Text

Forwards thirty-three Discrepancy Repts Identified During Review Activities for Independent CA Verification Program IAW Communications Protocol,PI-MP3-01
	ML20203J061
Person / Time
Site:	Millstone
Issue date:	12/17/1997
From:	Schopfer D; SARGENT & LUNDY, INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	9583-100, NUDOCS 9712190113
	Download: ML20203J061 (89)
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/[fg ~ ,.9-I 1:: sot'pge iLundy"* fY Don K. Schopler $?t$N$?$ December 171997 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Ststion, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed the following thirty three (33) 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. DR No. DR-MP3-0144 DR No. DR-MP3-0723 DR No. DR-MP3 0227 DR No. DR MP3-0727 DR No. DR MP3-0279 DR No. DR MP3 0729 DR No. DR MP3-0592 DR No. DR MP3-0731 DR No. DR-MP3-0654 DR No. DR-MP3-0738 DR No. DR-MP3-0663 DR No. DR-MP3-0739 DR No. DR MP3-0682 DR No. DR-MP3-0740 DR No. DR-MP3-0684 DR No. DR-MP3-0741 f DR No. DR MP3-0688 DR No. DR MP3-0744 DR No. DR MP3 0690 DR No. DR-MP3-0746 \\ I DR No. DR MP3-0691 DR No. DR-MP3 0753 DR No. DR-MP3-0702 DR No. DR-MP3-0754 i

DR No. DR-MP3-0704 DR No. DR-MP3-0758 DR ho. DR MP3-0711 DR No. DR-MP3-0762

,) DR No. DR-MP3-0717 - DR No. DR-MP3-0771 / DR No. DR-MP3-0718 DR No. DR MP3-0772 / DR No. DR-MP3 0774 [ F M M fE ll l Illi,llll'lll 1.1 3au? o e $$ East Montoe Street

Chicago. IL 60603 5780 USA. 312-269-2000

u - United States Nuclear Regulatory Commission December 17,1997 Document Control Desk Project No. 9583-100 Page 2 I have also enclosed the following nine (9) DRs for which the NU resolutions have been-reviewed and accepted by S&L DR No. DR MP3-0190 DR No, DR-MP3-0212 DR No. DR-MP3-0205 DR No. DR-MP3-0345 DR No. DR-MP3-02% DR No. DR MP3 0445 DR No. DR-MP3-0207 DR No.- DR-MP3-0524 DR No. DR MP3-0542 I have also enclosed the six (6) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided. DR No. DR MP3-0013 DR No. DR-MP3-0328 DR No. DR-MP3-0015 DR No. DR-MP3-0348 DR No. DR-MP3-0263 DR No. DR-MP3-048v Please direct any questions to me at (312) 269-6078. Yours very truly, N D. K. Schepfer Vice President and ICAVP Manager DKS:spr Enclosures Copies: E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council - J. Fougere (1/1) NU m%eM7ew1217.aes

I Northeast Utilities ICAVP DR No. DR MP3-0144 Millstone Unit 3 Discrepancy Report Rev6ew Group: system DRVAUD Potential Operebany issue D6ecipl6ne: Mediencal Desgn O va Diecrepency Type: Drewrg gg SystenWProcese: Oss NRC SigrWAconce level: 4 Date faxed to NU' Date Published: D6screpancy: Discrer>ancies on PalD EM 115A Revision 18 are as follows: De*cr$pt6on: llem i P&tD EM 115A shows valves 30SS*MOV34A and 3QSS*MOV34B closing on a low level signal from Refueling Water Storage Tank (RWSD level switches 30SS*LS56A and 3QSS*LS$6B, respectively. This is inconsistent with Design Basis Summary Document (DBSD) 3DBS-NSS-002, Revision 0, Sections 3.1.7 and 12.2.7.3. According to the DBSD, valves 30SS*MOV34A and 30SS*MOV340 close on a RWST empty level signal. Also, the P&lD is inconsistent within itself. First, a signal from both RWST level switches 30SS*L56A and 30SS*L56C is shown going to valve 3QSS*MOV34A at coordinate N1, Second, a signal from both RWST level switches 3QSS*L56B and 30SS*L56D is shown going to valve 30SS*MOV34B at coordinate N4. However aststated above, the signals to valves 30SS*MOV34A and 30SS*MOV34B are shown at coordinates JS & J7 only from switches 30SS*LS56A and 30SS*LS568, respectively, item 2 FSAR Section 6.3.5.1 requires the Refueling Water Storage Tank temperature to be recorded in the control room. P&lD EM-115A does not show this recorder. Review Valid invalid Needed Date inMietor: Fempoid. D. J G O O '2/247 VT Leed: Nort. Anthony A y Q Q 12597 VT Mgr: schopfer. Don K Q Q Q 12/1147 IRC Chmn: singh, Anand K G O O 52ris97 Date: INVAUD: Date: RESOLUTION: Previously ident6Aed by NU7 Q Yes

i Na Non D4ecrepent Cort #6on?Q vos @ No Resolution Pending70 voo + No ResolutionUnresolved?O vos @ No Review Acceptable Not Acceptable Needed Date inhe: F 0,1 Printed 12/17471.54 25 PM Page 1 of 2

i 1 Northeast Uulbs ICAVP DR No. DR MP3-0144 f Milestone unn 3 Discrepancy Report O O O YT Lead: Nort, Anthony A O O O VT Mgr; Schopfat, Don K 1RC Chmn: Singh, Anand K O O Date: SL Correnants: e 4 i- ) i i I-i i !~ i PrWed 12/17/971.54 32 PM Page 2 of 2

Northeast Utilmes ICAVP DR No. DR MP3 0227 Milletone unk 3 Discrepancy Report Review Ofoup: Configurete DR VALID IW IMIN Potent 6el Operetselsty 86eue Diecipi.ne: a e Do 8" O vee D6ecropency Type: Insteilston implementaten 4g systen#rocess: GWP Wic siermcance level: 4 Date faxed to NU: Date Putd6ehed: D*ctePeacy: Instrument Sealing Deecrepuon: The sealing of instruments to preclude moisture intrusion or the introduction of foreign matertal/ contaminates into the device thereby rendering it inoperable is provided by specification and vendor instrument manuals. The following inconsistencies between the installed conditions and the requirements of the referenced documents were noted during the system walkdowns

1. l&C Technical Bulletin #102,

Subject:

"Use of Teflon Tsoe (Corrective Action for ACR M3-96 0067T and Specification SP.

EE 212, ' Instrumentation Installation, Piping and Tubing

set forth requirements for use of thread sealant. SP ME 570, *Fleid Fabrication and Erection of Piping and Supports
Sections 18.1.4 and 18.1.4.1 also contain requirements. These documents lixlicate that Teflon tape should not be used.

Contrary to this requirement, the following instruments have Teflon tape applied to their threads: 3SWP FIS41 A 3SWP Pl46A 3SWP Pl23D 3SWP Pl45A 3SWP Pl23B 3SWP,Pl46C 3SWP Pl23A 3SWP Pl458 3SWP Pl23C 3SWP Pl45B 3SWP PDl164B 1he following material conditions were observed during the walkdown, These items are not configuration management related issises.

1. Pressure switch 3SWP'PS278 shows signs of galling of a housing plug. The electrical pipe plug used to seal an used port is excessively corroded to the point that leakage may occur,

2. Pressure Transmitter 3RSS-PT430 service cap is very loose. The O ring seal appears to be the wrong size or broken -

a large gap between the service case cover and the fixed case housing exists which creates an inleakage potential.

3. Drawing BK 16P 05 Rev 13 Sheet 1 of i shows proper instrument installation for 3RSS PT24. This instrument is not securely mounted and not sealed.

Veild invol6d Needed Date ledt6etor: Serwr, T. L Q Q Q 12/1/97 VT Lead: Neri, Anthony A O O O 125S7 VT Mer: schopfer. Don K Q O O $2'ii/S7 IRC Chmn: singh, Anend K O O O '2/ SS7 Preiled 12/17471:5513 PM Pope 1 of 2

Norttmast Utilities ICAVP DR No. DR MP34279 Milletone unit 3 Discrepancy Report Review oroup: System DRVAUo Review Elemorst: srelem Doogn i ,g gy 06ecip66tw: Elsetnce Doogn O Yes Diecrepency Type: Cebulehan 4 g, syetamerocese: N'A NRc sleemcence leve 4 Date faked to NU: Date Pundished: D6ecrepencF! Calculation NL 028 Deecription: Calculation NL.028 was prepared to determine the minimum length of a 4160 volt cable required to reduce the short circuit current to the short circuit rating of the 4160 voit switchgear. It is based on Calculation 12179179E, which indicates that the available short circuit at some of the 4160 t 1 switchgear exceeds the rating of the switchgear. However, calculation 12179179E has been superseded by Calculation NL 051. Calculation NL 951 indicates that the available short circuit current at all dit 0 voit buses is less than the switchgear rating 8. (However, see DR MP3-0318 for comments on the short circuit calculations in NL 051.) Therefore, it is no longer necessary to calculate a minimum cable length to Ilmit the short circuit current. Calculation NL 028 should be volded, if Calculation NL 028 were still valid there would be two discrepancies. The impedan. ;, of the Thevinin equivalent of the system supplying the switchgear and the impedance of the feeder cable were added arithmetically. They must be added vectorially. Because the equivalent system impedance is mostly reactive and the cable impedance is mostly resistive, the two impedances add at nearly right angles to each other. Adding these two values arithmetically makes the cable more effective in limiting the short circuit current than it actually is. Therefore, the required cable length is longer than that determined by the calculation. Also, there is an arithmetic error in Equation 2 on Page 5 of the calculation. Review Valid involid Needed Date inatiator: Bloathe.O William O O O i2/as7 VT Lead: Noti. Anthony A Q Q Q 12Mh97 VT Mget schopfer. Don K Q Q Q 12/11/97 1RC Chmn: smgh. Anand K O O O '2'1557 Date: INVAUD: Date: RESOLUTION: '* previously identifled by NU? Q Yee iGI No Non D6ecropont Condition?O Yes it) No Reco6ution Ponding70 Yes M No ResolutionUnresolvedtO Yes @ No Review initiator: Boosthe G. William

- - E
O O

O VT Lead: Nort, Anthony A l Prtiled 12/17/971:56 o2 PM Paes 1 of 2 l

Northeast Utilkies ICAVP DM No. DR MP34279 Millstone Unit 3 Discrepancy Report v i s. i.---7n vrun w.oonx e 0 O 1RC Chmn: Singh, Anand K O O O o.: SL Commerds: 4 i i l ~M i2/17.97 iMOS PM Page 2 of 2 P l - ---i

~ Northeast Utilities ICAVP DR No DR MP3 0692 um tone unit 3 Discrepancy Report Revtow Oroup: system DR VALID Review Element: Syelem De6e PMentW Opmy lseue Diecipime: Moctemcal De** O ve. 06ecrepency Type: Calculaton % No systemProcess: Rss '~ NRC sigrwacarwe level: 3 Date faxed to NU: Date Published: D6ecreparwr: Design Requirement for Recirculation Spray after Main Steam Line Break D**cripeion: There are several design basis and design documents that state RSS is requitud to function aftet a postulated MSLB:

1. FSAR Sec. 6.2.2 states that the QSS and RSS ' containment heat removal systems are designed to reduce containment prr ssure following a break in either the primary or secondary piping system inside containment."(System 'toquirement REQ.

MP3 RSS 0804)

2. The containment pressurization analysis, Calculation US(B).

266, Rev. 2 assumes RSS operates after an MSLB.

3. The results of Calculation US(B) 266, which indicate that RSS operates after an MSLB, are provided in FSAR Tables 6.2 24 and 6.2 25. (System Requirements REQ MP3-RSS-078 and 0759) 4

4. Specification 2280.000 968, Rev.10, Sec.13.45 states that the RSS spray nozzles are designed to operate after a LOCA or an MSLB.

The requirement that RSS operate after an MSLB is contradicted by the following containment sump design and operations documents:

1. ES 234, Rev. O concludes that there is an insufficient sump water supply for RSS operation after an MSLB.

2. US(B) 278, Rev. O concludes that there is an insufficient sump water supply for RSS operation after an MSLB.

3. EOPs require the RSS be secured if RWST volume is greater than $20,000 gal and containment pressure drops below 17.5 psig. This condition will occur after MSLB. The results of US(B).

266 Indicate that during the design basis MSLB at 75% power, contalnment pressure will drop below 17.5 psig at approximately 800 to 900 seconds into the event. This is within three minutes of the RSS effective time. Review Valid invalW Needed Date initiator: Wakeland J F. O O O 12SS7 VT Lect Nort, Anthony A Q Q Q 12497 VT Mgr; schopfer, Don K Q Q Q 12/11/97 IRC Chmn: singh, Anand K Q Q Q 12/1697 Printed 12/17/971.56 53 PM Pope 1 of 2

t Northeast Utilities ICAVP DR No. DR MP34892 Mmstone unit 3 Discrepancy Report Date: WWAUD: Date: nESOLUTION: Previously identmed by NUP Q Yes t#1 No Non Discrepent condsthm?Q Yes @ No Reeo6ution Poneng?O vos <!) No noe.iunion unre ev.d70 vos ci)No 1 neview Acceptebio Not Acceptsale Needed Date VT Leed: Nort. Anthony A VT Mert Schopfw Don K IRC Chmn! Segh, Anand K g Dele: SL Commente: 4 4 PrWes 17/17/971:57.00 PM Page 2 of 2 ~..

Northeast UtilRies ICAVP DR No. DR-MP34664 Millstone UnN 3 Discrepancy Report Rev6ew Group: system DR VALID Potentiel Operability issue O vee Onecropency Type: Compone'd Deu @ No systemProceae: QSs NRC s6pn4Acance 6evel: 3 Date FAKod to NU: Date Putd6ehed: D'*cros*-i: Inconsistency between FSAR Sec 6,1,1.1 & design specs w/ respect exclusion of low melting alloys, D*ecr$P'60n: FSAR Section 6.1.1.1 states that low melting alloys (zinc, lead, mercury, etc.) that can cause stress corrosion cracking when in contact with stainless steelis prohibited during fabrication of stainless steel parts. A review of component design specifications show that the desi')n of the following components does not address the exclusion of low melting alloys during fabrication of stainless steel parts: 30SS'P3A,B 3OSS*TK1 3OSS'MOV34A,8 30SS V44 3OSS*V945, V946 3OSS*V1, V2, VS, V6 3RSS'PI A,B,C,D 3RSS P2A,B 3RSS*MOV20A.B.C.D 4 3RSS*MOV23A,B,C,0 3RSS*V38 V45 3RSS*V50 V53

References:

Specification 2214.602 040 Revision 6 Specification 2362.200 ib4 Revision 1 Specification 2275.001023 Revision 3 Specification 2214.802 044 Revision 1 Specification 2214.202 050 Revision 7 Review Valid invalid Needed Date lehtor: Foingold. D. J-B D O 12/1/87 VT Leed: Nort, Anthony A g Q Q 12597 VT Mgt: Schopfer, Don K G O O 12/11/87 IRC Chmn: Singh, Anand K Q Q Q 12/1697 Date: INVAllD: Date: REsOLUT)0N: Provlouo!y identined by NU7 Q vos @ No Non Discrepent Condet6on70 vee to) No Resolut60n Pend 6ng70 vee @ No Resolubon UnteeolvedtO vos @ No Review Acceptable Not Acceptable Needed Deu ._ mi m _, ,a Prtiled 12/17/971:573 PM Page 1 of 2

_.. _ _ _ ~. Northeast Utilities ICAVP DR No. DRMP3 0654 Mill

ton
UnN 3 Discrepancy Report vu

. ;AMW A O O O D g O vi u,n w.r. oon x MC Chmm $rgh, Anand K m SL Comnents: e l O PrWed 12/1M71.51.,;? PM Page 2of 2 ) i

l Northeast Utilities ICAVP DR No. DR MP34663 M6:1 tone unk 3 Discrepancy Report Revtew Oroup: syetem DR VALID I* Potent 6el operabii#y issue 06ecipl6ne: Electncel Design Om D6ecrepancy Type: Lkensq Document 4~) No SystemProcess: HVX NRC signeconce level: 3 pese Faxed to NU: Date Pubnehed. Deecrepency: Operation of EDG Enclosure Supply Fdn 8 does not match description in 3DBS-EDG 001 D**cription:

Background:

Paragraph 8.5.1 of the Design Basis Summary Document (DBSD) 3DBS EDG 001, dated 5/28/97 states: The supply fans for the EDG enclosure shall automatically start when the EDG comes up to speed and enclosure temperature is above the set temperature... Discussion: Diesel Generator 'A' Enclosure Ventilation Supply Fan [3HVP'FN1 A] operates as defined in the DBSD. Supply Fan B [3HVP*FNI A) operates in a similar mode whenever the

Remote-Isolate
control switch located on the Fire Transfer Shutdown Panel (FTSP) is in the
Remote' position. Note: Supply Fan A has no similar
Remote Isolete" control switch, if the
Remote Isolate' switch is in the ' Isolate' position, the fan will not respond to enclosure temperature.

== Conclusion:== The DBSD description of Supply Fan 8 operation is not complete. This was verified by a review of the following drawings: ESK 6ABG Rev 10 Elem Diag 480V MC Diesel Generator A Enclosure Ventilation 6. pply Fan [3HVP'FN1 A] ESK-8ABH Rev 08 Elem Diag 480V MC Diesel Generator B Enclosure Ventilation Supply Fan [3HVP*FN18) ESK 08KD Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSA03 [3EUS*G A) ESK 08KG Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSB03 [3EGS*G B) ESK 3AB Rev 03 Control Switch Contact Diagram ESK 3C Rev 11 Control Switch Contact Diagram Rev6ew Valid invalid Needed Date inniseor: womw,1-G O O $ 2'4" Printed 12/17/971,5e 22 PM Page 1 of 2'

Northeast Utiliths ICAVP DR No. DR MP3 0443 Millstone UnN 3 Discrepancy Report VT Lead: Nort, Arthony A g 12597 VT Mgt: SctWer, Don K Q Q 12/11/97 O O 12/1697 IRC Chmn: Sangh. Anand K Dese: 18NAUO: Date: RESOLUTION: Prov6ously iderstWied by NU7 U Yes 'e) No Non D6ecrepard Cond6tlon?(,) Yes @ No Reco6ution Pend 6ng70 Yes @ No Pu%Unreootved70 vos @ No Review Acce @ Nd AcceplaWe Needed Date gg; g VT Lead: Nort, Anthony A O h b VT Mgr: Schopfer, Don K 1RC Chmn: Sinph, Anerul K = - e: SL Conenents: 1 i l Printed 12/17/971:58.32 PM PeGe 2 of 2 ) I n .,,-----~,,w, ,, -, - -. - - +

Northeast Utilities ICAVP DR No. DR MP3 0482 Millstone Unit 3 Discrepancy Report Review Group: syteem DR VALlo Potential Operetaility leeue 06ec6peine: Me:hencal Desgn Om D6ec.repency Type: conculaten @' No system 9'rocess: N/A NRC sien4Acance level: 3 Date faxed to NO: Date Pub 66thed: 06ecropeacy: Calculation US(B) 349 D**criphon: The purpose of Calculation US(B) 349, Rev. O is to conservatively quantify the containment mixing rate between the sprayed and unsprayed regions as a function of time during the time when the quench spray operates following a LOCA. The mixing rate will be used in accident dose calculations. Three discrepancies were identified in Calculation US(B) 349.

