0756 (Joe Groncki)
The misunderstanding surrounding the intent of Section 3.3 of Technical Evaluation No. M2-EV 0110 began with the NNECo response to various Parsons RAls requesting seismic documentation for non-SSEL components. In their responses to these RAls (1125,1517,1560, and 1785), NNECo stated that the requested seismic information was not available. The responses go on to state, "However, Technical Evaluation No. M2-EV-98-0110 issued by MP2 Desien Eneineens f*ovides the iustification recardine the seismic basis of cauipment and comoonents at Millstone Por q: 1 "
This sentence, when read with the " provide a level of assurance" statement in Section 3.3, in.( ai a Parsons that the A-46 Program was being used to provide a " full" level of assurance of the seismic adequacy of non-SSEL components.
Based on the response to this DR, as well as other conversations with NNECo, Parsons now understands that the intent of Section 3.3 is to refer to the A-46 Program as providing "some" level of assurance for the seismic adequacy of non-SSEL components with missing qualification documentation. Parsons agrees with this intent for Section 3.3.
However, Parsons feels that this DR does identify a Significance Level 4 documentation discrepancy in that the intent of Section 3.3 as explained above is not immediately apparent when reading Section 3.3 as it is now written in Technical Evaluation No. M2-EV-98-0110. Therefore, Parsons feels that the NNECo response to this DR should be incorporated in some manner into Section 3.3 so that any potential future misunderstandings concerning the NNECo position on the use of the A-46 Program.
Di=len-This topic was discussed 10-21-98. Parsons will close DR-0172 as Non-Discrepant. DR-0756 will j
be closed as a Confirmed SL 4. CR M2 98-3162 was issued.
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l c) DR-0597 (Dick Cronk)
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There are two issues identified by this DR: (1) MEPL MP2-CD-1512 designation for RM-8168, LIC-8168 and RIC-8168 contradicts with the as-built drawings and the Cable and Raceway Schedule Data (TS02). MEPL identified these components as " Category 1"(Facility Zl) while the drawings and TS02 identified these components as " Facility 1." (2) Assuming the as-built drawings and TS02 are correct, there is improper isolation between non-safety components and safety components associated with VA10 Breakers 1 and 15.
Parsons agrees that the second issue of the DR was a previously identified condition (per PIR 2 232) and is being addressed by DCN DM2-00-0268-98 and DCN DM2-00-0580-98. Parsons disagrees that the first issue is a previously identified condition. NNECo has provided no esidence to support their assertion of previously discovered for this issue. Because there is no licensing and design basis affected by the MEPL discrepancy, Parsons recommends that this DR be reclassified as a Level 4. Issuance of CR M2-98-2851 (A/R 98017534) dated 9/22/98 to issue a new MEPL evaluation to downgrade RM-8168 and associated equipment to non-QA supports the validity of the issue and provides an acceptable method of resolution.
Discussion:
NNECo will accept this as a Confinned SL 4. CR M2-98-2851 was issued.
d) DR-0646 (Dick Cronk)
Parsons agrees with NU's approach to resolving DR-0646: updating Calculation PA85-082-0812GE to include coordination plots of the var'ous breaker / fuse combinations which exist not only for the co;nponents evaluated by ICAVP, but others as well. However, regarding the components evaluated by ICAVP which reference DR-0646, NU needs to provide the following to close this DR:
- 1. A preliminary plot demonstrating coordination between a 30 ampere breaker and a 20 ampere fuse to envelope the remaining cases identified in the DR.
- 2. A justification for the acceptability of the slight overlap of the characteristics for a 20 ampere breaker and a 15 ampere fuse (Attachment 3 to NU's response to DR-0646).
j Parsons agrees that, with the acceptable completion cf the above two items, DR-0646 can be dispositioned as a Significance Level 4.
Discussion:
The calculation will be revised. Based upon this discussion, Parsons will close as a SL 4. CR M2-98-2685 was issued.
e) DR-0599 (Dick Cronk)
Parsons accepts NU's corrective action plan as depicted in their response but Parsons cannot accept NU's classiJaaticn as Significance Level 4 nor can Parsons accept NU's position that these corrective actions are enhancements. These corrective actions require completion prior to restart to provide 4
assurance that the worst case circuits have been properly selected and analyzed. Assurance cannot be obtained until the reviews proposed in MP2's response are completed and documented. NU assumes in their response that the calculation's conclusions will not change as result of these resiews. Based on the information presently available in the calculation, Parsons does not share this position. The defmitive documentation and justification that those circuits presently selected in the calculation Page 5 of 8 M981020. doc
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l bound all other MCC circuits must be placed in the calculation prior to restart to ensure that MP2 has analyzed the worst case conditions and satisfied MP2's licensing basis.
Parsons accepts NU's response that most of MP2's cable data came from Construction and that the lengths represent cut values and that these are historically conservative. That response, however, does not address the issue identified in DR-0599. The cable length and conductor size used in the calculation were derived from a non-QA source which has not been verified nor has the software i
which controls the cable data been verified. The calculation should be revised prior to restart to either identify that the cable data is an assumption and providejustification that it is acceptable to enter restart with this assumption unverified or perform verification of said data prior to restart.
Discussion:
NNECo will place in follow up status to study further.
f) DR-0709 (Dick Cronk)
]
Parsons agrees that using the minimum voltages identified in PA91-004-290E2 Rev. 00 provided more conservatism to calculation 97-ENG-01658-E2. Parsons agrees that the results and conclusion of calculation 97-ENG-01658-E2 will remain unaffected if no reductions are made to the values of the MCC's minimum voltages.
Parsons disagrees with NU's NON-DISCREPANT disposition of the DR until the corrective action to address DR-0599 in M2-98-2731 is completed and until it is documented that no conclusions of 97-ENG-01658-E2 are affected.
Discussion:
Parsons agrees that this DR is Non-Discrepant.
g) DR-0590 (Dick Cronk)
NU concurs with Parsons on issues 1,2, and 5 as identified in DR-0590. Parsons does not accept NU's positions on issues 3 and 4. NU's response for issue 4 is that it is non-discrepant since the loads on Bus 24E are not normally energized as they are spare units. Although this statement agrees with the FSAR description, it does not exclude the energization of these loads during normal operation.
The FSAR does not indicate that a LCO is entered whenever the loads on Bus 24E are used.
Therefore, the calculation must address the acceptability of voltage levels when these loads are energized and ensure that adequate voltage is available at the loads' terminals during a design basis event. NU also discusses in their response a comparison of the various cable lengths between the 9 loads connected to Bus 24C,24D, and 24E. This comparison has limited usefulness since the comparison failed to include the connecting cable between Bus 24C or Bus 24D to Bus 24E.
NU's response for issue 3 states that the loss oflife would be minimal since the motors typically operate at less than rated temperature or are not operating or are - ; fully loaded. NU also submits l
that overvoltage relaying will alert operations who are to take actmas to minimize the exposure to the i
motors. Parsons agrees that, based on these statements, the duranon of overvoltage exposure to the j
motors appears to be short relative to the motor's qualified life. However, Parsons believes that since these statements are qualitative in nature, additional documentation should be included in the calculation to support these statements. This documentation would typically include operational history for these predicted periods to determine the amount of time the system was in an overvoltage Page 6 of 8 M981020. doc
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i condition, the amount of overvoltage present, the loading present during these periods, and quantitatively define the impact on the equipment's qualification. This logic should apply to all connected equipment, including 125VDC and 120VAC and sclid state controllers.
l Discussion :
Items 1,2, and 5: Parsons and NNECo concur with DR positions.
Items 3 and 4:
NNECo will accept these as SL 4. CR M2-98-2916 was issued.
i h) DR-0403 (Ken Mayers) l-NNECo acknowledges that HSPI flow indicators (0-300 GPM) will be " pegged out" (approximately 320 GPM per loop). RG 1.97 Rev 2 requires 110% of design flow. NRC indicated that evaluation criteria for SER approval for RG 1.97 was based upon licensee requested exception (s). If no exception was requested, NRC review was based upon the requirements ofRG 1.97. Status of compliance in SP-M2-EE-0012 Rev 2 for variable D-06 under Range lists RG 1.97 requirement as "0-110 % of Design Flow" and NNECo's compliance as 0-300 GPM.
- 1. NNECo stated that Cal 87-014-586GM is to be superseded by 97-122 to analyze ECCS flows:
- a. How is the 466 GPM flow indicated calculation 87-014-586GM Case 6
. dispositioned?
- b. Is this calculation the basis for the 320 GPM?
- 2. Since NNECo stated that the HPSI flow can be as high as 320GPM, why does NNECo believe this is NON-DISCREPANT rather than a SL 3?
- 3. NNECo stated that the HPSI flow indicators are not credited for flow indication during/after a LOCA." How is step 2.37 a of EOP 2532 Rev 15 performed without these indicators?
Discussion:
NNECo will place in follow-up status for further study.
h) DR-0422 (Ken Mayers)
Based upon the NNECo response Item 1.b, Item 2.a & 2.b is closed as Non-Discrepant while
' Item 3.a is closed to Item 1.a. This question deals with item 1.a.
Background:
NCR-97-468 evaluated the instrumentation addressed by this DR and concluded that transmitters PT-319/329/339/349 and FT-311/321/332/341 were originally procured as Category 1. Further, NNECo's review of AWO's indicate that except for replacement of FT-341 with Category 1 transmitter taken from pressurizer level loop L110Y all transmitters are original equipment.
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Specification 18767-ICE-903-03 Section 4.1.1 " Seismic requirements is shown on individual sheets." Further, Section 4.5.1 states "The equipment identified as Class I on the individual data specification sheets, with the exception of panel mounted indicators shall be designed such that maximum seismic acceleration in the horizontal and vertical direction occurring together shall not cause loss of function of equipment either during or following a seismic disturbance." ICAVP review of the data sheets indicate that Quality Class 1 was not specified on sheet 175 Rev 2 for PT-319/329/339/349. While data sheet 189 Rev 3 specified transmitters FT-311/321/331/341 as Quality Class 1.
