ML20203F442
| ML20203F442 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/26/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9802270311 | |
| Download: ML20203F442 (46) | |
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Don K. Schopfer Senior Vice President 312 269 4078 February 26,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk
- Washington, D.C. 20555 Enclosed are discrepancy reports (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 enclosed the. following nine (9) DRs for which the NU resolutions have been reviewed and accepted by S&L.
DR No. DR-MP3-0067 DR No. DR-MP3-0230 DR No. DR-MP3-0469 DR No. DR-MP3-0574 DR No. DR-MP3-0770 DR No. DR-MP3-0771 DR No. DR-MP3-0779 DR No. DR-MP3-0788 DR No. DR-MP3-1020 I have also enclosed the eight (8) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.
tkj DR No. DR-MP3-0349 DR No. DR-MP3-0370
[v DR No. DR-MP3-0563 DR No. DR-MP3-0658
, u, j 3
.(,ll[ll lll llll[ g DR No. DR-MP3-0659 DR No. DR-MP3-0679
- 6 c'
DR No. DR-MP3-0783 DR No. DR-MP3-0808 9802270311 980226
~
PDR ADOCK 05000423 hicago, IL 60603-5780 USA + 312-269-2000 P
4
- United States Nuclear Regulatory Commission February 26,1998 Document Control Desk Project No. 9583-100 Page 2 Please direct any questions to me at (312) 269-6078.
Yours very truly, A
f.
D. K.
er Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/l) Deputy Director, ICAVP Oversight T, Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/l) NU m:\\icaspWwe98WO2264&x i
Northeast Utilities ICAVP DR N3. DR-MP3 0067 Millstone unit 3 Discrepancy Report Reviow Group: Configuration DR RESOLUTION ACCEPTED Discipline: Electrical Design Potential Operability issue Om Discrepency Type: Installation implementation gg SystemProcese: sWP NRC SignlAconce level: 4 Date faxed to NU:
Date Published: 8/31/97 Diecrepency: Conduit Attachment not Shown on Tray Supports
==
Description:==
1, Conduits 3CX970PB ano 3CK970PB are supported on tray supports G4000-33, G400-31, G400-29, G400B-26, and G400D-22 (3CX970PB only). The support detail drawin0, EE 34JK Rev, 3, (J-5) does not show the connection of these conduits nor provide any reference to the fact that conduits are supported from these supports.
- 2. Condults 3CX767PE3,3CK970PB, and 3CC752PB are connected to tray supports G326A-44 and -45. There is no indication on the tray support detail or location drawing (EE-34JH Rev. 3,34EP Rev. 6) that there are any conduits attached to the supports.
- 3. Conduit 3CC752PB is attached to tray support G327-49.
These is no indication on the tray support detail or location drawing (EE 34JH Rev. 3,34EP Rev. 6) that there are any conduits attached to the supports.
- 4. An 1%" lighting conduit is attached to tray supports G305-38 and G306-39. These is no indicatior. 7n the tray support detall or location drawing (EE-34JH Rev. 3,34EP Rev 6) that there are any conduits attached to the supports. The Electrical Installation Specification E350 (Section 3.5.12) indicates that lighting conduits shall comply with applicable requirements of the specification. The Specification (Section 3.1.3.11, item 5) sequires that all non-seismic condult, which should include non-essential lighting such as this, shall not be attached to tray hangers without engineering approval. Since the conduit is not shown on the support drawings, there is no evidence of this approval and it is, therefore, unclear if all support loads are correctly calculated. Further, a 4-foot fluorescent light fixture is supported from the horizontal member connecting the two supports G305-38 and G306-39.
Review Valid invalid Needed Date initletor: server, T. L G
O O
e/27/97 VT Lead: Neri, Anthony A G
O O
e/2897 VT Mgr: Schopfer. Don K G
O O
e/28/97 1RC Chmn: Singh, Anand K Q
Q Q
8/28/97 Date:
INVALID:
Date: 10/7/97 RESOLUTION: Disposition:
Prtnted 2/26/981:34 06 PM Page 1 of 3
Northeast Utilities ICAVP DR N;. DR MP3-0067 Minstone Unit 3 Discrepancy Report
- 1. NU has concluded that the issue reported in item 1 of Discrepanvy Report, DR-MP3-0067, does not represent a discrepant condition. There are two errors in the information provided in the DR description. The DR list conduits 3CX970PB and 3CK970PB as being attached to the cable tray supports.
These conduit numbers are actually 3CX970PE and 3CK970PB.
In addition, conduit 3CX970PB is indicated as attached to support G400D 22. This should be conduit 3CK970PB. Given the above clarification, the documentation for the attachment of the subject conduits to the cable tray supports is provided in E&DCR FE-41790 issued on July 17,1985.
OSignificance Level criteria do not apply here as this is not a discrepant condition.
2.ONU has concluded that the issue reported in item 2 of Discrepancy Report, DR MP3-0067, does not represent a discrepant condition. There is one error in the information provided in the DR description which indicates that the 3 conduits are attached to cable tray supports G326A-44 and -45.
Conduit 3CC752PB is not attached to cable tasy support G326A-44 but is attached to support 45 Given this clarification, the documentation for attachment of the subject condults to the cable tray supports are addressed in E&DCR FE-41790, issued July 17,1985 and DCN DM3-XX 1227-96 issued April 23,1997.
OSignificance Level criteria do not apply here as this is not a discrepant condition.
3.ONU has concluded that the issue reported in item 3 of Discrepancy Report, DR-MP3-0067, does not represent a discrepant condition. Documentation for the attachment of the subject conduit to the cable tray support is evntained in DCN DM3-03-1227 96 issued April 23,1997.
4.ONU has concluded that the issue reported in Item 4 of Discrepancy Report, DR-MP3-0067, has identified a condition not previously discovered by NU which requires correction. The lighting fixture described is installed in accordance with drawing EE-67G which addresses the attachment to the cable tray support. The lighting conduit powering the light fixture does not have any specific documentation which could be located showing the attachment to the cable tray support. This is a documentation change only. Condition Report (CR) M3-97-3197 has been written to provide the necesscry corrective actions to resolve this issue.
==
Conclusion:==
NU has concluded that the issues reported in items 1,2, and 3 of Discrepancy Report, DR-MP3-0067, does not represent a discrepant condition. Documentation for attachment of the conduits to the cable tray supports are addressed in E&DCR FE-41790, issued July 17,1985 and/or DCN DM3-03-1227 96 issued April 23,1997. NU has concluded that the issue reported in item 4 of Discrepancy Report, DR-MP3-0067, identified a condition not previousiv discovered by NU which requires correction The Printed 2/26S81:34:10 PM Page 2 or 3
l 4
Northeast Utilities ICAVP DR N9. DR-MP3-0067 Mil; stone Unit 3 Discrepancy Report lighting conduit powering the light fixture does not have any specific documentation which could be located showing the attachment to the cable tray support. This is a documentation change only. Condition Report (CR) M3-97 3197 has been written to provide the necessary corrective actions to resolve this issue.
Previously identmed by Nu? O Yes @ No Non D.screpent fiondNion?O Yes @ No Resoiutbn Pending?O vee @) No R.
iuii ount. ev.de O vos @) No Review Acceptable Not Acceptable Needed Date inNWor: W T. L.
O O
O mm VT Lead: Nerl Anthony A O
O
=
VT Mgt: Schopfer, Cm K O
m IRC Chmn: Singh. Anand K De'e:
SL Comments:
Printed 2r26961:3411 PM Page 3 of 3
Northeast Utilities ICAVP Dit N:. DR-MP3 0230 Millstone Unit 3 l iscrepancy Report Review Group: Configurshon DR RESOLUTION ACCEPTED A'V E
8 Potential Operability issue Dieciplint.: I & C Design O Ya Discrepency Type: Instellebon Implementation
@ No SystemProcess: Rss NRC SWe level:4 Date faxed to NU:
Date Published. 9/29/97 D6*croPent.7: Missing Equipment Tags
==
Description:==
The following installed instruments were found not to have identification tags: 3RSS-PS41 A and B.
Review veind inveild Needed Date initiator: servw, r. L 0
0 O
o<12/97 VT Lead: Nort, An:hony A O
O O
S'15'S7 VT Mgt: schopfw, Don K O
O O
e/22/97 1RC Chmn: s6ngh, Anandit O
O O
st2ss7 Date:
INVALID:
L'ete:
1/6/98 RESOLUTION, Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0230, has identified a condition previously discovered by NU which is being corrected. A management initiative to label all components began in 1996. This was a site-wide process to improve the overall configuration management e* fort. As a result of this effort, a new label for 3RSS-PS41 A has already been hung. The new label for 3RSS PS41B is currently in progress per the requirements of OA9, System and Component Labeling.
==
Conclusion:==
NU has concluded that Discrepancy Risport, DR-MP3-0230, has identifiea a condition previously discovered by NU which requires correction. A new label for 3RSS PS41 A has already been hung. A request for an equipment label for 3RSS PS418 is currently in progress per the requirements of OA9, System and Component Labeling.
Previously identified by NU? (9) Yes Q No Non Descrepent Condition?O Yes t#> No Resolution Pending?O vos t No ResolutionUnroscived?O Yes @ No Review initiator: server, T. L VT Lsed: Neri, Anthony A VT Mgr: schopfer, Don K B
O mm IRC Chmn: singh, Anand K O
O O
Date:
sL Comments:
Prtnted 2/26981:34.56 PM Page 1 of 1
Northe:st Utilities ICAVP DR No. DR-MP3-0469 Miiistone Unit 3 Discrepancy Report Review Group: Configurobon DR RESOLUTION ACCEPTED Disciphne: Piping Design PotentialOperalditty issue O Yes Discrepancy Type: Installation implementation
@ No System / Process: OsS NRC Significance level: 4 Date faxed to NU:
Date Published: 10/23/97 Discrepency: Modification DCR M3-96056 Modification to QSS pipe support Descrl tion: Pipe support 3-OSS-4-PSST 060 shown on drawing 12729-BZ-P 798-30 Rev 4 contains a rigid strut with the pin to pin dimension shown on the drawing to be 2ft-21/8 in. This dimension was verified to be 2 ft-9 in, during the walkdown which is a difference of 6 7/8 in. Spec SP-ME 570 Appendix "N"(Pipe Support Field Fabrication and Erection Tolerances) Section 1.6 for Swing Strut Assembly allows a tolerance for the pin to pin dimension of + or-31/2 in. unless the tolerance is wavled and explicitly documented which it was not on the drawing.