1. The is no valid basis for the sprayed volume within the containment of 902,000 ft3. This volume is taken from Reference 2 (Calculation US(B) 280, Rev.0). However, CCN 1 for US(B) 280 volds Calculation US(B) 280. Additionally, Reference 3 (Calculation US(B) 341, Rev.1) page 11 (not page

20) uses the value of 902,000 ft3 to determine a total sprayed volume of 1,166,200 ft3 (page 15 of US(B) 349). Therefore, cannot verify the spray volume of 1,166,200 ft3, due to the quench spray, used in calculation US(B) 349,

2. The maximum flow rates identified on page 19 for quench sprays (6400 gpm) and LHSl(9700.2 gpm) are not consistent with Calculation US(B) 295, Rev. 5, CCN 1. Calculation US(B).

295 identifies the runout flow rate for two OSS pumps as 6500 gpm and the runout flow rate for 2 RHR pumps as 10,200 gpm (CCN 1, page 5). The higher flows would be more conservative than the flow rates used in the calculation since the earilest time for quench spray to stop would be less than the time calculated on page 20 of US(B) 349.

3. The time of 2330.6 seconds (39 minutes) (page 20) for the earliest time the LHSI could stop drawing from the RWST is not consistent with US(B) 295, Rev. 5, CCN 1. The minimum time to drain the RWST is 33 minutes (US(B) 295). This time difference affects the time calculated on page 20 of US(B) 349 for when quench spray would stop. Quench spray would stop earlier than calculated in US(B)-349.

A revision to Calculation US(B) 349 to evaluate the above discrepancies should be performed. Review Val 6d inval6d Needed Date Initiator: Wakeland J. F. Q Q Q 12/897 VT Leed: Neri, Anthony ^ G O O i:SS7 VT Mgr: Schopfer, Don K Q Q Q 12/11/97 4RC Chnm: Singh. Anand K Q Q Q 12/1697 Date: Prtrend 12/17,971:5a o8 Pb Pope 1 of 2 l

Northeast Utiinies ICAVP DR No. DR MP34482 Milletone UnN 3 Discrepancy Report j m auv. l Date: RESOLUTION: Previovely identined by NU7 U Yes 98 No Non Discrepent Cornist6on?U Yes @ No ResolutionPending?O Yes ib) No ReconullonUrwoeofvodtO ve. @ No Rev6ew Acceptable Not Me?d '- Needed Date l VT Leed: Nort Antrey A 0 0 O vi u n swe.oon x e l me chmn: se. Anona x SL Connords: 4 e e i Prmeed 12/17/971.5014 PM Page 2 of 2 l

~__ Northeast Utilities ICAVP DR No. DR44P34644 Millstone Unit 3 Discrepancy Report Review Ofoup: synnem DR VAUD Rev6ew Elemorst: sretem Deegn p g Diecipline: Electneal Desgn O va D6ecropency Type: Calculeuon i No systemProcess: DGX NRC sngnmcance level: 3 Dale faxed to NU: Date Putd6ehed: Descrepancy: Setting of 4160 voit Protective Relays for Safety Related Unit ' Substations (Calculation 413CA) Deecrtption: Calculation 413CA determines the settings of the protective relays for the safety related unit substations. The setting of the 480 Volt tie breaker is different from that shown in Calculation 818CA. If the settings in Calculation 818CA apply, then there is probably a lack of coordination between the 4 kV breaker and the tie breaker. This w.'ii reduce the reliability of the supply to safety related loads since a fault that should be cleared by the bus tie breaker will result in the loss of the entire unit substation. The time cunent curve indicates that the unit substation transformers have a short circuit capability of 4.5 seconds, while ANSI C5712.01 requires a short circuit capability of only 2 seconds. The reason for this difference should be documented by an appropriate reference, such as manufacturer's data. -4 Review Valid invalid Needed Date initletor: Bloethe, G. Wilhem O O O i:/'87 VT Lead: Nwt, Anthony A O Q Q 12597 VT Mgr: schopfer, Don K O O O 12/11/97 IRC Chmn: Segh, Anand K Q Q Q 12/1697 Dei.: INVALID: Dele: RESOLUTION: Previously identifled by NU7 O Yes e) No Non Discrepant Condition?Q vos @ No Resolution Pending?O vee @ No Resoiuison unresolved?O vee @ No Review Acceptable Not Acceptable Needed Date VT Leed: Nort, Anthony A VT Mer: Schopfer, Don K 1RC Chmn: Singh. Anend A - e. SL Cormwnts: Prtnied 12/17/971.59 So PM Pope 1 of 1

Northeast Utilities ICAVP DR No. DR MP3 0448 Mill

tone UnN 3 Discrepancy Report Rev6ew Oroup: splom DRVAUD Potential Operetditty leeue D6ecip66ne: Moctancal Desg" Om D6ecropency type: Conculation 4g syslerWProcess: DOX NRc sigtwncence level: 3 p.g, pgg,q go yg Dele Putiliehed:

D'*cropency: Discrepancies in Calculation 3 92102 263 M3/Rev. O, CCN 1 De* crepe 6on: Review of the calculation ' Emergency Diesel Starting Air System Design Pressure and Temperature *, calc. no. 3-92102 263-M3, Rev 0. Calculation Change Notice no.1 resulted in the following discrepancies:

1. This calculation is classified 'Non-QA" on the Calculation Change Notice No.1, page 1, box 7, and "non QA* and seismic qualincation basis *N/A' on page 1 of the calculation. However, among components included in th: scope of the calculation are Air Receiver Tank 3EGA*TK1 A,18,2A.28 (classified QA Cat.1 component) and safety related piping (lipes with line sequential numbers 1,3,5,11,13,15).

2. The model used to calculate air temperature at the air compressor discharge (page 9 of the calculation) yields temperatures below those provided by the Emergency Diesel Generator supplier via the Colt industries letter " Contract 206072 Millstone 3 Quincy Air Compressor *, dated April 5,1983, and attached to calculation P(T) 1042, Rev. (blank) as Attachment

2. The Colt industries letter states that if the compressor tums 900 rpm, the air discharge temperature at 450 psi will be approximately 585 degrees F, and at 425 psi approximately 575 degrees F. (This information was used in calculation P(T) 1042 to define operating temperatures at limiting compressor discharge pressures.) The model used in this calculation yields air temperature of 570 degrees F at 450 psig and $64.5 degrees F at 500 psig. In comparison to the ven: tor provided data, the temperature calculated in this calculation appears non consesvative.

3. The calculation states that the aftercooler design pressure is 500 psig per 'Aftercooler Heat Exchanger Spec. Sheet",

Appendix E, Specification 12179 2520.300 730, Add.1, dated 3/21/85. The Aftercooler Heat Exchanger Spec Sheet could not be found in the referenced purchase specification. Hewever, the purchase specification, Attachmen* 2 does specify the air cooled aftercooler process side design pressure at 450 psig.

4. Calculation states that *The whole EGA system is using pipe Class 301, Spec SP ME 572... Class 301 piping is suitable for 555 psig up to 600 degrees F temperature.

Conclusion:

Piping is OK for 500 psig." The P&lD's EM 1168 25 and EM 116D 5 show a class change within the dryer package between the l aftercooler (CL 602), condensate separator (CL 151), prefilters (CL 602), and the dryer (CL 151). Per Spec. SP ME 572 piping Class 151 is good for 275 psig at 100 degrees F, and 150 psig at "J d0;;'oes F, c " bc!= the 90 !!On k'cfSd !?rM W 2 p, ggggog l

Northeast Utilities ICAVP DR No. DR-MP3 0488 Millstone Unit 3 Discrepancy Report pressure and the design pressure. Review Val 6d invalid Needed Dele inniator: Otewl.Bojen. O O O i t.21/97 VT Lead: Nort, Anthony A g Q [ 11/249/ VT Mgr: Schopfer, Don K O O O 52 tiro 7 1RC Chmn: $Wgh, Anend K O O O 12/iss7 Date: INVAllD: Date: RESOLUTION Previously identifled by NU7 Q Yes '9) No Non Descrepent CondAion?Q vos (G) No Resolut6an Pending70 vos # No Resolution Unresolved?O vos (!)No Review Acceptable Not Acceptable Needed Date g,g,g VT Leed: Nort, Antreg A VT Mgr: Schopfer, Doi K 1RC Chmn: Singh, Anono K SL Comments: 4 4 Printed 12/17/97 2m34 PM Pope 2 of 2

Northeast Util,' ties ICAVP DR No. DR MP3 0690 Millstone Unit 3 Discrepancy Report Rt ow Group: system DR VAUD Rev6ew Element: system Desen Potential Operability issue D's-ip46ne: Electncal Deegn Q yeo Diecrepancy Type: Celculaton @) No systerWProcess: DGX NRC Signiacence level: 3 Date faxed to NU: Date Published: D6ecrepancy: 480 Volt Load Study (Calculation WL-025)

== Description:== Calculation NL-025 documents the running loads on e volt unit substations and motor control centers under steady +tu 'ull load conditions, ensuring that none of the Safety Rb' ec.a Non-Safety Related low voltage buses are overloaded. Tk, information is used as input data to other calculations, such as NL-038, which calculates the voltages in the electrical auxiliary system. Attachment i develops demand factors, which are really multiptiors to be applied to rated horsepower to obtain the running brake power for *>at,h connected ioad. The development of these demand factors is described in detall, but the values of the demand factors are not wbstantiated in a verifiable wa/ with numerical data. The statemc.it is made that the brake power for pumps & fans (all sizes) is always less than the moinr rated horsepower. The issue of service factors is not addressed. The development presented would only be strictly correct if all motors were 1.0 service factor. However, some types of motors are normally provided with a service factor of 1.15. No effort was made to detemkine what additional loads at the motor control centers may be running under accident conditions. An assumption on page 4 states that the ' loads are based on normal operating conciti, ns'. Since there are many systems that are provided strictly to mitigate the effects of an accident, the applicability of the calculated demand factors during accident conditions shoLid be verified. Since the diversity factrws are used as input data to the voltage drop calculations in CalcuiJon NL-038, this issue is vital to assessing the adequacy of the auxiliary system design. lists diversity factors for various types of loads. The development of the diversity factors for motor control centers is explained. However, no explanation is given for the diversity factors for any other type of load. On page 2 of Attachtrat 9, it is stated that the initialload measurements (December 29,1992 for Train A) were taken at 60% plant loading, and additional data (January 5,1993 for Train B, and May 13,1993 and May 14,1993 for Train A arvi Train B) ~ were taken at 100% plant loading. However, no statement is made nor reference given as to how the plant loading on these dates was determined. Some of the motor contrt4 centers had power factors over 90%, but it is stated that 85% is used for all of the motor control Nok Printed 12/17N7 2:01:07 PM 2

Northeast Utilities ICAVP DR No. DR MP3-0490 Milistone unit 3 Discrepancy Report to the motor control centers. Page 4 states that 'The MOC power factor is assumed to be 0.85...' This is not used in this calculation. The power factors of the motor control centers do not have a role in this calculation. All kVA's of the loads and motor control centers are added using magnitude only (not vectors), regardless of the stated power factors. Page 4 of the calculatior) states that the, ' transformer loading is based upon output rating, ignoring losses, since transformers are typically 96-99% efficient.' Apparently this applies only to 480-120/208V transformers, because the 4160-480 volt transformers do not appear here. This should be clarified. Page 8 of the calculation gives the maximum permissible loading of the unit substations. However, no reference is given for venfying this information. Based on the above discussion, a vertflable design basis for the demand and diversity factors for the 480 volt portion of the electrical auxiliary system has not been provided. Since these factors are used to calculate the loading of the 480 volt buses of the auxiliary system, the loading of this portion of the electrical auxiliary system cannot be verified This affects other calculations, such as NL-038. Review Valid inval6d Needed Date initiator: Bloettu, G. Wilisem O4 O O $2 tis 7 VT Lead: Nett, Anthony A O O O ':SS7 VT Mgr: Schopfer, con K O O O 2ritm7 IRC Chmn: sngh, Anand K O O O $2 ties Date: INVAtlO: Date: RESOLUTION: Previously identlAed by NU? O vee (G) No Non Diecrepent Condation?O vos @ No ReeolutionPend4ng70 vos @ No R.aoivison unreeoiv.d?O vos @ No Review Acceptable Not Acceptable Needed Date MMietora M VT Lead: Nett, Anthony A b VT Mgr: schopfer, Don K 1RC Chmn: singh. Anand K - e. SL Comments: l Printed $ 2/1747 2:01:14 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0491 Millstone Unit 3 Discrepancy Report R.v6ew oraup: syvem DR vAuo Reh Eiernene syween % E" - : Electncel Desgn O v. Diacropency Type: Cak:uishon @ No SystemWocess: RSs NRc SignHicence level: 3 Date faxed to NU: Dete Putdished. Descrepancy: Setting of Containment Recirculation Pump Motor Protective Relays (Calculation 409CA) Deecrist6on: Calculation 409CA selects the settings of the containment recirculation pump motor (3RSS*P1 A,3RSS*P18,3RSS*P10, and 3RSS*P10) protective relays. The Millstone 3 FSAR, Section 8.3.1.1.4 (Desi n Criteria), item 6a states that the Class 0 1E motors should be able to start at 70% of r9ted voltage unless specific justification is provided. However, Calculation 409CA demonstrates coordination between the motor starting cunent as a function of time and the relay characteristic at 100% and 80% v'oltage only. Therefoie, the calculation does not demonstrate that the motor could start at 70% voltage without being tripped off by the protective relays. It is necessary to demonstrate proper relay coordination at 70% voltage to ensure that the containment recirculation pump motors can start under all conditions under which they would be required to operate. A Review Valid invalid Needed Date initiator: Bioethe, G. Will6am Q Q O 12/497 VT Lead: Neri, Anthony., Q Q Q 12/5/97 VT Mgt: Schopfer, Don K Q O O 12/11/97 IRC Chmn: Singh, Anand K Q Q Q 12/1697 Date: INVALIO: Date: RESOLUTION, Previously identifled by Nu? O Yes (ei No Non Discrepent CondiUon?O vos (e.) No Resolution Pending?O vos @ No R oiuiion unreeoiv.d70 ves @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A b VT Mgt: Schopter, Don K IRC Chmn: singh, Anand K Date: SL Corronente: Pftnted 12/1747 2:o1$4 PM PeGe 1 of 1

Northeast Utilities ICAVP DR No. DR-MP3 0702 Millstone unR 3 Olscrepancy Report Rev6ew Group: system DR VALID Rev6ew Element: system Dwon p g Diecipline: Mechenecal Dwgn O Ya D6ecropency Type: Drewmo @ No Systemerocess: HVX ~ NRC Sigenconce levet: 4 Date faxed to NU: Date Published: Discrepancy: HVAC P&lD Discrepancies Deecription: During review of the auxiliary building Ventilation system. supplementary leak collection and release system, and emergency generator enclosure ventilation system the following discrepancies on the piping & Instrumentation diagrams were identified.

1. The fail position vent direction for the following solenoid valves is show inccrrectly on EM-148A:

3HVR*SOV44B 3HVR*SOV4481 3HVR*SOV44A 3HVR*SOV44A1 3HVR*SOV428

2. The fall position of 3HVR*AOD428,3HVR AOD438 are not shown on EM-148A.

a

3. Drain lines for MCC and Rod Control Area air conditioning units,3HVR*ACU1 A/B are not shown on EM-148A

4. P&lD EM-150C does not show the class break between the non-safeiy related normal exhaust duct and safety related tomado dampers 3HVP DMPT2A-D.

5. P&lD EM 148E does not show the variable inlet Vane dampers for SLCRS exhaust fans 3HVR*FN12A/B.

Review Valid invalid Needed Date initiator: stout, M. D. O O O 2/is/97 VT Lead: Nort, Anthony A Q Q Q 12/11/97 VT Mgt; schopfer, Don K Q Q O 12/11/97 IRC C.wnn: singh, Anand K G O O 12/15S7 Date: INVAUD: Date: RESOLUTION: ~ Prev 6ously identitled by NU7 Q Yee @ No Non D6screpent CondMion?U Yes @ No Resolut6on Pending70 Yes @ No R.coivison unr..osv.d70 Yee @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri. Arthony A Printed 12/17/97 2M21 PM Page 1 of 2

, = _ ..~ Northeast Utilities ICAVP DR No. DR MP3 0702 Minstone unit 3 Discrepancy Report O O VT Mgri SctWw, Don K C b RC Chmn: S&gh, Anand K O D G om.: sL Conenents: 'd e o ~

~ ! t Northeast Utilities ICAVP DR No, DR MP3 0704 Millstone Unit 3 Discrepancy Report Review Group: system DR VALID Potentist Operetniary leaue Diecip66ne: Mechancel Design O ve. Diecropency Type: Component Data fe) No SysterWProcess: OSS NRc signancence leveh 3 Date faxed to NU: Date Published: 06ecrepency: RWST Levels Used to Determine NPSHa for ECCS Pumps. De*cription: There are three calculations which determine if RWST provides sufficient NPSH to ECCS pumps in the RHS, SlH, and CHS systems: P(R) 0982, Rev. O, P(R)-0983, Rev. O, and US(B)-294, Rev.4. The RWST levels used in these three calcualations to determine NPSHa for the ECCS pumps contain inconsistancies. They do not agree with each other, they do not correspond with the o,pertion of the RWST, and they do correctly incorporate level setpoint uncertainties. The inconsistencies between the RWST levels used in the NPSHa calculations are as follows: P(R)-0982 P(R)-0983 US(B)-294 RHR 37.9 ft - 25' 5" 19'2" SlH 37.9 ft 4' 5" 19'2" CHS 37.9 ft 4%5" 19'2" Since the RHR pumps trip on low low RWST level, the worst-case RWST level for RHR is the low low level setpoint minus the setpoint unced=%ty (RWST level after two minutes of drawdown in the event of a failure of the auto-trip function of one RHS pump is assumed to occur in US(B) 295, but the RWST does not need to be designed to provide adequate NPSH for this scenario). According to Calculation 3451801-1232, the low low level setpoint is 25' 5" and the uncertainty in the setpoint is 28.28". Therefore the minimum RWST level at which the RHR pump is required to operate is 23' 1"(see item 3 of DR MP3-0373). This level is not used for any of the NPSH calculations. Therefore the RWST levels used to determine RHR pump NPSHa are not conservative in P(R)-0982 and P(R)-0983. The design basis for mareal ECCS suction switchover is that it would be completed ten minutes after operators receive the RWST low low level alarm. According to FSAR Sec. 6.3.2.2.3 and FSAR Fig. 6.3-6, the minimum level at which SlH and CHS pumps are required to take suction from the RWST is 19'-2", Discrepancy Report DR-MP3-0266 identifies an error in this reported minimum level. Using the inputs of Calculation US(B)- 295, Rev. 5, "RWSY Draw Down Rates and Switch Over Levels," DR-MP3-0266 concludes that the minimum lewl should be 18.90 ft. If the Correct value of 28.28"is used forthe uncertainty in the low low level setpoint, the minimum level at which ECCS pumps are required to take suction from the RWST is 18.54 ft. This level is not used in any of the NPSHa calculations. Pnnted 12/17S7 2.06AG PM 1 of 2