Specification 18767-ICE-903-03 specified various CE instrumentation. Per NNECo a.
response, Specification M700, MRR WEO-1645 indicates procurement of PT-319/329/339/349 as Category 1. CE PO 9102838 indicates procurement of these instruments. However, neither the PO or the parent specification 18767-ICE-903-03 sheet 175 Rev 2 demonstrates that these transmitters are Category 1. What document demonstrates NNECo's basis for stating that these are original equipment QA?
- b. FT-311/321/331/341 according to the NNECo response is Category 1 per Specification M700, MRR WEO-2438. The parent specification 18767-lCE-903-03 sheet 189 Rev 3 specifies that these transmitters are Quality Class I. However, CE PO 9103751 does not list these transmitters as part of the PO. What document demonstrates NNECo's basis for stating that these are QA?
NNECo confirmed Item 1.a as a SL 4 discrepancy. Since PI-3046/3048/3050 need to be c.
replaced to meet Category I pressure boundary, why isn't this item of the DR upgraded and considered a level 3 discrepancy? -
Discussion:
NNECo will accept this DR as a Confirmed SL 3. CR M2-97-2621 was issued.
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w CONFERENCE NOTES DATE: 10/21/98. Rev. O TlME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
DRs, Parsons requested topic to discuss DRs (rescheduled):
DR-0738, DR-0172, DR-0756 and DR-0422.
- 1. DRs, NNECo ltems:
DR-0275, and DR-0278.
- 2. DRs, Parsons Items:
DR-0654, DR-0106, DR-0140, DR-0746, DR-0066, DR-0078, DR-0155, DR-0231, and DR-0062.
3.
DRs, NNECo Items:
DR-0339, DR-0085, and DR-0078.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Norbert Carte Ray Necci Gene Imbro none Mike Akim Joe Groncki Sing Chu JeffScheeler John Nakosky Eric Blocher Ken Mayers Farid Elsabee Chris Scully Dick Boyd Ron Smith Joe Fougere Steve Stadnick Bill Clemenson Dan Wooddell Ron Jackson Greg Tardif Dick Diederich Jon Winterhalter Fred Mattioli Bob Weth Wayne Dobson Rescheduled items from 10-20-98: (See 10-20-98 notes for these DRs) 2.a DR-0738 (Clemenson) 2.b DR-0172, DR-0756 (Groncki) 2.h DR-0422 (Mayers)
- 1. Topic: NNECo's Items a) DR-0275: RWST Weather Enclosure (Farid Elsabec, Sing Chu, N) (Joe Groncki, P)
NNECo has concluded that this item is Significance Level 4. Parsons concluded this item is Open Level 3 discrepancy.
NNECo wishes to reiterate that the A-46 Walkdown and evaluations were performed by a qualified seismic review team (SRT) whose methodology, procedures and walkdown results were validated by a peer review performed by industry recognized and accepted expert seismic qualification consultants.
The SRTs conclusion was that the RWST weather enclosure is not a credible seismic interaction.
NNECo considers the overall A-46 program implementation to be adequate, and in conformance with GIP-2 criteria.
Discussion:
NNECo will accept as a SL 4. Corrective action is complete.
Page 1 of 5 M981021. doc
CONFERENCE NOTES DATE: 10/21/98, Rev. O TIME: 2:00 n.m.
b) DR-0278: (N. Carte, R. Ewing, J. Scheeler, N) (Ken Mayers, P)
Parsons requested the procedures used to perform maintenance on ASCO solenoid valves. NU provided the appropriate component replacement schedules for these valves and noted that maintenance procedures existed. However NU did not provide a description of how the valves are used and the associated maintenance requirements.(NOTE: The maintenance requirements dictate the need for maintenance procedures. That is to say if there are no maintenance requirements, then there is no need for procedures.)
NNECo would like to discuss the following.
The solenoid valves (SOV's) are all used as pilot operators for Air Operated Valves (AOV's). The j
maintenance requirements consist of cycling these AOV's periodically and SOV replacements. The periodically cycling is to be performed in accordance with scheduled AWO's.
The replacement activities are governed by work instructions. General tasks such as torquing and termmating via an approved / qualified termmation method are covered by either general instructions and procedures or are " skill of the trade" type activities (and therefore do not require procedures). If a maintenance activity were performed on these valves then it would have been done per work instructions. In the process ofgenerating these work instruction the appropriate notes from the Component Replacement Schedule (CRS) would have been included. According to the CRS the 1
shortest replacement interval on any of the components was 17 years, therefore the earliest anticipated maintenance would occur 17 years after installation.
Discussion:
Parsons agrees that this DR is Non-Discrepant.
l
- 2. Topic: Parsons' ltems a) DR-0654 (Ken Mayers) FOLLOW UP to 10/13/98 Teleconference and 10/16/98 FAX l
NNECo transmitted FAX 10/16/98 with pages L1 - L3 from EDG tech manual 25203-138-002A.
l During the teleconference Parsons agreed to close this DR as non-discrepant pending review of this l
material. Based upon this review, the ICAVP has several follow up questions:
The PS that detects inadvertent FO valve closure is located in the downstream tap of the duplex filter.
l Per the tech manual, the flow path to get into the FO drain heeder is through the FO pump gears, l
check valve on the upstream side of the duplex filter, the dup! :x filter, and individual injection pumps
- 1. Assuming that the FO pump gears are not worn, what is the leakage specification across the FO pump? What is the leakage specification across the injector pumps?
2.
Since NNECo is taking credit for this leakage (vent) path to determine whether the FO valve has inadvertently closed, what procedure checks to assure isolation valves in the clean FO drain line to the clean oil storage tanks are not closed?
i i
- 3. Given the " variable" nature of this design (both for leakage and operation [ clean oil drain isolation valves), why is periodic testing not required?
Page 2 of 5 M981021 doe i
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CONFERENCE NOTES DATE: 13/21/98. Rev. O TIME: 2:00 o.m.
Discussion:
4 NNECo will accept this DR as a SL 4. A procedure (s) will be changed. CR M2-98-2880 was written.
b) DR-0106 (John Archer, Ken Mayers) FOLLOW UP to 10/13/98 Teleconference Original 10/13/98 agenda item.
" Parsons wishes to discuss the difference in Significance Levels assigned to this DR. Parsons classified as a SL 3, NNECo as a 4. Parsons concurs that Items 2,3, and 4 of this DR can be properly classified as SL 4 issues.
For Item 1, FT-5277A&B, NNECo's DR response states that " Low points and slope in the horizontal portions of sensing lines, from root to drain valves, for FT-5277A, and FT-5277B will be corrected as a maintenance item before restart via a approved Design Cha' ige Notice DM2-00-0054-98 (see attachments) by reclamping or rerouting to be consistent with drawing 25203-28408 sheet 977. The restored layout will be in compliance with drawing 25203-28402 sheet G-1, " General Instrument Installation Notes."
'Ihe NNECo response also diseasses current practices and proposed future calibration procedure enhancements that reduce or eliminate potential for air induction into the tubing lines.
Parsons does not consider the rerouting of this tubing to be a minor " maintenance item" when Design Change Notices are used as the basis for the work. Drawing 25203-28402, Sh F02 establishes a 1"/ft muumum slope requirement. Walkdowns confirmed that the tubing has low points and other portions
'of the lines when the slope requirement is not satisfied.
Parsons agrees that the corrective action proposed for this DR is appropriate but considers the DR to be SL 3 based upon the field changes being made to bring the field condition into compliance with slope requirements."
Current Position:
After reviewing the walkdown infonnation, Parsons' still believes the current instaliation in not in compliance with the original design documents. Parsons concurs with the corrective action; however, the only remaining issue is why this is not an SL3.
Discussion:
Parsons will close as SL 4. DCN DM2-00-0554-98 and CR M2-97-2633 were prepared.
c) DR-0140 (Dan Cardinale)
Parsons has reviewed NNECo response to DR-0140 and agrees that accuracy requirements are not specified by RG 1.97. Failure of one of the two RG 1.97 channels would not impact the ability of the operator to detect whether core power is increasing or decreasing. Accordingly, designation of only two out of the four installed channels as post accident monitoring instruments in and ofitselfis not a discrepant condition. However, Parsons requests answers to the following questions before DR closcout.
Page 3 of 5 M981021. doc
CONFERENCE NOTES l
DATE: 10/21/98, Rev. O TIME: 2:00 p.m.
NNECo letter dated November 7,1995 to NRC declared that NNECo was reducing the number of channels of WRNI from four to two for RG 1.97 purposes. The previous design had been accepted by NRC in their 2/5/91 SER. Has NRC issued another SER or given any other concurrence to that decision? If so, please identify the concurrence mechanism.
- 1. Has NNECo performed any analysis or evaluation which documents how conformance to RG 1.97 regulatory position 1.3.1.b (divergence of two instrumentation channels) is met? Has the analysis identified the back up channels that would be used? Has the analysis addressed the issue of electrical and physical independence requirements for the back-up channel (s)?
- 2. What mechanism exists to control time out of service for one or more channels of WRNI? Are these controls and limits any different for Channels B & C than they are for Channels A & D?
Discussion:
Parsons will close this DR as Non-Discrepant.
d) DR-0746 (Ken Mayers)
Parsons has reviewed NNECo response M2-IRF-02815 and its attachments. The ICAVP agrees that items 1 and 2 of this DR are non-discrepant based on the logic provided by NNECo and the NRC's approval of the original design philosophy.
j l
ICAVP agrees with NNECo's Corrective Action Plan for item 3, however, based on the l
" Recommended corrective actions" identified in Condition Report M2-98-2792, the addition of color l
coded bands on the redundant Zl, Z2, Z3, and Z4 cables, in switchgear cabinets 24C and 24D, constitutes a physical change in the plant in order to meet the design and licensing basis.
- 1. Why doesn't NNECo believe this is an SL3 discrepancy?
