ML20216C896
| ML20216C896 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/12/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9803160230 | |
| Download: ML20216C896 (114) | |
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-Sar gert.4 Lundy 'c Don K. Schopfer Senior %ce President 312-269-6078 March 12,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed the following six (6) 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-MP3-1044 DR No. DR-MP3-1077 DR No. DR-MP3-1057 DR No. DR-MP3-1081 DR No. DR-MP3-1071 DR No. DR-MP3-1082 I have also enclosed the following thirty-one (31) DRs for which the NU resolutions have been l
reviewed and accepted by S&L.
DR No. DR-MP3-0149 DR No. DR-MP3-0559 DR No. DR-MP3-0157 DR No. DR-MP3-0590 DR No. DR-MP3-0189 DR No. DR-MP3-0673
~
DR No. DR-MP3-0197 DR No. DR-MP3-0733
,L f
DR No. DR-MP3-0302 DR No. DR-MP3-0845 l
DR No. DR-MP3-0307 DR No. DR-MP3-0853 DR No. DR-MP3-0362 DR No. DR-MP3-0858 DR No. DR-MP3-0365 DR No. DR-MP3-0870 DR No. DR-MP3-0382 DR No. DR-MP3-0872
.,n,0 V U d, DR No. DR-MP3-0384 DR No. DR-MP3-0894
- DR No. DR-MP3-0435 DR No. DR-MP3-0897 DR No. DR-MP3-0452 DR No. DR-MP3-0902 DR No. DR-MP3-0458 DR No. DR-MP3-0911
((((\\\\{\\\\\\{ll{}$kkll\\fkkk DR No. DR-MP3-0467 DR No. DR-MP3-0926 DR No. DR-MP3-0481 DR No. DR-MP3-0956 9803160230 900312 DR No. DR-MP3-0995 PDR ADOCK 05000423 P
P DR.,............. Chicago, IL 60603-5780 USA
- 312-269-2000 J
E
United States Nuclear Regulatory Commission March 12,1998 Document Control Desk Project No. 9583-100 Page 2 l
I have also enclosed the four (4) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.
DR No. DR-MP3-0068 DR No. DR-MP3-0077 DR No. DR-MP3-0598 DR No. DR-MP3-0831 Please direct any questions to me at (312) 269-6078.
Yours very truly,
(
.I
/
D. K. Schopfer Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/1)NU mnicavpbrA98W0312-a. doc I
Northe:st Utilities ICAVP DR N2. DR-MP34149 umstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p
Diecipline: Structurel Design Om Discsepancy Type: Calculation
@ No SystemfProcese: SWP NRC Signi;lcance level: NA
% 'Med to NU:
Date Putdished.1o/1o/s7 D6screpancy: Small Bore Pipe Support Calculation Discrepancy Dacription: We have reviewed Calculation no. NP(B)-1061-XC,Rev.1. Based upon the results of the revi3w,the following discrepancy has been noted:
Weld equations 4.1.1(a),4.1.1(b),4.1.2(a) & 4.1.2(b) contain multipliers (coefficients) for forces and moments for 3/4"NPS clamp plate. Calculation no. NP(B)-1071-XC,Rev.1,pg.no. 81 has been referenced as a source of derivation for the multipliers (coefficients).
Review of Reference calculation has determined that this reference is not appucable to the aforementioned weld equations since it provides test data for pipe slip of 1/2" NPS clamp.Therefore, the adequacy of the weld equations cannot be verified.
Review Valid invalid Needed Date initletor: Kleic, N 9
O O
st2 sis 7 VT Lead: Nert, Anthony A B
O O
st2srer VT Mgr: Schopfw, Don K B
O O
8/30/97 NtC Chmn: Singh, Anand K B
O O
ior2/97 Date:
NWAUD:
Date:
3/6/98 RESOLUTION. NU has concluded that Discrepancy Report, DR-MP5-0149, does not represent discrepant condition. Calculation NP(B)-1061-XC, Rev.1 references calculation NP(B)-1071-XC, Rev.1 as the source of equations 4.1.1 (a),4.1.1 (b),4.1.2 (a) and 4.1.2 (b).The referenced test data for pipe slip of 1/2" NPS clamp is depicted on page 81 of Rev.3 to calculation NP(B)-1071-XC, the correct information comes from Revision 1. Attached is calculation NP(B)-1071-XC, Rev.1 to confirm that the referenced information is correct.
Previoudy identmed by NU7 O vu (e) No NonDiscrepentConstion?@ vos O No Re.woiion P.nane70 y=
@ No RenksonUntmaved70 va @ no Review Ae=rdA a Na* * -- " _ Needed Date VT Lead: Nerl. Anthony A O
O O
3/11/98 IRC Chmn: syth, Anand K O
O O
Date:
SL Comments:
Pnr4ed Y1298 3.19:12 PM PeGe 1 of 1
Northeast Utilities ICAVP DR No. DR-MP34157 l
Millstone Unit 3 Discrepancy Report Review Group: Syelem DR REGoLUTioN ACCEPTED Review Element: Syelem Design y
gy Diecipline: Piping Design Om Discrepency Type: ceicuestion (e)No systemerecese: N/A NRC 8:f-ace level: NA Date faxed to NU:
Date Published: 9/19/97 Diecrepency: High frequency modes not accounted for in the response spectra seismic analysis
==
Description:==
In the process of reviewing the following documents, (i) FSAR Section 3.78.3.1.2 Seismic Analysis Methods - Piping Systems (ii) Pipe Stress Analysis Criteria Document, NETM-44, Revision 2
(iii) US NRC Standard Review Plan, NUREG-0800, Section 3.7.2 we noted the following discrepancy:
Background:
According to (i) and (ii): All significant dynamic modes of response under seismic excitation with frequencies less than 50 cps or modes less than 50, whichever is reached first are included in the dynamic analysis.
According to (iii): Sufficient modes must be included in a dynamic response analysis to ensure the participation of all significant modes. The criterion for sufficiency is that the inclusion of additional modes does not result in more than a 10 percent increase in responses. A demonstration that adequate consideration la given to the high frequency modes is required.
According to Appendix A to (iii): The implementation of the abo
- quirement may require the inclusion of modes with nk quencies at which the spectral acceleration roughly rMums c 9,e zero period acceleration (ZPA). The square-root-of-sum-of-squares (SRSS) combination of such modes is highly inaccurate and may be significantly unconservative.
Discrepancy:
The above cdteria from (i) and (ii) does not ensure that all piping system modal frequencies below the response spectra cut-off frequency will be included in the system seismic response calculation. If the frequencies associated with the first 50 modes are less than the cut-off frequency, the above criteria would imply that only these first 50 modes would constitute the system seismic response. Doing so, however, is un-conservative, and does not cover the entire frequency range of the response spectrum.
The ahnum tvitarin frnm rn nnri (in rinac ned attanientalv neitirect Prtnted 3/1296 3.19 47 PM Page 1 of 3 d
l Northe:st Utipties ICAVP DR No. DR-MP3-0157 Millstone Unit 3 Discrepancy Report thw intended requirements of the SRP (iii).
Review vand invand Nooded Date initis1or: Prekesh, A.
O O
O 8'5'87 VT Lead: Neri, Anthony A B
D D
8/'o'87 VT Mor: schopfer, Don K B
O O
8/10/87 IRC Chmn: Singh, Anand K O
O O
st12/97 Date:
INVALID:
Date:
3/9/98 RESOLUTION Response ID: M3-IRF-01176 Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0157, does not represent a discrepar:t condition. Pipe stress analysis utilins a cut-off for modal participation based on the criteria of 50 Hz or 50 modes, whichever is reached first. This is specifically licensed as documented in FSAR Eection 3.78.3.1.2. and typically results in a high percentage of mass participation 90 to 95%. Although no specific check is required, the analysts and stress group lead are cognizant that extremely stiff systems may only have a few modes participating below the 50 Hz cut-off frequency. In these unusual cases, the seismic analysis would typically be extended to 100 Hz to capture the significant modal response. Significance level criteria does not apply as this is not a discrepent condition.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0157, does not represent a discrepant condition. Pipe stress analysis utilizes a cut-off for modal participation based on the criteria of 50 Hz or 50 modes, whichever is reached first. This is specifically licensed as documented in FSAR Section 3.78.3.1.2. Significance level criteria do not apply as this is not a discrepant condition.
Previously identined by NU? O Yee @ No Non Discrepent condition?(#) Yee O No ResolutionPonding?O vee @ No Resoiutionunrosoeved?O vee @ No Review Acceptable Not Accepdeble Needed Date m,,,
g VT Leed: Nat. Anthony A VT Mgr: Schopfer Don K IRC Chmn: Singh, Anand K Dese:
3/9/98 sL commente: NU states that "the analysts ard stress group lead are cognizant that extremely stiff systems may only have a few modes participating below the 50 Hz cut-off frequency. In these unusual cases, the seismic analysis would typically be extended to 100 Hz to capture the significant modal response".
The analysts and stress aroup lead should also be coonizant that Prtnted 3'12/96 3.19.51 PM Page 2 or 3
Northe:st Utilities ICAVP DR No. DR-MP3-0157 Millstone unit 3 Discrepancy Report for extremely flexible systems, or large piping models, the cut-off mode criteria of 50 may not be sufficient to cover the full range of the response spectra. In these unusual cases also, the seismic analysis would have to be extended to include 100 modes, or more, to capture the significant modal response.
NU states that no specific check is required to ide"tify these
" unusual" cases. Extension of the range of modes to be included in the seismic anlaysis is left up to the cognizance of the analyst and the group lead.
l Several " unusual" cases were identified in the process of reviewing stress analysis calculations. Although the ranQe of modes considered was not always extended to capture the significant modal response in earlier revisions of these calculations, in the latest revisions of these calculations this has been done. Therefore, S&L concurs with NU's re ponse that this is not a discrepant condition, and as such significance level criteria do not apply.
)
l Printed 3/12/96 3:19 s3 PM Page 3 of 3
Northe:st Utilities ICAVP DR ND. DR-MP3 0189 umstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: Mechanical Design Om Discrepency Type: Lkeneing Document
- No System / Process: sWP NRC Signiacence novel: NA Date faxed to NU:
Date Putished 1/10/96 Discrepency. FSAR Section 9.2.1.2 is not consistent with P&lD EM-133D
==
Description:==
While dispositioning Requirement SWP-0073, the following discrepancy was noted:
FSAR Section 9.2.1.2 [Page 9.2-5] states:
"Whenever an emergency generator starts, sufficient service water is suoplied to the emergency generator engine coolers by the automatic opening of air-operated valves located in the discharge lines of each emergency Generator engine cooler."
The valves referred to here are 3SWP'AOV39A & B. Per the P&lD [EM1330), and the associated logics and schematics, the valves open automatically only on receipt of LOP, SIS, or CDA si0nal. Any other time the diesels are started, e.g. for surveillance testing or any manual starts, operator action is required to open the service water valves in order to provide cooling water to the coolers in question. There is no inte 1ock bewteen the valves and the engine to ensure that they are open any time the diesels are running. Therefore the FSAR requirement is not fulfilled.
Since the diesels are already declared inoperable during surveillance testing, and no other conditions for the diesels to start without cooling water were identified as part of this review, no operability issue was raised.
[UIR 54 identified a similar concem related to an Appendix R fire in the cable spreading / control room requiring manual action to dump the air from the AOV diaphragms in order to start the diesels; the UlR also identified that requirement as being in conflict with the FSAR.]
l Review i
valid invoud Needed Date l
inittstor: Tonwinkel, J. L G
O O
s2tias7 VT Leed: Neri, Anthony A B
O O
$2itais7 VT Mor: senopfw, Don K G
O O
12/23/97 1RC Chmn: singh, Anand K G
O O
$2 ratio 7 Date:
INVAUD:
Date: 3/11/93 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0189, does not represent a discrepant condition. The EDG is normally aligned for auto start, which is the condition described for the Service Water valves in Section 9.2.1.2 of the Printed 3/s2/96 3.20-21 PM Page 1 of 2
Northe:st Utilities ICAVP DR N2. DR-MP3-0189 Millstone Unit 3 Discrepancy Report FSAR. The FSAR does not describe every line-up for the Service Water valves. There are procedures which govem the surveillance testing of the EDGs, and ensuring that service water flow is established. Procedure Nos' SP 3646A.1 & A2, i
Emergency Diesel Generator A & B Operability Test, respectively, step 4.2.3 opens 3SWP*AOV39A & B prior to step 4.2.5, which actually starts the diesel. The statement in question, that the valves open automatically whenever the diesel starts, is I
taken from the paragraph in FSAR Section 9.2.1.2, System Description, that deals with operation during hot shutdown due to Loss of Power (LOP). Further details of the valve operation are not required in the FSAR. UlR # 54 was closed VOID with the conclusion that the valve will operate as designed.
Significance Level criteria do not apply as this is not a discrepant condition.
==
Conclusion:==
l l
NU has concluded that the issue reported in DR-MP3-0189 does not represent a discrepant condition. It is true that " automatic" i
valve operation does not occur from a manual start. However, a manual start is a deliberate act govemed by procedure. The intent of the FSAR is to address automatic diesel start to support i
an LOP, SIS or CDA. The statement in question, that the valves open automatically whenever the diesel starts, is taken from the paragraph in FSAR Section 9.2.1.2, System Description, that I
deals with operation during hot shutdown due to Loss of Power (LOP). There are procedures which govem the surveillance testing of the EDGs, and ensuring that service water flow is established. Procedure Nos' SP 3646A.1 & A2, Emergency Diesel Generator A & B Operability Test, respectively, step 4.2.3 opens valves 3SWP*AOV39A & B prior to step 4.2.5, which actually starts the diesel. Further details of the valve operation are not required in the FSAR.
Significance Level criteria do not apply as this is not a discrepant condition.
Previously identifled by Nu? O Yes @ No Non D6ecrepent Condition?@ Yes Q No Resolution Pending70 v.
@ No p+ uar=*ed70 va @ No Review Acceptable Not A-- - ""- Needed Date VT Leed: Neri. Anthony A VT Mgr: schopfer, Don K NtC Chmn: singh. Anand K Dete:
3/11/g3 sL commente: Even though the service water flow is not automatically controlled under all conditions, S&L agrees with NUs disposition that it is adequately controlled by procedures in those instances where automatic control is not provided.
Printed L/12/98 3 20:27 PM Pope 2 or 2
)
Northe:st Utilitie3 ICAVP DR No. DR-MP3-0197 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Piping Design D6screpancy Type: Calculaten g
SystemProcess: N/A E
4 Date faxed to NU:
Date Published: 9/19/97 Discrepancy: Discrepancy between FSAR damping values and those used in fluid transient time-history analyses Ducription In the process of reviewing the inliowing documents, (i) FSAR Section 1.8 - Nuclear Regulatory Guides (RG 1.61)
(ii) FSAR Section 3.78.1.3 Critical Damping Values (iii) FSAR Section 3.7B.3.1.2 Piping Systems (iv) Time History Analysis Calculation 12179-NP(B)-355-XF Rev.
1,CCN1 (v) Time History Analysis Calculation 12179-NP(B)-366-XF Rev.
O, CCN 1 (vi) Time History Analysis Calculation 12179-NP(B)-371-XF Rev.
OCCN1 we noted the following discrepancy:
Back0round:
According to (1):
- The NRC granted that Millstone Nuclear Power Station Unit 3 will not be required to comply with RG.1.61, Damping Values for Seismic Design of Nuclear Power Plants, dated October 1973.
- Plants docketed prior to April 1,1973 are not required to address this Re0ulatory Guide. FSAR Tables 3.7B-1 and 3.7N-1 list the damping values used with Seismic Design of Millstone 3.
According to (ii): " Damping values utilized in the analysis of Seismic Category I structures, systems and components are conservative with regard to Regulatory Guide 1.61, which does apply as described in Section 1.8".
According to (iii): Damping values used for piping are 0.5 percent for OBE and 1 percent for SSE, except that increased damping values may be applied on an as-needed basis for final stress reconciliation (or piping system backfits) in accordance wei ASME Code Case N-411.
