ML20212D393
| ML20212D393 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/29/1997 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9710310086 | |
| Download: ML20212D393 (32) | |
Text
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Q.s yy A:
Sar gerd Luncly " c gy
'oenK.schopter'
. Vice President '
312 269-6078 e
' October 29,1997 Project No. 9583-100 a,
.R's'_j~ ;
Docket No. 50-4231 l
N6nheast Nuclear Energy Company
- Millstone Nuclear Power Station, Unit No. 3 -
Independent Corrective' Action Verification Program Im
~ United States Nuclear Regulatory Commission
. Attention: Document Control Desk JWashington, D.C. 20555 :
-I have~ enclosed the following six (6) discrepancy reports (DRs) identified during our R
review activities for the ICAVP. These DRs are being distributed in ccordance with the Communications Protocol, PI-MP3-01.-
F
- DR No' DR-MP3-0338 '
- DR No. DR-MP3-0504 DR No. DR-MP3-0380.
DR No. DR-MP3-0524 i DR No. DR-MP3-0461:
DR No. DR-MP3-0578
+
- I have alsc enclosed the following eight (8) DRs for which the NU resolutions have been
- reviewed and accepted by S&L.
y
- DR No. DR-MP3-0010 ~
DR No. DR-MP3-0025
%~ ' %, DR No. DR-MP3-0011-DR No. DR-MP3-0027 DR No. DR-MP3-0016
. DR No. DR-MP3-0028
- DR No. DR-MP3-0019 DR No.' DR-MP3-0255 I have also enclosed the following two (2) DRs for which the NU resolutions have been reviewed but not accepted.' S&L comments on the resolutions have been provided.
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. DR No. DR-MP3-0009 DR No. DR-MP3-0014 lfll l,lllfllllfll]l]lllll]flll 9710310086 971029 PDR ADOCK 05000423 P
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t 55 East Montce Street + Chicago. IL 60603-5780 USA
- 312-269-2000
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iUnited States Nuclear Regulatory Commission -
October 29,1997 Document ControlDesk Project No. 9583-100 pj Page 2 j
Please direct any questions to me at (312) 269-6078.
.-Yours very truly,
- n q
_s D. K. Sch pfer -
Vice President and ICAVP Manager DKS;spr.
. Enclosures l Copies:
. E. Imbro (1/1) Deputy Director, ICAVP Oversight
- T. Concannon (1/1) Nuclear Energy Advisory Council
?J; Fougere(1/1)NU muswynessMPar1029 a doc '
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Northeast Utilities :
ICAVP DR N3. DR MP3-6334
)
umsten. Unit 3 -
Discrepancy Report Review ereup: C,- _ & Mairdenence end Testm0 DR VALID Review Elennsnt: Test Procedure O ve:
Deserspency Type: Test Reedremente gg
~
syseenwpreseso: oss NRC Signiscence levet: 3 Date Faxed to NU:
Date Putsehed: 1 o/31/97
^
.F 6 Surveillance Testing incomplete Deeceipeen: For the Quench Spray System (QSS), Tech. Specs, i
3/4.6.2.1.c.1) & c.2) contain requirements to verify the automatic acication of QSS flow path valves and pump start on a Cor,tainment Depressurization Actuation (CDA) signal, n'~
Surveillance Procedure SP-3646A.17 and OPS Form 3646A.17 1 a,e performed to satisfy these requirements.
A review of test c:ata from 7/24/96 revealed the following:
Procedure step 4.3.4, Pg. 29 requires the performer to refer to Section C of OPS Form 3646A.171, anc. with the exception of pump QSS*P3A, establish all " Prior to CDA" conditions. Section C of OPS Form 3646A.17-1 requires that QSS*MOV34A Quench Gpray Header Isolation Valve be verified CLOSED prior to CDA.
= This step was marked "Not Tested
- during the surveillance peformed on 7-24-96. Procedure step 4.4.24 requires verification that this same valve has transferred to it's post-CDA OPEN
+
p position following initiation of the CDA signal. This step was -
- marked "Not Tested
- during the surveillance performed on 7 24
- 96. OPS Form 3646A.17-1 contains a note which states " Power L
is RTO-Test Exception." It was not verified that valve b
3QSS*MOV34A opened on a CDA signal, as required by the Tech Specs., and this requirement was not met. The form cover I;^
page also contains a note stating that the MOV34A test was not h
performed, along with a reference to a retest performed on OPS Form 3646A.17-2," Train A Engineered Safeguards Features g
(ESF) With Loss of Power (LOP) Test Failure And Retest
' Documentation."
Additionally, Step 4.3.3 requires that the POSITION PRIOR TO Safety injection System (SIS)/ LOP be verified for the listed components on OPS Form 3646A.17 2 Section A, and Step 4.4.16 requires that the POSITION AFTER LOP bo verified for
_ those same components. Recirculation Spray System Pump 1C is required to bJ ON prior to SIS / LOP and OFF after LOP. This verification block is marked "Not Tested" on the form and a note on the form cover sheet refers to a retest per'~mied on OPS Form 3646A.17 2.
Step 4,4.23 requires verification that CDA/ LOP components sequence ON following initiation of a CDA event. OPS Form 3646A.17-1, Sec!!on B, is marked "Not Tested
- for RSS*P1C Recirculation Spray System Pump. A note on the form cover sheet refers to a retest performed on OPS Form 3646A.17-2. No reason is given for not performing the initial test. Tech. Spec.
Section 4.6.2.2.c. requires that es:h Recirculation Spray System
- be demonstrated operable at least once each refueling interval Printed 1W2W97 Itc&45 AM Page 1 of 3
,m Northeast utstles ICAVP DR Nr.. DR-MP3 0334 umstone unit 3 Discrepancy Report by vertfying that on a CDA test signal, each recirculation spray
- A pump starts automatically after a 660 +/- 20 second delay. This requirement may not have been met for RSS*P1C, Stop 4.4.24 and OPS Form 3646A.171, bection C, requires that 3RSS*MOV20A, the Recirculation System Train A discharge isolation valve, be verified CLOSED prior to a COA test signal,
=i and OPEN after the CDA signal. The valve ws:: marked "Not Tested,' and it was not vertfled that it opened on a CDA test signal. A note on the form cover page refers to a retest on OPS f
Form 3646A.17-2.
7 U-Step 4.4.25 requires that a Manual Trip Block (MTB) check be performed for each component on OPS Form 3646A.171, Sedion B, Fan 3HVU-FN2A was not checked. A note states that if,'
- It was not checked due to a fault in the procedure. The form cover sheet has a note stating that it was not tested because it s
f was not included at step 4.4.20 and was already stopped by the Jtime step 4.4.25 was performed.
~ 8tep 4.4.27 requires documentation of reset of all MOV Thermal O
' Overtoads. This documentation was left blank for MOVs E 3RSS*MOV20A and 3QSS*MOV34A because these valves were not tested as previously noted.-
Most jumper installation and removal steps on OPS Form 3646A.171, Sections F & G, Pop 13,14 & 15, were marked NA.
A note on Pg. it states: "S/G H.H. Level jumper installation and removal to De per Shift Manager direction at the end of outage.'
. Nor*.heast Utilities haa not demonstrated that retesting was performed and the surveillance completed satisfactorily.