Northeest Utilities ICAVP DR No. DR MP3 0704 Millstone Unit 3 Disc.<pancy Report pump NPSHa are not conservative in P(R)-0982 and US(B) 294. Review Valid invalid Needed Date initiator: Wakeiend. J. F. O O O 12/5S7 VT Lead: Nwt, Anthony A B D 0 12 fits 7 VT Mgr: Schopfer, Don K g Q 12/11/97 1RC Chmn: Swe, Anand K O O O 12 fin 7 Date: IWAUD: Date: RESOLUTION. Previously identmed by NU7 U Yes (G) No Non Discrepent Cond6 tion?O Yes @ No Resolution Pending70 ves @ No Resolution Unresolved 70 Yee @ No Review Acceptable Not Acceptable Needed Date ,g,,, ?TLeed: Nort, Anthony A VT Mer: Schopfer. Don K IRC Chmn: Sangh. Anand K Date: st Commente: 4 I Prtnted 12f17t97 2.06:56 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3 0711 Millstone unit 3 Discrepancy Report Review Oroup: System DR VAUD N"" Potential OperatWity leeue Diecipline: Mecherucal Deegn O vu Descrepency Type: Liceneme Document @~ No SystemProcese: OSS NRC Significence level: 3 Date faxed to NU: Date Putdehed: D6screpency: Minimum OSS Initiation Time in FSAR Table 6.2-60 Ducription: FSAR Table 6.2 60 states that the minimum QSS effective time is: For a LOP /LOCA and Max ESF: 48 seconds For a LOCA with offsite power available and Max. ESF: 33 seconds This is inconsistent with the Calculation US(B)-225, Rev. 6, " Quench Spray Header Fill Time." US(B)-225 concludes that the minimum OSS effective time from receipt of a CDA signalis: For a LOP /LOCA and Max ESF: 37.3 seconds For a LOCA with offsite power avaltable and Max ESF: 26.3 seconds Review Valid invalid Needrd Date inetnetor: Waketend. J. F. O O O i2/as7 VT Lead: Nwt. Anthony A Q Q Q 12/11/97 VT Mgt: schopter, Don K 8 O O 12/ii/97 1RC Chmn: Singh, Anand K G" O O 12/iss7 Date: DNAUD: e-Date: RESOLUTION Prev 6ously identined by NU7 O Yee @ No Non Discrepent Cor@ tion?O Yee @ No Resolution Pendmg?O vos @ No ResolutionUnresolved?O yes @ No Review Acceptable Not Acceptable Needed Date Mietw* M VT Lead: Nett Anthony A VT Mgt: Schopfer. Don K IRC Chrrm: Smgh, Anand K Date: SL Comments: Printed 12/17<97 2:07.39 PM Page 1 of 1

i Northeast Utilities ICAVP DR No. DR-MP3-0717 Millstone Unit 3 Discrepancy Report neytow Group: Piev eiiw.ec DR VAUD Rev6ew Element: Change Process Potential Operatdiety issue Diecipline: I & C Design O Yes Discrepancy Type: Procedure implementation @ No l System / Process: sWP j NRC Significance level: 4 Date faxed to NU: Date Putdished: Descrepancy: Setpoint changes without implementing documents. ] Ducription: Setpoint change calculation SP 3SWP 29, Rev. O, CCN 1 references E&DCR N-ME 02985 as the parent document, but E&DCR N-ME-02985 is stamped superseded by DCN DM3-S-1009-95. Setpoint changes cannot be implemented through the DCN process. Setpoint changes are implemented via Setpoint Change Records or Plant Design Change Records which are classfied as modifications (parent document); however, no implementing docurr.entation (e.g. SCR, PDCR, DCR) was provided when requested from NU. Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisions (ops, annunciator, surveillance) are referenced or were provided when requested. Setpoint change calculation SP-3SWP 25 Rev.1, CCN 1 references calculation 95-ENG-1177 M3, Rev. O as the parent document. Setpoint changa are implemented via Setpoint Change Records or Plant Design Change Records which are classfied as modifications;however, no modification is referenced. No implementing documentation (e.g. SCR, PDCR, DCR) was provided when requested from NU. Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisions (ops, annunciator, surveillance) are referenced or were provided when requested. J Setpoint change calculation SP 3SWP-25, Rev.1, revises a i setpoint without a parent document. Setpoint changes are implemented via Setpoint Change Records or Plant Design j Change Records which are classfied as modifications; however, no modification is referenced. No implementing documentation (e.g. SCR, PDCR, DCR) was provided when requested from NU. Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisons (ops, annunciator, surveillance) are referenced or were provided when requested. Review Valid Invalid Needed Date inittetor: Dombrowsal. Jim O O O 12ss7 VT Lead: Ryan, Thomas J Q Q 12597 VT Mgt: schopfer, Don K G O O 52/1 tis 7 IRC Chmn: snah. Anand K Q Q 12/16,97 Date: FdAUD: Date: RESOLUTION: w %,n r 3 v.. .an m w ru.,e me ew%ar 1 v rei m Printed 12/17/97'2:ce:1e PM ' Page 1 of 2

t l l Northeast Utilities ICAVP DR No. DR-MP3 0717 Millstone Unit 3 Discrepancy Report l Resoluuon/ernsing70 ve. @ so Re.oiouon uar. eved70 ve. @ wo Review Acceptabi. Not Acceptable Needed Date VT Lead: Hyen, Thomas J VT Mgr: Schopfer, Don K IRC Chmn: Sqh, Anand K Date: SL Commerds: 4 .c Printed 12/17.97 2.06.25 PM PQ 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0718 Millstone Unit 3 Discrepancy Report Rev6ew Group: Accxtent Mdgaten DR VALJD

I Potential OperebWty issue Diecipline: Mechanecal Deegn Ow Diecrepancy Type: Ucenomg Document

($) No SystemProcess: N/A NRC Signmcence level: 3 Date faxed to NO: Date Published: Descrepancy: Natural Circulation Flow Data Cited in FSAR is Not Used in Accident Analyses. Deecription: The ICAVP reviewed FSAR Sections related to natural circulation subsequent to reactor trip and reactor coolant pump coastdown. The specific sections reviewed were:

1) Loss of Nonemergency AC Power to the Station Auxiliaries (FSAR $15.2.6),

2) Loss of Normal Feedwater Flow (FSAR $15.2.7),

3) Feedwater System Pipe Break (FSAR 615.2.8), and

4) Complete Loss of Forced Reactor Coolant Flow (FSAR

$15.3.2.2). In these sections, Table 15.2 2 is cited as the justification for natural circulation flow that is sufficient to provide adequate core decay heat rer. oval following a reactor trip and reactor coolant pump coaf.aown and therefore, acceptable capability to respond to the accidents. IRF-01099 which responded to RFl 689, provided a Westinghouse letter (NEU-97-305E) which states 'The values preseried in Table 15.2 2 are estimates of the amount of natural circulation flow that is expected under these conditions, however, they are not used in the non-LOCA safety analysis in any way.' Specific sections of the FSAR where credit is taken for natural circulation for non-LOCA analysis are discussed below; a) FSAR $15.2.6.3 for accident 1) above states ' Conclusions - Analysis of the natural circulation capability of the RCS has demonstrated that sufficient heat removal capability exists following reactor coolant pump coastdown to prevent fuel or clad damage.' b) FSAR $15.2.7.2 for accident 2) above states " Method of Arselysis - Assumptions made in the analysis are as follows. 3. For the case with a loss of off-site power, a heat transfer coefficient in the steam generator associated with RCS natural circulation.' c) FSAR $15.2.8.2 for accident 3) above states

Method of Analysis The code describes the plant thermal kinetics, RCS including natural circulation,...* Also this section states

'Following the trip of the reactor coolant pumps, there is a flow coastdown until flow in the loops reaches the natural circulation value.' en FRAR Ri% 't 9 9 far nreiriant di nhnum etatot "The ranMar Printed 12/17/97 2-oe.52 PM Page 1 or 2 -

Northeast Utilities ICAVP DR No. DR MP3 0718 Millstone Unit 3 Discrepancy Report coolant pumps continue to coastdown, and natural circulation flow is eventually established, as demonstrated in Section 15.2.6.* ) NU should compare the Millstone 3 fuel reload analysis of record with FSAR $$ 15.2.6,15.2.7,15.2.8 and 15.3.2 to determine if ) the values in FSAR Table 15.2-2 are used. l Review Valid invalid Noe W Date initletor: Peebnee. W. R. O O O 12/sS7 VT Lead: Rehoja. Raj D 0 0 O $2/as7 VT Mer: Schopfer. Don K B D O $2/it/97 IRC Chmn: Singh. Anand K Q 12/1ss7 Det.: INVALID: Date: RESOLUTION: Previously identifled by NU7 O Yee @ No Non Discrepant Conddion?Q vos @ No Resolut6on Pendeng?O vos @ No ResolutionUnresolved70 vos @ tio Review ACC*Ptable Not Acceptable Needed Date gg. g 0 VT Lead: Rehele, Rej D O G VT Mgr: Schopfer, Don K 4 IRC Chmn: Singh. Anand K Date: SL Conwnents: l l Printed 12/17S7 2.06=5a PM Page 2 of 2 l

Northeast Utilities ICAVP DR No. DR-MP3 0723 Millstone Unit 3 Discrepancy Report Review Group: Programmetc DR VAUD 3 ^ Potential Operability issue Discipline: Other gy Discrepency Type: Conectrve Action No SystervvProcese: DGX NRC Signinconce level: 4 Date faxed to NU: Date Published: Discrepency: Justification for hardware issues documented in UIR 431 which e.re designated as post startup DeectiPtion: Sufficient information has not been provided for evaluation of the appropriate characterization of certain issues (documented in UIR 431) as post startup. Discussion UIR 431 documents several material conditions which were observed during walkdown of the A & B Emergency Diesel Generators by the Licensee. Many of the issues are hardware related, eg. bent tubing, inappropriate routing of tubing, missing or loose bolts / screws / clamps, missing insulation, etc. To evaluate appropriate corrective action, RFI 241 was issued to request the closure packago (DICP) for UlR 431. The Licensee's response to RFI 241 (M3-IRF-00226) states that UIR 431 is not closed and has " scheduled completion dates which are post startup". 4 issue evaluation and resolution (proposed corrective action) for the hardware related items must be reviewed to confirm appropriate characterization of the issues as post startup. Adequate information to conduct this evaluation (eg, submittal of DICP or technical justification to support post startup designation) has not been provided. Review Valid invalid Needed Date initiator: Navano, Mark 8 O O $2/2s7 VT 4.eed: Ryan, Thomas J B O O 12'5/87 VT Mge: sc,4fer, Don K Q Q Q 12/11/97 1Rc Chrnn: segh, Anand K Q Q Q 12/1&S7 Date: INVAUO: Date: RESOLUTION Previously identiSed by NU7 Q Yee @ No Non Diecrepent condation?O Yee @ No Resolution Pending70 Yee @ No R.aosuiionuar.conv.d70 Yee @ No Review Acceptable Not Acceptable Needed Date VT Lead: Ryan, Thomas J 0 0 8 vr m r: sc,,eer Don x e IRC Chmn: singh, Anand K Prtreed 12/17/97 209.54 PM PeGe 1 of 2

Northeast Utilities ICAVP DR No. DR-MP34723 Millstone Unit 3 Discrepancy Report .no u......., y -... n g Date: st Conwnents: r l 4 4 I j-a PrWed 12/17S7 210.00 PM Pe2W 2

Northeast Utilities ICAVP DR No. DR MP3-0727 - MillstDne unk 3 Discrepancy Report Review Oroup: System DR VALID m Em Systen W ,,,,,,,,,n,,,,,,,,y,,,, 06ecipline: Mechencel Design O va Discrepancy Type: Component Date gg system 9tocese: SWP NRC sign 6Heence level: 4 Date faxed to NU: Dele Published: Discrepancy: ESF Building discharge header design pressure not consistently documented. Ducriptm: ESF Building discharge header design pressure of 20 psig for the Service Water lines was not described in section 12.8.2 of the Service Water System DBSD (Design Basis Summary Document) with the other system design pressures. This reduced SWS design pressure was changed by modification PDCR MP3-95-029 from 100 psig to 20 psig, The modification updated FSAR Section 9.2.1.2 and the line list in the PMMS System. DCN (design change notice) DM3-95-029 was issued to update DBDP MP3-SWP upon its next revision relative to modification MP3 95-029, The information contained in the DCN was not included when the DBSD for Service Water was written and is therefore not consistent with the information given in the FSAR. This discrepancy is also applicable to system requirement REQ-MP3-SWP 0048. Review Valid invalid Needed Date initietor: Dionne, B. J. B.4 O O 1 '5S7 VT Lead: Nei, Anthony A g O Q 12 S 97 VT Mgr: Schopfw, Don K O 0 0 52/it/97 IRC Chmn: Segh, Anend K G O O i2 tie,s7 Det.: INVA!JD: Date: RESOLUTION: Previously identined by NU7 O Yes @ No Non Discrepent Condition?Q vea @ No Resolution Pending?O vee @ No R.coiuiioa unte.oived70 vos @ No Review Accepteble Not Accepteble Needed Date VT Lead: Nort, Anthony A VT Mgt: schopfer, Don K IRC Chmn: singh, Anand K sL Comments: Printed 52/57/97 2-1302 PM PeGe 1 of 1

n_.. Northeast Utilities ICAVP DR No. DR MP3 0729 Millstone Unit 3 Discrepancy Report Revtow Group: system. DR VALID I 8M Potential Operatety leeue Diecipune: Mechenecal Dee'" O va Discrepency Type: Component Date (G) Ns SystemProcese: HVX NRC Signincence level: 4 Date faxed to NU. Date Published: Descrepancy: HEPA Filter Material DescrtPtion: During review of the component data for the supplementary leak collection and release system (SLCRS) and auxiliary building ventilation system (ABVS) filter units a discrepancy regarding the HEPA filter frame material was identified. FSAR Section 6.5.1.6 states that the HEPA filters are constructed of chromized steel. This does not agree with tho vendor manual (OIM-065-0018) that sistes that the HEPA filter frame material is 409 stainless steel. Review Valid invalid Needed Date inMietor: stout, M. D. G O t2rt/s7 [ 12997 VT Lead: Nori, Anthony A v 0 O $2rit.s7 VT Mgr: 5 davis, Deny. = IRC Chmn: srgh, Anand K B O i2/ ire,7 Date: INVALID: Date: RESOLLITION: Previously identined by NU7 U Yee 1 90 ) No Non D6screpent CondNion?O Yee K No Resolution Pend 6ng?O vos @) No ResolutionUnresolved70 vos @) No Review inMietor: (none) VT Leed: Neri, Anthony A Vr Mgt: schopfer, Don K IRC Chmn: singh, Anand K Date: SL Conunents: Pnnled 12r17/97 2:13.30 PM Page 1 of 1 i

l I a Northeast Utilities ICAVP DR No. DR-MP3 0731 Millstone unit 3 Discrepancy Report Review Group: System DR VALID Review Element: system Desen Potonneloperability issue Diecipline: MecuncolDeogn Qy, j Discrepancy Type: Drmng ($) No System / Process: HVX NRC Significance level: 3 Date faxed to NU: Date Published: D6ecrepancy: Charging Pump and Component Cooling Water Pump Area Ventilation Winter Mode Damper Positions

== Description:== During review of the charging pump and component cooling water pump area ventilation system a discrepancy regarding the outside airflow during winter mode of operation was identified. Note 17 on P&lD EM 148A 24 states that during winter mode of operation dampers 3HVR*DMP4 and 3HVR*DMP32 are set to approximately the 50% open position. The note does not identify the minimum outside airflow required for stable operation of exhaust fans 3HVR*FN6A/B nor the maximum outside airflow allowed in order to maintain minimum room temperatures. As shown in calculation 3 92103191M3, Rev,1 (CCNs 1 thru 5) the amount of outside air drawn in by supply fans 3HVR*FN14A/B directly effects the ability of the system to maintain the minimum room design temperatures. Based on the above, winter 4 node design airflows are not reflected on P&lD EM-148A & EM 1488. Review Velid invald Needed Date intenator: stout, M. D. O O O i2/1/97 VT Lead: Nort, Anthony A Q Q 12/9/97 VT Mgt: schopfer, Don K Q Q Q 12/11/97 IRC Chmn: singn, Anend K Q [ Q 12/1697 Date: INVALID: Date: RESOLUTION Previously identified by NU7 Q Yes (9) No Non Discrepent conddkm70 vos @) No Resolution Ponding70 vos @ No ResolutionUnresolved70 vee (W)No Review Initiator: (none) b VT Leed: Nort, Anthony A O O O v7 wer: senopr.r. Don K IRC Chmn: singh, Anand K Date: SL Comments: Printed 12/17/97 2-14-18 PM Page 1 of 1

l Northeast Utilities ICAVP DR No. DR-MP3 0738 Millstone Unit 3 Discrepancy Report Rev6 w oroup: system DR VAuD Review Element: system Design Potential Operstdety lesue Diecipline: Mechancel Deegn O vee D6ecropency Type: Component Date @ No SystemProcese: HVX ~ NRC Signinconce levet: 3 Date faxed to NU: Date Publ%ed: Diecrepancy: Supply and Retum Air Registers Descripuon: During review of the charging pump and component cooling water pump area ventilation sysiem and the MCC and rod control area air conditioning system a discrepancy regarding the safety and seismic classification of the supply and retum air registers was identified, FSAR Table 3.21 identifies these systems as CA Category I and Seismic Category I systems. Specification 2170.430-565 states that the supply air registers shall be Agitair Type DDHO with Type "O" opposed action valve and the retum air registers shall be Agitair Type DHFO with Type "O" opposed action valve. The specification does not identify the registers as QA 1, Seismic Category I components. Failure of the opposed action valve in the supply and retum air registers to remain in position following a seismic event would affect the air distribution and the ability of the ventilation system to perform it's safety function. Review Valid invalid Needed Date init6etor stout, M. D. O O O 12/2/97 VT Lead: Neri, Anthony A O O O 2/S87 i-VT Mgr: schopfer, Don K g Q Q 12/11/97 IRC Chmn: singh, Anand K g Q Q 12'16.97 Date: INVALID: Date: RESOLUTION Previously identifled by NU? Q vos @ No Non Discropont Condicon?O vos ist No Resolution Pend 6ng?O vos @ No Resolution Unresolved?O vee @ No Review i Accepteble Not Acceptable Needed Date l_ VT Lead: Nort, Anthony A O O O VT Mgt: schopter, Don K IRC Chmn: s@ Anand K _e sL Conynente: Printed 12/17/97 2:14 se PM Page 1 of 1

~.. - _ Northeast Utilities ICAVP DR No. DR MP3-0739 Millstone Unit 3 Discrepaticy Report Revies Oroup: System DR VAllD Review Element: System Deegn p g g. Diecipline: Mechancel Deegn O Ya D6ecrepancy Type: Uconeq Document @ No SysterWProcess: HVX NRc Signiacence level: 4 Date faxed to NU: Date Published: Descrepency: FSAR Table 6.2 63 Deecripuon: During review of the supplementary leak collection and release system (SLCRS) exhaust fan ratings a discrepancy in FSAR Table 6.2-63 was identified. FSAR Table 6.2-63 states that SLCRS exhaust fans 3HVR*FN12NB are rate < for 9,700 cfm at 22.5 iwg total pressure. Vendor drawing 2170.430-141-004E states that the fans are rated at 9,700 acfm at 25.75 iwg static pressure. Review Volid invalid Needed Date inMietor: stout, M. D, O O O i22s7 VT Lead: Neri, Anthony A O O O 12ss7 Vr Mgr: schopfer. Don K Q Q 12/11/97 1RC Chmn: Sengh, Anand K Q O O 12/1ss7 Date: INVAUD: Date: RESOLUTION: Previously identifled by NU? O Yes iei No Non Discrepent Condition?Q Yes @ No Resolucon Pending?O Yee @ No Resoiution unre.oev.d70 Yee @ No Review Acceptabie Not Acceptable Needed Date VT Lead: Ned. Anthony A VT Mgr: Schopfer Don K IRC Chmn: Sargh, Anand K Date: SL Comments: l l Pnnted 12/17/97 2-15:34 PM Pege 1 of 1 i 1

Northeast Utilities ICAVP DR No. DR-MP3 0740 Millstone Unit 3 Discrepancy Report Review Oroup: system DR VAUD Review Element: system Desegn p g Diecipline: Mechence! Doogn Ow D6screpancy Type: Component Date @ No SystemProcess: Oss NRC Sign 6Acence level: 4 Date faxed to NU: Date Published: D6ecrepancy; Discrepancies found in PMMS Descript6on: The following are discrepancies found in the plant computer data base, PMMS:

1. PMMS shows the following valves designed to specification 713 (i.e.,2282.150-713), while PDDS shows them to be designed to specification 154, (i.e.,2282.150-154):

3QSS*V57 ' 3QSS*V949 3RSS*V32 3RSS*V58 3RSS*V59 3RSS*V971 Both the PDDS and PMMS identify the valve to be manufacturer's identification number VOSO60-W-2. Specifiestion 2282.150154, through Revision 2, includes valve VOSO60-W *, while specification 2280.150-713, through Revision 1, does not include a valve identification number similar to VOSO60-W-2.