Discrepancy:
The two secticas of the FSAR (i) and (ii) are inconsistent in regards to the use of RG 1.61.
RG 1.61 damping valuts are used in the fluid transient time-history analyses. For example, see (iv), (v) anu (vi). These dansping values are not consistent with and are less enntarvallum than ihnca cnmMfiari in riin Page 1 or 3 Printed 3/12/96 3:20:55 PM
Northe r_t Utilities ICAVP DR No. DR-MP3-0197 Millstone Unit 3 Discrepancy Report n.vi vm imraiia ua D.i.
initiator: Prakash, A.
Q Q
W11S7 VT Lead: Nwl, Anthony A B
O O
8/1157 VT Mgr: Schopfer. Don K O
O O
at2m7 l
IRC Chmn: singh. Anand K 8
0 0
S' 3'S7 Date:
INVALID:
Det.: 3/10/98 RESOLUTION Response ID: M3-IRF-01327 Disposition:
NU has concluded that the issue reported in Discrepancy Report DR-MP3-0197 has identified a condition previously discovered by NU which requires correction. Considering the damping values listed in Table 3.78-1 that are clear 1y different from the regulatory guide, the prior statement that the higher values are used only when justified, and the syntax of the phrase "which i
does apply", makes it clear that the word "not" was unintentionally omitted from the phrase. Thus it was originally intended to read "which does not apply". The typographical error was previously discovered by NU. FSARCR 97-MP3-413 was initiated on 4/17/97 to clarify that, consistent with FSAR Section i
1.8, Millstone 3 was granted an exemption to Regulatory Guide 1.61. Therefore consistency with the regulatory guide is not required, and there is thus no inconsistency with the licensing basis. On the issue of time-history integration analysis of fluid transient loads, FSAR Section 3.78 describes analysis for earthquakes only; there is no statement regarding damping values to be used for fluid transient analysis. Consistent with the section title, ' Seismic Design', all statements pertain only to seismic analysis. The requirements of Regulatory Guide 1.61 are similarly limited to damping values to be used in response i
spectrum or time history analysis of seismic loading events.
Since there is no FSAR commitment regarding damping for Puid transient loading, and no Regulatory Guide 1.61 requirement regarding them, there is no discrepancy. Damping values that were used for time history analysis of fluid transient loading were i
controlled and specified via the piping design specification, 2280.000-149, Rev.13 dated 12/6/1985 with Addendum 1 dated 12/11/1985. Pipe stress criterla NETM-44, referenced in the piping design specification, references a lower tier document, Stone & Webster memorandum EMD-82-07 (attached). It specified on page 3 that if not otherwise available, the damping values from Regulatory Guide 1.61 should be used. Thus the damping values used for time history analysis of fluid transients were coitsistent with the piping design specification. Since the previously discovered discrepancy is typographical in nature, and does not result in non-compliance with the design basis, NU believes that this is a Significance Level 4 issue.
Attachments: 1. Excerpt from in-process FSARCR 97-MP3-413 showing proposed chance to Section 3.7B.1.3.2. S&W Print.d 3/12/96 3.2o 59 PM Page 2 of 3
f Norther.st Utilitie3 ICAVP DR No. DR-MP3 0197 millstone Unit 3 Discrepancy Report I
memorandum EMD-82-07 ' Dynamic Analysis of Fluid Transients Utilizing NUPIPE-SW(ME-110)' dated 6/16/1982.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report DR-MP3-0197 has identified a condition previously discovered by NU which requires correction. FSARCR 97-MP3-00413 was initiated on 4/17/97 to clarify that, consistent with Section 1.8, Millstone 3 was granted an exemption to Regulatory Guide 1.61.
Since the discrepancy does not involve a departure from licensing basis, the Significance Level should be 4.
Previously identified by Nu? ($ Yee U No Non Discrepent condition?U Yes (@ No RudutionPending?O va @ No RndutionUnrudved?O Ya @ wo Review initiator: Prokesh, A.
VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K oete 3/10/98 SL Corronents: S&L concurs that the first discrepancy is typographical in nature, and does not result in non-compliance with the design basis. This is a Sionificance Level 4 issue.
On the issue of time-history inte0 ration analysis for fluid transient loads, NU's response is based on a somewhat narrow interpretation of the FSAR that different values of structural damping apply for earthquake induced vibrations than for fluid transient induced vibrations. As the piping system does not distinguish between the source of the vibration in selecting structural damping, the different damping values are presumably Justified on the basis of uncertainties in the load definitions.
S&L concurs that since there is no literal FSAR commitment regarding damping for fluid transient loading, there is no discrepancy.
Printed 3/12S6 3.2101 PM Page 3 of 3
Northe:st Utilities ICAVP DR No. DR-MP3-0302 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: I & C Desigr.
Om Discrepancy Type: Calculation gg System / Process: Rss NRC Signincance level: 4 Date faxed to NU:
Date Published: 11/15/97 Discrepancy: Calcualtion NSP-101-RSS data discrepancies
==
Description:==
The purpose of calculation NSP-101-RSS, Rev. O is to provide setpoints for opening the Containment Recirculation Pump min flow recirculation valves 3RSS*MOV38A, B for low flow conditions (especially during start-up and shutdown conditions) and closing once normal pump flows are established.
There were several discrepancies identified during the review of the calculation. Following is a listing of these findings:
[
- 1. Per page 8 of the calculation the transmitter errors are assumed to be similar to model 11538. Per specification no.
2472.510-662, revision 0 data sheet (pye no 2-55) for 3RSS*FT38A/388, model no. is 1154HP4RC. Hence, specifications figures for model 1154, series H dated April, 89 were reviewed. The following is a list of discrepancies between the calculation and the Rosemount manual:
Type of error Calc. data Rosemount data Supply voltage 0.15% of span
< 0.005% of effect error out put span / volt Operating 2.5% of URL +
Max LOCA influence of 0.5% of span Temp-420'F temp during
+/-(1% URL +
accident 1% SP) Range code 4-8.
Operating 1.5% of URL
- (0.2% URL +
influence
+ 1% of span 0.2% SP) of accident radiation Drift error 0.25% of URL Post DBE i 2.5%
- 2. The converter errors and bistable errors appear on page 9.Per reference 6 page 3-4L, the ccfiverter accuracy is 10.25% of output span. Attachment 3 of the calculation identifies it as 0.5%
of span. Per Reference 6 page 3-9A, there is a voltage to voltage converter in the loop. Calculation does not account for this converter. Per page 3-10J of reference 6 the bistable accuracy is i2% of input span. The calculation identifies it as 11% of span per attachment 4. Based upon these observations calculated accuracy verification could not be performed.
Review Printed 3/1298 3.23 41 PM Page 1 or 3
3 Northeast Utilities ICAVP DR No. DR-MP3-0302 Millstone Unit 3 Discrepancy Report Vaud invand Needed Date initietor: Hindia, R.
O O
O 5 15/87 VT Lead: Neri, Anthony A B
O O
11/5'87 VT Mgr: Schopfer, Don K G
O O
11/7/87 1RC Chmn: Singh. Anand K B
D D
11/11/S7 Date:
INVAUD:
Date: 3/11/98 RESOLUTION Disposition:
I NU has concluded that Discrepancy Report, DR-MP3-0302, has identified a condition previously discovered by NU which requires correction. The discrepant data issues identified in Calculation NSP-101-RSS, Rev.0, have been resolved in revised Calculation NSP-101-RSS, Rev.1, Dated 10/17/97.
ACR No. 6627, Dated 1/12/96, identified Calculation NSP-101-RSS, Rev. O, "3RSS*FT38A,B-Setpoint for Miniflow Recire. Line Operation of 3RSS*MOV38A,B (3RSS*FS38A1, A2, B1, B2)"
having errors due to failure to account for the non-linear characteristic of flow measurernent and incorrect assumptions of instrument accuracy. Corrective Actions for ACR No. 6627 resulted in issuing a Setpoint Change Request including a revised uncertainty for NSP-101-RSS.
The following changes have been incorporated in Calculation NSP-101 RSS, Rev.1, to eliminate the conflicting data issues identified in DR MP3-0302.
- 1. This issue identified conflicting calculation transmitter calibration data when comparing an assumed Page 8, similar Rosemount Model 1153B Transmitters technical data to Page 6, i
Reference 5, Specification No. 2472/10-662, Rev. O, l
Rosemount Model 1154, Series H techc.ical data.
The transmitter data documented in the revised calculation is specifically identified with the correct Rosemount Model 1154 product data sheet (Reference 10, Attachment D) where applicable. Where required technical data is not available technical justification and references are included in the calculation (e.g. drift data) for clarity. The references and assumptions have been revised accordingly.
- 2. This issue identified conflicting converter and bistable errors between Attachments 3 & 4, Foxboro Data Sheets and Reference 6, Specification No. 2472.510-662, Rev. O. Also per Specification Data Sheet,2472.710-392, Reference 6, page 3-9A there is a voltage to voltage converter in the loop and the calculation does not acomnt for the converter, The converter and bistak ulibration data referenced in the rev; sed calculation is individually identified with corresponding references and attachments to support the accuracy of the uncertainty calculation. The references and attachments have Pnnled 3/12/96 323 46 PM Page 2 or 3
Northe:st USlities ICAVP DR No. DR-MP3-0302 Millstone unit 3 Discrepancy Report been revised accordingly. The original calculation referenced the vendor specification data however, the calculation used accuracy's from the actual component qualification reports which were valid for qualified equipment. The specification Data Sheet, 2472.710-392, Reference 6, page 3-9A for this loop list a voltage to voltage converter which is used for the interface of the RSS flow signal to the plant process computer. That card is not used in the development of the bistable trip and therefore it is not required to be included in the setpoint uncertainty calculation.
NSP-101-RSS, Rev.1 was issued to S & L via RFI No.:C41, Dated: 11/21/97
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0302, has identified a condition previously discovered by NU which requires correction. The discrepant data issues identified in Calculation NSP-101-RSS, Rev.0, have been resolved in revised Calculation NSP-101-RSS, Rev.1 Dated 10/17/97. ACR No.
6627. Dated 1/12/96, identified Calculation NSP-101-RSS, Rev.
O, *3RSSYT38A,B-Setpoint for Miniflow Recire. Line Operation of 3RSS*MOV38A,8 (3RSSTS3.8A1, A2, B1, B2)" having errors due to failure to account for the non-linear characteristic of flow measurement and incorrect assumptions of instrument acc ccy. Corrective Actions for ACR No. 6627 resulted in issuing a Setpoint Change Request including a revised i
uncertainty for NSP-101 RSS.
Previously identi#ed by NU7 O Yes (9) No Non W ; ' Condition?O Yes (G) No numisonPeadiao70 va @ No RumtionUnru*ed?O va @ No novi Initiator: Hindle. R.
VT Lead: Nort. Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Dete:
3/11/98 st. comments: Per disposition, NU write-up in ACR No. 6627 identified calculation NSP-101-RSS having error due to failure to account for non-linear characteristic of flow measurement and incorrect assumptions of instrument accuracy. These issues are not the same issues identified in the DR. During the calculations revision process the discrepancies identified by this DR have been incorporated in the body of the calculation. However, since the revision date of the calculation is 10/20/97, revision of the calculation is considered done after the cutoff date of May 1997.
Printed 3/12,96 3 23A8 PM Page 3 of 3
_ _. _ ~.
Northe:st Utilities ICAVP DR N2. DR-MP3-0307 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipline. Mechanical Design Discrepancy Type: Lloonsing Document Ow systemProcese: sWP g
NRC significance level: NA Date faxed to NU:
Date Published: 11/9/97 D6screpancy: Discrepancy Between P&lD and GL 89-13 Commitment re SWS Continuous Chlorination
==
Description:==
In dispositioning requirment SWP-0303 it was noted that on Page 2 of Attachment 4 of their Letter A08201 to the NRC dated 1/25/90, providing Millstone 3 responses to GL 89-13, NU states that "The Millstone Unit No. 3 service water system is continuously chlorinated." As shown on P&lDs EM-133A and C, SWS chlorination is provided when both of the following conditions are met:
- 1. SWS Train A [which has the only connection to supply dilution water to the chemical feed chlorination system] is operating, and
- 2. the dilution water line from SWS Train A is not isolated [which occurs when a CDA signal is received, instrument air supply to either of the isolation valves [3WTC*AOV25A or B] is lost, or electrical power to any of the three instrument air solenoid valves to 3WTC*AOV25A or B is lost.] In the case of LOP, the three lA solenoid valves are all backed by the DGs, however, valve A2, in the lA line to 3SWP*AOV25A, is powered by a non-safety-related charger and battery.
Based on the above, there are a number of scenarios, none of which is expected to occur on a frequent basis, when continuous chlorination of the SWS would not b6 provided.
It was also noted when dispositioning requirement SWP-0417 that SER Section 9.2.1 required each SW header to have connections to and from the chemical feed chlorination system for the addition of chlorine to the SWS to inhibit biological fouling. As noted above and as chown on P&lD EM-133A, chlorination dilution water is supplied only from Train A of the SWS, which is supplied by SW Pumps A and C. No connection is provided from Train B of the SWS, supplied bv SW Pumps B and D. Also, the chlorine injection has been traved from the SWS headers as originally desl ned to the suction bell of each 0
of the four SW Pumps which provides more complete and reliable treatment when the chlorination system is operating.
Review venid invalid Needed Date initiator: Taminkel, J. L.
O O
O e<24/97 VT Leed: Nort, Anthony A B
O O
10/7/S7 VT Mgr: Schopfw, Don K B
D 0
50/25'S7 lac chmn: Singh, Anand K O
O O
5'4'S7 Det.:
INVALID:
Date: 3/11/98 RESOLUTION: Disposition:
Printed 3/12/96 323.11 PM page 1 of 3
- ~ - ~ ~ ~ ~ ~ ' ~~
hhst Utilitic ICAVP DR No. DR NP3 4307 l
Ministone Unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report, DR MP3-0307, does not represent a discrepent condition. The hypochlorite (chlorination) system is non-safety related and is required to operate during normal plant operation to minimize biofouling of the service water system. It is not required to operate following an accident and isolates on a Containment Depressurization Actuation.
The requirement as stated in GL 89-13 is:
- implement and maintain an ongoing program of surveillance I
and control techniques to significantly reduce the incidence of l
flow blockage problems as a result of biofouling."
in addition, Enclosure 1 of the Generic Letter states:
"B. The service water system should be continuously (for i
example, during spawning) chlorinated (or equally effectively treated with another biocide) whenever the potential for a macroscopic biological fouling species exists..."
NU's response uses the word " continuously" in a similar context.
Also, the statement " continuous chlorination" is not meant to l
imply that the system is not susceptible to the effects of normal equipment failures. The intent of the hypochlorite system is to prevent biofouling in the service water piping. The impact of short duration and Infrequent failures of the hypochlorite system I
would be minimal.
l The duration that hypochlortte would be isolated under two of the scenarios described in the DR is limited. Actions would be taken to stabilize the plant in each event and then restore systems sequenced by their level of necessity.
l Loss of Air: If the loss is such that instrument air pressur a decreasing rapidly or lost altogether, the unit would be tripped in accordance with AOP 3562, Loss of instrument Air (LOA).
Restoration of instrument Air can be completed concurrent with E-0. If the LOA is slow, the operators would take adion in accordance with AOP 3562, find the leak, isolate it and restore i
IA in step 16.
l Loss of DC: A failure en battery bus 1,2,5 or 6 results in a l
reactor trip. All three solencids are associated with one of these busses: 3WTC*SOV25A1 supplied by battery 1: 3WTC*SOV258 supplied by battery 2; 3WTC-SOV25A2 supplied by battery 6.
Restoration of the bus may be performed in accordance with AOP 3563 Attachment A, B or F and 33450,125 VDC, and concunently with E-0, 1
\\
If the event results in a Containment Depressurizadon Actuation, i
other problems in the plant would be more pressing Qan the isolated hypochlorite system.
