ML20198N504
| ML20198N504 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/19/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9801210098 | |
| Download: ML20198N504 (69) | |
Text
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Surgont & Lundy ' c W/
kf Don K. Schopter EIIEcNo$
January 19,1998 Project No. 9583-100 Docktt No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Ac*. ion Verification Program United States Nuclear Regulatory Commission Attennon: Document Control Desk Washing'on, D.C. 20555 I have enclosed the following thirty-one (31) discrepancy repons (DRs) identified during our review actititics for the ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.
DR No. DR MP3 0167 DR No. DR-MP3-0829 DR No. DR MP3-0402 DR No. DR-MP3-0839 DR No. DR MP3-0437 DR No. DR-MP3-0844 DR No. DR-MP3 0680 DR No. DR MP3-0850 DR No. DR-MP3-0681 DR No. DR-MP3-0851 DR No. DR MP3-0710 DR No. DR-MP3-0852 DR No. DR MP3-0716 DR No. DR MP3-0853 DR No. DR-MP3-0759 DR No. DR-MP3-0856 DR No. DR.MP3.:1767 DR No. DR-MP3-0865 DR No. DR MP3-0803 DR No. DR-MP3-0890 DR No. DR MP3-0809 DR No. DR-MP3-0891 DR No. DR-MP3-0814 DR No. DR-MP3-0892 DR No. DR-MP3-0821 DR No. DR-MP3-0893 DR No. DR-MP3-0822 DR No. DR-MP3-0895 Dh No. DR-MP3-0807 DR No. DR-MP3-0911 ,
DR No. DR-MP3-0941 y 9001210098 900119 P" " " " = upng!I.il Lp 55 Dst Monroe Street
- Chicago, IL 60603-5780 USA = 312 269 2000 J
4 United States Nuclear Regulatory Commission January 19,1998 Document Control Desk Project No. 9583100 Page 2 I have alto enclosed the three (3) DRs for which the NU resolutions have been reviewed b"t not accepted. S&L comments on these resolutions have been provided.
DR No. DR MP3-0143 OR No. DR-MP3 0161 DR No. DR-MP3-0291 Please direct any quemions to me at (312) .o9-6078.
Yours very truly, f
%.~x ~
D. K. Schopfer i Vice President and ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/1) NU mWavpwen93rvrol194 &c
4 DR No. DR 4AP3 0167 l Northeast UtH6 ties ICAVP Ministone Unit 3 Discrepancy Report Review Group: Opershons & Maintenance and Testing DR VALlo Review Element: OpershnD Procedure PotentW Operabany issue Diecipline: Operatens Q y,.
D6ecrepancy Type: Teet implementsten (p) No SystemProcess: Oss NRC Signinconce level: 4 Date faxed to NU: y Date Published: 1/2296 Dioct*Peacy: IST Valve Timing Testing Appears To Not Be in Accordance With Standard lindustry Practice.
De*cription: The following are excerpts taking from various references which provide guidance for Inservice Testing of Power-Operated Valves at Nuc ear Power Plants. This information should have been used in the development of the procedures for inservice Valve Testing.
- 1) Section 4.2.2 of NUREG 1482,' Guidelines for Inservice Testing at Nuclear Power Plants *, states that 'the traditional method of stroke timing power-operated v0ves was to use stopwatches to measure the stroke time from initiation of the signal at the handswitch to the change in position-indicating lights (switch to light). The traditional method includes signal processing time from the switch to the valve actuator.
- 2) NRC Generic Letter 89-04, Supplement 1: 'Gttidance on Developing Acceptable Inservice Testing Programs", Attachment 1,
- Potential Generic Deficiencies Related to IST Programs and Procedures *, states:'The Code Intent with respect to measuring the full-stroke times of power operated valves is to verify operability and to detect valve degradation.'
- 3) ASME Section XI, Article IWV 3000 Test Requirements, IWV-3413 Power Opersited Valve states: " Full-stroke time is that time interval from initiation of the actuating signal to the end of the actuating cycle.'
- 4) Part 10, inservice Testing of Valves in Light Water Reactor Power Plants, OMa 1988, also defines ' full-stroke time', the same as ASME Section XI.
- 5) FSAR Section 6.2.2.4.2 states," Proper functioning of interlocks, time delays, alarms, instruments, and valves during both the spray mode and switchover to recirculation mode will be verified during a simulated system actuation test. Valve speed and positioning will be verified in the control room and by local visual observation."
Operations Procedure SP 3609.9, Quench Spray Valve Operability, and OPS Form 3609.91, OSS Valve Biennial Position Indication Verification, were reviewed to determine how the requirements stipulated in the references noted in items 1) thru 5) above were being met.
SP 3609.9 provides Instructions to verify quench spray system valve operability to meet the requirements of T/S 4.0.5 thrvalflanrw Daniilr8 ment @ incarvlem intnardian nrvi Tactinn Page 1 oT 3 Prtreed 1/1&8811M29 AM a
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ICAVP DR No. DR4P3 4167 Northeast utsties M astorm U Mt 3 Discrepancy Report of ASME Code Class 1,2, and 3, components), T/S 4.6.3.3 (Surveillance Requirements, Containment isolation Valvers), and ASME Boiler and Pressure Vessel Code,Section XI (and its appl 6 cable Addenda).
The methodology uses the plant computer or Control Room Operator with a Stop watch to measure the length of time between the open and close limit switch signals. This time is then used as the opening or closing time for the valve. Limit switch readings do not meet the intent of items 1 to 5 above, for the following reasons:
1, Limit switches on valves are usually set 5 to 15% before the end of valve travelin both the open and close direction.
- 2. The general nature of a limit switch is that it is an inaccurate device and not necessarily repeatable.
OPS Form 3609.91 does require an operator to observe the stroking of the valve locally, but his function is to only verify that the vah*e physical!y strokes. The acceptance criteria is that:
" Local position Indication matches Control Room indication for the open and closed position *. There is no measurement of the valve's physical stroke timefor this activity. Valve stroke time is determined in the same manner as for SP 3609.9.
Further review was conducted to determine if a 'compensat!on factor" was developed and applied for the actual stroke times from receipt of signal .o completed valve movement; none cauld be found. The fact that actual storke time from receipt of signal to end of valve movement is not being accurately measured as required by the applicable code or regulatory requirements outlined above is a discrepancy, it appears that the extent *f the concem is broader than for just the QSS valves, as evidenced by:
- 1) The purpose of Operations Procedure SP 36128.6, Containment isolation Valve Opcat41ity After Mahttenance, is
'To provide a cross reference of containment isolation valves and surveillance procedures'. This procedure does not provide for the measurement of the valves' physical stroke times.
- 2) Other valve stroke time procedures were also looked at and they used the Control Room Board valve indicator lights, which also use the valve limit switches for their input, for the valve timing.
Therefore this Discrepancy has the potential for effeding all MOVs and AOVs in the plant that must meet the IST
. requirements as described above, neview Vai6d invahd Nooded Date initiator: Ungeren. R. O O O imee imD8 VT L.ead: Bass, Ken Q Q Q O irt2ree VT Mgr: SchopW, Don K O O Prtreed 171&9611:o333 AM Page 2 of 3 s
1 i
O ICAVP DR No. DR MP3 4147 Northeast Uuudes
[ wustone unu 3 Discrepancy Report trisse
, IRC Chmn: $ @ ,Anand K D D l Date:
I
- NALID:
Dele: .
RESOLUTION:
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ns/~ ?; hientened by NUF (,) vos iG) No f;.m D6ecrepent Conetton?(,) Y.s @ No W%PenenetO v.e r#) No n-= unroe.ev.drO vos (h) No Rev6.w i
- I inllistor: Ungeren, R.
VT Lead: Bees, Ken VT Mgr: Schyter, Don K O O O ,
U wiC Chmn: sinen, Anand K
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SL Conenents:
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Printed 1/19,e ti23.35 AM PeDe 3 of 3 J
1 Northeast Utiitties ICAVP DR No. DRMP3-6402 Mitigane Unit 3 Discrepancy Report Review Group; syonem DR VAUo
"## 8*
- Posennel operatmy issue t-:+O a Mechanical DeeAgn n Diecrepency Type: Calcuishon (;,, g, systemerecese: 1,wp NRC Sientecance level: 3 Date Faxed to NU:
De*e Published: 1/22S6 D6ecrepency: Calc. 90-0691097 M3 contains errors in the database update DeectiP #on: The purpose of Calculation 90-0691097 M3, Rev 0, through CCN#4 was to update the small bore portion of the ,
comprehensive Millstone Unit 3 SWS Database which is used in several PEGISYS service water system models. Item 2 in the Calculation Workscope Summary, page 9, states that a benchmark flow calculation will be compared to results obtained for the
- CASE
- alignment in Westinghouse Calculation FSE/SS-NEU 1956 (dated 7/1/93), which later became NU Calculation 90-0691116 M3 (dated 5/18/95).
The remaining portion of this Discrepancy Report sites specific discrepancies in the calculation reviewed. The examples given are not an exhaustive list of those found, but rather used to illustrate the types of discrepancies found.
Page 49, Section 6, Part B, item i states that nodes were placed at the entrance and exit t 'nges of each component, including heat exchangers. The nodal diagram on page 13 does not contain nodes at the inlet or outlet of the CCP, CCS, HVK and RSS heat exchangers.
On page 67, the component fUD for the HVQ' ACUS 1 A,1B,2A,28 heat exchangers is listed as 11.12.
Note (3) for this section references calculation 90-0691116 M3.
Page 33 of the referenced calculation lists the fUD value for these heat exchangers to be 11.28.
Design input 11, page 12 of calculation 90-069-1116 M3 states that when pumps P3A and P3B are tumed off for the CASE alignment, they introduce additional resistance in the pipirg system. The additionalloss, K=ftJD, for pumps P3A and ,338 being tumed off was determined to be 52.8 by calculation FSE/SS-NEU-1576. This was addressed in the CASE alignment of calculation 90-069-1116 M3, but was neglected in the benchmark run of calculation 90-0691097 M3, This additional fUD should have been displayed for pathways 106-109 and 106-107 on page 99 of calculation 90-069-1097 M3.
Some of the heat loads identified on page 67, do not agree with the heat loads in the printout of the benchmark run. The heat load for HVK*CHL 1 A,B is listed as 3,275,387 Btu /hr on page 67, but is displayed as 6,315,400 Btu /hr on page 95, the benchmark run printout. The heat load for HVQ' ACUS 1 A,B is listed as 338,750 Blu/hr on page 67, but is displayed as 677,500 Blu/hr on pages 96 and 97, The heat load for HVQ'At.~S2A B is listed as
. 387,500 Btu /hr on page 67, but is displayed as 775,000 Blu/hr on Prtnied 1/199811:05.34 AM
'--s' ' ' y' Pepe 1 of 3 J
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M No, M MP3 4402 Northeast utsties ICAVP milistorm Unit 3 Discrepency Report To update the small bore portion of the PEGISYS SWS database, isometric drawing were used to generate piping takeoffs. The pl#ng takeoffs were then summarized in this calculation corresoponding to the nodil diagram established for the PEGISYS SWS model. The piping takeoff summaries were subsequently input to the PEGISYS SWS database (filename =
NEUSWS). The review of this calculation did not include a comprehensive review of the database updating process, however, a representative sample was reviewed and found to contain discrepencies. Examples are given below.
Errors were identified when summarizing the piping takeoffs because an inconsistent accounting method was used. When a node 5 located at a Tee, sometimes the Tee was included in the line upstream of the node and at other times, the Tee was included in the line downstream of the node. For example:
There is a Tee at node 1071 in the 6)e from node 107 1071, .
see page 122. In the piping summary for this line, page 197, the l Tee is not included, rather, it is accounted for in the line downstream of the Tee, in line 1071 1072. This is acceptable, however, the accounting method changed in path 224 2251, A Tee is located at node 2251, see page 135A. The piping summary for thia line, page 207, includes the Tee for 'he line upstream,224 2h ., This inconsistency led to incorrect piping summaries. The Tee at node 227, page 136, is included in the line upstream of this Tee,226-227, page 137. The line summary for 22719 on page 207 also includes this Tee, accounting for it twice. This inconsistency is also apparent for the line 2122, page 137, which accounts for a Tee at both the beginning and ending nodes of the line, t
Errors were also identified when transposing the piping takeoff j summaries into the PEGISYS database (fliename = NEUSWS)
- as described below.
L The pipe length for line 66-42 is listed as 39.5 feet in the piping summary on page 190. The pipe length for this line was transposed to the database as 1 foot, page 257.
l The olping summary for line 102108 on page 202 listed the elevation for nodes 102 and 108 as 21.3 and 44.8 feet, respectively. When transposed to the database on page 280, the elevation for nodes 102 and 108 were input as 19.50 and '
28.60 feet, respectively.
When the information for the (2) 90 deg 4D bends were l transposed to the database for pathway 79 23, page 315, the values for the angle and radius of the bends were switched.
The piping summary for line 22122'.1 on page 207 indicates
! there are (2) 45 deg elbows in the line. The line was entered into the database on page 321 with (4) 45 deg elbows, Note: Several SWP calculations used a previous version of this service water system database for PEGISYS modelina, such as PrWed 1/1W9e 11M36 AM Page 2 of 3 A
_. - - - . _ _ _ _ = - - _
0 ICAVP DR No. DR44P34402 Northeast Utilities Millstorm Unit 3 Discrepmcy Report FSE/SS NEU 1405 and 90-069-1116-M3. The discrepancies identifi4KI in the database may be applicable to other service water system calculations which used the database after the update by Calculation 90-0691097 M3. Examples include Calculation 90 0691065 M3, and those calculations developed after the PEGISYS model was converted to PROTO-FLO in the PROTO POWER / NU calculations 94 065,96-001,97-04197 035,97 001 and 97 ENG 01427D3. j Review Vaud invelld Needed Date initiator: Denne, B. J. O O t2tister O
VT Leed: Nort, Anthony A O O O 12/15"S7 O tar 23/s)
VT Mgr: rehopfer, Don K O O 1/16S8 IRC Chmn: Singh, Anend K O O O ooie:
INVALID:
Date:
RESOLUTION:
Previously iderElfled try Nu? (,) Yes (@ No NonD6ecrepentCondetionFO Yee ($ No meeclution Pend 6ng?O vos @ No meeoiuisonunresoeveerO vos @ No Review Acceptable Not Acceptelde Needed Date VT Lead: Nort, Anthony A b
VT Mgr: Schopfer, Don K b b ;
iRC Chmn: S6ngh, Anand K Dele:
SL Comments:
Printed 1/11W9611:05.30 AM Page 3 of 3 a
1
. l 4
DR Ne, DR.MP3 0437 f Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Review Oroup: Syelem DR VALID 8
Peterdial Opereldhty issue M a N Design 4) y,,
D6ecrepency Type: CdWen O No Systemerocess: "WP NRC Sierdacance level: 3 Date faxed to NU:
Date Putd6ehed* 1/22/96 06ecropeacyTLack of Documentation to Demonstrate Qualification of the SWS Model
Description:
GL 8913 Item 4 requires the licensee to confirm that the SWS will perform its intended safety function. In NU Letter 814406, NU stated that they were [in 1993]"in the process of completing quality assurance recommendations, sensitivity studies, et;., to fully qualify the (computer) model" that had been established for the system Pair Letter B14406, test!ng had been completed for Verification prior to issue of t:1e letter, in dispositioning requirement SWP 0320 to confirm NU compilance with this commitment relative to GL 89-13, the hydraulic model used by NU to respond to GL 89-13 was reviewed. This model is summrAzed in Calculation 90-069-1065-M3. This calculation summarizes the results from the Westinghouse PEGISYS model operating alignments from Calculation 90-0691116-M3, which utilized input from Westinghouse documents FSE/SS-NEU 1405 and 1488, plus updates to these documents, for the physical representation of the Millstone SW system. These FSE/SS-NEU documents could not be located in the NU calculation database, but were fumished by NU upon request for review. Calculation 90-069-1065-M3 contains the statement on page 6, paragraph 11 that "the model was not adjusted to match the field test data." No documentation could be found in any of these documents that confirmed validation of either the PEGISYS model or of the FSE/SS-NEU documents that formed the basis for the plant configuration used in the model. Qualification of the model, or confirmation that this had been completed, was not found to be
' addressed in later NU submittats to the NRC regarding GL 89-
- 13. Therefore it was not possible to confirm NU compliance with the commitment contained in Letter 814406 "to fully qualify the SWS model" from the documents in the review scope.