- Administrative procedure DC 4, " Procedural Compliance,"
classifies procedures according to level of use. Surveillance Procedure SP 3646A.17 is classified as a " Continuous Use" procedure. This means that the procedure contmis a work activity that is crthcal, complex, or involves infrequently performed evolutions or activities. Continuous level of use procedures require step-by-step use to prevent immediate f
_ effects on nuclear or personnel safety and plant reEability.
' Administrative procedure, DC 1, " Administration of Procedures and Forms," requires, that if a certain procedure step cannot be
- perforr ed, then a procedure cht age is required before proceeding with the work. A change is performed to modify a document quickly and accurately to allow work to continue. Per DC 1, an
- Intent Change' would have been the proper mechanism for revision of SP 3646A.17. An " Intent Change' 4
Involves the modification of a regulatory requirement, policy, 1-e technical basis, setpoint, acceptance criterion, safety limit,
. operating limit, tolerance, etc. Additionally, it includes anything
' that modifies the scope of the document or the basic method of
' task performance.
' Pitnted 10/2aS711 ve:52 AM Page 2of 3 a
?
_ ~ -.
u Northeast Utilities.
ICAVP DR No. DR-MP3 0338 Maston. unit 3 :
Discropancy Report Based on the previously identified discrepancies and tne g"-
administrative procedure requirements, performance of surveillance procedure SP 3646A.17 and OPS Form 3646A.17 1, which was completed 7 24-96, was deficient in the following areas:
The surveillanco testing was not performed step-by step, and several steps related to testing of critical components were U
omitted.
l l
There were no procedure changes or revisions documents attached to or a part of this surveillance test data package, and a check of procedure change records does not show that a change was initiated.
9 Procedure performers failed ;o initiate a procedure revision when
- steps could not be performed as written.
- No reasons are given for not performing the initial tests and no raasons are given for retests. Retest forms are not a part of the tem data package. Retest results, if any, are unknown.
Based on ?.3 lack of documentation of procedure steps and the obvious omission of testing of critical components, procedural requirements were not met, and it has not been demonstrated that Tech. Specs. requirements have been satisfied.
Review Vead invahd Needed Date initialer Petrosky,AL Q
Q Q
10/1W97 VT Lead: Bees, Ken g
Q Q
10/17/97 VT Mgr: Schopfer, Don K B
O O
10'nS7 IRC Chmn: Singh, Anand K B
O O
te 2s/97 Date:
INVALID:
Date:
1 c
REsOLUDoN Previously heentiaed by NU7. U Yes @ No Non Discrepent Cendelen U Yes @ No Review -
Acceptabte Not Acceptable Needed Date m,g VT Lead: Bees, Ken VT Mgr: Schopfer, Don K IRC Chmn: Singh, An,y X Date:
- sL Commente:
F Printed 10/2W971199:56 AM Page 3 of 3
~.
v 1
g Northeest Utgities ICAVP DR N3. DR MP3-0340 uslistone Unit 3:
- Discrepancy Report noview esesp: opmusens s MsNonense and Teenne onVAuo newtow elemose: TesiPrecedure
*""d Yee m
nisci,ano: opam-O Diessepancy Type: Test Requrements gg syneemmessee: oss -
- 9500 Signiscence levei: 3 :
Date FAXmi mal-Date Putdished: 1041/97
)
Dinesepency: Surveillance Procadure Test Methods inadequacies ossareption: Quenc5 Spray System (QSS) Tech. Specs. Surveillance Requirements are as follows: 4.6.2.1.c. states: "Each Containment Quench Spray subsystem shall be demonstrated operable at least once each refueling interval, by 1) verifying that
/ each automatic valve in the flow path actuates to its correct W
position on a CDA test signal, and 2) vertfying that each spray pump starts autc. walally on a CDA test signal."The test -
methods used in the applicable surveillance procedures, SP-3646A.17 & 18, and OPS Forms 3646A.17-1 & 18-1, may be inadequate to demonstrate operability of either the QSS "A" or "B" Train components.
Procedure step 4.1.3 requires the pump circuit breaker to be placed in the REMOTE TEST position, and it remains there t
- 2 throughout the test. This methodology activates the circuit
' h" breaker indicating lights but dues not check the breaker auxiliary contacts operation, or that the breaker would have operated to stad the pump with a CDA signal.
Automatic valves in the flow path which are required to actuate to the correct position on a CDA test signal are 3QSS*MOV34A T
& B. For SQSSWOV34A, the Train A valvs. the test was marked "Not Tested" On OPS Form 3646A.171, Section C, Pg.
'9, and it was not vedfied that the valve opened on a CDA signal.
~
~ The form cover page also contains a note stating that the
,a
. MOV34A test was not performed, along with a reference ta S retest performed on OPS Form 3646A.17-2. Retest data 'm not attached to the surveillance data package, and retest results, if s
- any, are unknown.
~
Other problems were noted as well:
y
' 1) OPS Forms 3646A.17-1 & 18-1 Jumper Document Sheets, Sections F & G, were all marked as "Not Applicable." This procedure requires a significant number of jumpers to be n@
-installed. Based on the test data reviewed, it cannot be
.. determined that appropriate jumpers were installed to property configure the system to support the intent of the test.
t
- 7) Test methodology is confusing and extremely hard to follow, 4
p
- SIS and LOP tests are performed almost simultaneously, followed very closely by a CDA test, using a single test procedure. Results of all three tests are recorded in multiple sections of the OPS forms, and no one form section seems to 2
apply exclusively to any one test. The related procedure steps
' are not included on the data collection forms, and doubt exists as PrWed lof294711:10:28 AM -
Page 1 of 2 Jw i
Nwtheast utsties ICAVP DR No. DR MP34380 Emsewn unn 3 Discrepancy Report to which stop is applicable, or even which section relates to which test. Load shedding is supposed to be verified on the the forms, txt there is no procedure step that clearly identifies this requiremert. There la a great potential for error on the part of the procedure pedomme, especially if he hasn't performed the proced'are several times before. Cince this is an infrequently used procedure, it is unlikely that the pe ",rmer will have a great amount of experience performing it.
It is concluded that these surveillance test procedures may be inadoreste to perform their stated function of satisfying Tech.
- ~
r
. Spoos. requirements. AddMionally, the testing requirements of f
NRC Genedo Letter No. 96-01.
- Testing of Safety Related Logic
. l' q.
3 Oltcuts," may not have been met.
4
.1 :
Review r' '-
4 vand invald Noseed Date I
inallater Petreeky,AL 0
0 0
10/iwe7 VT Leed; teos, Ken Q
Q 10/1T/97
. VT Mgra schopfer, Den K Q
Q 10/2397 m%
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me cienni sigh, Annw K O
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$0/2857
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.Yd$f; lese 20 sed tsy Nu7 Q Yes @) No Non Diertopent Candluen U Yes (S) No
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.,,,, 4,,,,3 Not Asaepieue N.eae Dee l,*
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b 1100 {.lenn: singh, Anand K yj 4
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Pr61ted 10/29/9711:10:34 AM Page 2 of 2
+
Northeret utsties ICAVP DR No. DR Mp3 0441 waistone unit 3 Discrepancy Report newtow ereup: Proyemmeno onyAuo moview elemese: Canes #* Aohen Procus Deselpline: Omar PNonenalOperatilleyleeue O vos
, _, Type: Camponent Date
@ No ayeemanceses: NIA NRo Glenlaeoneslevel: 4 (Me Fsuled to AU:
Date Publ6ehed: 103147
,-v Numerous Defleiencies in Production f Aalntsnacle Aanagement
~
System (PMM8)
Desertpeton: The ICAVP includes review of proposed corrective actions for various UIR8, Our review has noted a trend in that there are f
numerous UIRs (at least 74) which identify deilciencies related to PMM8 data inoonsistencies with the plant design drawings s
and/or plant labeling. The number of components with reported PMM8 data deficiencies is considerable, Some individual UIRs
- list over 100 components where deficient PMM8 data has been identified, on safety related systems such as the Class 1E Emergency Diesel Generators. Taken individually, the final disposition of each UIR to "fix" the discrepancy is considered acceptable, however the aggregate effect of such a large number of deficiencies in the PMMS system in conjunction with the management'Mecision to resolve these items post startup requires generic consideration.