The service water header connections to and from '.:hemical feed Prweed 3n2/98 3.2314 PM Pa0s 2 or 3
Northe:st Utilities ICAVP DR No. DR-MP3-0307 Millstone Unit 3 Discrepancy Report configuration were modified under PDCR 3 91-186.
Subsequently, the FSAR was changed per FSARCR 92-MP3-37.
Letter B14049 dated 2/27/92 provided a description of this design change to the NRC.
Significance Level criteria do not apply here as this is not a discrepant condition.
j
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0307, does not represent a discrepant condition. The i
hypochlorite system is non-safety related and is required to operate during normal plant operation to minimize biofouling of the service water system. The hypochlorite system is not requiredand autornatically isolates (CDA) during accident conditions. The NRC was informed of the changed system i
configuration in the NU Annual report contained in letter B14049.
Significance Level criteria do not apply here as this is not a discrepant condition.
Previously udentiaed by NU? O Yes (#) No Non Discrepent Condition?(#) Yes U No ResolutionPending?O vos @ No e-aionunresoeved70 vos @ No Review
=;""
Not AWh Needed Dete TW4 L VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn* Singh, Anand K Dete:
3/11/98 sL Conwnents: S&L agrees, based on NUs disposition provided above, that the hypochlorite (chlorination) system is designed and controlled consistent with the intent of GL 89-13.
Prtnied 3/1298 3:23.16 PM Pege 3 of 3
.~ - __..-.- - -__
i Northeast Utilities ICAVP DR N3. DR-MP3 4362 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design i
Discipiirw: Piping Design g
Discrepancy Type: ceiculation Om System / Process: SWP NRC Significence level: NA Date faxed to NU:
Date Putdished. 10/18/97 D6ecrepancy: Bellow Loads have been not qualified and documented.
i 1
Ducription: It was noted during the review of Calc.12179-NP(B)-X1907, l
REV.4, CCN #1 and Calc.12179-NP(B)-X1908, REV. 3, CCN
- 1 for SWP and Calc.12179-NP(F)-X7923 REV.1, CCN # 5 for RSS that these calculations contain an unverified assumption.
The expansion joints have not been qualified for the new 4
displacements and loadings.
l Review I
Valid invalid Needed Date initletor: Singh, R.
G O
O of o'S7 VT Lead: Nwl. Anthony A B
O O
'of 3/97 VT Mgt: Schopfer Don K G
O O
10/14'87 lRC Chmn: Singh, Anand K B
D 0
10/14/97 l
Date:
INVALID:
Date: 3/10/98 i
l RESOLUTION Disposition: Response ID: M3-lRF-00848 NU has concluded that DR-MP3-0382 does not represent a discrepant condition. Calculations 12179-NP(B)-X1907, REV.4, CCN #1,12179-NP(B) X1908, REV. 3, CCN #1, and 12179 NP(F)-X7923 REV.1, CCN # 5 for RSS are in-process calculations. The expansion joint loads and displacements were processed through the equipment vendor and were expected to require an extended schedule. Final approval for the expansion joint loads is currently under review and is a start-up item. This issue is identical to DR-MP3-0098 and was responded to in M3-IRF-00580.
Significance level criteria does not apply as this is not a discrepant contition.
==
Conclusion:==
NU has concluded that DR-MP3-0382 does not represent a discrepant condition. Calculations 12179-NP(B)-X1907, REV.4, CCN #1,12179-NP(B)-X1908, REV. 3, CCN #1, and 12179-NP(F)-X7923 REV.1, CCN # 5 for RSS are in-process calculations. The expansion joint loads and displacements were pmcessed throu9h the equipment vendor and were expected to require an extended schedule. Final approval for the expansion joint loads is curTently under review and is a start-up item. This Issue is identical to DR-MP3-0098 and was responded to in M3-l l
IRF-00580.
l Significance level criteria does not apply as this is not a discrepant contition.
Previously idenused by NU7 Q Yes (S) No Non C-- M Condelion?(G_) Yes Q No Printed 3/12/96 3.24.14 PM Page 1 or 2 E
Northe:st Utilities ICAVP DR No. DR-MP3-0362 Millstone Unit 3 Discrepancy Report ResolutionPending?O v
(*) No R iuisonune sv d?O v (e) u.
Review initiator: Jain, R. C.
O VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K RC Chmn: Singh, Anand K Det.:
3/10/98 SL Comments:
l Printed 3/12/96 3:24.18 PM Page 2 of 2
Northerct Utilities ICAVP DR No. DR-MP3 0366 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipline:I a C Design O vee Discrepency Type: Draw 6ng systemerecese: HVX NRC SWnce level:3 Date faxed to NU:
Date Published: 11/2/97 D6ecrepancy: Drawing Discrepancy-LSK-22-7C Descrission: Logic Diagram 22-7C, Rev g shows that dampers 3HVP* MOD 20A, MOD 23A, MOD 26A and MOD 20C are controlled automatically if either of the vent supply fans, 3HVP*FN1 A or FN1C, is running. Fans are 50% capacity fans per FSAR Section g.4.6.2. Dampers are controlled automatically if both vent supply fans are running per FSAR Section 9 A.6.5.
Logic Diagram shows that dampers are driven to a position opposite their failure positions if both vent supply fans are not running. Dampers are driven to a position opposite their failure positions if either vent supply fan is not running per P&lD EM-150C-15. This would prevent the temperature controller from modulating the inlet, outlet and recirculating air dampers that would be required when only one supply fan is operating.
The Condition " Dampers Driven to Position Opposite Failure Position" has no Source inputs.
Review Velid invalid Needed Date initletor: Pineise, H.
O O
O 10/18/87 VT Lead: Nort. Anthony A B
O O
tot 27/97 VT Mgr: Schopfw, Don K O
O O
tor 2ews7 IRC Chmn: Singh. Anand K O
O O
o/30/S7 Date:
INVAUD:
Date:
3/2/98 RESOLUTION. Disposition:
j NU has concluded that Discrepancy Report, DR-MP3-0365, has identified a condition not previously discovered by NU that requires correction. LSK 22-7C and ESKs 6ACL and ACM depict the correct logic for the fan and damper interlocks. When either (or both) ventilation supply fan is running the temperature controller will modulate these dampers provided the diesel i
enclosure room temperature is above the nominal setpoint.
j During a normal shutdown when both fans have been secured the outlet and inlet dampers (3HVP* MOD 20A, C, and 23A) close and recirculation damper (3HVP* MOD 26A) opens.
However, on a loss of power the outlet and inlei dampers open and the recirculation damper closes assuming their fall safe position.
The P&lD incorrectly states that when either supply fan 3HVP*FN1 A(B) or 3HVP*FN1C(D) is not running the dampers will assume their opposite failure position. The P&lD should state Pnnled 3/12/96 3:24.45 PM Page 1 of 2
L Northe:st Utilities ICAVP DR No. DR-MP3-0365 Ministorm Unit 3 Discrepancy Report that when both supply fans 3HVP*FN1 A(B) and 3HVP*FN1C(D) are not running the dampers will assume their opposite failure position.
FSAR section 9.4.6.5 incorrectly states that when both supply l
fans have started, the temperature controller modulates the inlet, recirculation and outlet dampers. This is inconsistent with the control logic as depicted on LSK 22-7C and ESKs 6ACL and ACM. The FSAR section 9.4.6.5 should state that when either l
supply fan starts the temperature controller modulates the inlet, l
recirculation and outlet dampers to maintain temperat' ce below 120 'F in the emergency generator enclosure.
CR M3-97-3965 was initiated to document the P&lD and FSAR discrepancies.
The approved corrective action plan for M3-97-3965 will correct the P&lD and FSAR discrepancies prior to startup.
Attachments:
MS-97-3965 approved corrective action plan
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0365, has -
identified a condition not previously discovered by NU that requires correction. CR M3-97-3965 has been written with the corrective action plan approved to revise FSAR section 9.4.6.5 and the associated P&lD to reflect the correct emergency generator enclosure ventilation logic as depicted on the applicable LSK and ESK drawings.
The approved corrective action plan for M3-97-3965 will correct the P&lD and FSAR discrepancies prior to startup.
- 7...
-, hienessed by Nut U Yee @ No NonDiscrepentCondnion?O Yes @ No Pam Pending?O Y=
@ N.
- unr.e.ev.d? O Y a @ N.
noview Aeoeptense not a~ r -w-Nooded Does a
,,,,,,,,, %g, I
VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K Wic counn: singh, Anand K poes:
?/25/98 sL conenenes: The action plan appears to be correct with the following exception with regard to scheduled completion. The Corrective Action Plan (CAP) Form RP41 Rev. 5. Pa0e 4 of 7, sheet 1 identifies AITTS Tracking No. 97027528-02 with a Sched. Ref. 06U02 Mode: 4.
i l
ICAVP Response Form Response ID: MS-lRF-00921 is dated l
2/19/98. According to Portal G, Action Tracking viewed on 2/25/98, Panel TIMX291 for Task 02 of A/R 97027528 states l
"1/21/98 PROCESSED CHANGE FORM: CHANGE MODE l
FROM 4 TO 2." This change should have been noted in the attachments to the IRF.
Printed 3/12/98 3:24.50 PM Page 2 or 2
Northeast Utilities ICAVP DR No. DR MP3-0382 Ministone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: Syelem Design gg Diecipane: Pipin0 Design Ow Discrepency Type: m G No SystemProcess: SWP NRC Significance level: 4 Date faxed to NU:
Date Publ>hed: 11MV97 D6screpency. Error in equation and incomplete loads considered for stability evaluation of posulated pipe cracks
==
Description:==
In the process of reviewing the following documents, (i) Calculation No. 89-032-1131GP, Rev. 00, Brittle Fracture Evaluation of Eroded Service Water Piping and the additional reference (ii) EPRI Report No. NP-6045, ' Evaluation of Flaws in Ferritic Piping". Dated October 1988 we note the following:
Background and Discussion:
1)The applied loading for the pressure stress, weight stress, etc., as identified on page 7 of the calculation and used in the calculation, were not referenced properfy. The basis for the values used appear to be assumed bounding values.
- 2) Based on a review of the EPRI Report (ii) the formula for limit stress of the axial through wall crack on page 11 of 45 is incorrect. The numerator of the formula should read (1-x) instead of (1+x). The limit stress formula for a "part - through wall" axial crack can not be applied for a through wall axial crack since the limit stress approaches 0 as all approaches 1. The limit stress for through well axial stress per the EPRI Report is approximately 1/3 of the calculated value on page 11. This will change the failure mode of the axial flaw from brittle to ductile tearing failure mode.
- 3) Based on a review of the input parameters for the PCFAD analysis (pages 13-43),used to evaluate circumferential cracks, it is not clear that a pressure load was included in the PCFAD analyses.
4)As identified in the PCFAD input listing on page 13, the sources of Ramberg-Osgood (alpha) material constant (taken from the EPRI report) and the value of *n" (taken as the PCFAD default value) are not taken from the same document. Since these constants are related to the referenced yield strain and stress, they should be from the same source. Other material data such as JR curve for FAD curves was not documented.
3 i
Discrepancy:
Pnnled 3/12/98 327.15 PM Page 1 of 6
l Northeast Utilities ICAVP DR No. DR-MP3 0382 3
Millstone Unit 3 Discrepancy Report Based on a review of reference (ii), we believe the failure mode of a postulated axial crack will be < Mile tearing vs. brittle failure. Therefore, certain axial crack / pipe size combinations may result in stable conditions.
Based on a review of the PCFAD input / output listing for the evaluation of circumferential cracks, the values of " alpha" and "n" used are not taken from a common reference source and the pressure load is neglected. Therefore, the predicted stable circumferential crack sizes and safety factors may be unconservative.
Review vand invalid Needed Date initiator: Olson, P.R.
O O
O 10/ 4/S7 VTt.eed: Nei, Anthony A O
O O
10/14'87 VT Mor: schopfer, Don K O
O O
$or2os7 IRc Chmn: singh, Anand K O
O O
10/31/87 Date:
INVAUD:
oste:
3/4/98 REsOLUTmN: Response ID: M3-IRF-01326 Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0382, does not represent a discrepant condition.
The following is a discussion of each of the issues identified and the response to each issue:
/
- 1) The applied loading for the pressure stress, weight stress, etc., as identified on page 7 of the calculation and used in the calculation, were not referenced property. The basis for the values used appear to be assumed bounding values.
Response: The purpose of the calculation was to perform a failure mode sensitivity evaluation, to determine if brittle fracture could be excluded as a failure mode when evaluating erosion or corrosion defects typical of the Service Water (SW) piping. The calculation was intended as a generic evaluation to cover the SW piping at Connecticut Yankee and at the three Millstone Units. Since the evaluation was not intended to demonstrate regulatory compliance or structuralintegrity of any specific system or component, no specific / referenced loads were applicable to this evaluation. The loads used in the calculation were chosen based on experience as documented in the calculation and were intended to be reasonably conservative but not necessarily bounding for every possible loading condition.
These loads were obtained by reviewing several pipe stress analysis outputs from various service water systems.
- 2) Based on a review of the EPRI Report (NP-6045) the formula for limit stress of the axial through wall crack on page 11 of 45 is incorrect. The numerator of the formula should read (1 x) instead l
Printed 3/12/9e 3.27:19 PM Page 2 of 6
Northe:st Utilities ICAVP DR No. DR-MP3 0382 Millstone Unit 3 Discrepancy Report of (1+x). The limit stress formula for a "part-through wall" axial crack can not be applied for a through wall axial crack since the limit stress approaches 0 as alt approaches 1. The limit stress for through wall axial stress per the EPRI Report is approximately 1/3 of the calculated value on page 11. This will change the failure mode of the axial flaw from brittle to ductile tearing failure mode.
Response: The sign in the numerator was changed from minus to plus because the numerator would approach zero as the flaw depth approaches 100% through wall, as stated in the DR. This change was required in order to obtain a bounding stress intensity (KI) for any depth flaw. Without this change, the evaluation would be limited to either a through wall flaw or to a part through wall flaw with a depth of
< 80% through wall since these were the only two cases for which solutions were readily available in the literature. However, it was felt at the time that neither of these cases were adequately bounding for flaws deeper than 80% through wall and still be structurally acceptable by local wall thinning analyses in accordance with ASME Code Case N-48C which is endorsed by Generic Letter 90-05. Although NU agrees that the above conservative assumptions could change the failure mode of the axial flaw from brittle fracture to ductile tearing, the conclusion reached in the calculation that brittle fracture could not be discounted for deep, part through wall flaws is conservative and appropriate.
3.0 Based on a review of the input parameters for the PCFAD j
analysis (pages 13-43), used to evaluate circumferential cracks, i
it is not clear that a pressure load was included in the PCFAD analyses.
i Response: The purpose of the PCFAD evaluation performed for the circumferential flaws was to determine at what point one could expect unstable crack propagation under ductile crack extension conditions. Even though the version of PCFAD i
available at the time was considered state of the art, it could not handle flaws under combined membrane (i.e. pressure) and bending loads. This feature was not available until later versions j
of the PCFAD Code. Even though this limitation was recognized at the time, the approach was still deemed appropriate for the following reasons:
a) The axial pressure stress in the affected SW piping is low (i.e.
< 2.0 ksi) compared to the typical bending stresses, and b) The evaluation was intended only as a sensitivity study and the type of applied stress (i.e. bending vs. membrane) was considered not to have any measumble impact on the result.
Clearly the conclusions reached in the calculation would only apply to a specific location if that location was demonstrated to be bounded by the material properties, flaw dimensions, pipe dimensions and applied stresses used in the calculation.
4.0 As identified in the PCFAD input listina on pace 13. the Printed 3/12/96 3 2720 PM Page 3 or 6
Northe:st Utilities ICAVP DR N3. DR-MP3-0382 Millstone Unit 3 Discrepancy Report sources of Ramberg-Osgood (alpha) material constant (taken from the EPRI report) and the value of "n" (taken as the PCFAD default value) are not taken from the same document. Since these constants are related to the referenced yleid strain and stress, they should be from the same source. Other material data such as JR curve for FAD curves was not documented.