Review Val 6d Inve46d Needed Date l Initiator: TenerAet, J. L. O O O 12/22/97 VT Lead: Neri, Anthony A O O O 12/2297 VT Mer: Schopfer, Don K O O O 12r22s7 1RC Chmn: Singh, Anand K O O O it'8'88 Date:
INVALID:
! Date:
RESOLUTION:
- Previously identined by NU7 O Yes @ No Non D6screpent Condellon?O Yes (y) No l
Prned 1/19961107.1s AM Page 1 of 2 l
l A
4 ICAVP DR No. DR MP34437 Northeost Utilities l Milletone Unit 3 Discrepancy Report Resolut6cnPendeng7Q Yes (e' No ResolutionUnresolved?U Yes (W No Review Acceptande Not Me"," "- Needed Date VT Leed: Nort, Areony A VT Mgr: 6 Don K O 1RC Chmn: Singh, Anand K O Q O Date:
SL Comnente:
Prwed 1/19961127.18 AM Page 2 of 2 1
l l
Northeast Utilities ICAVP DR No. DR MP3 0660 Millstone unit 3 Discrepancy Report Review Group: Syelem DR VAUD Review Element: System Doolgn Diecipline: MechanicW Doeg" D6ecropency Type: Calculchon Om gg
~
SystemProcese: DGX NRC signWicence level: 3 Date faxed to NU:
Dele Published: 1/2298 Dmcrepency: Discrepancies in Calculation P(T) 1042 Rev. (blank)
D* cription: Calculation " Operating Conditions in the Emergency Diesel Generator Air Starting System (EGA)" calc. no. P(T)-1042, Rov.
(blank) was performed in 1934. Since, the EGA has been modified, primarily a dryer with an aftercooler has been added on the air compressor discharge side and the relief valve 3EGA-RV20A1,A2,B1,82 set point has been raised to 500 psig (as shown on the system PalD's). This significantly changes system operating conditions. The scope of the calculation has been changed by changing piping configuration, and added line numbers. More specifically, following discrepancies between the calculation and current system configuration were noted:
- 1. Objective of this calculation is to determine the operating pressures and temperatures of EGA. The piping considered in the calculation does not match the off skid lines as listed on the EGA Line List and as shown on the system P&lD's (EM-1168-25 and EM-116D-5). The calculation does not include lines with sequentialline numbers 60 and beyond (lines 60,61,62,63,64, 65,86,87,88,89,90, and 91 are ASME Section ill, Class 3); for the SDP Condition i lines with sequential line number 44 and beyond are not included (page 4 of the calculation).
- 2. In this calculation the relief valve 3EGA RV20A1,A2,B1,82 (on the air compressor discharge) set point is considered to ba 450 psig (page 5 of the calculation). Since the calculation was completed the relief valve set point has been reset at 500 psig (as shown on the system P&lD). This higher relief valve set point will affect maximum operating pressure and, consequently, operating temperature for piping upstream of the air receiver tank for operating modes due to an operator error or a control component failure. This willimpact calculation SDP Conditions 3 (p. 8), and 4 (p. 9).
- 3. During the air receiver tank charging operation mode (SDP Condition 2, page 5 of the calculation) the compressed air leaving the air compressor at high temperature normally passes through the aftercooler and the dryer before entering the air receiving tank. The aftercooler reduces air temperature to 130 degrees F max. (SWEC Spec. 2520.300 730, Add.1; per this Specification, Section 3.5, the maximum inlet air temperature for air dryer components downstream of the aftercooler is 130
' degrees F). Thus, during normal air charn% operation, the lines with line sequential numbers 1,3,5,11, w . d 15 will see air operating temperature of 130 degrees F max. In this calculation, however, for this mode of operation the operating temperature for lines between the dryer and the air receiving tank is set at g y 576 P;p= F, m::tum : ptd temg:tum of 2 !:gg ,
a
No theast Utilities ICAVP DR No. DR MP3 0640 umstorm unk 3 Discrepancy Report the air compressor at 425 psig. (The system design allows for bypassing the dryer via normally closed valve in the bypass line.
Under such condelions, the above listed lines could be exposed to temperatures of the air exiting air compressor However, this ,
mode of operation is not addressed in the calculation.)
- 4. No supporting justification is provided in the calculation or by reference for the number of cycles for SDP Conditions 3,4, and 5.
- 5. Air compressor discharge relief valve is OA Cat. 2 (per PDDS database). On pages 5 and 10 of the calculation the valve is identified with valve number 3EGA*RV20A1,*RV20A2,*RV2001,
'RV20B2.
Review vand invalid Needed Date initiator: Obersnel,Bojen. O O O 12r2ss7 VT Leert: Nort, Anthony A O O O 52/is97 VT Mge: Schopfer, Don K @ Q Q 12/2397 1RC Chmn: Singh. Anand K O O O sitrise Dete:
IW Allo:
Date:
REsOLLmON:
~
Ptsviously identified by NU7 O von (*) No NonD6ecrepentCondet6on?O vos (V) No Resolution Pendmg?O vee (6) No Resonutionunresoeved?O von (*) No Review initietor: (none)
VT Lead: Nort, Anthony A O O O vi m r:e senope.r, Don K O O O ,
IRC Chmn; Singh, Anand K sL Comments:
Printed in b9011 o9.26 AM Page 2 of 2 J
Northeast UtilRies ICAVP DR No. DR-MP3 0680 Milistone Unit 3 Discrepancy Report Review Group: system DR VALID Potential Operaldiity issue Diecipline: Mechanical Des
- D6ecrepancy Type: Calculeuon O v.
@" No SysterrvProcess: DGX NRc Signincance level: 3 Date faxed to NU:
Date Published: 1/22S6 D6screpency: Discrepancies in Calculation P(T) 1042, Rev. (blank)
Ductlption: Calculation " Operating Conditions in the Emergency Diesel Generator Air Starting System (EGA)', calc. no. P(T)-1042, Rev.
(blank) was performed in 1984. Since, the EGA has been modified, primarily a dryer with an aftercooler has been added on the air compressor discharge side and the relief valve 3EGA-RV20A1,A2,B1,B2 set point has been raised to 500 psig (as shown on the system PalD's). This significantly changes system operating conditions. The scope of the calculation has been changed by changing piping configuration, and added line numbers. More specifically, following discrepancies between the calculation and current system configuration were noted:
- 1. Objective of this calculation is to determine the operating pressures and temperatures of EGA. The piping considered in the calculation does not match the off skid lines as listed on the EGA Line Lis,t and as shown on the system P&lD's (EM-116B-25 and EM 116D-5). The calculation does not include lines with sequentialline numbers 60 and beyond (lines 60,61,62,63,64, 65,86,87,88,89,90, and 91 are ASME Section Ill, Class 3); for the SDP Condition 1 lines with sequentialline number 44 and beyond are not included (page 4 of the calculation).
l 2. In this calculation the relief valve 3EGA RV20A1,A2,B1,82 (on the air compressor discharge) set point is considered to be
- 450 psig (page 5 of the calculation). Since the calculation was i completed the relief valve set point has been reset at 500 psig l (as shown on the system P&lD). This higher relief valve set l point will affect maximum operating pressure and, consequently.
l operating temperature for piping upstream of the air receiver tank for operating modes due to an operator error or a control component failure. This willimpact calculation SDP Conditions
- 3 (p. 8), and 4 (p. 9). l l
- 3. During the air receiver tank charging operation mode (SDP l
Condition 2, page 5 of the calculation) the compressed air leaving the air compressor at high temperature normally pass through the aftercooler and the dryer before entering the air receiving tank. The aftercooler reduces air temperature to 130 degrees F max. (SWEC Spec. 2520.300-730, Add.1; per this Specification, Section 3.5, the maximum inlet air temperature for air dryer components downstream of the aftercooler is 130 '
degrees F). Thus, during nonnal air charging operation, the lines l with line sequential numbers 1,3,5,11,13, and 15 will see air j operating temperature of 130 degrees F max. In this calculation, l however, for this mode of operation the operating temperature l for lines between the dryer and the air receiving tank is set at PrWed in94e 11:10:10 AM hof2 L
l l
! J
Northeast Utilities ICAVP DR No. DR MP3-0640 Mmetone unit 3 Discrepancy Report i the air compressor at 425 plig. (The system design allows for bypassing the dryer via normally closed valve in the bypass line, Under such conditions, the above listed lines could be exposed to temperatures of the alt exiting air compressor. However, this mode of operation is not addressed in the calculation.)
- 4. No supporting justification is provided in the calculation or by reference for the number of cycles for SDP Conditions 3,4, and 5.
- 5. Air compressor discharge relief valve is QA Cat. 2 (per PDDS database). On pages 5 and 10 of the calculation the valve is identified with valve number 3EGA*RV20A1,*RV20A2,*RV20B1,
- RV2002.
Review Vaind invalid Needed Date initiator: Obersnel,Bojen. O O O 12/2/97 VT Leed: Nort, Anthony A O O O $2/iss7 VT Mer: ScitA. Don K O O O $2/22s7 IRC Chmn: Singh, Anand K Q Q Q tt17/9e Date:
INVALID:
Date:
RESOLUTION:
Prev 60usly identined try NU7 Q Yee @ No NonDiecropontCondnion70 Yee (#1 No ResolutionPend6ng70 vos @ No Resoeunionunresoeved70 vos @ No Rev6ew gg g Acceptable Not Acc.pa.haa Needed Date VT Lead: Nort, Anthony A VT Mgt: Schopfer, Don K IRC Chmn: Singh, Anend K g
Date:
SL Commente:
l l
l l
l Printed 1/19se 11:10:14 AM Page 2 of 2 m
Northeast Utilities ICAVP DR No DR MP3-0441 Millstone Unit 3 Discrepancy Report Review Oroup: System DR VAUD Review Element: System Deelen g p
D6ecipline: Mechanical De"
D6ecrepancy Type: calculaten O vee gg Systemfrocess: HVX NRC significence levet: 3 Date faxed to NU:
Dole Putd6ehod' 1/22/96 Descrepency: MCC & Rod Control Area Cooling Load and Ventilation Calculations
Description:
During review of the Cooling load and ventilation calculations for the MCC & Rod Control Area Air Conditioning System discrepancies regarding the loads and airflows were identified.
References:
- 1. Calculaticn P(B) 1184, Rev. 0
- 2. Calculation P(B) 1129, Rev. 2 3, Calculation P(B) 1129, Rev. 2, CCN 1
- 4. Calculation P(B) 1129, Rev. 2, CCN 2
- 5. Calculation P(B) 1129 Rev. 2, CCN 3
- 6. P&lD EM 148A 24
- 7. Duct drawing EB-45H 12
- 8. Duct drawing EB-45M-9
Background:
Calculation P(B) 1184 evaluates the affect of a 6"x2" hole in the 3HVR*ACU1 A Jupply duct on system performance.
Calculation P(B) 1129 determines the cooling load and ventilation requirements for the MCC and Rod Control Area Air-Conditioning system.
Air conditionMg units 3HVR*ACU1 A & 1B prtalde cooling for the east and w9st MCC & Rod Control Areas in the Auxiliary Building as shown on P&lD EM-148A. >
I Discrepancies:
l
- 1) The hole in the supply duct is caused by a missile from fan 3HVR FN4A,3HVR FN48 or 3HVR FN5 which are located near the 52" x 28" supply duct to the east MCC & Rod control area on elevation 66' 8" of the auxiliary building. The location of the fans
- and duct are shown on drawings EB-45H 12 and EB-45M-9.
l Calculation P(B)-1184 determined that 428 cfm would be lost t
through the hole in the ductwork in evaluating the impact the hole in the ductwork would have on system performance the calculation considered the effect on overall system performance
, Instead of the effect it would have on the east MCC & Rod l Control Area.
- 2) Calculation P(B) 1184 was not revised when calculation P(B)-
1129 was updated to evaluate lower than design altflow to the l
east MCC & Rod Control Areas with 3HVR*ACU1B running, l
- 3) The supply air lost through the hole in the supply duct on elevation 66' 6" of the auxlhary building will result in air inrtitration Intn thm nrane marvad hv AHVR*.AC1A/18 ThismulcL.
Printed 1/1M611:13 52 AM Pope 1 or 2 J
Northeast Utilitios ICAVP DR No. DR-MP34641 Millstone UnN 3 Discrepancy Report increase the cooling load on the system since the temperatures in the surrounding eqas have a higher design temperature.
Calculations P(B) 1129 and P(B) 1184 do not address this impact on the room cooling loads,
- 4) Calculation P(B) 1129 takes credit for l'est loss to auxiliary building ductwork rassing though the MCC & rod control area.
This is not valid for accident conditions when the non-safety- !
related fans (3HVR HVU2B and 3HVR FN11) associated with l this ductwork are not operating. i Review Voad invJd Needed Date inatiator Stout, M D.
O O O i2tiiis7 VT Leed: Neri, Anthony A y- O O 52tias7 VT Mgr Schopfer, Don K O O 52/23,7 O
IRC Chmn: Singh, Anand K O O O iitrios Dei.:
INVALID:
Date:
RESOLUTION:
Previously identitled try Nu? O Yee ? No Non D6ecrepent Constion?Q Yes @ No ResolutionPending70 Yes (!)No Mesolutionunrosoeved?O vos (#)No ,
Review A-:- ;':": Not A--:7-- ": Needed
^
Date VT Leed: Nort, Anthony A VT Mgr Schopfer, Don K IRC Chmn: Singh, Anand K O O O Date: ,
st Commente:
- Printed i/11W96 ii:13.56 AM Page 2 or 2
ICAVP DR No. DR MP3-0710 Northeast Utilities
- Millstone Unit 3 Discrepancy Report noview oroup: syeinn DavAuo 3I Potential Operabany issue Diecipune: Mechee lDesen g y, i D6ecrepency Type: Conculation
@ No SysteeWProcess: RSs NRC Significance level: 3 Deee faxed to NU: l Date Published: II22/96 06screpancy: Basis for RSS Pump Performance Requirement for Cold Leg / Hot Leg Recirculation Modes of ECCS D*ecription: FSAR Figure 6.31, " Safety injection / Residual Heat Removal System Process Flow Diagram", indicates that the RSS pumps must meet the following two performance requirements:
- 1. One RSS pump atinged to one train of HHSI during ECCS Mode B, Cold Leg Recirculation, must deliver at least 131p opm at 206 psig to the suction of the SlH and CHS pumps (REQ-MP3-RSS-0867).