- 2. In addition, in switchgear cabinet 24C, the Corrective Action Plan does not address the 'te-wrap" tying together the redundant cables for channels Z1 and Z3. The CR states that a justification will i
be performed for ESAS field cables for undervoltage terminating in switchgear cabinet 24C/D without meeting separation requirements of SP-M2-EE-0016. Why aren't these issues also considered SL3 since they do not meet the design and licensing basis?
Discussion:
NNECo will accept this DR as a SL 3. CR M2 98-2792 was issued.
e) DRs Listed Below (Dick Boyd)
The following DRs can be closed out as Confirmed Level 4 when CRs are assigned by NNECo:
DR-0066 SL 4 from "Previously Identified review by NNECo" CR M2-98-2880 DR-0078 SL 4 from "Previously identified review by NNECo" CR M2-97-2269 and l
AR 960588960588l
DR-0155 SL 4 in 10-1-98 teleconference CR M2-98-2880 DR-0231 SL 4 in 7-29-98 teleconference CR M2-98-3042
[
DR-0062 Is a Level 4 which could be closed as it is similar to DR-0061 and the same CR could i
be used; CR M2-98-3042 Page 4 of 5 M981021. doc
i'-
CONFERENCE NOTES DATE: 10/21/98. Rev. O TIME: 2:00 p.m.
Discussion:
The NNECo-supplied CR numbers are shown above.
- 3. Topic: NNECo's Items a) DR-0339 (Norbert Carte, N) (Ken Mayers, P)
This DR involves lack of documentation required to demonstrate qualification of the replacement transmitters. NNECo would like to discuss the documentation that does exist in the project file for PA 80-168 and in the MRIR package 281-135 (ref RAI 943). Weaknesses in documentation does exist l
and NNECo would considered this DR a SIGNIFICANCE LEVEL 4 discrepancy.
Discussion:
Parsons agreed to close this DR as a SL 4. CR M2-98-2883 was issued.
b) DR-0085 (Bob Weth, N) (Dick Boyd, P)
NNECo would like to discuss the relationship between the IST program,10CFR50, Appendix B Criterion XI, and Post Modification Testing, and Instrument accuracies. NNECo plans to address each item presented by Parsons in Jieir follow-up to NNECo's initial response to this DR.
l Discussion:
This topic was tabled at Parsons' request.
c) DR-0078 (Fred Mattioli, P) (Dick Boyd, P)
NNECo would like to discuss the tracking mechanism used for item 2 of the DR. When the AR's are reviewed in AITfS the mechanism which supports these items is the ESAR for Appendix R.
Discussion:
NNECo will accept this DR as a SL 4. CR M2-97-2269 was written.
1 Page 5 of 5 M981021. doc
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CONFERENCE NOTES DATE: 10/22/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons Items:
DR-0688, DR-0564, and DR-0404.
2.
DRs, NNECo items:
DR-0515, DR-0180, DR-0193, DR-0194, DR-0730, and DR-0533.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Sing Chu Fred Mattioli Peter Koltay none Mike Akins Gary Jackson Peter DutT Ray Necci Eric Blocher Roger Mauchline Farid Elsabee Dick Boyd Bob Moyer Joe Fougere Dick Diederich Ron Smith Norm Goldstein Wayne Dobson Dan Wooddell George Howard Joe Groncki
- 1. Topic: Parsons' Items a) DR-0688 (John Archer)
Issue Related to Licensing Basis FSAR 7.5.1.4 (Post Accident Monitoring)
As part ofNNECo's response to DR-0688, NNECo referenced the A-46 Program SEWS and the LT-5282 level transmitter's Bounding Spectrum. A review of the LT-5282 SEWS did not indicate a reference source or provide a justification for the transmitter's correlation to this SEWS' seismic bounding spectrum.
- 1) What was the source for the bounding spectrum data for this Foxboro N-823 transmitter?
- 2) Was the transmitter's correlation to the bounding spectrum based on generic experience, EPRI NP-7149, or what?
- 3) Is it NNECo's intent to use the A-46 Program SEWS for the LT-5282 seismic qualification as it relates to R.G.1.97 requirements?
In addition, NNECo has implied for DR-0688 Item 3 that seismic qualification associated with R.G.
1.97 variable LIS-5489 would be integrated with the response to DR-0116. Currently, the NNECo response to DR-0116 states that the Specification SP-M2-EE-0012 was updated to Rev.1, which shows that seismic qualification was provided for CST level instrumentation. The response did not identify which seismic method was used to qualify LIS-5489, nor did it provide any qualification details. In contrast, NNECo response to RAI 552 stated that LIS -5489 was not safety related and did not address the seismic qualification issue.
What qualification document does NNECo claim validates the seismic qualification of LIS-5489?
Dh
- c=-
This topic has been rescheduled to 10-23-98 at Parsons' request.
Page 1 of 3 M981022. doc
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CONFERENCE NOTES DATE: 10/22/98. Rev. O TlME: 2:00 p.m.
b) DR-0564 AFW/SG Instrument Tubing (Gary Jackson)
Parsons agrees with NU's DR-0564 dispositions except as follows:
DR Issue Items # 2b,3c,4 and 10: Closure of these items is acceptable as Confirmed Significance Level 4 conditions; NU dispositioned as Non-Discrepant.
DR issue item # 8: NU's response to the LT-5272 Issue item 8 evaluated the existence of two 3-D clamps on the same tubing segment as acceptable based on ambient system conditions at the clamps physical location due to the distance of the installations from the process heat source. However, consideration was not given to the expansion effects (279 to 400 F) this tubing segment would be susceptible to under accident conditions. It is estimated that under accident conditions, axial expansion stress would exceed Code allowable by a factor of 3. The installation of two (2) 3-D supports on the same tubing segment requires corrective action, field modifications required.
Therefore, the LT-5272 issue remains open as a Significance Level 3 discrepancy pending further NU resolution.
Discussion :
Item #8 NU stated B31.1 does not require stresses due to external heat to be considered, therefore the tubing for this level transmitter does not need to be analyzed for accident temperature conditions.
NNECo further identified their simple hand calculation indicates the expansion is only on the order of 1/64 inch. This DR was tabled, Parsons to relook at AFW design basis during accidents, as this level transmitterinitiates AFW.
l c) DR-0404 (Roger Mauchline) l Item numbers follow those in NU response M2-IRF-02823:
- 1. It was not Parsons' mtention to make 12' spans a starting point forjustifying longer spans based on light cable loads. 10' spans are the established GIP criteria.
I Does the acceptance oflonger tray spans, based on loads less than maximum, require any action to limit future routing of cables in these trays?
- 2. NU found three conduit spans beyond limits and justifies these based on cable weights less than maximums. Smce this is ajustification beyond that obvious by visual inspection, should this justification be included in the A-46 Raceway Area Sununary?
i
- 3. We have sent copies ofICAVP field notes to help in locating the items that NU could not locate based on the DR description alone.
4.5 The ICAVP concern is the potential damage to the cable due to the bolt through the conduit, not the structural capability of the attachment.
- 5. Since this support fell outside the GIP inclusion rules and requires a justification, should this justification be included in the A-46 Raceway Area Summary?
6.1 Not clear why the seismic interaction is " limited...having no adverse affects?" Is this statement based on size, limited motion, ductihty, etc.?
6.2 ICAVP concern was not whether supports have the capability to tie floors together, but whether floor motion will overload non-ductile components such as expansion anchors. It was Page 2 of 3 M981022. doc
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.g CONFERENCE NOTES DATE: 10/22/98. Rev. 0 TIME: 2:00 n.m.
l not clear that maximum bolt slip would be within the capability of anchors. Note that motions l
-of two floors are involved.
l
. Discussion :
Agreed SL 4 for Items 1,2,& 5. Agreed Non-Discrepant for items 4.5,6.1, and 6.2. Item 3 was tabled until NU performs walkdown. NU will put this item on the agenda when ready.
\\
l
- 2. Topic: NNECo'sItems a) DR-0515: AFW Modification PDCR 2-123-82, Seismic II/I concerns (Farid Elsabee, Sing Chu, N) l (Bob Moyer, P) l NNECo has concluded that this item is Non-Discrepant. Parsons reduced this item to Significance
)
Level 4.
NNECo wishes to reiterate that the Non-Safety Related terminal boxes and conduits located in the Turbine Bldg. are adequately mounted for seismic class Il components. They were installed by i
following industry practice therefore is adequate for position retention. NEO 5.19 " Seismic Qualification Review" had not been in effect during the 1982 PDCR implementation. The guideline from MS-35 does not require documentation of positive condition. Upon receipt of DR-0515, NNECo l
l-performed a walkdown and verified the PDCR installation met Seismic II/I Licensing Bases.
(
Therefore, no corrective action is necessary and this issue remains Non-Discrepant.
Discussion :
Parsons agreed this is Non-Discrepant.
I i
b) DRs Listed Below; i
NNECo would like to discuss the following DR's. These DR's were initially responded to as Previously Discovered. NNECo would like to re-classify each as Confirmed Level 4 Discrepancies:
NNECo's Parson _s SL as NNECo's Original DR Number Current Originator /Respons_ble i
Issued Resoonse
Response
Engineer L
DR-0180 SL3 Previously Identified SL4 Rickert/ Jackson l
l DR-0193 SL3 Previously Identified SL4 Lee / Jackson l
DR-0194 SL3 Previously Identified SL4 Lee / Jackson DR-0730 SL3 Previously Identified SL4 Capiotis/Boyd DR-0533 SL3 Previously Identified SL4 Goodling/ Jackson Discussion:
j Parsons agreed to SL 4 for DRs-0180, -0193, -0194, and -0533. Significance Level for DR-0730 to i
be discussed with the NRC on 10/26/98.
Page 3 of 3 M981022. doc I
CONFERENCE NOTES DATE: 10/23/98. Rev. O IlME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
DRs, Parsons Items:
DR-0688, and DR-0642.
2.