Review Valid invalid Needed Date initiator: Reed, J. W.
O O
O 10/11/S7 VT Lead: Neri, Anthony A
]
]
10/11/97 VT Mgr: schopfer, ton K O
O O
1o/15/S7 IRC Chmn: s6ngh, Anars x 0
0 0
to/18'S7 Date:
INVALID:
Date: 2/20/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0469, 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 Pl-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97-418L has been written to develop and track resolution of this item pu RP-4.
==
Conclusion:==
NU has concluded that Discrept ncy Report, DR-MP3-0469, 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 M3-97 4180 has been written to develop and track resolution of this item per RP-4.
Previously identified by NU? () Yes (9) No Non Discrepent Condit6on?() Yes @ No ResolutionPending?O ves @ No ResolutionUnresolved?O Yes @ No Review inittator: Reed, J. W.
VT Lead: Neri, Anthony A VT Mgt: schopfer, Don K Printed 2/26/De 1:35:43 PM Page 1 of 2
Northe st Utilities ICAVP DR N). DR MP3 0469 Millstone Unn s Discrepancy Report g
g ma ace w:om,An.nox Date:
SL Comments Prirded 2/26W 1:35 46 Ph Pg 2 of 2
Northeast Utilities ICAVP DR N3, DR-MP3 0674 Millstone Unit 3 Discrepancy Report
- e. _.,
Rev6ew Group: Configurobon DR REs0LtriloN AccEP RED Potentialfeperability *ue Deecipline: Piping Deed 9' Om D6ecropency Type: DreMng 4g systen#rocese: $WP
~
NRC s6pniacance level: 4 Date faxed to NU:
De's Publ6shed: 11/1597 D6 cropency: PDCR MP3-93-009 Modifications to Service Water piping on inlot and outlet of pumps 33WP*P2A/B Descric%: DCN DM3 S 0475-93 of PDCR MP3-93-009 adds a standard support (Dwg BZ 300A 26) for pipe support CP 319012 H003 and attaches it to pipe support CP 319012 H005. However, in drawing BZ 19R 10 Rev 2 ( revised to incorporate DCN DM3-S-0475-93) the identificatien of support CP 319012 H005 had been deleted.This is not consistent with the DCN. Both supports.
H003 and H005 should be called out on drawing BZ 19R 10.
Review Valid invalid Needed Date inet6etor: Reed, J. W.
D O
O 5 5$7 VT Leed: Neri, Anthony A D
D D
it/5S7 VT Mgr: Schopfer, Don K Q
Q Q
11/1097 1RC Chmn: Singh, Anand K O
O O
11/11/S7 Date:
INVAUD:
DMe: 2/17/98 REs0LUTION: Disposition:
NU has concluded that Discrepancy Report, DR MP3-0574, has identified a condition not previously disc' vered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3 97 4064 has been written to develop and track resolution of this item per RP-4,
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3-0574, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criterth and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97 4064 has been written to develop and track resolution of this item per RP 4.
Previously identifled by NU7 O Yee tel No Non Discrepent Condition?O Yes (e) No Resolution Pending?O ve. (i) No Resolution Unresolved?O ve. (i) No Review
^*
inillator: Reed, J. W.
VT Leed: Nort, Anthony A V's Mgr: Schopter, Don K 1RC Chmn: Singh, Anar d K Printed 2f26961:37.09 PM Page 1 of 2
Northeast UtilNies ICAVP DR N3. DR MP34674 l
Millstone Unit 3 Discrepancy Report O
O O
o.:
SL Commente:
PrWed 2/26981:37.13 PM Pm2d2
Northeast Utilities ICAVP DR No. DR MP3 0770 Milletone unit 3 Discrepancy Report Roylew Group: system DR REsct'JTioN ACCEPTED R
EM W W Potentiel operebHNy leaue D6ecipline: Mechanical Doeg" O va Diecropency Type: Component Date (98 No systernerocese: R$s NRC sterncence level: 4 Dele > Axed to NU:
Date Published: 12/21/97 Di*crepeacy: Discrpancy between PDDS and PMMS relative to valve 3RSSI V918 Dacriphon: Plant computer data base. PDDS, shows valve 3RSS-V918 to be a Date valve. This is consistent with P&lD EM 112C Revision
- 16. However, the plant computer data base, PMMS, shows this Valve to be a globe valve.
Review Vand invaad Needed Dele Inilleton Fein0old, D. J.
O O
O 12/1o57 VT 1.oed: Nori, Anthony A y
Q Q
12/11/97 VT Mer: Schopfer, Don K O
O O
12/11/87 IRc Chmn: Singh, Anand K O
O O
12/11'S7 Date:
IN N ID:
Date: 2/23/96 RESOLUTION: Disposillon:
NU has concluded that Discrepancy Report, DR MP3 0770, 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 por U3 PI 20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3 98-0217 has been written to develop and track resolution of this item per RP 4.
==
Conclusion:==
NU has concluded that Discrepancy Report. DR MP3-0770, has identified a condition not previously discovered by NU which requires correction. This discrrpancy 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 98 0217 has been writtesn to develop and track resolution of this item per RP 4.
Previously identitled by NU? O vos @) No Non Discrepent Condition?O ves (9) No ~
Resolut60n Pending?O vee
- No RenoiuikmunresoivedtO vee + No Review Acesptable Not Acceptable Nooded Date Wm FM DJ O
O O
m VT 1.eed: Nort, Anthony A VT "'" **h P' "f b
25 PN M96 2M27 M *." ~ v - ~ "
Page 1 of 2
Northeast Utilities ICAVP DR No. DR MP34770 Millstone unit 3 Discrepancy Report O
3 O
. - ~'
Date:
2/23/98 sL connente: The intended corrective action is not apparent from the Northeast Utilities disposition or from condition report CR M3 98 0217.
However it is apparent that the corrective action is either to change the PalD or PDDS to match each other based on the design requirements of the system, but limited by the Installed plant configuration.
=
Pdhted 2f26,98 2.34 32 PM Page 2 of 2
Northeast Utilities ICAVP DR No. DR-MP34771 Millstone Unit 3 Discrepancy Report Revtow Group: systern DR RESOLUTION ACCEPTED I
I Potent 6el Operstditty leeue i
l D6ecipiene: Mechenical Dwign O vos l
D6ecrepency Type: DrW (9) No I
system 9tocese: Ras NRC s'f me level: 4 Date Faxed to NU:
Date Putelshed: 12/2097 D6ecropency: Inconsistency behween FSAR and structural drawings with respect to sun 04 Miection grating,
==
Description:==
FSAR Sectioni.e 9 );d FSAR Table 6.2-61 state that the containment sta,a 44 m,p is protected by 1 1/2 inch vertical trash rejection gratloc. Drawing 12179 ES 53J Revision 1 concurs with the FSAR. However, drawing 12179-ES 53G Revision 3, Section C4, shows the vertical trash rejection grating to be 1 inch by 3/16 inch.
Review Valid invalid Needed Date initiator: Feingold, D. J.
O O
O 12/1097 VT Leed: Nort, Anthony A O
O O
12/1157 VT Mert schopfer, Don K Q
Q Q
12/11/97 1RC C5mn: Singh, Anand K O
O O
12/15S7 Dnie:
INVAUD:
Date: 2/23/98 RESOLUTION: Disposltion:
NU has concluded that Discrepancy Report, DR MP3 0771, 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 operebility or reportability concems and meets the Unit 3 deferral criteria. CR M3 96 0512 has been written to develop and track resolution of this item per RP-4,
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3-0771, 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 operaWity or reportability concems and meets the Unit 3 deferral ci..erta, CR M3-98-0512 4
has been written to develop and track resolution of this item per RP-4.
Previounty ident6 fled by NU7 O vos @ No No..D6ecrepard Condition?Q Yes it' No Resolut6onPonding?O vos 4) No Resolutionunresolved70 va @) No 7
Review initletor: Feingold, D. J.
O O
O Printed 2/2696 2.34 57 PM' Pege 1 of 2
Northeast Utilities ICAVP DR No. DM MP3 0771 Millstone unN 3 Discrepancy Report O
Q 2'2m l
VT Mer: SchopW, Don K l
NtC Chmn: Singh, Anand K O
O O
Das:
2/23/98 st. comments: The intended corrective action is not apparent from the Northeast Utilities disposition or from condition report CR M3 96-0512.
However, it is apparent that the corrective action must be to correct the drawing and, if necessary, the installed trash rejection grating to match the FSAR.
I
(
Printed 2/2696 22 03 PM Page 2 of 2
Northeast Utilities ICAVP DR No. DR MP3-0779 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTK)N ACCEPTED Roh EW: s#em %
Potential Operately leeue Diecipline: Erwironmnental Queltreetwi 4 y, D6ecrepancy Type: Calculat6on No SysterWProcese: N/A NRC 64greconce level: NA Dele faxed to NU:
Date Published: 1/1096 D6*ctopency: Class 1E Cabla Qualified to DOR Guidelines
==
Description:==
The review of Electrical Equipment Qualification (EEO) Test Repc,t Assessment rJo. EEQ TRA 107.1 shows that Kerite Company's TPNS Jacketed Power Cables Model J/C 750 MCM, SKV Plant I.D. 3VARIOUS-10 (1), is qualified to the Division of Reactors (DOR) Guidellr.es.
However, Millstone FSAR Section 3.11B.2.2 states that the Environmental Qualification of all safety related equipment shall meet the requirements of IEEE 3231974, the intent of NUREG-0588, and NRC 10CFR 50.49.
Also, Wyle qualification fest report No. 471761, Rev,0, dated March 23,1984 did not address the synergistic effects as required in FSAR Section 3.11B.2.2, NRC 10CFR 50.49(e)(7),
and R.G.189, Rev.1. Section C.S.a.
The synergistic effects that should be addressed dunng the equipment quellfication are the dose rate effects and the effects resulting from the different sequence of applying radiation and (elevated) temperature on the equipment qualified life.
Review Vaind invalid Needed Date initiator: Yosem.S.