RFI MS-RF100402 requested a basis for categorization of the
- resolution of PMM8 deficiencies as non startup (This RFl listed a small sample of PMMS related UlRs). The response to RFI 402 (IRF 415) has been reviewed, and it did not pluvide the required information.
There was no basis or supporting justification provided as to why the aggregate of all PMM8 deficiencies discovered 13 date does t
not represent a safety conoom weeranting resolution prior to startup. The RFI response implient that NUs initiative to correct the deficiencies is justification for NUs determination that such deficiencies "were not considered required for restart".
Justification is needed to establish that the existing errors in PMMS will not pose a safety concera for maintenance activities
. or other plas.t operations after startup. Appropriate justification could involve a description of the use of the various fields in the database, how they affect safety-related activities, and the effect the errors would or would not have on plant operations.
Review Valid -
14 valid Needeel Date inalater: Neverro, Mark O
O O
10/2187 VT Leed: Ryan, Thomme J
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C 1o71S7 v7 men sonoprn,oen x 0
D 0
in22,7 IRC Chmn: Sineh. Anend K Q
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0 10'2*S7
- Date:
INVAUD:
c-Date:
REa08.UTtoN:
P sited 101a4711:11:1e AM Page 1 of 2
Northeast Utilities ICAVP DR N3. DR MP34441 i
.. Millstone Unit 3 Discrepancy Report E-
-, identened by NUF U Yes @ No Non D6ecrepent condelkwi U Yes (e) No Rev6ew
- T Not keptable Needed Date inineter!(none)
O O
VT Leed: Ryan,itemme J O
O O
VT Mgrt Schopler, Don K O
O O
mc ch= swi,w g O
O O
SL Commente:
i i
t
,i t Prtnien 1Was711:11:23 AM P
2W 2 1
't
Nwtheast Ummes ICAVP DR No. DR MP3 0604 umstaw unit 3 Discrepancy Report Reviser ersup: C."
DR VAUD Disalpiene: Electrieel Desi'"
Potentnel Opereldlity leese O va Diseespency Type: Droning g g, Systemmenees: swP NRC Signiteense imi: 4 Date faxed to NU:
4 Date Putdlehed: 1G'31/97
- - - -. + Vendor Da% not in agreement nameplate data.
Descripeten: Vendor drawing 2332.516-063-005, Rev. B Indicates the motor speed for strainer motors 3SWP*STRI A thru 1D is 1800 rpm and the horsepower to be 1.3. Single line EE 1 AE Rev. 35 also shows a horsepower of 1.3. The nameplate indicates a speed of 1700 rpm and a horsepower of 1.4.
Rev6 w Vand invand Nooded Date i
Initialer Server, T. L g
O 10/5
- 87 VT Lead: Nort, Anthony A Q
Q Q
10/1597 VT Mgr Sohopfer. Den K O
O O
10/2057 IftC Chan: 66gh, Anand K O
O O
100 *87 Date:
INWALD:
Date:
IIEaOLUTION:
Peevteuely identleed by Nut V Yee @ No Non D6screpent Conde6an U Yes @ No Review
'. Not #, "-
Date VT Lead: Nerl, Anthony A O
VT Mgr: Schopler, Don K
,, litC Chmn: Singh, Anand K g
Date:
SL Commente:
(il Printed toGIW9711:12:00 AM Page 1 of 1 I$.
Northeast UtWties ICAVP DR N9. DR MP34824 m asterm unit 3-Discrepancy Report Review Group: Opericans & Maintenance and Teetnf DR VALID 3
Potential Opereldely leeue O Yes Discrepancy Type: 0 & M & T Precedwo gg systemeresses: swr 9tRC Wlows: 4 Date faxed to NU:
Date Putmehed: 10r31/97 i
DeserspeneFi inadequate documentat6on to Verify Service Water Pumps are allemated for uniform wear.
Descripmen: The FSAR states that "the service water pumps are rotated intervice for uniform wear," NU's response to a request for information identified the operating procedure tilat is used to allemate the train A and train 8 sowice water pumps, but did not identify the procedure or document that required that the pumps be rotated intervios for uniform wear, No information was peevided that identified what frequency or how often the pumps are to be allemated.
The requirement to altemate service water pumps to ensure uniform wear could not be verified Review Valid invetid Needed Dale intilater Speer, R.
a 10/17/97 VT Lass: Bees, Ken g
10/17/97 VT tagri Scheps r. Den K O
O O
10rass7 e
IRC Closoir Singsh. Anand K Q
Q Q
10/21W97 Date:
- DNAUD:
Does:
RE800 MON:
Provtously Idoneland Ipy NU? U Yes @ r3 Non D6ecrepent Condition V Yes (91 No Review AWh Not.' - - - '
Needed Date VT Lead: Bees, Ken VT Mgri Schopfer, Don K 1RC Chmn: Singh, Anand K g
Date.
c SL Comments:
Pfhted 10f29/9711:12A0 AM Pope 1 of 1 l
L
Nenheast utsties ICAVP DR N3. DR MP3 0578 mustan unit a Discrepancy Repoft Review eseup:.% _ _._
DR VAUD oleelpensa MachenkelOseign.
Potenueloperabanyleeue O Yes obserspeney Type: comove Aasen g g, spenenweressen: swp Nnc sardneenselevet:4 oste rAxed to NU:
Date Published: 1011/97
-v Corrective Adion Plan Documented in CR MS 971612 De**ripelen: CR MS 971612 lists eleven (11) discrepancies:
- 1. E6W 4) Uhe hems refer to discrepancies identified in f
Servicy 7%' Spsm Training 'SWS Text SWP076T'. These eight itute scit stifled by number in the CR as numbers 3,4, 5,6,7,9,10, a.,411. The corrective action plan for the aforementioned items is acceptable.
- 2. Two items (identified as items 1 and 2 in the CR) refer generally to deficiencies in ' operator training materials" without specific reference to the actual document (s) found to be discrepent.
- 3. One item (identified as item 6 in the CR) refers to a description in the 8WS text concoming a " bypass which has been in place since 1990 and a plan for modification in RF06",
L'_
This discrepancy states that " bypasses of that age should be in drawings and FSAR regardless of their status as modifications".
Discrepent Conditions A. From the description provided in the CR for hem 2 above, it is not clear what specific operator training materials were found to be discrepent not if the corrective action plan which is only stated to evaluate changes and incorporate into SWP076T would resolve such identified discrepancies.
B. The corrective action plan as documented only evaluates changes for incorporation into SWP076T, This does not address the discrepancy relative to the drawings and FSAR discussed in item 3 above.
