ML20198G534
| ML20198G534 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/17/1998 |
| From: | Curry D AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUM2-PPNR-2217, NUDOCS 9812290094 | |
| Download: ML20198G534 (32) | |
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PARSONS Daniel L Curry, Vice President. Nuclear Servces Parsoqs Energy *& Chomicals Group inc.
2675 Morgantodh Road
- Reading. Pennsylvania 19607 * (610) 855-2366 + Fax: (610) 855-2602 December 17,1998 Docket No. 50-336 j
Parsons NUM2-PPNR-2217-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 (ICAVP)
Gentlemen:
This letter transmits summaries of telephone conferences between Parsons Power Group Inc., the U. S.
Nuclear Regulatory Commission, NNECo and NEAC on December 1, December 2, December 3 and December 4,1998.
Please call me at (610) 855-2366 if you have any questions.
Sincerely, g
Daniel L. Curry Parsons ICAVP Project Director DLC:djv Attachments cc:
E. Imbro (2) - USNRC J. Fougere - NNECo Rep. Terry Concannon - NEAC R. Laudenat - NNECo i
Project Files ODl f l r
9812290094 981217 O PDR ADOCK 05000336i P
PDRyj PPNR2217. doc
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CONFERENCE NOTES I
l DATE: 1?!!/98. Rev. O i
TIME: 10:00 a.m. and 2:00 p.m.
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PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
10:00 a.m.: Parsons Items:
DR-0814, DR-0640, DR-0588, DR-0319, DR-0730, DR-0733, and DR-0752.
2.
10:00 a.m.: NNECo Items:
DR-00724, DR-0734, DR-0620, DR-0744, and DR-0788.
l 3.
2:00 p.m.: Parsons Items:
DR-0797.
l 4.
NNECo Items:
DR-0403 and DR-0714.
. LIST OF ATTENDEES:
l NNECo NRC NEAC Parsons Bill Cushman l Tom Pryhoda John Nakoski none John Archer Roger Hall Prasad Bandaru Marcel Ranieri Eric Blocher Dave Lengel James Diluca Chris Scully Dick Boyd Trent Powers Mike Ehredt Dick Seder Dick Cronk Dom Ramos Joe Fougere Howard Shamro Dick Diederich Jon Winterhalter George Howard Greg Tardif Rich Glaviano Dan Wooddell Ron Jackson Harold Thompson Fred Mattioli Jim Wheeler Gil Olsen Topics for 10:00 am Teleconference
- 1. Top lc: Parsons' Items a) DR-b314 DBA Analysis (Rich Glaviano)
Item 3 - EBFS Bypass Flow (Dave Lengel)
Background:
The EBFS Bypass flow rate is used as an input to the Control Room and Offsite Dose Analysis.
Only bypass flow from sources (penetrations) that directly by-pass the secondary containment need be considered. The applicable penetrations are:
Svstem 14 Normal Sump 67 Refueling Water Purification 6R Refueling Water Purification The value used for the Control Room Dose analysis (References 36 and 37) is 6.44E-6 SCFM.
Per TS 3.6.1.2.c (Reference 1) the maximum allowable leakage from these 3 penetrations is 0.017
+
La, which corresponds to approximately 0.5 scfm.
l Page 1 of 8 M981201. doc I
y CONFERENCE NOTES DATE: 12/1/98, Rev. O TIME: 10:00 a.m. and 1:00 n.m.
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l NU Response:
l The value used for the EBFS Bypass Flow is not consistent between analyses for offsite dose (acference 35) and control room dose (References 36 and 37). This is the licensing basis of l
Millstone Unit 2 as documented in a memo from M.D. Ehredt (Unit 2 Regulatory Compliance) to R.J. Schmidt, dated 8/6/98, titled ' Current Licensing Basis For Enclosure Building Leakage to be Assumed for Control Room Dose', memo number RAC-98-249. The conclusion of this memo is based upon the AEC requirements set in May 10,1974 and correspondence leading up to the i
SER, the control room dose assumptions use a negligible bypass flow while the bypass flow of l
1.7% of La was mandated in evaluating 10CFR100 doses. This is not a discrepant condition.
l Parsons Comments:
NU letter (RAC-98-249) is referenced but not provided with the DR response.
l When the MP-2 licensing basis was established in 1973, the Technical Specifications did not address leakage limits for the subject penetrations. Between 1973 and 1975, the penetrations were added to the Technical Specifications and leakage limits established. Parsons comment is that the current Technical Specification value (0.5 SCFM) for bypass leakage does not support the licensing basis (i.e. analysis value of 6.44E-6 SCFM). The current TS limit (approximately 0.5 scfm) for these penetrations is much greater than 6.44E-6 scfm used in the analysis. Since the actual bypass leakage may exceed the value used in the current Control Room Dose analysis, this could result in actual Control Room doses in excess of those contained in the analysis.
The basis for the value listed for EBFS Bypass Flow,6.44E-6 scfm, could not be traced to a calculation. However, this value was traced to responses to FSAR Amendment 16 questions. The 6.44E-6 scfm bypass leakage can be found in Table 6.16.1, Potential Containment Leakage Paths, in FSAR Amendment 16 questions and responses. Per note 1 of this table, this leakage is based on the potential containment leakage paths following a LOCA without assuming a seismic event concurrent to the LOCA. This table identifies that this leakage would be into the Auxiliary Building and therefore would bypass the EBFR.
In the summer of 1973, there was no Technical Specification limit for the 3 penetrations listed above. This is evidenced by the response to question 6.16.3 which states "On this basis and on the results of the proceeding analyses it is not deemed necessary to impose Technical Specification limitations on these three penetrations."
In July,1975, per Amendment 39 to the License Application, the response to question 6.16.3 was revised and identificd Technical Specification 3.6.1.2.c as the reference for the allowable EBER bypass leakage. T he TS were issued in August,1975 and contained the same criteria as the existing TS with respect to EBFR bypass leakage. The SER, dated May 10,1974, stated that the proposed reac* r containment leakage testing program complied with Appendix J to 10 CFR 50 l
and such compliance provides adequate assurance that containment leaktight integrity can be verified periodically on a timely basis to maintain such leakage within the limits of the technical specification.
What documentation between the NRC and NNECo clearly states that the lower value is acceptable for use for the Control Room dose analysis?
Parsons considers this a DISCREPANT CONDITION (Significance Level 3).
Item 6 - Control Room Operation in the Recirculation Mode Page 2 of 8 M981201. doc
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7 CONFERENCE NOTES I
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DATE: 12/1/98 Rev. O TIME: 10:00 a.m. and 2:00 p.m.
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Unit-2 Control Room Emergency Ventilation System response to Unit-3 LOCA Parsons Comments:
Please explain how the required Unit-2 configuration is achieved for the Unit-3 LOCA.
j 11/30/98 NU response: Rad monitors put control room HVAC on recirculation.
l Followup Question: Does the Rad momtor setpomt consider a Unit 3 LOCA?
l Discussion:
Item 3: Discussed again on 12-2 and 12-3. Parsons will close this Item as Non-Discrepant.
1 Item 6: NNECo will call later with Cale number.
Item 9: NU can't find documentation for air velocity over the filter. SL 3. CR M2-98-3557.
Unit-2 Control Room Emergency Ventilation System response to Unit-3 LOCA: Setpoint is such that the Control Room will isalate for a LOCA in Unit 3.
b) DR-0640 (Dan Wooddell) l Parsons proposes to close this DR as a SL4 documentation discrepancy. UIR 2679 previously identified the need to evaluate the intake and exhaust systems for tomado wind and missiles.
However, DR-0640 noted discrepancies between the FSAR, PMMS database, and Bechtel Specification 7604-MS-1 concerning the seismic category of the intake and exhaust piping. These discrepancies do not appear to be addressed by UIR 2679 or the resolution to DR-0581.