O O
O 12/ir/97 VT l.oed: Nort, Anthony A Q
Q Q
12/17/97 I
VT Mgr: Schopfer, Don K Q
Q Q
12/2197 IRC Chmn: $1ngh. Anand K Q
Q Q
12/31/97 Date:
wvAuo:
Date: 2/21/98 RESOLUTION: Dispositiord NU has concluded that Discrepancy Report, DR MP3-0779, does not represent a discrepant condition. Test Report Assessments (TRA's) evaluates and summarizes the environmental qualification test reports and analyses used to qualify a component. These assessments are developed for use by all four units (CY MP1, MP2, and MP3) as potential design inputs into the Equipment Qualification Records (EQR) revision process. Assessments are not automatically applicable to MP3 unt:1 they are specifically referenced within an Equipment Qustification Record.
The Kerite cable in EEQ-TRA 107.1 is qualified to the Division of Reactors (DOR) Guidelines. It is however, not applicable to MP3 since Kerite Company's TPNS Jacketed Cables Model J/C 750 MCM, SKV, is not used or installed at MP3. Additionally, EEQ-TRA 107.1 is not referenced within EOR 107 file and therefore, not applicable to MP3.
Printed 2/269e 2 35 2e PM Page 1 of 2
Northeast Utilities ICAVP DR No, DR MP3-0779 Millstone Unit 3 Discrepancy Report To determine which TRAs are applicable from the electrical Equipment Qualification Master List (EEQML) Index, the vendor EQR file needs to be reviewed since, the index only provided the vendor EQR number, Realizing that this can be confusing the EQML was enhanced to include the specific EQR and TRA numbers in the Index. This was accomplished by incorporation oi DCN DM3-00196197 Into Specification SP M3-E0353.
NU has concluded based on the above that Discrepancy Report, DR MP3-0779, does not represent a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3-0779, does not represent a discrepant condition. Since, Test Report Assessment No. EEQ TRA.107.1 is not applicable to MP3.
Significant level criteria does not apply as this is not a discrepant condition.
Prev 6ously identined by NU? U Yee it) No Non D6screpent Condition?(#) Yee O No Resolut6on Pend 6ng?O vee 4) No ResolutionUnresolved?O vee (si No Review Accepteble Not Acceptable Needed Date m,,; yg g, VT Leed: Nort, Anthony A V1 Mgt: Scigfor, Don K IRC Chmn: Singh, Anend K sL Comments:
Printed 2/2696 235 30 PM Pege 2 of 2
Northeast Utlinies ICAVP DR No. DR MP3 0784 Millstone Unit 3 Discrepancy Report Rev6ew Group: system DR RESOLUTION ACCEPTED A'
ON 06ecipilne: Electrical Design PotentielOperoidetty leeue O v.
D6ecrepancy Type: Calculeton (4) No SystemProcess: N/A NRC Significence level: NA Date faxed to NU:
Date Putdished: 1/ioS6 D6ecrepency: Value used for motor Contribution to fault is not referenced.
(Calculation 123E).
Ducription: This calculation determines the minimum 1000 V power cable size under fault conditions. The calculation assumes a motor conti,bution to the fault of 2500 kVA but does not provide the basis for this assumption.
In determining motor contribution for a fault, industry standards su90est 3.6 times fullload current for induction motors and 4.8 times full load current for synchronous motors. The basis for the 2500 kVA short circuit motor contribution should be provided.
Review Valid invol6d Needed Date initletor: Crockett, Ed.
O O
O 12/i2S7 VT Leed: Nerl, Anthony A O
O O
12/16S7 VT Mgr: schopfer, Don K O
O O
12'22S7 IRC Chmn: singh, Anand K O
O O
12/31/97 Dei.:
INVALlO:
Date: 2/23/98 REs0LUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report DR MP 3-0788 does not represent a discrepant condition.Instead of using the industry assumption of 3.6 induction /4.6 synchronous times full load motor current, NU has ut.ed a more conservative standard of 2500 KVA for their 480 VAC load system.
Assuming, HPzKVA, and the industry assumption of 3.6 times full load amperes for induction motors, the 2500 KVA figure would equate to approximately 700 HP, MP3's load center transformers are rated for 1000 KVA. From calculation NL-038, the worst case loading on a 1000 KVA transformer is less than 700 KVA, Motors comprise approximately 2/3's (approx. 470 HP) of the 480 VAC loading.
Therefore the 2500 KVA is a more conservative assumption than using 3.6 or 4.6 times full load amperes.
Significance level criteria does not apply as this is not a discrepant condition,
==
Conclusion:==
Pnnled 2/2696 2:35 57 PM Page 1 of 2 l
O Northeast Utilities ICAVP DR No. DR MP3 0788 l
Millstone Unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report DR MP3-0788 does not represent a discrepant condition. Instead of using the industry assumption of 3.6 Induction /4,6 synchronous times fullload motor current, NU has used a more conservative standard of 2500 KVA for their 480 VAC load system.
Significance level criteria does not apply as this is not a discrepant condition, Previously identified by NUF Q Yes M No Non Discrepent Condelion?% Yes O No Resolution PenengtO Yes v No ResoMion Unres**d?O Yes @ No Rev6vw Acceptable Not Accogdebio Needed Date Nietw: Wwnw,1.
O O
O ma VT Leed: Neri, Anthony A O
O O
N VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anend K Dele:
sL Commente:
h Printed 2/2698 2:36 01 PM Page 2 of 2
l Northeast Utilities ICAVP DR No. DR-MP31020 Millstone unN 3 Discrepancy Report Rev6ew Groep: System tKt RESOLUTION ACCEPTED A'* I
- D'*
Potential Operabiloty lesue D6ecipl6ne: PW Dugn O vee 06ece Wy Type: Calcu6stkm (e) No System'Procese: NEW NRC 56gnmcence level: NA Date faxed to NU:
Dele Published: 2/9/9e D6.crepency: Effect of Fluid Transient induced header movements on 4" branch line not considered Ducription: In the process of reviewing the following documents, (1) 12179 NP(F) X7923 Rev 2, CCN # 01,117 97 (2) 12179 NP(F) X7925 Rev 2, CCN # 1 through CCN # 7 ( part
'C' and part "D"),9 23-97 we noted the followin9 discrepancy:
Hender movements for the 12"line resulting from fluid transient loads, as analyzed in (2), have not been considered in the stress analysis of the decoupled 4' branch pipirg analyzed in (1),
Note:
Calculation (1) has been revised per modification DCR MS-97045, Rev 0 Revlow Valid invalid Needed Date inPlator: Patel, Ramesh D 0
0 0
2/2/9e VT Lead: Neri, Anthony A O
Q Q
2/2/9e VT Mgri Schopfer, Don K O
O O
2/4Se RC Chmn: Singh, Anand K Q
Q Q
2/4/9e Dei.:
INVALID:
Date: 2/23/98 RESOLUTION: Response ID: M3 lRF 01779 Disposition:
NU has concluded that Discrepancy Report DR MP* 1020 does not represent a discrepant condition, Calculation 1JP(F)-X7925 addresses the piping between the containment encapsulation and RSS pump suction. Calculation NP(F) X7923 addresses the piping between the RSS pump discharge and the RSS Heat Exchangers.
New mini-flow lines were added to the 'C" and "D" RSS trains and modeled in stress calculation NP(F) X7923. These lines tie back into stress problem NP(F) X7925 as de coupled branch lines, and are therefore not included with this stress model.
Stress calculation NP(F) X/925 does not have n,'luid transient case due to the low magnitude of the predicted loads (refer to fluid transient calculation NP(B) 163FA, rev. 3. Waterhammer Printed 2/269e 2.3e 42 PM Page 1 of 2
~.
Northeast Utilities ICAVP DR No. DR-MP301020 Millstone Unit 3 Discrepancy Report Analysis of Recirculation Spray System, sent in response to RFl.
1008 on 1/9/98); therefore there are no header movements to consider at the connection of the 4" mini flow lines to the 12' main header.
Significance level criteria do not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report DR MP31020 does not represent a discrepant condition. Stress calculation NP(F).
X7925 does not have a fluid transient case due to the low maOnitude of the predicted loads, as supported by calculation NP(B) 163FA, rev. 2. Therefore there are no header movements to consider at the connection of the 4" mini flow lines to ths 12" main header, Significance level criteria do not apply as this is not a discrepant condition.
Previously identieod by NUF V Yes ~78) No Non Dieciapent condetton?@ Yes O No
~
RoooMionPonengtO ves 4) No Ree suisonunresoevedtO ves 4) No Review initiator: Petel, Ramesh D O
O O
=
VT Lead: Nort, Arnhany A O
O MS VT Mgr: schopfer. Don K IRC Chr,m: Sin 0h, Anand K SL Conenente:
Med 2/26/96 2.36 46 PM Page 2 of 2
Northeast Utilities ICAVP DR No. DR MP3 0349 Millstone Unit 3 Discrepancy Report Review Group: System DR REs0LUTION REJECTED Review Element: Byetem Design g
g Diecipline: Mechanical Dool'"
O vee 06ecropency Type: Component Date
- No systemProcote: Rss NRC sienteconce level: 3 Date faxed to NU:
Date Putd6ehed: il1096 06ecrepancy: Specs SP ME.784 is inconsistent wi'h PCDR 3-93-015 D** Crept 6on: Specification SP ME.784 through Revision 2 only applies to valves 3RSS*MOV23A,B,C,D, as they were replaced via PDCR
~
3 93 015. However, the specification ls misleading because it contains valve data sheets for valves 3RSS*MOV20A,0,C,D, 3RSS*MOV23A,B,C.D, and 3QSS*MOV34/.,B, but PDCR 3 03-015 addresses only the replacement of valves 3RSS*MOV23A,B,C,0. No design change packages are identified to implement tne replacement of valves 3RSS*MOV20A,B,C,0 and 30SS*MOV34A,8 as defined in specification SP ME 784, The design specifications SP ME 784 through Revision 2 and 2362.200164 through Addendum 1 for valves 3RSS*MOV23A,B,C,D overiep each other but contein conflicting data.
Specifications SP ME 784, the more recent of the two specifications, is for this replacement of Pratt Butterfly Valves only, and not the associated motor operators.
Specification 2362.200164, the earlier specification, identifies the design requirements for both the butterfly valves and their associated motor operators. As such, this specification provides synergistic requirements such as valve stroke time, motor-operator hammer blow feature, and equipment qualific'".on with respect to electrical components, and other motor r,,erator features. The seismicloading of the motor operatoris addressed in PDCR 3 93-015.