1 Review Valid invalid '
Needed Date inilister: Neverro, Me*
O O
O 1o/2257 VT Leed: Ryan, Thomme J G
O O
tor 2ss7 VT Mgr: schopfer. Don K O
O O
tor 2sS7 IRc chmn: singh, Anand K Q
O O
'102SS7 Date:
"?
INWAUD:
DEM:
REa0LUTION:
Previously hientland by NUf ( ) Yee @ No Non 06ecrepent condetion
( ) Yee @ No Prtreed 10f299711:14:27 AM Pope 1 of 2
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Nwtheast utstles ICAVP DR N:. DR MP3 0874 Mustaw Unit 3 Discrepancy Report n
M ;-t'_ '- Nc4 *= =- ' ' ' '
Needed Date VT Lead: Ryan, Thomas J O
g VT Mgr schopfer, Don K IRC Chmn: S$ Anand K O
O Dele:
. SL Comments:
+
Prtnled 10GIW9711:14:33 AM Page 2 of 2 v
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Northeast UWWes ICAVP DR No. DR MP3 0010 museuw ure a Discrepancy Report ReviewGroup: AcomentMagshan DR REs0LUTioN ACCEPTED Rwlew Element: Systern Design Potent 6el opereWWy leeue O vee Desersponey Type: Woonsing Deoumont g
eyelempresses: NA NRC Signiacene twel: 3 Date faxed to NU:
Date Putdished: W22/97
-i. SER $15.4.3 requirement to perform cycle specific analysis demonstrating DNS limits are not exceoied Desereption: The Millstone 3 SER, $15.4.3, page 15 9, cites the case of rod cluster control malfundions with rod locations where the reador does not scram. In this case the automatic controller may retum the roedor to full power and the control could result in a power overshoot. The NRC reviewed a generic analysis of this case.
The staff socepted the generic results tnt noted that the results are reacior and cycle specific. Therefore, as an interim position, pending the completion of Millstone cycle specific analyses, the staff imposed a restriction for operation above 90% power such that either the reactor is in manual control or rods are required to be out more than 215 steps.
Millstone 3 SSER Supplement 1 $15.4.3, page 151, cites the completion of the requetted analyses for fuel cycle 1 and removes the operating restridion for operation above 90%
power. The SSER stales that Amendment 12 to the FSAR included a discussion of this event and the results of the oratysis. The results are found acceptable for fuel cycle 1 for N
. and N-1 loop operation. The continuing requirement to analyze future reload cycles remains in place.
Millstone 3 SSER Supplement 3, $15.4.3, page 151, cites the review and acceptance of the generic resolution to this issue.
However, the SSER maintains that the ' solution requires a reactor cycle specific analysis showing that departure from nucleate boiling (DNB) limits will not be exceeded."
Beyond fuel cycle 1, including the Vantage 5H Fuel analyses, no mention of results of these analyses are found in the FSAR, y
reload analyses or supplements to the SER. There is a
. continuing fuel cycle specific analysis requirement that is not documented.
Rev6ew Vehd invahd Needed Date inilleter: Postnes, W. R.
8 O
O
- 1/87 VT Leed: Rehele,ReiD G
O O-
- 1/87 VT Mgr schopfer, Don K -
'O O
O 8'5'S7 unc chen: Singh, Anand K.
O O
O w 2/o7 Date:
INVAUD:
Does: 10/21/97 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report. DR MP3-0010. has Prtreed tor 2SS710:5s:5s AM Pe0s 1 of 3
Northeast utilities ICAVP DR No, DR MP3 0010 masteen unit 3 Discrepancy Report identified a condition previously discovered by NU which required correction. The Me3 dropped rod event (RCCA misalignment), in FSAR Sedion 15.4.3, was analyzed using the NRC approved Westinghouse methodology detailed in WCAP.
11395 P A,
- Methodology for the Analysis of the Dropped Rod Event? WCAP 11395-P A documents the methodology which was used in the current analysis of record which was performed for Cycle 5. FSAR Sedion 15.4.3 was revised in FSAR CR 97-MP3 54, initiated 3/3/97, to reference WCAP 11395 P A. As noted in the FSAR discussion for the RCCA misalignment, the transient response, including nuclear peaking factor analysis and DNS design basis confirmation, is evaluated for each fuel cycle in accordance with this WCAP 11395 P A methodology, These are documented by Westinghouse in the Reload Safety Analysis Checklist (RSAC). For each reload / cycle, if M is confirmed that there are no changes to the analysis inputs that would impad the transient response, nuclear peaking fador analysis and DNB design basis for the RCCA malfunction, then the analysis of record and the FSAR remains limiting, the FSAR discussion does not need revision and there would be no reference to th; analysis of this event in the Reload Safety Evaluation.
Additionally this cycle specific RSAC evaluation performed by Westinghouse is not discussed in the FSAR or SER. As stated previously, the analysis of record was performed for Cycle 5.
The RSAC process was subsequently performed for Cycle 6 and it was deterrWned that the analysis of record remained limiting and reenalysis was not necessary. As noted above, the proper reference which documents that an accident was evaluated for a given reload / cycle is the RSAC.
u Refer to the copy of FSAR CR 97 MP3-54 attached to M3 IRF 00270 (ICAVP response to DR MP3-0023) for changes associated with FSAR section 15.4. The FSAR CR is awaiting PORC approval.
NU concurs with the Significance Level of this DR.
==
Conclusion:==
NU has concluded that Discreper.cy Report, DR MP3-0010, has identified a condition previously discovered by NU which required correction. For the RCCA misalignment, the translent response, including nuclear peaking fador analysis and DNB design basis confirmation, is evaluated for each fuel cycle in accordance with this WCAP 11395-P A methodology. This is documented by Westinghouse in the RSAC for each cycle.
FSAR Sedion 15.4.3 was revised in FSAR CR 97 MP3 54, in.11sted 3/3/97, to reference WCAP 11395-P A. The RSAC process is not specified in the FSAR because it is govemed by Westinghouse intemal procedures. NU concurs with the
'~
Significance Level of this DR.
Of:riidenuned by Nu? @ Yes Q No Non W ;- " Condenon U Yes @ No hertow ininetor: Peebles, W. R.
VT Lead: Reheja, Ral 0
~
Prtnted 10/29/9710.50 o5 AM Page 2 of 3
Northeast UtWties ICAVP DR N2. DR MP3-0010 umotone use Discrepancy Report O
iM7 YT he r: schapsw, con x e
0 im7 unc chen: singh, Anand x O
O O
ter M:
10/14/97 sL comunente:
I i.
^
I Pnreed 16710.50.06 AM 1
P93W3
Northeast UtWties ICAVP DR No. DR Mp3 0011 j
maestone Unit 3 Discrepancy Report nwoon oreup: Pneremmeno Dn nesoturioN ACCEPTED nwtow sinnene: ceneenv. Aomen Pra O vs.