Response: The values used in the calculation are alpha = 2.51 (from the EPRI Report) and n = 4.2862 (PCFAD default value).
The value of n provided by the EPRI report was 4.2. NU belicves that the value of 4.2862 used for "n"in the above calculation is appropriate. The reason for this conclusion is that the values of alpha and "n" need not be obtained from the same reference document as long as the chcsen values appropriately described the strain hardening characteristics of the materialin question.
Figure 5-3 of the EPRI Report demonstrates that the actual stress-strain relationship varies significantly from heat to heat of material. The use of the above strain hardening coefficients results in a stress-strain relationship which is well within the heat to heat variations. In additior,, the calculation was intended only as a failure mode sensitivity evaluation and had no impact on the actual structural integrity or ASME Code compliance of any system, structure or component as discused above. The JR curve, material yield strength, ultimate strength, Young's modulus and Poison ratio values used in the calculation were the default values in PCFAD which are typical values for cart >on steel materials. This is considered adequate for this type of fsilure mode sensitivity analysis.
Discrepancy:
1.0 Based on a review of reference (ii), we believe the failure mode of a postulated axial crack will be ductile tearing vs. txittle fracture. Therefore, certain axial crack / pipe size combinations may result in stable conditions.
Response: NU agrees that, as a result of the conservative assumptions made in the calculation, certain axial crack / pipe size combinations which were predicted to behave in an unstable manner may actually behave in a stable manner. However, the purpose of the calculation was to determine whether unstable crack propagation could be discounted as a potential failure mode. The results of the calculation indicated that since brittle fracture was possible, all failure modes needed to be considered.
The conclusion that some crack geometries could fall as a result of brittle fradure when the actual failure mode may be ductile tearing is a conservative conclusion since this assumes that all of the system energy is available to extend the crack and none of it is converted into plastic strain. Furthermore, the only available method for flaw evaluation in ferritic piping at the time the calculation was performed was Appendix A of the ASME,Section XI Code which is based on brittle fracture. The method described in the calculation (i.e. screening for the applicable failure mode) was introduced into Appendix H of the 198g Addenda of the ASME Section XI Code and was not approved by 10CFR50.55a at the time the calculation was performed.
PrWed 3/1296 3 27 21 PM Page 4 or 6
Northert Utilities ICAVP DR No. DR-MP3-0382 Millstone unit 3 Discrepancy Report 2.0 Based on a review of the PCFAD input / output listing for the evaluation of circumferential cracks, the values of " alpha
- and "n" used are not taken from a common reference source and the pressure load is neglected. Therefore, the predicted stable circumferential crack sizes and safety factors may be unconservative.
Response
See response to items 3.0 and 4.0 above.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0382, does not represent a discrepant condition. The purpose of the calculation was to perfonn a sensitivity study of the potential failure modes applicable to SW, cartson steel piping to determine if brittle fracture could be excluded as a potential failure mode.
The calculation conservatively concluded that brittle fracture was possible, especially for axial flaws, in addition, document searches indicated that this calculation was not used in any design or licensing application. Significance Level criteria do not apply as this is not a discrepant condition.
Previou.ly identiflod by Nu? O ve.
(*) No Non Discrepent Condition?O ve.
(9) No Resolution Pending70 ve.
- No no.osution unr sv.d70 ve.
@ No n.vi
^
Not M ^
Needed Date I m % P.R.
VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date:
3/4/98 sL comments: S&L's review and observations pertaining to the subject calculation were based on the technical merit of the calculation to address it's stated purpose. We viewed the purpose of the calculation to be two-fold;
- 1. Based on a technical evaluation, determine if the carbon steel portions of the service water piping is susceptible to brittle versus ductile failure due to the effects of emslon/ corrosion whereby
- 2. The conclusion will be used as a bounding / screening analysis of these systems The calculation concludes that for certain combinations of pipe sizes and postulated flaws, both brittle or ductilo fracture may be of concem.
Technical concems were raised in the DR with the view that the stated purpose of the calculation was to provide a screening basis for cases which might be encountered. Additionally, the concems were raised because the calculation was based upon a range of pipe sizes, flaw sizes, configurations and assumptions regarding load magnitudes. In addition, material properties questions were Pnnled 3/12/96 32723 PM Page 5 or 6
l Nortbe:st Utilities ICAVP DR No. DR-MP3 0382 milistone unit 3 Discrepancy Report noted as well as an apparent error in the application of a formula.
NU has responded in the IRF that, based on a document search, this calculation was not used in any design or licensing application. NU also acknowled0es that later editions of the Code, Code Case guidance and enhancements to the PCFAD code now exist, which were not available at the time the calculation was prepared. The apparent formula error in the calculation is j
identified by NU as a conscious attempt to adjust the referenced formula to address the postulated condition. This was done in the j
calculation without providing an explaination of the technical i
basis.
Given the above observations, the fact that the calculation is a very generic treatment of the subject, and that flaw assessments, beyond Code defined allowable limits, warrant detailed assessments on a case by case basis, the overall value of the calculation is diminished.
S&L would therefore recommend that the calculation could be removed from the NU cak,ulation data case, or superseded by a criteria document that defines approaches consistent with the current case by case methods available.
In the event NU does not elect to remove the calculation from the data base, it is suggested that the calculation be revised. This is because the comments generated during the review of the calculation could not be dispositioned without the benefit of the technical clarifications provided in the IRF. A calculation revision should include the technical clarifications provided by the IRF response in order to preclude any future questions related to the formulation, limits and application of the calculation.
We believe the DR written aGainst this calculation is now Significance Level 4 based cn NU's conclusion that the calculation was not used in any design or licensing applicatien.
i Printed 3/1298 32724 PM Page 6 or 6
- ~ _. _ _.
s
1 Northe:st Utilitie3 ICAVP DR N3. DR-MP3-0384 Millstone Unit 3 Discrepancy Report l
ReviewGroup: AccidentMaigation DR RESOLUTION ACCEPTED
{
Review Element. Operating Procedure O veo l
Discrepancy Type Uoensing Document go systemiProcese: N/A NRC Significance level:3 Date faxed to NU:
Date Putdehod.11/20S7 I
D6screpancy: Verification of time critical operator actions following a CVCS line break
==
Description:==
FSAR Section 15.6.2 evaluates the consequences of the worst case line break outside containment, which is a rupture of the letdown line. The FSAR contains the statement:
j j
" Area radiation and leakage detection instrumentation provide the means for detection of a letdown line rupture. Frequent operation of the CHS reactor makeup control system and other CHS instrumentation also aids the operator in diagnosing a letdown line rupture."
In addition, in the Safety Evaluation Report (SER) for Millstone 3, the NRC states that the operator can respond to a change in the level in the Volume Control Tank (VCT) to identify and isolate the break.
From the above one can conclude that for a letdown line rupture outside containment the operator can rely on:
- 1. Radiation detect!on instrumentation
- 2. Leak detection instrumentation
- 3. VCT makeup control and instrumentation The ICAVP reviewed the following documents in ordcr to verify that there are area radiation monitors and level and leakage detection capabilities sufficient to detect and mitigate the design basis CVCS leak of 152 Opm within 30 minutes:
A. EOP 35 ECA 1.2 LOCA Outside Containment.
B. Unit 3 Millstone FSAR Section 15.6.2.
C. AOP 3555 Rev.7 Reactor Coolant Leak.
D. Operating Procedure 3353.MB3A Rev.1 VCT Level Hl/LO.
E. NUREG 1031, Safety Evaluation Report, Section 15.6.2 F. EOP 35 E-0 Reactor Trip or Safety injection G. EOP 35 E-1 Loss of Reactor or Secondary Coolant The FSAR on page 15.6-3 states that the operator has diverse means of detecting the letdown line rupture through:
- a. Area radiation monitors.
h I ank timtardinn intimmontatinn Printed 3/12/96 3:27:50 PM Pope 1 of 4
_. _ _ l 9
Northert Utilitie3 ICAVP DR N2. DR-MP3 0384 Millstone unit 3 Discrepancy Report
- c. Frequent operation of the CHS reactor makeup control i
system and the CHS instrumentation.
if the break is large enough, the reactor will trip and the and the i
operator will enter the Emergency Operating Procedures (EOP's) for reactor trip and LOCA (Documents F and G). In both of these procedures, a high alarm on an area radiation monitor outside containment will cause the operator to enter the EOP for the LOCA outside containment (Document A). Note that the only entry point into this EOP for a LOCA outside containment is an i
abnormal radiation reading. In the event of abnormal radiation in the auxiliary building, explicit directions are given to close the outer and inner containment isolation valves, 3CHS*CV8152 and 3CHS*CV8160, respectively.
To determine if there is another means for the operator to isolate the letdown line rupture using other instrumentation, additional procedures were reviewed.
The stated purpose of the Abnormal Operating Procedure (AOP) for reactor coolant leakage (Document C) is to provide the actions necessary for evaluating the magnitude of a small (within the capacity of the Charging System) Reactor Coolant System leak in Modes 1,2,3 or 4. Some of the entry conditions that may indicate a CVCS leak outside contLinment are:
- a. Pressurizerlevel decreasing slowly.
- b. Unexpected increase in charging flow.
- c. Makeup volume increasing or abnormally high.
- d. RCS inventory computer program indiceting an abnormal leak rate.
Following the directions of the AOP leads an operator to determine the leak rate using the Volume Control Tank (VCT) level trend. The procedure then directs the operator to proceed to try to identify the location of the leak. At no time in this AOP is the CVCS letdown 1;ne rupture stated as a possible cause of the leakage or are directions given to verify that 3CHS*CV8152 and/or 3CHS*CV8160, the containment outer and inner letdown isolation valves, are closed.
As noted above, the NRC stated in the SER (Document E) that the VCT level indicator would be used to identify and isolate the I
letdown line rupture. The operating procedure for response to volume control tank level alarms (Document D) does not identify:
i) A possible cause of low VCT level is a letdown line rupture as stated in the SER
- 11) The valve numbers for the containment letdown isolation lii) Operator action to isolate letdown within 30 minutes of a design basis CVCS leak of 152 gpm l
CONCLUSION 1
In summary, abnormal radiation readings outside containment coincident with reactor trip or loss of coolant will invoke the PrWed 3/12516 327.52 PM Page 2 ri 4 l
N::rtherct Utilities ICAVP DR N2. DR-MP3-0384 Millstone Unit 3 Discrepancy Report EOP's which will lead to letdown isolation. There is no indication In the procedures reviewed that RCS leakage without a radiation monitor reading, or a change in VCT level, will lead to the isolation of the letdown line. Furthermore, the operator is not provided guidance to isolate letdown of a design basis CVCS leakage of 152 gpm within 30 minutes.
Based on this review, there is a discrepancy between the existing operating procedures and the commitments in the FSAR and SER.
Review Vaud invalid Needed Date initiater: schwartz, Bany 8
O O
Sor31/97 VT Lead: Rahoje. Raj D B
O O
10/31/97 VT Mgr: schopfer, Don K B
O O
11dvo7 IRC Chmn: singh, Anand K B
D D
11"7/97 j
Date:
INVALID:
{
Date: 2/27/98 RESOLUTION: Disposition:
)
NU has concluded that Discrepancy Report, DR-MP3-0384, has identified a condition previously discovered by NU which has been corrected. This discrepancy was previously identified in March of 1997 by both the 10CFR50.54f review of FSAR chapter 15.6.2 and an NRC inquiry. Rufer to the attached electronic mail, transmitted in accordance with OP 3265 EOP Changes and Revisions, from Dcog Holderbaum to the MP3 EOP coordinator i
(MP3EOPS) regarding the isolation of letdown during letdown line break. CR M3-97-0866 documented a related discrepancy with the FSAR and prompted a rey!ew of the AOPs / EOPs to ensure that assumptions in the FSAR were being implemented in the AOPs / EOPs. Revision 8 of AOP 3555 implemented the change to close 3CHS*CV8152 or 3CHS*CV8160. Also, refer to the attached Safety Evaluation conducted for the AOP revision.
During normal operations, the RCS total makeup flow controller, 3CHS-FK111, is set in automatic. When CHS*l.T112 indicates 41% VCT level, makeup to the VCT is suo itically initiated.
The total makeup flow controller is hard-wired to 80 gpm when the controller is in automatic. This makeup flow is insufficient to maintain the VCT level stable during a 152 gpm leak on the letdown line. Therefore, the postulated accident discussed in the DR (no radiation monitor alarm and no VCT level deviation) is not credible.
In addition, the control room would be alerted to the decreasing pressurtzer level at -5% deviation from program or decreasing pressurizer pressure at 25 psi below setpoint (2250 psia). These alarms can be assumed because a single charging pump through 3CHS*FCV121 could not makeup for the 152 gpm leak.
Therefore, AOP 3555 would be entered and the letdown line isolated in accordance with step it.
Normal progression through the event and the AOP will ensure that the letdown line is isolated within 30 minutes. Therefore, it is not necessary to caution about the 30 minute time requirement Printed 3/12/98 3:27;55 PM Page 3 of 4
Northe:st Utilities ICAVP DR No. DR-MP34384 Millstone Unk 3 Discrepancy Report in the AOP. In general, AOPs and EOPs do not contain time restraints. Rather, the sequence of steps in the procedures is written to mitigate the event as safely and quickly as possible.
NU concludes that this is a significance level 3 discrepancy.
l Prev 60u9y identitled by MJ7 (@ Yee Q No Non D6ecrepent Oondition?Q Yes
(@ No ResolutkmPending?O vee @ No Re a%unrosoeved70 ves
@ No Rev6ew A, "- Not A -- **
Needed Date VT Lead: Reheja. Raj D VT Mgr: Schopfer, Don K g
IRC Chmn: S@, Anand K O
O O
Date:
2/27/98 st. Comments:
l i
Printed 3/12/96 3.27.57 PM Pape 4 of 4
Northeast Utilities ICAVP DR No. DR-MP3-0435 milistone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED PotentialOperability leaue D6scipline: Mahonical Desig" Ow Discrepancy Type' he h
@ No SystemProcess: SWP NRC Signiacance level: 4 Date FMed k NU-Date Published 1/1oS8 D66cryancy: InCorred and Missing Data from SWP Design Basis Summary Document Descripthn:
In dispositioning requirements SWP-0111 through 0116, it was noted that the SWP DBSD lists the heat load for the MCC and RCA A/C Units as 587,000 btu /hr, but does not list the corresponding SW flow rate, which should be 55 Opm.
The SWP DBSD lists the SW flow rate for the Containment Recirc Spray HXs as 5,900 gpm, but lists the heat load incorrectly as 318,000 blu/hr, when it should be 318,000,000 blu/hr.
Both of the above are considered to be editorialin nature, as the calculation [90-069-1065-M3] referenced in the DBSD has the corred values contained therein.
Review Valid invalid Needed Date initiator: Tonwinkel, J. L 8
O O
12/22/97 VT Lead: Nort, Anthony A G
O O
12/20s7 VT Mgr: schopfer, Don K B
O O
12/2357 WtC Chmn: singh, Anand K 8
O O
12/31/97 Dme:
INVALID:
i Dde: 3/11/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0435, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per US PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0513 has been written to develop and track resolution of this item per RP4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0435, has identified a condition not previously discovered by NU which requires corredion. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0513 has been written to develop and track resolution of this item per Printed 3/12/98 3.28:28 PM Pope 1 of 2
~ --
Nrthert utmties ICAVP DR No. DR-MP3-0435 Millstone Unit 3 Discrepancy Report 4
RP-4.
