ML20202E379

Forwards Nineteen Deficiency Repts (Drs) for Which Util Resolutions Have Been Reviewed & Accepted by S&L.One Dr That Has Been Determined Invalid & Two Drs for Which Resolutions Have Been Reviewed & Not Accepted

ML20202E379
Person / Time
Site:	Millstone
Issue date:	02/13/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9802180132
Download: ML20202E379 (43)

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February 13,199C Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power S'ation, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Enclosed are discrepancy rmrts (DRs) identified during our review activities for the ICAVP.

These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.

I have also enclosed the following one (1) DR that has been determined invalid. No action is required from Northeast Utilities for this DR The basis for its invalid determination is included on the docu nent DR No. DR-MP3-1017 I have also enclosed the following ninrf een (19) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR MP3-0009 DR No. DR-MP3-0662 DR No. DR-MP3-0017 DR No. DR-MP3-0672 DR No. DR-MP3-0183 DR No. DR-MP3-07 '9 t

DR No. DR MP3-0264 DR No. DR-MP3-0750

/ g )I g DR No. DR-MP3-0578 DR No. DR-MP3-0761

(

DR No. DR-MP3-0591 DR No. DR-MP3-0769 DR No. DR MP3-%05__

DR No. DR-MP3-0775 DR No. DR MP3-0611 DR No. DR-MP3-0811 DR No. DR MP3-0653 DR No. DR-MP3-0859 DR No. DR-MP3-0909 ER"'f8su58,46:.

l.llI.lll.li.!!I.ll.l!I. I.I 55 East Monroe Street

• Chicago, IL 60603 5780 USA + 312 269-2000

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United States Nuclear Regulatory Commission February 13,1998 Document Control Desk Project No. 9583-100 Page 2 I have also enclosed the two (2) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.

DR No. DR MP3 0202 DR No. DR-MP3-0884 Please direct any questions to me at (312) 269-6078.

Yours very truly, D.

opfer SeniorVice President and ICAVP Manager DKS:spr Enclosures Copies:

E. Imbro (1/l) Deputy Director, ICAVP Oversight s

T, Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU mhvpWswo213+&w t

y Northeast Utilicos ICAVP DR No. DR MP301017 l

Millstone Unit 3 Discrepancy Report Review oroup: system DR puAuo Review Element: Change Procese oweepene: Modenkow g y,,

t, :y Type: Corresve Act6en implemenisuon g

SyeiuWProcese: DGX

~

NRC signiacence level: 3 Date faxed to PA):

Date Putdehed: 2/1W96 Dwerepancy: Discrepancy in UIR 1842 Closure Package r:-.

While reviewing the UIR 1842 Implementation Package the following d;acrepancy was noted:

The Final Disposition of the Unresolved item Report #1842 states:

i

• Review Diesel site specific and industry operating experience i

for evidence of problems associated with fuel oil algae, if there is evidence of algae problems, incorporate sampling into the operating procedures including the FSAR statement, 'l; algae is found to be the cause of the high level of tank sediment, a procedure will be written at the time to address its treatment'. If there is not sufficient operating experience to warraid sampling, remove statement from the FSAR. Note: See NRC IN 87 004 and related information."

The UlR 1842 Closure Package offers no objective evidence that industry operating experience was reviewed for evidence of problems associated with fuel oil algae.

• "" BASED ON MY CONVERSATIONS WITH RYAN,WE SHOULD BE DOING A TECHNICAL VERIFICATION OF CLOSURE. THEREFORE,lF WE BC.lEVE THEY DID ENOUGH,YOU SHOULD NOTE ON YOUR CHECKLIST THAT ACTION TAKEN WAS SUFFICIENT EVEN THOUGH lT DIDN'T DO EXACTLY WHAT WAS STATED IN UIR DISPO, THAN INVALIDATE THIS DR.""

Review Valid invalid Needed Date initiator: obweneteclea-0 0

0 2*S8 VT Leed: Nort, Anthony A Q

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?$96 VT My: schopfw, Don K O

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NtC Chmn: Singh, Anand K O

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Date:

2/6/g8 scAuo: This review was based on the technical acceptance of the implerruntation Package only. The Implementation Package for UlR 1842 is technically sound. FSAR change via FSARCR 97-MP3 298 is based on the site soecific experience as reflected in the contracted o'f site lab fuel oil sample test report, and the site fuel oil storage tank sampling program. No requirement was found, and the review of NRC Information Notice # 87 04 offered no basis to preclude the FSAR change deleting "procWure will be written at the time to address Ms treatment" and replacing X with "an appropriate action will address its trestroent." It is noted that the revised FSAR sentence does not preclude writing a procedure,if and when needed.

Printed 2/1396 2:30 ot PM Page 1 of 2

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Northeast UtilMies ICAVP DR No. DR MP31017 Millstone unit 3 Discrepancy Report Dele RESOLUTION:

Previously ident6ned by NU7 O Yes (@ No NonD6ecrepentCondet6on?O Yes (@ No Paa%Pending?O Yes @)No Resolut6onUnreconvedtO vee rF'No Rev6ew A:=^,^ '

Not AccepteLk Needed Date g

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O VT Lead: Nort, Anthony A VT Mgr: Schoper, Don K h

IRC Chmn: Singh, Anand K g

=

Date:

SL Conenente:

Printed 2/1396 2-30.08 PM

.'eGe 2 of 2

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Northeast Utilities ICAVP DR No. DR MP3 0009 m.

Millstone unit 3 Discrepancy Report ReviewGroup: AcektentMaigetton DR REsOLUThoN ACCEPTED Potential Operabilty leeue j

Diecipune: Other g y, Diecrepency Type: Dooneine Document g

systerwProceos: N/A NRC slgniacence iml* 4 Date faxed 16 NU Date Putd6ehed: 8/22/97 Diacropency: 10CFR 60.59 for ATWS Does Not Address 'inclease in Feedwater Flow" Desert 6 ten: The 10CFR 60.59 safety evaluation for the Anticipated Transient P

Without scram (ATWS) modification does not address the modification's impact on an increase in feedwater flow accident.

The 50.59 addresses the impact of a spurious turt>lne trip, but does not address spurious initiation of auxillary feedwate; This impact needs to be addressed.

Review Vend inval6d Nooded Oste l

i Initletor: Neh, J.

O O

O 7/81/87 f

VT Leed: Reheja,RelD G

O O

7/85/87 i

VT Mer: schopfer, Don K Q

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a/5/97 wic chmn: singh. Anand K Q

Q Q

8/1$97 oeis:

l WVALID:

Date: 1/20/98 RESOLUTION: (First Round NU Commenis)

Disposition:

NU has concluded that the issue reported in Discrepancy Report.

DR MP3-0009, does not represent a discrepant condition.

Nu has reviewed the Integrated Safety Evaluation (ISE MP3 - 008) associated with the PDCR (MP3-88-008) that installed the l

AMSAC Modifications. We have determined that the ISE l

appropriately and adequately addresses the issue of spurious initiation of Auxiliary Feedwater on page 2,4 and 6 of the -

attached evaluation. This evaluation was completed in accordance with NSAC 125 guidelines, which at the time, represented the best available guidance for completing safety evaluations. Significance Level criteria do not apply as this DR does not represent a discrepant condition.

==

Conclusion:==

Nu has concluded that the issue reported in Discrepancy Report, DR MP3-0009, does not represent a discrepant condition. NU has reviewed the Integrated Safety Evaluation (ISE MP3-88-008) associated with the PDCR (MP3-88-006) that installed the AMSAC Modifications. We have determined that the ISE

- appropriately and adequately addresses the issue of spurious initiation of Auxiliary Feedwater on pa0e 2,4 and 6 of the attached evaluation. This evaluation was completed in -

. accordance with NSAC 125 guidelines which, at the time, represented the best available Quidance for completing safety Page 1 or 3 PrWed 2/13i3612.11:Sa PM

o Northeest Utilities ICAVP DR No. DR MP34009 Millstone Unit 3 Discrepancy Report evaluations. Significance Level criteria do not apply as this OR does not represent a oiscrepent condition.

(Second Round NO Comments)

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR MP3-0009, haa identified a condition not previously discovered by NU.

Two design basis accidents potentially impeded by modification:

1. Decrease in feedwater tempels'ure.

2. Increase in feedeter flow.

NU concurs that the above mentioned accidents should have been identified in Safety Evaluation ISE/MP3 88123, sodion 1.1 and specifically evaluated in sodion 1.2 and 1.3 of the safety evaluation form. Section 1.8 in Safety Evaluation ISE/MP3 88-123 for the ATWS modification (PDCR MP3-88 008) conter..d considerable dr'.all conceming the safety Impilcation of operation or failure of ths AMSAC system and considered both accidents mentioned Ove. Based on the conference call (12/15/97)with Sargent und Lundy/NRC/NEAC/NU lt was determined that the ISE contained an administrative shortfall in not identifying the aforementioned accidents, therefore the Significance Level for this DR should be reclassified as Significance Level 4. Condition Report (CR) M3 97 2888 was written to evaluate this condition.