- 2. One RSS pump alinged to one train of HHSl during ECCS Mode C, Hot Leg Recirculation, must deliver at least 2341 gpm at 160 psig to the SlH pump suction and 170 psig to the CHS pump suction (REQ-MP3-RSS-0873).
No analytical basis was found for the RSS pump performance requirement for the cold leg / hot leg recirculation modes of ECCS.
Westinghouse Letter NEU 562 (3 2173) transmitted ECCS piping resistance criteria. Westinghouse Letter NEU-1693 (113-
- 75) transmitted the results of a preliminary ELCS hydraulic analysis. Calculation P(R)-982, Rev. O confirms that the ECCS piping system design conforms to the criteria of Westinghouse Letter NEU 562. Calculation US(B) 245, Rev. 0 (and CCNs 1,2 and 3) develops the design basis model for the ECCS hydraulle network (the ECCS system from the RWST and sump to the RCS cold legs). Calculation US(B) 311. Rev. O employed the US(B)-245 hydraulic modelwith the 10% degradation of ECCS pump head allowed by the IST program. It calculated the design basis Min. ESF ECCS flows for injection mode (including RSS spray flow). US(D)-311 also calculated the dugn basis Min.
ESF ECCS flows for cold leg recirculation mode.
For the cold leg recirculation mode analyzed in US(B)-311, Rev.
O, RSS pumps supply water to the HHSI pumps and directly to the RCS through the LHSI cold leg injection lines (via the 3SIL*MV8809A/B valves). This mode of operation is no longer part of the ECCS system design. According to FSAR Table 6.3-7, R'4R r, sump cold leg in}ection valves 3SIL*MV880gA/B are closed prior to manual ECCS suction switchover (REQ-MP3-RSS-0225 and RSS-0265). Thus, there no longer is any LHSI function for the RSS pumps. CCN 1 to US(B)-311 recongnizes this fact and deletes the hydraulic analysis of ECCS cold leg recirculation mode (Design Basis Summary Document 3DBS-NSS-003 still contains data from the deleted portion of US(B)-
'H1 ean f)R.MD'Ln7A71 hio nihar hydrantir annivele
' ' hac hamn Printed 1/19/9611:14 de AM Page 1 of 3
ICAVP DR No. DR4P3 0710 Norttwa:3 Utilities Ministorm Unit 3 Discrepancy Report found which addresses ECCS Mode B, cold leg recirculation.
No calculation has been located which demonstrates that the RSS pumps can deliver the design basis flow of 1310 gpm to each train of HHSI during the cold leg recirculation mode of ECCS. No calculation has been located which demonstrates that the RSS pun.,4 can deliver the design basis flow of 2341 gpm to each train of HHSl during the hot leg recirculation mode of ECCS.
No pre-operational test was found which proves the RSS pump meets it: performance requirement for the cold leg / hot leg recirculation modes of ECCS. The preoperational test. T 3306 P.
verified that the ccmbined HHSl/LHSI flow requirement could be provided by the RSS pumps during ECCS cold leg recirculation mode. According to UNS-5767 the RSS pumps in the as-tested configuration delivered a combined LHSI/HHSI flow of $250 gpm. UNS-5767 determined that this flow was great enough to raise a concem about RSS HX tube vibration.
No test has been located which demonstrates that one RSS pump can provide the required 1310 gom to each train of HHSI for the cold leg recirculation mode of ECCS. No test has been located which demonstrates that one RSS pump can provide the required 2341 gpm to each train of HHSI for the hot leg recirculation mode of ECCS.
It is probably true that the flow required to support the combined operation of the HHSl and LHS! flow paths is less than the flow required to support operation of the HHSI alone. However, no such evaluation has been located. This discrepancy should be resolved before DCR 97045 is closed-out.
Documentation of the NPSHa available to the HHSl pumps from the sump /RSS path is addressed in DRMP3-0712.
Review Valid invalid Needed Date O i2/11/97 initiator: Weholand, J. F. O O VT Leed: Nort. Anthony A Q Q Q 12/17/97 VT Mgr: Schopfer. Don K O O O $2r23s7 IRC Chmn: Sin 0h, Anand K O O O $/17/88 Date:
INVALlo:
Date:
RESOLUTION:
MJM r";identined toy NU7 U Yee () No NonD6screpentConditiontU Yee @) No ReeosutionPending?O vos @ N. Ree iuiionunresoeve47O vos @ No Review ACCePtolde Not Acceptable Needed Date gg,,, p VT Leed: Nort. Anthony A O O O me .m O O O Printed 1/1W9611;14 53 AM ~ ' Page 2 or 3 a
. 4 ICAVP DR No. DR MP3-0710 NortheCst UtHMies muotone unn 3 Discrepancy Report IRC Chmn: Singh, Anand K O O O O O O Date:
SL Comments:
l 4
i l
l l
Printed 1/1EW9611:14.54 AM Page 3 of 3 J
1 ICAVP DR No. DR MP34716 Northeast Utilities Millstone Unit 3 DIScrepaticy Report Review o,.up: s,eiem DR vAuo Revlow Element: system Deegn D6eciphne: N Dwign O Yn Diecropency Type: Conculaten
% No
~
systemProcess: Oss NRC Mme level: 3 Dato Faxed to NU:
Dele Published: 1r22/96 D6 crepency: Instrument error inferred in FSAR Sec 6.3.2.8 differs from that in j calculation 3451B01 1232.
Ducript6on: FSAR Section 6.3.2.8 states that:
- 1. Initiation of switchover is conservatively assumed to occur at the Refueling W.1er Storage Tank (RWST) low-low level setpoint wtth allowance for negative instrument error (tank elevation = 23 feet 5 inches).
- 2. When instrument error at this setpoint is considered, the volume of water available for core injection is reduced to 605,000 Gallons from 646,000 gallons, a difference of 41,000 gallons..
According to setpoint calculation 3451801 1232 Revision 0, the lowest level at which the RHS pump can take suction from the RWST is the low-low level trip setpoint of 25' 5", m'nus the setpoint error / drift of 28" (RHS pumps trip on low-low RWST level).
The volume of RWST water equivalent to a 28" negative instrument error is more than the 41,000 gallons identified in the FSAR.
Based on similar discrepancies identified in Discrepancy Reports DR MP3 704 and DR MP3 373, the FSAR assumes a different instrument error than calculations 451B01 1232 Revision 0, US(B)-295 Revision 5, and P(R)-983 Revision O.
Review vend invalid Needed Date init6etor: Feingold, D. J. O O O 2/i7/97 VT Leed: Nort, Arnhony A O O O 12ii7m7 VT Mgr: Schopfer, Don K O O O 122397 Q 1/1746 IRC Chmn: Sin 0h, Anand K Q Q Date:
INVALID:
Dele:
RESOLUTION:
previously identitled by Nu? O Yes @ No NonD6ecrepentConetton?Q Yes @ No Reeduuanrenens?O va @ No RuohdonUnreedved?O va @ No Review Acceptable Not Acceptable Needed Date gg VT Leed: Nort, Arthony A Printed 1/199611:16:25 AM Page 1 of 2
t ICAVP DR No. DR-MP3 0716 Northeast UtHRies
- Minstone unM 3 Discrepancy Report VT Mgri Schapter Don K O -
, j IRC C# wen: Singh, Anand K O O '
Date:
SL Cortunents: l 1
l l
Prtnied II1MI611:16:29 AM Page 2 of 2
- -. _ ~ . . , _ . _ . .
Northeast Utiliti9s ICAVP DR No. DR44P3M89 milistone Unit 3 Discrepancy Report Review Group: Opershone & Mesnlonence end Testy DR VALID Review Element: Test Procedure
%: Opershone Diecrepency Type: O A M & T Procedure O va g-systemProcese: QSs NRC significence level: 4 Date faxed to NU:
Date Putdiohed: 1/22/98 P- , ay: Deficiencies in C.SS Procedures SP 3609.1 and SP 3609.2 Deecripuen: 1. Step 4.1.5 of both procedures states: " Verify 3QSS*P3B*. It sppears that this step should refer to the "A" Pump in Procedure SP 3609.1. Though this appears to be a ' typo', it could lead to misunderstandin0 and confusion to an operator enhancing the opportunity for an error.
- 2. There is no Section/ Attachment to these precedures which allows for the Emergency Condition Restoration from the Quench Spray Pump Operational Readiness Test
- Condition', as ,
was included in the Containment Recirculation Pump Operational Readiness Tests. It appears that this would be of a benefit to minimize confusion during a CDA or St.
- 3. Step 4.3.1 appears to serve no function in the proceduro.
The step should be deleted or the procedure should be enhanced by adding more steps te make the procedure more functional as explained below:
Step 4.3.1 is the only part of Section 4.3 that mentions testin0 the opposite train.
There are no other actions to be taken.
There is no reference as to which step to enter the opposite Tral.Ts procedure at.
There 4. 3 time limit as to how long the RWST RECIRC PP'S may be in " PULL TO LOCK
- In Step 4.3.2, when that step is skipped per Step 4.3.1, S&L considers the above items to be discrepant.
Review Valid travel 6d Needed Date 12/22,97 inMistor: Ungeren, R. O O O VT Lead: Bees, Ken O O O 12/2497 O ir12/9e VT Mer: Schopter, Don K O O IRC Chmn: Singh, Anand K Q Q Q 1/17/9e Date:
l INVALID:
Date:
RESOLUTloN.
Previously identHled by NU? O Yes (9) No NonD6ecrepentCondit6on?O Yes NI No Resolut6cn Ponding?O vos (GD No ResolutionUnresolved?O Yes @ No R. view Acceptable Not Acceptetne Needed Date
,,, , g ,n ,)
VT Leed: Bees, Ken O O O VT Mgr: Schophr, Don K IRC Chmn: Singh, Anand K Printed 1/19/9611:27:23 AM Pope 1 of 2 l
Northeast Uti4Nies ICAVP PR No. DR44P3-0759 mm unn 3 Discrepancy Report j I
- . _ . . _ . - ~ "
O O O Date:
St Conenente:
I I
l
^
i t
PrWed 1/194611:27.26 AM Pc2W2
ICAVP DR No. DR MP3 4767 Northeast Utilities Miiisione Unit 3 Discrepancy Report )
Review oroup: system DR vu.iD m Elemene se W ,,,,,,,,o,,,,,,,,y,,,,
re. 2. usenenic.i c=wn O vos i Discrepancy Type: Lloonsin0 Docu' vent
- No SystemProcess: Rs3 NRC %acance level: 3 Date faked to NU:
Date putdiet.ed: 1/22Se D6.crepancy: Use of 1187 gpm as the RSS Flow Supplied to the HHSI Pumps for ECCS Cold Leg Recirculation Mode Dacri Pt60n: Sections 8.2,8.3, and 12.2.2 of 3DBS-NSS-003, Rev. O require the RSS system to supply a minimum of 1187 gpm to the HHSI ,
pumps during ECCS Mode B, Cold Leg Recircirculation (REQ.
MP3-RSS-0417,0527, and 0528). This requirement is based on Calculations US(B)-253,266,273 and 342.
US(B) 342, Rev.1/CCN 1, references a telephone conference memo from Westinghouse Fluid System's Dob Magee, dated 1-28-86,
- Safety injection Flows from the HHSI and Charging Pumps.' This telephone memo states that the total flow for the ECCS cold leg recirculation mode is 1187 gpm per train. US(B)-
342 uses this flow to determine the RSS heat exchanger UA for min. ESF (Case 3) and max. ESF (Case 4).
Calculation US(B)-253, Rev. 4, also references the telephone conference memo fro.n Westinghouse Fluid System's Bob Magee, dated 128-86 as the basis for assuming a 1187 gpm flow for each train of ECCS for the cold leg recirculation mode.
US(B)-273 Rev. 5 uses 1187 gpm for the min. ESF flow for ECCS cold leg recirculation mode in the design basis analysis of containment pressure and temperature after a postulated LOCA.
The US(B)-273 cites US(B)-342 and 253 as the references for this flow.
US(B) 266 Rev. 2 uses twice 1187 gpm, or 2374 gpm, for the max. ESF flow for ECCS cold leg recirculation mode in the design basis analysis of containment pressure and tempcrature after a postulated MSLB. The US(B)-266 cites US(B) 342 and 253 as the references for this flow.
RSS hydraulic calculations US(B)-245, Rev. 0/CCN 3 ar d US(B)-
311 Rev. 0/CCN 1 do not provide information on this operating mode. No basis, except the Westinghouse telephone memo, was found for using 1187 gpm as the flow for each train of HHSI during ECCS cold leg recirculation mode (see DR MP3-0710).
A telephone memo is not an appropriate basis for this type of information.
Review Valid invalid Needed Date initiator: Wakelend.J.F. O O O 12/12/97 VT Lead: Nori. Anthony A O O O 52/iss7 VT Mgr: Schopbr, Don K O O O irt2Se IRC Chmn: Singh, Anand K G O O 1'17/98 Printed b199811:2e 41 AM Page 1 of 2
i i .
Norttwest utiinies ICAVP DR No. DR MP3 0767 mm tone Unit 3 Discrepancy Report Dele:
1pWALID:
Date:
RESOLUTION: l l
Previously identdled by NU7 O Yes (#1 No Non06ectopentCondit6on?O vee '#) No l Resolution Pending?O vee (*> No Resoeuiionuarosoeved70 vee (i)No Review A-: '" " NM Acceptable Needed Date i l
Init6ator: (none) "
VT Lead: Nei, Anthony A VT Mgr: Schopkt, Don K 1RC Chmn: Singh, Anand K [ .
Date:
, SL Comments:
i t
t Printed 1/19S611:26 45 AM Page 2 of 2
_ _ - - . . . _ _ . . _ - _ _ _ - _ ~ - - - - . . - . - . . . . - - -.
Northeast Utilities ICAVP DR No. DR-MP3-0803 mitistone Unit 3 Discrepancy Report i Revlow Group: system DR VAUD EW. W W Petential Operately leaue Diecipline: Mechemcal Design - O yes '
Diecrepancy Type: CalcuWoon r#)No~
SysteWProceae: HVX NRC Significance level: 4 Dele faxed to NU:
Date Published: 1/22/98 Dmcrepancy: Calcul5iion 3-92-103-192-M3 Setpoint for 3HVR*TS45A1, B1, A2, B,t Descripuon: During icview of calculation 3-92103-192 M3 Rev 2, 'Setpoint for 3HVR*TS45A1, B1, A2, B2' the following discrepancies were identified.