Specification SP ME 784 does not cross reference specification 2362.200164 or any other motor operator specification.
Therefore, specifications SP ME 784 and 2362.200-164 cannot be reconciled to fully define the design and performance requirements for valves 3RSS*MOV23A,B,C D, relative to stroke time, equipment qualification, and operator hammer blow feature.
Review Valid invalid Needed Date initletor: Feingold, D. J.
O O
O i:'1SS7 VT Lead: Nort, Anttwny A O
O O
12/iaS7 VT Mgr: schopter, Don K O
O C1 5272297 IRC Chmn: singh, Anand K O
O O
12r31/97
- Date:
WVAllo:
Date:
2/2/ge Printed 2/2696 2.s4 53 PM Page i of 3 l
l
Northeast Utilities ICAVP DR No. DR-MP3-0349 i
Millstone Unit 3 Discrepancy Report RESOLUTION: Olsposition:
NU has concluded that Discrepancy Report, DR MP3 0349, does not represent a discrepant condition for the following reasons:
- 1. Srecification SP ME 0349 through revision 2 provides purchase and det.lgn requirements for replacement Henry Pratt valves. PDCR 3 93-015 provides the design change package for the actual replacement of valves 3RSS*MOV23 A,B,C D only and references the specification as the source and design requirements of the new valves. There are no plans to install valves 3RSS*MOV20A,B,C,D and 30SS*MOV34A,B.
When valves 3RSS*MOV20A,B,C,0 and 30SS*MOV34A,B are replaced, new design change packages must be issued.
- 2. Specification SP ME 0349 purchased new style valves with field replaceable seats in lieu of seats bonded to the valve bodies, provided more restrictive service conditions, and expanded seismic requirements. Afterinstallation DCN DM3-S-00139 93 required S&W Specification 23C2.200164 be revised to remove valves applicable to 3RSS*MOV23A,B,C,D.
Specification SP ME 0349 will replace S&W Specification 2362.200164 as the replacement valves are installed.
- 3. This statement is correct.
- 4. DCN DM3 S-0957 93 revised the MOV Test Plan to VOTES Testing in accordance with the Corporate MOV Program (NRC Generic Letter 8910). The design requirements identified in S&W Specification 2364.200164 are deleted per DCN DM3-S-00139-93.5. S&W Specification 2362.200-164 and Specification SP ME 784 are different specifications. Specification SP ME.
784 provides valve design requirements only. S&W Specification 2362.200164 has been replaced by the Corporate MOV Program for valves 3RSS'MOV23A,0,C,D. Significance Level Criteria do not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3 0349, has identified a condition which is not discrepant. One specification is a NU prarement/ design document applicable to replacement valves and the other is an original AE procurement specification which is being replaced as replacement valves are Installed.
Significant Level Criteria do not apply as this is not a discrepant condition.
Previously klentined by NU7 O Yes (930 NonDiscrepantCondit6on?O Yes (91 No Res,Aut6cn Pending?O Ye.
- No Re oiution unre.oived7O Yes No Review initiator: Feingold. D. J.
VT Lead: Nort. Anthony A VT Mgt: Schopfer, oon K Printed 2/26S8 2 54 57 PM Page 2 of 3
Northeast Utilnies ICAVP DR No, DR MP3 0M9 Millstone unk 3 Discrepancy Report 9
9 Wtc Chmn: sWgh. Anand K O
O m
Dese:
2/2/96 st. cm,vnenes: Note: In Northeast Utilnles' disposition, the reference to
' Specification SP ME 0349'is assumed to be a typographical error, where the actual reference is ' Specification SP ME.764".
- 0349'is the number of the discrepancy report.
!! is unclear which design specification applies to the motor operators for valve 3RSS*MOV23A,B,C,0 given the response that states:
"DCN DMS-S 00139 93 required S&W Specification 2362.200-164 to be revised to remove valves applicable to 3RSS*MOV23A,B,C,D. Specification SP ME 0349 will replace S&W Specification 2362.200164 as the replacement valves are Installed."
and
'S&W Specification 2362.200164 has been replaced by the Corporate MOV Program for valves 3RSS*MOV23A,B,C D."
Consequently, a determination cannot be made related valve stroke time (FSAR Table 6.31), motor operator equipnient qualification, and motor operator hammer blow feature requirement (FSAR Section 6.3.2.2.5).
Pnntec 2rWw6 2.c4i2 PM Page 3 of 3
Northeast Utilities ICAVP DR No. DR MP3 0370 Millstone UnN 3 Discrepancy Report Review Ofoup: systeri DR REs0LUTioN REMcTED I
I Potential Operabillty leaue D6ecipune: PW Doo$n O vee D6et.repency Type: ceiculetwi (9) No systemMocese: Rss NRo significence level: 3 Date faxed to NU:
Date Published: 10/2597 Diecropency Safety factors used for potentially non conforming welds may be unconservative Descrepeton: In the process of reviewing the following documents, (i) Calculation No. 79 236 397GP, Rev. 01, Fracture Mechanics Evaluation of F.mbedded Contalnment Sump Line (11) SDP RSS 01361M3,Rev. 04,5/29/97 Stress Data Package, RSS and the additional references (ill) Newman and Raju, " Stress Intensity Factors for Intemal Surface Cracks in cylindrical Pressure Vessels", Transactions of ASME, Vol.102, November 1980.
(iv) G.C.Sih, "Hanobook of Stress Intensity Factors", institute of Fracture and Solid Mechanics, Lehigh University,1973, we note the following:
Background:
- 1) Calculation 79 236 397GP,(i), is based on the formulations provided by Newman, reference (111), for the Applied Stress Intensity, Kl. On page 4 it is noted that: "This solution is valid to at least 90% through wall [ defects)..."
The initial condition assumed for the evaluation is a 95% through wall defect which would have passed the Inlllal hydro pressure test.
2)Furthermore, assumption 2) on page 12 acknowledges that "At 95% they [the solution) may no longer be very accurate" and
" substantial errors in the calculation of fatigue growth would not change the conclusions."
3)The final acceptance of this condition is not based on demonstration that the end of design life condition satisfles the original design ba:,ls (ASME lii) but rather that the computed safety factors are comparable to those implied by the ASME Code. The computed safety factor is 3.0 whereas the stated safety factor imp!ied by ASME Section XI is 3.2.
Discussion:
Based on ' review of reference (ill), we believe the limits of the a
Newmari formulation are 80%, a defect with an alt ratlo (crack depth to wall thickness) of 0.8.
Printed 2/26,96 2.30 36 PM Page 1 of 6
Northeast Utilities ICAVP DR No. DR MP3-0370 Millstone Unit 3 Discrepancy Report Therefore, the sa ratio (0.95) exceeds the limitation of the Kl stress intensity f ador formula. It is our opinion that it may not be conservative to use the formula for this higher na ratio. This conclusion is based on a calculation using the K1 formula provided by Sib's Handbook (reference Iv) for an edge crack on a finite width plate subject to tension loading.
Comparing the results of these two formulations yleids the following; The ratio of Newman's Kl values for aA=0.95 and alt =0.8 is 1.845 The ratio of Sih's Ki values for aA=0.95 and s/t=0.8 is 9.035 Therefore, the potential for a lower value of Kl will under predict the value of crack growth per load cycle, da/dN, by the difference in Kl to the power 3.25.
It is also noted that the calculation identifies the design conditions for the affected piping as 235 degrees F, whereas the SDP (reference il) Identifies the maximum operating and design temperatures as 257 degrees F and 260 degrees F, respectively. This will have a nominal influence on the values -
for Flow Stress (collapse) and KIC used, Discrepancy:
The formulation used to calculate crack growth rates may be unconservative for the postulated sa ratio of 0.95 when compared to other methods. A higher growth rate would result in a lower safety factor than predicted and less than the stated safety factor implied by ASME Section XI.
Review Val 6d inval6d Needed Date init6etor: Olson, P.R.
Q Q
Q 10/2197 VT Leed: Nort, Anthony ^
O O
O o'ioS7 VT Mgri Schopfer, Don K Q
Q Q
10/1497 IRC Chmn: Singh, Anand K Q
Q Q
10/18,97 oeie:
INVALID:
Dele: 2/13/98 RESOLUTION: M3-IRF 01374 Disposition:
NU has concluded that Discrepancy Report, DR MP3-0370, does not represent a discrepant condition.
NU concurs that the depth of the postulated flaw evaluated in the above referenced calculation was greater than the range of applicability of th; equations used. This issue was acknowledged and discussed in the calculation.
Printed 2/2696 2.39 40 PM Page 2 of e l
Northead Utilities ICAVP DR No. DR4P3 0370 Miketone Unit 3 Discrepancy Report To address the specific issues identified in this DR, the following discussion is provided:
- 1) At the time that the calculation was pedormed, were there standards / equations (i.e. ASME or equivalent) available to evaluate deep (i.e,95% through wall) part through wall flaws? '
No. Based on a literature survey performed at that time, it was N
concluded that no equations were readily available to evaluate a 95% through well flew which was considered to be the bounding flew size that could have survived the hydrostatic pressure test.
- 2) Are the equations used expected to yleid reasonable and/or conservative results?
Yes. Equations for part through wall flaws are not expect 3d to result in grossly inaccurate results for deeper (i.e. > 80% through wall) flaws and are also expected to be conservative, The basis for this conclusion is that the Kl equations used to calculate the stress intensity are based on linear elastic fracture mechanics (LEFM) concepts which neglect any effects of crack tip yielding typical of deep cracks (i.e. Small remaining ligament).
Consideration of ligament yleiding results in a lower Kl value since some of the potential crack propagating energy is converted to plastic strain, Furthermore, the Newman equations used in the calculation are the most conservative of the equations considered by ASME XI and included as part of the flaw acceptance standards as described in Attachment 3 of the calculation. These equations are also considered to be more accurate than those published by G, C. Sih in 1973 since Newman's equations included further technology 9dvances and additional piping test data not available in 1973. Atto, NU does not concur that an edge crack on a finite width plate provides a better representation of the actual stress field around the crack tip than the Newman equations used in the subject calculation.
- 3) Does the accuracy of the calculation impact the conclusion?