Pmvlously klontiSod by NU7 (,) 5es @ No Non EMecrepent Condition?(,,) vos (9) No RoachdionPending70 vos @)No w % uar ev.d70 vos
(*) No neview Accafdh Not A- --, ^ " - Needed Date Meatw: TW, A L I
I VT Leed: Nori, Anthony A u
O
- 11m VT Mgr: Schopfer, Don K O
O
$11m IRC Chmn: Sirp, Anand K O
Date:
1 SL Comments:
l
\\
l j
Printed W12/96 3:26.31 PM PeDe 2 of 2
Northe:st Utilities ICAVP DR No. DR-MP3-0482 milistone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design Diecapline: Mechenwal Doengn O v.
Discrepency Type: Drewing g
SystemProcess: SWP NRC s4
=-s level:4 Date faxed to NU:
Date Putdlehed io/23S7 06 crepency: Safety Related Components in PDDS Not Shown on P&lD Ducription: The follovng safety related components are listed in PDDS but not fourt on P&lD EM 133A, B, C, or D:
3SWP*V684 3SWP*V687 3SWP*V927 3SWP*V928 3SWP*STR4A 3SWP*STR4B The only additional information found regarding the above was a notation in PDDS that 3SWP*V927 and 928 are ' abandoned in place." However,if they are still part of the SWP pressure boundary, they should still be shown on the P&lD as these are check valves.
In addition, it is noted that two lines are shown on EM-133D with incorrect size designation - line numbers 256 and 257 are shown as 3 inch and should be 30 inch.
Review Valid invalid Needed Date initletor: Tonwiniw(. J. L 0
0 0
10'aS7 VT Leed: Nwi, Anthony A B
D D
10/1 /87 vT Mor: schopfer, Don K 9
O O
10/15'87 IRC Chmn: singh, Anand K G
O O
so/ts/97 Date:
INVALID:
Date: 3/11/98 RESOLUTION
- Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0452, has identified a condition previously discovered by NU which requires correction.
Components 3SWP*V684,3SWP*V687,3SWP*V927, 3SWP*V928,3SWP*STR4A & 3SWP*STR4B were in the Plant Design Data System (PDDS) however, these items did not appear on the unit 3 system P&lD drawing EM-133A. These items were removed by Desti Chan0e Notices (DCNs) DM3-S-1256-93, DM3-00-1469-96, DM3-S-024-93 and DM3 S-025-93 and had been previously identified to the PDDS coordinator.
Due to the fact that items are historical in nature, they had not been deleted from PDDS until a complete verification was performed. A PDDS package number was established ( PDDS-Printed 3/12/98 3:29:o4 PM Page 1 of 2
i l
Northe:st Utilities ICAVP DR No. DR-MP3 4462 Millstone unit 3 Discrepancy Report 97 0303) with the PDDS group to delete these components from l
PDDS. The components were removed from PDDS on 10/28/97 which eliminated the discrepancy. See attached PDDS PKG.
NO. PDDS-97-0303 closure information. The Design Control Manual (DCM) close-out process has been strengthen today with a new close-out checklist to verify that items are input into PDDS.
The discrepancy of line numbers (256 & 257) is a duplicate from DR-MP3-0041, items 7 & 8 of DR-MP3-0041 were previously identified and addressed by ICAVP Response M3 IRF-00366.
==
Conclusion:==
NU has concluded that Discrepsney Report, DR-MP3-0452, has identified a condition previously discovered by NU which requires correction.
These components were removed from the plant by Design Change Notices (DCNs), the components were removed from PDDS on 10/28/97.
The discrepancy of line numbers (256 & 257) is a duplicate request from DR-MP3-0041, items 7 & 8 of DR-MP3-0041 were previously identified and addressed by ICAVP Response M3-lRF-00366.
Previously klontifled by NU7 (e) Yes Q No Non D6screpent Condition?O Yes (@ No Resolution Ponding?O vos @ No Resolution Unresolved?O vos @ No Rev6ew Not A-:-
^
Needed Date TNJ L.
VT Lead: Neri, Anthony A VT Mgr: Schopfer. Don K IRC Chmn: Singh, Anand K O
O Dete.
SL Cormients:
I i
Printed 3/12/98 3:29:06 PM Page 2 of 2
Northe:st Utilities ICAVP DR No. DR MP3-4464 Millstone Unit 3 Discrepancy Report Review aroup: System DR RESOLUTION ACCEPTED Review Element: system Doetn Diecipline: MechanicalDesen g y,,
W, q Type: calculaten Om SyenerWProceae: SWP NRC Sign 6hcance level: 4 Dets faxed to NU:
Date Putnished 10/26/97 D6ecrepency: An elbow was compared to unverified and incorrect acceptance criteria
==
Description:==
The purpose of Calculation NCR 391-406-116-EM, Rev 0, was to ensure that the predicted minimum wall thickness of 6 inch retum piping from the HVK was not less than the minimimum required.
The approach used the ' Erosion / Corrosion Restart Program",
which evaluated system inputs and ultraWe testing measurements, to determine if compor,a "A met certain acceptance criteria. Printed output from this program was included as Attachment 1 to the calculation, however, the pages were not labeled as such and the program was not included as a reference in the References Section.
The acceptance criteria involved comparing the nominal wall thickness, t(nom), with the predicted wall thickness, t(pred). For
)
straight run pipe, the program deemed a t(pred) greater than 30% of t(nom) to be acceptable. For elbows, the program deemed a t(pred) greater than 87.5% of t(nom) to be acceptable. These two acceptance criteria could not be verified because no reference was given.
The calculation states the evaluation is being made for lines 3-SWP-006-035-3 and 3-SWP-006-050-3. Included in Attachment 1 are (6) printouts from the ' Erosion / Corrosion Restart Program" output. The program printouts in Attachment 1 indicate they are for lines 3-SWP-006-035-4 and 3-SWP-006-050-4. Here, the assumption is made that a typographical error was made when inputting the lines into the program, and the program output corresponds with the lines being evaluated.
The body of the calculation addresses only (1) of these evaluations and determines all of the components to be acceptable. A review of the (6) program outputs in Attachment i revealed that the elbow being evaluated in the 3-SWP-006-050-3 line was compared to a different acceptance criteria than the elbow in line 3-SWP-006-035-3. This program output was designated as ' Calculation Number: M3-92-01237-2B' in. The predicted wall thickness for the elbow, t(pred), was compared to 30% of the nominal wall thickness, t(nom), and determined to be acceptable. However, according to the methodology previously used by the program, the t(pred) for the elbow should have been compared to 87.5% of the f(nom), if this elbow had been evaluated following the methodology used in the calculation, this component would have been deemed trs be unacceptable, contrary to the stated enneindan Printed 3ft2/96 3:29:36 PM Pepe 1 of 5 l
Northe:st Utilities ICAVP DR No. DR-MP3-0#.58 Mtlistone Unit 3 Discrepancy Report The calculation did not reference a design change notice (DCN) or any other source to indicate the elbow was going to be replaced. Therefore, it could not be verified this elbow has been replaced, if this elbow has not yet been replac6J ft is a potential operability issue that would impact system functionality.
Review Vend invand Needed Date initiator: Deonne. B. J.
G O
O 10/15/97 VT Leed: Nerl, Anthony A Q
O to/16/97 VT Mgr: schopfw, Don K 8
0 0
50/20/97 IRC Chmn: singh. Anand K O
O O
$o/22/97 Date:
INVALID:
Date: 3/10/98 RESOLUTION: Disposillon:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0458 has identified a condition not previously discovered by NU which requires corrective action. NU agrees that the Erosion / Corrosion Restart Program was not included as a reference in the References Section. However, the Erosion / Corrosion Restart Program was the stated basis for the l
calculation as noted in the " Method of Analysis
- section of the calculation.
The following background is helpful in understanding the detailed NU response to this DR.
Calculation NCR-391-406-116-EM, Rev 0, and Attachment -1 analyze the same elbows. The calculation dispositions the localized wall thinning UT measurement on elbows provided via memo CTS-91-530. The Attachment-1, on the other'iand, evaluates the detailed UT data mapping for 3 components,
namely, the upstream pipe, elbow (Same as calculation) and the downstream pipe in each line numbers 3-SWP-006-0035-003 and 3-SWP-006-0050-003. These 6 separate evaluations are identified in Attachment - 1 as M3-92-01237-1 A,1B and 1C for line number 3-SWP-006-0035-003 and as M3-92-01237 2A,2B and 2C for line number 3-SWP-006-0050-003. Attachment -1 was appended to calculation NCR-391-406-116-EM on 1/20/92 for ease of filing and tracking.
The following provides a specific response to the questions raised by this DR:
Question 1 Printed output from the
- Erosion / Corrosion Restart Program" was included as Attachment 1 to the calculation, however, a) The pages were not labeled as such.
Response
The pages should have been labeled and numbered. This was an oversight. CR M3-98-0303 has been generated to track Printed 3/12/98 3:29A0 PM Page 2 or s
~-
1 Northe:st Utilities ICAVP DR No. DR-MP3 0458 Millstone Unit 3 Discrepancy Report corrective action to label and number the pages.
b) The program was not included as a Reference in the references section.
Response
CR M3-96-0303 has been generated to track corrective action to add the reference to the Erosion / Corrosion Restart Program.
The Discrepancy Report appears to imply that the 'Joftware"
]
program was used in the calculations. However, no ' software
- program was used to perform any calculations. The type written sheets included in the calculation were developed to implement the calculation instructions from the Erosi<m/ Corrosion Restart Program Project instruction 91155A-10 using a standard off-the-shelf spread sheet program and all of the results were independently verified by hand. Thus, the Erosion / Corrosion Restart Program used in Attachment -1 was not a " software" program but rather a process.
Question 2 For straight run pipe, the program deemed a tpred greater than 30% of tnom to be acceptable. For elbows, the program deemed a tpred greater than 87.5% of tnom to be acceptable. These two acceptance criteria could not be verified because no reference was given.
Response
It is agreed that the acceptance criteria could not be verified withnut the attached Project Instruction, PI-91155A-10, Revision
- 2. It should be noted that the criteria is merely a screening criteria and not an acceptance criteria as discussed below. The Pl-91155A-10, Revision 2 was the original source of the above screening criteria. It contains a series of screening and structural evaluation requirements; if tmeas < 0.30 (nom screening is complete and the component is rejected. This applies to both elbows and piping.
If tmens > 0.30 inom then a check to see if tpred > 0.875 tnom is made. If tpred > 0.875 tnom, screening is complete and the component is accepted. This applies to both piping and elbows and it is based on the fact that the thickness of a new component is considered acceptable if it is within the manufacturer's allowance of 12.5%.
If tpred is greater thar; 0.30 tnom but less than 0.875 tnom, a structural evaluation is required which compares tpred to the calculated a tmin based on pressure plus mechanical load induced stresses.
As stated above, the acceptance criteria for any piping component (elbows, straight pipe, etc.) requires the predicted thicimess of that component to be either greater than 87.5% of the nominal thickness (requires no further evaluation) or areater Printed 3/12/98 329 42 PM Page 3 or 5
Northe:st Utilities ICAVP DR Nr. DR MP3 0468 Minstone Unit 3 Discrepancy Report than the required thickness which is calculated based on design considerations.
Question 3 The program printouts in Attachment 1 indicate they are for lines 3-SWP-006-035-4 and 3-SWP-006-050-4. Here, the assumption is made that a typographical error was made when inputting the lines into the program.
Response
A typographical error was made when inputting the lines into the spreadsheet. The correct line numbers are 3-SWP-006-035-3 and 3-SWP-006-050-3. CR M3-96-0303 has been generated to track corrective action to correct this typographical error.
Question 4 The calculation addresses only one of the evaluations and determines that all of the components to be acceptable. A review of the (6) program outputs in Attachment i revealed that the elbow being evaluated in the 3-SWP-006-050-3 line was compared to a different acceptance criteria than the elbow in line 3-SWP-006-035-3
Response
The predicted tnickness of elbow in line SWP-006-035-3 is 0.125 inch (Refer to Attachment -1) which is greater than 87.5% of the nominal thickness of 0.134 inch. Hence this elbow is accepted without further evaluation (Notice N/A entry for required thickness calculations). On the other hand, the predicted thickness for elbow in line 3-SWP-006-050-3 is 0.089 inch (Refer to Attachment -1), which is between 30% and 87.5% of nominal thickness, hence requiring evaluation for design loadings. Since the design loads require a minimum thickness of 0.073 inch, the elbow is acceptable for continued service.
Question 5 The calculation did not reference a design change notice (DCN) or any other source to indicate the elbow was going to be replaced. This may be an operability issue.
Response
When the calculation was performed in 1992, no replacement was recommended at the time because the elbow was found to be structurally acceptable for at least another operating cycle.
However, both elbows were replaced during the following outage in 1993 via DCN numbers DM3-S-0030-93 and DM3-S-0031-93.
Thus, there is no operability issue.
Additional Information:
CR-M3-96-0303 ha: bee initiated to address the discrepancies identified in this DR. Its action plan includes preparation of a calculation change notice to address the discrepancies identified in this DR and track corrective action.
This condition has no impact on the results or the conclusions of the orlainal calculation or the satisfaction of desian basis. Thus PrWed 3/12/96 329.43 PM Page 4 of 5
Northeast Utilities ICAVP DR No. DR-MP3-0468 Millstone Unit 3 Discrepancy Report NU believes the item constitutes a Significance Level 4 l
discrepancy.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0458 has identified a condition not previously i
discovered by NU which requires corrective action. CR M3 0303 has been generated to track corrective action. However, the significance level should be 4 because the results and i
I conclusions of the orig!nal calculations were corred even though there were inconsistencies. Furthermore, the elbows in question were replaced durir : the next refueling outage.
Previou.ly identined by NU? U yw () No Non Discrepent ComNtion?O ve.
(G) No n muon P.adina70 v
@ No a *tionvare.*ed70 v
@ No n.wi A- =f - _ _ Not Acc*r*= eda Needed Date VT Lead: Nerl, Anthony A VT Mgr: Schapter, Don K 1RC Chmn: Singh, Anand K Dete:
sL Comments:
l l
I Prtnted 3/12/98 3'29 44 PM
~
Page 5 or 5
Northe:st Utilities ICAVP DR No. DR-MP34467 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLLTOON ACCEPTED R
E W.Spem W Potentiel Operetnlity issue Discipline: Electrical Doongn Ow Discrepancy Type component M
@ No SystemProcess: SWP NRC SWance Imt: 4 Date faxed to NU:
Date *utnished: 11/297 Discrepancy: Calculation Discrepancies involving SWP Non-Reversing Motors
==
Description:==
- 1. Calculation SP-M3-EE-342 (Rev.1) assumes that, "where B.H.P., efficiency, power factor and rated voltage values are not available from the project documentation * (Appendix B, Page
]
B2), brake horsepower (BHP) is equal to the nameplate horsepower, efficiency is 0.92, and the power factor is 0.88 for 460V motors. However, for the following 460V motors, the project documentation is available for this data but was not used in the calculation:
Motors 3SWP*P3A and 3SWP*P3B have an efficiency of 0.84 and a power factor of 0.88 as shown in Plant Design Data System (PDDS) and a BHP of 7 as shown in Specification 2214.432-042 Add.1 (rtev.1) and PDDS.
Motors 3SWP*P2A an j 3SWP*P2B have an efficiency of 0.84 and a power factor of C.80 (per Vendor Drawing 2332.502-042-012A) or 0.82 (per Specification 2214.432-042 Add.1 (Rev.1)
Page 2-17 and PDDS). These motors have a BHP of either 7.55 i
(per Specification 2214.432-042 Add.1 (Rev.1) Page 2-17) or 7 (per PDDS).
Motors 3SWP*STR1 A,3SWP*STR1B,3SWP*STR1C, and 3SWP*STR1D have an efficiency of 0.79 and a power factor of 0.77 as shown in Specification 2332.515-063 Add. 4.
Since the actual brake horsepower of 3SWP*P2A,3SWP*P28, 3SWP*P3A, and 3SWP*P3B is less than that assumed in the calculation, the results of Calculation SP-M3-EE-342 are conservative. The data listed above for 3SWP*STR1 A, 3SWP*STRIB,3SWP*STR1C, and 3SWP*STR1D have no effect on the results of the calculation.