Deseroponey Type: conoceve Acean gg systemeresses: mas NnC alenlacense twel: 4 Dele faxed to Nu:
Dele Putdiohed: tv)147 Diemepenoy: Failure to implement or otherwise disposition Recommended Corrective Adlon in ACit # M3 96-0352 coewsplion: The Corrective Action Plan included in ACR # M3 96-0352 (Page 3 of form RP 4 7 ) does not address the Recommended Corrective Adion (2nd sentence of block 6 of form RP 41) to determine 'If heat exchanger was ever out of service". The results of such determination could be reportable if an RSS heat exchanger was ever out of service when it was required to be operable and the associated LCO was not entered. Accordingly, the response to the ACR form 4 3 block 3 question, 'Is the ACR reportable?" should have been checked as ' Uncertain" rather than 'no" pending completion of the Recommended Corrective Action discussed above. The ACR documentation should include evidence that the Recommended Corrective Adion was performed with results indicating that the issue is reportable or non reportable as the case may be; OR the ACR documentation should include justificatirn why the Recommer.ded Corrective Action is not warranted and was therefore not performed, nwiew veed tweed Needed Date inliteter: Neverro, Mark O
O O
IV2247 VT Lead: Ryan, Themes J G
O O
se22 7 VT Mor schopfer, Das K O
O O
v22 7 inc Counn: sineh, Anend K G
O O
ar27s7 De e:
s INVALID:
Date: 10/16/97 nasoumON: Disposition NU has concluded that the issue reported in Discrepancy Rcport.
DR-MP3-0011, does not represent a discrepant condition, Recommended corrective Actions on ACRs are considered when final corrective action is determined. The only required Corrective Adions a: s those identified in the formal CorTective Action Plan and agreed to by the appropriate responsible managers. The initiator was not aware that it is Operations standard procedure to log into the Action of LCO 3.6.2.2 when any RSS pump is out of service and if the A or B RSS pump or both pumps in one train are out of service the Action of LCO
- 3. 5.2 is logged as well. This would also apply to any components within the particular loop which when out of service would render the loop inoperable. A review at the time the Corrective Action Plan was developed did agree that a m*
clarification could be made and a change to the TRM was initiated. This chance was for the benefit of anyone who might Prmled 1or21W9711:00A0 AM Page 1 or 2
9-Northeast utilities ICAVP DR No. DR.NP3 0011 umetone unit s Discrepancy Report with to know N the LCO Action should be entered for an out of servios RSS component.
Significance level criteria do not apply here as this la not a discrepent condition.
Conclusion NU has concluded that the issue reported in Discrepancy Report, DR MP3-0011, does not represent a discrepent condition.
Recommended Corrective Adions on ACRs are consioered when final corredive adion is determined. The required Corrective Adions are those identified in the formal Corrective Adlon Plan and agreed to by the appropriate responsible managers.There is no procedural requirement to perform a recommended corrective action or justify why it is not done, it is a suggestion only and not a requirement.
Significance level criterie do not apply here as this is net a disciopant condition.
Prowleasey teenused by Nu? U Yes @ No. Non D6ecrepent CwuMWen
@ %to V No nev6.w Wh Not M=, '
Needed Date b'
VT M: Rm Themes J VT Mgr: schopfer. Don K j
IRC Chan: singh, Anand K Dele:
i f
aL Commente:
L Printed to/2EW9711:00.57 AM Page 2 or 2
.- -. - - -.~ -
4 Northeost utsties ICAVP DR No. DR MP3 0016 ismesorm unit s Discrepancy Report Revtewereup: AeeWentMagehen DR MESOLUTioN ACCEPTED me*w element: syehm Design O yes Deseroponey Type: Usensing Desument
@ No syseesWProceses N/A W signiteense W: 4 7
Date faxed to NU:
h new Pued6ehed a22/97 ai Inoonect Values in FSAR Table 15.7 9 Daeripeient We have reviewed calculation XX XXX 107RA, Revision 0,
" Radiological Consequences of a Fuel Handt!ng Accident at MP.
3,* for consiciency with the input data and assumptions (including critical system charaderistics) and resuns presented in Chapter 15 of the FSAR. The two documents are in agreement except for some Hems in Tabis 15.7 9, "Adivities Released to the Environment As a ResuM of a Fuel Handling Accident in the Fuel Building.' Thesa Hems are:
- 1. The activMy for lootope 1-130 is listed in the table as L31E+01. The results of the calculation Indicate the actual activMy is 1.31E 03,
- 2. The lootope identified as 5e-82 should be St 82.
- 3. In the second Note the numerical value 5.71 should be s.
changed to 6.10 to be consistent with the value in the table.
The first item should be corrected since it implies an incorrect basis for the offsite dose presented in Table 15.0-8 (which is in agreement wMh the calculation) The other two Hems are edMorialin nature, A review of the UIR database did not identify any items related to this section of the FSAR.
The above incorpH.kncies need resolution.
Rev6 w Valid invol6d Needed Deh initialer: Johnson, W. J.
9 O
O 7/35'97 VT Lead: nah4e, nel 0 9
O O
7/31/87 vi m ri sehopen, een K B
O O
- 7 e
y IRc chen:_ singh, Anand K G
O O
5"7 Date:
INVAUD:
Date: 10/20/97' RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR MP3-0016, has identified a condition not previously discovered by NU which requires correction. FSAR CR 97 MP3-426, initiated 8/9/97, identified two of the three errors noted in the DR. The FSAR CR corrected the activity for 1130 and corrected the note.
Mnwaver the inenrred kninna was not identinnd and corrected.
Prtmed to71W9711:02:44 AM Page 1 of 2 4
met ummes ICAVP DR N3. DR4AP3 0016 Mastone unit 3 Discrepancy Report An FSAR CR will be issued to corred the error CR M3 97 2917 was initiated to provide the necessary corredive actions to resolve this issue.
Refer to attached copy of FSAR CR 97 MP3 426 for prediscovered changes associated with FSAR section 15.7. The F8AR CR is in the review process.
The issue identified in this DR does not imped the licensing of design basis. Therefore, NU concurs with a significance Level M 4.
==
Conclusion:==
NU has concluded that Liscrepancy Report, DR MP3-0016, has Identified a condition not p,sviously discovered by NU which h
requires correction. As noted in FSAR CR 97 MP3 426, two errors were prediscovered and correded by NU in Table 15.7 9 regarding the adivity level of I 130 and the note. However, NU j
did not identify and correct a third enor in referencin0 Be 82 l-.
versus Br 82. An FSAR CR will be issued to corred the error.
CR M3-97 2917 was initiated to provide the necessary corrective adlons to resolve this issue.
{
Peeviousey Wenused by nut V Yoo @ No Non C; :, _ ; Coneteen U Yes @ No nev6.w i-Inmiehen Johnson,W.J.
n t.es: nee.n.lo 9
O O
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-7 8
8 8
=
- - ~ ~
Date:
at Cenenente
+
.g.
Pftised 10/2fve71192.51 AM Pe 2 of 2 l
Northeast Utilities ICAVP DR No. DR-MP3 0019 88Morm unit a Discrepancy Report Review emap: Acoulart MMpeten DR RESOLUTION ACCEPTED Potential opereldisty laoue
- , Type: unenneng Document systen#ressee: N/A NRC W W Dale Faxed to Nu:
Date Putdlehed: W22S7
- ll Innenpency/ Westinghouse Comments of FSAR Sedion 15.1 r
.- We have reviewed Westinghouse Electric Corporation letter NEU 96 623, ' Northeast Utilities Service Company Millstone Unit 3 FSAR Chapter 15 Verification non-LOCA." dated November 25,1996, which provided NU suggested page markups for FSAR Sedion 15.1, increase in Heat Removal by y
the Secondary System.- The purpose of these comments and markups was to pro' tide assurance that the Millstone 3 FSAR is consistent with the Plant Safety Evaluation of record for the current fuel cycle.'