No. As the calculation acknowledges, there is the potential for inaccuracles in the calculated values. However, the purpose of the calculation was not to assess the structural integrity of a known flaw but rather to assess the potential crack growth of a postulated flaw The calculation concluded that the 0.3562' postulated flaw would be expected to grow to approximately 0.35629' by the end of life of the plant. If one were to assume.
that the growth in crack depth was unconservative by a factor of 10, this would have an impact of approximately 0.2% on the final crack size, A factor of 100 would have an impact of -
approximately 2% on the final crack size, Since the purpose of a flaw tolerance evaluation is to assess the potential behavior of a flaw rather than to demonstrate strict regulatory compliance with any one specific requirement,inaccuracles of this magnitude
--- - (i.e,2%) are considered to be within the overall accuracy of the evaluation. NU believes that the conclusion reached in the calculation that the postulated flaw is not expected to exhibit sionificant flaw crowth durino the life of the plant. remains valid PrWed 2/26s96 2.30 41 PM Page 3 or 6
Northeast UtilMies ICAVP DR No. DR MP3 4370 Millstone UnN 1 Discrepancy Report and appropriate. It should further be noted that the effected portion of the piping system has since been encased in concrete which provides additional structural support for the imposed
- loads, l
Compliance with ASME 111.
Since ASME 111 does not allow cracks to be left in service, any component / pipe which contains cracks can not be demonstrated to be in compliance with ASME lit. The calculation acknowledged the fact that any location which contained a flaw similar to that eyaluated in the calculation, would be outside of the limits of the ASME Code and therefore require r~)ulatory approval.
Compilance with ASME XI margins of safety.
Page 9 of 14 of the calculation provides a comparison of the estimated normal and faulted margins of safety (i.e. 3.0 and 2.6 respectively) compared to the A SME Code required margins of safety (i.e. 3.2 and 1.4 respectively). The DR questions whether the appropriate margins of safety are satisfied.
As discussed above, the purpose of the caiculation was to demonstrate that future crack growth will not have a significant impact on the structural integrity of the piping. The margins of safety provided on page 9 of the calculation are based primarily on the successful completion of a system hydrostatic pressure test at 155 psi as compared to the design pressure of 60 psi.
Even though the calculation states that the implied ASME margins of safety are 3.2 and 1.4,later Editions of the ASME Code (i.e. lWB 3640) clarify the minimum required margins of safety to be 2.77 and 1.39 respectively for circumferential flaws and 3.0 and 1.5 for axlat flaws in stainless steel piping. Both of these values are equal to or less than the calculated margins of 3.0 and 2.6 respectively, Accuracy of the system design temperature The DR Indicates that the calculation lists the system design temperature as 235' F while reference 11) of the DR lists the design temperature as 260* F and that this discrepancy will have a nominalinfluence on the values for flow stress and KIC.
Although NU agrees that the actual design temperature is different from that provided by Stone & Webster in attachment 4 of reference I), this temperature was not used in the calculation and therefore has no impact on the resultsNof the calculation.
The flow / collapse stress used in the calculation was obtained from the results of the testing provided in EPRI report NP 2472 (reference 2 of the calculation). Furthermore, the ASME XI, Flaw Evaluation Subcommittee has published the basis for the stainless steel evaluation procedures of IWB 3640 (Attachment i to this retponse). Page 2 5 discusses the concept of flow stress and defines it as 3Sm since this provides a reasonable estimate of the onset of plastic collapse in stainless sjpel pipina Since the Printed 2/269e 2 39 42 PM Page 4 or e
Northeast Utiinnes ICAVP DR No. DR MP34370 Millstone UnN 3 Dik. opancy Report value of Sm for SA 312, TP304 material does not depend on temperature for temperatures less than 300' F (see ASME lil, Appendix 1. Winter 1985 Addenda) a change in system design temperature from 235' F to 260' F will not impact the flow stress.
Furthermore, a slightly higher system design temperature has a beneficialimpact on the fracture toughness (KlC) of the stainless steel because fracture toughness increases with increased temperature.
Based on the above discussion, NU has concluded that the results of the flaw tolerance evaluation performed in the above calculation remain appropriate for its intended use. Significance Level Criteria does not apply because this is not a discrepant condition.
Attachment:
EPRI NP 4690 SR,
- Evaluation of Flaws in Austenitic Steel Piping", Dated July 1986.
==
Conclusion:==
Nu has concluded that Discrepancy Report, DR MP3 0370, does not represent a discrepent condition. The purpose of the subject calculation was to assess the potential for fatigue crack growth in embedded sections of the Recirculation Spray System piping through the end of the plant life using a flew tolerance approach.
NU concurs that the limiting flew depth to thickness ratio was greater than the range of applicability of the equations used in the calculation. However, this issue was recognized and evaluated in the calculation with the conclusion that the expected accuracy of the results was consistent with the accuracy of a flaw tolerance evaluation. Significance Level Criteria does not apply as this is not a discrepent condition.
Previously identined by Nu? O Yes @ No Non F-
,- condn6on?O Yes @ No Resolut6cn Pend 6ng?O va + N.
RoootunonunresoevedtO va
- No Review Acceptable Not #-::;"
Nooded Date intuator: % P.R.
VT Leed: Nort. Anthony A O
O O
N VT Mor; Schopfer, Don K 1RC Chmn: Singh. Anand K Date:
2/13/98 sL comments: The conditions leading to the preparation of the subject calculation were that the embedded RSS sump line pipe welds had questionable documentation. Volumetric examinations to establish the actual weld condition was not possible.
Lacking any clear evidence to establish the condition of the welds, it would be prudent to assume that a weld defect may exist and that the defect would not meet ASME Section ill Code limitations. Given that situation, an exemption request with regulatory approval would be required. This was recognized in conclusion 5 of the calculation and acknowledged in the response provided by NU.
Pnnled 2/2tV96 2.39 44 PM Page 5 of 6 9
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l Northeast utilities ICAVP DR No. DR MP34370 Millstone Unit 3 Discrepancy Report S&L believes the final closure of the issue bs based on verification that the required regulatory exemption was filed and Oranted. This aspect of the condition is not related to the resolution of any specific technical comment on the calculation itself, but related to the inherent assumption regardin0 the condition of the weld.
The NU response does not identify the documentation which supports the stated need for regulatory approval. Therefore, we request that NU identify the documentation that was provided to address the Code exemption for the weld condition.
Observations on the IRF disposition of technical issues The following observations are provided on NU's response to the technicalissues raised in the DR We do not believe these observations require further response from NU based on the following two considerations applicable to the issue at question; The subject pipin0 experiences limited loading conditions (primarily pressure). In the absence of other loading or mechanisms which contribute to flew growth, the expected propagation of an initial flaw would be small for a wide range of potential flaw sizes (a4 ratios) for which Good predictive methods are available.
The postulation of an initlet flaw with an aA ratio of 0.95 is judged to be conservative given that included flaws encountered during acontrolled welding process would be expected to be much smaller.
Specific Observations on NU Responses it is noted that the 0.95 a4 ratio for the postulated flaw size does not define a real upper bound limit at which a leak might be expected under the 155 psig hydro pressure. Using the method provided in the reference report, EPRI NP-4690 SR, an axial flaw with an a4 ratio of 0.99 and crack length of 2*t can be shown to have suvived the appilded hydro test pressure. Therefore the initial condition for a ' worst case' postulated flaw could have been even greater than used in the calculatinn.
The calculation addressed a potential flaw with an a4 ratio of 0.95 This case is outside of the limits of available predictive equations specifically developed for crack growth evaluations. In the absence of other published data, the Shl approach was suggested for this case as a point of comparison with the calculation's mathods, albeit conservative or not.
Finally, the only load considered significant to potential crack growth is the pressure (hoop) stress effect. Given the Da ratlo for the subject pipe, we do not believe the encasing concrete
. provides any significant additional structural support in the hoop direction. hat would arrest potential crack growth.
Pnnled 2/2696 2.30 45 PM Page e of 6 i
Northeast Utilities ICAVP DR No. DR MP3 0643 Milletone Unit 3 Discrepancy Report Rev6ew oroup: Operatione s Maintenance and Techne DR RESOLUTION REJECTED
"'**"""*P'"**"
reee, iei OpereMia,i.
06eenpawn: Opersuone O vee D6ecrepency Type: Llooneing Docurnent g) g, systenVProcess: SWP j
NRC significence level: 4 Date FMed to NU:
Date Putd6ehed: 11/2497
~.crepency: Service Water Pump Testing inconsistent with FSAR D6 Requirement Deecrape6on: Service Water Pump Testing inconsistent with FSAR Requirement FEAR Section 7.3.1.1.5 states:
'The service water system is periodically tested in accordance with the Technical Specifications.
"This testing will consist of manually starting the pump during normal surveillance of the system or the breaker for the pump will be in the test position. Once the pump is running or the breaker is in the test position, the AUTO start and tripping is verified using the emergency generator load sequencer with safety signals generated intemally or extemally to the sequencer."
The following two surveillances that test the operation of the service water pumps were reviewed to confirm that the above requirements were being satisfied, SP 3626.4, ' Service Water Pump SSWP*PI A operational Rewiiness Test'(including checksheet OPS Form 3626.41) and SP 3646A.18," Train B ESF With LOP Test (IPTE)". No evidence could be found to confirm that the requirements were being met. Neither procedure documents a manual start of the pump. Page 2 of SP 3626.4 (Basis Document edition) states in the Basis Information block on page 2 that:
"This procedure provides for two sequencer starts and eliminates the manual start from the control room, No written requirement for a manual start has been found checking the FSAR and the ISI manual. The conclusion has been made that a manual start is not necessary since the pumps are started for other reasons during the month. If a manual start is needed, credit can be taken for pump C in this procedure and for pump A in 3626.6, since the pumps are started to switch lineup.'
Our interpretation of the FSAR seguirement is to manually start the pumps so that the AUTO trip function and sequencer loading on the EDG can be verified. Both procedures test the AUTO start of the pumps on the load sequencer but do not test the AUTO trip function.
Additionally, a review of the OPS forms associated with these procedures indicate that change of pump operating states are not documented.
Prtnted 2/26Se 24.15 PM Page 1 of 2
~..
Northeast Utilities ICAVP DR No. DR MP3 0643 Millstone unN 3 Discrepancy Report it was also noted that the FSAR requirement that the pumps be started manually or that the breaker for the pump be in the test position are not equivalent actions. The equivalent action to a manual pump start would be to place the breaker in the test position and close the breaker, The testing cunently performed does not adequately demonstrate that the FSAR requirements are being satisfied.