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Discussion:
NNECo agrees this is SL 4. CR M2-98-2828.
l c) DR-0588 (Roger Hall)
Parsons wrote DR-0588 on the MP2 EDG Loading calculation, PA-79-126-1027-E2, Rev 1 (5/14/97), regarding the emergency diesel generators (EDGs) sizing to adequately to shutdown Unit 2 i
for the scenario of a concurrent loss-of-offsite power and loss of coolant accident (LOCA).
l Item #2 identified some calculation discrepancies with equipment nameplate information:
- 1. Per our field inspection of nameplate data, Auxiliary Feedwater Pumps (AFW) P9A and P9B's motors are rated 350 horsepower with a 1.0 ser ice factor. This data also agrees with the data i
sheet in Appendix E (page 30) of this calculation. However, the value used in the loading analysis is 360 horsepower which exceeds the rating of the motor. This discrepancy is considered Level 3 significant since these pumps are modeled in the calculation above their rating and their licensing l
basis of 350 horsepower.
MP2 has responded that the calculation uses a value of 360 for brake horsepower as is documented in Appendix E, memo PSM2-93-499 as the required brake horsepower necessary for the required pump flow rate. MP2 submits the value is correct and therefore there is no discrepant condition.
If 360 hp is the required brake horsepower necessary for the required pump flow rate. please explain how the installed motor can deliver the required pump flow when it is rated for 350 hp?
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CONFERENCE NOTES l
DATE: 12/1/98, Rev. O TlME: 10:00 a.m. and 2:00 n.m.
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- 2. Also, per field inspection: (1) the full-load current of the P9A and P9B motors is 47 amps but the calculation uses 46 amps, and (2) the full-load current of valves 2-MS-201(HV4189) and 2-MS-202(HV4189) is 1.0 amps but is shown as 0.95 amps on drawing 252003-29048, sheet 52. These items were assigned a Level 4 significance.
MP2 responded that the 46 amp value for full load current for P9A and P9B was based on the data sheet provided for the motor. The difference of I amp is insignificant and has no impact on the calculation results. To avoid conflict with the vendor motor data sheet being used as a reference document, no change will be made to this value. NU as a policy does not make changes to vendor data sheets. The full load current for 2-MS-201 and 2-MS-202 shown on drawing 25203-29048 sheet 52 is presented as vendor data sheet information. The difference between 1 amp and.95 amp is insignificant and has no impact on the calculation results, therefore no changes will be made.
Parsons assigned a SL 4 to these discrepancies because we agree the discrepancy between the vendor data sheet and the nameplate information is insignificant. We do not expect NU to change vendor data sheets but we would expect the calculation to include the field walkdown data, and justify the differences.
What is MP2's commitment in regards to using as-constructed data in their calculations?
Discussion:
1 NNECo will issue a CCN to PA-79-1027-E2, Rev.1. Parsons will close as a SL 4.
d) DR-0319 (Dick Boyd)
Parsons agrees with NU response to Items I and 2.
Item 3 identifies an issue in which NU's response is to con < ct the FSAR defined volume for SRAS actuation to meet the design calculations. This is Significance Level 3.
Discussion:
NNECo agrees this is a SL 3. CR M2-98-1563.
e) DR-0730 (Dick Boyd)
This was specified by NU as Previously Identified but was determined to be not Previously Identified after further review by NU.
This DR addressed discrepancies in the calculation SGP-M-003-91 which determined that the replacement steam generators had the same or greater mass of water at the 10% of narrow range setpoint for AFW initiation, thereby demonstrating that the original heat removal analysis for the replaced steam generators was still bounding.
NU responded to this DR by the issuance of Siemens Evaluation EMF-98-049, Rev. 0; ' Millstone Unit 2 FSAR Chapter 10 Loss of Normal Feedwater Flow Transient with Reduced Auxiliary Feedwater Flow.' This analysis determines that one motor driven AFW pump is capable of providing sufficient AFW flow to provide cooldown to meet FSAR Chapter 10 conditions. This is not the Design Basis Accident analysis of Chapter 14 and does not demonstrate the adequacy of the AFW system to meet the Chapter 14 analysis; which is covered by Siemens Evaluation EMF-98-015, Rev.
O, ' Millstone Unit 2 Loss of Normal Feedwater Flow Transient with Reduced Auxiliary Feedwater Page 4 of 8 M981201. doc
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CONFERENCE NOTES DATE: 12/1/98. Rev. 0 TlME: 10:00 a.m. and 2:00 p.m.
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Flow.' This analysis demonstrates that the new steam generators along with reduced AFW pump i
performance requires that the Turbine driven pump be started in 10 minutes to meet the Design Basis Accident conditions. Therefore, the calculation SGP-M-003-91 did not demonstrate that the then existing heat removal analysis was bounding.
It is not clear what the Chapter 10 analysis has to do with the calculation which was done to demonstrate that the new steam generatorr has sufficient inventory to demonstrate that the original safety analysis was still bounding.
Discussion:
Another CE calc. addressed Chapter 14 analysis. Parsons will close this as a SL 4. No further corrective action required.
f) DR-0733 (Dick Boyd)
.his was specified by NU as Previously Identified but was determined to be not Previously Identified after further review by NU.
This item is similar to DR-0730 and NU has responded that the ' Chapter 10' evaluation by Siemens makes this condition acceptable.
It is not clear how the Chapter 10 evaluation demonstrates that the specified criteria for steam generator dry-out time is satisfied or that all criteria specified by the NRC for not auto-starting the turbine driven AFW pump are satisfied.
I Discussion:
In progress with NNECo to find documentation link that addresses SER criteria 2, 3, and 4 as acceptable. (Specifically, the 45-minute dry out time.) Will be continued on 12-3-98.
g) DR-0752' (Dick Boyd)
Parsons agrees with NU's response.
Discussion:
NNECo agrees. Parsons will close as Non-Discrepant.
- 2. Topic: NNECo's Items a) DR-0724 & -0734 (Fred Mattioli, N) (Trent Powers, P)
NNECo would like to have a discussion on these two DRs to address the remaining open issues discussed during last week's conference call.
l Discussion:
Rescheduled to 12-2-98.
b) DR-0620 Page 5 of 8 M91 1201. doc l
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CONFERENCE NOTES L
l DATE: 12/1/98. Rev. 0 TIME: 10:00 a.m. and 2:00 p.m.
f Discuss' ion:
In 1986, the NRC stated in an SER that the plant complied with the licensing basis. Parsons will close this as Non-Discrepant.
c) DR-0744 Discussion:
Clarification existing in the TRM states ". using ' guidance' given in ANSI N510." Enhancement modifications would be required to test in total compliance with N510. Parsons will close as Non-Discrepant.
d) DR-0788 Discussion:
Parsons will close as Previously Identified.
Topics for 2:00 p.m. Teleconference 3.
Topic: Parsons' Items a) DR-0797 (John Archer)
Licensing Basis: FSAR Setpoint Value for ATWS is 2400 psia. This is a licensing basis issue because the FSAR states that the High Alarm setpoint is 2400 psia and the current setpoint analysis calculation has a range of 2395 psia to 2500 psia, therefore, the licensing basis will need to change and this becomes a Significance Level 3 discrepancy.
GDC:13,20,29,10CFR50.36.
Design Basis:
Calculated ATWS Analytical Limit is 2425 psia.
NNECo:
Confirmed Significance Level 4.
ICAVP:
SL3 Item #1
- 1. FSAR 7.9.5.2 states that the high alarm setpoint is 2400 psia. Is this the setpoint of the ATWS loop bistable card or the pressure at the Pressurizer instrument tap?
- 2. Will the ATWS related pressurizer pressure loop channels be recalibrated following a seismic OBE or SSE event? If not, two concerns exist because of no margin available. The first l
concern relates to the inability to have demonstrated that the analytical limit would not be l
exceeded and the pressurizer relief valve would lift prior to ATWS reactor trip occurring. The j
second issue is the inability to have demonstrated that the RPS weald definitely be able to trip prior to an ATWS trip (as a result of post seismic calibration shifts) as discussed in Technical Evaluation #M2-EV-98-0173.