DRs, NNECo Items:
DR-0139, DR-0255, DR-0775, DR-0083, DR-0066, DR-0113, DR-0167, DR-0174, and DR-0449.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Norbert Carte Joe Fougere Peter Koltay none Mike Akins Ron Smith Sing Chu Greg Tardif Eric Blocher Jon Winterhalter Farid Elsabee Wayne Dobson
- 1. Topic: Parsons' Items a) DR-0688 (John Archer) (Rescheduled from 10-22-98.)
Issue Related to Licensing Basis FSAR 7.5.1.4 (Post Accident Monitoring)
As part of NNECo's response to DR-0688, NNECo referenced the A-46 Program SEWS and the LT-5282 level transmitter's Bounding Spectrum. A review of the LT-5282 SEWS did not indicate a reference source or provide ajustification for the transmitter's correlation to this SEWS' seismic bounding spectrum.
- 1) What was the source for the bounding spectrum data for this Foxboro N-823 transmitter?
- 2) Was the transmitter's correlation to the bounding spectrum based on generic experience, EPRI NP-7149, or what?
- 3) Is it NNECo's intent to use the A-46 Program SEWS for the LT-5282 seismic qualification as it relates to R.G.1.97 requirements?
In addition, NNECo has implied for DR-0688 Item 3 that seismic qualification associated with R.G.
1.97 variable LIS-5489 would be integrated with the response to DR-0116. Currently, the NNECo response to DR-0116 states that the Specification SP-M2-EE-0012 was updated to Rev.1, which shows that seismic qualification was provided for CST level instrumentation. The response did not identify which seismic method was used to qualify LIS-5489, nor did it provide any qualification details. In contrast, NNECo response to RAI 552 stated that LIS -5489 was not safety related and did l
not address the seismic qualification issue.
What qualification document does NNECo claim validates the seismic qualification of LIS-5489?
l j
Discussion:
Parsons will table this DR as a SL 4.
l Page 1 of 4 M981023. doc l
w CONFERENCE NOTES DATE: 10/23/98. Rev. O TIME: 2:00 p.m.
b) DR-0642 (Michael Ober)
The ICAVP agrees with NNECo's resolution of the issues associated with DR Item 3, Jacket Cooling Water Expansion Tank Instmmentation, and considers this item as a closed as a SL4. These questions are concerned with items la/c and 2a/b/c of the DR.
- 1) This issue is concemed with item la/c of the DR. NNECo has indicated that MEPL MP2-CD-3595, downgrades the diesel fuel oil level instrumentation, however, one of the bases for the downgrade is NNECo spec 7604-MS-64. Per NNECo response to DR-0772, MS-64 is not used to classify instruments.
What is the basis that demonstrates Diesel FO Supply tank pressure boundary is maintained?
a.
- b. Why does NNECo not consider this to be SL3?
- 2) These issues are concemed with Item 2a dealing with the pressure boundary integrity of the air supply tank pressure boundary, NNECo has classified this portion of the DR as a significance level 4 discrepancy based on an a.
" initial investigation" that the non-Category 1(non-QA) pressure indicators PI-8833 and PI-8834, are " equal to" the Category 1(QA) Duraguage pressure indicators, which they replaced, in " fit, form, and function." Further, as part of NNECo's response to item 2a of this DR, NNECo indicated that part of the corrective action plan for CR M2-98-2319 was to prepare a
" Maintenance Support Engineering Evaluation (MSEE)" to document the changes on the EDG starting air pressure indicators PI-8833 & PI-8834.
Since the ICAVP issue is concerned with pressure boundary of the PI's and the replacement with non-QA indicators, how will does a MSEE resolve this issue?
- b. NNECo's response for pressure indicators associated with the EDG air supply tanks PI-8729, Pl-8730, PI-8833, and PI-8834 states that, "a walkdown of these pressure indicators determined that the installation consists of a very short horizontal pipe length to a socket welded elbow (approximately 5 inches total horizontal length) and a vertical length of approximately 17 inches, including the root valve." This is a total cantilevered (unsupported) length of approximately 22 inches with a 3-1/2 pound gauge at the end of the piping. The response went on to conclude that, "This installation is considered to be seismically rigid although a calculation was not located."
1.
Since there is no calculation, criteria, drawing, or other means that provides a basis to declare these oressure indicators and associated oiping as seismically adequate and there loss could deplete the EDG starting air supply, what is the basis to conclude this is not a concern?
- 2. Why does NNECo consider this as an SL4 and not a SL3 issue?
- 3) This issue is concerned with Item 2b/c. dealing with pressure boundary integrity of the starting air compressor pressure switches. The ICAVP agrees that an Item Equivalency Evaluation (IEE) determination is the correct action. However, NNECo has classified this portion of the DR as a significance level 4 discrepancy based on initial investigations without justification of pressure boundary integrity. NCR 295-350 acknowledges that the four pressure switches were replaced with "non-QA" compor ents. Those non-QA components are of a different manufacture than the OEM.
Since there is no calculation, criteria, drawing, or other means that provides a basis to declare these pressure indicators and associated pioinn as seismically adequate and there loss could Page 2 of 4 M981023. doc
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e CONFERENCE NOTES I
DATE: 10/23/98. Rev. O TIME: 2:00 p.m.
deplete the EDG starting air supply, why does NNECo consider this as a SL4 and not a SL3 issue?
Discussion:
This topic will be rescheduled at NNECo's request.
- 2. Topic: NNECo's Items:
a) DR-0139 (Norbert Carte, N) (Wayne Dobson, P)
NNECo believes that this DR is Non-Discrepant Documentation supporting our position is available.
05:- ':- :
Parsons agrees this DR is Non-Discrepant.
b) DR-0255 (George Howard, N) (Ken Gabel, P)
NNECo believes that this DR is Non-Discrepant. A single nut on each post develops the full capacity of the support.
Discussion:
This topic has been rescheduled to 10-27-98 at Parsons' request. See 10-27-98 notes.
c) DR-0775 (George Howard, N) (Dick Diederich, P)
NNECo believes that this DR is Non-Discrepant. The requirements ic seismic qualification for this item have been met.
Discussion:
This topic has been rescheduled to 10-27-98. See 10-27-98 notes.
l d) DR-0083 (Joe Fougere, N) (Ken Gabel, P)
NNECo believes that this DR is a Significance Level 4.
Discussion:
NNECo and Parsons agree this DR is a Confirmed SL 4. CR M2-98-2883 was written.
l Page 3 of 4 l
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CONFERENCE NOTES DATE: 10/23/98. Rev. O TIME: 2:00 p.m.
e) DR-0066 (Joe Fougere)
Recant previously identified and accept as SL 4 with corrective actions in progress and tracked by NRC commitments as noted in M2-IRF-02375.
Discussion:
NNECo and Parsons agree this DR is a Confirmed SL 4. Corrective actions as described above.'
f) DR-0113 (Joe Fougere)
Recant previously identified and accept as SL 3 with corrective actions complete (MOV program).
Discussion:
This was discussed on 10-27-98. This DR is a Confirmed SL 3, corrective actions are complete, CR M2-97-2667 was issued.
g) DR-0167 (Joe Fougere)
Recant previously identified and accept as SL 4 with corrective actions in progress and tracked by AR 97016619 and 97002778. Lack of documentation does not constitute an SL3 issue.
Discussion:
This was discussed on 10-27-98. This DR is a Confirmed SL 4, CR M2-97-0829 was issued.
h) DR-0174 (Joe Fougere)
Same as DR-0167 above.
Discussion:
This was discussed on 10-27-98. This DR is a Confirmed SL 4, CR M2-97-0829 was issued.
i) DR-0449 (Joe Fougere)
Recant previously identified and accept as SL 3 with corrective actions complete.
Discussion:
This was discussed on 10-27-98. This DR is a Confirmed SL 3, CR M2-97-0035 and DCN DM2-02-0213-98 were issued.
Page 4 of 4 M981023. doc
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CONFERENCE NOTES DATE: 10/26/98. Rev. O TIME: 2:00 p.m.
j l
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Parsons Items:
DR-0651, EBFS Charcoal Cooling Tie-In Dampers, DR-0773, DR-0464, and l
DR-0798.
LIST OF ATTENDEES:
j NNECo NRC NEAC Parsons Norbert Carte Tom Prvhoda John Nakosky none Mike Akins Ken Mavers Joe Fougere Greg Tardif Eric Blocher Trent Powers Ron Jackson Frank Cobb Jon Winterhalter l
Fred Mattioli Wayne Dobson Dan Wooddell Joe Groncki i
- 1. Topic: Parsons' Items l
a) DR-0651 (Frank Cobb)
This issue addresses NNECo's disposition to DR-0651.
l NNECo is designating this DR as Non-Discrepant. From a technical standpoint, Parsons agrees that, sufficient PM activities exist to have adequately tested the subject dampers and the issues associated 1
with the seismic qualification of the dampers are independently covered in DR-0585. Parsons does not agree with the Non-Discrepant classification supported by NNECo for the following reason.
The PDCR 2-13 83 is deficient in that it fails to include consideration for the post modification testing and seismic requirements of the new components. These were programmatic requirements at the time the modification was generated. Based on this Parsons believes this DR can be reduced and closed as l
a Significance Level 4.
l Discussion:
l l
NNECo accepts this DR as a Confirmed SL 4. The corrective actions have been completed.
i l
i b) EBFS Charcoal Cooling Tie-In Duct Damners IIV-8254 & HV-8078 (Dom Ramos)
According to the flow diagram 25203 26028, Sheet 5, the subject dampers are manually operated.
What p;ocedure describes the operation of these dampers?
l l
Discursion:
No precedure exists to operate these dampers. CR M2-98-1974 was issued to investigate this subject.
l c) DR-0773 (Ken Mayers) (Follow Up to 10/19/98 Teleconference)
During the 10/19/98 teleconference with NNECo and NRC, NNECo changed DR-0773 from previously identified to Confirmed SL 3. Only item 3 of the original DR was classified as presiously
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identified. Items 1,2 and 4 were categorized as Non-Discrepant and not discussed. The ICAVP concern is that this DR has a broader concern that just It'em 3.