- 1) On page 9 of the calculation the temperature rise across the exhaust fan was changed to 2.49'F from 2.42'F. Not all pages in the calculation were revised to reflect this change.
- 2) The temperatu. . Jr,e in the chardi n0 pump room (-13.4'F) is different from the temperature rise in the component cooling water pump room area (-14.9'F). The bulk temperatature rise for the system is -14.5'F. The calculation does not appear to address the effect this has on the selection of the alarm setpoints.
- 3) On page 7A, for the summer case, F6 (exhaust to outside) is equal to F13 (exhaust fan flow). The calculation uses a value of 14,800 cfm for F6 Instead of 26,600 cim. The calculation appears to be looking at the temperature eise with the dampers in the winter mode instead of the summer mode.
- 4) Calculation does not address impact of MCC & Rod Control Area Booster Pump arca on temperature sensed by l 3HVR*TS41 A2, B2.
Review Valid invalid Needed Date initletor: Stout. M. D. O O O 12/is97 VT Leed: Neri, Anthony A Q Q Q 12/1697
( VT Mgr: Schopfer, Don K O O O 52r2397 1RC Chmn: Singh, Anand K Q Q Q 1/1698 l Dei.:
INVALID:
Dele:
RESOLUTION:
Previously idenulled by NU? O vee (6 No Non D6ecrepent Condst6on?L) vos @ No ResoluuonPend6ngTO va @ No Renoiunon vareedved70 va @ No Review g Acceptable Not Acceptable Needed Date i VT Leed: Nori, Anthony A VT Mgr: Schopter, Don K IRC Chmn: Singh, Anand K Printed 111&9811:30.23 AM Page 1 W 2 l
ICAVP DR No. DR MP3 0803 ,
Northeast utsties Mastone unit 3 Discrepancy Report
_......_...__m g Dele:
r SL Comments:
t 5
PrHed 1/1h9611:3026 AM - Py 2 of 2 i
0 ICAVP DR No. DR MP3 0803 NortheaC3 Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR VALID Review Element: Syelem Design Emir *w: uschenical Design O Yes Diecroponey Type: Calcuestum
@ No
~
SystemProcess: HVX NRC Signescence leM: 4 Date faxed to NU:
Date Putdiohed.1/22/96 D6ecrepency: Calculation 3 92103-192-M3 Setpoint for 3HVR*TS45A1, B1, J A2,B2 i
Description:
During review of calculation 3-92103192-M3 Rev 2, 'Setpoint for 3HVR'TS45A1, B1, A2, B2' the following discrepancies were identified:
- 1) On page 9 of the calculation the temperature rise across the exhaust fan was changed to 2.49'F from 2.42'F. Not all pages in the calculation were revised to reflect this change.
- 2) The temperr ture rise in the charging pump room (-13.4*F) is different frum the temperature rise in the component cooling water pump room area (-14.9'F). The bulk temperatature rise for the system is -1*.5'F. The calculation does not appear to address the effect this has on the selection of the alarm setpoints.
- 3) On page 7A, for the summer case, F6 (exhaust to outside) is equal to F13 (exhaust fan flow). The calculation uses a value of 14,800 cfm for F6 instead of 26,600 cfm. The calculation appears to be looking at the temperature rise with the dampers in the winter mode instead of the summer mode.
- 4) Calculation does not address impact of MCC & Rod Control Area Booster Pump area on temperature sensed by 3HVR*TS41 A2, B2.
Review Valid inveild Needed Date initiator: Stout, M. D. O O O ' '/ SS7 VT Lead: Nort. Antnony A O O O 12/iae7 O O 12/2ss7 VT Mgr: Schopfer. Don K O 1RC Chmn: Singh, Anand K Q O O risse Date:
INVALID:
Date:
RESOLUTION:
Previously Identland try NU7 O Yes @? No NonDiecrepentCondition?Q Yee @ No ResolutionPending?O vos @ No Recoeuiionunr oev.d?O vos @ No Review Acceptable Not Acceptable Needed Date VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Srgh, Anand K Printed 1/1W9611:30.30 AM Page 1 of 2
perthe:st utilities ICAVP DR No. DR44P34803 Ministone unit 3 Discrepancy Report
-= - =._._.. , " - ~ "
O O O
, Date:
SL Corrments:
1 e
f ainted 1/194611242 AM Page 2 of 2 j
ICAVP DR No. DR-MP3 0809 Northeast Utilitie0
, MiiistOne unM 3 Discrepancy Report Review Group: Opershone & Mairtenance and Teobn0 DR VALO PotentialOperability lasue Discipline: Operettor" Discrepancy Type: Procedure trnplementation Om gg-System / Process: DGX M S IN'I'Y'l 4 Date faxed to NU:
Date Published: 1r22/98 Descrepency: Unable to confirm through procedurt review that an NRC commitment is satisfied, Ducription: Safety Evaluation Rep 3rt (SER) 9-64 committed to:
- 1. Monitoring the length of Dme that the diesel generators operate at no load or at low load (< 20% full load) conditions.
- 2. For each 24 hrs of no load or low load operation run the diese; for one hour at > 50% load.
A review of the operating procedures confirm that item 1 (above) of this committment is addressed in OP 3346A, " Emergency Diesel Generator" and OPS Form 3346A-13 "EDG - Data Sheet."
However, the review did not reveal how the station documents that the second part of the commitment that the diesel be run at
> 50% load is satisfied once it has been determined that the diesel has operated at the no load or low load condition. There is no place on OPS Form 3346A 13 to document that item 2 (above) has been satisfied to provide confirmation that the entire commitment has been met.
In add 3lca, the instructions in OP 3346A for filling out OPS Form 3346A-13 are vg imprecise by using the terms "prestart portion", " initial portion", " appropriate section", and " complete."
Since the steps in data sheet OPS Form 3346A 13 are not numbered or in sections titled "prestart ", " initial ", " appropriate",
it is unclear how the operators know what they must do.
Review Valid inval6d Needed Date initistor: Tamlyn. Tom O O O 12/29/97 VT Lead: Bass, Ken B 0 0 12rso/97 VT Mgr: schopfer, Don K Q Q Q 1/12/98 IRc Chmn: Singh, Anand K Q Q Q 1/17/98 Date:
INVALID:
Date:
RESOLUTION:
P eviously identifled by NU? O Yes (e) No NonDiscrepantcondition?O Yes @ No ResolutionPending?O ves @ No Resoiuiion unresotved70 ve. @ No Review Acceptable Not Acceptable Needed Date go,,
VT Lead: Bass, Ken Pnnted 1/19/9811:31:30 AM Page 1 of 2
Northe=t Utilities ICAVP DR Ns DR MP3-0809 l
Millstone Unit 3 Discrepancy Report.
. . . . ~ "
VT Mgr: Schosh, Don K O O O g
RC Chmn: Sept Anand K O O Date:
SL Comments:
PrWed 1/195611:31:34 AM Page 2 of 2
ICAVP DR No. DR-MP3-0814 Northeast Utilities Miiistone unit 3 Discrepancy Report Review Group: system DR VALID Potential OperatMty issue D6ecipline: Mechanical DesiD "
O va Discrepancy Type: Calculation gg SystemProcess: sWP NRC Signifkance level: 3 Date faxed to NU:
Date Published: ifa90 D6screpancy: Manufacturers Report required by ASME Section 111, Paragraph ND-3649 is not identified in PDCR.
Description:
PDCR 3-92-042,3-92 043 and 3-92-006 are for the replacement of expansion joint assemblies 3SWP*EJ18,3SWP*EJ1C and 3SWP*EJ1D in the discharge piping from the service water pumps, The existing expansion joints, as shown on Drawing No.
25212 29348-20, had bellows manufactured of Monel 400 (ASTM SB127) material. The replacement expansion joints, as shown on Drawing No. 25212 29348-36, have bellows manufactured of Inconel 625 (ASTM SB-443) material.
The P&lD, Crawing No.12179-EM-133A-26, shows that these expansion joints are installed in 30" diameter ASME Class 3 piping, Drawing No. 25212-29348-36 for the replacement expansion joints indicates that they are designed and fabricated to ASME Code, Section lil, Class 3,1974 Edition, Winter 1974 Addenda. The design requirements for Class 3 bellows expansion joints are found in Paragraph ND-3649 of the Code.
Subsubparagraph ND-3649.4(h) requires that the Manufacturer submit a report which demonstrates compliance with ND-3649.
The Seismic Qualification Review for the referenced PDCRs does not reference or identify a Manufacturers report and it does not provide any other basis for the qualification of the bellows.
Review Valid invald Needed Data initiator: Jahrson, Jay B O O 12iiers7 VT Lead: Neri, Anthony A B O O 12/iss7 12/23,97 VT Mgr: schopfer, Don K O O O IRC Chmn: singh, Anand K O O O 1'17/98 Date:
INVALID:
Date:
RESOLUTION, Previously identifled by NU? O vos @ No NonDiscrepentCondition?O vos @ No Resolubonpending?O ve. @ No Re.oeution unresoivea?O vs. @ No Review Acceptabie Not Acceptabie Needed Date VT Lead: Neri, Anthony A VT Mge: schof fer, Don K IRC Chmn: singh, Anand K g Date:
SL Comments:
i Prinirr " N 11:34.03 AM Page 1 of 1
. ICAVP DR No. DR-MP3-0821
! Nottheast Utilities ministone unit 3 Discrepancy Report Review oroup: system DRvAuD
"""* ""8*
- Potential operetmity tuu.
D6ecipline: Mechanical Desig" O va Descrepency Type: Drawing gg System / Process: DGX NRC signincance level: 3 Date faxed to Nu:
Date Putsahad. ir22/96 D6screpancy: Discrepancies for P&lD's EM 116B-25 and EM-116D-5 Descr5 tion: Review of the EGA system P&lD's EM-116B-25 and EM-116D-5 yleided following discrepancies:
- 1. Per NU (IRF-00993) a sizing calculation for EGA piping was not required. Although the off skid piping was supplied by NU, the piping was sized in accordance v.ith Colt industries schematic drawing Starting Air & Control Air Schematic, dwg. no.
2447.300-241-008. Review of this NU drawing (Rev. J) and Colt industries' OIM-241 schematic drawing 11869459 confirms that the NU provided piping was sized as shown on the vendor drawing. However, the P&lD does not match either schematic drawing. By comparison of the drawings it can be determined that the schematic drawing does not show the air dryer package, its bypass, the cross-tie between the two Starting Air trains (lines ,
3-EGA-750-5 3 and 3 EGA-75015 3), and hoses 3EGA* HOSE 1 A,1B,2A, and 28. In addition, a 1/2" takeoff from 3/8" compressed air line to the Air Tank 3EGA*TK3A/B supplying control air to Jacket water instruments and controls shown on the schematic is not shown on the P&lD's. The comparison also shows that the air compressor discharge relief valve setpoint is 450 psig un the schematic drawing, and 500 psig on the P&lD. This conditions indicate two discrepancies:
- System P&lD and the schematic draJ ing do not match, and
- Significant changor to the system r,.dy have required line sizing calculation o a pressure drop calculation, neither of which was found existing at time of the review.
- 2. Safety class change points are not shown at the point of safety class change. For instance: safety class change between line 3-EGA-E-84-4 and the check valve 3EGA*V4 should be shown at the valve inlet nozzle, and not on the line itself. Furthermore, as shown on the P&lD, the line number (Class 4 line) is shown on the Class 3 side of the safety class change point. The same is true for the equivalent safety class change points for the other three Starting Airtrains.
In addition, no safety class change is shown at the Air Receiver Tank drain valve (3EGA*V7, *V17, *V972, *V973) outlet, where the drain piping is apparently Class 4. The drala line downstream of the valve has no line numt 3r (which would identify pipe safety class), and the continuation drawing (EM-157A) does not identify pipe safety class either. However, the drain line continues into Misc. Floor Dr&s (DNF) system, where the first valves in the system, check valves 3DNF-V5 and 3DNF-V3 are non safety related.
Pnnted1119/9011:37.31 AM Page 1 of 2
ICAVP DR No. DR-MP3-0821 Northeast Utilities 1
Ministone Unit 3 Discrepancy Report components included in PDDS are not on the system P&lD's:
Excess flow valves 3EGA*EFV29A/B and isolation valves 3EGA*V978 and *V991.
- 4. Lines 3-EGA-500 73-4 and 3-EGA-500-50-4 on drawing EM-116D-5 are misnumbered as 3-EGA-500-69-4 and 3-EGA-30-4 respectively, as evident from the Line List . Also, the drain line continuation drawing for Air Receiver Tank 3EGA*TK2B should be identified as EM-157A instead of EM-1578.
Review Vahd invalid Needed D te initiator: Obersnel,Bojen. O O O 12r23/97 VT Leed: Nort, Anthony A B O O 12/20/97 VT Mgr: Schopfer. Don K Q Q Q 12r23/97 O 15/S8 1RC Chmn: Singh, Anand K O O Date:
INVALID:
Date:
RESOLUTION Prev 60uet; $ent6 fled by Nu? C) Yes @ No Non Discrepent Condition?O Yes @ No Resoludon Pending?O vos Ce) No Resoiuiionunreeoived70 ves @ No Review initiator. (rot,)
b(Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K O O O D.ie:
SL Comments:
Printed 1/10/9611:37:35 AM Page 2 of 2
ICAVP DR No. DR-MP3-0822 Northeast Utilities Miiistone unit 3 Discrepancy Report R.vi oroop: sysi.m mvAuD Potential Operat24ty issue Diecipline: Mechanical Design Om D6ecrepency Type: Drewing j' SystemfProcess: DGX NRC Signincance level: 4 Date faxed to NU:
Date Published: 1/2258
- D6ecrepancy: Discrepancies for P&lD's EM 116A 27 and EM 116C-12 Deecription: Review of the EGS system portion of the P&lD's EM-116A 27 and EM-116012 yielded following discrepancies:
- 1. Comparison of P&lD with the PDDS database resulted in following discrepancies:
- 3EGS*PS28A1 is found in PDDS, but could not be found on P&lD,
- 3EGS*Tl37A/B is safety related per PDDS, non safety related per P&lD,
- 3EGS*P3. Engine Sump appears on P&lD (15), but could not be found in PDDS. The same mark number is used for both diesel generators, that is on both P&lD's. Per equipment code it appears to be a number for a pump, although pump is not shown at that location; it is also in conflict with the Engine Driven Intercooler Water Pump number 3EGS*P3A/B,
- 3EGS*EG1A could not be found in the PDDS database.
- 2. Line 3-EGS-500 26-3(A-) on drawing EM 116A-27 is misnumbered as 3-EGS 500-22-3(B-). Line numt:et 3-EGS-500-22 3 is already assigned to intercooler retum line for diesel generator A (on the same drawing). In addition, the direction of this line in the Line List is erroneously describe 6 9s connecting to the hose 3EGS* HOSE 6B; the correct number for 0e r- r..w : ting hose is 3EGS* HOSE 6A.
sw Valid inve46d Needed Date 12/1e,97 initiator: Obersnel,Bolen. 8 O O VT Lead: Neri, Anthony A O O O 12/20/97 VT Mgt: Schopfer, Don K Q Q Q 12/23/97 Q 1/1698 BRC Chmn: Singh, Anand K Q Q Date:
INVALID:
Date:
RESOLUTION Previously identified by NU? U Yes (#) No Non Discrepant Condition?Q Yes (9) No Resolution Pending?O ve. @ No Reeosuisonunresoived?O Yes @ No Review Acceptable Not Acceptable Needed De,te VT Lead: Neri, Anttw.ny A VT Mgr: schopfer, Don K IRO Ctrnn: Singh, Anand K Daie-Printed */19/9811:39:07 AM Page 1 of 2
ICAVP DR No. DRMP3 0822 Northeast UtWties .