2. PMMS shows valve 30SS-V44 to be seismically designed. However, specification 2362.200-164, through Addendum 1, Section C, does not show this valve to be seismically designed. Furthermore, thlal valve is not safety related according to P&lD EM-112C, Revision 16 and specification 2362.200-164. Typically, non safety related valves are not seismically designed unless it is adjacent a safety related component or system, (i.e., a two over one condition).

3. PMMS shows the following valves to be 2 inch nominal size; however, drawing 2282.150-154-019 Revision G and the PDDS show these valves to be 1 1/2 inch nominal size:

3RSS*V968 3RSS*V980 3RSS*V981 Review Valid invalid Needed Date 8"% FairwdA fi t 19mm7 Printed 12/1747 2:17:44 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP34740 Millstone Unit 3 Dlscrepancy Report innestor: Feingoed, D. J. g Q Q 12/2,97 VT Lead: Nort, Anthony A Q Q Q 12,9S7 VT Mgr: Schopfer, Don K O O O 52tii/97 IRC Chmn: Segh, Anand K Q Q Q 12/1697 Date: INVAUD: Date: RESOLUTION: Previously identined by NU? Q Yes @ No Non Discrepent Cosekm?Q Yee (S) No Resolution Pend 6ng?O vos @ No ResolutionUnresolved?O yee @ No Review Acceptable Not Acceptable N W sd Date VT Lead: Non, Anthony A VT Mgt: Schopfer, Don K IRC Chmn: Sngh. Anand K Date: SL Commente: 4 Prtnted 12/17S7 2:17.51 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0741 Millstone Unit 3 Discrepancy Report Review Group: System DRVAUD Review Element: System Deegn poem operebuny leaue D6ecip44ne: Mechancel Desgn O vos Diecropency Type: Component Date @ No SyeterrvProcess: OSS NRC signinconce level: 4 Date faxed to NU: Date Published: D6ecrvency: Inconsistency between PDDS and design information on valve 3QSS V044 Descripuon: Specification 2362.200164, through Addendum 1, page C15 show valve 3OSS V044 to be manufacturer's identification number Wl1015-B-4. Drewing 2362.200-164-034, Revision D, shows valve 30SS-V044 to be manufacturer's identification number Wl015 B-4 or W1015 K4, The plant Computer data bases, PDDS & PMMS, show valve 3OSS-V044 to be manufacturer's identification number W1015 K4. Review Valid invalid Needed Date inettetor: Feingold, D. J. O O O 12/2/97 VT Lead: Nort, Anthony A B O O i2/sS7 VT Mgt: Schopfer, Don K O O O 52/11/97 1RC Chmn: Sogh, Anand K O O O i2iises7 Date: j INVAUD: Date: RESOLUT10N' Prevlously idenUned by NU? O Yee (*) No Non Discrepent Condalon?Q vos (8) No Resolution Pending?O vos @ No Resoiuiion unresoaved?O vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgt: Schopfer. Don K IRC Chmn: Sngh, Anand K Date: SL Commentt: l I i Prwed 12/17/97 2:18.32 PM Page 1 of i l l

l l l Northeast Utilities ICAVP DR No. DR-MP3 0744 Millstone Unit 3 Discrepancy Report Review Group: System DR VAllD

M**

Potential OperatMty issue O vee Diecropency Type: Component Dets @ No SystemMrocese: Rs3 NRC signifkance level: 3 Date faxed to NU: Dele Published: Discrepency: inconsistency between FSAR Sec 6.3.2.4 & the seating design of 3RSS*MOV20A,B,C,D & 3RSS*MOV23A,B,C,D Descripuon: FSAR Section 6.3.2.4 states that, for components of the emergency core cooling system (ECCS), valve seating surfaces are hard faced with Stellite number 6 or equivalent to prevent galling and to reduce wear. FSAR Table 6.3-1 identify components within the containment recirculation spray system flowpath as being part of the ECCS, According to P&lD EM 112C Revision 16 and design specifications SP ME.784 Revision 2 and 2362.200-164 Revision 1, vCves 3RSS*MOV20A,B,C,D and 3RSS*MOV23A,B C D are butterfly valves with soft seats. Because butterfly valves typically contain soft seats, the statement in FSAR Section 6.3.2.4 infers that no butterfly valves are installed in systems used for emergency core cooling. Rev6ew Valid invalid Needed Date initiator: Feingoed, D. J. Q.4 O O $2rss7 VT Lead: Neri, Anthony A B O O 12,1997 VT Mgr: Schopfer Don K G O O $2 itis 7 1RC Chmn: Singh, Anand K G O O 2/ia<o7 D.t.: INVALIO: Date: RESOLUTION: Previousiy identafled by Nur O Yes T No Non Discrepent Condition?Q ve. @ No Resolution Pending70 vee @ No Re.osution unreceiv.d70 ve. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date: sL Comments: Printed 12/1747 2.19:18 PM Page 1 of 1

r Northeast Utilities ICAVP DR No, DR MP3 0746 Millstone Unit 3 Discrepancy Report Rev6ew oroup: syWom DR VAUD Review Element: syWem DeWgn Potonnel Operstdidy lasue Diecipline: Mechanscal Desagn Q y,, Discrepency Type: Ucensing Documnt @ No SystenVProcess: Rss ..RC Significance level: 3 Date FV.ed to NU: De's Putnished: D6ecropency: Inconsistency in FSAR Sec 6.3.2.8 related to automatic switchover to cold leg recirculation Deecrtphon: According to FSAR Section 6.3.2.8, the switchover to the recirculation mode is initiated automatically and completed manually by operator action from the main control room. Automatic initiation cannot be confinned. P&lD EM 115A shows level switches 30SS*LS54A and 3QSS*LSS4C providing the train A low-low RWST level signal and level transmitters 3OSS*LSS4B and 3QSS*LS54D providing the train B low-low RWST level signal. These signals initiate a low-low RWST level alarm at MB2 in the control room. These signals also stop the residual heat removal pumps RHS*P1 A and RHS*P18. The only automatic action that could be considered automatic initiation of switchover is stopping the residual heat removal pumps on RWST low-low level. Procedure EOP 35 ES 1.3 Revision 6 " Transfer To Cold Leg Recirculation *, steps 2 through 4, provide for manual switchover to cold leg recirculation. This procedure does not rely on any automatic actions for switchover. The low-low RWST level alarm in the control room alerts the operator to take manual action to complete switchover to ECCS recirculation according to FSAR Figure 6.3-6 and FSAR Section 6.3.2.8. However, this alarm is not relied upon in designated entry procedures for EOP 35 ES-1.3 to signalinitiation of manual switchover, instead, the RWST level indication is relied upon in the entry procedures for detennination of when to initiate switchover, independent of the alarm. According to the entry procedures, switchover is initiated manually if the RWST level is 520,000 gallons or less. The 520,000 gallon reference corresponds to the RWST low-low level setpoint of 25 feet 5 inches, but again the alarm is not relied upon in the procedures. Procedure EOP 35 ES 1.3 is entered from the following procedures: EOP 35 E 1, Loss of Reactor or Secondary Coolant, step 8 and i step 14 EOP 35 ES-1.1, St Termination, step 12e -4 EOP 35 ECA 2.1, Uncontrolled Depressurization of All Steom Generators, step 8 and step 0 EOP 35 ECA-3.1, SGTR With Loss of Reactor Coolant - Subcooled Recovery Desired, step 5 EOP 35 ECA-0.2, Loss of All AC Recovery With Si Required, step 1 Fremni int etnnninn thm QMR niirnne nn AWRT Inw.inut laumi nn Printed 12/17/97 2.20:16 PM Page 1 of 2

Northeast UtiHties ICAVP DR No. DR-MP3 0746 Millstone Unit 3 Discrepancy Report automatic actions occur during switchover to cold leg recirculation. Automatically stopping the RHR pumps is not sufficient to constitute automatic initiation of switchover because this does nothing to ensure proper system alignment for switchover. Furthermore, the RWST low-low level alarm cannot be considered automatic initiation of switchover because it is not utilized in the emergency procedures to initiate switchover. Therefore, automatic initiation of switchover to cold leg recirculation is not consideied to occur as stated in FSAR Section 6.3.2,8. Review vand invahd Needed pote instietor: Femgold, o. J. O O O 12/4s7 VT Leed: Non, Anthony A G O O 12.ss7 VT Mgr: schonfer, oon K Q Q 12/11Ml7 IRC Chmn: smgh, Anand K G O O 2/iss7 om.: INVAllo: oste: RESOLLITioN: Prov6ously identifled by NU7 O Yes (9) No Ned36screpentCondition?U Yes

9) No Resolution Pending70 Yee @ No R--aaaian unr.aolv.470 Yee @ No i

Review initiator: (none) b VT Leed: Nort, Anthony A VT Mgt: Schopfer, oon K IRC Chmn: Segn, Anand K o: SL Conwnents: Ptinted 12/17/97 220'23 PM Page 2 of 2 .. l

Northeast Utilities ICAVP DR No. DR-MP34753 Millstone Unit 3 Discrepancy Report Review Group: System DR VAUD Potential Operabilty lseue Diecipline: Mechancal Desagn yg 06ecrepancy Type: Instelisten implementaten @) No SystemProcess: HVX NRC Significance level: 3 Date faxed to NU: Data Published: D6screpancy: PCDE MP3 90-076 Test Requirements D**cropuon. During review of modification PCDE MP3-90-076 a discrepancy regarding the post modification testing requirements was identified. The modification added a bracket to limit the travel of backdraft damper 3HVR*DMPB138 at the discharge of SLCRS fan 3HVR*FN'?B. The PDCE required retest of SLCRS fan 3HVR*FN12A airflow. The PDCE did not address retesting SLCRS fan 3HVR*FN128 to verify that adjustment of 3HVR*DMPB138 did not reduce fan airflow below design requirements. PDCR MP3-91 124 was issued to make additional modifications to damper 3HVR*DMPB138 to increase fan 3HVR*FN128 airflow, Review Valid invalid Needed De*? Irdtiator: Stout, M. D. O O O iztiss7 VT Lead: Nort, Anthony A O O O 52ss7 VT Mgr: Schopfer, Don K Q -^ O O $2ttiiv7 IRC Chmn: Singh, AnaN K O O O i2tiss7 ( Date: l MM: Date: j RESOLUTION Prev 6ously identifled by NU7 O Yes @ No Non Discrepent Condition?Q Yes (fi No Resolution rending 70 Yee @ No Resoiuiionunreouved70 vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anttony A VT Mgt: Schoofer, Don K IRC Chmn: Singh, Anand K Date: sL Comments: r l Printed i2/17/97 2.22.35 PM Page 1 of 1

Northeast Utilities ICAVP DR No. DR-MP3-0764 Millstone Unit 3 Discrepancy Report Rev6ew Group: Spiern DR VAUD Revtow Element: Modification Design p g Diecip44ne: Mechancel Design O va Discrepency Type: Cm @ No System / Process: HVX NRC Signiacance level: 4 Date faxed to NU: Date Putdished: Diecrepency: Calculation PBV 45AA 1 affected by PDCR MP3-06-074 j Deecripuon: Review of modification PDCR MP3-86-074 that removed fire dampers 3HVR*DMPF4 and 3HVR*DMPF5 from the MCC & Rod i Control Area air conditioning system identified the following discrepancy: Calculation PBV-45AA 1 that determines the extemal total pressure loss for 3HVR*ACU1 A & 1B was not revised to reflect the removal of the fire, dampers, Review Valid invalid Needed Date [ [ 12897 init!stor: Stout M. D. = 0 0 12/n/97 VT Lead: Nort, Anthony A VT Mgt: $ctopfer, Don K O O O $2rt s/97 Q 12/1697 IRC Chmn: Singh, Anand K = Date: INVAUD: .a Date: RESOLUTION: Previously identifled by NU7 Q voo (Gi No NonDiscrepardConddlon?O vos (#1 No ResolutionPending70 ves @ No ResolutionUnresolved70 vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgt: Schopier. Don K IRC Chmn: S@, Ar.wl K Date: SL Conments: A Printed 12/17/97 2:23.10 PM Page 1 of 1

f Northeast Util;tles ICAVP DR No. DR-MP3 4758 %Ilstone Unit 3 Discrepancy Report Review o,oup: se DRvAuo Revtow Element: Madsfceton Doogn p g 06ecipline: Mechenenal Doogn O Ya D6ecropency Type! Celculeton 4 g, $y1 tem /Procese: HVX NRC sigeWficanca level: 4 Date faxed to NU: Date Publ6ehed: Diecrepency:'PDCR MP3 92 024 Affected Documents Caecrisdion: During review of PDCR MP3 92-024 that installs larger olameter wheelin exhaust fans 3HVR'FN12A/B the following discrepancies were identified:

1. Calculation P(B)-M3 ' Supplementary Leak Collection and Release System ' was not revised to reflect the fan performance with the larger diameter wheel,

2. Calculation P(9)-45AF.1 'Extemal Pressure Loss for System 3HVR*FN 12A & 128' was not revised to reflect the fan performance with the larger diameter wheel.

3. Specification 2176.430141 ' Centrifugal Flow Fans' was not revised to reflect the faa performance and brake horsepower with the larger diameter wheels.

Review valid invalid Needed Dale inm6sior: Stout. M. D. Q.4 O O 12/M7 VT Lead: Nort, Anthony A O O O 12/ser VT Mgr: schopfer. Don K O O O 12/11/87 IRC Chmn: Srgh. Anand K Q O O 12/t"7 Osle: INVAllo: Dele: REsOLUTX)N: Previously ident6fted by NU7 Q Yes t#) No Non Descrepard Conott6on?U Yes (9) No Resolut6en Pend 6ng?C Yes @) No ResolutionUnresolved?O Yee @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Antrony A VT Mgt: Schopfer, Dun K IRC Chmn: Sngh, Anand K Dele: sL Comment 5: Printed 12/1747 2.24 36 PM Pope i d 1

Northeast Utinties ICAVP DR No. DR-MP3 4782 Ministone Unk 3 Discrepancy Report Review Oraup: syotern DR VALIO Rev6ew Element: Madefce#en inetoI6eton D6er4ene: Moohenecal Desig" O Ya 06ectopency Type: Toot implementaten 4g syoterrWProcese: HVX NRC Sigrecence level: 3 Date faked to NU: Date Published: D'ectoPo'KY: PDCR MP3 92 024 Fan 3HVR*FN128 Vibration Test De*cript6an: During review of PDCR MP3 92 024 that installed a larger diameter wheel in supplementary leek collection and release system (SLCRS) fan 3HVR*FN128 a discrepancy regarding vibration test Jesults was identified. Reg. Guide 1.52. Rev. 2 Position C.3.1 states that the system fan, its mounting, and the ductwork connections Sl;ould be designed, cor'structed and tested in accordao with the provisions of Sections 5.7 r.r.d 5.8 of ANSI N5091976. AP,31 N5091976 Section 5.7.3 states that the maximum permissible vibration velocities shall be 0.1 inJsec radisily and 0.2 in/sec axially. FSAR Table 1 M, Reg. Guide 1.W, Rev. 2 does not take exception to this requirement. The fan vibration test results dated 6/19/92 included with AWO M3 9214052 exceed ANSI N5091976 reqquirerNnts. The radial vibratlA was.205 in/sec horizontal and.122 in/sec vertical at the outboard mot 6r bearing,.215 in/see horizontal and 0.052 in/sec at the inboard motor bearing. The axial vibration was.265 in/sec at the motor outboard bearig. Review Valid invalid Needed Dale init6stor: Stout, M D. Q Q Q 12/&97 VT Leed: Ned. Anthony A O O O 12/asr VT Mgt: Schopfer. Don K Q Q Q 12/11/97 IRC Chrm: Engh. Anand K Q Q Q 12/1697 Dele: INVAUD:

== Dele: Kare0LUTION: Previously identtaed by NU7 O Yeo M No No.1 Descrepent Condition?Q Yeo @ No Renowoa Poaman?O va + No Roeoluuon UnreWyeo?O va @ No i Rev6ew I Acceptable Not At wptable Needed Date b VT Lead: Non, Anthony A VT Mge: Schopfer, Don K 1RC Chmn: Singh. Ana.1 K SL Commente: Pnneed 12/17/97 2.25 21 PM ' age 1 of 1

Northeast Utilities ICAVP DR No. DR MP3 0771 Millstone Unit 3 Discrepancy Report R. vie. o,oop: stei.m DavAuo Revlew Element: System Dosagn p D6ecipline: Mechancel Desgn O va D6screpency Type: Dreeng 4g SyederWProcese: RSS ~ NRC Sign 6hcence leveh 4 Date faxed to NU: Date Published: D'*cr*P*ncy: inconsistency between FSAR and structural drawings with respect to sump trash rejedion grating. D**cnpe6aa: FSAR Gedion 6.2.2.2 and FSAR Table 6.2-61 state that the containment structure sump is protected by 1 1/2 inch vertical trash rejection grating. Drawing 12179-ES 53J Revision 1 concurs with the FSAR. However, drawing 12179 ES 53G Revision 3, Section C4, shows the vertical trash rejedion grating to be 1 inch by 3/16 inch. Review Venid invalid Needed Date initiator: fempoed. D J O O O 12/ ids 7 VT Lead: Nori. Anthony A Q Q Q 12/11/97 VT Mgt: Schupfer Don K Q Q Q 12/11/97 1RC Chmn: Singh, Anand K Q Q 12/16s7 Dese: INVAUO: Dele: 4 RESOLUTION

Previously identined by NUf Q vee

I No Non D6screpent Condit6on?Q vos @ No Resolution Pending70 vee + No Resoivisonvaresoevedf0 vos @ No Revlow Acceptable Not Acceptable Needed Date gg O

O O VT Leed: Nor1. Anthony A VT Mgr: Schopfer Don K 4RC Civw Singh, Anand K = D.. SL Comments: Prtnted 12/1747 2 25 59 PM page1 of 1

Northeast Utlinies ICAVP DR No, DR MP3 0772 Millstone Unk 3 Discrepancy Report neview oreup: Progromrnene DR vALio Review Elen.ent: Conecwe Achun Process pg g ygg,,, 06ecW hw Desagn O vee Diecropency Type: Conocwe Acton @ No system?tocese: HVX ~ NRC s6gnHnconce level: 3 Dale faxed to NU: Date Published: DA(M"dipsure of Design Deficiency Report (DDR 1027) f M ipuoa: DDR 1027 documented a concem with the ventilation design for the Charging and Component cooling Water Pump areas. The potential exists for cross contamination (from charging pump areas to component cooling pump areas) due to a recirculction flow path. This flow path was part of the original plant design. DDR 1027 was closed to PMR 3-88-026. Page 7 of PMR 3 88 026 Indicates that with regard to DDR 1027,

this has not been a problem to date and potential solutionc were evaluated and rejected due to high cost'...