Item I was never classified by NNECo in the DR response although from the answer, it would appear to be Non-Discrepant. Items 2 and 4 were indicated as Non-Discrepant. The concern of the DR was that issues identified in Items 1 to 4 (collectively) were examples (not necessary the extent of conditions) to demonstrate that the intent of 10 CRF50.34 (b) requiring the FSAR include a design basis which identifies specific functions is not satisfied.
ICAVP agrees that Item 2 of the DR is an enhancement and is considered Non-Discrepant. Rese questions are concerned with Items 1 and 4 of the DR that were not addressed on the 10/20/98 teleconference.
- 1. Item 1 of the DR tried to address that Tables 8.3-3A and B were not complete and had sequenced loads missing from the appropriate sequenced steps (i.e., boric acid pumps, boric acid valve, and TBCCW valve).
Why does NNECo consider Item 1 and their proposed solution as Non-Discrepant?
a.
- 2. With respect to DR Item 4, the FSAR figure number in the ICAVP DR and NNECo response is incorrect. It should be Figure 7.3-02 not 7.3-3. Since ICAVP DR item (4) is a Figure included in the FS AR and is the document that also describes load shedding, the ICAVP's DR pointed out that the document (i.e., the figure) is incorrect.
a.
Why does NNECo consider this FSAR Figure as Non-Discrepant?
- 3. The root issue associated with DR was that FSAR text, Figures, Tables and design documents are inconsistent and have varying degrees of errors associated with them.
Therefore considering these inconsiste' cies, what design basis documents are to be used to a.
n define the EDG sequencer so that the licensing basis inconsistencies can be resolved?
- b. Why are Items 1,3 and 4 not collectively considered a SL3?
Discussion:
Item 1:
Previously identified per NNECo. Parsons will review and raise again, if required.
Item 2:
his item is Non-Disc-at.
Item 3:
This item is a Confirmeu SL 3. CR M2-97-0680 will correct.
Item 4:
NNECo agreed this item is a Confirmed SL 3. CR M2-97-0680 will correct.
d) DR-0464 (Ken Mayers)
TS table 3.3-4 " Engineered Safety Feature Actuation System Instrumentation Trip Values" indicates the trip setpoint to be EOUAL to 4.75 psig (SIAS). SP 2403D Rev 5 sets the trip set point to 3.8 psig. NNECo confirms this condition as a SL4 and justifies it by providing documentation demonstrating that NNECo's proposed TS revision date December 17,1981 identified the setpoint as LESS THAN OR EQUAL to 4.75 psig.
a.
While the sign convention does appear to be an error that was propagated since 1981, the plant documentation and surveillance was still being performed in accordance with the TS of D no ? nf 4 M)81026 doc
m CONFERENCE NOTES lt-DATE: 10/26/98. Rev. 0
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TIME: 2:00 p.m.
i i
record. Surveillance against the TS of record placed the plant outside ofit design basis during this period. Why does NNECo believe that this a SL4 and not a SL3?
Discussion:
Parsons will close this DR as a Confirmed SL 4.
l 1
e) DR-0798 TM/LP Trip Setpoint Uncertainty (John Strange, Rich Glasiano) l Issue 1: TM/LP Pressure Uncertainty DR Statement:
l The accident analyses use a TM/LP uncertainty value of 22 psig. Uncertainty calculation PA-XX-
[
XXX-0573GE Rev.2 shows the uncertainty for RPS inputs to be +23.6 psig. Therefore, it is possible for the plant to trip at a lower pressure than is calculated and assumed by the accident analysis.
NU Response:
As shown in Table 14.0.7-3 of the Millstone Unit 2 FSAR, the accident analyses use TM/LP uncertainty values of +14/-24 psi (-5 psi Bias and
- 19 psi Uncertainty).
Parsons Comment:
The accident analyses use a TM/LP uncertainty value of +22 psi. See PORV/PRV Inadvertent j
Opening analysis, for example.
NU Response:
l l
Uncertainty calculation PA XX-XXX-0573GE, Rev. 3 shows the uncertainties to be +27.2/-20.5 psi.
Please note that PA XX-XXX-0573GE, Rev. 2 as referenced in M2-DRT-00798 has been resised to Rev. 3. Since TM/LP is used to protect DNB, the use oflower setpoint in safety analyses is conservative.
Parsons Comment:
Concur.
NU Response:
'Rerefore, the use of-24 psi in safety analyses is more conservative than using -20.5 psi.
Parsons Comment:
The positive uncertainty value applies, not the negative uncertainty value. The positive uncertainty value applies when the installed setpoint must be greater than the analytical limit.
Setpoint must be 2 Analytical Limit + positive uncertainty.
Two cases need to be considered, the TM/LP floor pressure setpoint and the variable pressure setpoint.
TM/LP floor setooint Allowable Value 2 Analytical Limit + Allowance #1 Setpoint 2 Allowable Value + Allowance #2 1
l
' M981026. doc Page 3 of 5 l
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w CONFERENCE NOTES DATE: 10/26/98. Rev. O TIME: 2:00 p.m.
Calculation 92-030-1260E2, Rev. 02, dated 6/98, includes the setpoint, Allowable Value and i
Acceptance Criteria for the TM/LP Floc-RPS calculator (CPC). His calculation applied the harsh emironment uncertainty to the SBLOCA analytical limit of 1750 psia. This resulted in an allowable value of 21855 psia and a Trip Setpoint of 21865 psia. A calculation using the non-harsh emironment analytical limit (1822 psia) and associated uncertainties was not performed. Using the i
page 18 calculation for allowance #1 and neglecting the harsh emironment terms gives a TA(IF) value of 26.4 psia. Applying this number to the analytical limit gives an Allowable Value = 1828 psia
+ 26.4 psi = 1854.4 psia. Applying the 10 psi TA(2F) adjustment gives a setpoint of I864.4 psi.
Thus, the allowable value and trip setpoint shown in the calculation for the harsh emironment case also satisfy the non-harsh emironment case. Note, however, that the TM1LP floor and uncertainty values provided in the July 21,1998 Tech Spec Change Request (Limiting Safety System Settings Bases for TM/LP) appear inconsistent with the values determined by Calculation 92-030-1260E2, Rev.02.
Variable Pressure Trio Setnoint The accident analyses use the Tech Spec Curves adjusted by the +22 psi uncertainty for the variable pressure trip function. That is, the analytical limit +22 psi yields the Tech Spec calculated Pvar.
Since the actual uncertainty is +27.2 psi, the required trip setpoint is higher than specified in the Tech Specs.
==
Conclusion:==
The RPS Trip Setpoint is non-conservative. The discrepancy is Significance Level 3.
Issue 2: TM/L.P ASI Uncertainty DR Statement:
No calculation can be found which supports the ASI Uncertainty of 0.06. This infonnation was requested by RAI-0726. The RAI was closed on 11/26/97 with an explanation that the calculation could not be located in NDS.
NU Response: (key points)
The response to M2-RAI-00726 was incorrect. The following calculations support the use of ASI instrument uncertainty of 0.06. These calculations of ASI uncertainty support because the use of 0.06 is more conservative than the value calculated.
a) W2-517-30lRE (dated 3/82), Section 7.6 and Table 10 calculated an ASI uncertainty ofi 0.00711 ASI units.
b) W2-517-357RE (dated 4/83), Section 5.3 and Table 10 calculated an ASI uncertainty of 0.009 ASI units.
c) W2-517-352RE (dated 1/83) Summary (page 11) lists an ASI uncertainty of
- 0.009 ASI units.
Calculation 18767-ICE-3628 Rev. 01 was prepared to support EWR M2-97061 (which is not yet complete) has not been reviewed an approved by NU and is therefore not the calculation of record.
However, it is anticipated that it will become the calculation of record.
d) ABB Calculation 18767-ICE-3628, Rev. Ol(dated 10/97) determined an ASI uncertainty ofless than *0.06 for power levels greater than approximately 30% and increase to slightly over + 0.12 from approximately 30% to 10% (ASI uncertainty increases as power decreases).
The issue of a reference for the ASI uncertainty was identified via UIR 2811 and AR 97013973-01 has been generated to address it. NOTE: This calculation is not currently in NDS.
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DATE: 10/26/98. Rev. 0 TIME: 2:00 p.m Significance level criteria do not apply here as this is a not discrepant condition.
Parsons Comments:
A UIR applies. An Action Request was initiated. A new cale was generated. Parsons classifies this issue as PREVIOUSLY IDENTIFIED BY NNECo.
Discussion:
NNECo requested that this DR be rescheduled. This topic was discussed Il-2-98. See Notes for that date.
i l
l Page 5 of 5 M981026. doc
w CONFERENCE NOTES DATE: 10/27/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Parsons Items:
DR-0564, and DR-0116.
- 2. NNECo Items:
DR-0255, DR-0702, DR-0585, DR-0744, DR-0455, DR-0775, DR-0551, DR-0360, and DR-0712.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Kahin Anglin George Howard John Nakosky none Mike Akins Trent Powers Norbert Carte Ron Jackson Eric Blocher Jon Winterhalter Sing Chu Fred Mattioli Frank Cobb Dan Wooddell Bill Cushman Rod Peterson Wayne Dobson Peter Duff Tom Prvhoda Joe Groncki Joe Fougere Greg Tardif Ken Mavers
- 1. Topic: Parsons' ltems l
a) DR-0564 AFW/SG Instrument Tubing (Ken Gabel) (Continued from 10-22-98.)
Parsons agrees with NU's DR-0564 dispositions except as follows:
DR Issue items # 2b,3c,4 and 10: Closure of these items is acceptable as Confirmed Significance Level 4 conditions; NU dispositioned as Non-Discrepant.
DR Issue item # 8: NU's response to the LT-5272 Issue item 8 evaluated the existence of two 3-D clamps on the same tubing segment as acceptable based on ambient system conditions at the clamps physical location due to the distance of the installations from the process heat source. However, consideration was not given to the expansion effects (279 to 400 F) this tubing segment would be susceptible to under accident conditions. It is estimated that under accident conditions, axial expansion stress would exceed Code allowable by a factor of 3. He installation of two (2) 3-D i
supports on the same tubing segment requires corrective action, field modifications required.