Millstone Unit 3 Discrepancy Report SL Comments:
1 I
+
i Printed 1/199611:39:10 AM Page 2 of 2
ICAVP DR No. DR-MP34407 l Northe:st Utilities l Miiistone Unit 3 Discrepancy Report Revtew Oroup: System DR VAUD Potentiel OpersbuRy issue Diecipl6ne: Other D6screpency Type: Component Date O Ya SystomrProcese: DGX Om NRC $6gnificance level: 3 Date Faked to fAl:
Date Putmehed: t/1096 D6screpency: Means for meeting commitment not identified
Description:
Section 8.3 of the FSAR contains the following statement. Safety-related equipment in all plant areas is either prc.dcted from automatic fire prote'llon effluents or, on the basis of test data, have demonstrated their operability in the environment that may be caused by the fire protection effluents.
Per item 453 in the annotaded SAR this is an open item;"Yet to review specifications for cable, equipment, etc., in CO2 areas -
TBD." This note indicates that CO2 effects will be evaluated.
However information cauld not be located which indicated that Halon effluent effects have been evaluated for those areas where Halon systems are installed.
Review Valid invalid Needed Date initiator: Rich, J. M. O O 52/1e/97 VT Lead: Nort, Anthony A G O 12/17/s7 VT Mgr: Schopfer, Don K G O O 2rza/97 O O $2rsitor IRC Chmn: $1ngh, Anend K G Dee:
INVALID:
Date:
RESOLUTION Previously identitled by NU? O Yes (*) No Non Descrepent condet6on?O Yes (#1 No Resolution Pending?O Yu @ No RuoM6onUnruolved?O Yu @ No Review initiator: (none)
VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Segh, Anand K O O O Date:
SL Consnents:
Printed 1/19tDe 12;ce 05 PM Page i of i
DR Na, DR-MP3-C829 Northe:st Utilities ICAVP Ministone Unit 3 Discrepancy Report Review Or> System DR VALIO Review Elemen System Design p
"'***"*"*""**'**" O ve.
Diecrepency Type: Component Deta
@' No System 9tocess: DGX NRC Significance level:4 Date faxed to NU:
Date Published: 1/22/98 Discrepancy: EGA Pipeline Data Discrepancy
Description:
Review of the EGA pipeline data per the Pipeline Checklist yielded following discrepancies:
- 1. Line List for the EGA piping contains desiga pressure and temperature data. No calculation was found that supports these data. Calculation for design pressure and temperature for EGA system was req;ested via RFi #MP701. NU reply IRF #00993 stated that the requested information was provided in the calculations P(T)-1042 and 3-92-102-263M(3). Calculation P(T)-
1042, ReV. O, " Operating Conditions in the Emergency Diesel Generator Air Start System (EGA)* documents operating pressure and temperature for various operating modes, but does not determine design pressure and temperature. Calculation no.
3-92102 263M(3), Rev. O, CCN 1," Emergency Diesel Starting Air System Design Pressure and Temperature" reviews consequences of raising air compressor relief valve set poln' from 450 psig to 500 psig on the affected portion of the EGA system from the air compressor to the air receiver tank. This calculation is classified "non-QA", and the only safety related portion of the EGA system included in it, is the piping from the air dryer to the air receiver tank. It is noted that the calculation no. SDP EGA-01342M3, Rev. 02, " Emergency Generator Air (EGA) Stress Data Package" lists the EGA system design conditions in a table on page 14 of the calculation; however, it references Line List as the source of the infom atiot1.
Review Valid InveWd Needed Date Inulator: Obers 4Bojen- 0 0 0 12/22/97 VT Leed: Neri, Anthony A B O O 12r2as?
VT Mgt: schopfer, Don K Q O O 12/23/97 IRC Chmn: singh, Anand K B D 0 1'15'98 Date:
INVALID:
Date:
RESOLUTION Previously identmed by NU? Q Yes @ No NonD6eovntCondMion?Q Yes @ No ResolutionPend6ng?O vos @ No Reeoiuisonunre.oived?O ve. @ No Review Acceptable Not Acceptable Needed Date g,gg.
VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Printed 1/19/9e 12:08:s5 PM Page 1 of 2
ICAVP DR N3. DR-MP3-0829 Northeart Utilities i Miiistone Unit 3 Discrepancy Report
_..._ "~-~"
O O O Date:
SL Comments:
P>inted 1/19/9812 0B_58 PM
. Page 2 of 2
ICAVP DR No. DR-MP3-0439 I Northeast Utilitle0 Milistone Unit 3 Discrepancy Report Review Group: Operatene & Maintenance and Teotng DR VALID Review Elensent: CorrectNo Acton Procese , ,
D6scipl6ne: Operetone Om Discrepency Type: CorrectNo Acton gg
~
System &rocess: HVX NRc Significence level: 4 Date faxed to NU:
Date Put:llehed: 1/22/9e 06ecrepency: Commitment Record System is not updated effectively.
Description:
S&L reviewed commitments that were made to the Nuclear Regulatory Commission (NRC) in 1984 and 1985. The *date of last change' to the commitment records was May 1997. The commitment records reference letters to the NRC that are either unrelated or incomplete.
Commitment Record (CR) 24578 requires verification of the system flow alte versus pressure drop during plant operation.
The CR notes that in a letter to the NRC dated July 13,1984, that *(1) the system flow rate and pressure drop will be verified at least once every 18 months and (2) the system fans are fixed-
' peed fans and the system flow rates against pressure drops will De vertfled during plant operation using the certified fan curves".
The CR references NRC letter A04258 Letter A04258 discusses
- Emergency Operating Procedures and the Control Room Design Review. This reference is not correct and the NU response to cMedive ar,tions in the Commitment Record System can not be vt <M.
Commitment Record 23439 and NU letter Bled iB state "that all QA Category I fire dampers requiring closure under system flow will be tested in place for closure under design flow conditions.
Any dampers which fall this test will be evaluated on a case-by-case basis to determine the best course of corrective action and modified accordingly". This letter was considered to be the final report but is incomplete with respect to stating if specific corrective actions were taken.
These commitment records were reviewed in May 1997 and are unacceptable. These are not isolated examples of concems with the Commitment Record System. S&L consider this to be a discrepancy.
Review Valed invalid Needed Date inttletor: Pleniewicz, FL G O O $2722/97 VT Leed: Bees, Kor. G O O i2t24S7 VT Mgt: Schopfer. Don K G O O tr 2.Se IRC Climn: 66ngh, Anand K Q Q Q 1/17/96 Dete:
INVALID:
Date:
RESOLUTION:
Previously identifled by NU? O Yes (9) No NonDiscrepentcondM6on?U Yes @ No Printed 1/196)e 12:00:47 PM Pege 1 of 2
ICAVP DR N2. OR-MP3 0839 Northe:st Utilities Ministone Unit 3 Discrepancy Report w
ResolutionPonding?O Yes (S) No Ree'Aution Unresolved?O Yes (*) No Review Acceptable M Acceptable Needed Me gy.
VT Lead: Bass,Kan O O O VT Mgr: Schopfer, Don K T'C Chmn: SW, Anand K Date:
SL Commmts:
1 Printed 11199612:00.51 PM - Peg ( 2 of 2
e ICAVP DR No. DR-MP3-0444 Northe:st UtilMies Millstone Unit 3 Discrepancy Report Review oroup: system DR VAuD Review Element: System Design p g Di.cipm.e: sinxus' ""
O v.
Diecrepency Type: Chm g Systemerocess: HVX NRC Significer,ce level: 4 Date faxed to NU:
Date Published: 1/22/96 D6scroponey: Duct Support Calculation Discrepancy Dacrission: We have reviewed duct support calculations for the following supports:
(1) CALC. # 12179-NP-(F)-Z545J-1221, REV. 5 (2) CALC.# 12179-NP(F)-Z60R 530-H005, REV. 3 (3) CALC.# 12179-NP(F)-Z545J-1235, REV. 2 Based on this review we have noted that the final " Normal &
shear stress
- Interaction check has not been performed.See the following examples:
(1) CALC.#12179-NP-(F) Z545J-1221, REV.5, PAGE #
15,16,17 & 18.
(2) CALC.#12179 NP(F)-Z60R 530-H005, REV.3, PAGE # 15.
(3) CALC.#12179-NP(F)-2545J-1235, REV.2,PAGES #
11,12,13 & 18.
Review Valid invalid Needed Date initiator: 10eic, N O O O 12iias7 VT Leed: Neri, Anthony A @ ] [ 12/19/97 0 ri2me VT Mgr: schopfer, Don K 8 0 1'$5S8 IRC Chmn: sin 9h, Anand K O O O Dei.:
INVALID:
Date:
RESOLUTION:
Previounty identitled by NU? - O Yes @ No NonDiscrepentCondition?O ves @ No Resolution Pendhg?O ves @ No Resoiutionunreceived?O vos @ No Review Acceptable Not Acceptable Needed Date VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh. Anand K O G Dei.:
SL Commente:
Printed 1/19/9612426 PM Page 1 of 1
_a ________ _ _ __ _ _ _ _ ._ . _ _ - - , -
ICAVP DR No. DR-MP3-0860 Northeast Utilities Millstotie Unit 3 Discrepancy Report Review aroup: symem DR vAuD Review Element: Test Procedure p ,
"'"""* ""' O Yee E= , - ;y Type: Procedure implementation @ No System /Proceee: DGX NRC Significesce level: 3 Date famed to NU:
Ode PutWehed 1/2290 D6ecrepency: Prcadures forload testing emergency DG use a loading range above that in the Tech Specs Deecription: Per Technical Specification Manuat Volume 1. Section 4.8.1.1.2, Paragraph a.6), during the monthly survelilance test it is required that the generator is gradually loaded in accordance with manufacturer's recommendations between 4800-5000kW and operates with a load between 4800-5000 kW for at least 60 minutes. The operating ban is meant as guidance to avoid routine overloading of the diesel.
In Procedures SP 3646A.1,' Emergency Diesel Generator A Operability Test" and SP 3646A.2, ' Emergency Diesel Generator B Operability Test," It states in Step 4.4.3.c that the generator be loaded over approximately 10 minutes to between 5000 and 5100 kW. The procedures contain a caution not to exceed 5100 kW to prevent exceeding the accident rating of 5310 kW and require that the Engineering Department be informed if the load is greater than 5100 kW (Step 4.4.5). This is outside the range set in the Technical Specifications.
it appears that either the procedure or the Technical
' Specifications should be revised.
Review venid invalid Needed Date O 12tist97 initiator: Leuni. C. M. O O 52rias7 VT Leed: Nort, Anthony A B O O VT Mgr: schopfer, Don K G O O 12/23/97 O l'17/S8 IRC Chmn: singh, Anand K G O Date:
INVALID:
Date:
RESOLUTION:
Previously identitled by NU7 Q Yes @ No Non Discrepent Condition?Q Yee t#) No ResolutionPending?O Yee - @ Ne Reeoiuiionunroeoived?O Yee @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K O O O s Date:
SL Comments:
Pege9 of 1 Printed in9I9812M16 PM
DR No. DR MP3 0851 h' Northeast Utilities ICAVP Ministone Unit 3 Discrepancy Report Review Group: System DR VALID Potentiel Operebil#ty issue Diecipeww: Med*" "*'
O Ya D6ecrepancy Type:Irmtenstranimps e.i , 4 SystemProcess: SWP NRC Signmcance level: 4 Date faxed to NU:
Date Pubnehed: 1/22/96 -
Descrepency: PDCR 3-94-090 Implementation and Test Requirement Discrepancies Dacripuon: PDCR 3-94-090, which involved replacement of several pipe spools, in some cases with spocis of the sarne [CuNi lined]
material and in some cases with diff erent [Monell material, was reviewed and the following discrepancies notod.
- 1. The mod package lists two work orders [AWOS] under the
" Implementation and Testing" Section - AWO M3 94-19304 and AWO M3-96-06860. However, AWO M3-94-19304 could not be found in PMMS and therefore could no' be verified to have controlled the work activities as required by PDCR 3-94-090.
AWO M3 96-06860 Indicated that it controlled portions of the work per ASME Section XI Repair / Rep'acement, and Indicated that it [AWO M3-96-06860] was a " continuation of AWO MS J4 19304," which could not be located. NU, In res:tonse to a request for this item, indicated that it *could not be found in Nuclear Plant Records and is therefore unavailable." [See IRF M3-IRF-01193.]
- 2. Under the " Retest Requiroments" section of PDCR 3-94-090 Procedure EN 31603 "ASME XI ISI System Pressure Tests" is listed as the procedure to be used to conduct the hydrotest upon completion of the modification. However, work order AWO M3-9004810 (found in PMMS) indicated that it was a " retest of M3-4419304" [which could not be located - see above] but instead listed Pitcedure EN 31090 " Elevated Pressure Test" as the goveming procedure, Procedure EN 31603 indicates that it is applicable for testing at " normal operating pressures while Procedure EN 31090 indicates that it is applicable for " testing components at elevated pressures." The mod package documentation was insufficient to determine which procedure was appropriate.
Re4]w Vei6d invol6d Needed Date intuntor: Tonwinkel, J. L G O O 12iiaS7 VT Leed: Nort, Anthony A O O O 52/1SS7 VT Mge: Schopfer, Don K Q Q Q 12/23/97 1RC chmn: Singh. Anend K Q Q Q 1/17/98 Dete:
INVALID:
Dete:
RESOLUTION:
Previously identmed by NU7 O Yes @ No NonDiscrepentcondetton?O Yes @ No Pruited 1/19/9812:45os PM Pege 1 of 2 (
i DR No. DR-MP3-0851 j
- Northeast Utilities ICAVP l
Millstone Unit 3 - Discrepancy Report ResolutionPending70 Yes (9) No ResolutionUnresolved?O Yes (G) No Review
^~~
Not ^ E ;' Needed Date VT Leed: Nort, Anthony A O O O VT Mgr: Schop8er. Don K O O O IRC Chmn: Sin 0h, Anand K .
Date:
SL Comments:
l f
1 Pnnled 1/19/9812'45:10 PM - page 2 of 2
ICAVP DR No. DR.MP3-0862 Northeast Utilities Millstone Unit 3 Discrepancy Report -
Review Group: System - DR VALIO EW. N W Potential OperabiNty leeue Ciecipione: Mechanical Design O va Diecrepancy Type: Installebon Requiremente C9) No SystemProcess: SWP NRC Signiacance level: 3 Date faxed to NU:
Date Published.1/22.96 D6ecrepancy: PDCE 3-87-039 Installation Requirements Discrepancies DescriptLm: PDCE 3-87-039, which involved replacement of the primary service water strainer [3SWP* STRIA, B, C, D) tube sheets with tube sheets of attemate material for increased resistance to corrosion, was reviewed and the following discrepancies noted.