NU evaluated the need to revise the safety Evaluation and concluded no corrective action it, req' aired.

NU has undertaken an initiative to in. prove the quality of safety evaluations. This initiative includes a new safety evaluation procedure (RAC 12) which provides more detailed guidance and new training classes.

==

Conclusion:==

NU has concluded that thn issue reported in Discrepancy Report, DR MP3-0009, haC "fied a condition not previously discovered by NU aluated design base accidents should have been listed an 1.1 and specifically evaluated in section 1.2 and I a safety evaluation form. Condition Report (CR) M1.. : 388 was written to evaluate this condition.

NU evaluated the need to revise the Safety Evaluation and concluded no corrective action is required.NU ha' undertaken an initiative to improve the quality of safety evale ons. This initiative includes a new safety evaluation ',..ocedure (RAC 12) which provides more detailed guidance ard new training classes.

Pr.vinuely identmed by Nur O Yee @ No NonD6ecrepentCondIll ntU Yee @ No n wi P.nanet O Ya @ N.

n.e.wi unr.e*.dtO Y.e

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Page 2 or 3

l Northeast Utilities ICAVP DR No. DRMP3 0009 Millstone Unit 3 Discrepancy Report sL Comments: (S&L Response to First Round NU Comments)

ICAVP finds the disposition not acceptatAe. The discrepancy as stated in the Description Sedion of Discrepancy Report DR MP3-0009 is that the safety evaluation for the ATWS modification

'does not address the modification's imped on an inctesse in feedwater flow accident.' We do not dispute the fad that spurious initiation of feedwater ficw is addressed in the safety evaluation. However, Part 1.1 of the NU safety evaluation form requires identification of ' design basis accidents potentially impeded by the change.' An increase in feedwater flow accident should be identified in this portion of the safety evaluation and properly addressed and evaluated in Parts 1.2 and 3 of the safety evaluation form.

e PrWed 2/1T9612;12:o8 PM Page 3 of 3

C' Northeast Utilities ICAVP DR No. DR MP3-0017 MillstDn* Unit 3 Discrepancy Report heviewGroup: AccidentIM6peton DR RESOLUTION ACCEPTED Potential Opstability lotue 06mipline: ce*'

O Yo.

Dioctopency Type: Lkoming Docuwt

@ No systeWProcess! N/A NRC Signiacance level: 4 Dele FAAed to NU:

Date Putuohed: W22S7

~

D6xresencyl Westinghouse Comments on FSAR Chapter 15.0 Douript6on: We have reviewed Westinghouse Electric Corporation letter NEU 96-623, 'Northeart Utilities Service Company Millstone Unit 3 FSAR Chapter 15 Verification. non-LOCA " dated November 25,1996, which provided NU suggested pa06 markups for FSAR Section 15.0, introduction. The purpose of these comments and markups was to provide assurance that the Millstone 3 FSAR is consistent with the Plant Safety Evaluation of record for the current fuel cyclo, The comments on this section identify changes to the initial conditions, nominal values and the reactor and ESF frip functions and sequence of event diagrams for the accidents in Westinghouse scope. These changes have not been incorporated into the FSAR making the FSAR and the Plant Safety Evaluation inconsistent.

~

A review of applicable corrective action databases for Mllistone 3 has not identified any pending FSAR change notice hems that will incorporate the Westinghouse comments into the FSAR.

Review Val 6d lovelnd Needed Date init6etor: Jahrnon, W. J.

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INVALID:

Date:

2/4/98 RESOLUTION: Disposition:

FSAR CR 97 MP3-91,inillated 2/27/97, incorporated all Westinghouse comments from letter NEU-96-623 pertaining to Chapter 15.0. Refer to attached copy of FSAR CR 97 MP3-01 for changes associated with FSAR section 15.0. The FSAR CR is currently in th6 review process with PORC approval expected by 10/21/97.

==

Conclusion:==

DR MP3-0017 identified a discrepant condition with FSAR Chapter 15.0 that NU has previously addressed. The subject Westinghouse letter and comments were evaluated and will be incorporated into FSAR section 15.0 through FSAR CR 97 MP3-

91. No further action is required.

~

Previounty iderdified try Nu? @ Yes U No Non D6ecrepent Condition 70 Yes (9) No Printed 2/13Se 12-12:s1 PM Page 1 or 2 I

Northeast Utilities ICAVP DR No. DR MP34017 untstono unit 3 Discrepancy Report RmNut6en Poneng?Q Yes @ No ResehA%Urwesolved?Q Yu @ No Review

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inmisews Jahr.aon,W.J.

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VT Leed: Rahele,ReiD O

O VT Mgri Schopfer, Don K inc chmn: swe, Anand K Dah 11/18/97 sL commwds:

O PfNed 2/1&9612:12:57 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3 0183 Millstone Unit 3 Discrepancy Report Review Group: Accident Mtipsbon DR Ftts0LUTioN ACCEPRD RMi*w Elermat: system Dese p

D6eciptim: OUwr O vm Discrepancy Type: Leleutetion g

systemPtwese: HVX NRC sW'oe lowl:4 Date faxed to NU:

1 Date Pabhehed: 10G97 rueerspency: The reference for the dispersion parameter used in the F Jet Handling Accident is not current Dacripelen: As part of verification of the resuas of the Fuel Handling Accident (FHA) in the Fuel Building (FSAR Section 15.7.4), the following calculations were reviewed:

1. XX-XXX 107RA, Rev. O, " Radiological Consequences of a Fuel Handling Accident at MP 3"

2. UR(B)-228-4," Radiological Consequences of a Fuel Handling Accident in the Fuel Building' Reference 1 is the basis for the current analysis of the FHA in the FSAR. Most of the input data in Reference 1 is taken from Reference 2. In Reference 2 the basis for the atmospheric dispersion parameter (also known as X/0) used to calculate the offsite dose was referenced to calculation 8ENVR W156. This calculation was requested (MS-RF1-00353). The responsat to this RFI (M3-lRF 00278) stated that calculation ENVH W156 was never issued and ENVR W221 is the basis for the atmospheric dispersion parameters. Therefore the reference for design input in the current design basis dose calculation is not correct.

(NOTE: A review of ENVR W221 confirmed that the atmospheric dispersion parameters documented in this calculation are the seme as the ones used as input to the dose calculation. Therefore the rosults of the dose calculation are considered valid and the discrepancy is in the documentation of the input.)

Review venid invand Needed Date inn 6stor: Johnson W.J.

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INVALID:

Date: 1/29/98 RESOLUTION: NU has concluded that Discrepancy Report DR-MP3-0183 has 6dentified a condition not previously discovered by NU which requires correction. Condition Report ( CR ) M3 97 3672 was

_ written to provide the necessary corrective actions to resolve this issue. The corrective actions to correct this issue are ( see page 20f2)

Printed 2t!3/9e 1214:13 PM PeGe 1 of 2

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Northeast Utmtles ICAVP DR No. DR MP34183 Millstone Unit 3 Discrepancy Report

1. Ensure that Calculations UR(B) 227 ar '.'Ti(b) 228 are revised to refled the correct reference.

2. Ensure that all references associated with Ca',ulations UR(B)-

227 and UR(B) 228 nre researched to chew !s inaccurate references to ENVR W156 and ensure that any references to ENVR W156 are corrected.

3. Search Passport Calculation Tracking Program to ensure that any potential references to ENVR WiS6 are identified to Engineering.

These corrective adlons will be performed prior to MP3 Startup.

Cunclusion:

NU has concluded that Discrepancy Report DR MP3-0183 has identified a condition not previously discovered by NU which requires corredion. The corredive actions necessary to resolve the Issues detailed in DR MP3 0183 will be implemented and tracked under the auspices of condition report MS 97 3672. The corrective actions outlined in Condition Report M3-97-4255 necessary to correct this issue are: 1) Ensure that Calculations UR(B) 227 and UR(B)-228 are revised to refied the correct reference. 2) Ensure that all references associated with Calculations UR(B) 227 and UR(B) 228 am researched to check for inaccurate references to ENVR W156 and ensure that any references to ENVR W156 are correded. 3) Search Passport Calculation Tracking Program to ensure that any potential references to ENVR W156 are identified to Engineering.

These corrective actions will be performed prior to MP3 Startup.

Previously Idone6Aed by Nu? Q vee @ No Non06ecrepentcondition?Q vos @ No fleeolut6cn PendingtO vos @ N.