- 3. If the pressurizer pressure loop channels are not recalibrated following a seismic event, how can NNECo assure that the analytical limit of 2425 psia will not be exceeded because of Page 6 of 8 M981201. doc
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CONFERENCE NOTES DATE: 12/1/98. Rev. 0 5
TIME: 10:00 a.m. and 2:00 p.m.
I undetected seismic calibration shifts that had not been included in the ATWS setpoint analysis, especially since there is no evidence of the existence of any margin in the setpoint determination?
- 4. The current Procedure SP2402B's acceptance criteria of 18.32 to 18.48 ma allows channels' drift to have a range ofi 5 psi and may require updating, even though the associated Safety Evaluation Screen Form indicated that no surveillance procedures or setpoint values require revision.
(
- 5. Why did calculation 92-030-1260E2 Rev. 3 not implement Method #1 for the ATWS setpoint determination as had apparently been used in establishing the RPS setpoint value and is a recognized approach method in NNECo's SP-EE-315 Rev.1 Guideline? As pointed out in DR-0797, the combination of Method I approach which combines Allowance #1 with Allowance
- 2 results in a value of 28.2 psi which does not support the ATWS trip setpoint determination i
presented in Calculation 92-020-1260 E2, Rev. 03 even when seismic calibration shift or EMI/RFI effects have not been considered. Why did NNECo not consider using its conventional Method #1 combined with a single side ofinterest approach in which seismic effects have been considered?
- 6. FSAR Setpoint Value for ATWS is 2400 psia. This is a licensing basis issue because the FSAR states that the High Alarm setpoint is 2400 psia and the current setpoint analysis calculation has a range of 2395 psia to 2405 psia. Therefore, since this is a change to the licensing basis in the FSAR, why would NNECo not consider this as a change with a Significance Level 37
- 7. Since the EMI/RFI issue has been deferred to the final disposition of DR-0765, can NNECo provide an update of what progress has been made in this disposition?
Item #2 ICAVP could not identify in the NNECo Response where NNECo had addressed the issue presented by ICAVP in Item 2 of DR-0797. Could NNECo please provide a response to this i
ATWS system safety analysis issue?
Item #3 NNECo has now established an ATWS Analytical Limit of 2425 psia in Calculation 92-020-1260 E2, Rev. 03, Since this now establishes the ATWS design basis limit for the ATWS system, why is this not considered a Significance Level 3 issue?
Discussion:
Item #1:
- 1. SL 4. 2. through 7. N-D.
Item #2:
SL4.
Item #3:
SL4.
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CONFERENCE NOTES DATE: 12h /98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
- 4. Topic: N 'ECo's Items a) DR-0403 Discussion:
Parsons will close as Non-Discrepant.
' b) DR-0714 Discussion:
A MEPL was in progress and would have evaluated the switches. A new CR was written to '.xpedite the OD of the switches. These devices were listed in MEPL 1494. Parsons will close as P v.uusly Identified.
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M981201. doc
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j CONFERENCE NOTES l
PATE: 12/2/98. Rev. 0 TIME: 10:00 a.m. anJ_2:00 p.m.
PURPOSE: - Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
I Leftovers from 12-1-98:
DR-0797 1
1.
10:00 a.m.: Parsons Items:
DR-0557, DR-0129, DR-0601, DR-0636, DR-0735, DR-0736, and DR-0772.
2.
10:00 a.m.: NNECo Items:
None.
I Leftovers from 12-1-98:
DR-0814, DR-0724, and DR-0734.
3.
2:00 p.m.: Parsons Items:
DR-0676, DR-0076, DR-0632, and DR-0731.
4.
2:00 p.m.: NNECo Items:
DR-0244, and DR-0245.
LIST OF ATTENDEES:
NNECo NRC NEA Parsons 1
C Roger Bajumpaa Chris Scully Peter Koltay none John Archer l Ken Mayers David Balfour Dick Seder John Nakoski Eric Blocher Trent Powers Chris Cristallo Howard Shamro Dick Boyd Kent Russell Mike Ehredt Greg Tardif Dick Cronk Ron Smith 1
Joe Fougere Roy Terry Wayne Dobson Jon Winterhalter George Howard Harold Thompson Roger Hall Dan Wooddell Ron Jackson Jim Wheeler Rich Glaviano Fred Mattio:
Daniel Van Duine Tom Prvhoda Bob Weth Topics for 10:00 am Teleconference (I & C and Electrical)
Leftovers from 12-1-98:
a) DR-0797 (John Archer) (Continuation ofItem #1, I and Item #2 from 12-1-98.)
Discussion:
Item #1,1: Parsons will close as a SL 4. No additional corrective action required.
Item #2:
Parsons will close this as a SL 4. NNECo described the documentation link.
Page 1 of 5
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CONFERENCE NOTES
' DATE: 12/2/98. Rey, O TIME: 10:00 a.m. and 2:00 p.m.
- l. Topic: Parsons items
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a) DR-0557 (Ro.gerllall)
Parsons initiated DR-0557 to identify that NU had never functionally tested Panel C21 and its Isolation Transfer Switch as an integrated whole and assigned it a Significance Level of 3.
i NU responded that part of DR-0557 is a Confirmed Significance Level 4 and M2-98-280thas been written to track completion of corrective actions.
NU discovered that 2 of the 48 components had not been tested. What is the rational for categorizing this discrepancy as SL 4 since their functional operability has not been demonstrated from C217 95 = 9 --
Parsons will close as a SL 4. Ilistorical documentation was not found. No corrective action is required.
b) DR-0129 (Ken Mayers )
Discussion:
Parsons will close this as Non-e, 4.nt. Although Parsons does not totally agree with NNECo's method of drift analysis, the resulting value is believed to be insignificant since hysteresis is treated in a separate term.
c) DR-0601 (Kent Russell) l Based on Parsons' initial question related to NNECo's demonstrating that the significant elements of M&TE have been considered and documented, Parsons' recent review of Calc PA91-004-0317E2, Rev,2 dated 1/30/98, did not result in a determination that it has been addressed. Ilow does NNECo plan to incorporate the appropriate M&TE factors that have been identified in DR-0130 into Calc PA91-004-0317E2, Rev. 2 or its design input Lab Calc 93-ENG-368 E2, Rev. 27 Discussion:
The only contribution comes from temperature and the instruments are operated within the specified range. Parsons will close this as a SL 4.
d) DR-0636 (Rescheduled from 12-1-98) (Ken Mayers)
I Discussion:
Rescheduled to 12-3-98,2 p.m.
e) DR-0735 (Ken Mayers)
Discussion:
Rescheduled to 12-3-98,2 p.m.
Page 2 of 5 M981202. doc
CONFERENCE NOTES DATE: 12/2/98. Rev. O TlME: 10:00 a.m. and 2:00 p.m.
f) DR-0736 (Ken Mayers)
Discussion-Rescheduled to 12-3-98,2 p.m.
i g) DR-0772 (Ken Mayers)
Discussion:
' Rescheduled to 12-3-98,2 p.m.
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- 2. Topic: NNECoitems None.
Topics for 2:00 p.m. Teleconference Leftovers from 12-1-98:
a) DR-0814 (Rich Glaviano) (Continuation of discussion from 12-1-98.)
Discussion:
Rescheduled to 12-3-98,10 a.m.
l b) DR-0724 and DR-0734 (Dave Bajumpa, N) (Dick Boyd, P) (Rescheduled from H-25,11-30, and j
12-1)
NNECo would like to have a discussion on these two DRs. We would like to understand what the remaining open issues are and then reschedule these DRs for Monday 11/30/98 for closure.
Previous Discussion from 11-25-98:
DR-0724: As of 10-1-98, open questions remain. Parsons sent questions to NNECo for follow up.
DR-0734: Item I still open. NNECo to review and discuss again.
Discussion:
DR-0724: Parsons will close as a SL 4. Calc. will be revised.
DR-0734: Parsons will close as Non Discrepant.