Page 8 of PMR 3-88-026 ls a memo (dated July 26,1994) from a radiation protection supervisor to MP3 Design stating that based on review of summaries contained in PDCRs MP3 86-069 and MP3-86-025 *with regard to Al. ARA concems with disbursement of radioactivity with the air flow pattems, I do not saa this as a problem at Millstone 3.* While the recirculation flow path was part of original plant design, there are some inconsistencies in system description between the design, SER, and current FSAR, in addition, closure of the DDR did not address compliance with system design / licensing requirements.

1. The current FSAR discusses a winter mode of operation wherein the recirculation flow path is in service to maintain a minimum area temperature. The recirculation flow path (when in service) is contrary to another statement in the FSAR ( page g.4.18) which states 'once air is drawn from a building space, it is either discharged to the atmosphere through the ventilation vent or diverted to the auxiliary building filtration units, prior to release through the ventilation vent.'

2. Since the charging pumps handle primary coolant, the potential for higher airbome contamination exists relative to the Component Cooling Pump area. Therefore, the recirculation flow path (when in service) is contrary to item No. 7 on FSAR page 12.3.17 which states ' air flow within the auxillary, waste disposal, and fuel buildings during normal operation is from areas of lower to higher potential airbome.ontamination and then to monitored V e nt s.....*

3. The recirculation flow path (when in service) is contrary to MP3 SER page g 32 which states ' control of airbome activity is accomplished by exhausting air supplied to clean areas through the potentially contaminated areas. The air in tum is processed by the filtered exhaust system. The remaining air supplied to clean areas is exhausted by the unfiltered exhaust system.'

Prtnied 1247/97 2 M 36 PM Page 1 of 2

= _ _ _ Northeast Utilities ICAVP DR No. DR MP34772 Millstone Unit 3 Discrepancy Report 4.The recirculation flowpath (when in service) would constitute plant operation contrary to item No.12 on FSAR page 9.417 anytime the Charging pump areas are inore contaminated than the Component Cooling Pump Areas,

5. Closure of the DDR appeared to rely in part on accumulated operational experience and existing low contamination data (memo shown as page 8 of PMR 3-88-026 referenced above) without acknowledgement of the higher potential for contamination that exists in the Charging pump areas compared to the Component Cooling Pump areas and the associated flowpath design / licensing requirements which would apply. (eg.

FSAR and SER items documented in items 1 through 4 above). Review Valid invalid Needed Date inalletor: Neveno, Mo'* O O O 12/1587 VTLeed: Rren Thome.J Q Q Q 12/1147 VT Mgr: Schopfer. Don K Q Q Q 12/1147 IRC Chmn: Segh. Anond K O O O $ 2/'657 Det.: eNAUo: Date: MEs0LUTION: Prev 6ously identeaed by Nu? O Yes iGi No Non,Discrepent Condit6on?O vs. @ No Mesolution Pendingr0 vs. (5) No Raaaaadia9 0nresolved?O vs. (5') No Review initiator: (none) VT Lead: Ryan, Thomes J VT Mgr: Schopfer, Don K 1RC Civnn: Srgh, Anand K Date: sL CommerWs: 4 Prned 12/17S7 2.26 43 PM Pope 2 of 2

l Northeast Utilities ICAVP DR No. DR MP3-0774 Millstone unk 3 Discrepancy Report Rev6ew Group: Progrerrrnetc DR VAUD Revtew Element: Correcttve Acton Procow O Yee CM ;- ;y Type: Corrective Acton fe) No { systerWProcese: DGX ~ NRC sigenAcance level: 3 Date FAKad to NU: Date Publiehtd. i Dac'apeacy: Improper UlR Completion Milestone Requirement. 1 Deecript6on: The UlR 302 Completion Milestone is *Not Startup Required'. The UIR 302 Completion Milestone should be 'Startup Required' for the following reason: The UIR Subject states

Cablo 3ENSBPC501 Llfted and Colled as ' Spare' '.

The UIR Description states

Cable 3EWSBPC501 was lifted from RR S & 4 and coiled in place as a spare. No documentation as to the basis; no change document identified'.

The Cable Schedule Data shows the cable 3ENSBPC501 is in use and lists the Connection Drawings as EE 3MJ and EE 8BN. The Connection Diagrams EE.3MJ, ReV. 8 (dated 11/1/94) and EE-8BN Rev. 22 (dated 12/4/96) show the cable 3ENSBPC501 connected and required for circuit operation. 4 Based on the above, it is indeterminate whether or not this cable is needed for plant operation.. Note 1: Cable 3ENSBPC501 is shown connected to the 4160V Emergency Switchgear Section 14 at terminal points SS1 & 2. Cable EGSBPC900 is connected to terminal points RR5 & 4. The 4160V Emeroency Switchgear Section 14 feeds the Emergency Diesel Generator B, 3EGS*EG B. Note 2: Cable 3EWSBPC501 referenced in the above UIR Description is a typographical error and should be Cable 3ENSBPC501. Cable 3EWSBPC501 does not appear on the NU Cable Schedule. Review Venu invalid Needed Date inatiator: Caruso. A G O O 12/11/97 VT Leed: Ryan. Thomas J Q Q Q 12/11/97 VT Mgr: Schopfer. Don K Q Q Q 12/11/97 IRC Chmn: SWgh, Anand K O O O ' ' S'S7 Date: INVAUD: Date: RESOLUTION Prov6ously ident6Aed by NU7 Q Yee @ No Non Discrepent Condation?Q Yee @ No Printed 12/17/97 2 27.14 PM Page 1 of 2

Northeasi Utilities ICAVP DR No. DRMP3 0774 Millstone Unit 3 Discrepancy Report PMd6en Pend 6ng?O Yes e) No MesoluuanUnresolved?L) Yts ei No Review AccepuMe Not Acceptable Needed Date D D D VT Leed: Ryen. Tremes J 0 0 0 v7 m n w.r.oon x e b l me chmn: see. Anana x 0 ~ e: SL CorrenerAs: I 4 e e Printed 12/17/97 2 27.21 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3 4190 Millstone UnN 3 Discrepancy Report Review Otoup: Programrnetc DR RESOLUTION ACCEPTED Review Element: Change Process p D6ec6pl6ne: Mechancel Deogn O veo D6ecrepancy Type: CorrecWe Acton

No systemProcess: HVX NRC sngnmcence level: 4 Date faxed to NO:

Date Putdiohed: 1 % 97 D6acropency: Auxiliary Build!ng Ventilation Exhaust System fan testing acceptance criteria and NCR Disposition Descripoon: The Disposition Details of NCR 392 255 state that during test IST 3 92 028, the air flow through 3HVR*FN68-under dirty flow conditiorviid not meet the design enteria of 15,500 Standard Cubic Feet Per Minute (SCFM). The measured flow was 14,835 SCFM. The NCR is dispositioned 'Use As Is* stating that the 15,500 SCFM was an estimated "Giean Filter Criteria

and was developed to provide margin to prevent fan stalling, The disposition details also state that IST 3 92 028 simulated " Dirty Filter" conditions and the fan did not trip or stall.

PDCR MP#-92103, Rev 1, attached to the NCR identifies the minimum flow point of 15,000 SCFM along with the statement, "The minimum flow point of 15,000 SCFM was estab!!shed by test to be the minimum flow capacity of fans 3HVRVN6A/6B without stalling." There is a contradiction between the acceptance criteria of IST 3 92-028 and acceptance enteria stated in the PDCR, i.e., the IST uses 15,500 SCFM, and the PDCR identifies 15,000 SCFM. Review veind invoind Needed Dale Irdiator: Wrone, s. P. O O O S/ 7/87 VT Leed: Ryen. Thomes J Q Q Q 9"2497 VT Mge: schopfer, Don K O O O S25S7 IRC Chmn: Srgh, Anand K Q Q Q 9/27/97 Dele: INVALID: Date: 11/19/97 RESOLUTION: NU has concluded that Discrepancy Report DR MP3-0190 does not represent a discrepant condition. The 15,000 CFM value was chosen as the flow at the normal filter dp conditions that would keep the fans out of the stall region as the filters become dirty, As stated in the attached technical evaluation, testing was necessary to verify this value, since this flow was derived from system curves and shop test curves. The stall region was determined from IST 3 92 022 to be 14,000 CFM, D!rty filter tests showed a flow of 14,835, which is greater than the measured stall region, so is therefore acceptable as recorded in NCR 392 255 To determine (l':t minimum clean filter flow,1,000 cfm was added to the stall threshold of 14,000, Then the reduction in flow due to a dirty filter was added. Shop testing has shown that filter Printed 12/17/971;42.55 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR MP34190 Millstone Unit 3 Discrepancy Report DP increased 0.6 inches after 1000 hours of operation at 29,000 cfm. To this an additional 0.4 inches was added to account for monthly surveillance testing, giving and adding a DP increase of 1.0 inches for a dirty filte<. Flow reduction was calculated for a 1.0 inch DP increase F. :'],000 cfm prorated to 15.000 cfm which results in a minimum ek an filter flow of 15,500 cim. Since this value is derived by supplementing shop test data with in plant test data, it differs from the value provided from shop test curves. Significance level criteria do not apply as this is eot a discrepant condition. Previously idenHAed by NU? Q Yes

9) No Non Dioctopent Condion?'9) Yes () No Meeoaut60n Pend 6ng?O Yes

> u.

n iouon un,. sv.drO ve. @ No Review initiator: Wrone. S P. VT Leed: Ryan Thomes J VT Mer: Schopfw oon K IRC Civvvi: singh. Anand K oste: 11/13/97 l st Comnents: The test information in PDCR MP# 92103, Rev.1, did not O V8 an accurate discription of the air flow test results. These results have been accurately presented in the Disposition to this DR. 4 1 1 l 1 Prtnied 12/17/971:43 02 PM Poes 2 of 2 j

Northeast Utilities ICAVP DR No. DR MP3-0205 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTK)N ACCEPTED

8#**

Potermel operately issue Diecipione: I & C Desg" Ow Diecropency Type: Drawvg 4g systemProcess: Oss ~ NRC sigrWftcence level: 4 page faxed to NU: Date Published: togs 7 Diecr*P*ncy: Drawing Discrepancy. LSK 2712B D*ecr$Puon: On Logic Drawing LSK 27128. Rev 13, red and green indicating lights on escutcheon for 3QSS*AOV27 are reversed. They are inconsistent with valve escutcheons shown on other logic drawings. The description ' Quench Spray A Motor Temp Hl/ Quench Spray 8 Motor Temp Hi' between sources 3QSS TE39A and 30SS-TE40A should be deleted, it does not identify the condition associated with either source. The conditions associated with sources 30SS-TE39A and 30SS TE40A are shown to be "30SS*P3A Motor Temperature" and '3QSS*P3A Motor Temperature High' respectively. Review Valid invalid Needed Date initiator: 1. wise. H O O O $25S7 VT Lead: Non, Anthony A O O O a2ss7 VT Mgr: schopfer, De K O O O a2ss7 IRC Chmn: singh, Anand K Q" Q Q a27/lft Date: INVAllO: Dese: 11/20/97 RESOLUTION: Disposition: NU has concluded that Discrepancy Report, DR MP3-0205, has identified a condition not previously discovered by NU which requires correction. On Logic Drawing LSK 27128 the green and red indicating lights in the escutcheon detail for 3QSS*AOV27 will be revised to agree with ESK 3E, Detail AE1 and Plant condition. The description Quench Spray A Motor Temp Ha/ Quench Spray B Motor Temp HI between sources 3OSS TE39A and 30SS-TE40A on LSK 27128 depicts the split window annunciator to the description's right. This description will be repositioned to the right of the annunciator symbol to be consistent with the standard annunciator presentation on logic diagrams. Condition Report (CR) MJ 97 3517 was written to provide the necessary corTective actions to resolve this issue, Approved Corrective Action Plan (CAP) attached, DCN DM3 1663-97 was issued to correct the drawing errors mentioned in the CR (DCN attached). No work is required in the field.

== Conclusion:== NU has concluded that Discrepancy Report. DR MP3-0205, has identified a condition not previously discovered by NU which Printed 1217/97143 35 PM Page 1 of 2

Northecst Utilities ICAVP DR No. DR MP3 0205 Millstone Unit 3 Discrepancy Report requires correction. On Logic Drawing LSK 27128 the green and red indicating lights in the escutcheon detail for 3QSS*AOV27 will be revised to agree with ESK 3E. Detail AE1 and Plant condition. The description Quench Spray A Motor Temp Hi/ Quench Spray 8 Motor Temp Hi will be repositioned to the right of the annunciator symbol to be consistent with the standard annunciator presentation on logiv diagrams. Condition Report (CR) M3-97 3517 was written to provide the necessary corrective actions to resolve this issue. Approved Corrective Action Plan (CAP) attached. DCN DM3 001663 97 was issued to correct the drawing errors mentioned in the CR (DCN attached). No work is required in the field. Previously identtned try NU7 Q Yee @ No Non oincrepent CondM6on?U vos @ No Resolution Pending?O ve. + No Resolution Untoeolved70 vos @ No Review ACC # 8 M Acce#W Needed Me inMietor: Prmes. H b I VT Lead: Nort. Anthony A O O "m87 VT Mgr: Schopfer. Don K O i2 m r

L IRC Chrm: Sngh. Anand K 0

12/isS7 O sL Commente: 4 Printed 12I17471:43 42 PM P92W2

i Northeast Utilities ICAVP DR No. DR-MP3 0206 j Millstone Unit 3 Discrepancy Report Review Oroup: System DR RESOLUTION ACCEPTED Potential Operetniary lasue D6scipiene: 1 & C Deeg" O vee 1 N i n;i Type: Drewvg @ No SysterWProcess: QSs ~ l NRC Engrdftcance level: 4 Date rAXed to NU: Date Putdished: 1D397 D6.crepency: Drawing Discrepancy LSK 2712C Deecript6on: Notation on Logic Diagram LSK 2712C, Rev 13 adjacent to annunciator symbol for 30SS-TE37 reads *RWST Temp Hi/RWST Temp Lo'. PalD EM 115A 18 depicts the alarm for 30SS-TE37 to be only for Temperature Alarm Low. Review Veild invalid Needed Date hutor: Pineses, H. O O O $c557 VT Leed: Nort, Anthony A O O O $2557 VT Mgt: Schopfer. Don K Q Q Q B7597 $27/87 IRC Chmn: srgn. Anand K O O :.___. O Date: DNALlD: D*: 11/26/97 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0206, does not represent a discrepant condition. The annunciator symbol downstre'am of source 30SS TE37 shown on LSK 2712C is a split annunciator window for RWST Temp Hi/RWST Temp Lo, The logic flow arrow is pointing to the lower half of annunciator symbol, implying the second half of the descdption applies, RWST Temp Lo. This agrees with the supporting documentation when viewed with this philosophy.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR MP3-0206, does not represent a discrepant condition. The annunciator symbol downstream of source 3QSS-TE37 sho'vn on LSK 2712C is a split annunciator window for RWST Temp Hi/RWST Temp Lo. The logic flow arrow is pointing to the lower half of annunciator symbol, implying the second half of the description applies, RWST Temp Lo, This agrees with supporting documentation when viewed with this philosophy. There are no drawing or field changes required by this DR. I Previously identifned t>y NU? Q vos @ No NonDiscrepentcondeuon?@ vos ( ) No Resolution Pending?O vos (el No ResolutionUnresolved?O ve. @ No Review Inellator: Pineteo, H. VT Leed: Nort, Anthony A O O "N VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Printed 12/17/971:44 So PM Page 1 of 2

[ Northeast Utilities ICAVP DR No. DR-MP34206 Millstone UnN 3 Discrepancy Report m e.......... - - ~ " O O O tm7 Date: SL Coevenceds: 1 1 4 e I i Prtnied 12/171971.44 56 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3 0207 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACr:EPTED Revtew Element: splom Desgn Potentid OperabMylseue Diecipiene: I & C Desgn Q y,, D6screpency Type: Drawin0 @) No systemMocese: Oss NRC Sigrutcance level: 4 Date faxed to NU: Date Published: 10G97 Discrepancy: Drawing Discrepancy LSK 2712D Deschption: Notation on Logic Diagram LSK 2712D, Rev 14 adjacent to annunciator split window symbol for 3OSS-TE23 reads "RWST Temp bdRWST Temp Lo'. P&lD EM 115A 18 depicts the signal from 3QSS TE23 to actuate a Temperature Alarm High (TAH) at M82. Loop Schematic 3QSS-023, Rev 4 shows a singular (rather than split) window labelled "RWST Temp Hi*. One of the conditions shown on LSK 27120 for 3QSS-TE23 states

30SS*TK1 Refueling Water Storage Tank Temp Hi Hi* which is inconsistent with above information.

Notation adjacent to 3QSS*LS54A bubble reads *(Note 3)*. The drawing depicts Notes 1 and 2. Note 3 is not depicted. Review Valid invalid Needed Date inetlator: Pinsies, H. O O O S2557 VT Lead: Nort, Arthony A B O O 5v 5S7 VT Mor: set @fer, Don K g O O D2s97 IRC Chmn: singh. Anand K O O sv27/or Date: INVALID: Date: 11/20/97 RESOLUTION: Disposition: NU has concluded that the first issue in Discrepancy Report, DR-MP3-0207, does not represent discrepant condition. The annunciator symbol downstream of source 30SS-TE23 shown on LSK 27120 is a split anne?ciator window for RWST Temp Hi/RWST Temp Lo. The logic flow arrow is pointing to the upper half of annunciator symbol, implying the first half of the de.scription applies, RWST Temp Hl. This agrees with the supporting documentation when vie,ved with this philosophy. The Test Loop Diagram (TLD) 30SS-023 depicts a whole annunciator window, but accounts for split window by use of letter suffix after the numerical window assignment (1 1 A). NU has concluded that the second issue in Discrepancy Report, DR-MP3-0207, has identified a condition not previously discovered by NU which requires correction. The conoition from source 3QSS-TE23 on LSK 27120 will be revised to read 3QSS*TK1 Refueling Water Storage Tank Temp Hi to agiee with the supporting documentation. The notation adjacent to source 3QSS*LS54A on LSK 27120 will be revised to read note 2. This note was renumbered on thei last revision and the cross-reference to it was overlooked. Condition Report (CR) M3 97-3517 was written to provide the necessary corrective actions to Printed 12/17s11:45 25 PM Page 1 of 2

Nortliesst UtilMies ICAVP DR No. DR MP3 4207 Millstone Unit 3 Discrepancy Repoft resolve these issues. Approved Correction Action Plan (CAP) attached, DCN DM3 00-1663 97 was issued to correct the drawing errors mentioned in the CR (DCN attached). No work is required in the field.