Ree.iuiionunteeoivedtO vos @ No i

Review No D +:,"

Needed Date O

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VT Leed: Rehele, Rai D b

b VT Mgr Schopfer. Don K IRC Chmn: Sin 0h, Anand K Date:

alComments:

' Pnnled 2/139612:14:19 PM -

Page 2 of 2

j N:rthe:st Utilmies

. ICAVP DR No. DR MP3 4264 useistone unn 3 Discrepancy Report Review Group: Programmaso DR MEsoLufloN ACCEPTED Revtew Element: Corrective Acton Procese Discipens: oinw.

O yee.

D6eceepeney Type: Coneouve Aston g

systempresses: N/A NRC sientacenselevel:4 >

Date faxed to NU Datepummehed: iWise7 i

Descrepancy: Voided Unresolved item Reports (UIRs) Considered to be in 4

Scope i

Deewir#en: The following UIRs were received for review wRh the final

- disposition noted as "Vold". These UlRs are considered to be in the scope of the Configuration Management Plan (CMP) and should have been dispositioned and resolved. No irgication is given that the recommended disposition has been or will be implemented.

UlR2424

' ~

UlR2468 UIR1594-UIR1959-i UlR2314 UlR1958 i

1 UlR2143 UIR2458 UIR2472 UIR2132 UlR2256 -

noview l

= vand inveNd Needed Date inleistor Neweno, Mark G

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10'1'87-

' VT Lead: Ryan, Thomme J Q-Q 10/1/97 VT Mgr schopler DonK G

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10'18*7

- IRC Chmn: Singh, Anand K Q

Q 10/1497.'

Date:

l INVAUD:

l' Date: 2/11/98 nasoLUTIoN: NU has concluded that Discrepancy Report, DR MP3-0260, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the crHerla specified in NRC letter B16901 r 417010. It has been screened per U3 PI-20 crMena and found ' nave no operability or reportability-concems and meets tiia Unit 3 deferral criteria. CR MS 97 3804 has been written to develop and track resolution of this hem per RP-4,'

Conclusion NU has concluded that Discrepancy Report, DR MP3-0260, has identified a condhion not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per US PI-20 criteria and found to have no operability or reportability Printed 2/1W961235:32 PM Page 1 or 2 r--,e

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Northeast Utilities ICAVP DR No. DR-MP34264 Millstone Unit 3 Discrepancy Report concems trd trieets the Unit 3 deferral criteria. CR M3 97 3804 has been written to develop and track resolution of this item per RP 4.

Previoudy enthW by NUF U Yes @ No Non[Nectopent t.,onet6on?U Yes @ No

n. i m o P.nenet O Y

@ No neewenunt wv.atO v

@ No neview inanator: Nearro, Mark O

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VT L.ed: Ryan.Thomes J b

VT Mgr: Schorder, Don K Ntc Chmn: Singh, Anend K Dde:

2/11/98 st Comments: CR M3 97 3804 appropriately addresses the corrective action to be taken to resolve this DR.

4, Printed 2/139612:15:38 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3.F8 Millstone Unit 3 Discrepancy Report Review Ogoup: Petgrammetto DR RESOLUTION ACCEPTED Revlow Elemoed: Corrective Action Procese g

"'"*hne: Mehdel "*"

O va D6ecropency Type: Correedve Act6on g g, systemProceae: SWP NRC signiscence level: 4 Date faxed to NU:

Date Pub"shed: iW31/97 D6*crepency: Corrective Action Plan Documented in CR M3 971612 DescripHon: CR M3-971612 lists elevon (ii) discrepancies:

1. Eloht (8) of the items refer to discrepancies identified in Service Water System Training "SWS Text SWP076T". These eight items are identified by number In the CR as numbers 3,4, 5,6,7,9,10, and 11. The corrective action plan for the aforementioned items is acceptable.

2. Two items (identified as items 1 and 2 in the CR) refer Generally to Ceficiencies in " operator trainin0 materials" without specific reference to the actual document (s) found to be discrepant.

3. One item (identified as item 8 in the CR) refers to a description in the SWS text conceming a " bypass which has been in place since 1990 and a plan foi modification in RF06".

This discrepancy states that " bypasses of that age should be in drawlsigs and FSAR regardless of their status as modifications".

Discrepent Conditions A. From the description provided in the CR for item 2 above, it is not clear what specific operator training mat 6rlais were found to be discrepant nor If the corrective action plan which is only stated to evaluate changes and incorporate into SWP076T would resolve such identified discrepancies.

B. The corrective action plan as documented only evaluates changes for incorporation into SWP076T. This does not address the discrepancy relative to the drawings and FSAR discussed In

' item 3 above.

Review Vead invol6d Needed Date intilator: Neverro, Mark Q

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107297 VT ugr: Schopfer, Don K G

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tor 2ss7 inc chmn: steh, Anend K O

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5w2s,7 Date:

INVALID:

Date: 2/11/96 RESOLUTION: Disposition NU has concluded that Discrepancy Report, DR-MP3-0578, has identified a condition not previously discovered by NU which Printed 2/139e 12;1896 PM Page 1 of 2

1 Northeast Utilities ICAVP DR No. DR MP34878 Misistone unit 3 -

Discrepancy Report requires correction. This discrepancy meets the crHerla specified in NRC letter B16901 and 17010. It has been screened per U3 Pl.

20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferial criteria. CR M3 98 0135 has been written to develop and track resolution of this item per RP-4.

Conclusion NU has concluded that Discrepancy Report, DR MP3-0578, has Mentified a condition not previously discovered by NU which requires correction. This disclepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per US Pl.

20 criteria and found to have no operability or reportabliity concems and meets the Unit 3 deferral criteria CR M3 96 0135 has been written to develop and track resolution of this hem per RP 4.

Prev 60uely klontlaed by Nut U Yes @ No NonD6ectopentCorNellion?C Yes @ Mo R.edmionP.nenetO Yes @ No ReedunonUnreedMrO Yes @ No Review inillator: Neverro, Mark VT Leed: Ryan, Thomme J O

O m

VT Mgrt Schopew, Don K IRC Chmn: singh. Anand K Dde:

2/11/98 sL comments: Acceptance is based on the understanding that NU will correct (in a timely fashion) the descrepancy as described in the DR.

PrWed 2/139812-18:14 PM Page 2 of 2 i

Northeast Utilities ICAVP DR No. DR MP3 0591 uliistone unit 3 Discrepancy Report Revlow Group: Progre nmotic DR REs0LUTioN ACCEPTED Review Element: Change Process g

Diecipane: Otho' O vos Diecrepancy Type: 0 & M & T Procedure gg systemPreceos: N/A NRC signHlcance level: 4 Dale faxed to NU:

Dele Puldlehed: 11/2497

~

D6ecrePancy: Technical Errors in Past Procedure Changes Doocription: Procedure SP 3601F.5, Revision 3, effective 6/17/92, titled

• Reactor Coolant Valve OperabiHty* and OPS Form 3601F.5 3, Revision 2, effective 10/28/93, titled *RCS Check Valve Refueling Outage Stroke Testing

• were reviewed as part of the assessment of the technical adequacy and compliance with the licensing bases of past procedure changes.

Both procedures contain lechnical errors which have not been corrected in later procedure revisions as viewed on WorldView, nor were any corrective action documents or pending rtanges found which are tracking the correction of these procedures.

1. The note following paragraph 7.1 of SP 3601F.5 states that the plant must be 'n Mode 6 in order to test valves ORCS *V26 and 3RCS*V102. Table 1.2 of the Technical Specifications defines Mode 6 in part as the reactor vessel head closure bolts less than fully tensioned or the reactor, head removed.

Relief R 1, added to the Inservice Test Program (IST) Program on 5/20/95, states under *Altemale Testing" for these valves:

'The valves will be full stroke exercised during refueling outages when the reactor closure head is removed? The reason given In R 1 for not fully stroking the valves at cold shutdown is that doing so risks overpressurtzing the reactor coolant system.

Therefore, SP 3601F.5 does not agree with R 1 Ins.ar as it allows these valves to be fully stroked with the head on the reactor and the bolts detensioned.

Paragraph 3A of SP 3601F.5 refers to the 1980 Edition of ASME Section XI with the Winter,1980 Addenda. The IST Program is based on the 1983 Edition with the Summer,1983 Addenda.

2. SP 3601F 5, page 3, shows the test position for 3SlH*V19 as open whereas the IST Program shows it as closed. Page 3 also shows the test posittori : f 3S!H'V100 as closed whereas the IST Program shows it as both open and closed.

Review Valid invaad Needed Dite initiator: Shepperd, R. P.

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- INVAUD:

s' Pnnled 2/139612-18.56 PM Pope 1 of 2

Northeast UtilRies ICAVP DR No. DR-MP3 0591

~

Millstone Unit 3 Discrepancy Report Dele: 2/11/96 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report DR MP3 0591, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the crtteria specified in NRC letter 816901 and.17010 it has been weened per U3 Pl.

20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3 96-0492 has been written to develop and track resolution of this item per RP 4.