- 3. Topic: Parsons Items a) DR-0676 (Roger Hall, Ken Mayers) i L
Discussion:
This DR was closed on 12-1-98 as a SL 4. No discussion necessary.
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CONFE'r ',NCE NOTES DATE: 12/2/98, Rev. O TIME: 10:00 a.m. and 2:00 p.m.
Q DR-05i6 (Wayne Dobson) (Rescheduled to 12-4-98,10:00 am.)
Discussion:
1 Rescheduled to 12-4-98,2 p.m.
c) DR-0632 (Trent Powers)
Discussion:
This topic will be continued on 12-3-98.
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d) DR-0731 (Dick Boyd)
Response to NUs Disposition:
- 1. The calculation specifies a C, of 37.09 for FW-43A/B which is a calculated C, not the valve manufacturer's specified Cy of 86.9. Using 37.09 is only more conservative when considering pressure drop not runout flow. Also, Attachment F specifies the valve C, at wide open as 37.09 when it is really 86.9 from the vendor drawing. The C, of 37.09 is a ' throttled' C, and therefore when used in the calculation model does not actually 'model' the system. This incorrect Cy is also incorrectly specified in the evaluation identified in item 2, which referenced the calculation model.
- 2. NU identified that run-out condition for a single motor driven AFW pump were evaluated in Technical Evaluation M2-EV-98-0167, Rev 0; Auxiliary Feedwater System and determined that this was not a problem. However, the evaluation only looked at single pump at low steam generator pressures while in Mode 3. This did not consider the effects of single pump operation for an accident such as a MSLB. In addition, the evaluation does not conclude that pump runout is acceptable, only that the turbine driven pump can be started to provide AFW flow. This does not cover the aspects of AFW operation with single failure for a MSLB in which pump runout is a safety concem.
3..
AGREE-CONFIRMED SL-4.
- 4. AGREE - NON-DISCREPANT.
- 5. AGREE-NON-DISCREPANT.
- 6. NU responded to this item by citing a reference to calc 98 CST-02644-M2, MP2 CST LO-LO Alarm and AFW Pump NPSH. This DR was addressing the pipe roughness used in the calculation model for the AFW system. What accounts for the use of clean pipe in the AFW model calculation?
- 7. We believe that this is a SL-4. Although the effect is small, the concem here is that the calculation uses assumptions that are not supported or results that are different than those l
determined in other calculations relating to the condensate storage tank. These issues are related I
and the calculations should be consistent or provide an evaluation of the differences.
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e, CONFERENCE NOTES DATE: 12/2/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
Discussion:
Item 1: SL 4.
Item 2: In progress with NNECo. Will be discussed 12-3-98.
Item 6; In progress with NNECo. Will be discussed 12-3-98.
Item 7: In progress with NNECo. Wdi be discussed 12-3-98.
- 4. Topic: NNECoItems a) DR-0244 (Trent Powers, P)
Discussion:
Parsons will close as Previously Identified.
b) DR-0245 (Trent Powers, P)
. Discussion:
Item 3: SL 4.
Item 5: Parsons will close as Previously Identified.
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M981202. doc I
i CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
PURPOSE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
1.
10:00 a.m.: Parsons Items:
DR-0403 and DR-0617.
2.
10:00 a.m.: NNECo items:
DR-0658.
- 3. 2:00 p.m.: Parsons Items:
DR-0636, DR-0814, DR-0632, and DR-0731.
4.
2:00 p.m.: NNECo Items:
DR-0819, DR-0820, DR-0685, and DR-0733.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Mike Ahern Fred Mattioli Peter Koltay none John Archer Trent Powers Dave Bajumpaa Clark Maxson John Nakoski Dick Boyd Kent Russell Prasad Bandans Mike O'Meara Rich Glaviano Victor Willems Chris Cristallo Gil Olsen Dave Lengel Jon Winterhalter Claude Florv George Pitman Ken Mayers Joe Fougere Tom Prvhoda George Howard Greg Tardif Dan Hundlev Harold Thompson Ron Jackson Jim Wheeler Topics for 10:00 am Teleconference
- 1. Topic: Parsons Items a) DR-0403 (Ken Mayers)
Discussion :
Parsons will close as Non-Discrepant.
b) DR-0617 (John Archer)
Discussion :
The NRC stated that IEEE 279-1971 does not apply once EOPs are entered. Based on that, Parsons will close as Non-Discrepant.
Page 1 of13 M981203 doe
ej' CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
l 2.' Topic: NNECo items a) DR-0653 (Ken Mayers, P)
Topic: DR-0658
- 1. Parsons is in agreement with NNECo's disposition on the following items: E3, F1, and 16. T%se items can be closed. (E3, J6 - SL3; FI - Non Discrepant).
- 2. DR-0658 identified 30 specific discrepancies relative to the Radiation Monitoring system. With the exception of a few items, NNECo's response did not specifically address the identified discrepanciet,. Instead the response groups the discrepancies into four broad categories and classifies most of the items as previously identified through reference to CRs that are not specific to the identified discrepancies. As a result, Parsons has been unable to determine NNECo's disposition on the following identified discrepancies: E l, E2, G1, G2, H2, H3, H4, II,12,13,14, 11, J2,38,39, J10, J11, J12, J13 and J14. The NRC has stated in past conferences that items can not be considered previously identified when documentation of previous discoveries lack i
specificity. Why does NNECo consider these items to be previously identified, and how will the j
corrective action be linked to the specific discrepancies identified in the DR7
- 3. Item I.1 of DR-0658 references an interoffice memo (Bates to Kross) that recommends detector replacement and recalibration for RM 8123A and RM 8262A. NNECo's DR response does not specifically address this issue. Were the detectors replaced as recommended? If not, how were the l
j out of spec yield values addressed?
l
- 4. Item J.4 of DR-0658 calls into question the peak temperatures used in PA-201-842GE, Rev. O.
NNECo's response states: "NU believes this temperature to be conservative and bounding for l
evaluating the potential effects on the HRRM." What is the basis for this conclusion?
- 5. NNECo's response to item J.5 states that PA 79-201-842GE Rev 1 discusses the use (or non-use) of data from PA 78-771-806GE. How has the limiting IR leakage current been accounted for since the bounding environmental temperature has not been incorporated?
- 6. Item J.10 of DR-0658 raises the concern that the detector is the only instrument in the loop that is l
addressed by Calculation 2-ENG-013 Rev. O even though their are other devices in the loop that are used to adjust the setpoint. NNECo's original response to the DR did not address this issue.
Providejustification for this exception.
j
- 7. Item J.12 of DR-0658 identifies that Calculation 2-ENG-036 Rev. I assumes a stack flow rate of l
32,000 cfm when the actual flow rate could range from 32,000 cfm to 96,000 cfm. NNECo's response did not specifically address this issue. How is this difference addressed?
l Discussion :
Parsons reviewed many calculations which NNECo said were in the process of being superseded.
Since this DR has been accepted as a SL 3, Parsons will close this DR and include a list of specific l
topics that NNECo should address in the new calculations.
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,DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
DR-0658 Issue Level NNECo Response Parson's Assessment Final Resolittion I Comments P/N El. RM setpoints do not agree 3/PI PI by CR M2-97-0829 Agree that issue is addressed by CR M2-97-0829 address with calculations CR M2-97-0829 calculation deficiencies in general. Not specific to RM i
cales.
E2. Conflict among setpoints in 3/PI PI by CR M2-97-0829 Agree that issue is addressed by different RM calcs.
CR M2-97-0829 E3. Containment High Range 3/3 Confirmed SL3.
Agree w/ proposed corrective monitor does not meet factor of 2 CR M2-98-3169 initiated action.
accuracy requirement of RG 1.97 to address problem. CA to be completed prior to Mode 4 on CHRM Fl. Vendor Tech manual and 4/ND NNECo's review of FSAR Parsons also can find no FSAR do not agree on range of indicates no discrepancy.
discrepancy in referenced FSAR NMC SC-2B Beta :',cintellator table.
s Gl. Sampling efficiency for RM 4/PI NNECo's response does Response considered 8123A is not consistent w/ Tech not specifically address satisfactory. See third Manual Apparently covered by paragraph under item 1 page 12 general problems of NNECo response..
described in CRs M2 0829 and M2-98-1576.