Review v.nd i.nd N ed Dei.
Initiator: Temlyn, Tom O
O O
ior31'87 VT Lead: Bass, Ken O
O O
10/31/87 VT Mge: Schopfer, Don K O
O O
11'5S7 IRC Chmn: Singh, Anand K O
O O
11/ISS7 Dele:
wvAuo:
i D*: 2/19/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR MP3-0563, 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 Pl.
20 criteria and found to have no operability or reportability concemt. and meets the Unit 3 deferral criteria. CR M3-98-0167 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3 0563, 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 Pl-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral enteria, CR M3 98-0167 has been written to develop and track resolution of this item per RP-4.
Previously identined by Nu? O Yes # No Non D6screpent Condnion?O Yes @ No Re w on Peamaar O vos @ No Re.osutioavare.oevedrO Yes @ No Review initiator: Spear, R.
b VT Lead: Bass. Ken VT Mgri Schopfer. Don K 1RC Chmn: Singh. Anand K O
3 O
Date:
2/19/98 sL Connsats: S&L does not concur with NU's determination that this discrepancy meets the Unit 3 deferral criteria. The DR identifies a discrepancy between the FSAR and plant procedures which have a direct impact on plant safety and operation.
Printed 2/269e 2A0.20 PM Pa0e 2 of 2
Northeast Utilities ICAVP DR No, DR MP3 0668 Milletone unit 3 Discrepancy Report Review Group: sychm DR REs0LUTioN REJECTED Potential oporabituy issue Diecipline* MechanicalDoeng" O va 06ecrepancy Type: Component Date system / Process: HVX NRC signiacance level: 3 Date faxed to NU:
Date Publ6ehed: 11/2497
~
D6ecre D ry: ABVS Filter Unit Electric Hester capacity Deecript6en: During review of the Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/1B a discrepancy regarding the capacity of the electric heating coilin the filter units was identified.
Regulatory Guide 1.52, Rev. 2, position C.3.b requires the heaters to be riesigned, constructed, and tested in accordance with the requirements of Section 5.5 of ANSI N5091976. ANSI N5091976 Section 5.5.1 states that the heater shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air steam mixture (RH=100%) to approximately 70% in the housing space between the moisture separator and profilter stage, at system design flowrates. FSAR Table 1.8 2 and FSAR Table 6.51 state that the filter units are in compliance with Regulatory Guide 1.52 Rev. 2, position C.3.b.
The results of calculations 97 ENG-01453M3, Rev. O and B235-9915, Rev. B indicate that for degraded voltage and the specified 170*F,100%RH entering air conditions the electric heater capacity results in a relative humidity of 75.2%. The 75.2% RH value does not meet the RG 1.52 requirements.
Review Val 6d inval6d Needed Date initiator: Stout. M. D.
O O
O ii'11'S7 VT Lead: Nort. Anthony ^
O O
O 15'11/S7 VT Mgt: Schopfer, Don K O
O O
11'17/S7 1RC chnm: Singh, Anand K O
O O
Itran97 Date:
wvAuo:
)
Date: 2/16/98 REs0LUTION: NU has concluded that the issue reported in Discrepancy Report, OR MP3 0658, does not represent a discrepant condition.
ACR M3 97 0161 was written on 6/1/96 to document discrepancies between the minimum design voltage for Class 1E heaters and the low voltage capability of the heaters to perform their design basis function.
A design basis review of the degraded voltage calculation (NL-042) was performed and documented on ACR M3-97 0119, which was determined to be reportable. During the review of that ACR, it was noted that the acceptance criteria used for motors (90% of rated voltage,460 volts) was also applied to resistive devices (heaters, rated 480 volts). This results in a Printed 2/2696 2-40 52 PM Page 1 of 4
^
Northeast Utilities ICAVP DR No. DR MP3 4468 Millstorm Unit 3 Discrepancy Report 25% reduction in heater output. No justification for this assumption was given in calculation NL 042. Upon further review it did not appear that this reduced operating margin was accounted for in the heater sizing calculation either. This finding was reinforced by a previous review for reportability (Ref 92 25) whereby, neither the eledrical nor mechanical calculation accounted foi operating margin at reduced voltage (voltage just above the degraded voltage setpoint) during a DBA condition.
At that point the ACR M3 97 0161 was generated for the suspect equipment and a formal reportabilty review commenced.
ACR M3-97 0161, item 4, discussed Auxiliary Building Ventilation System (ABVS) filter unNs 3HVR*FLT1N15 CVI inc., provided the MP3 filter assemblies. CVI Calculation (DWG B2553 9915, change B dated 4 2192), determined the relative humidity at design flow and degraded voltage (414V) to be 75.2% RH for the Auxillary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/18. This calculation determined that Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1N1B does in fact meet the RH criteria of ANSI N509 4
at design flow and degraded voltage. The Conclusion was based on the following criteria.
ERDA 764t, Nuclear Air Cleaning Handbook, for Design, Constructios cr4 Testing of High Efficiency Air Cleaning System for Nuclear Application is referred to as a supplement to ANSI-N509. ERDA 78 21 recommends conservative efficiency values for design of 2 inch impregnated activated carbon beds (ref.
section 3.4.2 and table 3.11).
For example, from table 3.4.2, at 85% or less RH, the design for charcoal is 95% efficient at 70' and 98% efficient at 270'.
These temperatues are consistant with the expected condition when the heaters are required. The ERDA values are conservative and have been validated with the charcoal testing vendor (NCS) where NCS's assessment stated that charcoal could exceed 80% relative humidity without impacting charcoal adsorption measurably. The MP3 Radiological calculations credit charcoal filters at 95% efficiency. AlthouJh, the purchase specification states each electric heater shall reduce the relative humidity to less than 70%, it also states that the heaters are to meet design requirements of ANSI N509, which states that "the heators shall be sized on the basis of heat transfer calculations showing its capability of reducing the maximum expected relative humidity of the entering air stream mixture to approximately 70% in the housing space'. The purchase specification was providing margin when it specified less than 70% while meeting the specified requirements of ANSI N509.
This is the widely recognized and acceptable requirement.
Therefore, the filtration unit heaters meet the purchase specification requirements of ANSI-N509. Based on Northeast Utilities Memo No. PSM3-92 066 the effect on the charcoal sample penetration test with higher relative humidities of 75.2%
- in the Auxiliary Building Filtration System (#HVR*FLT1 A & 1B) will be unmeasurable. The memo further stated that (NNECO) could exceed relative humidity without Imoactina the charcoal PrWed 2/2698 2:40.56 PM Page 2 or 4
,r
.r.
Northeast Utilities ICAVP DR No, DR MP3 0888 Millstone Unit 3 Discrepancy Report absorption to a measurable level.
Additionally, concems were sufficiently substantiated to question the validity of the degraded Grid Voltage Calculations (CR M3-97-0119 & LER 97 010). Reviews performed on MP3 heater applications found that the heaters were able to perform their design functions with the orception of the Hydrogen recombiner heaters. The corrective action plan for CR M3 97 0119 required a comprehensive review of all the class 1E components to ensure operability at the voltage levels at the DGV setpoint analyticallimit. (see LER 97 01100). Calculation NL 038 documents the voltage profile and load flow and NL 042 determines the DGV setpoint. Calculation 97 ENG 01453M3 evaluates the heater minimum volta 0e capacity. This Calculation,97 ENG 01453M3, has concluded that minimum available voltage is 414VAC for heaters at all locations except those at the Auxiliary Building Area. The Auxillary Building Area Heaters Relative Humidity will be approximately 5% higher than 70% requirement, at a temperature of 170'. This environmental condition should only last 30 minutes and then retum to normal.
Supplemental calculations, following the CVI calculation method show that at 120*F the heaters are capable of achieving 70% RH at degraded voltage (Ref. Calc. NL 038 Rev. 2, CCN 7. Included in Package) conditions. The actual degraced voltage is greater than 414/422VAC as determined from Calculation NL 038 (VN4500-F02-001).
Based on discussion above the plant was not and is not outside its design basis and this subject is not reportabb.
Therfore, NU has concluded that the issue reported in Discrepancy Report, DR MP3-0858, does not represent a discrepant condition.
Significance level criteria do not apply as this is not a discrepant condition.
Attachments:
- 1. ACR M3-97 0161
- 2. Ref 92 25 & PS M3 92 bo6
- 3. NL 038, Rev 2. CCN7
- 4. 97 ENG 01453M3 Previously identined by NU? O vos (Si No Non D6ecrepent Condition?Q vos feb No ResolutionPending?O vos @ No Resoiuiionunresoeved?O ves + No Review inellator: Stout, M. D.
O O
O m
VT Lead: Nort, Anthony A VT Mer: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
2/16/98 sL Commente: Disagree with NU's response that this is not a discrepant condition.
This is a discrepant condition because FSAR Table 1.81 and Pnnted 2/2tV9e 2 40 57 PM Page 3 of 4
Northeast Utilities ICAVP DR No. DRMP34468 Millstone unk 3 Discrepancy Report Table 6.51 do not take exception to nor provide clarification to RG 1.52, Rev. 2, pare 0raph C,3.b requirements regarding i
capibility of the electric heating coil to maintain relative humidity of air entering the adsorber below 70%.
NU's response should also address impact on laboratory testing of charcoal adsorbent which is conducted with a 70% relative humidity entering condition.
l Printed 2/2696 2 40.50 PM Page 4 or 4
i the:st Utmties ICAVP DR N2. DR MP3 0669 Millstone unit 3 Discrepancy Report Review Oruup: System DR RESOLUTION REJECTED 4
Potential OperatWity leeue D'ecipi6ne: Mechanical Dwig" O vee Discrepency Type: component Date gg SystemProcese: HVX NRC Sign.ncence level: 3 Date faxed to NU:
Date Putdished: 11/24/97 Discrepency: SLCRS Filter Unit Electric Heating Coll Ccpacity Desctlption: During review of the the Supplementary Leak Collection and Release System (SLCRS) fit *er units 3HVR*FLT3A/3B a discrepancy regarding the capacity of the eiectric heating coilin the filter units was identified.