==

Conclusion:==

NU has concluded that Discrepancy Report, DR MP3-0591, has

)

identified a condition not previously discovered by NU whic requires coliection. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 Pl.

20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3 96-0492 has been written to develop and track resolution of this item per RP 4.

Previously identift d by NUF ()Yee @ No Non D6ecropont Condson?(.) vos @ No Reeolut6on Pend 6ne?O vos @ w.

Ree wienunreadvoorO vos @ No Review kcep able Not ^ ^{ ;" - Needed DWe m or sW, R. P.

G G

O

=

VT Leed: Ryan, Thomme J O

O O

N VT Mori schopler Don K wic chmn: sineh Anand K DWe:

2/11/96 sL commwee: 1. NU's explanation in CR M3-96-0492 thn.t the Code edition referenced in Procedure SP 3601F.5 was corrected and why the valve positions shown in Procedure SP 3601F 5 are correct is acceptable.

2. NU's proposad corrective action for item 1 (clarify the surveillance frequency section) is acceptable.

PrHed 2/13Se 12:19:02 PM Page 2 of 2

4 ICAVP DR No. DR-MP3-0606 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Elennnt: CorrectNo Action Procoes p,,

Diecipline: Ctner Ow-Dioctopency Type: Corredke Action gg System /Procese: N/A NRC SL.1 me level: 4 Date faked to NU:

Date Putdished: 11/2N97 06screpancy: Insufficient Corrective Action Plan o ecripuon: The ACR # M3 0429 Corrective Action Plan does not require docw.nentation of the 'as-built

• condition in either the drawings or specification.

Per the ACR Block # 2, the Installations (as described in Block

1. 2) are not in accordrince with drawing CE-54 cnd expose the Blue Cable ;o less than 3-feet horizontal (21-inches) from Neutral Cables from penetration 3RCPS-6V. This violates separation requirement from Specification SP-EE-076, Per the ACR Block # 4, thh ACR was reviewed against the operability evaluation MP3-247 96 provided for ACR 96-131.

Since the cables are greater than 6-inches away horizontally from neutral cables from penetration, the cables are considered operable based on Wyle Test Configuration 3, This "as-built" corJiguration should be documented on design documents (e. 9. through a drawin0 or specification revision),

y a

Update of the design documents are not a part of the Corrective Action Plan.

Review Valid invalid Needed Date initiator: Caruso, A.

O O

O 11/1/97 VT Lead: R1n,Thome J Q

Q 11/1/97 VT Mor: sciopfer, Don K G

O O

11'S/S7 IRC Chmn: singh. Anand K Q

]

.11/19/97 oste:

IrJ'AL10:

Date: 2/11/96 RECOLLTTION: D}$pos} tion; Nu has concluaed that Discrepancy Report, DR MP3-0605, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC'ietter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no aperability or reportability concems cod meets the Unit 3 deferral criteria. CR M3-98-0135 has been written to develop and track resolution of this item per RP-4.

==

Conclusion:==

NU has concluded that Discrepancy Report, DR-MP3-0605, has identified a condition not previously discovered tr/ NU which

.1x;uires correction. This discrepancy meets the critoria specified in NRC letter 216901 and 17010. It has been screened per U3 PI-Printed 2/13/9e 12:2071 PM Pege 1 of 2

s l

Northe=t Utilitle3 ICAVP DR No. DR-MP34406 Millstone Unit 3 Discrepancy Report 20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferr61 criteria CR M3-98-0135 has been written to develop and track resolution of this item per RP 4.

Attachments: CR M3-98-0135 Prov6ously kloctHled by NU7 U Yes @ No NonD6ecrepentcondition?Q Yes (#) No nasuiionP.nsne70 va @ No naduiionunr=wved?O Ya @ No Review

""d*d inittstor: ceruso, A.

G O

O na VT Lewi: Ryen, Thomas J VT Mgr: Schopfer, Den K mc chmn: $1ngh, Anand K Date:

2/11/98 sL comments: Acceptance is based on the understanding that NU will correct the discrepancy as described in the DR.

[

Printed 2/13/9612:23.33 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3 0011 Millstone Unit 3 Discrepancy Report Review Oroup: Pivy.6. A DR RESOLUTION ACCEPTED Review Element: Operating Procooure g

Diecipline: Operet.one Om Diecropency Type: 0 & M & T Procedure

@ No Systemprocess: N/A NRC Signiacence level: 4 Date faxed to NU:

Date Published: 11/2497

~

Discrepency: Abnormal Operating Procedure AOP 3572 Minor Discrepancy Descript6on: AOP 3572 Rev. 4 included in part, a change to step 8b RNO (Respnse Not obtained) column to ' establish emergency makeup using EOP 3505A, Loss of Spent Fuel Pool Cooling *,

Entrance to the RNO column stems from failure to successfully imp'ement step Ba which says

• Establish normal makeup from RWST using OP 3305...Section 7.3.2".

3 Of the makeup supplies identified in Attachment A of EOP 3505A, steps 2,5 and 6 are idantified as

• Emergency Makeup *,

Step 2 is for emergency makeup from the RWST, Step 5 is for local emergency makeup from the fire protection water system, Step 6 is for local emergency makeup from the service water system EOP steps are performed in order, unless specifically etirected otherwise. The wording used (i.e. Emergency Makeup) in the B

revision of AOP 3572 Rev. 4 step 8b RNO column could be taken as an instruction not to perform step 4 of EOP 3505A (Attachment A Rev.2) which is to supply makeup from the primary grade water system since th% supply is not identified as an " Emergency Makeup

• supply. Since it is the intent of EOP 3505A Attachment A to attempt makeup from the Primary Grade Water System (step 4) prior to attempting makeup from the Fire Protection (step 5) or Service Water System (step 6), and since the Primary Grade Water Supply is not identified as an

• Emergency Makeup

• supply in the EOP, AOP 3672 sWp 8b

}

RNO column should be revised to be consistent with the intent of the EOP and to avoid confusion.

Review Valid inveled Needed Date initiator: Neverro, Mark 8

O O

" 'S7 VT Leed: Ryan, Thornes J G

O O

11'3/87 VT Mgr: schopfer, Don K G

O O

11'S/S7 IRC Chmn: Singh, Anand K G

O O

15'1S'87 Date:

INVALID:

w Date: 2/11/98 RESOLUTION: Disposition NU has concluded that Discrepancy Report, DR-MP3-0611, has identified e condition not previously discovered by NU which requires rauection. This discrepancy meets the criteria specified Printed 2/13/9e 12 2100 PM Page 1 of 2

Northeast Utilities

!CAVP DR No. DR-MP3-0411 uitistan. Unit 3 Discropancy Report -

In NRC letter B16901 ano 17010. It has been scresned per U3 PI-20 criteria and found to have no operability or reportabili'y concems and meets the Unit 3 deferral criteria. CR M3-98-0134 has bee.1 written to denlop and track resolution of tlas item per RP-4.-

Conclusion NU has concluded that Disciepticy Report, DR-MP3 0611, has identified a condition not previously discovered by NU which requires correctior,. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no vperability or reportability ccncems and meets the Unit 3 hierral criteria. CR M3 96-0134 has been written to develop and track resolu'lon of this item per RP-4.

Prevkmely klentmed by NU7 U Yes

~@ No Non Discrepent Condition?O Yes @ No

~

P.6aolutionPending?O vos @ No ResolutionUntosolved?O vos @ No Review Accepteble Not Accape haa Needed Date VT Leed: Rpn, Thames J b

b VT Mpr: schopfw DonK Sin 0. Anend K h

IRC Chmn:

Date:

2/11/98 sL commente: Acceptance is based on the understanding that NU will correct the discrepancy (in a timely fashion) as described in the DR.

h 1

PrWed 2/13/9812.21:16 PM Page 2 of 2

Northe:st UtRitbo ICAVP DR N3 DR-MP3 0653 Millstone unit 3 Discrepancy Report Reb Group: Programmenc DR RESOLUTION ACCEPTED Revbw Element: Corrective Action Process D6ecipline: Mechanical Desig" O Y=

W - y Type: calcuation g

System / Process: N/A NRC SigMT.cance level: 4 Date FAhd to NU:

Date Putdished: 12/7/97 D6 crepency: Design Basis Calculation for Ventilation System Described in Design Deficiency Report (DDR) No. 870

==

Description:==

The DDR was originally dispositioned on 1/21/86 as " accept as is'. The technical justification included an estimate (not calculation) of maximum credible hydrogen concentration in air for the portion of system of interest and concluded that the design (which uses compressed air as pairge supply for the rad monitors sample) was acceptable and that no further action was warranted. Another document in the DDR package (labeled to GMB 87 R-192) documents a subsequent review of the DDR disposition concludina thet documentation is inaoequate...and that the estimate of hyJrogen concentration in the original disposition should be documented in a formal calculation with traceable references. This subsequent review was dated and signed on 5/22/87. No evidence in the package exists to indicate that the actions to prepare a formal design basis calculation were completed.