Herefore, the LT-5272 issue remains open as a Significance Level 3 discrepancy pending further NU resolution.
Discussion:
NNECo agrees that 2b,3c,4,8, and 10 are Confirmed SL 4 discrepancies. Parsons will close. CR M2-98-2858 was issued.
b) DR-0116 (Dan Cardinale)
Re: NNECo response to DR 0116 issues:
Parsons agrees that items 3,6, and 7(a) can be closed as being Non-Discrepant:
Parsons agrees that items 1,2,4,5,9, and 10 can be closed as a Significance Level 4.
Parsons wishes to discuss the following items that NNECo considers SL 4.
l Page 1 of 5 M981027. doc
CONFERENCE NOTES DATE: 10/27/98, Rev. O TIME: 2:00 p.m.
i Item 7(b), Condensate Storage Tank level, Variable D-21, SQ question. Per NNECo response to DR-0688, CST level instrument seismic adequacy was to be addressed in this DR. NNECo's response referenced Rev i to SP-M2-EE-0012 but did not include or reference seismic qualification data with j
the package. How and in what DR will NNECo document the seismic adequacy of the CST level instruments?
Item 7(c) Condensate Storage Tank Level instmment redundancy question. NNECo addressed this item as SL 4 and states "a corrective action has been agreed upon" to resolve the item. Because this item is related to compliance to a licensing basis (RG 1.97 requires redundant analog level indication in the control room) why doesn't NNECo consider this item as SL3? Also, please proside the Corrective Action number.
Item 8, Pressurizer Level (Variable D-11)
NNECo considered this as SL 4. NNECo performed plant modification DM2-S-0273-95 to conform the as-built plant to the licensing basis requirements of RG 1.97 by providing vital 1E power to the level recorder in place of non-vital power. Why does NNECo consider this action SL 4 rather than SL 3?
Discussion:
.. Item 7(b) NNECo will supply seismic qualification test report for LT-5282. After receipt and resiew of this report, Parsons will consider Item 7(b) closed.
2 Item 7(c) a) Because the absence of redundancy (for variable D-21) was contained in a footnote to NNECo's 8/7/86 conformance matrix submittal, NNECo considers that this item is below SL3 significance. NNECo stated that lack of redundancy and lack of Category I design characteristics for the LIS was docketed in a 1992 submittal to the commission which has not be responded to by SER.
b) NNECo transmitted a copy of CR M2-98-1550 with the DR-0116 response that acknowledges the condition reponed by Parsons, but the CR does not project a corrective action plan to resolve the issue.
Parsons requested a copy of the CA mentioned in NNECo's response to DR-0116.
c) Parsons considers the lack of two Category I analog readout of CST level in the control room to be a Level 3 discrepancy. NNECo states that discussion is being held with NRC on CST level instmmentation.
The discussion will determine whether the present non-redundant instrument design is considered satisfactory, or whether an additional channel of Category 1 CST level instrumentation is judged to be necessary to meet RG 1.97 requirements. Accordingly, item 7(c) of DR-0116 is placed en hold for resolution between NRC and NNECo.
(During the 10-28-98 teleconference, the NRC said that it was their view that NNECc's LB does not allow them to deviate from the redundancy requirement. NNECo will formally request a deviation from redundancy in this matter from the NRC. The NRC agrees tha' the corrective action is correct but this is a SL 3 discrepancy.)
- 3. Item 8.
NNECo claims that the lack of 1E power to the Pressurizer level recorder (variable D-11) was pre-discovered, and corrected by PDCR 2-25-86. NNECo agreed that specification SP-M2-EE-0012 was not changed to reflect the field change until issuance of Change 1 to Revision 2 of SP-M2-EE-0012 in May 1998. Since the correction occurred after CMP complete date, Parsons considers this was a DR of SL 4 that has been corrected, and thus can be closed out.
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CONFERENCE NOTES DATE: 10/27/98 Rev. O TIME: 2:00 p.m.
- 2. Topic: NNECo's items a) DR-0255 (George Howard, N) (Ken Gabel, P)
NNECo believes that this DR is Non-Discrepant. A single nut on each post develops the full capacity of the support.
Discussion:
I NNECo will accept this as a SL 4. CR M2-98-2881 was issued.
I l
b) DR-0702 (Norbert Carte, N) Ken Mayers, P)
NNECo believes this DR is a SL 4. (Parsons issued as a SL 3.)
The first issue is non-discrepant. NNECo maintains its position that Parsons correctly cites that l
FSAR Section 7.3.1.2.6 as stating that the ESFAS and component parts conform to the requirements ofIEEE 279-1971. However, the AFW Terry Turbine and associated controls are not part of l
ESFAS. Therefore IEEE 279-1971 does not apply to the AFW Terry Turbine.
The second issue is a Confirmed Significance Level 4. NNECo maintains that LB/DB was not violated.
l l
Discussion:
Rescheduled to 11-2-98 at Parsons request.
c) DR-0585 (Tom Pryhoda, N) (Roger Mauchline, P)
NNECo believes this DR is not discrepant. (Parsons issued as a SL 3.) NNECo maintains the original response provides thejustification regarding the seismic adequacy of the dampers and thereby concludes that this DR is non-discrepant. (NNECo requests that Parsons focus on the specific "Conunent on NNECo Response" discussion topic that demonstrates how the LB/DB was violated.)
u..w......
This topic was rescheduled to 10-29-98.
4 l
d) DR-0744 (Tom Pryhoda, N) (Frank Cobb, P)
NNECo believes this DR is not discrepant. (Parsons issued as a SL 3.) MP2 was not originally licensed to RG 1.52. Portions of the RG that has been committed to is documented in the TRM.
l (NNECo requests that Parsons focus on the specific " Comment on NNECo Response" discussion topic that demonstrates how the LB/DB was violated.)
Discussion:
NNECo will table for further investigation and will raise the topic later.
Page 3 of 5 M981027. doc l
i CONFERENCE NOTES DATE: 10/27/98. Rev. O TIME: 2:00 p.m.
e) DR-0255 (George Howard, N) (Ken Gabel, P)
NNECo believes this DR is not discrepant. (Parsons issued as a SL 3.) NNECo maintains a single nut develops the full capacity of the support. (NNECo requests that Parsons focus on the specific
" Comment on NNECo Response" discussion topic that demonstrates how the LB/DB was siolated.)
Discussion:
This was covered in 2.a. above.
f) DR-0455 (Sing Chu, N) (Dick Boyd, P)
NNECo believes this DR is not discrepant. (Parsons issued as a SL 3.) NNECo, upon receipt of Parsons response to the original IRF, investigated the follow-up comments. That investigation concluded that these valves were part of the SSEL and were screened out since they are rugged components. This DR is considered Non-Discrepant. (NNECo requests that Parsons focus on the specific " Comment on NNECo Response" discussion topic that demonstrates how the LB/DB was violated.)
Discussion:
Parsons agrees that this DR is Non-Discrepant and will close.
g) DR-0775 (George Howard, N) (Dick Diederich, P)
NNECo has changed its view on this DR. NNECo believes this DR is a Significance Level 3 DR.
The FSAR needs to be corrected to state 5% damping is acceptable.
Discussion:
This topic was rescheduled to 10-28-98.
h) DR-0551 (Norbert Carte, N) (Ken Mayers, P)
NNECo has changed its view on this DR. NNECo believes this DR is Non-Discrepant. CR M2 0855 was issued for this DR. Upon investigating this CR, a walkdown was performed and it has been confirmed that the surge suppressors are installed.
Discussion:
Parsons agrees that this DR is Non-Discrepant and will close.
i) DR-0360 (Bill Cushman, N) (Ken Mayers, P) l NNECo has changed its view on this DR. NNECo believes this DR is a Significance Level 3 DR.
l Color bands will be installed as described in the FSAR.
Discussion:
Items 1-4:
Parsons agrees these items are Non-Discrepant items 5-10:
All SL 3.
Items 9 and 10:
Note that these items involve more than just color taping problems.
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i DATE: 10/27/98. Rev. 0 TIME: 2:00 p.m.
.j) DR-0712 (Bill Cushman, N) (John Archer, P)
)
Item 1.A.2: Confirmed SL3. Field Modifications Required.
Item 1.B: Confirmed SL3. Field Modifications Required.
Item 2:
Confirmed SL4. Revise PDCR to reference correct Foxboro Report.
Item 4:
Confirmed SL3. Field Modifications Required Discussion:
Parsons agrees with the above classifications. CR M2-98-2759 was issued.
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i Page 5 of 5 M981027. doc
CONFERENCE NOTES l
DATE: 10/28/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
I
- 1. Parsons Items:
DR-0761.
)
- 2. NNECo Items:
l DR-0775, DR-0620, DR-0279, DR-0585, DR-0046, DR-0048, and DR-0679.
l
- 3. NRC Items:
I i
j DR-0357, DR-0290, and DR-0116, Item 7(c).
LIST OF ATTENDEES:
l NNECo NRC NEAC Parsons Prasad Bandaru Greg Tardif John Nakosky none Mike Akins Ken Mayers Bob Carritte Eric Blocher Bob Moyer Norbert Carte Dick Boyd Trent Powers l
Joe Fougere Dan Cardinale Dom Ramos George Howard Dan Curry Jon Winterhalter Fred Mattioli Wayne Dobson Dan Wooddell Tom Prvhoda Joe Groncki i
- 1. Topic: Parsons' Items j
j a) DR-0761 EBFS Design, Operation, and Testing. (Dan Cardinale)
'(Item numbers refer to DR-0761 item numbers).
Item 1. Use of non-qualified devices in a IE control circuit.