== Conclusion:== NU has concluded that the first issue in Discrepancy Report, DR. MP3 0207, does not represent a discrepant condition. The annunciator symbol downstream of source 3QSS TE23 shown on LSK 27120 is a split annunciator window for RWST Temp Hi/RWST Temp Lo, The logic flow arrow is pointing to the upper half of the annunciator symbol, implying the first half of the description applies, RWST Temp Hl. This agrees with the supporting documentation when viewed with this p'illosophy. The Test Loop Diagram (T1.0) 3QSS-023 depicts a whole annunciator window, but accounts for split window by use of letter suffix after the numerical window assignment (1 1 A), NU has concluded that the second issue in Discrepancy Report, DR-MP3-0207, has identified a condition not previcusly discovered by NU which requires correction. Condition Report (CR) M3 97 3517 was written to provide the necessary corrective actions to resolve this issue. Approved Corrective Action Plan (CAP) attached, DCN DM3-001663-97 was issued to correct the drawing errors mentioned in the CR (DCN attacned). No work is required in the field. Previously identined by NU7 Q Yes tel No NossDescrepent Condetion?O Yes (9) No Resolution Pend 6ng70 Ye. 'M No R..oiuiion unto #vedtO Yo. Ce)No Review initiator: Peeles H G O O mw VT Lead: Nort. Anthony A VT Mgt; schopfer. oon K IRC Chmn: Segh, Anand K Date: sL Conwnents: Printed 12/17S71/* 32 PM Page 2 of 2

i Northeast Utliities ICAVP DR No. DR MP3 4212 Ministone Unit 3 Discrepancy Report Revtew Group: System OR RESOLUTION ACCEPTED h Element: s#em Doogn Potenteel Operetdisty leaue D6ecipa6ne: 14 0 Design O va D6ecrepency Type: Dreeng @ No System 9toceae: Oss NRC Sign 6Acance level: 4 Dele faxed to NU: Date Putdiohed: 1MS7 Diecrepency: Drawing Discrepancy. Schematics 30SS-040A,8 D**cript6on: Designation for RTD 30SS TE40A on Loop Schematic 3QSS. 0408. Rev 2 should be changed to 30SS TE408 to agree with pump 30SS'P3B designation. Rev6ew val 6d invei6d Needed Date initaetor: Peeles. H-O O O 5v2557 VT Lead: Nen. Anthony A O O O $2557 VT Mgt: schopfer. Don K O O O e/2sS7 IRc Chrnn: sngh. Anand K O O O Sv:7/87 Deis: INVAllo: Dele: 11/20/97 RESOLUTION Disposition: NU has concluded that DiscJepancy Report, DR MP3-0212, has identified a condition not previously discovered by NU which required correction. The identification of the RTD for SQSS*P3B on Test Loop Diagram 3QSS4408 will be revised to read SQSS-TE 60B to agree with schematic ESK 5DH and logic LSK 27128. Condition Report (CR) M3 97 3517 was written to provide the necessary corredive actions to resolve this issue. Approved Corrective Action Plan (CAP) attached, DCN DM3-001663 97 was issued to correct the drawing errors mentioned in the CR (DCN attached). No work is required in the field.

== Conclusion:== NU has concluded that Discrepancy Report, DR MP3 0212, has identified a condition not previously discovered by NU which required correction. The identification of the RTD for 3QSS*P3B i on Test Loop Ditgram 3QSS-040B will be revised to read 3OSS-TE40B to agree with schematic ESK SDH and logic LSK 27 j 128. Condition Report (CR) M3 97 3517 was written to provide the necessary corrective actions to resolve this issue. Approved Corrective Action Pian (CAP) attached, DCN DM3-001663 97 was issued to correct the drawing errors mentioned in the CR (DCN attached). No work is required in the field.

Prov60uely ident6Aed by NU7 Q Yes @ No Non Discrepent Condation?O Yes

(*) No Resolution Pending?O Yee (*? No Resoiution unre.oiv.d?O Yes @ No Review initietor: Pooles. H. YT Leed: Nort. Art %ny A Prtnied 12/17/97 be6 06 PM Pope 1 of 2

Northeast Utilkies ICAVP DR No. DR MP3 0212 Millstone Unit s Discrepancy Report O O iir2trer VT Mgra schop#er, con x R O ' m S7 IRC Chmn: Singh, Arwd K C LJ O 12/1697 SL Comrrents: f e Printed 12'17/971.46.12 PM Page 2 of 2

Northeast Utilitie. ICAVP DR No. DR MP3 0348 MilletOne Unit 3 Discrepancy Report ILeview orpup: Programmetc DR RESOLUTION ACCEPTED Review Element: Operating Prtcodure Pot i Opraba#y kaue 06ecipione: 0;eestone Om D6screpency Type: 0 & M & T Procedure ft) No SystenvProcess: N!A NRC signincence level: 4 Date faxed to NU: Data Published: 1D?s97 D6ecrepency: Incorporation of Approved Change to Operating Procedure OP3319A Rev.13, Change No.1 D**cr5 Hon: OP 3319A Revision 13 change number 1 (as approved) was issued to provide instructions regarding an attemats source of sealing water for the tube sheet sealing water system. To accurately incorporate this change into the procedure, changes to two sections ( pages 18 and 25) are required. However, only one of the two sections were revised. Additionally, an observation is made regarding ambiguities. Discrerant Condition Revision 14 of OP3319A indicates the change approved for page 18 of Rev.13 was incorporated on page 19 of Rev.14 in the appropriate section, however, the change approved for page 25 of Rev.13 was not incorporated into the appropriate section of on page 26 of Rev.14. This is a discrepant condition. Observation The documented Reason for Change (for Revision 13, Change No.1) contains wording which is not clear and could be misunderstood. The wording ',if 3CNS V935 is unavailable" could be taken to mean that it was the Author's, and by their subsequent approval, PORC's intent, to allow the attemate supply of sealing water (in this case,3CNS V899) to be used only 'if 3CNS V935 is unavaltable', implying that there is a preferred source which must be used *1f available*, The procedure as written /revi.%d, does not impose any restrictians or suggest a preferred suurce. Review Valed invalid Needed Date inn 6eto'a Navarro, Mark Q Q Q 10%97 VT Leed: Hrer,. Tho. nae J O O O 'SSS7 VT Mgr: schopfer, Don K O O O 'o 5S7 IRC Chmn: Singh, Anand K Q Q Q 10/1897 Dm.: INVALID: Date: 11/20/97 RESOLUTION: Disposition NU has concluded that Discrepancy Report, DR MP3-0345, has identified a condition not previously discovered by NU which requires correction. While revising OP 3319A to Revision 14, the procedure writer inadvertently missed the change to section 7.3.3.8.c which was previously approved on Revision 13 Change

1. The change allowed the use of 3CNS V889 as a flowpath for Printed 12/17/971 A7A0 PM Page1oIT

~m ~ m' ~-

Northeast Utilities ICAVP DR No. DR MP3-0346 Millstone unit 3 Discrepancy Report condenser tube sheet sealing. This was an isolated incident and no adverse trend of similar events exists. A Feedback Form. DC

1. Attachment 10, has been submitted to the Operations Procedure Group. OP 3319A is scheduled for upgrade to Revision 15 in November,1997. The change will be incorporated during that revision. This is not a restart item.

Attached is a copy of the approved corrective action plan for C ' M3 97 3715. The observation that the Reason for Change on the change cover sheet could be misinterpreted would not be a problem. That block serves only as a summary of the change and a place to document Basis information. Procedural guidance is always obtained within the procedure itself, not on the change fonns. The procedure does not impose any restrictions or suggest a preferred source for tube sheet sealing. Conclusion NU has concluded that Discrepancy Report, DR MP3-0345, has identified a condition not previously discovered by NU which requires conection. The change to section 7.3.3.8.c was inadvertently missed during the last revision. CR M3 97 3715 has been written with the corrective action plan approved to incorporate the change during the next scheduled revision in November,1997. Previously identmed by NUF Q Yee ie) No Non Discrepent Conddion?Q vos @ No Mesolution Ponding?O vee

No ejeoosuiionuaresoev.drO vee

@ No Rev6ew O inMlator: Neverro. Mark VT Lead: Ryan, Thomas J .J O O 15r557 vr u,,: scnope.,. oon x NtC Chmn: shgh, Anand K -e SL Comments: PrWed 12/17/97147.47 PM Pege 2 of 2

Northeast Utilities IC.WP DR No. DR MP3 0446 Millstone Unit 3 Discrepancy Report Revtew Gtoup: System DR RESOLUTION ACCEPTED Potential Operabatty leeue Diecipune: I & C Desagn O vee Descrepency Type: Drewog @ No SystemProcess: Rs3 NRC Sign 6Aconce level: 4 Date faxed to NU: Date Published: 11/2/97 D6*ctwya Discrepancy Between FSAR and P&lD Deecription: Section 6.3.5.2 of the FSAR states that recirculation pump discharge pressure indication is provided at the discharge of each pump and in the control room. P&lD EM 112C 16 shows a pressure indicator in the control room for each pump discharge pressure; there is no local pressure indicator shown on the PalD, Electricalloop schematics 3RSS-025A, Rev 2; -0258, Rev 2; 0250, Rev 2; 025D, Rev 2 agree with the P&lD and show no local pressure indicator, Review Vol6d involed Needed Date initietor: Pinetes. H. Q Q Q ioflW97 VT Leed: Nwt, Anthony A Q Q Q 10/1697 VT Mer: Schopfer, Don K O O O 50587 IRC Civnn: Sngh, Anand K O O O 10/30S7 Date: INVALID: e Date: 12/2/97 RESOLUTION: Disposition: NU has concluded that Discrepancy Report, DR MP3 0445, has identified a condition previously discovered by NU which has been corrected Section 6.3.5.2 was revised by FSARCR 97 MP3-244 to agree with the P&lD A copy of this FSARCR was transmitted to you via M3-lRF 00141 dated A.y 21,1997.

== Conclusion:== NU has concluded that Discreparscy Report, DR MP3-0445, has identified a condition previously discovered by NU which has been corrected, Section 6.3.5.2 was revised by FSARCR 97 MP3 244 to agree with the P&lD A copy of this FSARCR was transmitted to you via M3-IRF 00141 dated July 21,1997, Provlously identined by Nu? (Gi Yes U No Non Discrepent Condition?O Yes @ No Resolution Pending?O vos @ No Recoiotion unresoeved?O vos @ No Review initletor: Pooles H O N7 VT Lead: Nort, Anthmy A O mW VT Mgt: Schopfer, Dor. K IRC Chmn: Sngh, Arend K D.e: SL Conwnente: Prtnied 12/17/971:48:2e PM Page 1 of 1

Northeast Utilities ICAVP D't No. DR-MP3-0824 Millstone Unit 3 Discrepancy Report Review Oropp: 0;eretons & Meantene're and Teetng DR RESOLUTION ACCEPTED Review Enervent: Operstang Proce6te g, D6ecipline: Ope'eteor* Ow Diecropency Type: O 4 M & T Procedure @" No SyedertWProcees: SWP NRC $6gn6acence levet: 4 Date faxed to NU: Date Published: 10'3147 ~ D6*crepency: Inadequate documentation to venfy Service Water Pumps are attemated for uniform wear. D*eeription: The FSAR states that "the service water pumps are rotated inservice for uniform wear," NU's response to a request for information identified the operating procedure that is used to attemate the train A and train 8 service water pumps, but did not identify the procedure or document that required that the pumps be rotated inservice for uniform wear. No information was provided that identified what frequency or how often the pumps are to be alternated. The reqairement to attemate service water pumps to ensure uniform wear could not be venfied Review Va 1 inval6d Needed Date Inst 6stor: Speer, R. O O O 10/5787 VT Leed: Bees. Ken g Q Q 10/1747 VT Mgt; schopfer, Don K O O O $02257 IRC Chmn: Sangh. Anand K Q4 O O 1G'2697 Dese: INVAUD: Date: 12/9/97 RESOLUTION: Sackground: Discrepancy Report, DR MP3-0524, reports: The FSAR states that "the service water pumps are rotated inservice for uniform wear.' NU's response to a request for information identified the operating procedure that is used to attemate the train A and train B service water pumps, but did not identify the procedure or document that required that the pumps be rotated inservice for uniform wear. No information was provided that identified what frequency or how often the pumps are to be attemated. The requirement to attemale service water pumps to ensure uniform wear could not be venfied. Disposition: NU has concluded that the issue reported in Discrepancy Report, DR MP3-0524, has identi' led a condition previously discovered by NU which required con Ntion. OIR 075 (attached) Identified and corrected this conflict with FSAR Section 9.2.1.4. SP3626.A 7 and EN31084 were revised to review and adjust pump run times. Attachments:OIR 075SP3626.4SP3626.5 SP3626.6SP3626.7EN31084

== Conclusion:== Printed 12/17471:40.14 PM Page 1 of 2

Northeast UtilRies ICAVP DR No. DR4P3 0824 Minstone Unit 3 Discrepancy Report NU has concluded that the issue reported in Olscrepancy Report, DR.MP3-0524 has identified a condition previously discovered by NU which required correction. The Engineering Notice and surveillance procedures for these pumps were revised to comply with the FSAR statement to attemate pumps. Prev 6ously identined by NU? ? Yes O No Non D6ecropent CoruleuonFQ Yo. (el No RMM P*mians70 v.. + w. R..uion unt.ouv.470 yo. @ u. Roylew c opta W Date inm6elot: Spear. R. O O O $ 2*7 VT Lead: Bees. Ken O O O 12w7 VTMgr Schopfer, Don K O im7 1RC Chmn: $@, Anand K O O $2 m 7 nei.: sL Corrments: d e ( l f I PrWed 12/17/971.40 21 PM Pe 2 W 2

Northeast Utilities ICAVP DR No. DR MP3 0542 Millstone Unit 3 Discrepancy Report Rev6ew Oroup; s#em DR RESOLUTION ACCEPTED Reyww Ewn=at: smem Daen , en u ope,e6=yi. m :couD$n om D6ecrepency Type: calcuwton 4 y, systenVProceae: DGX NRC sigenconce levet: 4 Date faxed to NU: Date Published: tin $97 ~D6ec*epeacy: Second Level Unde 5~oltage Relay Setpoint (Calculation NL 042) Deecr6ption: Calculation NL 042 determines the setting of the second level undervoltage relays. The function of these relays is to detect a degraded voltage condition in which the voltage applied to the safety related electrical loads is less than the minimum rating for contiunous operation. If the degraded voltage condition persists for too long a period, the emergency diesel generators are started and the safely related loads operated from the diesel generator. The operator is wamed before the emergency diesel generators are started to allow the operator to correct the degraded voltage condition. On page 7, the ratio error and burden error are treated as non-random errors. However, the voltage transformer tums ratio is fixed and is actually a bias except for the measurement uncertainty. Generally, the burden on the voltage transformers is fixed. This allows the ratio error to be determined within narrower bounds than the accuracy classification. These effects allow reducing the instrumentation tolerance. Calculation NL 042 is ( conservative in this regard. On page 9, the calibration tolerance for the pick up of the voltage relays is given as 0.05% when the value fce the relay calibration tolerance is substituted into equation 6. However, the value of 0.05% is not consistent with the *as left" values Olven in, which can be as high as 108.28 volts, (100.26% of 108 volts). (See the report for the test performed on May 17, 1987 on page 11 of Attachment 2.) The discussion on page 10 only addressed the repeatability of the timer relays and the accuracy of the equipment used to verify the setting of the timer relays. Other common sources of inaccuracy such as power supply variations, temperature effects (for the non Agastat relays), etc. are not discussed. They should be addressed by the calculation. If some or all of these are negligible, an explanation should be provided. l The calculation ignores temperature effects on the undervoltage relay based on a relatively small normal temperature range at the relay location (10'F). However, the temperature effect also l needs to address the temperature difference between the location where the relay is calibrated and the normal relay location as well as the temperature rise in the relay cubicle above the room ambient temperature. The Justification on page 7 is based on the nonnal temperature variation in the instrument IO^A IOO ~ U Ih0 M h 0% ? D !O 00 I 300 IO O P IO!O h f,g 3 p g g,3g7 g $$pg

DR No. DR MP3-054[ Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report an abnonnal tempercture condition (e. g. failure of the HVAC equipment serving the relay location) that must be considered as well. The implicit assumption is made that the temperature effect is a simple function of the temperature span, that is reducing the variation from 85'C to 5.6'C (10'F) will cause a proportionate reduction of the temperature effect from *0.5% to a much lower value. This implicit assumption should be explicitly verifled based on testing or manufacturer's data. Page 7 of the body of the calcetation states that the drift error is taken to be 10.5%. Page 5 of Attachment 2 states that this value has been adjusted to an 18 month interval. However, the data shows a drift at Bus 34D of +0.5 to +0.6% over the interval of February 15,1991 to September 11,1991. Similar drift values are seen in the pick up values during this period. The drift at Bus D was.0.5 to 0.7% over the interval between Odober 6,1992 through September 3,1993. Based on this data the value of drift used in the calculation, t0.5% seems too low unless the calibration intervalla shortened. The calculation makes the assumption that drift of the Agastat time dc'ay relays can be neglected. However, relay 62H shows drift of about 1% of setting between calibration checks that are conducted annually. This 1% error is comparable to some of the other uncertalntles that are considered. The 62T relay shows l lower drift. Calibration driftphould not be neglected, at least for the 62H relays. ReVloW vand Involad Needed Date innlebor: Bioethe, G. W6116am O O O ' I"7 VT Leed: Nort, Arthony A O O O 11'IM7 i VT Mgr; Schopfer, Don K O O O t'io'S7 IRC Chmn: S ngh. Anand K Q Q Q 11/11/97 D.t.: INVALID: -f D*I*: 12/2/97 Resolution: NU has concluded that Discrepancy Report, DR MP3-0542, has identified a condition previously discovered by NU which requires correction. The discrepancies with the calculatiori NL. 042 were identified during the 10CRF50.54f calculation review program. Adverse Condition Report (ACR) M3 97 0119 and Licensee Event Report (LER) No. 97 010-00 were issued to document discrepancies in electrical degraded grid voltage j (DGV) calculations. DCR M3 97030 has been initiated to replace the existing DGV protection relays with improved repeatability ABB 27N relays (this is a Startup issue). Calculation NL 042 was corrected by the issuance of ne4 celculation NL 042. Rev. No. 2, i CCN No. 8. Prev 60uely 16 mesned try Nu? ici vos Q No Non Discrepent Cond46on?Q Yee ie) No Re.wouan PendmetO va @ N. needuuon var..wv.dtO va @ No Review Prned 12/17/971:50 01 PM Page 2 of 3

Northeast Utiinies ICAVP DR No. DR MP3 0642 Millstone Unk 3 Discrepancy Report insteetor: Blosthe, G. Weam VT Least: Nort. Anthony A VT Mge: $ct War. Don K O O minST IRC Chmn: SWgh. Anand K O O m aS7 Date: SL Comments: j s 4 4 Pitnied 12/17/971:5005 PM Page 3 of 3

Northeast Utilities ICAVP DR No, DR MP3 0013 Misistone unM 3 Discrepancy Report Revtew Geoup: Accdert Mageuon DR RESOLUTION REJECTED Potential Operategy issue Diocetine: I & C Doogn Ow Diacrepancy Type: Desgn Control Procedure System 9tocese: N/A NRC Sig'ecence level: 3 Date faxed to NU: Date PubliaW: fv2297 Disc'*Pency: Impact of Re-Analysis of Transients and Accidents Deecriptkm: We have reviewed the following MP 3 documents: A) NGP 3.12 Safety Evaluations, Rev,9, April 7,1995; B) NGP 4.03 Changes and Revisions to Final Safety Analysis Reports.Rev.7,Nov. 4,1996. C) Updated page markups for FSAR, Chapter 15, ACCIDENT ANALYSIS,as reviewed and submitted by Westinghouse under letter # NEU 96-623, dated November 25,1996. The Chapter 15 Accident Analysis markups by Westinghouse, referenced above, include accidents which have been reanalyzed and/or accidents with additional hformation. Although the limits and consequences may remain within the previously analyzed boundaries the methods, processes, or systems used to mitigate the consequences of an accident may require changes based on the analysis and additional information submitted to NU by WestinghoJse. For example, Figure 15.0-9 that is used to represent the results of the accident " EXCESSIVE LOAD INCREASE

which was analyzed in section 15.1.3 and marked up in the Westinghouse letter, added a
Low Pressurizer Pressure" and " Manual" to trip the Reactor Trip System to mitigate the transient. Also, a Note 3 was added which states the following: " Note that safety valve setpoints are not reached in the analysis of the Section 15.1.3 event."