Since the actual motor data is available, either Calculation SP-M3-EE-342 should be revised to reflect this data or the statement in Appendix B Page B2 of Calculation SP-M3-EE-342 should be revised.
i
- 2. There is a discrepancy in the minimurr required voltage for 3SWP*TV35A and 3SWP*TV358. Calculation 209E (Rev. O, CCN 2) Page 6 states that the minimum required voltage is 97 volts (this value is discussed in the telephone memorandum attached to Calculation 209E as Page 79). Specification 2472.110-185 Add.1 (Rev. 4) Page 1-12 requires that the motors operate with a minimum reouired voltage of 85% of rated v:! 0, rh!2 cqu::: to 102 E: c. Thi 4rrthe v2:0 thet g y 3 p
,g g
Northe:st Utilities ICAVP DP. No. DR-MP3-0467 milistone unit 3 Discrepancy Report in Calculation 210E (Rev. O, CCN 1) Page 86. These calculations should be revised to reflect the minimum rated voltage. Since these actuators were procured from the same vendor and specification, their acceptance criteria should be identical.
The minimum calculated voltage for motor 3SWP*TV35B is 104.8 volts as shown in Calculation 209E Page 6. The voltage used for MCC 3EHS*MCC182 (which feeds 3SWP*TV358) is shown as 430 volts (Page 8 of the calculation), but Degraded Voltage Calculation NL-042 (Rev. 2, CCN 5) now shows this MCC to have a voltage of 424.8 volts. Using the NL-042 MCC voltage results in a motor terminal voltage of 99.6 volts, which satisfies the minimum voltage requirement of 97 volts shown on Page 6.
The minimum calculated voltage for motor 3SWP*TV35A is 102.5 volts as shown in Calculation 210E Page 86. The voltage used for MCC 3EHS*MCC1 A2 (which feeds 3SWP*TV35A) is shown as 434 volts (Page 6 of the calculation), but Calculation NL-042 new shows this MCC to have a voltage of 427.9 volts.
Using the NL-042 MCC voltage results in a motor terminal voltage of 96.4 volts, which does not satisfy the minimum voltage requirement of 102 volts shown on Page 86 of Calculation 210E nor does it satisfy the minimum voltage requirement of 97 volts shown on Page 6 of Calculation 209E.
Note that Calculations 209E and 210E state that the calculation of record that determines the MCC bus voltages is NL-038. It appears that Calculations 209E and 210E should be revised to use Calculation NL-042, which provides lower minimum voltages and is more conservative than Calculation NL-038, and not NL-038 for determining the MCC bus voltages.
- 3. For motors 3SWP*P1 A,3SWP*P18,3SWP*P10, and 3SWa*P1D, Calculation GM-60-03.405CA (Rev.1) shows an acceleration time of 6 seconds for a minimum starting voltage of 70% of rated voltage. This does not agree with the 5 second acceleration time shown in Specification 2441.003-009 (Rev. 2)
Page 2-8 (the 6 second acceleration leads to more conservative results in Calculation GM-60-03.405CA).
- 4. Calculation NL-033 Rev. 3 Page 17 shows two entries in the
" Safety Related Pump Table" for 3SWP*P1 A/C. The first entry (the one with BHP = 591 and kW = 469) should read i
3FWA*P1 A. This has no effect on the results of the calculation for the service water pumps because only the data from the "econd entry was used in tha calculations.
j Review l
Valid invalid Needed Date initiator: Kondell, D. J.
9 O
O sa27/97 VT Leed: Nort, Anthony A B
O O
iot27/97 VT Mgr: schopfer, Don K Q
Q Q
1o/28/97 Printed 3/12/96 330:26 PM Page 2 of 5
Northe:st Utilities ICAVP
' DR No. DR-MP3-0467 Millstone UnR 3 Discrepancy Report IRC chmn: singh, Anand K O
O O
oramri Date:
INVAUD:
Date: 3/10/98 RESOLMiloN: Disposition:
NU has concluded that item #1 of Discrepancy Report, DR-MP3-0467, has identified a condition not previously discovered by NU which requires correction.
Item 1)The NU OPAL database for low Horsepower (HP) motors connected to the Motor Contml Centers (MCCs) uses 92%
efficiency and 88% power factor (pf). These values are non-conservative when compared to low HP motors of similar design.
But in practice all MCC motors including 3SWP*P2A, 3SWP'P28,3SWP*P3A, and 33WP*P3B assume Brake Horse Power (BHP) loading at the 100% of the nameplate rating. The actual BHP loading will typically be less than nameplate, this offsets the non-consentatism from efficiency and power factor values. The project documentation values for BHP, efficiency and pf should have been used. Condition Report (CR) M3-97 4061 was written to address the issue. The approved Corrective Action Plan (CAP) (attached) and DCN DM3-001769-97 were issued to complete the otrrective actions.
NU has concluded that the issues reported in item #3 of Discrepancy Report, DR-MP3-0467, does not represent a discrepant condition.
Item 3)
For motors 3SWP*P1 A, 3SWP*P1B, 3SWP*P10, and 3SWP*P1D, in attachment 4.3.1 of SP-M3-EE-269 (calculation GM-60-03.405CA, rev.1) shows a calculated acceleration time of 6 seconds for a minimum starting voltage of 70% of rated. The original purchase specification 2441.003-009(rev. 2, page 2-8) stated the maximum starting time of 5 seconds for minimum i
starting voltage of 70% of rated. Review of the motor curve from SP-M3-EE-260, rev.1(attachment 4.3.1 page 38 of 99) Indicates the 6 seconds start time is more conservative. Therefore, the protective relays conservatively are set to envelop the stated start time of 5 seconds and prevent inadvertent tripping during motor starting and consistent with the specification SP-M3-EE-269 philosophy.
Sionificance Level criteria does not apply here as this is not a discrepant condition.
NU has concluded that items #2 and 4 of Discrepancy Report, DR-MP3-0467, have identified conditions previously discovered by NU which requires correction.
j ltem 2)
Pnnted 3/1298 3:30:27 PM Page 3 of s
Northe:st Utilities ICAVP DR No. DR-MP3 0467 Millstorm Unit 3 Discrepancy Report The discrepancies with the calculations 209E and 210E were identified during the 10CRF50.54f calculation review program.
Adverse Condition P.eport (ACR) M3-97-0119 and LER No. 97-011-00 were written to address the issue. Also calculations 209E and 210E were corrected by the issuance of new calculation 97-ENG-01512E3.
Item 4)
Calculation NL-033 Rev. 3 page 17 shows that two entries in the
" Safety Related Pump Table" for 3SWP*P1 A/C is in error. The error was urrected in NL-033 Rev. 3 CCN# 4 the " Safety Related Pump Table" page 11 of 43.
NU believes that this DR was classified Significance Level 3 as a result of item 2 which is previously discovered. Since item #1 is only discrepant item, and the Design Basis is not affected, NU j
considers this DR to be a Significance Level 4 issue.
==
Conclusion:==
NU h !s concluded that item #1 of Discrepancy Report, DR-MP3-4 0467, has identified a condition not previously discovered by NU which ruquires correction.
Item 1)
The assumed methodology used in the NU OPAL database fc.-
modeling low HP motors is an adequate approach. This approach agrees with S&L that the calculation SP M3-EE-342 is conservallve. Condition Report (CR) M3-97-4061 was written to address the issue. The approved Cr Trective Action Plan (CAP)
(attached) and DCN DM3-001769-97 were issued to complete the corrective actions.
NU has concluded that the issue reported in # 3 of Discrepancy Report, DR MP3-0467, does not represent a discrepant condition, item 3)
Calculation SP-M3-EE-269 uses the more conservative starting time of 6 seconds than the 5 seconds in the original purchase specification. Therefore, the protective relays conservatively are set to envelop the stated start time of 5 seconds and prevent inadvertent tripping during motor starting and consistent with the specification SP-M3-EE-269 philosophy. Significance Level criteria does not apply here as this is not a discrepant condition.
NU has concluded that items #2 and 4 of Discrepancy Report, DR-MP3-0467, have identified conditions previously discovered by NU which requires correction.
item 2)
Adverse Condition Report (ACR) M3-97-0119 and LER No. 97-Pmted 3/12/98 3:3029 PM Page 4 of 5
4 Northecst UtilFlas ICAVP DR No. DR-MP3-0467 Millstone unit Discrepancy Report
'11-00 were written to address the issue of calculations 209E
- 210E Calculations 209E and 210E were correded by the
- ance of new calculation 97-ENG-01512E3.
4 hem 4)
The error was corrected in revision N1.-033 Rev. 3 CCN# 4 the
" Safety Related Pump Table" pa0e 11 of 43.NU believes that this DR was classified Significance Level 3 as a result of item 2 which is previously discovered.
Since item #1 is only discrepant item, and the Design Basis is not affected, NU considers this DR to be a Significance Level 4 issue.
Previously identined try Nu? O Yes (9) No Non D6screpent Condet6on?O Yes
(*) No Resolution Pending70 vos @ No nosoeunionunresoeved70 vos @ No
- n. view initiator: KendeR,D.J.
VT Leed: Neri, Anthory A VT Mor: schopfer, Don K NtC Chmn: singh, Anand K Date:
3/10/98 sL Commente: Item 2 - Based on the analysis provided in Calculation 97-ENG.
01512E3 (which supersedes Calculations 209E and 210E),
Sargent & Lundy has reclassified this as a Level 4 discrepancy because the technical concems have been adequately resolved as documentation and not hardware issues. NU refers to ACR M3-97-0119 and LER 97-010 (written on 1/13/97 and 2/28/97, respectively), which address the de0raded voltage condition issues identified in item 2 of DR MP3-0467. However, these documents do not address the inconsistencies conceming the acceptance criteria used for devices 3SWP*TV35A and 3SWP*TV35B which has now been resolved by new Calculation 97-ENG-01512E3 Since Calculation 97 ENG-01512E3 was written on November 12,1997, this discrepancy was not previously discovered and resolved prior to the cutoff date of 5/27/97 for Wave 1 systems, therefore, it is still a discreant condition.
Item 3 - Based on clarification provided in NU's response to this discrepancy report, SarDent & Lundy concurs that this item is not a discrepant condition.
Item 4 - Since Calculation NL-033 Revision 3, CCN 4, was issued in September 1997, this discrepancy was not previously discovered and resolved prior to the cutoff date of 5/27/97 fer Wave 1 systems, therefore, it is still a discrepant condition, item 1 - NU has concluded that this item is a discrepant condition.
l Printed 3/12/96 3:30:30 PM Page 5 r,r 5
1 Northe:st Utilities ICAVP DR No. DR-MP3-0441 Millstone Unit 3 Discrepancy Repoft Review oroup: conrguraten DR RESOWTMW ACCEPTED Review Element: System Instellation D6ecipline: Electrical Design Ow Diecrepency Type: Instelletlon Irnplementation e No Systemerocess: sWP NRC Signiecance levet* d Date faxed to NU:
Date Putdished.11MW97 D6 crepancy: Installation not in accordance with drawings
==
Description:==
The following differences between installation documents and the field conditions were noted during walkdowns of the SWP System.
- 1. The FSAR Fire Protection Evaluation Report in response to questions (page A-18) states that all penetrations between fire areas will be sealed with silicone. Contrary to this, the wall penetration for trays 3TC206P and 3TC161P through the Auxiliary Building to the cable tray chase / tunnel has no silicone and appears to be sealed only with Kaewool.
- 2. Section 4-4 of Drawing EE-34GQ Rev. 6, shows support for j
tray riser 3TX206N. The support detail does not include the field observed Appendix R li0ht attached to the north leg of the support. In addition, this tray riser support is identified in the Cable and Raceway Program as GQ-VIEW 4-001; the drawing should provide reference to this support number. Further, it was noted that a large quantity of cable exits tray 3TX205N transitioning into 3TX206N at the same point, over the same rung - this puts a significant load on the rung in a non-standard confi0uration. The evaluation of the sin 0le rung to support such a load is not apparent. Adoitionally, cables exiting conduits 3CC203NG, K and 3CC215NX transitioning to trays 3TC203N and 205N are routed across sharp edges of the tray and cable support hardware which is part of the tray support.
- 3. Tray Location drawing EE-34DX, Rev. 8 (M-6) shows a lateral brace on tray support A104. This member was not observed as l
installed in the field.
- 4. Cables routed / installed in tray 3TC206P (or co-located tray 3TC161P) between supports A176 and A174C as shown on tray Support Location drawing EE-34DY, Rev. 8 (J-9) short cut the 90-degree horizontal fitting. The cables exit over the side rail and then re-enter the tray over the side rail. This is not consistent with the Electrical Installation Specification E-350, Rev. 9.
- 5. Tray support A327B-46 (EE-34GC, Rev. 4) was observed to have a strut attached across the bottom member for the connection of lighting fixtures and a lighting conduit attached to one of the vertical members. These attachments are not shown on the support detail.
- 6. Tray 3TK202P was observed to have flat covers installed top and bottom. The Cable and Raceway Program (TSO2) shows these covers to be vented; the Tray Location drawing EE-34Y, Rev. 9, nc'c 2 Pd=t= thct44 pc;;= trcyc (K ccMcc) gh 5
p g
pg
Northe:st Utilities ICAVP DR No. DR-MP3-0481 Millstone Unit 3 Discrepancy Report have vented covers.
- 7. The Cable and Raceway Program (TSO2) indicates that conduits 3CC2020A and 3CC202OB are held in place with 3 supports. These conduits are supported by 6 supports.
- 8. Conduits 3CC932PD,3CC932PC, and 3CC932PE are listed in the Cable and Raceway Program as having only one support.
These installed raceways have four supports.
- 9. Conduit 3CC1000B11s supported by two supports in the field.
The Cable and Raceway Program does not show any supports for this conduit.
- 10. The Cable and Raceway Program (TSO2) indicates that conduit 3CK1010A1 is support by three supports. The installed conduit is supported by two supports.
Review Vaud inval6d Needed Date initietor: servw, T. L B
O O
int 2ss7 VT Leed: Neri, Anthony A B
O O
sot 27/97 VT Mgr: schopfw, Don K Q
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10'30S7 IRC Chmn: singh, Anerh1 K G
O O
11/4S7 Date:
INVAUD:
1 Date: 3/11/98 RESOLUTION' NU has concluded that Discrepancy Report DR-MP3-0481 item 2d,4 and 10 have identified a condition not previously discovered by NU which requires correction. Condition Report (
CR ) M3-98-0424. was written to provide the necessary corrective actions to resolve this issue. The eight (8) remaining conditions (Items 1,2a,2b,2c,3,5,6,7,8,9) do not represent discrepant conditions. These DR ltems The items are discussed below:
A search of the Fire Stops and Seals (FS&S) drawings for Trays 3TC206P and STC161P indicates they are penetrating through wallline 51.3 which is FS&S Map AB-222. A review of drawings EE-348Q indicates tray 3TC206P is on the North side of the wall and 3TC161P is the continuation on the South side. FS&S Drawings 25212-24273 Sh. AB222A,222D and 222F shows this tray has a seal detail of E17 in Blockout #11. A review of drawing 25212-29G80 Sh. 32 shows that the seal material for Detail E17A is TCO-050 Silicone Foam with damming material por Note 8 of that drawing. This note points to drawing 25212-29680 Sh 22 and Notes 3 & 5 on this drawing indicate the damming material is to be permanent and an acceptable damming material is "Cerabianket". Field walkdown confirms the seal is installed as detailed. The "Kaewool" as observed in this item was actually "Cerabianket* permanent damming matertal.