NNECo considers non-discrepant. Parsons considers SL 3.
f l
A. Parsons requests explanation of why the use of non qualified power supplies (X-134, X-135),
i circuits, and devices (PT-8060C/J and PC-8060C/J) for protecting the integrity of an l
Engineered Safety Feature (EBFR) as defmed in FS AR I. A & l.2.7 is not a violation of 10CFR50 Apo B Introduction. or NUOAP Manual. Anoendix A. Item m?
B. With regards to NNECo statement that "no devices are required to shut down the fan to protect building seals," Parsons requests an understanding of why PDCR 2-32-84 was i
j implemented to install an overpressure trip (PC-8060C and J) of fan F-23. (The stated purpose of the PDCR was to prevent damage to the building seals caused by overpressure.)
Note. Parsons and NNECo have previously considered in DR-0426 and DR-0027, and left unresolved, the issue of equivalency of the tested 1/40 scale model (of EBFR boundary) to the as-built condition of the EBFR. Parson's basis was the model results do not approximate actual pump down test results, and that model testing consicerd only negative pressures and not positive pressures. Parsons' position is that if positive pressures can impact the integrity of the Enclosure Building, or if positive pressures make it unlikely to be able to satisfy the Technical Specification pumpdown requirements, any device needed to protect against overpressure of the Enclosure Building should be safety related.
Item 2 "No basis for setpoints of 0.4" wg, no cales, and no periodic testing of high dP trip setpoint" Page 1 of 4 M981028. doc
CONFERENCE NOTES DATE: 10/28/98, Rev. O TIME: 2:00 p.m.
Parsons concurs that this item can be closed as a SL 4 with CR M2-98-2944 assigned to track this work.
Item 3. "No calculations or testing has been done to show that EBFS pumpdown per Tech Spec can be accomplished from a positive DP up to 0.4" wg" NNECo cons;ders this item as SL 4 and has assigned CR M2-98-1275 to track the work. Parsons considers this as SL 3.
Parsons requests explanation of why NNECo considers that demonstrating the ability to pump down the Enclosure Building as specified in Technical Specifications 4.6.5.1 starting from the most conservative operating condition (positive EBFR pressure of 0.4" wg) is not a licensing basis requirement as defined in 10CFR50 App B. Part XI. Also, why does NNECo consider that the lack of testing is not in conflict with NUOAP Section i 1.0. Test Control. and 11.1 General Ecquirements?
Item 4 Use of unqualified devices in IE circuits.
NNECo considers this non-discrepant. Parsons would like to understand why NNECo considers the use of the non-qualified non-electrically isolated temperature switch in a 1E circuit is not a violation ofisolation requirements in the licensing basis (i.e., IEEE-279. FS AR 7.3 1. & Rec.
Guide 1.75)?
Item 5 No basis, no setpoint calculation, and no testing for low temperature fan trip set at 40F.
Parsons concurs that this item can be closed as non-discrepant w a Licensing Basis or Design f
Basis issue.
Item 6. Lack ofintegrateo system surveillance and testing.
NNECo considers as non-discrepant. Parsons considers this item as discrepam of SL 3, but redundant to items 2 & 3 above. As such it should be closed as a separate itera and tracked with Item 3.
Discussion:
This topic was rescheduled to 10-29-98.
- 2. Topic: NNECo's Items a) DR-0775 (George Howard, N) (Dick Diederich, P) (Rescheduled frorn 10-27-98)
NNECo has changed its view on this DR. NNECo believes this DR is a Significance Level 3 DR.
The FSAR needs to be corrected to state 5% damping is acceptable.
Discussion:
l Parsons will review and close if satisfied or raise again if required.
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b) DR-0620 (Tom Pryhoda, N) (Dom Ramos, P)
NNECo believes this DR is Non-Discrepant.
NNECo maintains the responses provided justifies that the response of the containment isolation valves to a CIAS is sufficient protection for the EBFS ductwork when venting in accordance with OP 2314B.
Discussion:
- NNECo will place in follow up status. Parsons believes two questions need to be answered. Will the humidity limit be exceeded? Will ductwork design pressure be exceeded?
c) DR-0279 (Norbert Carte, N) (Ken Mayers, P)
The trip setpoint as provided in TS is supposed to consider uncertainty and additional terms, and therefore Calculation ESAS-01510D2 did not need to consider uncertainty. The SP 2403B was determined to be IAW the TS, and activities to address whether the TS is correct are addressed in l
UlR 1737.
Discussion:
1 Parsons agrees that this DR is Non-Discrepant.
d) DR-0585 (Tom Pryhoda, N) (Roger Mauchline, P) (Rescheduled from 10-27-98)
NNECo believes this DR is not discrepant. (Parsons issued as a SL 3.) NNECo maintains the original response provides the justification regarding the seismic adequacy of the dampers and thereby concludes that this DR is non-discrepant. (NNECo requests that Parsons focus on the specific
" Comment on NNECo Response" discussion topic that demonstrates how the LB/DB was siolated.)
n:...- :-.
l This item was rescheduled to 10-29-98.
(
e) DR-0046 (Bob Weth, N) (Joe Gronckt, P)
NNECo believes this DR is a Confirmed Significant Level 4. Corrective actions are complete.
Atta^ments to the calculation address the issues described in the Parsons follow-up response.
Discussion:
Parsons has closed this DR as a SL 4.
f) DR-0048 (Bob Weth, N) (Joe Groncki, P)
NNECo believes this DR is a Confirmed Significant Level 4. Corrective actions are complete.
Calculation for the supports have been updated to reflect new support loads.
Discussion :
i Parsons has closed this DR as a SL 4.
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g) DR-0679 (George Howard, N) (Wayne Dobson, P)
NNECo believes this DR is a Confirmed SL 4. During the 10-1-98 teleconference, this Item was tabled in order for NNECo to review the VTM regarding minimum recirculation requirements for the pump. Memo SE-93-633 states that the flow rates presented are recommended and not required flow rates. This fact is substantiated by Reference 2 of Memo SE-93-633. Reference 2 (Memo 93-626) represents notes of a teleconference between NU and the pump vendor Ingersol Rand. The purpose of the teleconference was to discuss the Short Period and Continuous operation min. flow rates. The vendor stated: " this information was not previously sent to NU as a recommendation or as a change to IR vendor technical manuals. The information is a recommendation, not a requirement."
Discussion:
Parsons agrees that this DR is a Confirmed SL 4. Corrective action is complete.
- 3. NRC Items:
a) DR-0357, DR-0290 The NRC position regarding conduit / raceway labeling.
Discussion:
The NRC believes that NNECo is in compliance with its LB. NNECo is not required to have labels on raceway.
j b) DR-0116, Item 7(c) The NRC position regarding absence of redundancy (for variable D-21).
Discussion:
The NRC said that it was their view that NNECo's LB does not allow them to deviate from the redundancy requirement. NNECo will formally request a deviation from redundancy in this matter i
from the NRC. The NRC agrees that the course of action is correct but this is a SL 3 discrepancy.
Page 4 of 4 M981028. doc
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CONFERENCE NOTES DATE: 10/29/98. Rev. O TIME: 2:00 n.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
Parsons Items:
DR-0508, DR-0761, and DR-0293.
- 2., NNECo Items:
DR-0585, DR-0108, DR-0190, DR-0237, DR-0179, and DR-0177.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Norbert Carte Howard Sharmo John Nakosky none Mike Akins Roger Mauchline Farid Elsabee Greg Tardif Dan Cardmale Trent Powers Joe Fougere Dan Curry Dom Ramos Ron Jackson Wayne Dobson Victor Willems Fred Mattioli Joe Groncki Jon Winterhalter Tom Prvhoda Ken Mayers
- 1. Topic: Parsons' Items a) DR-0508 (V. Willems, K. Mayers)
Parsons still considers this as a SL3.
LB/DP: RGl.11, FSAR 5.2.8.2.1 - Since the M2 design is an exception to RGl.11, the ICAVP concem is that containment integrity is maintained and wheie the potential exists for leakage, this leakage and leakage path have been adequately considered.
Backaround MECo noted in their response that 8/13/98 & 8/18/98 teleconferences with the ICAVP, failure of the instrument line was the topic of the concem. NNECo's response provided sufficient justification to demonstrate that the failure of the instrument sensing line out side of conta' ment is not considered m
licensing basis at M2 The ICAVP accepts this position. From the discussion during the reference teleconferences and NNECo response, there does not appear to be a calculation to support the FSAR statement in section 5.2.8.2.1 "The instrument lines are sized or orificed on the inside of the containment such that the response time of the transmitters remains within an acceptable level while in the unlikely event ofinstrument line or transmitter housing failure, the leakage is reduced to the minimum extent practical."
The DR focused on two issues both which are concemed with loss of pressure boundary associated with the instrument lines and pressure transmitter housing; and ultimately, with the post accident leakage and the effect on 10CFR100. While the referenced teleconference and subsequent response dealt with the instrument line boundary, the transmitter pressure housing has not been addressed.
- 1. SECY/-77-439 defines active components as components requiring mechanical movement to perform their functions. A pressure transmitter which requires bellows movement to develop an output signal, meets the definition of an active component. Containment integrity is typically accomplished using two series components / devices. In this case, the instrument diaphragm is the only boundary used to satisfy containment integrity. FSAR section 5.2.8.2.1 states "All mstrumentation provided is designed as a pressure containing device, wlereby rupture of the Page 1 of 4 M981029. doc t.
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sensing bellows will not release radioactivity to the emironment but will be contained within the housing of the instrument itself."
Since all the containment pressure transmitters have one side of the transmitter diaphragm a.
vented to the auxiliary building, should the diaphragm rupture how is the referenced FSAR statement accomplished?
- b. How is the orifice size and potential leakage into the auxiliary building addressed and considered in your evaluated 10CFR100 release values?
Discussion:
NNECo will followup. From the vendor information Parsons has, it is not clear that two carriers exist. NNECo will contact Foxboro to clarify. CR M2-98-1737 investigated this same question on 6-16-98.
b) DR-0761 EBFS Design, Operation, and Testing. (Dan Cardinale) (Rescheduled from 10-28-98)
((This topic has been rescheduled to Il-5-98 at NNECo's request.))
c) DR-0293 (Dan Cardinale) 1.