Review Valid InveNd Needed Date insenator: Neverro, Mark 8

O O

tiie/97 VT Leed: Ryen, Thomas J G

O O

11'1S'S7 VT Mgt: schopfer, Don K Q

O O

12/1i87 IRC Chmn: singh, Anand K O

.O O

2i3/97 Dei.:

INVALID:

Date:

2/4/98 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report DR-MP3-0653 does not represent a discrepant condition. The attached formal calculation on this subject was issued as no. 88-RPS-599 GM, Hydrogen Concentration in Rad Monitor 3HVR*RE19A/B. Significance Level Criteria do not apply since this is not a discrepant condition.

Conclusion NU has concluded that the issue reported in Discrepancy Report DR-MP3-0653 does not represent a discrepant condition. The subject of this report has been addressed by calculation no. 88-RPS-599 GM. Significance Level Criteria do not apply, since this is not a discrepant condition.

Previously Idwntifled by NU? U Yes @ No Non Discrepent Condition?@ Yes O No Resolution Pend 6ng?O e.

@ No no.aut% unre.aved?O Ye.

@ No Printed 2/13/961222:13 PM Page 1 of 2

i Northea:t Utilities ICAVP DR No. DR-MP3 0463 Mmstone unit 3 Discrepancy Report n.

b*

Initletor: Neverro, Mark O

O

=

VT Leed: Ryan, Thomas J D

D

=

VT Mgr: Schopfer, Don K II #

IRC Chmn: S@, Anend K

-e SL Comments:

Pe 2 of 2 Printed 2/1396122219 PM

Northeast Utilities ICAVP DR No. DR %e>3 0662 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance end Testing DR RESOLUTION ACCEPTED Review Element: Test Procedure Diecipline: Operations Ow D6ecrepancy Type: CorrectNe Action gg systerWProcese: DGX NRC signiacence level: 4

- Date Faxed to NU:

Date Pulsehed: 11i24<97 Disaepency: DG suiveillance tests could be conducted with lube oil temperatures less than 115 degrees F Descrg en: LER 87-003-00 commits to "... surveillance tests will not be conducted unless tube oil temperatures are at least 115 degrees F (and increasing) after the tube oil heater has been re-energlied."

A search of NU maintenance and operating procedures for the diesel generators could find no reference to this specific commitment.

A review of operating procedures reveals that in OP 3346A,

, e

' Emergency Diesel Generator", there is a prerequisite (Step 4.1.1.e) that the tube oil temperature be greater than 110 degrees F or rising. The basis for this setpoint is a manufacturer's recommended low temperature alarm. A search of station documents did not reveal any subsequent transmittal to the NRC that changed the commitment made in the referenced LER.

Other diesel generator operating procedures reviewed reference the prerequisites in OP 3346A.

The use of the phrase ' greater than 110 degrees F or rising" could abo be interpreted to mean that the lube oil temperature could actually be icis than 110 degrees F as long as the temperature was rising, it is concluded that there is nothing in the existing procedures from precluding the diesel from being started with the lobe oil temperture less than 115 degrees F and possibly less than 110 degrees F.

Review Valid invalid Needed Date inRistor: Tomlyn, Tom G

O O

tii 2/97 VT Leed: Bess, Ken 9

O O

isi12/97 VT Mgt: schopfer, Don K G

O O

11'17/S7 1RC Chmn: singh, Anand K G

O O

3ti2oro7 Date:

INVAUD:

Dek: 2/10/96 RESOLUTION: Dispos [;lon; NU has concluded that DR-MP3-0662 idensfies a condition previotsly discovered by NU which bn been addressert. The commitment to ensure that the DG lube oil temperature is at Page 1 of 2 Printed 2/13G31223:04 PM

Northeact Utilities ICAVP DR No. DR-MP34662 Miitstone unit 3 Discrepancy Report least 115'F is no longer required ( See Attached AR 97014434-01 Closure Request ). The current DG lube oil temperature requirement is 110 'F prior to start as detailed on OPS Form 3346A-14 Rev 7 CHG 5 ( See Attached ).This issue was previously identified by UIR 122.

==

Conclusion:==

NU has conclud2d that Discrepancy Report DR-MP3-0662 identifies a condition previously diswvered by NU which has been addressed. As detailed in the disposition, the ccmmitment to ensure that the DG lube oil temperature is at least 115'F is no longerrequired(See Attached AR 97014434-01 Closure Request ). The current DG lube oil temperature requirement is 110 'F prior to start as detailed on OPS Form 3346A 14 Rev 7

CHG5, This issue was previously identified by UIR 122.

PNviously idenuAed by NU7 (6) Yes Q No Non Discrepent Condition?Q Yes (#) No Resolution Pending?O Ye.

@ No ResolJtionUnresoNed?O Yee

• No Review Acceptable Not tcceptable Needed Date hm Sm R.

VT Lead: Bass, Ken W Mgr: schopfer, Don K IRC chnn: Singh, Anand K De 2/10/98 sL comments:

Printed 2/1M612 23:10 PM Page 2 of 2 l

Northe:st Utilities ICAVP DR No. DR-MP3-0672 Miiistone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: CorrectNe Action Process Diecipline: Otho' O yes D6ecropency Type: corre **ve Achon gg system /Procese: N/A NRC 56gnHlcance leW: 4 Date faxed to NU:

Date Published: 12/8/97 D6screpancy: Improper incorporation Documents are Referenced in EWR No. 3-93-00132 Desctlption: EWR No. 3-93-00132 requested the incorporation of all outstanding Calculaton 188E Rev.1 CCN's and the NRC comments per NRC-EDFSI (Information Request) IR No's. 3327 and 3339 into Revision 2 of Calculaton 188E.

EWR No. 3-93-00132 was closed out based upon issuence of Revision 2 of Calculaton 168E dated 12/22/94. Revision 2 incorporated CCN #1 through CCN # 8 and the NRC comment pertaining to IR No's. 3327.

NRC-EDSFl IR No. 3339 was not incorporated into Revision 2 of Calculaton 188E.

Calculaton 188E is limited to the sizing of the 125V DC System batteries and chargers; consequently, IR No. 3339 is not applicable to Calculaton 188E, IR No. 3339 pertains to derating factors used in cable sizing for 480V/4.16kV power cables and was to be incorprated into the cable sizing calculations. IR No.

3339's Narrative stated that " Cable sizing calculations do not appear to show derating f actors for 480V / 4.16kV power cables in trays (random fill) or condults".

EWR No. 93-00132 incorrectly requested NRC-EDSFI IR No.

3339 is to be incorporated into Calculaton 188E.

It is not known if the NRC comments as coverM in NRC-EDSFl IR No. 3339 have been incorporated into the appropriate cable sizing calculation (s).

Review Valid invalid Needed Date initiator: Caruso. A.

Q Q

Q 11/14/97 VT Lead: Ryan, Thomme J G

O O

1 S'S7 VT Mgr: Schopfer, Dor' K G

O O

12/1/97 IRC Chmn: Singh. Anand K G

O O

12/4/97 Jete:

INVALID:

Date: 2/11/98 RESOLUTION: Dispositjon; NU has conclutted that Discrepancy Report, DR-MP3-0672, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC ietter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or reportability Printed 2!13/9e 2:21:s4 PM Pe9e 1 of 2

Northeost Utilities ICAVP DR N3. DR-MP3-0472 un: stone unit 3 Discrepancy Report concems and meets the Unit 3 defenal criteria. CR M3-98-0135 has been written to develop and track resolution of this item per RP-4.

==

Conclusion:==

NU has concluded that Disciepancy Report, DR MP3-0672, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or repcriability concems and meets the Unit 3 deferral criteria. CR M3-98-0135 has been written to develop and track resolution of this item per RP-4.

Attachments: CR M3-98-0135 Previously identleed by NU? O Yes @ No NonD6screpentCondetion?O Yes (G) No Resolut6on Pend 6ng?O Yes @ No Resoiuiionunresotved?O vos @ No l

Review Accepteblo Not Accepteble Needed Date g,,,

%g VT Leed: Ryan, Thomas J O

O VT Mgt: Schopfer, Don K IRC Chmn: singh, Anund K Date:

2/11/98 sL Commente: Acceptar.ce is bated on the understanding that NU will correct the discrepancy as described in the DR.

Printed 2/135le 2:22:co PM Pege 2 of 2

Northeast Utilities ICAVP DR No. DR MP3-0730 Miiistone unit 3 Discrepancy Report Review Group: Programmatic DR RESoLUTioh ACCEPTED Review Element: CorrectNo Action Process Diecipline: I & C Design O va Discrepency Type: CorrectNo Action

@ No SystemProcess: HVX NRC Significance love.1: 4 Date faxed to NU:

Date Putnished: 1/3S6 -

D6ecrepency: Lack of setpoint implementation documentation and unverified assumptions.