The silicone material is not visible from the north side of the wall. Therefore, these trays are sealed in accordance with the Printed 3/12S6 3:3106 PM Page 2 of 5 N
Northecst utenties ICAVP DR No. DR.MP3 0481 milestone Unit 3 Discrepancy Report applicable documentation and there is no discrepancy item 2a: the first statement, describes a support for a tray riser of
- tray 3TX206N on drawing EE-34GQ, Section 4 - 4 which does not include the field observed Appendix R light attached to the North leg. A search of GRITS against the applicable affected document (EE 34GQ) reveals an E&DCR F-E-44217 which approves a request to attach a battery unit for Appendix R lighting to an existing C6 x 8.2 Channel of a tray support. Also, Section 4 - 4 on drawing EE-34GQ has a Section 21 - 21 cut on the North leg at approximate El. 30'-0". This Section is shown on EE 34GP and details the connection of an item "AU" and "L" to an item *BX" (i.e. C6 x 8.2). A field walkdown of the location and details described in E&DCR F-E-44217 confirms that the battery unit is attached to GQ-VIEW 4-001. Therefore, the attachment is documented and qualified and is not a discrepancy.
Item 2b: the second statement, notes that the Cable and i
Raceway Program identifies the tray support as GQ-VIEW 4-001 whereas drawing EE-34GQ does not provide reference to this support number.
The purpose of giving unique mark numbers to cable tray support is to differentiate between similar support details which may cover several supports at different locations on a given location drawing. In the case of support GQ-VIEW 4-001, in the Cable and Raceway Program this is a unique mark number.
However, there was no need to label the support on drawing EE-34GQ since there is no other " VIEW 4' on that drawing. This is true with several other types of support details on other drawings. Since there is no need to label GQ-VIEW 4-001 on EE-34GQ, this is not considered a discrepancy and no further action is recommended.
Item 2c: the third statement, identifies a large quantity of cables exiting tray 3TX205N transitioning into tray 3TX206N over the same rung. This puts a significant load on the rung in a non-standard configuration with no apparent evaluation. Field walkdown confirms that the cables from tray 3TX205N actually transition from three different rungs which spreads the weight of the cables. The vertical sections of the cables as they leave tray 3TX206n are all supported by "Kellem Grips" which are intended to take the total weight of vertical cable runs and will also share the weight of the catnes as they span to tray 3TX205N. E&DCR F-E-44175 details the Kellem Grip support from tray 3TX206N.
The reference calculation for the E&DCR is calculation 1217g-SEO-SE 34.413. Therefore, there is adequate support for the large amount of cables transitioning from horizontal tray 3TX20$N to vertical tray 3TX206N and no further action is i
required item 3: A GRITS search against the cable tray location drawing EE-34DX and the support detail drawing EE-34GP, indicates an unincorporated E&DCR N-CS-02415 posted against both drawings which describes a condition where an interference existed which precluded the installation of "M" bracing between supports A105 and A104 as shown on EE-34DX. The E&DCR continues on Pa. 2 of 4 with directions to add new bracina in lieu Printed 3/12/98 3:3128 PM Page 3 or 5 1
~
Northe:st UtilRies ICAVP DR No. DR-MP3 0481 milistone unit 3 Discrepancy Report of the "M* bracing on EE-34DX as well as the W bracing as specified on EE-34DX and EE-34GP. The reference to W bracing on EE34GP refers you to drawing EE-34JB, Det. W.
This detalls calls for item *BF" for the W brace which is the i
item called out on EE 34DX. The new braces added per E&DCR l
N-CS-02415 are documented and are qualified as the replacement for the item called out as *BF*. Therefore, this is not a discrepant condition.
Item 5: This attachment is in accordance with the Lighting Plan and Fixture Support Detail Drawings EE-69B & 69E. Therefore this item is not valid and requires no further action item 6: The Tray Arrangement, identification and Cover Drawings EE-34Z,34BP & 34TP were reviewed for this "K" service tray run, identified as 3TK207P,3TK208P, 3TK202P, 3TK203P and 3TK210P. The drawings indicate that these trays should be covered top and bottom with a vented cover. These trays were then verified in the field and found to have a vented cover installed on top and bottom for the entire run. The "C*
service tray below this "K* service has a flat cover installed on top and bottom in accordance with these drawings. Due to close proximity, there may have been some confusion when the initial walkdown was performed. As a result, this item is not valid and requires no further action.
Item 7: A search of the Cable and Raceway Program confirms three supports (AB-2317 AB-2318 and AB-2319) are listed for conduits 3CC202OA and 3CC20208.
However, copies of the Conduit Support Logs (CSL's) indicates the following :
CSL AB-2317, is a Floor to Ceiling Detail from BE-52WN and it has (4) cross members so that there are (4) attachment points for this one support.
CSL AB-2318 Detail BE-52WV has a single attachment point.
CSL AB-2319 Detail BE-52WV has a single attachment point.
Therefore, there are a total of (6) attachment points with only (3) conduit supports details which indicates the documentation is correct and this is not a discrepant condition.
Item 8: A search of the Cable and Raceway Program confirms one support (AB-057) for conduits 3CC932PD, 3CC932PE and 3CK231PC (the DR lists a conduit 3CC932PC that does not exist, which indicates this may be a typo).
Further, a copy of the Conduit Support Log (CSL) indicates the following :
CSL AB-057, is Detail BE-52WN and it has (4) cross members so that there are (4) attachment points for this one support.
Therefore, there are a total of (4) attachment points for the three conduits, with only (1) conduit support detail which indicates the documentation is correct and this is not a discrepant condition.
Item 9: A search of the Cable and Raceway Program indicates there are two supports (AB-812 and AB-738) for conduit 3CC1000B1 and since them are (2) supports in the field which indicates the documentatic is correct and this is not a discrepant condition.
PrWed 3/12/96 3:31:08 PM Page 4 of 5
NortheCst Utilities ICAVP DR No. DR MP3 4481 milistone unit s Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-0481 item 2d,4 and 10 have identified a condition not previously discovered by NU which requires correction. The corrective adions necessary to resolve the issues detailed in DR-MP3-0481 will be developed based on Condition Report M3-97-0424.
AR98001962 will track the corrective actions to c'osure.
The corrective actions detailed in Condition Report M3-97-0424 are:
1 Item 2d: The cables leaving 3CC203NG rest on the side rail of
)
the vertical tray at the midpoint of the transition to tray 3TC203N. These cables will be either shifted off the tray's side rail or some form of additional protection added such as a wrap.
Additionally from a configuration standpoint, conduit 3CC215NX will be added to conduit drawing EE-48F, extending from the block out at 53 3 and F.3 to the tray, item 4: Cables routed in tray 3TC206P between tray supports A176 and A174C in the Auxiliary Building at Elevation 24'-8",
which short cut the 90 degree fitting by exiting and entering over the tray side rail will be re-worked and trained to lay inside of tray 3TC206P, minimizing the risk of accidental cable damage.
item 10: The Cable and Raceway Program will be corrected to indicate conduit 3CK101 A1 is supported by AB-0813 and AB-0821 and 3CK10181 is supported by AB-0814 and AB-0822.
The discrepent conditions indentifed by this DR do not impact licensing or design basis information and /or are administrative in nature. Therefore the corrective actions will be completed after restart. Field modifications may be required. NU considers this DR to be a Significance Level 4 discrepancy.
Pr.viously identleed by Nu? U Yes @ No NonDiscrepentConestion?O Yee @ No n.edunonPenenetO Y=
@ N.
m unt.emv.dt O Y = @ No n.wiew initiator: Kielc, N O
O O
- =
VT Lead: Neri, Anthor y A VT Mgr: Schopfer, Don K Ntc Chrnn: Singh, Anand K Date:
st Cornments:
l l
Prtnted 3/12/9s 3.31:10 PM Pope 5 or 5
f i
Northe:st Utilities ICAVP DR No. DR-MP3-0659 Ministone Unit 3 Discrepancy Report i
Review Group: Conrguraten DR RESOLUTION ACCEPTED Review Element: System Installeuon p
i Disci une: Electncal Dwign O va P
Discrepancy Type: InstalleNon irg* mentation g
SystemProcess: Rss NRC SigntAcance level: 4 Date faxed to NU:
Date Published. 11/17/97 D6screpency: Tray covers not in accordance with design documents Ducription: 1. The Cable and Raceway Program (TSO2) indicates that tray 3TX768N has covers top and bottom. The Cable Tray Cover Location and Identification drawing, EE-34TB, Rev.1, indicates no covers are required and no covers were observed installed on this tray.
- 2. The Cable and Raceway Program indicates that tray 3TK7550 is 14 feet long. Based on field observation, this tray section is over 26 feet long. Since cable lengths used in calculations may be computed from raceway lengths, it is important to have reasonably correct data.
- 3. Tray 3TC7640 has a bottom cover on the horizontal 90 degree tum in the run installed in the field. Tray Cover identification and location drawing EE-34TB Rev.1 and the Cable and Raceway Program (TSO2) do not indicate that this cover is installed.
The following material condition was noted.
Cable Tray STK753N is corroded presumably from 61 dripping of fluid from a floor penetration directly above the tray - based on signs of previous dampness. This tray is not covered, therefore, j
the cables within the tray are exposed to this fluid flow.
Review Valid invalid Needed Date initiator: Server, T. L 0
0 0
11m97 vr Leed: Nei. Anthony A O
Q Q
11m97 VT Mgr: Schopfw, Don K O
O O
Si/ o/97 1RC Chmn: Singh, Anand K O
O O
tii13/97 Date:
WVALID:
Date: 3/10/98 RESOLUTION Disposition:
Nu has concluded that Discrepancy Report, DR-MP3-0559, has identified a condition not previously discovered by NU which requires correction.
Items 1 thru 3 were researched in the UIR, OIR and GRITS Dat: Mes and no matches were found in the UIR and OIR Dr.abae to indicate pre-discovery by NU. However the GRITS Drtabases avealed two E&DCRs posted against drawing EE-S aTB which sytt the drawing and TSO2 configuration for the Printed 3/12/98 3:32:37 PM Page 1 of 4
Northe:st Utilities ICAVP DR No. DR MP3-0569 Millstone Unit 3 Discrepancy Report condition described in item 3 of this DR. The following updates need to be completed for the DR identified discrepancies:
Issue 1) The drawing (EE-34TB) review for the tray cover requirements on 3TX768N indicate that no covers are required on the top or bottom of this tray. A field walkdown confirmed that cable tray 3TX768N has neither a top nor bottom tray cover, The cable tray cover drawings, EE-34 series, provide the installation information for cable tray covers to maintain the separation requirements given in the electrical installation specification SP-EE-076, appendix J. Conversely, the cable tray cover information olven in the Cable and Raceway Program (TSO2) is a take-off from the cable tray cover drawings and field conditions to account for the added weight on the applicable cable tray supports.
As a result, the cable tray cover type and quantity in TSO2 have been revised to indicate the documented and installed condition.
issue 2) Drawings EE-34AN and 34BB were reviewed for the length of tray 3TK7550 and determined it to be approximately 26 feet. Cable tray 3TK7550 was walked down in the field and observed to be approMmately 26 feet in length, also. A review of the last revision of the SWEC raceway ticket for this tray depicts a length of 14 feet which supports the present length in TSO2. A previous revision of this raceway ticket indicates the tray is 30 feet long Since the field conditions and drawing configuration support a length of 26 feet, TSO2 will be revised to reflect the actual length. Further the raceway length in the raceway file does not affect the as-installed cable length in the cable file in TSO2. This is because initially the raceway length is used only to estimate the cable length, which is in the WIP cable file. The final cable length in the cable file is based on field installed lengths fed back to electrical design via the AWO process per the requirements of the Electrical Installation Specification SP-EE-076. These as-installed lengths in the cable file are used in the electrical calculation process.
Issue 3) The drawing (EE-34TB) review for the tray cover requirements on 3TC7640 revealed that no covers are needed on the top or bottom of this tray. The GRITS Database was then reviewed, in which two E&DCRs were retrieved to support the drawing configuration. These E&DCRs (F-E-43845 & F-E-43876) eliminate the top and bottom tray covers and substituted cable wraps in their place for ease of installation. Field walkdown of this area confirmed the bottom tray cover was installed even though it is not required. Since the bottom tray in the bank above an open potential working area will provide additional mechanical protection, NU revised drawing EE-34TB to show a flat tray cover on the bottom of cable tray 3TC7640 at the 90 degree elbow and updated the Cable and Raceway Program (TSO2). Field Material Condition Another walkdown was completed on cable tray 3TK753N to verify the corrosive condition reported on this C;. This walkdown confirmed that the inner tray side rail. a number of runos and the horizontal PrWed 3/12/96 3:32Ao PM Pa0e 2 of 4
Northeast Utilities ICAVP DR No. DR-MP3-0669 Millstone Unn 3 Discrepancy Report members for tray supports G204-40 & 41 in the area of the 90 degree elbow south of the 45.3 line wall on elev. 21'-6" were covered with a white chalk like substance. The insulation of the cables in the tray were not covered with this substance and therefore do not appear to be damaged or degraded. The ceiling above the tray was dry, but looked like fluid had been leaking where the supply vent duct for 3FNQ-DMPF1025 penetrates the floor. NU generated Trouble Report TR#16M3102352 to correct this problem. As a result, the area of the tray and support in question will be cleaned, prepared and touched-up with Galvanox in accordance with specifications SP-EE-076 and SP.
EE-245 to prevent future deterioration.
Condition Report (CR) M3-97-4404 was written to provide the necessary corrective actions to resolve these issues. Approved Corrective Action Plan (CAP) (attached) and DCN DM3-00-1955-97 ~were issued to correct the drawings and the Cable and Raceway Program (TSO2). Since only drawing and Cable and Raceway Control Program (TSO2) revisions are required in this DR, NU considers this DR to be a Significance Level 4 issue.
This is a documentation errors that do not affect the Plant Design Basis.
l
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0559, has identified a condition not previously discovered by NU which requires correction. Condition Repcrt (CR) M3 97-4404 was written to provide the necessary corrective actions to resolve these issues. Approved Corrective Action Plan (CAP) (attached) j and DCN DM3-00-1955-97 were issued to correct drawings and i
the Cable and Raceway Program (TSO2) mentioned.
NU generated Trouble Report TR#16M3102352 (attached) to correct field material condition problem. As a result, tho area of the tray and support in question will be Cleaned, prepared and touched-up with Galvanox in accordance with specifications SP-EE-076 and SP-EE 245 to prevent future deterioration.
Since only drawing and Cable and Raceway Control Pro 0 ram (TSO2) revisions are required in this DR, NU considers this DR to be a Significance Level 4 issue. This is a documentation errors that do not affect the Plant Design Basis.
Previoudy identined try Nu? U Yes it) No Non Diecrepant Condenon?U Yes (9) No noenonPendiantO va @ wo namuonunr=*ed70 va @ wo Review initletor: Womer, l.
VT Lead: Nort, Anthony A 8
O O
st a vT mar: senope.r. Don r, IRC Chmn: singh, Anand K Date:
sL Comments:
Printed 3/12/96 3:32A2 PM Page 3 of 4
Northe:P.t Utilities ICAVP DR N2. DR-MP3-0669 millstone Unit 3 Discrepancy Report j
Printed 3/12S6 3.32.43 PM Page 4 of 4
[
Northeast Utilities ICAVP DR No. DR-MP3-0690 I
Millstone Unit 3 Discrepancy Report heview Group: system DR RESOLUTION ACCEPTED Review Element: system Design Diecipline: Elodrical Desig" Om Discrepency Type: Calculation g
SystemProcess: DGX NRC Significence level: 4 Date faxed to NU:
]
Date Putsehed 11/24S7 Discrepency: Motor Control Center Circuit Breaker Coordination Calculationb
)
848C and 849C
==
Description:==
These calculations verify the coordination required to maintain selective tripping on motor control centers 3EHS*MCC1 A1, 3EHS*MCC1B1,3EHS*MCC183, and 3EHS*MCC184. Both calculations do not include a list of references. This makes it difficult to verify the input data to the calculation. The citation of input data should be strengthened.
j in acidition, the following comments apply only to Calculation 849C.
The marofacturve time overcurrent characteristic curve for the iTE FJ molded case circuit breaker shows somewhat longer j
maximum tripping times at the upper end of the thermal element i
tripping characteristic. As a result, coordination between the FJ molded case circuit breaker and the upstream switchgear may be lost at the upper range of the thermal overioad characteristic of the FJ molded case circuit breaker.