Regulatory Guide 1.52, Rev. 2, position C.3.b requires the heaters to be designed, constructed, and tested in accordance with the requirements of Section 5.5 of ANSl fl509-1976. ANSI N509-1976 Section 5.5.1 states that the hesier shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air-steam mixture (RH=100%) to approximately 70% in the housing space between the moisture separator and prefilter stage, at system design flowrates. FSAR Table 1.8-2 and FSAR Table 6.5-1 state that the filter units are in compliance with Regulatory Guide 1,52, Rev. 2, position C.3.b.
Calculations 97-ENG-01453M3, Rev. O and B235-9915, Rev. B show that at an air flow rate of 8500 scfm and entering air concitions of 120'F & 100% RH the required heater capacity is 36 kW. The capacity of the heater at degraded voltage conditions is 37.2 kW. At the current maximum SLCRS air flow rate of 9,800 cfm shown on PelD EM-148E-12, the required heater caprp.ity increases above the available capacity of the heaters. This will result in a relative humidity greater than 70%.
Review Valid invalid K wded Date initletor: Stout, M. D.
O O
O 11111/S7 VT Lead: Neri, Anthony A O
O O
1 '11/S7 VT Mgr: Schopfer, Don K O
O O
11'17/S7 IRC Chmn: Singh. Anand K O
O O
i /20<97 Date:
l INVAUD:
Date: 2/17/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0659, has identified a condition previously discovered by NU which does not rer esent a discrepant condition.
ACR M3-97 0161 was written on 6/1/96 to document discrepancies between the minimum design voltage for Class 1E heaters and the low voltage capability of the heaters to perform their design basis function.
A design basis review of the degraded voltage calcula'Jon (NL-042) was performed and documented on ACR M3-97-0119, Printed 2/26/98 2:41:24 PM Page 1 of 4 t
v
I l
Northeast Utilities ICAVP DR No. DR-MP3-0650 Millstone Unit 3 Discrepancy Report which was determined to be reportable. During the review [
that ACR, it was noted that the acceptance criteria used for mctors (90% of rated voltage,460 volts) was also applied to resistive devices (heaters, rated 480 volts). This results in a 25% reduction in heater output. No justification for this assumption was given in calculation NL-042. Upon further review it did not appear that this reduced operating margin was accounted for in the heater sizing calculation either. This finding was reinforced by a previous review for reportability (Ref 92 25) whereby, neither the electrical nor mechanical calculation accounted for operating margin at reduced voltage (voltage Just above the degraded voltage setpoint) during a DBA condition.
At that point the ACR M3 97 0161 was generated for the suspect equipment and a formal reportabilty review commenced.
ACR M3-97 0161, item 4, discussed Supplemental Leak Collection and Release System (SLCRC) filter units 3HVR*FLT3A/3B. CVI inc., provided the MP3 filter assemblies.
CVI Calculation (DWG B2553-9915, change B dated 4 2192),
determined the relative humidity a' design flow and degraded voltage (414V) to be 73.4% RH for discussed Supplemental Leak Collection and Release System (JLCRS) filter units 3HVR*FLT3A/38. This calculation determined that discussed Supplemental Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/3B does in fact meet the RH criteriS af ANSI N509 61 design flow and degraded voltage. The Conclusion was based on the following criteria.
ERDA 6-21, Nuclear Air Cleaning Handbook, for Design, Construction and Testing of High-Efficiency Air Cleaning System for Nuclear Application is referred to as a supplement to ANSI-N509. ERDA 76-21 recommends conservative efficiency values for design of 2 inch impregnated activated carbon beds (ref, section 3.4.2 and table 3.11).
For exemple, from table 3.4.2, at 85% or less RH, the design for charcoalis 95% efficient at 70' and 98% efficient at 270'.
These f emperatues are consistant with the expected conditloh when the heaters are required. The ERDA values are conservative and have been validated with the charcoal testing vendor (NCS) where NCS's assessment stated that charcoal could exceed 80% relative humidity without impacting charcoal adsorption measurably. The MP3 Radiological calcelations credit charcoal filters at 95% efficiency. Although, the purchase specification states each electric heater shall reduce the relative humHity to less than 70%, it also states that the heaters are to meet design requirements of ANSI N509, which states that 'The heaters shall be sized on the basis of heat transfer calculations showing its capability of reducing the maximum expected relative humidity of the entering air stream mixture to approximately 70% in tha housing space'. The purchase specification was providing margin when it specified less than 70% while meeting it.e specified requ;rements of ANSI H509.
This is the widely recognized ar.d acceptable requirement.
Therefore, the filtration unit heaters meet the purchase specification requirements of ANSI-N509. Based on Northeast Pmted 2/26/98 2:41:27 PM Page 2 of 4 l
N:rthetst Utilities ICAVP DR Ns. DR MP3 0659 Millstone unit 3 Discrepancy Report Utilities Memo No. PSM3-92 066 the effect on the charcoal sample penetration test with higher relative humidities of 73.4%
in the discussed Supplemental Leak Collecf a and Release System (SLCRS) filter units 3HVR*FLT3A/B will be unmeasurable. The memo further stated that (NNECO) could exceed relative humidity without impacting the roarcoal absorption to a measurable level.
Additionally, concems were sufficiently substantiated to question the validity of the degraded Grid Voltage Calculations (CR M3-97 0119 & LER 97 010). Reviews performed on MP3 heater applications found that the heaters were able to perform their design functions with the exception of the Hydrogen recombiner heaters. The corrective action plan for CR M3-97 0119 required a comprehensive review of all the class 1E components to ensure operability at the voltage levels at the DGV setpoint analyticallimit. (see LER 97 01100). Calculation NL 038 documents the voltage profile and load flow and Nt.-042 determines the DGV setpoint. Calculation 97 ENG 01453M3 evaluates the heater minimum voltage capacity. T.11s Calculation,97 ENG-01453M3, has concluded that minimum available voltage is 414VAC for heaters at all locations except those at the Auxiliary Building Area. The Auxiliary Building Area Heaters Relative Humidity will be approximately 5% higher than 70% requirement, at a temperature of 170'. This environmental condition should only last 30 minutes and then retum to normal.
Supplemental calculations, following the CVI calculation method show that at 120'F the heaters are capable of achieving 70% RH at degraded voltage (Ref. Calc. NL.038 Rev. 2, CCN 7, included in Package). conditions. The actual degraded voltage is greater than 414/422VAC as determined from Calculation NL 038 (VN4500-F02-001).
Based on discussion above the plant was not and is not outside its design basis and this subject is not reportable. Therefore, NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0659. does not represent a discrepant condition.
Significance level criteria dc M apply as this is not a discrepant condition.
Attachments:
- 1. ACR M3-97-0161
- 2. Ref 92-25 & PS M3-02-066
- 3. NL-038, Rev. 2, CCN 7
- 4. 97 ENG-01453M3 Previously identified by Nu? O Yes T No Non Discrepant Condition?O Yes @ No Resoluuon Pending?O Ye.
@ No Re.oiution unr. iv.d?O s e.
@ No Review initiator: stout, M. D.
VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chrnn: singh. Anand K Date:
2/17/98 F 'Inted 2/28/96 2.41:29 PM Page 3 of 4
Northeast Utilities ICAVP DR No. P'-MP3-0669 Millstone Unit 3 Discrepancy Report sL Comments: NU's response did not address the discrepancy in calculation 97 ENG-01453M3, Rev. 0 which used an airfiow rate of 8,500 cfm instead of 9,800 cfm.
From calculation B235-9915, Rev. B at a 120'F 100% RH entering air conditions and 9,800 cfm, the heater KW required is 41.53 KW + housing losses. Note that the hous'ng heat gain determined in B235 9915 was based on a 300*F ambient temperature and is not applicable for the 120*F entering condition. Calculation needs to be revised to determine the correct housing heat loss that needs to be added to the required heater capacity. At 414 volts the heater output is 37.2 KW for 3A/38. At the switchyard voltage (not defined in calc) the heater output is 40.4KW for 3A and 39.7KW for 38. Therefore the heater capacity is not sufficient to limit the relative humidity to 70% RH.
FSAR Table 1.8-1 and Table 6.5-1 do not take exception to nor provide clarification to RG 1.52, Rev. 2, paragraph C 3.b ~
requirements regading capibility of the electric heating coil to maintain relative humidity of air entering the adsorber below 70%.
NU's response should also address impact on laboratory testing of charcoal adsorbent which is conducted with a 70% relative humidity entering condition.
D Printed 2/26.981:41:30 PM Page 4 of 4 l
Northe:st Utilities ICAVP DR No, DR-MP3-0679 Millstone Unit 3 Discrepancy Report Review Group: Operations & Meantenance end Testing DR RESOLUTION REJECTED PotentialOperability losue Diecipline: Operations g
Discrepency Type: O & M & T Procedure O No SystemProcess: DGX NRC Significance level: 4 Date faxed to NU:
Date Putdished: 12/1497
~
D6screpancy: Surveillance procedure designates a load range that is 186 kW less than the TS requirement Descripuon: Technical Specification 4.8.1,1.2.b states:
"At least once per 184 days, verify that the diesel generator starts and attains generator voltage and frequency of 41601420 and 60 *0.8 Hz within 11 seconds after the start signal. The generator shall be synchronized to the associated emergency bus, loaded to greater than or equal to 4986 kW In accordance with the manufacturer's recommendations, and operate with a load greater than or equal to 4986 kW for at least 60 minutes,,"
The " Technical Specification Surveillance / Testing for Requirement Cross Reference to actual Plant Procedure for all Tech, Specs." database identifies SP 3646A.1, " Emergency Diesel Generator A operability Test" as the controlling procedure that satisfies the requirements of TS 4.8.1.1.2.b. SP3646A.1 identifies OP Form 3646A.1 1, " Emergency Diesel Generator A Operability Tests" as the data sheet for establishing the T/S acceptance criteria and documenting the test results.
Both SP3646A.1 and OP Form 3646A.1 1 acceptance criteria for load is 4,800 to 5000 kW, and therefore designates a load range that is 186 kW less than the Technical Specification requirement.
Review Valid invalid Needed Date initiator: Tomlyn, Torn O
O O
114S7 VT Lead: Bass, Ken O
O O
11'17'S7 VT Mgr: schopfe, Don K Q
O O
i2/i/97 IRC Chmn: singh, Anand K O
O O
$2/s/97 Date:
INVALID:
Date: 2/19/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0679, has identified a condition 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 U3 Pl.