NGP 3.12 provides guidance for safety evaluations including those resulting from transient and accident analysis. This is discussed in some detail in Attachment 8.A to this procedure. There are no identifiable steps or guidance in this procedure to evaluate the potentialimpact on training material, simulator scenarios, other calculations, etc. NGP 4.03 provides guidance to screen and implement changes to Final Safety Analysis Report that summarizes the numerous calculations, analyses, evaluations, design Information and plant descriptions. There are no identifiable steps orguidance in this procedure to evaluate the potentialimpact of analysis results on training material, simulator scenarios, other calculations,etc. Both of these procedures may be supported by lower tier procedures, if that is the case, identify the procedures that cdc! the imp 00644he recu!!c Of4aahc!c cn p'ent p g, pg p ,,3

Northeast Utildles ICAVP DR No DR MP3 0013 Millstone unM 3 Discrepancy Report procedures. The impact of Westinghouse reanalysis for each reload cycle requires an assesment. Review Val 6d invahd Needed Date instnetor: Belode. V. E. O O O 65S7 VT Lead: Rehow. Raj D Q Q Q &597 VT Mor: schop'er. Don K O O O 6557 IRC Chmn: sagh. Anend K O O O atit/sr Date: PNALlo: Dele: 11/18/97 RESOLUTION: Disposition:0 NU has concluded that the issue reported in Discrepancy Report, DR MP3-0013, does not represent a discr oant condition. There are four reasons for chandnc the FSAR: 1, Changes that affect the design basis of the plant: DCRs, DCNs, EWRs, etc. are govemed by the Design Control Manual (DCM) and, therefore, appropnate reviews, including training impact review, are required per DCM form DCM 3 20. Fuel reloads are considered design changes so a DCR is prepared and processed per the DCM. This is done even if the specific design of the fuel assemblies is not being changed. The DCR identifies those transients reanalyzed for the particular reload and includes the Wettinghouse documentation transmitting the analysis results. As specified in the DCR, review by other departments,4ncluding training, is required.

2. Changes that affect the licensing basis: DC 10, incorporation and implementation of License Amendments, and NGP 4.02, Proposed Tech Spec Change Request and Requests for Enforcement Discretion, govem changes to the Tech Specs and provide guldence for implementing those changes, including FSAR change requests. DC 10 has specific instructions for a training review.

3. Changes that affect operator action: DC1, Aaministration of Procedures and Fonns, has guidance for including training i

impact on all procedure changes.

4. FSAR changes that are not generated as a result of design change, license amendment or procedure change would not automatically be routed to departments, such as training. There are not specific procedure requirements for the training department to evaluate ' stand alone* FSAR changes and FSAR changes associated with a Notification of Suspected Error as defined in NGP 4.03. The example cited in the DR with respect to Figure 15.0-9 falls into this category. This example represents 1

changes to the FSAR to clarify the existing text, correct inaccuracles and add additional information for completeness. !l These chant es are not being made to reflect new analysis. Thus, it would not affect the previous assessments made under the DCRs for previous reloads. This applies not only to Chapter Pnnted 12/17/971:33 s2 PM Pege 2 of 6

Northeest Utilities ICAVP DR No. DR MP3 0013 Millstorw Unit 3 Discrepancy Report 15 but to any chapter of the FSAR that could be used as source material for training. To capture these types of changes, step 6.3.2 of NGP 4.03 states that a CR should be inMated. Thus, reliance is placed upon the CR investigator to identify the need for training department review. Based on the above, it is clear that those substantive changes (plant modlfications, reload analyses etc) that could be the reason for revising the FSAR are covered by existing processes. While preparing this response, however, NU recognized that changes falling into the fourth c 'egory, albeit of a subtle and non intent nature, do have a chance 9eing underestimated in terms of theirimpact on the Nuclesi Milng Department For this reason, CR M3 97 3141 was initleied to evaluate the need for process improvements regarding the review of non-intent FSAR changes for training impact. NU views the proposed resolution to be one of enhancement to existing processes and, as such, believes that the desenbed condition does not constitute a discrepancy.

== Conclusion:== 0 NU has concluded that the issue r@orted in Discrepancy Report, DR MP3 0013, does not represent <. discrepant condition. Since core reloads are performed as Design Changes under the Design Control Manual (DCM), the controls in the DCM provide assurance that all re-ans ysis performed as part of a reload will receive review for impad on plant procedures and training (including simulator scenarios). Invest:gation of this DR was expanded to include a review of the process for FSAR changes that are not associated with design changes. NGP 4.03 has guidance for processirig each different type of FSAR change (design change, licensing change, change to operator actk,n, etc.) Changes that are significant and affect the design or licensing basis or that affect operator action have programs and processes in place to ensure the appropriate reviews are completed it was discovered however, that some non-Intent changes could be r-isjudged in terms of their impact on Nuclear Training. CR M3 97 3141 was written to evaluate the need for process improvements regarding the review of non. Intent FSAR changes for training impact. NU views the proposed resolution to be one of enhancement to existing processes and, as such, believes that the described condition does not constitute a discrepancy. Previously klont6 fled by Nu? O Yes i No Non Discrepent Condnion?Q Yes @ No Roeolut6on Pendmg?O v.s @ No Resolution Unresolved 70 m @ No Review ACC## CC*PtaW Nooded Date initietor: delo$s, V. E. O O O

Sw VT Leed: Rahepa.RelD O

O O mm VT h6gr: Schopfer Don K b IRC Chmn: S6ngh, Anand K O O O 121s57 m. ,,,4. Pnnled 12/17!971:33 56 PM ~ ~ ~ ~ ~ Page 3 or 5 )

ICANP DR Nr. DR MP3 0013 Northeast Utilities Millstone unit 3 Discrepancy Report St. comments: ICAVP finds the disposition not acceptable. ICAVP sgrees with the four reasons or categories that NU . provides in the response for changing the FSAR. However, we believe that the example cited by us shov'il have been identified and processed under category (1) as stattM in your disposition. Therefore, the process that identifies changes to the Accident Analysis of Record and the resulting action items - including methods, equipment, training, FSAR updates, etc.- remains in question. ICAVP reviewed these additional NU documents to support our conclusions: i) Design Control Manual, NUC DC,M, Rev 5, S/7/97; li) Millstone Unit 3: Chapter 15 FSAR Design Basis Review, TAG-NU 96-06, September 13,1996 by YANKEE ATOMIC - BOLTON; lii) UIR No.: 1041 Resolution of Yankee Report Comments on Ch 15 review. (AR 97004565). The ICAVP does not dispute the fact that Fuel Reloads are considered design changes so a DCR is prepared and processed por the Design Control Manual (Ref i). DCM, Rev.5, section 2.4

10CFR50.59 SAFETY EVALUATION", TASK 3 instructs "If requPed (i.e. for DCR), COMPLETE 10CFR50.59 Safety Evaluation in accordance wfth NGP3.12.

NGP 3.12, Rev.10, March 1/97, SAFET/ EVALUATIONS, section 6, INSTRUCTIONS, includes the seven questions under section 6.4.7 to determine if the change remains within the previously analyzed safety boundaries or if it is an Unreviewed Safety Question (USQ). If it remains within the previously analyzed boundaries and is not an USQ the Preparer may make a qualitative Safety determination per section 6.4.3.1. The clarification in NGP 3.12 Attachment 8.A, Section A.5 SAFETY DETERMINATION GUIDANCE states "The qualitative determination may mah use of the arguments used to determine that the Change is not a USQ to show that the Change would noi increase public risk". The original Licensing Basis Accident Analysis and the Technical Specifications define the boundary that separates what is acceptable, from the standpoint of public risk, and what is not. In this context, nsk is inwnded as the combination of the probability of occurrence and the Consequences of accidents that could affect public health and safet/. In the case of accident analysir, an accident is defined as a sequence of events beginihng with an InitiatM, followed by the possible failures of operators and/or equipment to terminate the event, and resulting in Consequences (e.g., doses) to the public. The evaluation of the changes in assumptions and the results of analysis used to mitigate the consequences of an accident derived in response to the Unreviewed Safety Questions frv the Printed 12/17/97 t33 Sa PM Page 4 of s

Northeast Utilities ICAVP DR No. DR MP3-0C$1 Millstone Unit 3 Discrepancy Report original Ucensing Basis Accident Analysis or subsequent fuel reload analysis should consider the four elements of risk as discussed in Section A.5 SAFETY DETERMINATION GUIDANCE. As NU stated in their response, procedure NGP 4.02 govems changes to the Tech Specs and provides guidance for implementing these changes. A similar procedure can not be traced for the records and actions associated with Accident Analysis. Since NU did not identify any other procedure, NGP 3.12 is the vehicle that must provide instructions to maintain a record and incorporate the original and updated Li Snsing Basis Accident Analysis assumptions and results. The Chapter 15 FSAR Design Sasis Review Report (Ref li) provides a one time summary of the status of the Accident Analysis of Record that, we believe, should have been discovered and evaluated under a MP 3 process. It does not address the maintenance and updates of these records. The UiR 1041 (Ref lii) addresses the incorporation of some changes in the FSAR. It does not discuss the incorporation or instructions for plant worir, processes. We recammend that NGP 3.12 needs changes either to a Lower Tier Procedure, or a clear requirement for the use of a risk analysis process for each Ucensing Basis Accident Analysis or fuel reload analysis. This should include an associated " Form" for each accident, to perform SAFETY DETERMINATION for accident mitigating items, act,lons, and time constraints, if any, as discussed in NGP 3.12 Attachment 8A, Sections A.S.1 through A.S.4 to assure their incorporation in.le plant work processes. t Pftted 12/17/971:3400 PM Page 5 of 5

Nottheast Utilities ICAVP DR No. DR-MP3 0015 Millstone Unit 3 Discrepancy R& port Review oroup: Acrdent Mitgaton DR RESOLUTION REJECTED Re EW: sW Des 96 Potential Operabilsty lasue D6scheine: Otho' Om Discrepen y Type: Calculaton M No SystenWProcess: N/A NRC Signiacence level: 3 Date faxed to Nu: Date Published: 8/2?/97 ~ D6ecropency: Compliance with GC Deecti th: A review of the followiro uue 'in has concluded that a P discrepancy exists with s 'd I. umented compliance with the Millstone 3 Operatin w. st 1AR and GDC 19 as they r0 late to the estimated doc. ' T %J by the operators following postulated design basis accid The documents reviewed are:

1) MP3 FSAR Tables 6.41 and 9.4-2

2) MP3 FSAR, Chapter 15.6, Loss-of Coolant Accident (LOCA)

3) MP3 Ventilation Systems DBD

4) MP3 Tech. Spec. 3/4.7.7 Control Room Emergency Ventilation System

5) MP3 Control Room Dose Calculations [UR(B)-365-1; UR(B)-

366-1; UR(B) 3671; and 88-019-97RA, Rev. 0] 4

6) UIR 343 The MP3 Technical Specification Indicates that the design and tested flow rate for the control room emergency filter system is 1120 cfm +/- 20% Based on this specification, the flow

Auld range from 8c;6 to 1344 cfm. This value is different from that reported in the FSAR and the DBD. The referenced dose calculations are the calculations of record to show compliance with contrni room hat,dility requirements at Millstone 3. The calculations use a val of 1000 cfm for the flow rate of this safety system. This value differs from the reported Technical Specification value. Since the flow rate through these filters directly affects the estimated post LOCA dose to the operators, a concem exists regarding NU compliance with the Millstone 3 FSAR estimates for post LOCA operator doses and General Design Criteria (GDC) 19. Use of a filter flow rate other than that which is put out by the control room emergency filter unit may be non-conservative.

GDC 19 requires that the operators be provided with a control room from which actions can be taken to operate the nuclear power plant safely un' der normal conditions and to maintain it in a safe condition under accident conditions, including a loss of-coolant accident (LOCA), it is this latter capability that is under question in this discrepancy report. NU has iderwified an unresolved issue report (UIR 343) that a discrepant condition exists with regard to the reported flow Pnn:ed 12/17/971:34 33 PM of 4

Northeast Utilities ICAVP DR No. DR MP3 0015 Millstone Unk 3 Discrepancy Report the control room emergency filter system. The UIR concludes that actio;,s in ACR 8843 and A/R 9600766 will process the FSAR change required to resolve the condition and states that no additional action is required. While these actions note the FSAR discreparcy, there is no objective evidence that NU has appropriately addressed the issue in the design calculations. i Rev6ew Valbd invalid Needed Date j inidator: Bennett, L. A. Q Q Q &M7 VT Lead: Rahep. Raj D Q Q Q &M7 VT Mget schopfer. Don K O O O SS7 IRC Chmn: singh. Anand K O O O 6"7 Date: INVAUD: Date: 11/21/97 REs0LUTION: Disposition: NU has concluded that Discrepancy Report DR MP3-0015 has identified a condition previously discovered by NU which requires correction. G&L's statement that UIR 343 does not adequately address the design calculation is correct, however, UlR 1005 was written to clarify this apparent discrepancy. The problem was documented on UIR 1005, and is due for completion on 10/16/97. A

== Conclusion:== NU has concluded that Discrepancy Report DR MP3 0015 has identified a condition previously discovered by NU which requires correction. The problem was recorded on UIR 1005, which is currently under evaluation. This issue is start up related and scheduled for completion on 10/16/97. NU concurs that this item is Significance Level 3. Previously identined by NU7 fe) ves Q No Non Discrepant Condition?Q vos @ No Resolution Pending?O vee @ No Resolution Unresolved?O ve. @ No Review t.cceptable Not Acceptable Needed Date Initiator: Bennett. L. A. O O iii2i/97 VT Lead: Rahefe. Raj O O 2 itis 7 VT Mgt: Schopfer. Don K O e O 1:/10/87 IRC Chmn: singh, Anand K O Q O 12iists7 Date: 11/21/97 st Cornments: The ICAVP Team has reviewed NU's response to this DR and the proposed resolution in the associated UlR 1005. NU has still not provided sufficient information for the ICAVP to conclude that the proposed actions will appropriately resolve the issue idet,tified in the DR. The basis for this determination is discussed below. ICAVP reviewed the following documents:

1) ACR# 8843 Pnnled 12/17/971MQ PM Page 2 of 4

Northeast Utilities ICAVP DR No. DR MP3-0015 Millstone Unit 3 Discrepancy Repoft

2) UlR 1005

3) MP3 Control Room Dose Cr'iculations [UR(B)-385-1; UR(B)-

3661; UR(B) 3671; and 88-019-97RA, Rev. 0]

4) F 3614F.1

5) SP 3614F.2 The discussion and recommended disposition in both ACR# 8843 and UIR 1005 indicates that NU has focused the engineering review and concem at the component level of the filtration portion for the control room emergency ventilation system (CREVS).

The discussion indicates tnat NU has determined that the Tech. Spec. flow rate of 1120 cfm +/- 20% could result in a velocity a xoss the charcoal adsorber bed in excess of that specified for the component. Although not explicitly stated in the UlR, the discussion infers that there is a potential for degradation of the CREVS filter efficiency. While the ICAVP team agrees that this is important, the NU reviews to date did not conclude this to be an LER reportable condition because there is no requirement to assure that the unfiltered air intake is <= 250 cfm as assumed in the Reference 3 calculations. The dose calculations of record (Reference 3) use 250 cfm as the filtered air make-up flow rate. The Tech. Spec. and the References 4 and 5 surveillance procedures do not specify that the condition of the control room emergency filter unit be such that the filtered air make-up is <= 250 cfm. Using this information, a cursory review of the design calculations concludes that, if the recirculated air flow is approximately 750 cfm as cited in the Reference 3 calculations, the filtered air make-up could be as high as 594 cfm. Since this represents an increase in the' source term being introduced into the control room of 130% over and above that estimated in the calculations, there is a potential to increase the estimated thyroid dose received by the operators by a factor of 2.0 or greater. The ICAVP concludes that NU has sufficient information to recognize that the currently estimated 26 Rem thyroid dose to the operators could exceed the GDC 19 limit of 30 Rem and the plant is outside the design basis. NU performed an LER reportability determination in the Reference 1 ACR. This determination cites the conservatisms in the design calculations as a basis to determine that no reportable condition exists. The ICAVP team does not agree with this determination because it does not specifically cite or quantify the con;ervatisms being credited. in addition, it is our judgment that these conservatisms are required by regulatory guidance and the MP3 design basis. Therefore, NU has a condition which is outside of the MP3 design basis ind is reportable under 10 CFR 50.73. The ICAVP Team concludes that NU is currently taking a component view of the problem versus the functional design implications. We expect that NU would have already determined that revisions to the calculations are reauired rather than the Pnnled 12/17/971:34 45 PM Page 3 of 4

Northeast Utilities ICAVP DR No. DR-MP3 0015 Millstone Unit 3 Discrepancy Report statement provided in UIR 1005 that calculations will be updated

if determined necessary". We request that NU reconsider this issue.

l Prmted 12/17/971:34 do PM Page 4 of 4 l

Northeast Utilities ICAVP DR No, OR MP3-0263 Millstone Unit 3 Discrepancy Report Review Oroup: Accident Megaton DR RESOLUTION REJECTED ~

Potonnel Operately issue Diecipline: Otho' Om Diecrepancy Type: Ucanung Document 4g SystemProcess: N/A

~ NRC Signmcance level: 3 Date faxed to NU: Date Published: iof397 D6screpancy: Venfication of the basis for the two second Fuel Drop Monitor response time. Descripoon: The ICAPV has reviewed the following documents in order to evaluate the response time for the radiation monitors 3RMS*41&42 used in the postulated FHAIC: A) Procedure SP3449E11, Rev. 4 Fuel Drop Radiation Monitor (3RMS*RlY=1 and 42) Analog Channel Operational Test with associated l&C Form 3449E11 1. B) Procedure SP3449E02, Rev.1 Containment Area Purge and Exhaust isolation Radiation Monitor Calibration (3RMS*RE42) with associated I&C Form 3449E021. C) Procedure SP3449E01, Rev. 3 Ccatainment Area Purge and Exhaust isolation Radiation Monitor Calibration (3RMS*RE41) with associated I&C Form 3449E01 1 D) Technical Requirements. Manual-Clarification 3.3.2 Rev. 6 Instrumentation, Engineered Safety Features Actuation System Ins *rumentation TRM Table 3,3.2-1 Engineered Safety Fea'ures Response Times E) FSARCR 97 MP3-4 Affecting Fuel Handling Accident in Containment F) Calculation 3-ENG-244 Rev.1 Analyr of Stroke Time for Containment Purge and Exhaust Dampers dated 5/30/97 G) Unit 3 Millstone FSAR Section 15.7.4 in reviewing the above documents, the ICAVP identifies the following discrepency: The two (2) second radiation monitor response timt stated in the FSAR Section 15.7.4 and confirmed in Item E cannot be verified by reviewing the operat'ility procedure contained in item A or the calibration procedures contained in items B and C. This value can be extracted from Technical Requirements Manual (TRM)- Clarification Section 3.3.2 Rev. 6. " Instrumentation, Engineered Safety Features Actuation System instrumentation". TRM Table 3.3.2 and item F both state that it takes 5.89 seconds for completing the action and item E states 3.89 seconds for closing the valve. However, there is no test data to confirm the two second Fuel Drop Monitor response time. Review Pnnted 12/17/971:38.26 PM Page 1 of 3

Northeast Utilities ICAVP DR No. DR MP3-0263 Millstone Unit 3 Discrepancy Report Valid invalid Needed Date intuator: sctwortr. Barry O O O

17/S7 VT Leed: Rahope, Raj D D

D 0 $17'S7 VT Mgt: schopfer DonK y O O W2297 IRC Chmn: singh, Anand K O O O s/27/s7 Dele: INVALID: es== Date: 11/20/97 RESOLl.fT10N. Disposition NU has concluded that Discrepancy Report DR MP3-0263 has identified a condition previously discovered by NU for which correction is complete. ACRs M3-961119 and M3 96-1120 were issued on 11/8/96 to address this problem. Design Change DCR M3-97032, Fuel Drop Monitor 3RMS*RlY41/42 Hardware Change, was approved on 8/8/97, completed and tumed over to Operations on 9/10/97. This DCR included hardware changes to the monitor, a FSARCR and a change to the Technical Requirements Manual. The system is now operable, and significance level criteria do not apply as this is no longer a discrepant condition.