==

Description:==

Design Deficiency Report (DDR) 973 is resolved through E&DCR 2

N EC-01733. This E&DCR adjusts the setpoint of flow switches without revising the setpoint calculation. The E&DCR does not state what is the average flow value or where this information is documented. The E&DCR states the revised setting is "just below" the average flow value without quantifying this margin.

Review Valid invalid Needed Date Inluetor: Dombrowald, J6m O

O O

12/547 VT Lead: Ryan, Thomas J G

O O

2/a/97 VT Mgt; schopfer, Don K Q

O O

12:11/97

RC Chmn

Singh, Anand K G

O O

12:24/97 Deio:

INVALID:

Date: 2/11/98 RESOLUTION: NU has concluded that Discrepancy Report, DR MP3-0730, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 h has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0494 has been written to develop and track resolution of this item per RP-4.

CR M3-98-0494 Previously identitled by NU? Q Yes (f) No NonD6screpentCondition?U Yes

(*) No Resolution Pending?O ve.

@ No Resolution Unresolved?O ve.

• No Review Ac eptable Not Acceptable Needed Date inMor* M W M VT Leed: Ryan, Thomes J VT Mor: schopfer, Don K IRC Chmn: S.rgh, Anand K Date:

2/11/98 st Comments: Acceptance is based on understanding that NU will correct the discrepancy as described in the DR.

Printed 2/13r96 2:239 PM Page 1 of 1

Northecct Utilities ICAVP DR No. DR-MP3 0760 g

Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION 'CCEPTED ev wE W : W M W m Potential OperabilKylasue Diecipline: Otho' Om Discrepancy Type: corrective Action

(#') No SysterrVProcess: N/A NRC significance level: 4 Date faxed to NU:

Date Published: t/396 D4screpency: Failure to implement Design Deficiency Report

==

Description:==

DDR # 803 superseded DDR # 42 and DDR # 43. The design es shown on the DDR # 803 drawings ESK-5BD and SBE adds the Bus Tie Breaker 52S-3 ENS *ACB-TA (B) contact as an interlock to the Reserve Station Service Breaker 3 ENS *ACB-AR and 3 ENS *ACB-BR control circuits.

The Plant Design Change Request (PDCR) # MP3-07-20 Evaluation Form disapproved the incorporation of DDR # 803 on the basis that the 'affected ESK's (SBE and SBF) presently show this design inr:orporated".

The design, as shown on the DDR # 803 drawings, was not incorporated based on a review of the latest drawin0s 25212-31001 Sheet 5 BD, Rev. 25, 25212 31001 Sheet 5 BE, Rev.

24, 25212-31001 Sheet 5 BF, Rev.18 and 25212-31001 Sheet 5 BG, Rev. 20.

Review Valid invalid Needed Date initiator: Caruso. A.

Q Q

Q 12/9/97 VT Lead: Ryan, Thomas J B

O O

12sS7 VT Mgr: schopfer, Don K O

O O

52ittr97 IRC Chmn: singh, Anand K Q

O O

$ 2/2+97 Date:

PNAUD:

Date: 2/11/98 RESOLUTION Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0750, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0494 has been written to develop and track resolution of this item per t

RP-4.

==

Conclusion:==

NU has concluded that Discrepancy Report, DR-MP3-0750, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified n

in NRC letter C16901 and.17010 It has b0en screened per U3 PI-e 2rl criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0494 has been written to develop and track resolution of this item per RP-4.

Printed 2/13/De 2 23 48 PM Page i e' 2 1

N:rtheast Utilitie3 ICAVP DR No. DR-MP3-0750 M!iistone unit 3 Discrepancy Report Attachments: cR M3 98-0494 Prevkmely klontifned by NU? U Yes (G) No NonDiscrepentCondition?Q Yes (8) No n.e*iion PeamnetO Yes @ No nee *iionunradadtO Ya @ No Review initiator: Caruso, A.

VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K 1RC Chmn: Singh. Anand K Date:

• 111/98 s;. Comments: Acceptance is based on the understanding that NU will correct the discrepancy as describec in the DR.

d.

I v

Page 2 of 2 Printed 2/13S6 2-23:55 PM

Northeast Utilities ICAVP DR No. DR-MP3-0761

~

Millstone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Discipline: I & C Design O va Discrepancy Typo: Procedure implementation g

System /Procese: QSS NRC Significence level: 4 Date faxed to NU:

Date Published: 1/10/96 D6screpency: Setpoint change without modification package.

Ducription: The setpoints for instruments 3OSS*LS56A thru D, affected by setpoint calculation SP-3QSS-9, and 3SWP*FIS36A & B, FIS37A & B and FIS118A & B, affected by setpoint calculation 3-ENG 106 were revised without implementing the change through the use of an appropriate modit.0,ation process. No implementing documentation (e.g. SCR, PDCR, DCR) was provided when requested frcm NU.

Review vend invand Needed Date initletor: Dombnmaid, Jim B

D D

12/is/97 VT Leed: Ryan.Thomes J G

O O

12/1ais7 VT Mor: schopfw, Don K O

O O

12/23/97 IRC Chmn: singh, Anand K Q

Q Q

52/31/97 Date:

INVAUD:

Date: 2/11/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0761, does not represent a discrepant condition.

The setpoint changes are implemented using the Design Change Request (DCR) and Minor Modification (MMOD) process described in chapter 3 of the Design Control Manual (DCM).

The implementing documentation for Setpoint Calculation 3-ENG 106 rev.1 and FIS37A & B is MMOD M3-97558 and ACR M3-97-0430 which are attadied. Instruments 3SWP*FIS36A & B and FIS118A & B were found acceptable and did not change as stated in the setpoint calculation. The RWST/QSS level Setpoint Calculation SP-3OSS-D is not presently implemented in the field.

DCR M3-97106 will be the implementing documentation. DCR M3-97106 for Setpoint Calculation SP-3QSS-9 is presently in the final stages of development and will be completed prior to startup. Page 1 of DCR M3 97106 is attached. NU has updated the DCM procedures to add aa " Installation Verified

• box on the Calcu!ation CCN Title Page. This box will eliminate confusion about if a setpoint has been updated in the field.

Significance Level criteria do not apply here as this is not a discrepant condition.

Previc,uely identified by NU7 O Yes @ No Non Discrepar4 Condition?@ Yes O No Resolution Pending?O ves @ No Resoiutionunresoived?O vos @ No Review initletor: Dombrowsid, Jim VT Leed: Ryan, Thomas J VT Mgr: Schopfer, Don K Prtnted 2/13/96 214:37 PM Page 1 of 2

Northes;t Utilities ICAVP DR No. DR-MP3-0761 uitistone Unit 3 Discrepancy Report O

d O

2n2Se RC Chmn. S@, Anand K O

O-O Date:

2/11/93 sL comments: Since the Modification Packages (Design Change Requests) have now been supplied, S&L agrees that DR-MP3 0761 does not represent a div.repant condition, 4

4 s

enneed 2na/9e 22443 PM

%2W 2

Northeast Utilities ICAVP DR No. DR-MP3 4769 Millstone unit 3 Discrepancy Report Review Group: Opershone & Maintenance and Testing DR RESOLUTION ACCEPTED Rev6ew Element: Change Process Niel @blHty leeue Diecipline: Operatione O vee Discrepency Type: O 4 M & T Procedure

@ No Systsrn/Procese: sWP NRC Significence level: 4 Date faxed to NU:

Date Published: t/to/96 Discrapency: Procedure revisions required by design change are not complete.

==

Description:==

PDCR# MP3-86-017, page 10 requires revisions to Op Forms 3326 9 and 3326-10, Revision 4, Change No.1 following completion of plant design change to Include the new valves.

PDCR closure Memo dated March 26,1996 also clates that the OPS Forms Revision 4, Change 1 were revised and approved by PORC on 3/8/96. A review of revision 5 (Eff 10/3/97) to the aforementioned OPS Forms discloses that only one valve in each train was added, *V685 for A Train (OPS Form 3326 9) and

• V686 for B Train (OPS Form 332610). Valves *V682 (A T rain) and 'V683 (B Train) were omitted. This omission is a descrepancy.

Review Valid invalid Needed Date initiator: Terreyn. Tom 8

O O

$2ii7/97 VT Lead: Bees. Ken 9

O O

i2itars7 vT Mgr: schopfer DonK S

O O

$2/23/97 mc chmn: singh, Anand K B

O O

$2/a1197

~

Date:

INVALIO:

Date: 2/10/96 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0769 does not represent a discrepant condition. Four valves (*VG32, *V683, *V685 and *V686 were added to OPS Form 3324 9 and 3326-10 Rev. 4 to comply with PDCR# MP3 -

86-017. Tw2 valves were added to Ops Form 3326-9 (*V682 and 1

• V685) and two were added to OPS Form 3326-10 (*V683 and

• V686). Operations revised OPS Forms 3326-9 and 3326-10 Rev. 4 to Rev. 5 and moved valves *V682 and *V683 to OPS Form 3326-1 Rev. 8 and 3326-2 Rev. 9 respectively. Significance level critetta does not apply as this is act a discrepant condition.