- 1. The PDCE did not address the tube sheet material change with respect to updating vendor documentation.
- 2. The PDCE did not contain reference to or specification of installation requirements or controlled procedures for disassembly, tube sheet changeout, and reassembly of the
[ safety-related) strainers. Work order AWO M3-8716059, referenced in the PDCE as the implementing work order, was reviewed in PMMS, but no reference was found in the work order for procedures to control this work.
- 3. The strainers were specified in the PDCE to be determinated electrically in order to change out the tube sheets, and to be reterminated electrically following completion of the changeout.
However, the PDCE does not contain reference to any testing requirements to ensure operability of the strainers prior to retuming the equipment to service after the tube sheet changeout.
Review Valid invalid Needed Date inatiator: Tonwinkel, J. L G O O 52t22/97 VT Leed: Neri, Anthony A B D 0 12tist97 VT Mgr: Schopfer, Don K Q O O $2/23/97 IRC Chmn: Singh. Anand K G O O 5'17/S8 Date:
INVALlO:
Date:
RESOLtHION:
Previously identi6ed by NU7 O vee @ No NonD6ecrepentCondition?Q vos @ No ResolutionPending?O vos @ No RecoMWhrescived?O vos @ No Review Acce @ Not Acceptable Needed Date VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K
!RC Chmn: singh, Anand K Date:
.,e Printed 1/1298 52:4571 PM ~ ~ ~ Page 1 of 2
M NE M-MP3-0482 i Northeost Utilities - ICAVP' -
- Millstone Unit 3 Discrepancy Report !
m __ _ _ . _
=
3 1 -
0 4
PrNed 1/19f9612'445 PM PQ2W2 8
DR No. DR-MP3-0863
' Northe:st Utilitica ICAVP Milistone unit 3 Discrepancy Report Review Group: system DR VAUD Review Element Modrfleetion Design Diecipline: Mechancel Design y Diecrepency Type: Instellation implementation (5) No
~
systerntProcess: SWP NRC signiScence level: 3 Dele Faxed to NU:
Date Published: 1/2296 Discrepency: PDCE 3-87101 Implementation and Test Requiremems Discrepancies Deecripuon: PDCE 3-87 101, which involved the replacement of an original field-welded joint with a flanged joint to facilitate maintenance, was reviewed and the following discrepancies noted.
- 1. Work order AWO M3-8717097 was referenced in the PDCE as the implementing document for the work. This work order was reviewed in PMMS and found to indicate that it was to control the " cutting of the SW pipe" but made no reference to controlled procedures for either cutting or welding to the [ safety-related] service water pipe.
- 2. Neither the PDCE nor the above-referenced work order contained reference to hydrotest or leak test requirements to be performed before retuming the system to service following completion of the modification.
Review Valid invalid Needed Date O 2/22s7 initiator: Terminkel, J. L G O VT Leed: Nort, Anthony A O O Q 12/19/97 VT Mgr: schopfer, Don K O O O 12/23/97 1/17/98 1RC Chmn: Singh, Anand K Q Q Q Date:
INVAllD:
Dele: {
RESOLUTION:
Previously identified by NU? O Yes @ No Non D6ecrepent Condition?Q Yes @ No ResolutionPonding?O vee @ so Re.oiutionunre.otved?O ve. @ No Review .
Acceptable Not Accepteble Needed Date g,g VT Lead: Nerl. Anthony A VT Mgt; schopfer, Don K IRC Chmn: Singh, Anand K
-e SL Comments:
Printed 1/19/9612:47.56 PM Page 1 of 1 l
DR No. DR-MP34864 Northeast Utilities ICAVP Milfstone Unit 3 Discrepancy Report -
Rev6ew Group: System DR VALID Rev6ew Element: Modification Design p, D6scipl6ne: Mechanical Design g D6ecrepency Type: Design cartrol Procedure p systowProcess: SWP NRC *O mace level: 3 Date faxed to NU:
Date Putsehod 1/22/98 D6ecrepancy: PDCR 3-94-094 Design Control Discrepancies Descript6on: PDCR 3-94-094, which involved changeout of pump intemals and coating of intemal surfaces with Arcor for 3 SWP *PIC and D plus deactivation of tube water to the bearings of 3SWP*PIB, C, and D, was reviewed and the following discrepancies noted.
- 1. The mod package originally fumished by NU in response to RFl # 159 was 'ncomplete, consisting only of Form A [one page]
Form B [ thirteen pages) and a one page attachment addressing
" Retest Requirements Discussion." During a trip to Millstone to complete reviews of mod packages, including 3-94 094, it was l
found that PDCR 3-94-094 had been checked out of the controlled library. in response to S&L's subsequent request for the complete mod package, NU Indicated that "It could not be located in Nuclear Records and therefore was not avaliable"-
[see IRF 01193 in response to RFI MP3 793). Despite the limited content of the package, the review was completed and l
additional discrepancies noted as follows.
- 2. Section 5 of Form B," Detailed Evaluations / Reviews,"
l indicated that detailed reviews had been completed and attached to the PDCR for Fire protection, Seismic Qualification, Electrical /l&C, Control Panel, and Mechamcal Systems, however none of these five items were included in the package.
- 3. Section 7 of Form B. " Safety Evaluations," indicated that a Enfety Evaluation had been completed and attached, however l
none was included with the package.
! 4. No work orders or procedures for controlling the work were referenced in the PDCR for implementation, however an uncontrolled report fumished by NU allowed retrieval of 15 AWOs that were issued and closed out implementing the change. These AWOs contained adequate references to procedures for proper control of the work activities.
l
- 5. The changeout of pump intemals requires that each pump be physically removed from the pump house and taken to the shop where it is disassembled and reassembled. This involves removal and replacement of concrete hatches in the roof of the pump house which results in breaching of a vital area barrier.
This was not addressed in the PDCR.
- 6. Section 15 of Form B," Requirements Prior to Operation,"
indicated that Redlining of Operations Critical Drawings, Update of Process Computer Alarm (s), and New, Revised or Changed Procedures were required prior to retuming to open/%n after Pnnted 1N 1M25 PM ==~EC = !== = hC PDCR' == v=? th ?= === == "' N
Northeast Utilities ICAVP DR No. DR MP3 0464 )
Millstone Unit 3 Discrepancy Report !
these items had been completed, and no identification of the affected drawings, alarms, or procedures was included to allow confirmation.
- 7. Section 17 of Form B, *ltems Required to be Completed Prior to PDCR Closeout," indicated that PMMS Data Sheets, Technical / Maintenance / Operations Manuals, Spare Parts Lists, DCNS, and New, Revised, or Changed Prr>cedures were required, Several DCN numbers were included and verified as part of tne review, The other requirements did not include any specific references which could be verifici. In addition, under item 17F, CCN Number 11 to Nasco Calc. NL-025 was '
referenced as required prior to closeout; however this calculation could not be located as it is not listed in the NU Calculation Database, Review Vand invasid needed Date initiator: Tenwinkel, J. L G O O $2r22rer VT Leed: Neri, Anthony A B O O $2/20s7 O 12r22s7 VT Mgr: Schopfer, Don K O O 5'17/se IRC Chmn: Singh, Anand K G O O Date:
INVALID:
Date:
RESOLUT10N' Previously identifled by NU7 O vos @ No NonDiscrepentCondition?O ves @ No Resolution Pending70 ve. @ No R iutionune.coev.470 ve. @ No R.vi Acceptable Not F-- Needed Date g,ggg. g VT Lead: Neri, Anthony A O O O VT Mgt: Schosk Don K 1RC Chmn: Sin 0h, Anand K Date:
SL Comments:
d.
Printed in1Mie 1248:29 PM Page 2 of 2
. - _ _ _ - _ _ _ _ - - - _ _ _ _ . --_=:__-__ ______
ICAVP DR No. DR-MP3-0866 Northeast Utilices Miiistone Unit 3 Discrepancy Report neview aroup: Prograrnrnste DR VAUD
' **** Potent 6el Operatssty issue Diecipline: Other O vee D6screpancy Type: Corrective Action g~ g ;
1 SystemProcess: SWP NRC Significance level: 3 Date faxed to NU:
Date Putushed: 1/22/98 D6*crepency: Inadequate 10CFR50.59 Safety Evaluations DacripHon: ACR M3-96-0357 dated 7/8/96 is associated with LER 96 005-000. The ACR states that neither the Bypass Jumper evaluation by the Engineer, Supervisor, and Plant Review Committee, nor the 10CFR50.59 evaluation addressed the deletion of the high temperature auto-start function of the Service Water System booster pumps. The corrective action states that the procedures for safety evaluations have Deen 'significantly strengthened."
Also,
- A standard form is now used for all safety evaluations, and there is a dedicated subcommittee of the Nuclear Safety Assessment Board that reviews all safety evaluations....'
Although this recognizes that performing safety evaluations is a problem, the corrective action only addresses a revised procedure and a subcommitte, but does not address the cause or extent of the problem.
l ACR M3-96-0041 identifies an inadequate 10CFR50.59 safety evaluation with respect to a PDCR involving the Service Water pump discharge valves. The corrective action plan included in the ACR is inadequate in that no action is addressed relative to the inadequate safety evaluations.
ACR M3-96-0920 identifies two inadequate 10CFR50.59 safety
!- evaluations. for which no corrective action was established.
UIR 2458 identified where a safety evaluation was not performed when the setpoint of a level switch for the Refueling Water l
j Storage tank was changed. This setpoint changed the approved
' levels as shown in the FSAR. The final disposition was to l
perform a 10CFR50.59 evaluation to assure that the change did not result in an unreviewed safety question. This was the appropriate immediate action to take to resolve the immediate deficiency; however, the cause of the problem was not addressed. That is, the reason for a safety evaluation not being performed, was not addressed The above are indicative of a possible generic problem associated with the failure to perform required safety evaluations, and the adequacy of those evaluations that are performed.
Review l Vef.e Myelid Needed Date l
initiator: Wrons. S. P. G 0 0 12/24s7 VT Lead: Ryan ThomesJ G O O 12r24s7 VT Mgt: Schopfer. Don K Q O O 1/12/96 IRC Chmn: Se@, Anand K Q Q Q 1/17/98 l
l Printed 1/199612:40 57 PM Page 1 or 2 l
o DR NC. DR MP3-0865 Northe:st Utilities ICAVP Millstone Unit 3 Discrepancy Report Date:
DNALID:
Date:
RESOLUTION Previously R9tfled by NU? O Yes (#') No Non D6ecrepent Condetion?O Yw (9) No Reeclution pow 70 vos @ No Resolut.onUnrescoved?O Yes @ No Review Acceptable Not Acceptable Nseded Date initietor: (none) ,
VT Lead: Ryan, Thomes J ,
VT Mgr: Schopfer, Don K ,
IRC Chmn: Singh, Anend K O O Date:
SL Comments:
i i
a Prtnted 1/199612:50:00 PM Page 2 of 2
l l *
^
ICAVP DR No. DR-MP3-0490 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR VALID Review Elemwd: System Deelon Diecipline: Mechancel D*
O vee Diecrepancy Type: Component Date IG) No
' ~ ~
SystemProcese: DOX NRC signHlcance level: 4 Date faxed to NU:
Date Pubitehed: 1/22/96 Necrepancy: Design Data for the EDG Cylinder Liner Jackets & Turbochargers Descrigelon: FSAR Table 9.5-3 Design Data for Components in the EmerDency Generator Cooling Water Systems" defines the following for the Engine Cylinder Liner Jackets and Turbochargers:
Temperature Differential = 15 degrees F normal : 18 degrees F maximum Design Heat Removal Rate = 6,781,000 BTU /hr Design Margin = 678,100 BTU /hr Total D* sign Heat Removal Rate = 7,459,100 BTU /hr A review ofine purchase specification (2447.300-241), P&lD's (EM 116A & EM-116C), the vendor drawings and the Operating Instruction Manual OIM-241, was not able to confirm this information.
Reference REQ-MP3-DGX 507 Review Veild invalid Needed Date inu6etor: Hemoetman, R. G O O 12/22/97 VT Leed: Neri, Anthony A [ [ [ 12/2097 VT Mgt: Schopfer, Don l' O O O 12/23/97 IRC Chmn: Singh, Anand K O O O 1/27/98 Dele:
INVALID:
Dele:
RESOLUTION:
Previously identiSed by NU? U vos (9) No Non D6ecrepent Condetion?O vos (9) No Resolution Pending?O vos @ No ResoeuuonUnr oiv.d70 vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A O O VT Mgt: Schopfer, Don K 1RC Chmn: Singh, Anand K Pr.ie:
SL Commente:
Printed 1/19s961150'43 PM Page 1 of 1
ICAVP DR No. DR MP3 0491 Northeast Utilities -
Millstone UnP. 5 Discrepancy Report Review oroup: Sywem DR VAuD PotentialOperetssty leeue Diecipline: Mechanical Doegn O va Diecrepancy Type: Component Dete
@ No Systemfrocese: DGX NRC Significance level: 4 Date F Axed to NU:
Date Puthehed: 1/2296 D w epency: Design Data for Components in the EDG Cooling Water System DescripHon: FSAR Table 9.5-3 Design Data for Components in the EDG Cooling Water System" defines the following for the intercooler water system intercoolers:
Design Heat Removal = 3,000,606 Blu/hr.
Design Margin = 880,362 Btu /hr Total Design Heat Removal Rate = 3,880,968 Blu/hr.
A review of the purchase specification (2447.300-241), P&lD's (EM-116A & EM-116C), vendor drawings and Operating Instruction Manual OIM-241, was not able to confirm th;s information.
Reference REQ-MP3-DGX-512 Review Valid invalid Needed Date 12/22/97 initiator: Hemoetman, R. -
O O VT Lead: Nori, Anthony A -
0 0 122o/97 O 12rz3s7 VT Mgr: Schopfer, Don K G O O O 1ris/se IRC Chmn: Singh, Anand K O Date:
INVALID:
Date:
RESOLUTION:
Previounty identified by NU7 (.) v9e 19' No Non Discrepent Condition?(.) ves @ No Resolution Pending?O vos @ No ResolutionUnresolved?O vos @ No Review Acceptable Not Acceptable Needed Date gg, VT Lead: Neri, Anthony A VT Mer: Schopfer Don K ORC Chmn: Sh$, Anand K O O 8 Date:
sL Commente:
Printed ir199612.51:16 PM Page 1 of 1
ICAVP DR No. DR-MP3 0492 l Northeast Utilities Ministone unit 3 Discrepancy Report ;
Review Groeg: System DR VALID EW: Spem W Potential Operatety issue I Diecipline: N Dewon O ve.
Discrepency Type: Componert Date g SystemProcess: DCX NRC Sign 4Aconce level: 4 Date faxed to NU:
Date Published: 1/22/96 De*cr*Pency: Design Data for the Components in the EDG Cooling Water System
Description:
FSAR Table 9.5-3 ' Design Data for Components in the EDG Cooling Water Systems" defines the following for the Intercooler Water System injection Nozzles:
Design Heat Removal Rate = 12,000 Btu / hr Design Margin = 3,521 Blu/hr.