The comments on this sedion identify changes to the input assumptions, time sequence of events and results for the accidents analyzed in this section. These changes have not been incorporated into the FSAR, making the FSAR and the Plant Safety Evaluation inconsistent.
A review of applicable corrective action databases for Millstone 3 has not identified any pending FSAR change notice items that will incorporate the Westinghouse comments into the FSAR.
Review Vead invand Needed Date Inluster: Johnson W.J.
O O
O atitie7 VT taed: nahele. Rel D G
O
[']
atitio7 vi m n. achepsw. Den K -
G O
O arisier e
IRc Chmn: singh. Anand K Q
Q Q
8/12/97 Date:
INWAUD:
Date: 10/22/97 RESr4UTloN: Disposition:
FSAR CR 97 MP3 53, initiated 3/5/97, incorporated all Westinghouse comments from letter NEU 96-623 pertaining to Chapter 15.1 Refer to attached copy of FSAR CR 97 MP3-53 for e mments associated with FSAR section 15.1. The FSAR CR is currently in the review process with PORC approval expected by 10/21/97.
m Conclusk1:
DR-MP3-0019 identified a ilscrepeat condition with FSAR Chapter 15.1 that NU has pisvious!y addressed. The subject Westinghouse letter and comments were evaluated and will be incorporated into FSAR section 15.1 through FSAR CR 97 MP3'
$3, No further action is required, t.t _, identtGod Ipy Nu7 - @ Yes U No Non 06screpent condstion Q Yes @ No Prtnied io/21W971193:30 AM Page1 o 2
+
- - -. -,, ~ -
---,e-m.-rm---
w
a" Northeast utilities ICAVP DR No. DR4AP34019 Mm Unit 3 Discrepancy Report R
Inittster: Johnson, W. J.
7 W
M' D
D D
im7 VT f.eed: Rahese,RajD O
O O
1m7 yttegr gehopsy. Don K Q
O im7 INC Chmn: Sergh, Anand K 0
0 O
invas7 Date:
SL Censmente:
- 1..
p.
1 Printed 1(F2EW9711:03.37 AM Pe 2 of 2
Northeast utsties ICAVP DR N2. DR MP34026
- usesono unit 3 Discrepancy Report randoweeoup: AsementMmessen onmasOLuTKNdACCEPTED Potenties opweediny nues niempune: i a e o""
O("
tt ni Type: uneneine oooumet f
syeneswer
- wA 8ac *isamaaa e one rAx.e i. wu:
oste Putdiohed: &'2297 Okarepeney: UFSAR Discrepency llegarding ATWS Turbine impulse i
Pressure Signal DesertP#ea: UFSAR, Rev,05/0147, Chapter 7.8, page 7.8-2 contains the following statement 'AMSAC also utilizes the turbine impulse.
pressure signal for measuring a pressure rise in the turbine, as measured with the pressure transmitters located in the steam supply line near the turbine...".
A review of P&lD EM 123C 12 identified the referenced pressure transmitters / sensors as correctly reading pressure at a location inside the high pressure turbine casing and not in the steam supply line near the turbine.
Moview Vend invalid Needed oste t
inimater.' Mieh,J.
O O
O ariser vit.es: nahwe.ngo
'S O
O ariie7 VT Men schopfer, Den K O
O O
ass 7 une ch.nn: sinen. Anand x 9
O O
- S7
' 11 pene:
CWAlm:
one : 10/20/97 nasowTION: D{sposition:
- MJ has concluded that Discrepancy Report DR MP3-0025, has Lentified a condition not previously discovered by NU which requires correction.
CR # MS 97 2889 has been Initiuted to address this condition.
Conective meas'nes will involve changing FSAR Section 7.8, y
page 7.8 2 to reflect the 'as-built' location of the turbine impulse pressure transmitterWsensors. The physical plant installation is conect and meets the design and license bases of the unit. The discrepant condition is an error in the FSAR which describes the manner in which the system functions to satisfy these bastss. NU has concluded that, because the "as-built
- condition satisfies the design and license bases, this DR should be designated a Significance Level 4 discrepancy.
==
Conclusion:==
NU has concluded that Discrepancy Report DR MP3-0025, has
=
identified a condition not previously discovered by NU which required correction. CR M3-97 2889 has been initiated to provide the necessary corrective actions to correct the discrepant cotdition in FSAR Section 7.8, page 7,8-2 NU has determined that there is no impact on the field *as-installed" condition; thus, no cha,nges are required to be incorporated in the physical Printed 10Gs971194:0s AM Pege 1 of 2 f-e.----,-e.,*
y--.
ur---w-.
m,-....m=-
1 Netheast utsties ICAVP DR No. DR MP34028 I
use6ene Unit 3 Discrepancy Report plant.The discrepent condition is limited to the FSAR description of how the system functions to satisfy the Design Basis of the unit. Thus, NU has concluded that the DR should be designated a Slonificanos Level 4 discreparc/.
Proveauser Wenened by NU? Q Yes @ No Non D6ecropent Conemen Q Yes @ No newtow M. ""- Not AcceptaWe Needed Date
% g, O
O O
-7 VT Leed: Rehefs, Red D O
O O
m7 VT Mett schepper, Don K inc cienn: singh, Anand K nues:
10/15/97 at conenente:
c; Printed to/21W9711M16 AM Pope 2 of 2 j
t-
.____s_.
Northeast Utimies ICAVP DR No. DR MP3 0027 Mastone unit 3 Discrepancy Report Reviewaroup: AachtentMeigetion DR RESOLUTION ACCEPTED Review element: system Deenn i
D6eelpane: Oth" O Ya wwy Type: uoerming > wumerd g g, syenemmenses: N/A NRCS W tevct: 4 Done faxed to NU:
Date Putnished: IV22/97 E1 wv Incorrect Nucl6de identified in FSAR Sedion 15.0 t:
- -^ We have reviewed FSAR Chapter 15 and have identified the following discrepancy:
In paragraph 15.0.9.2, inventory in the Fuel Pellet Gap, it is stated that the gap adivity is determined using the model in Regulatory Guide 1.25. The FSAR states that this activity
- includes 30% of the 1117. Review of Regulatory Guide 1.25 indicates that this should be 30% of the 1127.
Review veed inveed Needed Date tallister: Johneen, W. J.
v7L.ed: Re*, RW D
- O O
O arter B
D O
stier VT Mgr: Schopfer, Don K O
O O
arse 7 sec Chen: Singh, Anand K O
O O
arrier
~
Date:
WWALS:
Done. 9/23/97 Res0LUTION: Disposition:
g NU has concluded that D!screpancy Report, DR MP3-0027, has identified a condition not previously discovered by NU which requires correction. This error is editorialin nature. The correct nuclide was used for a 1 relevant calculations. An FSAR CR will be issued to correct the error. CR M3-97 2916 was initlated to provide the necessary corrective actions to resolve this issue.
==
Conclusion:==
NU has concluded %at Discrepancy Report, DR MP3-0027, has identified a condition not previously discovered by NU which 4
requires correction. An FSAR CR will be issued to Correct the error. CR M3 97 2916 was initiated to provide the necessary corrective actions to resolve this issue.
~
.../ : - _, Identdled by Nu? - U Yes @ No Non D6ecrepent Condition U Yes @ No
^
Review initiator: Johnson, W. J.