==

Conclusion:==

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0769 does not represent a discrepant condition ' he valves were added to Ops Form 3326-9 and 3526-10 Rev. 4 to concur with PDCR MP3-86-017. Operations revised these forms (Rev. 5) and moved two of the valves to Ops Form 3326-1 Rev.

8 and 3326-2 Rev. 9 to enhance system alignment and j

equipment operation..No corrective action is required. Significance level criteria does not apply as this is not a discrepant condition g

previa"*'y MHlad hv NL1? r 3 Yaa (9) h Nnn rwarran.d enn,talnn?(G) Yaa fIh Printed 2/13/9e 225:21 PM Page 1 of 2 i

l 1

Northeast Utilities ICAVP DR No. DR MP3-0769

~

Millstone Unit 3 Discrepancy Report

.:_. ~_...

^

ne=*monPoamastO va @m ne=*monunreecwtO va @ No Review Acceptable Not Acceptable !bded Date Mw: S R.

VT Lead: Bass, Ken VT Mgr Schopfer, Don K IRC Chmn: Singh, Anand K Date:

SL Comments:

Printed 2/13/96 2 25:27 PM Page 2 of 2

Northe:st Utilitle3 ICAVP DR NO. DR-MP3 0811 Millstone Unit 3 Discrepancy Report Review Group: Pro [ emmet 6c DR REs0LUTION ACCEPTED Rwh E W : C W N ees Potential Operability leeue Discipline: 1 & C Deelen O v.

Diecrepency Type: Procedure implementation

@ No System /Procese: HVX NRC signlScence level: 4 Date faxed to NU:

Date Published: 1/1096 D6screpancy: Verdor manual change without implemcnting document.

==

Description:==

DCN DM3-S-0874-94 installed a replacement pressure gauge; however, no vendor manual update is referenced as an affected document Vendorinformation/ documentation should have been processed in conjunction with the modification documer.!ation for maintenence purposes per station procedure DC-6, Rev,0, dated 7/1/94. No implementing / distribution form (Attachment 8) was provided when requested from NU. The status of the affected vendor manual is indeterminate.

j Review Veild invalid Needed Date Initletor: Dombroweld, Jim O

O O

52/is/v7 VT Lead: Ryan. Thomas J G

O O

t2/22/97 VT Mgr: schopfer, Don K Q

Q 12/23/97 IRC Chmn: singh, Anand K Q

Q 12/31/97 Date:

INVALID:

Date: 2/11/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0811, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B18901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0493 has been written to develop and track resolution of this item per i

RP-4.

Previously kJentifled by NU7 Q vos @ No Non Discrepent Cundition?O vos @ No Resolution Pending70 vos @ No Resoeuiionunresoeved70 vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Ryan, Thomas J VT Mgt: schopfer, Don K IRC CPmn: Singh, Anand K Date:

2/11/98 st commente: Acceptance is based on understanding that NU will correct the discrepancy as described in the DR.

Printed 2/1396 7:26:42 PM Page 1 of 1

I Northeast Utilities ICAVP DR No. DR-MP3-0859 Millstone Unit 3 Discrepancy Report Review Group: Pic,ri.ii. ele DR RESOLUTION ACCEPTED Rev

CW Wocess PotentialOperability issue Diecipline: Oth" Om Discrepency Type: Drawing

@ No SystenVProcess: SWP NRCS'f":We level: 4 Date FAXediJ NU:

Date Published: 1118/9e D6screpency: Failure to Assign Drawing Category Codes to Drawings included in Design Change Notice Packages.

Descriph: The NU Design Control Manual, Rev. 5, Chapter 7, Section 5.1 states 'The Design Engineering Manager specifies the t

appropnate Drtwing Category Code when a new drawing is submitte:I to GRITS for control.'

in GRITS, no Drawing Category Code was assigned to Drawing 25212-29144-00050, Revision *NEW" (Vendor Drawing 2178.430-144-050) included in DCN # DM3-S-0414-90 (System 3326).

In GRITS, no Drawing Category Code was assigned to Drawing 25212-20098-00002, Revision 02 included in DCN # DM3-S-0026-96 (System 3326).

With the omission of the Drawing Category Codes, it is not known if or when these drawings will be incorporated or revised per noted DCN's.

Review Valid invalid Needed Date InMietor: Caruso, A.

Q Q

12r23/97 4

VT Lead: Ryan, Thomes J B

O O

12r23/97 VT Mge: Schopfw, Don K B

O O

12r23/97 IRC Chmn: Singh, Anand K Q

Q 1114/98 Date:

INVAUD:

Date: 2/11/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0859, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3 98-0648 has been written to develop and track resolution of this item per RP-4,

==

Conclusion:==

NU has concluded that Discrepancy Report, DR MP3-0859, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC tetter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or reportability concerns and meets the Unit 3 deferral criteria. CR M3-98-0648 Prtnted 2'13/96 2 27:28 PM Pege 1 of 2

Northe st Utilities ICAVP DR No. DR-MP3-0869 Millstone Unn 3 Discrepancy Report has been written to develop and track resolution of this item per RP-4.

Attachments: CR M3-9b0646 PreYlously identmed by NU7 U Yes (() No NonDiecrepentCondition?U Yes (fl No ResolutionPend6ng?O Yes @ No Resolutionunresolved?O Yes @ No Rev h-M ;^ ^ W?:,"

Needed Dele g,

VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:

2/11/98 st Comments: Acceptance is based on the understanding that NU will co Tect the discrepancy as described in the DR.

Pdnted 2/1MI6 2:27:35 PM Page 2 of 2

Noithe:st Utilities ICAVP DR No. DR-MP3-0909 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Elemord: CorrectNo Action Process Discipline: Other.

Discrepancy Type: CorrectNo Action implementation g

SystemfProcese: N/A NRC Sigedftcence level: 4 Date faxed to NU:

Date Putsi6ehed: 1sl7/96

~

D6screpency: Caosure of Unresolved item Report (UIR) 36

==

Description:==

The Discrepancy item Closure Package (DiCP) for UIR 36 Irdicates that item 2 of the UlR was resolved by OIR 84.

Contrary to the above, evidence was not found in the DICP and included documents rSlated to OIR 84 to show that part of item 2 of the UIR was resolved.

Discussion UIR 36, item 2 documented a concem regarding inconsistency between FSAR sections 6.2.1.1,1, page 6.2.13 (FSAR section 6.2.1.1.3.6) and PDCR MP3-89-013 regarding peak containment pressures reached during a LOCA. The closure documentation in the DICP for this concem indicates that the concem was -

resolved by OIR 84.

A review of OIR 84 and its closure package indicated that OIR 84 did resolve the inconsistency issue for FSAR section 6.2.1.1.1 (which is part of UIR 36 item 2). hr"vever the issue of inconsistency (also documented in UlR 36 item 2), relative to FSAR page 6.213 (section 6.2.1.1.3.6) was not addressed as part of OIR 84 resolution, in fact, the inconsistency issue documented in UlR 36, item 2 for FSAR page 6.2,13 (FSAR section 6.2.1.1.3.6) is not documented as a concem in OIR 84, therefore closure of this portion of UlR 36 to OIR 84 is not correct.

Review Vaud invalid Needed DMe initiator: Neverro, Ma x 8

O O

12/ea7 VT Lead: Ryan.Thomme J Q

Q 12/267 VT Mgt: schopfer, Don K Q

Q 1/12/98 1RC Clwnn: singh, Anand K G

O O

'13/9e Date:

12/24/97 INVAUD:

Date:

2/6/98 RCSOLUTION: Disposition NU has concluded that discrepancy report DR-MP-0909 has identified a conditi.sn not previously discovered by NU which requires correction. A review of FSARCR 97 MP3-543 reveals that FSAR page 6.2-13 identified in UlR 36 was included for change in the FSARCR but not for revising the value given for peak cot.tainment pressure. FSAR page 6.2-13, section 6.2,1,1.3.6. must be updated to reflect the peak containment prescu e as 38.4 psig instead of current value of 38.49 psig.

Printed 2/13/96 2:29:02 PM Page 1 of 2

Northeist Utilitlos ICAVP DR No. DR-MF3 0909 Millstone Unit 3 Discrepancy Report FSARCR 97 MP3-543 only changed the containment pressure y

vP na in section 6.2.1.1.1, item 1. Calculation 12179-US(B)-273, i

Rev. 6 is the basis for the peak pressure of 38.4 psig. CR M3 98-0460 was initiated to develop the corrective action to correct the FSAR with a FSARCR. The corrective action for CR M3 93 0460 revised FSARCR 97 MP3-543 to include the correct calculated peak containment pressure of 38.4 psio on Page 6.2.13 Section 6.2.1.1.3.6. The corrective action has been completed. No field modifications will be required.