Total Design Heat Removal Rate = 15,521 Btu /hr A review of the purchase specification (2447.300-241), P&lD's (EM 116A & EM-116C), vendor drawings and Operating instruction Manual OlM 241, was not able to confirm this Information.
Reference REQ-MP3-DGX-0513 I Review Valid invalid Needed Date l
i2e2/97 i
Initiator: Hemoetman, R. O O VT Lead: Neri, Anthony A B O 12i2o/97 O 12/2297 l
VT Mge: Schopfer, Don K O O 1'1$S8 l lRC Chmn: Singh, Anand K G _
Date:
INVAllO:
Date:
l RESOLUTION t
! Previously identifled by NU? O vos [t Non D6screpent Condition?O yes @ No Resolution Pending?O ve. @ No Re.oiution u.we.oived?O vs. @ No Review Acceptable Not Acceptable Needed Date gg; i VT Lead: Nerl, Anthony A VT Mgr: Schopter, Don K IRC Chmn: Singh, Anend K g
Date:
SL Comments:
Printed 1/19/9612 52-17 PM Page 1 of 1 l
i ICAVP DR No. DR-MP3-0893 Northeast Utilities Millstone unit 3 Discrepancy Report i Review Group: System DR VALIO Review Element: Syelem Design D6ecipline. Mechanical Design O va Discrepency Type: Componerd Dete g' SystemProcess: DGX NRC $1,.?" = -level: 4 Date faxed to NU:
Date Puthshed il22/Be DioctePeacY: Design Data for Components in the EDG Cooling Water System D*ecription: FSAR Table 9.5-3 " Design Data for Components in the EDG Cooling Water System", defines the following for the Intercooler Water System Outside Bearings:
Design Heat Removal Rate = 6,000 Btu / hr Design Margin = 1,760 Btu / hr Total Design Heat Removal Rate = 7,760 Blu / hr A review of the purchase specification (2447.300-241), P&lD's (EM-116A & EM-116C), vendor drawings and Operating Instruction Manual OlM-241, was not able to confirm this information.
Reference REQ-MP3-DGX-0514 Review Vehd Invalid Needed Date initiator: Hemoetman, R. O O O 12/22/97 VT Lead: Nort, Anthony A y Q O 12f20/97 VT Mgr: Schopfer, Don K B O 12/22s7 1RC Chmn: Singh, Anand K O O $/17/98 Date:
INVALID:
Date:
RESOLUTION:
Previously identined by NU? O Yes @ No NonDiscrepentCondition?O vos @ No Resolution Pend 6ng?O v.e @ No PesolutionUnresolved?O ves @ No Review Acceptable Not Acceptable Naeded Date gg,,,; g VT Lead: Neri, Anthony A b
VT Mgt: Schopfer, Don K IRC Chmr: Singh, Anand K Date:
SL Comments:
Printed 1/19/9612:511o PM Page 1 of i
ICAVP DR No. DRJAP3-0896 I Northeast Utilities
- Minietone unit 3 Discrepancy Report Review Group: System DR VALID Rev6ew Element: Byetem Duign Potential Operability leeue Diecipline: Mechanical Design O vee D6screpancy Type: Caiculaten No System?rocess: DGX NRC &lgnificance level: 4 Date faked to NU:
Date Published: 1/22/96 D6* crop *ncy: Ambient Noise Calculation 2099.e15 does not follow the stated approach.
ce cription: The purmse of Calculation 2099.615 Rev 0 was to compute the maximum allowable sound pressure level (SPL) that can be tolerated for both the intake and exhaust of the emergency diesel generators. The calculation was to examine two cates:
(1) increase ambient by +15 dB; and (2) increase emblent by +3 dB, A previous calculation,2099.614, determined the acceptable SPL at a distance of 400 feet from the diesel generators.
Calculation 2099.615 was to evaluate the SPL ai a distance of 50 feet from the diesel generators. The SPL data was to be converted from a 400 foot ct".erion to a 50 foot criterion for evaluation. This process was carrlod out in the table on Page 7, Two different methodologies were employed. The first was in accordance with that stated in the approach. The second made a conversion based on a Sc,end Power Level (PWL) approch.
The methodology to make this conversion was not explained nor referenced. Furthermore, the latter methodology (results shown on line 10 of page 7) was the one chosen as representative of the SPL data 50 feet from the diesel generators.
Additionally, when determining the criteria to yield +3 dB above ambler t at 50 feet, the +3 dB was not added to the ambler,t SPL.
Review Val 6d Luolid NeeJed Dde initletor: Hemoetman, R. Q Q Q 12/22/97 VT Leed: Nort, Anthony A O O O 12/20S7 O O $222S7 VT Mgr: Schopfer, Don K O 1RC Chmn: Singh. Anarw* *( Q Q Q 1/17/98 Date:
INVALID:
Det9' REsoLU1' c Previously identified by NUF Q vos @ No NonD6ecropentCondellon?O vos @ No Resolutiost PemlingtO vee @ No ResoeuiionunresoevedtO vos @ No Review Acceptable Not Accostable Neeriod Date g
VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Sin 95, Anand K O O O Dele:
PrNed trib9812.54 28 PM Page 1 of 2 i
ICAVP DR No. DR-MP34495 Northeast utiinneo Milletone unit 3 Discrepancy Report seco ni.:
^
Printed 1/19S612.54.31 PM Page 2 of 2
~
ICAVP DR No. DR-MP3 0911 Northeast Utilities Millstorm Unit 3 Discrepancy Report R.vlew Group: Programmetc DR VALID Review Elemord: CorrectNo Acton Process p Disc 6pl6ne: Mechan 6 cal Des
- O ve.
D6screpancy Type: CorrectNo Action
@) No System / Process: N/A NRC Significance level: 4 Date faxed to NU:
Date Publiebed: 1/22/95 D6screpancy Insufficient information for Delay of Evaluatlans Dancrepair.: UIR 2455, dealing with the replacement of a section of Service Water piping, and UlR 2545, dealing with an unquallfled worker performing maintenance on an emergency diesel generator, are scheduled to be resolved after start up of Unit 3.
There is insufficient information presented in the UIRs to determine whether the delay of these evaluations is justified.
- 1. PDCE MP40137 contains no retest requirements for the Service Water piping and states ' leak testing is not possible due to piping configuration and need to keep pipe vented", IWA-5214 of ASME Section XI requires a hydrostatic test after replacing 3* safety related piping. Case N-4161 allows a
. ore test to be substituted provided a VT 2 visual
. amination is performed prior to or immediately upon retum to service. Has the structuralintegrity of the piping been maintained per Technical Specification 3.4.10.c?
- 2. UlR 2545 does not describe the particular equipment the unqualified worker maintained nor does it describe how unqualified the worker was. What mitigating circumstances allow delaying the resolution of this problem until after start up?
Review Val 6d invalid Needed Date O $272S7 initiator: Sheppard, R. P. O O O 2t24s?
VT Lead: Ryan, Thorr.as J O O VT Mgr Schopfer, Don K O O O ti 2/98 IRC Chmn: S6ngh, Anand K O O O $'t 7/98 Deio:
INVALID:
Date:
RESO .UTION:
Previously identitled by NU? O Yes 79i No Non D6screpent Condet6on?U vos 78-) No ResolutionPending?O vos @ No Renoiuiionenre orved?O ve. + No Review Acceptable Not Acceptable Needed Date g
VT Lead: Ryan, Thorns J VT Mgt; schopfer, Don K IRC Chmn: Shgh, Anand K O 3 O D.i.:
SL Commerdt:
~~
Prtr?od 1/199612.5s 44 PM Page 1 of 1
ICAVP DR No. DRJAP3 0941 l Northeast UtWties '
Milletone unn 3 Discrepancy Repoft Review Group: Operetsons & MeNonence and Testing DR VALID Review Element: Test Procedure E_
Diecipline: Operations
- y Type: Correcthe Action implementetson Om (b) No
~
syeeerWprocess: Oss NRC sL /^mlevel:4 Date faxed to NU: >
Dese Putdlehed: tr22S6 06ecrepeacy: Unable to confirm that commitment in LER 94-007@ was met.
Deecripe6en: SP 31024, Calculation of Reacter Trip and ESF Response Timel, is the only procedure that matches the description of the '
procedure referenced in the subjed LER. SP 31024, Attachment 9, Pa9e 81, Reactor Trip and ESF Component Response Times, requires transferring data from other surveillances into one of three tables. The review concludes that this portion of the attachment cannot be completed as written.
The first and second tables reference data collected from the Quench Spray (Without LOP) surveillance OPS Form 3909.9-2.
The listed valves, QSS*MV34A & B, are apparently incorrect equipment numbers. Only valves SQSS*AOV27 & 28 are listed on OPS Form 3909.9-2. If the correct valve numben, are OSS*MOV34A & B then the referenced forms should be OP3 l Form 3609.9 3 and 4.
l The third table references data collected for valves SQSS*MV34A & Is from the Quench Spray (With LOP) surveillances. A0ain the valves referred to appear to have incorrect equipment numbers. No source document is identified for this Information, it is unclear, once the data has been collected for these valves, how the data is used to perform calculations or what requirement the calculations support.
The commitment also states that SP 31024 will be revised prior to its next use. SP 31024, Revision 10 through Change 3 were reviewed using OSCAR. None of the changes reference a revision to pa9e 81. RFl 170, item 14 requested "SP 31024, Latest Results". The data provided is dated mid 1995 but Attachment 9 was not included with these documents. Therefore it cannot be resolved by this review if inis commitment has been satisf*HKl.
Fieview Valid invalid Needed Date initsstor: Tomlyn. Tom O O O $2rais7 VT Lead: Does, Ken D D D siivos VT Mgr: Schopfer, Don K G O O trizios IRC Chmn: singh, Anand K O O O $iirise Date:
INVALID:
summmmm=
- Dese:
MEsOLUTio*
~
Prned 1/1Mie 12R27 PM PeGe 1 of 2 ;
O ICAVP DR No. DR MP34H1 Northeast utstles Mastone Unit 3 Discrepancy Report ;
i Prov6ously identmed by NU? U Yes @ No NonD6ecropentCondel6on?() Yes @ No j Resolut6on PendingtO vos + No - % unt e r O vos @ No Review
- ":= ;' '
Not h:-: ;' NetM Date VT Lead: Boos,ran VT Mgri Schopfer, Don K O u IRC Chmn: Singh, Anand K g Dele:
SL Comments:
I b
4 e
Printed 1/199612.56.31 PM Page 2 of 2
e ICAVP DR No. DRW3 4143 Northeast UtmHes -
milistone Unit 3 Discrepancy Report Rev6ew Group: system DR REsott1 TION REJECTED Potential OperatMy leeue 06ecaps6ae: Mechen6 cal Design Om Diecrepancy Type: Doensing Document g g, System / Process: RSs NRC Stenencance level: 4 Date faxed to NO:
Date Putdiohed' 11/297 D6ecr*pency: Inconsistency between FSAR Section 6.2.2.2 & Spec 2361.900-921 regarding thermalinsulation Deecripuon: FSAR Section 6.2.2.2 states thW encapsulated insulation inside containment has inner and outer stainless steel Jackets with minimum thicknesses of 0.010 and 0.018 inches, respectively.
However, General Thermal insulation Specification 2361.900-921 Revision 2 states that the jacketing minimum thickness is 0.010 inches, not addressing whether the jacket is the inner or outer layer.
Rev6ew Val 6d invalid Needed Date instietor: Feingold. D. J. O O O 10'17/87 VT Lead: Nat, Arth:my 4 O O O 10/17/87 VT Mgri schopW, Don K O O O or2a97 IRC Chmn: singh. Anand K y O O 1o/3097 Date:
INVAllo:
Dese: 12/10/97 REsOLLITION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0143, does not represent a discrepant condition.
During the 50.54(f) effort, each stctement of fact in the FSAR was validated and verified. The subject statement 9) the FSAR was annotated and verified to be based Lpon specification 2361.900 345, Rev 1, Removable Thermal Insulation. The DD.
Inconectly identifies 2361.900-921, Rev 2, General Thermal Insulation, as the reference specification. The 345 specification confirms FSAR section 6.2.2.2 because it addresses the minimum thicknesses of the encapsulated insulation and includes equipment and piping inside containment. The specification referenced in the DR does not apply to the equipment and piping inside coatainment.
S10nificance Level criteria do not apply here as this is not a discrepant condition.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0143, does not represent a discrepant condition. The DR references the incorrect specification relative to the FSAR statement.' As indicated on the annotated section of FSAR section 6.2.2.2, the correct specification it 2361.900-345, Printed 1/1b96190.04 PM Pope 1 of 2
o ICAVP DR No. DR MP3 4143 Northeast UtilRies ,
milletone unN 3 Discrepancy Report l Removable Thermal Insulation. This specification addresses the !
minimum thicknesses of the encapsulated insulation and j includes equipment and piping inside containment. j 1
Significance Level critcda do not apply here as this is not a l discrepant condition.
Prev 60unty identised tr/ nut O Yes IG) No NonD6ecropontConde16ontQ Yes @ No Resolution PendtngtO vos re No noe.iulianunrosoevedtO vee <*) No Review insteolor: FeirW, D. J.
VT Lead: Nwt, Anthony A O O O "P VT Mgr schop8er, Don K b IRC Chmn: Singh, Anand K 7
oste: 11/25/97 st. Commente: Specification 2361.900-921, General Thermal Insulation",
identifies the specification scope on page 13 as being applicable to thermal insulation inside and outside the containment.
Specification 2361.900 345,
- Removable Thermal Insulation",
identifies the specification scope oil pags 12 as being applicable to removable thermal insulation, required for piping and equipment operating at temperature in excess of 150 degrees Fahrenheit. Sections 2 and 3 of specification 2361.900-345 identify explicitly the piping and components to be insulated according to the specification, in contrast, specification 2361.900-921 loentifies type of piping and components, inside and outside containment, to be insulated in accordance with the specification.
No documents are identifed, in the response to this Discrepancy Report, that provides assurance that piping and components inside containment are insulated using specification 2361.900-345 instead of specification 2361.900-921.
i l
' Printed 111EW9e 190 08 PM Page 2 ef 2 i
ICAVP DR No. DR44P3 4141 Northeast Utilties milictone UnN 3 Discrepancy Report Review Group: Opershons & Maintenance and Techn0 DR RESOLUTION REJECTED Review Element: Opereuno Procedwo y D6ecipune: opershons O va Diecrepancy Type: 0 & M & T Procedure gg systemProcess: SWP NRC signiacencelevat 4 Date faxed to NU:
Date Putd6ehed: 9/22/97 06ecrepancy: Flood Protection Procedures and Technical Specification l Requirements Discrepancy Ducript6an: Tech. Spec. section 3.7.6, Flood Protection, Limiting Condition for Operation (LCO), states that flood protection shall be provided for the service water pump cubicles and ccmponents when the water level exceeds 13 feet Mean Sea Level, USGS datum, at the Unit 3 intake structure. This LCO is applicable at all times.