G2. Sampling efficiency for RM 4/PI NNECo's response does Response considered i
8262A is not consistent w/ Tech not specifically address.
satisfactory. See third Manual Apparently covered by paragraph under item 1 page 12 general problems of NNECo response..
described in CRs M2 0829 and M2-98-1576.
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0 0 CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
Issue Level NNECo Response 2 arson's Assessment Final Resolution Comments P/N I
Hl. No instrument loop 3/ND Per reference 6.3.6 of SP-Requires further assessment.
The NNECo reference that uncertainties for the CRAM loop M2-IC-019 qualitative prosides that basis for not
' t assessment of calculating uncertainties for uncertainties is RM instruments is a acceptable.
" undated" internal NNECo I
document. Also see SP-M2-l IC-019 Sec 1.3.5.
H2. Calculation does not fully 3/ND NNECo's response does Requires further assessments.
address the function of the CRAM not specifically address.
Response appears to be i
loop WRT uncertainties this acceptable.
item would be addressed by response to item Hi H3. 2-ENG-026 references wTong 3/PI NNECo considers this issue isn't addressed rev oft /S and uses outdated issue addressed within the specifically by NNECo but values scope of CR M2 97-0829 appears to be with scope of and M2-98-1576 planned corrective actions.
H4. The setpoint in the 3/PI NNECo considers this Issue isn't addressed surveillance procedure exceed the issue addressed within the specifically by NNECo but settings referenced in calc 2-ENG-scope of CR M2 97-0829 appears to be with scope of 033.
and M2-98-1576 planned corrective actions.
H5.Calcs contain statement 3/PI NNECo considers this issue too vague to adequately relative to operability of RMS issue addressed within the assess. Without specifics.
with adequate basis scope of CR M2 97-0829 should consider non-discrepant.
and M2-98-1576
- 11. Interoffice memo 3/Not NNECo did not address Need info from NNECo on See conference call question recommended replacing RM Addresse this issue in their whether monitors were asking for additionalinfo 8123A and 8262A because yield d
response.
replaced.
from NNECo.
values out of spec. No evidence of replacement.
Issue Level NNECo Response Parson's Assessment Final Resolution Comments Page 4 of 13 98_12_03. doc
CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
P/N l
ENG-057 had "as-found" out of issue addressed within the specifically by NNECo. It is l
- 12. Cales. 2-ENG-054 and 2-3/PI NNECo considers this Issue isn't addressed tolerance and "as left" was set a scope of CR M2 97-0829 not clear how this will be max end point.
and M2-98-1576 addressed within the scope of planned corrective actions.
- 13. Vendors calibration data is 3/PI NNECo considers this Issue isn't addressed inconsisten* with data Cales. 2-issue addressed within the specifically by NNECo but ENG-054 and 2-ENG-057 scope of CR M2 97-0829 appears to be with scope of and M2-98-1576 planned corrective actions.
14.MT&E uncertainties not 3/PI NNECo considers this Issue isn't addressed included in calibration of issue addressed within the specifically by NNECo but particulate iodine and gas monitor scope of CR M2 97-0829 appears to be with scope of flow instruments.
and M2-98-1576 planned corrective actions.
- 15. In calc 2-ENG-057 it is 3/PI NNECo considers this This appears to be a question on unclear how the Xem quivalent issue addressed within the the part of the DR authc,t rather e
setpoints are calculated.
scope of CR M2 97-0829 than a discrepant condition.
and M2-98-1576 J1. Rad Monitoring 4/PI NNECo considers this Issue isn't addressed Instrumentation is not addressed issue addressed within the specifically by NNECo but in Setpoint Analyds Methodology scope of CR M2 97-0829 appears to be with scope of or Loop Accuracy Methodology and M2-98-1576 planned corrective actions.
J2 MT&E not addressed for rad 3/i'I NNECo considers this The MT&E issue is addressed i
monitoring.
issue addressed within the in DR-0130. Because MT&E is scope of CR M2 97-0829 addresses in generalin DR0658 and M2-98-1576 this is a repeat of the DR0130 issue.
J3. Incorrect assumption on use of 3/ND NNECo takes exception to Requires further evaluation by
(-) bias term results in non-the conclusion that bias Parsons.
conseivative uncertainty.
term assumption is incorrect.
Issue Level NNECo Response Parson's Assessment Final Resolution Comments Page 5 of13 98_12_03. doc
CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 n.m.
P/N J4. Max. CBA temperature values 3/ND NNECo takes exception to Requires further evaluation by 280*F taken from Rockbestos used are non-conservative thisconclusion. They Parsons.
Qualification report Gee PA-consider the temperatures79-20is. p 9-16.
to be conservative and bounding.
J5. The IR cable leakage and the 3/ND NNECo takes exception to Although PA-79-201-842GE IR penetration ledage is not used this discrepancy.
does not used the IR leakage in the CHRRM loop accuracy values calculated in 2,-78-771-calculation.
806-GE, IR effects are considered along with the impact ofelevated temperature impact on IR leakage. Failure to use the specific values from l
PA-78-771-806-GE does not constitute a discrepancy.
- 16. Uncertainty calculation 3/3 NNECo has accepted this Agree with NNECo's response.
erroneous for HRRM.
as a confirmed SL3 because the HRRM does not meet the RG 1.97 X2 requirement at the low r
end of scale due to the bias of the " keep-alive" i
source.
J7. The 22.5 month max drift is 3/ND NNECo considers this Previous generic discussion of not addressed by calcs.
non-discrepant because the generic drift issue within drift is negligible.
Parsons suggested that a non-consenative drill term did not constitute a discrepancy provided T/S allowable values were not exceeded. This needs to be considered in Parson's t
position. Further evaluation required.
i Issue Level NNECo Response Parson's Assessment Final Resolution Comments i
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CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
P/N
- 38. PMA Uncertainties not 3/PI NNECo considers this issue isn't addressed addressed in referenced issue addressed within the specifically by NNECo but i
calculations.
scope of CR M2 97-0829 appears to be with scope of and M2-98-1576 planned correctise actions.
- 19. Assumptions are not addressed 3/PI NNECo considers this The DR provided 3 examples of Parson's statement of the in cales for CRAM.
issue addressed within the missing assumptions. These discrepancy should be limited scope of CR M2 97-0829 specifics are not addressed in to the specific miring and M2-98-1576 the DR response; however, assumptions made identified NNECo's response covers the in the DR. The stated issue of stating assumption discrepancy of missing within the calculations in assumptions in general can general.
not be effectisely addressed J10. 2-ENG-013 does not address 3/P1 NNECo considers this This issue appears to be outside instruments in the loop other than issue addressed within the the scope of NNECo's planned the detector scope of CR M2 97-0829 correctist action. Additional and M2-98-1576 input from NNECo on their planned correctist action is Jl1. RE: 2-ENG-013 and 2-ENG-3/PI NNECo considers this ssue sn't addressed 057 the sample flow rate is stated issue addressed within the specifically by NNECo but to be 3 SCFM while actual flow scope of CR M2 97-0829 appears to be with scope of rate ranges from 2.5 to 3.5 SCFM and M2-98-1576 planned correcdse actions.
J12. Plant exhaust stack flow ~ ate 3/P1 NNECo considers this Issue isn't addrerS$1 stated in 2-ENG-036 does not issue addressed within the specifically by NNECo. A more consider the full range of possible scope of CR M2 97-0829 specific response is needed for flow rates from the stack and M2-98-1576 Parsons to adequately evaluate.
Issue Level NNECo Response Parson's Assessment Final Resolution Comments Page 7 of 13 98_12_03. doc l
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CONFERENCE NOTES.
' DATE: 12/3/98. Rev. 0 -
TIME: 10:00 a.m. and 2:00 p.m.