Conclusion NU has concluoed that discrepancy report DR MP-0909 has identified a condition not previously discovered by NU which requires correction. A review of FSARCR 97 MP3-543 reveals that FSAR page 6.213 Identified in UIR 36 was included for change in the FSARCR but not for revising the value given for peak containment pressure. FSAR page 6.213. section 6.2.1.1.3.6, must be updated to reflect the peak containment pressure of 38.4 psig instead of 38,49 psig. CR M3-98-0460 was k

initiated to develop the corrective action to correct the FSAR f

with a FSARCR.

Previously identineJ by NU? O Yes @ No Non D6screpent Condition?O Yes @ No Resolution Pend 6ng?C Yes @ No Resolutio.1 Unresolved?O Yes @ No Review initiator: Novem.. Mark VT Leed: Ryan, Thomas J VT Mgt: Schopfe'. Don K IRC Chmn: 3@. A. A K Date:

SL comments:

Printed 2/13,90 2:29:c8 PM Pege 2 of 2

I Northe st Utilities ICAVP DR No. DR-MP3 0202 Miiistone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION REJECTED Potential Operetditty lesue Discipline: Pipin0 Design Ow Discrepancy Type: CorrectNo Action

@ No systemIProcese: N/A NRC signiftcance level: 4 Date faxed to NU:

Date Published: 9/2997 Discrepancy: Insufficient Justification Provided in NonconfonTiance Report Package Dacription: NCR # 3-92-0269 dealt with some cracked lines in the Radioactive Waste Boron Recovery System. The NCR states that metallurgical examination revealed that the cause was stress corrosion cracking. The disposition was to replace the cracked piping with piping f abicated from the same material and to make no design changes. No justification is provided for this disposition.

Review valid invand Needed Date initiator: shepperd, R. P.

G 0

0

$/15S7 VT Lead: Ryan, Thomas J Q

O O

8/1" 7 A

VT Mgr: schopfer, Don K G

O O

s/22ro7 1RC Chmn: singh, Anand K O

O O

S/2sio7 Date:

INVALID:

Date: 2/10/96 RESOLUTION: Disposition:

NU has concluaed that Discrepancy Report, DR MP3-0202, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B 16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97-3698 has been written to develop and track resolution of this item per RP-4.

==

Conclusion:==

NU has concluded that Discrepancy regrt, DR-MP3-0202, has identified a condition not previously discovered by NU which

}

requires correction. This discrepancy meets the criteria specified in NRC letter B 16901 and 17010. It has been screened per U3 PI-20 criteria and found to have Po operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97 3698 has been written to develop and track resolution of this item per RP-4.

Prev 6cualy identined by NU? O Yes (9) No Non Discrepent Cuwittion?U Yes

(#_) No Resolution Pending?O vos @ No Renoiotionunresoived70 ves @ No Review Acceptable Not Acceptable Needed Date Niet s

. R. P.

O G

O 2r m un w.

o_ w_= =,

Page 1 of 2 Printed 2/13/961216:47 PM~

Northeast Utilities ICAVP DR No. DR-MP3-0202 Millstone Unit 3 Discrepancy Report

. n r.... - '

I O

O

=

VT Mgra schopfw, Don K O

O Sm RC Chmn: thy,,Ac.ardK O

O Date:

2/10/98 sL comments: The DR disposition states that the DR identified a a condition which requires coraction. Condition Report (CR) M3-97 3698 has been written to develop and track resolution. The CR states that no adverse condition exists because a technicaljustification is not required for rework dispositions.

3

• Rework" does not resolve the condition (i.e., stress corrosion

. b cracking) that led to the nonconforming cracked piping.

Therefore, a technical basis is needed to resolve the nonconformance.

Printed 2/13S812:16:54 PM Page 2 of 2

e Northeast Utilities ICAVP DR N3. DR-MP3 0444 a

Millstone Unit 3 Discrepancy Report Review Group: Programmet6c DR RESOLUTION REJECTED Review Element: Correcove Action Process g

Diecipline: Operations Ow Diecrepency Type: Correcuve Action implementation

@ No SystemProcese: SWP NRC Signinconce level: 4 Date faxed to NU:

Date Published: 1/1096 Discrepancy: Incomplete Closure of Unresolved item Report (UIR 1414)

Ducription: In conjunClion with UIR 1414, the Discrepancy item Closure Package (DICP) has been reviewed.

Only the first two Recommended Dispositions are addressed in the DICP, The recommendation for Design Engineering to Generate MMOD to correct Ops Form / Procedure designations, as applicable has not been addressed.

Note: It is recognized that changes to OPS Form / Procedure designations may not be needed to rddress the specific issue documented on this UIR, however,if no changes are needed, this should be documented with justification in the DICP since it is clearly indicated as a recommended disposition on the UIR which has been reviewed / approved by the EP/PVRT al.* UPM.

As an example, another recommended disposition was for Design Engineering to generate a DCN to correct P&lD, as applicable. The DICP documentation clearly indicates that the P&lD was reviewed and determined to be correct, so the issue is properly closed with regard to potential impact to P&lDs (eg. no impr ct) and the recommended disposition shown on the UlR was property addressed.

Reflew Valid invalid Needed Dets initletor: Neverro, Mark O

O O

12/23ro7 VT Leed: Ryan, Thomes J O

O O

12/23/07 VT Mgr: schopfer, Don K G

O O

12/23/97 1RC Chmn: sin 0h, Anand K G

O O

12/siiv7 Date:

eNVALlo:

Date: 2/11/98 RESOLUTION: Disposition Project instruction Pl 1 A section 1.3 Preparation and Processing of Unresolved item Reports (UlR) describes the preparation of an UIR. The guidelines to compirM< IJIR block #3 (Recommended Disposition Details) includes: " provide the proposed dispositk.1 and references or basis required to support the disposition.' A template for block #3 was developed by the group doing the P&lD walkdown to provide consistent recommendations. This template included the following items:

Des. Eng. PERFORM MEPL review and IDENTIFY correct safety des!gnation for affected equipment. System Eng.

GENERATE label request to correct field condl*lon, as applicable. Design Eng. GENERATE DCN to correct P&lD, as Printed 2/1s98 2-2e:13 PM Page 1 of 2

j0 Northeast Utilities ICAVP DR No. DR MP3 0484 Millstone Unit 3 Discrepancy Report applicable. Design Eng. GENERATE MMOD to correct Ops Form / Procedure designations, as applicable.This template was used on 58 UIRs to provide guidance if an issue was identified, it was never intended to require all items to be completed. PI 20 provdes guidelines for completing non-ACR assignment forms, that is the Discrepancy item Closure Package (DICP). This guideline only requires identified actions to be listed. If an action such as ' GENERATE MMOD to correct Ops Form / Procedure designations, as applicat>!o* is not identified it does not have to be listed. The Expert Panel has reviewed the UlR througt, the PI 14/20 process and concurred with the disposition or required actions. Therefore, UIR 1414 DICP is complete. Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion Pl 20 guideline only requires identified actions to be listed.

Therefore, UIR 1414 DICP is complete. Significance Level l

criteria do not apply here as this is not a discrepant condition.

Previously identined by NU? O vos @ No NonD6screpentCondluon?U vos @ No Resolution Pending?O ves @ No ResolutionUnresolved?O vos @ No

- Review A ept ble Not Acceptable Neded Date Inniator: Nam, M VT Leed:' Ryan, Thornes J l

VT Mor: Schopfer, Don K IRC Chmn: Sin 0h, Anand K l

Dese:

2/11/98 sL comments: The response provided is not acceptable. The response indicates that documentation is not required in the Closure Request Report for generic actions listed in the final disposition of the UIR if there was no action required since "P120 only requires identified actions to be listed

• and that the " Expert Panel has review the UIR through the Pl 14/20 process and concurred with the disposition or required actions". Contrary to the above,

1. Attachment 6 of M 20 states that "the disposition listed on the closure request shall contain a discussion on the related findings and stated solutions". This should include at least a stument that an MMOD to correct OPS Form / Procedure designations", as l_

Indicated in the UIR final disposition, was not required in l

addition, i

2. PI-20 Note states that "the DICP should be viewed as a stand alone document. An outside reviewer should have enough i-information within the DICP to fully answer all potential questions regarding issue background and resolution.

As pointed out in the DR, there was no required action to mrrect P&lDs and this was properly documented in the Closure F<equest Disposition. A similar statement in the Disposition should have been documented for the Licensee's conclusion that "MMOD to correct OPS Form / Procedure designations was also not required."

Printed 2/13/96 2'28:20 PM Page 2 or 2 l