~ '
VT Lead: Reheja RajD s
T VT Mer: Schopfer, Don K IRC CN: Singh, Anand K O
O O
im Date: -
SL Commento Printed 10/294711 o5:19 AM Ps0e 1 of 1
~
Northeast utsties ICAVP DR No. DR MP3 0028 asseistorm unit a Discrepancy Report moview eveup: Acohierd haugehen DR RESOLUTION AcctPTED I "*
Dissipline: Deer Potentiel operatuity leeue
-, Type: Liesmeing Docunent O vee eyesenWpressee.* N/A gg NRC Signissense lows: 4 Date faxed to NO:
e Date Pubsehed: s/2297 t.
e inconsistency in FSAR Section 15.7
-r Desertpelea: We have reviewed FSAR Chapter 15 and have identified the following discrepancy:
In Sedion 15.7.5, Spent Fuel Cask Drop Ac jents, Subsection 15.7.5.1, Analysis of EffeMs and Consequences, the first sentence roads "A spent fuel handling accident is..." This should be dianged to "A spent fuel cask drop accident is...'
vand Irwebd Needed Date inistster: Johnson,W, J. -
G O
O artier VT Lead: Rehele Rei0 G
O O
setier vitegn schapler DonK G
O O
sever sec cienn: sing'. Anand K G
O O
r/1/87 Deme:
p INWaLS:
c j
Date: 10/20/97 I
Raa0LUTION: Disposition:
NU has cJncluded that Discrepancy Report, DR MP3-0028, has identified a condition not previously discovered by NU which requires corredion. Originally, NU equated a " spent fuel handling accident" to a " spent fuel cask drop accident." Based on the input from this DR, NU has found that the wording is inconsistent with other 15.7 subsections. An FSAR CR will be issued to corted the error. CR M3-97 2821 was initiated to provide the necessary corrective actions to resolve this issue.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR.MP3 0028, has identified a condition not previously discovered by NU which requires correction. An FSAR CR will be issued to correct the error. CR M3 97 2821 was initiated to provido the necessary corrective adlons to resolve this issue.
M/ _, identelled by Nut V Yes @ No Non Diacrepent Condition V Yes @ No i
Review intuosen Johnson.W.J.
VT Lead: Rehele,ReiD D
D
-7 VT Mgr: Schopfer. Don K O
O
-7 IRC Chmn:' Singh, Anand K g
7 es alComments:
\\
I
~
Preced 10/2a9711:072 AM Page 1 of 1
Northeast UWWes ICAVP DR No. DR44PS 4268 unshww unit 3 aiscrepancy Report nevieweesuP: Anementumsenen on nasoLUTION ACCEPMo a*
- am.ieie u e
P,o Oneinano:ia c
- O vee 08ee'epeasy Type: Celeuinen gg treteWPresses: N/A NRC Signmeanee imi: 4 Date faxed to NO:
Date Putd6ehed: 10r397
,. Reactor Coolant Pump Underspeed Calibration Data Conversion (Discrepancy for Loop RCS*SY495)
Desertreisa: The ICAVP reviewed the following documents in order to
. evaluate the low shaft speed Reactor Trip function setpoint:
References:
- 1) FSAR Floure 7.21, sheet 5
- 2) Procedure 3442H01, Rev.7, Low Shaft Speed Reactor Trip Calibration
- 3) 14C Form 3442H01 1, Rev. 7. Data page 3 of 5
- 4) Technical Specification Manual, Table 2.21 item 15 Amendment 114 in reviewing these documents the ICAVP identifies the following y
disoropancy:
1he use of the Engineering Unit Conversion Factor shown in the Reference 3) Data Sheet, titled 'SETPolNT REFERENCES",
will not convert the calibration data to the acceptable seipoint values shown in Reference 4),.
SETPOINT
REFERENCE:
TECHNICAL SPECIFICATIONS (TS) Table 2.21, item 15 (TRIP SETPOINT >=95.8% of rated speed);
1 Hza.395% Rated Nominal Speed (from Page 3 of Data Sheets).
In order 10 convert the calibration data of 37.847 Hz (Page 3 of Data Sheets) to a calibrated speed in % and compare it with the acceptance criteria in the TS of >=95.8% the following must be performed:
1 Hza2.5316%;
Calibrated Speed in % = 37,847Xt.5316s 95.815 (%),
neview Valid inveNd Needed Dale inteister: Beinde, V. E.
Q
-O O
ar24,7 viLand: Rehek. Rai D D
'O O
st24,7
. VT Mgr Schopfer, Don K
'O O
O.
irass7 inc Clunn: Singh. Anand K O
O O
S27/87 Dese:
wvAuo:
Date: 10/21/97
[; -
nasoLUTioN. Disposition!
- Printed 1or2a4711:0e se AM.
Page 1 of 2 lI
Netheast Utilitie.
ICAVP DR No. DR MP3 0266 mustaw Unit 3 Discrepancy Repoft NU has concluded that Discre,ancy Report, DR MP3-0255, has identified a condition not pre flously discovered by NU which requires corredion.
There is no imped to the Reactor Coolant Pump Underspeed Channel calibration because the conversion fador listed on the data at.4et is reference information only. The incorrect data is not used in the performance of the test. The trip setpoint is measured and set based upon frequency input from an extemal test Function / Pulse generator. The Trip setpoint and Technical Specification Acceptance Criteria in the l&C Form 3442H01 1 used the corted conversion factor to develop the surveillance acceptance ortterk for this test. The Setpoint Reference section of the data sheet is an erroneous presentation of the conversion fador. Condition Report (CR) MS 97 3453 has been written to provide the necessary corrective actions to resolve this issue.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3 0255, has identified a condition not previously discovered by NU which requires corredion. No work is required in the field.
[
Condition Report (CR) MS 97 3453 has been initiated to provide the necessary corredive action to resolve the issue. The Reactor Coolant Pump Underspeed channel Calibration procedure will be revised to corred this error of reference information Pseuteuesy idenmand by Nut U Yes @ No Non Descrepent Cuuhteen U Yes @ No Rev6ew Aseeptable Not?n "
Needed Date N Balmas.VA VT Lead: Rehele. Ral D 0
0 O
y, u,n n,,,,,, o,, x IRC Clunn: sinsh, Anand K Date:
sL Cenenents:
PrNed 10/2W971199.c6 AM Page 2 of 2 I-..,ll
Nortmast UtWties ICAVP DR No. DR MP3 0009 Mastorm unit 3 -
Discrepancy Report movtowGroup: AeoidentMalgehen DR REsot.UTioN MEJECTED PotenuelOpereidity issue O vee Deserepancy Type: Useneing Document g g, a, f -
a N/A NRc tientasense level: 3 Dele faxed to NU:
Date Putdiohed: 622/97
~
- ri 10CFR 50.59 for ATWS Does Not Address ' increase in Feedwater Flow" i
Descriptiea: The 10CFR 50.59 safety evaluation for the Anticipated Transient I
Without Scram (ATWS) modification does not addr' O the modification's impact on an increase in feedwater flow accident.
- The 50.59 addresses the impact of a cpurious turbine trip, but does not address spurious initiation of auxiliary feedwater. This impact needs to be addressed.
Revtew vend invand Needed Dele insister: Mish, J.
O O
O 7/387 vit.eed: nahefe, Rei o O
O O
7/31/87 VT Men schopfer, Den K O
O O
ara 7 me chin : sign,Anandx 0
O O
a/tive7 p
este:
ones: 10/15/97 nemoumoN. Disposition:
NU has concluded that the issue renorted in Discrepancy Report, DR-MP3-0009, does not represent a discrepent condition.