P/N J13. 2-ENG-036 assumes that 3/PI NNECo considers this Issue isn't addressed 50% of the plant exhaust stack issue addressed within the specifically by NNECo but
'I flow comes from Unit 2 when scope of CR M2 97-0829 appears to be with scope of actually approx 33% comes from and M2-98-1576 planned correctist actions.
unit 2.
J14. The type of detector stated in 3/P1 NNECo considers this Issue isn't addressed 2-ENG-036 is incorrect.
issue addressed within the specifically by NhTCo but scope of CR M2 97-0829 appears to be with scope of and M2-98-1576 planned correctist actions.
t L
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CONFERENCE NOTES DATE: 12/3/98. Rev. 0 l
TIME: 10:00 a.m. and 2:00 o.m.
Topics'for 2: 6 p.m. Teleconference
- 3. Topic: Parsons Items a) DR-0636 (Ken Mayers) (Rescheduled from 12-1-98.)
Discussion :
See Il-30 -98 notes for this DR.
b) DR-0814 (Rich Glaviano) (Continuation from 12-2-98.)
Discussion :
The remaining open item was determined to be Non-Discrepant. Other aspects of this DR were previously agreed to be SL 3.
c) DR-0632 (Wayne Dobson) (Continuation from 12-2-98.)
Discussion :
Recent AW0s provide procedural steps to perform work. Parsons will close as Non-Discrepant.
d) DR-0731 (Dick Boyd) (Continuation from 12-2-98.)
Items 2,6 and 7.
Discussion :
Item 2: Technical evaluation will be reviewed to consider 1 pump running. If existing eval. Bounds the condition, then SL 4, if not, then SL 3.
i i
Item 6: NNECo will accept as a SL 4.
Item 7: NNECo will accept as a SL 4.
- 4. Topic: NNECo Items
)
a) DR-0819 (Bedrich Kohout, P) l Discussion :
Parsons will close as a SL 4. CR M2-98-3590.
b) DR-0820 (Bedrich Kohout, P)
Discussion :
l NNECo agrees this is SL 3. CR M2-98-3590.
i Page 9 of13 98_12_03. doc
CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 n.m.
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c) "DR-0'685 Item 3 - Containment Fan Coolers Heat Removal item 3, a) CAR Capacity (Juan Cajigas, Dave Lengel)
Background:
i l
The Containment Air Recirculation (CAR) cooling units are part of the plant Engineered Safety
{
Features systems designed to mitigate the effects ofpostulated accidents. As described in FSAR Section 6.5.2, each CAR unit is designed to remove 80 MBTUH (80E6 BTU /hr) from the containment vapor region m the event of a LOCA or a MSLB.
l The MSLB containment analysis (Calculation 006-ST97-C-024) takes credit for CAR capacity that
]
l appears inconsistent with the MP2 MSLB containment design basir analysis as described in the FSAR l
and inconsistent with the reported CAR vendor performance data shee;. The basis for the CAR L
performance data used in calculation 006-ST97-C-024 is a CAR computer performance model that
]
l has not been validated against the vendor performance data. He CAR performance data input to the analysis is non-conservative since it exceeds the vendor reported capac(ty at its design point by 19.35 MBTUH (24%).
i in order to develop the CAR performance data required by SGNIII/CONTRANS2, Proto-Power l
calculation no.97-120, Reference 6, develops CAR performance parametric data based on an MP2 l
CAR model developed with the PROTO-HX code. Calculation 97-120 determined that, at the post-accident design conditions, the MP2 CAR capacity is 99.35 MBTUH. This calculated total CAR heat removal capacity was distributed as 81.21 MBTUH removed by the RBCCW system and 18.14 l
MBTUH removed by the condensate. In validating this calculated CAR performance against the CAR manufacturer's data sheet (same data reported in the FSAR), Proto-Power indicates that since the PROTO-HX water side heat removal rate of 81.21 MBTUH "is within 1.25% of the data sheet value of 80 MBTUH,' it then suggests that the CAR vendor " reported the coil heat transfer in terms of heat gained by the coolire water system." Therefore, Proto-Power deemed this comparison as suflicient validation of the PROTO-HX MP2 CAR model and developed CAR performance parametric equations based on a design performance capacity of 99.35 MBTUH. These equations are then used to simulate the CAR performance in the 006-ST97-C-024 ABB MSLB containment analysis.
Neither the MP2 FSAR nor the CAR performance vendor data sheets documented in Proto-Power calculc. tion 97-120 support a total CAR heat removal rate of 99.35 MBTUH at the unit's design point.
Therefore, unless the CAR vendor test / performance data verifies that the MP2 CAR units can remove 99.35 MBTUH at their design point and the plant establishes an adequate CAR performance field verification program, the installed CAR performance data used in calculation 006-ST97-C-024 can not be validated as consistent with the analysis assumed conditions.
NU Response:
A question has arisen whether the 80 million BTU /hr value identified by the Bechtel Post-Incident CAR cooling unit data sheet (CAR cooling unit is supplied by Westinghouse) is the total energy removed from the containment steam space or the portion of energy removed from the containment steam space that is transferred to RBCCW. Using the RBCCW flow rate of 2000 gpm through the CAR coolers with an inlet temperature of 130 degrees F and an outlet temperature of 210 degrees the
)
energy transferred to the RBCCW system agrees with the 80 million BTU /hr identified on the CAR j.
cooling unit data Sheet. As such, the data sheet provides only the portion of the energy removed from l
the containment steam space that is transferred to the RBCCW system, and does not include the l
energy removed from the containment steam space that ends up in the containment sump.
l 98,12_03 doc
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-.. _ _ __.________.- _ __ -._. _._ _.__._._ _ _ _.~..__ _
CONFERENCE NOTES l
DATE: 12/3/98. Rev. 0 TIME: 10:00 a.m. and 2:00 n.m.
The fol' lowing discussion provides furtherjustification that the 80 million BTU /hr value is the energy transferred to RBCCW by the CAR cooling units and not the total energy removed from the containment steam space:
FSAR Section 6.5.4.2 references Westinghouse Topical Report WCAP-7336-L " Reactor Containment Fan Cooler Cooling Test Coil" which demonstrates the performance capability of CAR cooling coils i
based on testing of a scaled test coil under LOCA accident conditions.
Discussion of"HECO" computer code program (see DR-0685 Response):
He CAR coolers remove sensible heat from the contaimnent atmosphere during normal plant operation but become condensers in the post accident steam environment. As detailed in the WCAP, verification of the coil accident heat removal capability was determined by two independent methods:
- 1. Water Side Heat Balance-(measurement of the cooling water flow rate and inlet to outlet temperature difference)
- 2. Air Side Heat Balance-(measurement of the steam-air flow rate and inlet to outlet temperature difference, and the condensate flow rate and temperature)
The water side heat balance represents the heat removed from containment. The total heat removed from the enntainment steam-air mixture is the sum of the heat removed by the cooling water system plus the heat retained by the condensate draining to the containment sump. The test coil heat removal rates (MBTUH) documented in the WCAP were determined by measurement of the cooling water flow rate and temperature difference i.e. did not include the additional heat removal to the condensate stream. This is consistent with t" heat removal capability specified for the CAR coolers on the vendor coil data sheet.
Parsons Comments:
Vendor Data Sheet Proto-Power Calc Alternate Calc Heat Transfer Rate:
80 MBTU/HR 99.35 MBTU/HR 80 MBTU/HR Air-Vapor Mixture Temp In:
289 F
'289*F 289 F Air-Vapor Mixture Temp Out:
281.8 F 274 F 281.8 F Cooling Water Temp in:
130 F 130 F 130 F Cooling Water Temp Out:
210 F 211 F 188.2*F The Heat Transfer Rate term typically represents the total energy removed from the containment vapor space. This is composed of the energy transferred to the heat sink (~80% of the total) plus the sensible heat in the condensate (~20% of the total). Sufficient data to verify this via calculation is presented in the typical data sheet.