== Conclusion:== NU has concluded that Discrepancy Report DR MP3 0263 has identified a condition previously discovered by NU for which correction is complete. Desfgn Change DCR M3-97032, Fuel Drop Monitor 3RMS*RlY41/42 Hardware Change, was completed on 9/10/97. The system is now operable, and significance level criteria do not apply as this is no longer a discrepant condition. Previously idenufled by NU7 Q Yes @ No Non Discrepant Condition?Q Yes @ No Resolut6on Pending?O ve. @ No Resolution unresolved?O ve. @ No Review initiator: setwortz, Bany VT Lead: Reheta. Raj D VT Mgr: schwfor. Don K IRC Chmn: singh. Anand K oste: 11/20/97 st Conenents: ICAVP has reviewed the NU response to this OR and has the folicwing comments. NU issued LER 96-046-00 to the NRC by letter dated December 6,1996 reporting that the Containment Fuel Drop Radiation Monitors could not meet the monitor response time requirements of 2 seconds stated in the Technical Requirements Manual. NU's current position on travel time as referenced in Calculation 3 ENG-244 Rev.1 (Item F) is 9 seconds, which was calculated as 9.12 seconds. The corresponding valvo closure time is calculated as 7 seconds or less. (Note, to the best of our knowledge Rev.1 to this calculation has not been approved by NU.) Since this calculation is a parametric study which provides a monitnr rpennne time and a t'nrrpennndinn valve t'Inern tima Pnnted 12/17/971:38 34 PM Page 2 of 3

Northeast Utilities ICAVP DR No. DR-MP3 0243 Millstone Unit 3 Ciscrepancy Report any combination of monitor response and valve closure time can be " elected, provided the monitor responds within this time period to a FHAIC. We agree with the NU position of amending the FSAR, the Technical Requirements Manual and Procedure SP 31024 to be consistant with this new position. However, NU has not provided evidence that the monitor will respond to a FHAIC within 9 seconds with the established monitor setpoint of.92R/hr as discussed in DR-MP3-0159. Thus closure of this DR is linked to NU's response to DR-MP3-0159. 4 l l l l Printed 12/17S71:36.37 PM p.g 3 og 3

Northeast Utilities ICAVP DR No %MP3-0328 Miiistone Unit 3 Discrepancy Report Review Oroup: System DR RESOLUTION REJFCTE. Review Element: System Design p Discipione: Mechancel Desgn g Discrepancy Type: Component Date O No Systemfrocess: HVx NRC Significance level: 3 Date Faxed to NU: Date Pubushed: 1o/2397 Descrepancy: SLCRS and ABVS Filter Unit Drain Valves Deecr6poon: Dunng review of the component data for the Supplementary Leak Collection and Release Sydem (SLCRS) filter units (3HVR*FLT3A/38) and the Auxiliary Building Ventilation System (ABVS) exhaust filter units (3HVR*FLT1 A/18) a discrepancy regarding the safety and sismic classification of the isolation valves in the filter unit drain lines was identified. The SLCRS and charging pump, component cooling water pump and heat exchanger exhaust ventilation system (ABVS) are classified as ESF Filter systems per FSAR Section 6.5.1 FSAR Section 6.2.3.1 states that the SLCRS is classified QA Category 1, Safely Class 3, and Seismic Category 1. FSAR Section 9.4.3.1 states that the auxiliary building filtration units are Safety Class 3. FSAR Section 3.2.3 and FSAR Table 3.21 Indentify the ESF filtration trains as QA Category 1, Safety Class 3 components. FSAR Table 6.5-1 states that.the systems are in essential compliance with Regulatory Guide 1.52, Rev. 2 position C.2.C in that all componc.ats are seismically qualified. FSAR Table 1.81 states that the systems are in compliance with Regulatory Guide 1.52, Rev. 2 and does include the exception / clarification to position C.2.c contained in FSAR Table 6.5-1. Regulatory Guide 1.52, Rev. 2, position C.2.c requires that all components of an engineered safety-feature atmosphere cleanup system should be designated as Seismic Category I if failure of a component would lead to the release of significant quantities of fission products to the working or outdoor environments. P&lD EM-148E shows valves 3HVR V964, V965, V966, V967, V968, and V969 in the drain lines for SLCRS filter unit 3HVR*FLT3B and valves 3HVR V970, V971, V972. V973, V974, and V975 in the drain iines for SLCRS filter unit 3HVR*FLT3A. P&lD EM-148A shows valves 3HVR V988, V989, V990, V9991, V992, and V993 in the drain lines for ABVS filter unit 3HVR*FLT1B and valves 3HVR V994, V995, V996, V997, V998, and V999 in the drain lines for ABVS filter unit 3HVR*FLT1 A. The valves maintain the pressure and leakage integrity of the filter units anc' prevent unfiltered air from bypassing the HEPA and charcoal filter sections. Based on this and the above Ponted 12/1Ml71:37.41 PM hh1 bf 3 4

Northeast Utilities ICAVP DR No. DR-MP3-0328 Millstone Unit 3 Discrepancy Report Safety Class 3, Seismic Category I components. The Plant Design Data System (PDDS) database identifies the valves as QA Category 2 components. The valve description # shown in PDDS is VGF015-N-4. The PMMS database identifies the valves as non seismic, non-category I components. Specification 2282.050-153 identifes valve type VGF015-N-4 as a 2.5" ANSI B31.1 Class 4 gate valve. Review Valid invand Needed Date inMietor: stout. M. D. O O 1o/347 j VT Lead: Neft. Anthony A B O O Sor3rJ7 VT Mgr: schopfer, Don K Q O O 1o/1397 1Rc Chmn: sngh, Anand K O O O ottaS7 Date: INVAUD: Date: 11/29/97 RESOLtm0N NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0328, does not represent a discrepant condition. The piping and drain valves that are in question are subject to the requirements of Reg. Guide 1.52. As indicated on P&lD EM-148A note 4, the valves and associated drain system piping have been seismically supported and qualified which ensures the structural integrity of the system. Also, refer to the attached Pipe Stress Analyses for Aux Building floor and equipment drains.The drain valves are ancillary passive components and are non-safeiy related but seismically supported. Further, the normally closed valves do not require mechanical movement for SLCRS and Auxiliary Building HVAC (HVR) to perform their intended safety functions.There is no credible failure of these passive valves that would impose operational limitations to the system or would result in a loss of the capability of the SLCRS and HVR to perform ineir intended safety function. This is consistent with MEPL determinations MP3-CD-1027 and 1035. The exception to this are the drain valves off of the moisture separators. These valves are normally open, however, they are connected to the upstream side of the filter and discharge to the radioactive waste sump, located within the SLCRS boundary. Consequently, any leakage up the drain would still pass through the fi".er. Therefore, PDDS and PMMS are correct in categorizing the drain valves as QA CAT 2 and the filter as CAT 1 safety related but seismically supported. Significance level criteria do not exist as this is not a discrepant condition. ~ At%chments: 12179-NP(B)-X54000, Pipe Stress Analysis: Floor and Equipment Drains Auxiliary Building 12179-NP(B)-X54001, Pipe Stress Analysis: Floor and Equipment Drains Auxiliary Building 12179-NP(B)-X54002. Pipe Stress Analysis: Floor and Printed 12/17471:37A7 PM Page 2 or 3

Northeact Utilities !CAVP DR No. DR-MP3-4328 Millstone unM 3 Discre pancy Report Equipment Drains Auxiliary Building 12179-NP(B)-XS4003, P pe Stress Analysis: Floor and Equipment Drains Auxiliary Building 12179-NP(B) X54004, Pipe Stress Analysis: Floor and Equipment Drains Auxiliary Building MEPL Determination MP3-CD 1035, section 4.03, 3HVR*FLT3A/B Drain Valves McPL Determination MP3-CD 1035, Attachment 3, Non-QA Co nponent Listing MEPL Determination MP3-CD-1027, section 4.02, 3HVR*FLT1 A/B Drain Valves MEPL Determination MP3-CD-1027, Attachment 3, page 3-6, Non-QA Component Listing Previously klontifled by NU7 O Yes (95) No NonDiscrepentCondiuon?Q Yes @ No Resolution Pending?O Yo. @ No R oiution unr..oiv.d70 Y @ No Review " ^ inMietor: Stout. M D. VT Leed: N'wt. Anthony A O O O = VT Mor: schopfw, Don K wic chmn: srpi, Anand K Date: 41/29/97 st connents: FSAR Table 3.21 states that the ESF filter units are ANS Safety Class 3 components. Since the valves maintain the pressure and leakage integrity of the filter units and prevent unfiltered air from bypassing the HEPA and charcoal filter sections they should be classified the same as the ESF filter units. MEPL Determination MP3-Cb 1035 ane MP3-C'e* 1027 do not address this function of the valves. i Pnnted 12n7/971:37.51 PM Page 3 of 3

Northeast Utilities ICAVP DR No. DR MP3 0348 Millstone Unit 3 Discrepancy Report Review Group: Programmetc DR REs0LUTION REJECTED Potential OperabilMy issue rAsciphne: Otho' Ow Diecrepency Type: Calculaten g SystemProcess: sWP NRC Signancance levet: 4 Date faxed to NU: Date Published: 10/1097 DiscroPancy: Improper Preparation of Calculation Change Notice # 2 for Calculation No. 90-069-1130-M3, Rev. 0 kacription: Calculation Change Notice (CCN ) #2 's

Reason for Change
block states '50.54 (f) Review determined that Calculation No.

90-069-1130-M3, Rev. O supersedes Calculation 12179-(P). 1148, Rev.1 and NM-037-HVK". CCN #2 *s ' Description of Change & Technical Justification

block states " Calculation No.

90-069-1130-M3. Rev. O supersedes Calc.12179-(P) 1148, Rev.1* and provides a justification also. Neither the " Reason for Change' block nor the " Description of Change & Technical Justification" block state the change (s) to be implt;mented into the Calculation No. 90-069-1130-M3, Rev. 0. This appears to be an improper application of the calculation process as there is no change to the Calculation No. 90-069-1130-M3, Rev. O stated in CCN # 2. [The calculations which are superseded should be superseded through DCM Chapter 5, Section 6,

Superseding or Voiding Calculations" process)

Review Valid invalid Needed Date 4 inatiator: Caruso, A. O O O 10/1/S7 VT Leed: Ryan, Thomas J G O O o'1/S7 VT Mgt; schopfer. Don K Q O O 10/1/S7 IRC Chmn: sogh, Anand K O O O 'o/d/S7 Date: INVAUD: Dm: 12/1/97 REsOLUTON Disposition: NU has concluded that the issue reported in Discrepancy Report, DR MP3 0348, does not represent a discrepant _ condition. Part of the CMP effort included validating and updating the Calculation Tracking Program (CTP). Calculations were reviewed to ensure that, administratively, calculations were property linked to each other when necessary. CCNs were written to document any missing references between calculations that were found. That was the case in this DR. CCN #2 to 90 1130-M3 revision 0 was written to document an administrative oversight during the preparation of the CTP database sheets to the original calculation. CCN #2 does not impact the body of the calculation in any way. CCN #2 revises the CTP data base input r.heet to ensure that 12179-{P)-1148 revision 1 and NM 037 HVK have been superseded by calculation 90-069-1130-M3 revision O. Calculation 9049-1130-M3 does not require a new revision to document that it superceded 12179-(P)-1148 and NM-037 HVK. Prtnted 12f17!971:36.31 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP34348 Millstone Unit 3 Discrepancy Report DCM Chapter 5, Section 6 requires a revision for the calculation being superseded not for the superseding calculation. Significance Level criteria do not apply here as this is not a discrepant condition.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0348, does not represent a discrepant condition. The DCM Chapter 5 requirement for superseding calculations by issuing new revisions pertains to the calculation being superseded. There is no specific requirement that the superseding calculation needs to be revised to indicate it has superseded another calculation. A CCN was issued in this case to document, for administrative purposes only, that 90-0691130-M3 superseded 12179-(P) 1148 and NM 037 HVK. Significance Level cnteria do not apply here as this is not a discrepant condition. Previously klentmed by NU? i.s Yes @ No Non Descrepant Condt%?Q Yes @ No Resolution Pending?O Yes (#) No Resolution Unresolved?C Yes @ No Review Acceptable Not Acceptable Needed Date VT Lead: Ryan, Thomas J VT Mgr: schopfer. Don K IRC Chmn: sagn, Anand K Dde: 12/1/97 sL conwnem-* 'JU's response is not acceptable. The process to make changes to a calculation is covered in DCM Chapter 5, Section 5. The process to supercede a calculation is covered in DCM Chapter 5, Section 6. Section 6 does not include the use of CCN's to supercede calculations nor to use CCN's in update the CPT Data Base. Per DCM Chapter 5, Section 5, CCN's are only used to change calculations. The issuance of CCN # 2 to Calculation 90-069-1130 M3 to "....... supercede Calculations 12179-P(T)-1148, Rev,1 and NM-037 HVK."is a discrepancy against the procedural requirements of the NU DCM, Revision 5. PrinTd 12/17/971:36.38 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3-0480 Millstona Unit 3 Discrepancy Report Review Group: system DR RESOLUTION REJECTED Review Element: System Desgn Potenuel OpereWlay issue Disc 6pline: Mechenecal Desgn Om Diecrepency Type: Component Data @ No SysterWProcess: HVX NRC significance levet: 3 Date faxed to NU: Date Putdished: 10/26/97 Discrepency: ESF Filter Urut Compliance with RG 1.52. Rev. 2 Position C.3.g

== Description:== During review of the Supplementary Leak Collection and Releese System (SLCRS) filter units 3HVR*FLT3A/38 and the Aniliary Builiding Ventilation System exhaust filter units 3HVR*FLT1 A/1B for compliance with Regulatory Guide 1.52, Rev. 2 position C.3.g a discrepancy regarding the layout of the housing and banks of filters was. identified, FSAR Table 1.61 states that the filter units comply with the requirements of Regulatory Guide 1.52, Rev. 2, position C.3.g except that no intemal lighting is provided. FSAR Table 6.5-1 states that the charging pump, component cooling pump and heat exchanger area exhaust system is in compitance with Regulatory Guide 1,52, Rev. 2 position C.3.g FSAR Table 6.5-1 states that the supplementary leak collection and release system is in compliance with Regulatory Guide 1,52, Rev. 2 position C.3.g Regulatory Guide 1.52 position C.3.g requires that system filter housings, including floors and doors, should be constructed and designed in accordance with the provisions of Section 5.6 of ANSI N509-1976. ANSI N509-1976 Section 5.6 requires that the layout of the housing and banks of components within the housing shall provide for eccess to both sides of each bank of components for maintenance and testing. Drawings 2170.430-065-022D,2170.430-065 023E, EB-45G-9 and EB-45H-12 do not show access doors provided for the upstream side of the demister filter bank, the upstream side of the prefi'ter bank, and downstream side of the second HEPA filter i,ank. Review Valid invalid Needed Date initiator: Stout, M. D. O O O 'or'3S7 VT Lead: Nort. Anthony A Q Q Q 10/1497 VT Mgr: schopfer, Don K O O O 0<2ce97 IRC Chmn: sangh, Anand K O O O 10/21/97 Date: INVALID: Date: 11/20/97 RESOLUTION NU has concluded that the issue reported in Discrepancy Report, Pfirted 12/17/971:3s.39 PM Page1 or 3

Northeast Utilities ICAVP DR No. DR-MP3-0440 Millstone Unit 3 Discrepancy Report DR MP3-0480, does not represent a discrepant condition. The filtration units are in compliance with the requirements of both RG 1.52 and ANSI N509-1976. The requirement for access does not stipulate that the access be provided in the form of a door. These units are designed with removable filters and demisters. These components can be removed as required to gain access to areas of the units not provided with doors. There are also access panels on the inlet and outlet duct in locations that would aHow for limited visualInspection or installation of air test equipment if required. Access doors (DRAs) cro depcted on 12179-EG-45 series drawings. EB45A was transmrtted on 8/7/97 under transmittal

76. All others should be found on aperture cards. Grits has been reviewed to confirm that aperture card revisions are still current.

Significance Level criteria do not apply here as this is not a discrepant condition. ~ Provkxasly identthod by NU? O Yes i No Non Discrepant Cond:Gon?( ) Yes @ No Resolution Pending?O vs. @ No Resolution Unresolved?C) Yes @ No Review initiator: s5A. M. D. VT Lead: Nort. Anthony A W Mgr: sc%. pret, Don K IRC Chmn: Smgh, Anand K Dete: 11/20/97 sL ccmmenn: FSAR Table 1.8-1, Reg. Guide 1.52, Rev. 2, positon C.3.g states that the units are in accordance with ANSI N509 and that the units are provided with hinged doors or bolted panels with inspection windows. The ductwork access door identified in Attachment C to Specification SP-ME 576 do not have inspection windows as stated in FSAR Table 1.8-1. The duct access door locations for filter units 3HVR*FLT1 A/B shown on drawing EB-45G are located outside of the filter room and have fire dampers installed between the access door and filter unit. With the angle of the inlet and outlet transitions on the filter un;ts use of the ductwork access doors for visualinspection of the mounting frames required by ANSI N510 would be very difficult. The drawing also shows little room for removal of the duct spool piece between the filter unit and fire damper. Drawing EB-45H shows access doors in the inlet ductworK for filter units 3HVR*FLT3A/S. There is a damper (3HVR*AOD95A/B) and an elbow between the access door and the filter unit inlet. Use of these ductwork access doors for visalinspection of the mounting frames required by ANSI N510 would be very difficult. There are no duct access doors shown on the square to round duct transition between the filter outlet and fan 3HVR*FN12A/B. Removal and replacement of this duct section would require Pnnted 12/17/971:35.46 PM Page 2 or 3

Northeast Utilities ICAVP DR No. DR-MP3 0440 Millstone Unit 3 Discrepancy Report verification that the duct leakage is still within allowable limits. Therefore, the access requirements of ANSI N509 have not bev. met and FSAR Table 1.8-1 should be revised to include this exception to Reg. Guide 1.52, Rev. 2, position C.3.g 4 i 8 PrWed 12/175171:35.48 PM Page 3 of 3 a}}

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