The associated action statement is 'With the water level at 13 feet above Mean Sea Level, USGS datum, et the Unit 3 intake structure, shut the watertight doors of both service water pump cubicles within 15 minutes.'
The surveillance requirements associated with the flood protection LCO are:
- 1. Measurement at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the water level is below elevation 8 feet above Sea Level, USGS datum.
- 2. Measurement at least once per 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when the water level is equal to or above elevation 8 feet above Mean Sea Level, USGS datum.
The following listed procedures implement the flood protection requirement:
SP3665.1 Rev. 5 Flood Level Determination OPS Form 3665.1 1 Rev. 5, Flood Level Determination AOP 3569 Rev.10, Severe Weather Conditions SP 3670.2 Rev. 8, Tech Spec Pelated PEO Rounds (Mode 1-4)
OPS Form 3670.2-6 Rev. 7, Shift Outside PEO Tech Rounds (Mode 14)
SP 3672.3 Rev. 4. Tech Spec Related PEO Rounds (Mode 5/6)
OPS Form 3672.3-3 Rev. 4, Shiftly Outside PEO Tech Spec Rounds (Mode 5/6)
Three flood prote: tion requirement discrepancies were identified.
- 1. No procedural Guidance exists that describes the flood protection program actions to be it. ken when the water level is determined to be equal to or Greater that 13 feet above mean sea level USGS datum as documented in OPS Form 3665.1 1 Rev. 5. Section 7 Summary of changes, of SP3665.1 Rev. 5, Flood Level Determination , identifies one of the changes made in revision 5 of this procedure as ' References to the actions taken if water level exceeds 13 feet have beer, removed. These actio.ts are dealt with in EOP 3569, Severe Wet.ther rhrtifinna" prnem1nra pnp strJLQ Ragggg,,Wanthar Ennefitinnet Prtnied 1/199e 120 50 PM Page 1 or 4
C ICAVP DR No. DRMP34161 ]
Northeast Ut64kies Milestone unit 3 Discrepancy Report l does not exist This was confirmed by referencing Unit 3 Emergency Operating Procedures index,3500 Procedure Index, Rev.141 dated 5/20/97. Procedure AOP 3569 Rev.10, Severe Weather Conditions, does exist and may be the corred reference rather than EOP 3569. This AOP does not adequately identify the Tech Spec required actions to be taken if the water level reaches or exceeds 13 feet.
The performance requirements identified in the Tech. Specs, are not adequately translated into the referenced operating / surveillance procedures.
- 2. Page 2 of Procedure SP3665.1 Rev. 5, Flood Level Determination, states in the box identified as Casis Information,
'This monitoring is required every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> even if the watertight ,
doors and the normal sump drains are closed. No exemption is prrsvided in T/S 4.7.6.b which would allow cessation of monitoring'. Page 3 of the same procedure states in the box identified as CAUTION, 'With sea level approaching 13 feet above mean sea level weather conditions may warrant entering T/S 3.7.6 LCO and discontinue surveillance until conditions allow". These statements are in direct confhet Page 5, Step 5 of Procedure AOP 3569 Rev.10 required the operator to
- Monitor sea water level at the intake strudure houriy until wind speed exceeds 50 mph.' This step is not consbtent '
with OPS Fcim 3665.1 1 Flood Level Determination which requires that the water levelis recorded every two hours. If the operator ceases to monitor the sea level when the winds exceed 50 MPH the required Tech Spec surveillance that is dcrcribed in '
SP 3665.1 Flood Level Determination and OPS Form 3865.1 1 Flood Level Determ! nation may be missed if the water level is high during high wind conditions.
These procedures appear to be contradictory and may preclude the service water system from being monitored in accordance with the Technical Spectfication during high "vinds and/or flooding conditions.
- 3. Tech. Spec. sedion 3.7.6, Flood Protection, requires determination of water level referenced to *Mean Sea Level, USGS datum, at the Unit 3 intake structure. We were unable to determine from the documentation provided, what type instrument was used to determine the mean sea level, specifically where the instrumentation is located, or how the instrumentation is calibrated and reitrenced to the USGS datum.
Rev6ew Valid inveild heeded Date O O wi7/97 initiator: Spear. R. O O $/i7/S7 VT Lead: Sees.Kea O O VT Mgr: Schopfer, Don K O O O S'5SS7 9/18.97 IRC Chmn: Singh, Anand K Q Q Q Date:
DNALID:
Prned 1/199610193 PM Page 2 or 4
- < - . . p--
ICAVP DR No. DR MP3-01f1 Northeast Utilities Millstone Unit 3 Discrepancy Report D*: 12/17/97 ResoumoN. Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0161, identified multiple conditions. Items 1 and 3 of the DR do not represent discrepant conditions. Item 2 was an apparent discrepant issue previously 6dentified by NU which did not require corTection.
1, SP 3665.1 is entered when it is identified that Long Island Sound levelis greater than eight feet above mean sea level. SP 3665.1 has procedural guidance for actions that should be taken when ths intake is threatened by rising sea level. Upon notification from CONVEX of 6 hurricane advisory, AOP 3569 is entered. Steps 5,6 and 7 of AOP 3569 are the procedure steps that implement the actions of Tech Spec 3.7.6. These aclions are taken prior to level exceeding 13 feet.The reference to EOP 3569, Severe Weather Conditions, exists only in the Basis Document of SP 3665.1 and not in the procedure itself, A procedure Feedback Form, DC1 Att.10, was submitted to the procedures group to reference the correct procedure, AOP 3569.
- 2. CR M3-971613 was written 5/23/97 to document the inconsistency between AOP 3569 and Tech Spec 3.7.6 requirements of monitoring sea level. The investigation determined that the condition was not adverse. SP 3865.1 Implements the surveillance requirements of Tech Spec 3.7.6 to ensure that the appropriate action statement is met when conditions require it. Further, AOP 3569 provides guidance to refer to Tech Spec 3.7.6 for applicability and monitor sea level hourly until wind speed exceeds 50 mph. Subr.equent steps perform the actions of Tech Spec 3.7.6. At the Shift Manager's discretion or when winds exceed 50 mph, monitoring can be suspended by entering the action statement and verifying the watertight doors and sump drains are closed. This would be the logical course of action to ensure personnel and plant safety.
The basis information in SP 3865.1 is referring to only performing the actions of the Tech Spec. That alone does not exempt us from performing the surveillance requirements. In order to suspend the surveillance requirement, the action must be taken and the Tech Spec entered, as Indicated in the caution. A Feedback Form, DC 1 Att.10, has been submitted to the procedure group to clarify the intent of the basis information.
- 3. The instrument used to check sea level is a level reference (tidemoter)in one foot increments mounted on the side of the intake foundation. The tidemeter is installed with respect to intake area grade. Grade at the intake was determined during initial construction surveys to be 14.5 feet. Mean sea level was also determined during initial construction and benchmarks placed and monitored per SP CE 223, Movement Monitoring Program and documented on FSK 12179-G 029. Surveyed markings were placed on the wall where the tidemeter is hung with appropriate tolerances and uncertainties. Replacement tidemeters are hung corresponding to the surveyed marks. The intent of the tidemeter is to give the operator an estimate of tide /
Prinsed th9/981.0104 PM Page 3 ed 4
l
. L ICAVP DR No. DRW3 4161 j Northead Utilities weistone Unit 3 Discrepancy Report i
\
wave level. It is not calibrated to incremental tolerances, since it is intended that the operator be able to make a determination of sea level from a distance. Significance level criteria do not apply as this is not a discrepent condition l
Conclusion.
NU has concluded that the issue reported in Discrepancy Report, DR MP3 0161, doss not represent a discrepant condition. AOP 3569 steps 5,6 and 7 are the procedure steps that implement ,
the actions of Tech Spec 3.7.6 and are taken prior to level ,
exceeding 13 feet. The apparent discrepancies in AOP 3569, SP 3665.1, and Tech Spec 3.7.6 were previously identified by NU and documented in CR M3 971613. The CR resolution, however, determined that there was no' a discrepancy as the action for the l ach Spec would be taken in accordance with AOP 3569 and the LCO entered. Once *his is done, surveillance requirements are not applicable. The instrument used to determine sea level is a level reference (tidemeter) hung at the intake. During initial p! ant construction, surveyeri markings were placed in the location of the tidemeter to ensure it was hung property. Significance level criteria do not apply as this is not a discrepant condition.
Prev 6ously identtaed by NU7 O Yes @ No NonDiscrepentCondethm?O Yes @ No ResolutionPending?O vos @ No w%uaresoevedr@ vos Ci No
! Review
- T " Not M , ' _ _ Needed Date O O O i2tir/87 vT L.ed s.es.xen VT Mgr: Schopfer, Don K usc chmn: se; , Anand K Date: 12/17/97 st cowrents: ltems 2 and 3 of the DR are resolved with the additional Information provided. However, the information provided to resolvr item 1 it not sufficient, in that clear, unamb!auous procedural guidance describing flood protection actions for sea water level above 13 feet stipulated in Tech. Spec. 3.7.6 is not evident. This seCon of ths Tech. Spec. requires shutting water tight doors when the sea level exceeds 13 fett. Procedure SP3600.1 states only in the basis section that all actions which myht be required to comply with T/S 3.7.6 are addressed in AOP 3569 Severe Weather Conditions. Procedure SP3665.1 deals only with monitorir.g water level and AOP deals with Guidance for Severe Weather Conditions (Tomadoes ad Hurricanes). There is no procedural direction in either procedure SP3665.1 or AOP3569 that directs the operator to close the water tight doors and enter the LCO when the seal level is greater than 13 feet or when sea level surveillance is suspended.
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- 1 ICAVP DR No. DR MP34291 Northeast Utiinies Milletone unn 3 Discrepancy Report Rev6ew Group: System DR REscumoN REJECTED Rev6ew Element: System Design Diecipline* Mechenical Desien g y, Diecropency Type
- Component Dets O No systemerocess:livx NRC 4Me level: 3 Date faked to Nu:
Date Putdlehed: 13r30S7 F xy: CRS Filter Housing Design Pressure Ducripelon: ., %g the review of the design parameters for the Suppeentary Leak Colledion and Release System (SLCRS) filter units (3HVR*FLT3A/38) a discrepancy regarding the design pressure of the filter housings was identified.
FSAR Table 1.6-1 Indicates that tne filter units we in compilance with Regulatory Guide 1.52, Rev. 2, position C.3.g which requires the il:;ct housings to be desi'jned in accordance with the provisions of ANSI N5091976 Section 5.6.
ANSI N5091976 Section 5.6 states that the housings shall be designed and constructed to meet the strudural and pressure loadings of Section 4. Section 4.6 identifies the following three pressure loading conditions: 1) Units and comwnents that must withstand pressure transients,2) Units and * ..nponents that must withstand fan peak pressure, and 3) Units and components subjected only to rated air flow, in accordance with ANSI N509-1976 Section 4.6.2.2, the SLCRS filter units must withstand a negative intemal pressure equal to or more negative than the peak pressure of fan 3HVR*FN12A/B since there are isolation dampers (3HVR*AOD95A/B) upstream ( f the SLCRS filter units.
Specification 2170.430-065 states that the filter housings are designed for 15 inches of water gauge (iwg) negative pressure .
The SLCRS exhaust fans (3HVR*FN12A/128) have a rated pressure of 22.2 iwg per Specification 2176.430-141. Closure of the fire damper (3HVR*DMPF29, 3HVR*DMPF44) downstream l
of the fan or of the air operated damper (3HVR*AOD95A/958) at the inlet of the filter housing could result an intemal housing pressure of 22.2 iwg which is greater than the 15 iwg design prtssure for the housing.
' Review Vehd invalid Needed Date inatietor: stom, M. D. 9 O O 10/1/97
- VT Lead: Nwi, Anthony A O O O 10/3S7 VT Mgra schopfer, Don K O O O 10/13'S7 O 1or27'a' iRC Chmn: 8@, Anand K O O Date:
f INVAUD:
D6te: 12/16/97 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR MP3-0291, does not represent a discrepant condition. The l
i: filter trains can not be exposed to a negative pressure equivalent Prtnted 1/19r291.03.16 PM Pege 1 of 3
,.-. g,%. . s9 ,.,p.-
g.* DN No. DR MP3 4291 Northeast Utilities ICAVP ministone Unit 3 Discrepancy Report to the full shut-off pressure of the fans since fail-open inlet dampers 3HVR*AOD95A/B have to fully open before fans 3HVR*FN12A/B can start and have to remain fully open for the fans to stay running. Reference LSK-221R. Therefore, the filter trains need not withstand fan peak pressure.
Closure of fire dampers 3HVR*DMPF29 and 44 would have no negative pressure effect on the filters because the dampars are located at the discharge of the fans and th3 filters are located at the suction.
With dampers 3HVR*AOD95A/B fully open and each filter element (moisture separator, HEPA filter and charcoal hdsorber) at its change out delta P setpoint, the maximum pressore drop ct rated floiv is 7.25 iwg. Reference setpvint calculations SP 3HVR-33,35,36 sent on transmittal 90 on 8/27/97 in response to RFI 273, The filters and ducting between the inlet damper and the fan are rated for tha maximum negative pressure that they could be exposed to based on the controllogic of the damper and the fan. The failure of one damper's limit switch could be taken as the single active failure. One completa unit would still be ava.;labh for operation.
Significance Level criterla do not apply here as this is not a discrepant condition.
Previously identined by NU7 O Yes 79) No NonDhcrepentCondition?Q Yes (S) No Resolution Pend 6ngtO Yes @ No ResokdionUnree&odtO Yes @ No Re.Aw init6etor: stout. M. D.
VT Lead: Non. Anthony A VT Mgr: scWor, Don K IRC Cisnn: sin 0h. Anand K O -
O -
Date: 12/16/97 si. comments: Agree with NU's response that closure of fire dampers 3HVR*DMPF29 and 3HVR*DMPF44 downstream of the fan would .
not result in the filter unit being subjected the fan rated pressure.
Disagree with NU's response that the filter housing only sees the 7.25 iwg pressure drop across the housing. The pressure drop in the ductwork upstream of the filter unit also needs to be accounted for. The pressure in the last section of the filter housin0 is approximately the same as the suction pressure for the exhaust fan, Results from procedure T331411M04 dated 11/85 show a fan suction pressure between 11 and 11.5 twg which is lower than the 15 iwg filter housing design pressure. Failure of the upstream isolation damper (3HVR*AOD95A/B) to remahi open while the fan is running would subject the filter housing to the fan peak pressure which is greater than the housing design pressure.
FSAR Table 1.81, Reg. Guide 1.52, Rev 2, paragraph C.2.1 Printed 1/13W96123 20 PM Page 2 or 3
DR No. DR MP3 4291 Norttwest UtHities ICAVP miesstone unit 3 Discrepancy Report clarification provides a description why fan shut off pressure was not used for dud leaka0e tests. A similiar clarification / exception to Reg. Guide 1.52, Rev. 2, paragraph C.3.0 addressing why the fan peak pressure, as required by ANSI N5091976 section 4.6.2.2, was not selected as the flNer housing design pressure is needed.
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