NU has reviewed the Integrated Safety Evaluation (ISE MP3-88 008) associated with the PDCR (MP3 88-008) that installed the AMSAC Modifications, We have determined that the ISE appropriately and adequately addresses the issue of spurious initiation of Auxiliary Feedwater on page 2,4 and 6 of the attached evaluation. This evaluation was completed in accordance with NSAC 125 guidelines, which at the time, represented the best available guidance for completing safety evaluations. Significance Level criteria do not apply as this DR does not represent a discrepant condition.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report, DR MP3-0009, does not represent a discrepant condition. NU has reviewed the Integrated Safety Evaluation (ISE MP3 88 008) associated with the PDCR (MP3-88-008) that installed the AMSAC Modifications. We have determined that the ISE appropriately and adequately addresses the issue of spurious initiation of Auxillary Feedwater on page 2,4 and 6 of the attached evaluation. This evaluation was completed in accordance with NSAC 125 guidelines which, at the time, represented the best available guidance for completing safety evaluations. Significance Levei cetteria do not apply as this DR does not represent a discrepant condition.
Prtreed 10/21WD710.57;47 AM -
N go 1 or 2
Netheast utWtles ICAVP DR No. DR MP3 0009 mastone unit 3 Discrepancy Report e
Prevenemer hamnused any Nur U Yes @ No Non Dion,epent Condmon U Yes @ No Rev6.w
^-;^_
Not ^^^ '
Needed Date D
D D
VT t.eed: Rehele.ReiD O
O O
m7 yr,,,,,,,,,,,,, o,, g f
unc chmn: singh. Anand K
-Dok:
10/15/97 at.conenents: ICAVP finds the disposition not acceptable. The discrepancy as stated in the Description Section of Discrepancy Report DR MP3-I 0009 is that the safety evaluation for the ATWS modification "does not address the modification's imped on an increase in feedwater flow accident." We do not dispute the fad that I
spurious initiation of feedwater flow is addressed in the safety evaluation. However, Part 1.1 of the NU safety evaluation form requires identification of " design basis accidents potentially impacted by the change." An increase in feedwater flow accident should be identified in this portion of the safety evaluation and propedy addressed and evaluated in Parts 1.2 and 3 of the safety evaluation form, i
' s l
L Peted 10/2k9710.57:56 AM -
Pope 2 of 2
Nwtheast Utilmen ICAVP DR No. DR MP3 0014 Mmetwo Unit 3 Discrepancy Report Revtew Group: Progreermeio DR REsOLMTION REJECTED Review Elemere: conecove lesen Process g,,,,,
O va
- p Type: Usensing Desumert (f)No systenWPresses: Ras istc signiaeance level: 4 Date faxed to NU Date Putdiohed: W22/97 deeroponey: Inadequate Response on How Action Will Prevent Recurrence (ACR8MI 961015)
Desertption: The Ucensee's response in the ACR documentation on how corredive actions will prevent or reduce the possibility of recurrence is inadequate.
Amendments 100 and 122 of Tech. Specs. were issued using an out-of date revision of Tech. Specs. This was documented on ACR M3 961015. ACR M3-961015 (block 6 of form RP 41) recommends that " Licensing dept, should investigate the cause for this condition and propose corrective adlons to prevent recurrence." Contrary to the recommendations, the ACR indicates on Form RP 44 that a causal fador determination is L
not required in block 7 of form RP 4 7. the Licensee is required to state 'how the corredive adions will effectively prevent or reduce the possibility of the same or similar event or adverse condition from happening again". The Licensee's response to this question is " Administrative Error Correction Needed." No j
evidence is provided to indicate that the adual mechanism by l
which the administrative error occurred was determined (ie., how l
was the wrong revision of Tedi. Specs used to process new Tech Spec. Amendments, am procedural controls for processing Tech. Spec. Amendments adequate 7 etc.) and that any specific action is planned to prevent recurrence as recommended by the initiatorof the ACR.
Rev6 w Vaud invalid Needed Date inlaister: Nevervo Mark O
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7tatis7 VT Laod: Ryan, Themes J Q
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W4/97 Ve Mor: Echopfer. Den K O
O O
- /5/S7 WIC Chmn: singh. Anand K O
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stiseer Date:
INWAUD:
Date: 10/15/97 REscumoN: Disposition NU has concluded that the first issue in Discrepancy Report, DR-MP3-0014, does not represent a discrepant condition. Procedure RP 4 (Form RP 4-4) requires management to review the ACR and assign the significance level and issues to be addressed (see RP4, rev. 4, section 1.9 Unit Corrective Action Manager Review). There is no requirement to endorse the initiator's recommendations verbatim. Management assigned this ACR a level *D' which does not require a causal factor review and is in compliance with RP 4.NU has concluded that the secored issue Prtnted 1021W9711:o2c1 AM.-
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4 Northeast UtWties ICAVP DR No. DR44P34014 Mastone unit 3 Discrepancy Report identified in Discrepancy Report DR-MP3-0014 has identified a condtion not previously discovered by NU which requires corredion. The response ' Admin. Enor Corredion Needed* In block 7 of RP 4-7 is inappropriate and will be correded. CR M3-97 3172 was written to provide the necessary corrective actions to reso!ve this issue. This discrepancy condition does not affect the licensing and dos:gn basis. Based on the administrative nature of this discrepancy NU has concluded that this DR should be designated a Significa fios Level 4 discrepancy.
Conclusion i
y-
. NU has concluded that the first issue in Discrepancy Report DR.
- MP3 0014 does not represent a discrepent condition. Procedure RP4 requires management to review and assign significance level and issues to be addressed ( see RP4, rev. 4 section 1.9 Unit Conective Adion Manager Review).
NU has concluded that the second issue identified in Discrepancy Report DR MP3-0014 has identified a condition not Y
previously discovered by NU which requires correction. The responee in block 7 of RP 4 7 is inappropriate and will be oonecthiCR M3 97 3172 was written to provide the necessary cone 4&Mions to resolve this issue.This discrepancy condWwt M not affed the licensing and design basis. Based on the ai4mHdrative nature of this discrepancy NU has ooncluded that the DR should be designated a Significance Level 4 discrepancy.
l Provuumy idenamed by Nu? Q Yes @ No - Non Dioceepont Cenenen Q Yes @ No
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We Not #-
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Needed Date O
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N7 l
. VT l.and: Ryn. Thomas J vfm n schopor,conx 0
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1Rc Chan:~ singh. Anend K Date:
10/15/97-s K
sL conenents: The Licensee's response to this DR is not acceptable on the following basis:
The Licensee's response includes reference to a new CR (CR M3-97 3172) *.which has been generswd to i.ddress an inappropriate J
response in block 7 of form RP4-7 of ACR M3-961015.
' A copy of the new CR with planned corrective action OR a desaipNa of the planned corrective action in this DR response 4
(which "nswers "how the corrmive actions will effectively prevent or reduW t% possiNltty C;W same or similar event or adverse condition frcm happe 11rq cgaln") was not provided for our D
review 4
F Reference only to the new Clt by number without a description of Y
the planned correctivs setico it. !.* sufficient for our review since the reviewine; des its pait, so assessment of the adequacy of the
' }l plannen corrective ad'ons, p.
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