The MP-2 cooler data sheet, while in the typical format, does not contain sufficient information to validate the total Heat Transfer Rate. In fact, in one performs the calculation, the typical 80/20 distribution does not hold. So, the data sheet is inaccurate. Either the total. Heat Transfer Rate term is incorrect or another term (perhaps Cooling Water Outlet Temp) is incorrect.
NU believes the total Heat Transfer Rate term is the incorrect term and that the value should be ~99 MBTU/Hr. As stated above, it is possible that one of the other terms is incorrect. The above table shows that the other values in the data sheet can be matched by changing the Cooling Water Outlet Temperature. Parsons concern is that NU did not prove the total Heat Transfer Rate term is the incorrect term and thus can be recalculated.
Page 11 of 13 98,12_Oldoc
CONFERENCE NOTES DATE: 12/3/98. Rev. O TIME: 10:00 a.m. and 2:00 p.m.
- This issue was addressed with NU at a meeting on May 12,1998. At the meeting, NU agreed to contact Westinghouse to obtain additional infc tation to justify the total heat removal term. Parsons issued RAl-1565 on May 14,1998 requesting t s information. The RAI response, dated Sept. I1, 1998, is similar to the DR response, and is not repeated here.
NNECo and Parsons agree that there is an apparent conflict or missing information on the data sheet for the CAR units. An accurate data sheet would show a portion of the heat being removed by the RBCCW (about 80%) and the balance being carried out by a condensate flow rate. The Proto-Power Calculation (page 9) states that the coil heat transfer reporting is "not typical for data sheets for these types of coils." Parsons concludes that either the outlet water temperature is incorrect or the heat load value identified does not represent a total heat rejection by the coil.
NNECo's position is that the heat load value only represents the heat rejected to the RBCCW system and not the total heat load.
To validate this assumption, Parsons requires one of the following:
- 1. New data sheet information from the vendor (Westinghouse) which resolves the apparent discreptncy, or -
- 2. A validated / benchmarked model which proves the assumption.
To date,
- 1. No new data sheet information has been presided.
- 2. The Proto-Power calculations performed to date, do not justify a CAR heat removal rate higher than the vendor's value in that:
The Proto-Power model was not benchmarked against the vendor data sheet in the a.
accident mode. Note that since the data sheet is not accurate, no such benchmarking would be possible. The model only checks one set of data points and there is not a good correlation between the calculated values and the data sheet values, especially with respect to the air side values. The documented validation of the model for sensible heat removal does not demonstrate the model's accuracy in the accident or condensation mode,
- b. He Proto-Power model was not shown to accurately simulate a similar CAR unit performance, say as that documented in Attachment U of the Proto-Powwer Calc. Such validation would demonstrate the model capability to conservatively simulate this type of cooler and could be used to defend the proposed extrapolation of total capacity.
He validity of the Proto-Power model in simulating the MP2 CAR performance has not been demonstrated and should not be used as an accurate representation of then units for safety related calculations.
Because of the importance of this parameter to the accident analysis, Parsons believes that NNECo needs to either 1) provide additionaljustification for use of the 99 MBTU/Hr heat transfer rate or
Without any additional information tojustify the total heat removal term, Parsons considers this a DISCREPANT CONDITION (Significance i.evel 3).
Item 3, b) Air Flow
Background:
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' The C R performance assumed in the MSLB containment analysis is based on a minimum air flow rate of 34800 cfm per CAR unit. For 4 CAR unit configurations, used in several MSLB containment analysis cases including the peak temperature case from Reference 1, the field tested fan flow is lower than that required to meet the assumed CAR performance.
NU Response:
Regarding the minimum containment air flow rate through a CAR cooler, while Calculation 97-120 shows that the CAR energy removal is insensitive to a 15% reduction in air flow through a CAR cooler, the design flowrate of 34,800 cubic feet per minute for all four CAR fans is assured by the system design which includes fusible-link blowout doors in the CAR fan discharge ducts. There are four 20 inch by 59.25 inch blowout doors installed on the 66 inch by 66 inch discharge duct. The fusible links are designed to open at 165 degrees F and coil springs force the doors open.
Based upon the above discussion, NU does not believe that this item is discrepant.
Parsons Comments:
Concur NON-DISCREPANT ltem 3, c) CAR Performance Testing. Mike Sedlack)
Background:
In a telephone conference, Reference 10, NNECo indicated that the CAR units are not field tested for thermal performance and that the plant relics on calculations to justify this performance. There is no evidence that critical performance parameters, other than fan flow, such as RBCCW flow rates (see item 4), tube plugging, and fouling factors are verified in the field for consistency with the safety analysis.
NU Response:
Not addressed in NU Response Parsons Comments:
The NNECo response does not address the issue of tube plugging or fouling. Please discuss how tube plugging and fouling factors are verified for consistency with the safety analysis.
Discussion :
These topics are Non-Discrepant. Overall the DR is a SL 3.
d) DR-0733 (Dave Bajumpaa, N) (Dick Boyd, P) (Continuation from 12-1-98)
Discussion :
NNECo will prepare an evaluation, prior to startup, to determine if the assumed 45-minute dry out time is still valid. Parsons will close as a SL 4.
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CONFERENCE NOTES DATE: 12/4/98. Rev. O TIME: 2:00 p.m.
PUR SE:
Telephone conference with NNECo, NRC, NEAC, and Parsons to discuss:
10:00 a.m.
Canceled.
2:00 p.m.: Parson Item:
DR-0076.
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Bill Cushman Greg Tardif Peter Koltay none Dick Boyd Trent Powers Joe Fougere Bill Ziegenhagen John Nakoski Wayne Dobson Jon Winterhalter Topics for 10:00 a.m. Teleconference Morning conference canceled.
Topic for 2:00 p.m. Teleconference Topic: Parsons item DR-0076 (Wayne Dobson) hpm #1: AFW Pump Impeller - Improperly relied solely on a vendor's marking for material without performing commercial grade survey to approve vendor's control of material and markings.
NU Response: QA did surveys and source inspections on the vendor.
RAl-2128 asked for copies of the survey done to confirm acceptable vendor's control of material and markings. Response did not provide any survey information, but provided results of alloy analyzer test of one of five items still in stock. Parsons agrees with the corrective action to test the material. This is SL 4, the CGD package needs to be revised to reflect this testing.
Item #_2; Example of generic isrue of not recording actual test and inspection data. Parson agrees the inspector initials provides some evidence that test and inspections were performed and the results were satisfactory. As an enhancement however, NU procedures should be revised to require documentation of the quantified results of all Special Tests and Inspections (as defined in EPRI NP-5652 and EPRI TR-102260, and performed to verify selected critical characteristics during dedication by NU). The current practice of simply identifying satisfactory / unsatisfactory does not meet the intent ofindustry guidance.
Documenting actual test / inspection results would provide the licensee with objective evidence that the selected critical characteristics met acceptance / design criteria. Parsons proposes a SL4 for this issue, and all the rest of the items which contain the same issue will be non-discrepant.
Item #6: Limitorque motor operator - CGDF incorrectly states item performs no safety function, l
verification of buna-N seals not perfonned, verification of CC# 2&3 regarding configuration and operability was not perfonned.
NU Response: SL4, MOV project will test the valve and operator. MOV not in harsh emironment so buna-N seals are not required to support a safety function.
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DATE: 12/4/98. Rev. O TIME: 2:00 p.m.
Without vei.ification of these critical characteristics, unqualified equipment is installed in a safety related application. Why is this not a SL37 We would agree that if the testing shows the equipment has the specified critical characteristics, then this is a SL4 which needs to correct the CDGF to address the statements on safety function and remove the requirement to verification of buna-N seals.
Item #9: Basis for sample plan is not documented.
NU Response: SL4, Engineering has revised the evaluation to provide a basis for utilizing a normal sample plan.