Parsons concurs that problems with label marking on control room instruments for RG 1.97 as described in DR-0293 were pre-discovered by NNECo UIR. DCN DM2-00-0532-98 issued 6/15/98 detailed the changes necessary to bring control room labels into RG 1.97 compliance.
2.
Parsons concurs that NNECo has identified the changes required in SP-EE-261 to matcii the new RG 1.97 marking scheme and has included those changes in the same DCN.
Parsons notes that additional labeling conflicts noted in DR-0293 were not addressed by DCN DM2-00-0532-98. Specifically, specialty labels such as HSD and FIRE are provided with the same colors as Labels for RPS Channel D instruments. Specification SP-EE-261-2 does not provide for specialty labels, and does not permit using the same colors as are used for RPS Channel D instruments. Why does NNECo consider that using RPS Channe D label colors for 8
non RPS Channel D specialty functions does not represent a conflict with SP-EE-261, Rev 2?
Also, the table of acronyms and abbreviations in SP-EE-261, Rev 2 does not include all acronyms and abbreviations. Why does NNECo consider that these conflicts do not represent a discrepancy of SL 47 Discussion:
NNECo agrees this is a Confirmed SL 4. CR M2-98-2901 will track the specification reconciliation.
- 2. Topic: NNECo's Items i
a) DR-0585 (Tom Pryboda, N) (Roger Mauchline, P) (Rescheduled from 10-28-98)
NNECo believes this DR is Not Discrepant. (Parsons issued as a SL 3.) NNECo maintains the original response provides thejustification regarding the seismic adequacy of the dampers and thereby concludes that this DR is nondscrepant. (NNECo requests that Parsons focus on the specific
" Comment on NNECo Response" discussion topic that demonstrates how the LB/DB was siolated.)
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Discussion:
NNECo agrees that this is a SL 4 and will track actions via CR M2-98-2727.
b) DR-0108 (Sing Chu, N) (Gary Jackson, P)
NNECo believes this DR is a Confirmed Significance Level 4.
NNECo believes item I is a SL 4. Tech evaluation has been issued to cover welded attachments.
NNECo believes that item 2 is non-discrepant. The subject valves 2-CN-26 and 2-CN-27B are manually operated valves which are inherently rugged. FSAR 13.13.3 pertains to active vah:es.
NNECo believes item 3 is a SL 4. Supports have been shown to meet code allowables therefore LB is j
met.
Discussion:
l This topic rescheduled to Il-2-98.
c) DR-0190 (Bob Weth, N) (Gary Jackson, P)
NNECo believes this DR is a Confirmed Significance Level 4.
Item 1: Both NNECo and Parsons both agree this is a SL 4 item.
Item 2: Both NNECo and Parsons both agree this is previously discovered.
Item 3: Both NNECo and Parsons both agree this is non-discrepant.
Item 4: NNECo concurs with Parsons that this is a SL 4 item.
Discussion:
Parsons will close as a SL 4. CR M2-983245 was issued.
d) DR-0237 (Bob Weth, N) (Bob Moyer, P)
NNECo believes this DR is a Confirmed Significance Level 4.
l NNECo has issued calculation No. 98-ENG-02703-C2 titled " Containment Liner Penetrations -
Safety injection and Reactor Coolant Shutdown" which qualifies the existing penetration sleeve embedded in the containment building wall. As such, there is no affect on the LB/DB and therefore NNECo considers this SL 4.
Discussion:
NNECo will fo!!owup. Calculation will be sent to Parsons. If Parsons agrees DR will be closed. If there are questions, Parsons will raise topic again.
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i e) DR-0179 (Sing Chu, N) (Gary Jackson, P)
NNECo believes this DR is a Confirmed Significance Level 4. A CR (M2-98-3242) has been issued for this DR.
j Discussion:
Parsons will close this as a Confirmed SL 4. CR M2-98-3242.
l f) DR-0177 (Sing Chu, N) (Gary Jackson, P)
NNECo believes this DR is a Confirmed Significance Level 4.
Items 1,3, and 4 represent issues which Parsons considers to be Level 4 discrepancies. NNECo is willing to accept Level 4 discrepancies (CR number to be provided during Conference Call).
NNECo believes that item 2 is the same issue discussed in DR-0251. As noted in response to DR-0251, NNECo has accepted a Level 3 discrepancy to clarify the FSAR to state that absolute sum of modes is not used for piping or equipment seismic analysis. This clarification also includes closely spaced modes. NNECo believes item 2 should be closed to DR-0251.
Discussion:
This topic rescheduled to 112-98.
1 Page 4 of 4 M981029.e
w CONFERENCE NOTES DATE: 10/30/98. Rev. O TIME: 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
- 1. Parsons Items:
DR-0642 and DR-0564.
- 2. NNECo Items:
DR-0467, DR-0718, and DR-0599.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Rick Bonner Fred Mattioli John Nakosky none Mike Akins Trent Powers Bill Cushman Greg Tardif Wayne Dobson Joe Fougere Ken Mavers
- 1. Topic: Parsons' Items a) DR-0642 (Michael Ober)
The ICAVP agrees with NNECo's resolution of the issues associated with DR Item 3, Jacket Cooling Water Expansion Tank Instrumentation, and considers this item as a closed as a SL4. These questions are concemed with Items la/c and 2a/b/c of the DR.
- 1) 'Ihis issue is concerned with Item la/c of the DR. NNECo has indicated that MEPL MP2-CD-3595, downgrades the diesel fuel oil level instrumentation, however, one of the bases for the downgrade is NNECo spec 7604-MS-64. Per NNECo response to DR-0772, MS-64 is not used to classify instruments.
What is the basis that demonstrates Diesel FO Supply tank pressure boundary is maintained?
a.
- b. Why does NNECo not consider this to be SL37
- 2) These issues are concerned with Item 2a dealing with the pressure boundary imegrity of the air supply tank pressure boundary.
NNECo has classified this portion of the DR as a significance level 4 discrepancy based on an a.
" initial investigation" that the non-Category 1(non-QA) pressure indicators PI-8833 and PI-8834, are " equal to" the Category 1(QA) Duragauge pressure indicators, which they replaced, in " fit, form, and function." Further, as part of NNECo's response to item 2a of tids DR, NNECo indicated that part of the corrective action plan for CR M2-98-2319 was to prepare a
" Maintenance Support Engineering Evaluation (MSEE)" to document the changes on the EDG startmg air pressure indicators PI-8833 & PI-8834.
Since the ICAVP issue is concemed with pressure boundary of the PI's and the replacement with non-QA indicators, how will does a MSEE resolve this issue?
- b. NNECo's response for pressure indicators associated with the EDG air supply tanks PI-8729, PI-8730, PI-8833, and PI-8834 states that, "a walkdown of these pressure indicators determined that the installation consists of a very short horizontal pipe length to a socket welded elbow (approximately 5 inches total horizontal length) and a vertical length of approximately 17 inches, including the root valve " Tnis is a total cantilevere/, (unsuppomi) length of approximately 22 inches with a 3-1/2 pound gauge at the end of the piping The l
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l-response went'on to conclude that, "This installation is considered to be seismically rigid l
although a calculation was not located."
- 1. Since there is no calculation, criteria, drawing, or other means that provides a basis to f
declare these cressure indicators and asseiet~i nining as seismically adequate and there loss could deplete the EDG starting air supply, what is the basis to conclude this is not a i
concern?
- 2. Why does NNECo consider this as an SL4 and not a SL3 issue?
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- 3) This issue is concerned with Item 2b/c. dealing with pressure boundary integrity of the starting air compressor pressure switches. The ICAVP agrees that an Item Equivalency Evaluation (IEE) determination is the correct action. However, NNECo has classified this portion of the DR as a significance level 4 discrepancy based on initial investigations without justification of pressure boundary integrity. NCR 295-350 acknowledges that the four pressure switches were replaced with "non-QA" components. Those non-QA components are of a different manufacture than the OEM.
Since there is no calculation, criteria, drawing, or other means that provides a basis to declare these pressure inAra*nrs and associated pioma as seismically adequate and there loss could deplete the EDG startmg air supply, why does NNECo consider this as a SL4 and not a SL3 i
issue?
Discussion:
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This topic was rescheduled to 11/2/98.
l b) DR-0564 AFW/SG Instrument Tubing (Gary Jackson) Follow-on from 10/22/98 Parsons agrees with NUs DR-0564 dispositions except as follows:
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DR Issue Items # 2b,3c,4 and 10: NU dispositioned as Non-Discrepant. Closure of these items is l
acceptable as Confirmed Significance Level 4 conditions-1 DR Issue Item # 8: NUs response to the LT-5272 Issue Item 8 evaluated the existence of two 3-D clamps on the same tubing segment as acceptable based on ambient system conditions at the i
clamps physical location due to the distance of the installations from the process heat source.
i However, consideration was not given to the expansion effects ( 279 to 400 F ) this tubing segment would be susceptible to under accident conditions. It is estimated that under accident conditions, axial expansion stress would exceed Code allowable by a factor of 3. The installation of two (2) 3-D supports on the same tubing segment requires corrective action, field modifications required. Therefore, the LT-5272 issue remams open as a Significance Level 3 discrepancy pendmg further NU resolution.
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Discussion:
This topic was covered 10-27-98.
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- 2. Topic: NNECo's Itcins a) DR-0467 and DR-0718 (Bill Cushman, N) (Michael Ober/ Ken Mayers, P)
NNECo believes this DR is Non-Discrepant.
NNECo wi?l provide justification regarding how the FSAR is complied with respect to amber light indication.
Discussion:
'Ihis topic was tabled for the NRC to interpret FSAR 7.6.2.2.2.
b) DR-0599 (Ron Jackson, N) (Dick Cronk, P) i NNECo believes this DR is a Confirmed Level 4 NNECo will provide justification for the assumption and methodology used in the calculation PA91-004-0290.
Discussion:
This topic was postponed to Il-2-98.
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