20 criteria and found to have no operability or reportability concoms and meets the Unit 3 deferral criteria. CR M3-98-0169 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
Pnnted 2/26,9e 2:41:s8 PM Page 1 of 2
Northert Utilitie3 ICAVP DR No. DR MP34679 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report, DR MP3-0679, has identified a condition not previously discovered by NU which requires correction. This discrepancy maets 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 M3-98-0169 has been written to develop and track resolution of tr.'s item per RP-4, Previously identifled by NU? C) Yee @ No Non Discrepent Coruittion?() Yes (#1 No Resolution Pending?O yeo (6) No Resolution unre.olvedtO vee @ No Review Acceptable Not Acceptable Needed Date S
R.
D mm VT Leed: Base, Ken VT Mgri Schopfer, Don K IRC Chmn: Singh, Anand K Date:
2/19/98 st. Comments: S&L does not concur with NU's determination that this discrepancy meets the Un!! 3 deferral criteria. The DR identifies a discrepancy between the FSAR and plant procedures which have a direct impact on plant safety and operation.
Printed 2/26/98 2:42.02 PM Page 2 of 2
Northeast Utilities ICAVP DR No. DR-MP3-0783 Millstone Unit 3 Discrepancy Report j
Review Group: Wions & Maintenance and Testing DR RESOLUTION REJECTED Review Element: Correcttve Action Process g
Discipline: Operation.
Ow Discrepency Type: Correcttve Action
( g SystemProcess: Rss NRC Significence level: 4 Date faxed to NU:
Date Published: 1/2s/96 Discrepency: Licensee Event Report (LER) Root Cause Determination inadequacies /Close-out Inadequacies
==
Description:==
Millstor:e Unit 3 LER 89-017-00 was written to identify an event where one of the motor operi ' containment isolation valves (3RSS*MOV20D) for the Coi..enment Recirculation Spray header had not been fully operable for 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> and the required 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Technical Specification action had not been performed, The LER concluded that the root cause of the event was L
muate administrative guidance on the definition of r_ r
'ent isolaticn valves, which led to a misinterpretation of the Technical Specifications and the FSAR on the part of the operators and the operations shitt management. The LER commited to include guidance on containment isolation valves in permanent plant procedures by February 28,1990.
Commitment Record No.17556 was initiated to resolve and track this item. The commitment states: "As action to prevent recurrence, interim guidance was provided Indicating that all valves listed in FSAR Table 6.2 65 are containment isolation valves. Final guidance will be inclu%d in permanent plant procedures by February 28.1%0." The Validation Text states, however, that the final guidance is already contained in the Technical Requirements Ma7ual, STRM 3.6.3.
Additionally, two more commitments were made to resolve the LER commitment. They were:
(1) Commitment No. 3-89-0192, which stated: " Provide clarification to FSAR Table 6.2-65 to define clearly which valves are containment isolation valves foi urposes of T.S. 3.6.3.* The I
only action taken was addition of a note which str#s:" Changes to this table require 10CFR50.59 evaluation in accordance with Technical Specification 3/4.6.3 bases." The item was closed without providing clarification or guidance.
(2) Commitment No. 3-89-0151, which stated: " Engineering to revise / develop a new FSAR Table-6 showing containment penetration, required accident state & leakage requirement (relative to alr/ water and bypass leakage)." FSAR Table 6.2-65 already contained these items, and no change was made.
Since all of the commitments made in LER 89-017-00 failed to result in revisions to administrative guidelines to correctly identify containment isolation valves, Northeast Utilities (NU) should have revised the root cause determination in the LER.
Review Prm12/26/98 2:42 32 PM Page 1 of 2
Northeast UtlHties ICAVP DR No. DP. MP3 0783 Millstone Unit 3 Discrepancy Report Val 6d inveM Needed Dr.se initiator: Petroeky,AL G
O O
12/22/97 VT Leed: Bees, Ken O
O O
12/24/97 VT My: Schopfer, Don K Q
Q 1/1096 1RC Chmn: Singh, Anand K O
O O
1/21/96 Date:
INVALID:
Date: 2/25/98 RESOLUTl0N: NU has concluded that Discrepancy Report, DR-MP3-0783, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 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-CS52 has been written to develop and track resolution of this item per RP-4,
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0783, has identified a condition not previously discovered by NU wh2c.i requires correction, This discrepancy meets the criteria sp scified in NRC letter B16901 and 1701011 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 M3-98-0652 has been written to develop and track resolution of this item per RP-4.
Prev.ously identitled by NU? O yes @) No Non Diecrepent Condition?Q ves @) No Resolution Pet: ding?O vos @ No Resoiutionunresoived?O vos @ No Review initletor: Speer, R.
VT Lead: Bees, Ken VT uge: Schopfer, Don K IRC Chmn: SWh, Anand K Date:
2/25/98 SL Commente: It is not apparent from the corrective action description what changes are intended to resolve the misinterpretation of the Technical Specifications and the FSAR.
Further, S&L does not concur with NU's determination that this discrepancy meets the Unit 3 deferral criteria. The DR Identifies a discrepancy between the FSAR and plant procedures which have a direct impact on plant safety and operation Pnnted 2/26/98 2:42:37 PM Page 2 of 2 l
l Northeast Utilities ICAVP DR No. DR MP3-0808 l
Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Re E W :S $n W Diecipline: Electrical Design Potential operability leeue Om Discrepancy Type: Uconomg Documert M" No System /Procese: DGX NRC Significance level: 4 Date faxed to NU:
Date Publietted: 1/1oS8 Discrepency: Frequency and Voltage Values in DBSD do not appear to match Tech Spec Values
==
Description:==
Background:
Emergency Diesel Generator A Operability Test, OPS Form 3546A.1 1. Page 2 of 3, dated 5/6/97 lists a number of Generator Operability Tests and Tech Spec Acceptance Criteria, Step Parameter / Condition T/S Acceptance Criteria 4.2.7 EDG A Voltage 3740 - 4580 V 4.3.6 EDG A Frequency 59.2 60,8 Hz Design Basis Summary Document 3DBS-EDG-002, paragraph 8,1 states:
Generator Tenninal Voltage - Steady State: 4160 Volts nominal steady state 5347 volts maximum,3973 volts minimum) within
+/ 21 volts Design Basis Summary Document 3DBS-EDG-002, paragraph
8.2 states
Generator Frequency - Steady State: 60 Hz Nominal steady state (60.5 Hz maximum in the no load, droop mode,59.85 Hz minimum)
==
Conclusion:==
The nominal values stated in the Design Basis Summary Document do not appear to match the limit on "as found" values in the Tech Spec Operability tests.
Review Valid invalid Needed Date initiator: Warner,1.
O O
O 12/iem7 VT Lead: Neri, Anthony A G
O O
12/ irs 7 VT Mgr: schopfer, Don K G
O O
12/23 s 7 IRC Chrnn: singh, Anand K B
O O
12/31/97 Date:
INVALID:
Date: 2/23/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report DR-MP3-0808, has Pnnted 2/2658 2:43 00 PM Page 1 of 3
Northeast Utilities ICAVP DR No. DR-MP3-0808 Millstone unit 3 Discrepancy Report identified a condition previously discovered by NU which requires correction.
l The Emergency Diesel Generator (EDG) Voltage limits provided l
In the Technical Specification is common to all power plants and l
represer ts the reasonable EDG performance, The MP3 l
Technical Specification for diesel generator operability requires verifying that the diesel starts from standby conditions and achieves generator voltage and frequericy of 4160 +/- 420 volts (4580 to 3740 Volt:) and 60 +/ 0.8 Hz. Condition Report (CR)
M3 97-0730 was written to address operating outside the equipmert requirements. The Design Basis Summary Document (DBSD) 3DBS-EDG-002 section 8.1 and 8.2 steady state terminal voltage 4160 (4347 volts maximum,3973 volts minimum ) within +/ 21 volts and frequency 60 Hz nominal (60.5 Hz maximum in no load and droop mode 59.85 Hz) come from the Stone and Webster motor and generator system specification
- Emergency Diesel Generator System (E 241)".
The DBSD is not discrepant with the Technical Specifications because the Emergency Diesel Generator System specification is more restrictive and the equipment is better bounded by the values in the Technical Specifications. The approved Corrective
' tion Plan (CAP) (attached) for Condition Report (CR) M3 -
130 will "Redse proce: lures to include steady state voltage limits to be monitored between 4350 and 3950 Volts." This adivity is not a startup issue.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3-0808, has identified a condition previously discovered by NU which requires correction.
Condition Report (CR) M3-97-0730 was written to address operating outside the equipment requirements. The approved Corrective Action Plan (CAP) (attached) for Condition Report (CR) M3-97 0730 will revise procedures to include steady state voltage limits to be monitored between 4350 and 3950 Volts.
This activity is not a startup issue.The DBSD is not discrepant with the Technical Specifications because the Er.Prgency Diesel Generator System specification is more restrictive a.1 the equipment performance is better then required by Technical Specifications.
Previously iden*1 fled by NU? O Yes @ No Non Discrepent Condition?O Yes @ No ResolutionPending?O Ya @ No RuolutionUnruolved?O Ya @ No Acceptable Not Acceptable Date initletor: Warner. I.
VT Lead: Nort, Anthony A VT Mgt: schopfer, Don K 1RC Chmn: singh, Anand K Date:
2/23/98 sL comments: We concur that Condition Report (CR) M3-97 0730 (initialec 3/7/9 Printed 2/26/96 2:41os PM Page 2 of 3
)'
Northeast Utilities ICAVP DR N2, DR-MPt-0808 Millstone Unit 3 Discrepancy Report
- 7) Identified an issue with respect to operating the diesel Generators at more than 5% above or below its rated voltage. 'Ne (10 not concur that the CR addresses the DR issue.
The DR response states:
'The DBSD is not discrepant with the Technical Specifications because the Emergency Diesel Generator System specification is more restrictive and the equipment is better bounded by the values in the Technical Specifications."
The definition of " restrictive" is dependent on how the DDSD is being used. If the high end voltage value stated in the DBSD was used to estimate a fault current, then the value in the DBSD would not be more restrictive. in addition, the CR states that the k
voltage values in calculation NL-038 are 3744V (min) and 4310V (max) wbJch do not bound the values in the DBSD.
If the DBSD is to contain a value, such as 4160V +/- 4.5%, there should be some stated relationship between this value and the values used in other documents.
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