This item is an example of CGDF not providing a basis for the sample plan. In other examples of this issue NU provided a responsejustifying the sample plan that was used. Parsons will agree to a SL4 on this item, and non-discrepant on the other examples of this issue, if the corrective action addresses the need to enhance procedures to require documentation of the technical basis for sampling CGIs undergoing Special Tests / Inspections.
Item # 51 No test data results, M&TE equipment calibration due date not identified.
NU Response: QAS audit A60572 identified this discrepancy.
What is the date of this audit? Is it pre-CMP complete?
Item # 53: CPU board - Pre-operational Testing was specified, but no documentation of test being performed.
NU Response. Non-Discrepant. The dedication is not complete, the part has not been installed.
How did NU detennine this? The package provided for the ICAVP review was similar to others: i.e. a signed off MRIR which lists the CGDF #, and a POT form which is not complete.
Item # 54: HofTman panel clips - CC#3 specifies material strength and corrosion resistance. A magnet test was performed which does not demonstrate corrosion resistance. The sample acceptance process did not specify the sample size that was used. No actual test result data.
NU Response: SL4, Procurement Engineering has corrected dedication and the Stock Code number has been set to hold for pre-evaluation.
What does this response mean? What was done regarding the parts installed in the field. Why is installing unqualified parts not a Level 3?
ILem # 62: Control Room AC fan belt - Workmanship is not a CC. Material was omitted from CC.
NU Response: Non-Discrepant. Agree workmanship is not a CC. The control room AC fans receive monthly mechanical PM and operability check.
Proper material is a critical characteristic needed for the belt to perform its safety function. The NU response may be an acceptable basis for saying what is currently installed is acceptable. but the dedication should be revised to ensure new replacement belts are of the proper material. Parsons believes this is a SL4.
item # 63: EDO fuel filter vent hex head plug - No documentation that dimensional measurements and material testing was performed. MRIR 290-010 is blank for this item. Response to RAI-2128 provided no evidence of special tests or inspections.
NU Response: Non-Discrepant. Item was original spare supplied with diesel. The decision to perform a dedication was conservative. The inspections provide reasonable assurance that the item will perform it's safety function.
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RAl-2128 ask for any documentation of the inspections that were done. NU response: Dedication never completed, AWO M2-89-03392 did not use a HEX NUT.
This item is not a HEX NUT, it is a HEX HEAD PLUG.- Is there any thing in place today that provides j
the dedication status of a commercial grade item, or lack of documentation the only indication that a j
dedication is not complete?
Item # 71: Hilti Kwik bolt - Dimensional tolerances not specified.
NU Response: Non-Discrepant. This dedication was never implemented. Hilti was an approved vendor, and QA parts were procured.
How did NU determine this? The package provided for the ICAVP review looks no different than other packages were the dedication was donc, i.e the PO and MRIR all say QA Cat.1. We have compared the Hilti PO dated 2/12/90 with other POs of the same time frame provide with other commercially dedicated items and they all indicate "This is a QA Purchase Order", it invokes 10CFR21, and states it is QA Cat.
1.
Why was someone trying to dedicate a Cat. I part?
Item # 78: Relief Valve - No document of testing CC # 2,3, & 4, material, dimensions, and pressure testing.
l NU Response: Non-Discrepant. CGDF MP2-0171 is identical to CGDF MP2-0172. The MRIR references CGDF.MP2-0171, therefore CGDF MP2-0172 is a duplicate and was never utilized.
RAl-2128 ask some evidence that CC #2,3,4 were actually verified. AWO M2-86-07833 was provided.
This AWO documents that a pressure test was successfully preformed, but provides no documentation for material and dimensions.
Without verifying required material and dimension characteristics, what is the basis for qualifying this part for nuclear safety related application?
11gm # 87: Gate Valve - Dedication failed to recognize the need to assume worst design basis when specifying CC acceptance criteria.
NU Response: Non-Discrepant. The failure to consider non-metallic parts of the valve is due to the fact that the associated packing, 0-ring, and gaskets are considered to be non-Q since they are non pressure retaining.
RAl-2128 asked for the specific end use evaluation that addresses seismic considerations given the vah'es weight more than the specified critical characteristic. Ref. NRC 194-624, WO M2-94-12469 and any other WO that installed one of these four valves. NU response: An assignment was added to CR M2 0802 to evaluate the seismic impact of the weight difference.
It appears NU has changed the Non-discrepant classification. With out a complete dedication or evaluation, why is installing unqualified parts not a Level 3?
THE FOLLOWING FIVE ITEMS ARE EXAMPLES TO BE DISCUSSED TOGETHER ltem #17: CC# 1 & 2 were not verified on MRIR.
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NU Response: Non Discrepant. Dedication was never performed due to the product being changed on the PO to a basic component. The vendor was an approved supplier at the time.
Why is commercial grade dedication being done on basic components?
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- 40I ' Marking on cable was only CC specified. Dedication was based solely on product markings of l
an unqualified commercial grade vendor.
NU Response: Non-Discrepant. Dedication performed in error. Cable is non-Q per MEPL MP2-CD-1503, 12/94.
l At the time the cable was dedicated, (1992) it was required to be Cat I cable. So at the time, this was an improper dedication.
Item # 43: No documentation for CC #1 & 2 Transistor.
NU Response: Non-Discrepant. AWO M2-89-11270 used SP2404AL to demoastrate system operability.
We agree functional test OK, but no documentation of verifying part number as nquired by CC #1.
Item #45: CC #1 specifies a v;sual capacitance check.
NU Response: Non-Discrepant. CC#1 incorrectly specified visual capacitance check. Testing was performed with capacitance meter and documented on MRIR.
Item # 76: 24" Wafer Check Valve - CC testing is not documented in accordance wi'h procedure.
NU Response: Non-Discrepant. The acceptance signature on the CGDF is missing. However, post maintenance testing confirmed operability for this check valve.
The AWO and the material issue documentation do not identify the item as commercial grade or the need for post installation testing to complete the dedication. It appears that by luck, standard post maintenance testing fulfilled the dedication requirements.
DISCUSSION: These items are examples of conunercial grade dedications which have some documentation or process deficiency. Of the 83 items in this DR that NU classified as Non-Discrepant, approximately 29% contain some type of documentation or process deficiency. We agree these are not SL 3 because in our engineering judgement the equipment or part installed is capable of performing its safety function. And we agree that even though the documentation is not complete, there is an error in documentation, or there is indication of a process error, correcting the individual error has little value.
However, it is evident by the percentage ofitems containing some documentation or process deficiency that the commercial grade dedication process should be enhanced by training of personnel involved in nuclear procurement. A number of the discrepancies initially identified were a result of the procurement engineer not demonstrating a fundamental understanding of the EPRI guidelines and regulatory requirements. For example, specifying critical characteristics that are not measurable / identifiable attributes. In addition, one of NU's responses provides further evidence that NU procurement personnel may do not fully understand current industry guidelines and regulatory requirements (e.g., NU response to CGDF MPS-95-0214, Item # 1 I states " Lot homogeneity is considered by EPRI 7218, as a product purchased as a single line item and manufactured by the same manufacturer." This statement is not true nor does it convey the intent of EPRI NP-7218.)
Parsons will accept a Non-Discrepant classification for the remaining items, if an SL4 corrective action will consider the need for training using the standard course developed by EPRI which provides clear explanations of the generic procurement processes, and lessons learned throughout the nuclear industry, as a means ofimproving commercial grade dedication.
Discussion:
Parsons will close as a SL 4.
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l DATE: 12/4/98. Rev. O TlME: 2:00 p.m.
l DR 0735,DR-0736,~and DR-0772 Pressure Boundary P:scussion:
NNECo reviewed the subject instruments relative to HELB, scaffolding practices,2/1 concerns, etc. They feel the instruments listed in the DRs are OK, but NNECo has agreed to:
- 1. Review the MEPL Evaluations, 2.
Review Appendix A relative to the classification of such instruments, and
- 3. Revise the MEPL specification as required to address the concern in the future.
Parsons will close this DR as a SL 4. CR M2-98-2952 will track the corrective actions for all DRs.
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