ITE listed the short circuit rating of the FJ molded case circuit breaker as 18,000 amperes symmetrical at 480 volts. However, the coordination curves are drawn to a maximum short circuit current of 22,000 amperes. The coordination curve of the type FJ molded case circuit breaker should be redrawn so that its curve ends at 18,000 amperes, since its interrupting time is undefined at higher current levels.
Calculation NL-051 indicates that the short circuit current at i
motor control centers 3EHS*MCC1B3 and 3EHS*MCC184 are
~
less than 18,000 amperes, so the molded case breakers are operated within their interrupting capacity. Therefore, the sighnificance level of this discrepancy is level 4.
Review Valid invalld Needed Date armistor: Bloethe, G. William B
O O
$1/SS7 VT Leed: Neri, Anthony A Q
Q 11/11/97 VT Mgr: Schopfer, Don K D
0 0
11/17/S7 IRc Chmn: singh, Anand K O
O O
5 1 S'S7 Date:
INVALID:
l Date: 3/10/98 RESOLUTION: NU has concluded that discrepancy report DR-MP-0590, identified several concems, one that represents a condition previously discovered by NU which requires correction and one Printed 3/1296 3.33:12 PM Page 1 of 3
Northecst Utilities ICAVP DR No. DR-MP3-0690 Millstm Unit 3 Discrepancy Report that does not represent a discrepant conditions.
Item 1, Many instances have been cited in the calculations where design inputs were not referenced and calculation formulae were not explained or reference provided. Per Engineering report DE3-ERP 97-0002 dated 11/14/97,
" Assessment of critical calcultlions for the MP3 electrical distribution system", CR M3-971217, dated 4/28/97, was written to tract the discrepancies found in Calculation GM-60-03.848 and 849. Specification SP-MP-EE-269 Rev 1, dated 7/23/97, supersedes Calculation GM-60-03.848 and 849, contains and controls coordination curves, and also includes the electrical protection philosophies. Therefore, NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0590 has identified a condition previously discovered by NU which requires correction.
Item 2, Calculation NL-051 Indicates that the short circuit current at motor control centers 3EHS*MCCIB3 and 3EHS*MCC184 are less than 18,000 amperes, so the molded case breakers are 1
operated within their interrupting capacity. The manufacturers time overcurrent characteristic curve for the ITE FJ molded case circuit breaker shows somewhat longer maximum tripping times at the upper end of the thermal tiement tripping characteristic.
This part of the curve is only used for reference. Specification SP-MP3-EE-269, Rev 1, dated 7/23/97, which supersedes Calculation GM-60-03.848 and 849, contains and controls coordination curves, also included is the electrical protection philosophies. NU has concluded that this issue regarding Discrepancy Report DR-MP3-0590 does not represent a discrepant condition.
==
Conclusion:==
NU has concluded that discrepancy report DR-MP-0590, identified several concems, one that represents a condition previously discovered by NU which requires correction and one that does not represent a discrepant condition.
Item 1, Many instances have been cited in the calculations where design inputs were not referenced and calculation formulae were not explained or reference provided. Per Engineering report DE3-ERP-97-0002, dated 11/14/97,
" Assessment of critical calculations for the MP3 electrical distribution system", CR-M3-97-1217, dated 4/28/97, was written to tract the discmpancies found in Calculation GM-60-03.848 and 849. Specification SP-MP-EE-269, Rev 1, dated 7/23/97, supersedes Calculation GM-60-03.848 and 849, contains and controls coordination curves, and also includes the electrical protection philosophies. Therefore, NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0590 has identified a condition previously discovered by NU which requires correction.
Item 2. Calculation Nt.451 indicates that the short circuit current PrWed 3/12/98 3.33:15 PM Page 2 or 3
l Northe:st Utilities ICAVP DR No. DR-MP3-0690 Millstone Unit 3 Discrepancy Report at motor control centers 3EHS*MCC183 and 3FHS*MCC184 are less than 18,000 amperes, so the molded case 'Dreakers are i
operated within their interrupting capacity. Th0 manufacturers time overcurrent characteristic curve for the f TE FJ molded case circuit breaker shows somewhat longer max' mum tripping times i
at the upper end of the thermal element trir. ping characteristic.
1 This part of the curve is only used for reference. Specification SP-MP3-EE-269, Rev 1, dated 7/23/97, v.nich supersedes Calculation GM40-03.848 and 849, conf sins and controls coordination curves, also included is the electrical protection philosophies. NU has concluded that this issue regarding Discrepancy Report DR-MP3-0590 dcas not represent a discrepant condition.
Previously identleed by NU7 in Yes Q No Non Discrepeat Condition?Q Yes ($ No ResolutionPending70 vos Ce) No Res euikeiunresoeved70 vos Co' wo Review
~i initiator: Womer, l.
VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anend K Date:
SL commente:
)
i l
l 1
l Printed 3/12/96 3:33.17 PM Page 3 of 3
1
. NortheCst Utilities ICAVP DR Ns. DR MP3 0673 Millstone unit 3 Discrepancy Report i
Review Group: System DR RESOLUTION ACCFPTED Review Element: Syelem Design p
O vee 4
D6screpency Type: CalaW g
SystemProcess: HVX NRC Signiscence level: 4 Date faxed to NU:
Date Putdiohed 12/&97 Discrepancy: 3HVR* MOD 45C1 Blocked Open Air Temperature Calculation Description The objective of calculation 3-ENG-209, Rev. O was to show that j
the plant areas supplied by ventilation damper 3HVR* MOD 45C1 1
(charging pump area, component cooling water pump area, and MCC/ rod control area) will not drop to a temperature of less than 32'F if the damper is blocked in the full open position during April and May. During review of this calculation the following discrepancies were identified, j
- 1) Calculation used the nameplate rating for the component
)
coolin0 pump and charging pump motors when detertming the motor heat loss to the room. This is non-conservative as the pumps do not operate at their nameplate rating.
- 2) Calculation used a value of 7000 cfm for the outside air flow in determining the temperature rise in the areas. The calculation does not provide the basis for using 7000 cfm instead of the 27,000 cfm rating for supply fan 3HVR*FN14A/B.
- 3) Calculation used the entropy of saturated air instead of the specific heat of airwhen calculating the amount of heat required te raise the air temperature from 24*F to 32*F.
This calculation should be voided or identified as superceded by calculation 3-92-103-191-M3 Rev.1. CCN 1-003 to calculation 3-92-103-191-M3 Rev.1 shows that the component cooling water pump area and charging pump area are maintained above 32*F with an outside air temperature of 20.8'F.
Review Valid inveild Needed Date initletor: stout, M. D.
O O
O 11/13/97 VT Lead: Neri, AnthoryA O
O O
$'18/97 VT Mgr: schopfer, Don K O
O O
12iiro7 lRC Chmn: Singh, Anand K O
O O
2/4s7 Date:
INVAUD:
Date: 3/10/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report DR MP3-0673 does not represent a discrepant condition.
Calculation 3-ENG-209., as is stated on the cover sheet, was issued to support Bypan Jumper 391-090. The Bypass Jumper, which was a femporary deviation from normal system operating parameters, has been C wf and the calculation is for historical records only. 3-ENG-209 i w@ pen %nt of calculation Printed 3/12/96 3:33:50 PM Page 1 of 2
1 l
Northecst Utilities ICAVP DR N3. D*E-MP34673 Millstone Unit 3 Discrepancy Report i
3-92-103191M3.
Significance Level Criteria do not apply since this is not a discrepant condition.
Previously identmed by NU? ( ) Yes (G) No Non Discrepent Condit6on?( ) Yes (9) No Resolution Pending?O Ye.
@ No ResolutionUnresolved?O ve.
@ No Review
~
initiator: Stout, M. D.
VT Leed: Nerl, Arthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Date:
3/10/98 sL comments: A9ree that calculation was preprared to support bypass jumper 391-090.
The calculation should be revised, voided or superceded to prevent its use as a supporting calculation in the future. This is considered to be a Level 4 discrepancy Prtried 3/12/96 3:33:54 PM Page 2 of 2
Northe:st Utilitie3 ICAVP DR No. DR-MP3 0733 Millstone Unit 3 Discrepancy Report Review' Group: system DR RESOLUTION ACCEPTED Review Elemer,t: System Design N: Electrical Design Ow h.
- i Type: Component Date g
SyJ_.T.
=: HVX NRC S';-f"---A level:4 Date faxed to NU:
Date Published: 1/1098 Discrepency: Document Discrepancies involving HVAC Motors Description.1. Calculations NL-025 (CCN 8 Rev. 3) and NL-038 (CCN 6, Rev. 2) show a power factor of 0.9 for 3HVR*ACU1 A and 3HVR*ACU18, which disagrees with Specification 2176.430-648 (Add.1, Rev. 0) which shows a power factor of 0.839.
- 2. Efficiency varies for 3HVPTN1 A, 3HVP*FN1 B, 3HVPTN1C, 3HVPTN 1 D, 3HVRTN6A, 3HVR*FN68, 3HVR*FN 12A, 3HVRTN128,3HVR*ACU1A, and 3HVR*ACU1B betwesn the specifications, Plant Design Data System (PDDS), and caiculations. For 3HVRTN6A and 3HVRTN6B, Calculation NL-025 (CCN 8, Rev. 3) and NL-033 Page 47 (CCN 1, Rev. 3) show an efficiency of 0.902 which agrees with Specification 2170.430-140 (Add.1, Rev. 2); however, Calculation NL-038 (CCN 6. Rev.
- 2) and NL-033 Page 49 show an efficiency of 0.928 (NL-033's efficiency is based on test results). For 3HVRTN12A and 3HVRTN12B, Calculations NL-025 and NL-038 show an efficiency of 0.9 which disagrees with Specification 2176.430-141 (Add.1 Rev. 3) which has an efficiency of 0.925.
PDDS shows an efficiency of 0.92 for 3HVPTN1 A, 3HVPTN1B,3HVPTN1C, and 3HVPTN1D which disagrees with Specification 2170.430-140 (Add.1, Rev. 2). PDDS shows an efficiency for 3HVR*ACU1 A and 3HVR*ACU1B of 0.893 which disagrees with the efficiency of 0.902 shown in Specification 2176.430-648 (Add.1. Rev. 0) The appropriate documents should be revised to reflect the actual values.
- 3. Vendor Drawings 2i70.430-141-002G and 2170.430-141-004E show a design brake horsepower of 75 for the 3HVRTN12A and 3HVRTN12B driven equipment. This value does not agree with Specification 2176.430-141 (Add.1, Rev. 3) which shows a BHP limit of 47 and a max BHP of 67.5, or with Plant Design Data System (PDDS) which shows a BHP of 60.
Since the motor's developed horsepower is only 75, this encroaches on the motor's service factor which conflicts with FSAR Section 8.3.1.1.4. Note that Vendor Drawing 2170.430-141-001B showed a design BHP of 47, however, GRITS indicates that this drawing is no lon0er valid as it is superseded by 2170.430-141-004E.
l
- 4. The horsepower of 3HVP*FN1A,3HVP*FN1B,3HVPTN1C, ed 3HV"TNi0 !c 20;.. cr. V:Mer Oc;;T.g 2144.'.?g,,,,
mg
Northert Utilities ICAVP DR No. DR-MP3-0733 mmstone unit 3 Discrepancy Report 011C and 2144.430-140-010J with a horsepower rating of 40 but Vendor Drawing 2170.430-140-010D shows a horsepower rating of 60 (these drawings were reviewed against GRITS and are all active with no open change documents that would affect the horsepower rating).
The One Line Diagram EE-1 AK (Rev. 29), PDDS, and calculations show a 40 horsepower rating. Either value (40 or 60 horsepower) exceeds the brake horsepower of the driven equipment, although the 40 horsepower value is marginal. The affected documents should be revised to reflect the actual horsepower rating.
This issue was addrer. sed in Disempancy Report DR-MP3-0317, however, additional vendor drawings and the one line diagram documents are included in this DR which are not included in DR-MP3-0317.
- 5. In Specification 2472.900-594 (Add.1, Rev.1), Dampers 3HVRWOD46A and 3HVRWOD468 require 563 inch-pounds of torque, but Vendor Drawing 2472.900-594-265D indicates that these dampers require 595 inch-pounds. The affected documents should be revised to reflect the damper's required torque.
- 6. Dampers 3HVRWOD140A and 3HVRWOD1408 are not shown in Calculation 210E (CCN 1, Rev. 0) and therefore the voltage for these dampers cannot be confirmed (the results are indeterminate). Also, the torque developed by the motors and required by these dampers is not shown in either Specification 2170.430-140 (Add.1, Rev. 2) or Vendor Drawings 2170.430-140-200A or 2170.430-140-2018. Therefore, the sizing of these dampers cannot be confirmed (the results are indeterminate).
- 7. Calculation SP-M3-EE-342 (Rev.1) states as an assumption that, "where B.H.P., efficiency, power factor and rated voltage values are not available from the project documentation" (Appendix B, Page B2), brake horsepower (BHP) is equal to the namepiste horsepower, efficiency is 0.92, and the power factor is 0.88 for 460V motors. However, for the following 460V motors, the project documentation is available for this data but was not used in the calculation.
3HVPTN1 A/B/C/D: BHP (rated) = 37.2; PF = 0.85; EFF = 0.90 3HVRTN6A/B: BHP (rated) = 53.5; PF :- 0.92; EFF = 0.90 i
3HVRTN12A/B: BHP (rated) = 47 or 75; PF = 0.90; EFF =
l 0.925 (the BHP for 3HVRTN12A and 3HVRTN128 is shown as 47 in the specification but 75 on Vendor Drawings 2144.430-141-002G and 2144.430-141-004E) 3HVRYf113A/B: BHP (rated) = 45.1; PF = 0.92; EFF = 0.90 3HVRTN14A/B: BHP (rated) = 39.9; PF = 0.90; EFF = 0.88 3HVR*ACU1A/B: BHP (rated) = 37.2: PF = 0.84: EFF = 0.90 Printed 3/12/98 3:34:37 PM Page 2 or 6
)
Northe:st Utilities ICAVP DR No. DR-MP3-0733 Millstone unit 3 Discrepancy Report where BHP = brake horsepower, PF = power factor, and EFF =
efficiency Shce the actual brake horsepower is less than that assumed in the calculation, the results of Calculation SP-M3-EE-342 are conservative. However, since the actual data is known, either it should be used or the staterr.ent from SP-M3-EE-342 should be revised.
Review Vaud invalid Needed Date inluator: Kondell, D. J.
8 O
O 2/iiio7 VT Leed: Nei, Anthony A B
O O
12tists7 VT Mgr: schopfer, Don K B
O O
12/23ts7 IRC Chmn: singh, Anand K 8
O O
$2/35/97 3
Dele:
INVAUD:
Date: 3/10/98 RESOLUTION. Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0733, has identified a condition in items 2,4 and 5 not previously y
discovered by NU which require correction.
For item 2 of the DR, the efficiencies used in calculations NL-033 and NL-025 do not match the values specified on vendor data sheets and actual values are used in NL-038, this is similar to item 1 in that unless actual test data is available, a conservative assumption is made for motor efficiency for different size ranges. PDDS will be reviewed for the motors identified to ensure that the information it contains agrees with the latest vendor supplied information. This item will be tracked to completion by CR M3-98-0246 post startup.
For item 4 of the DR, the horsepower rating for fans 3HVP*FN1 A/B/C/D does not agree between vendor drawings 2144.430-140-0110,2144.430-140-0109 and 2170.430-140-010J,40HP is the correct value and drawing 2170.430-140-010 will be revised accordingly. This item will be tracked to completion by CR M3-98-0246 post startup.
For item 5 of the DR, a disagreemer.t between specification 2472.900-594 and drawing 2472.900-594-265D on the required torque value for dampers 3HVR* MOD 46A/B, the effected documents will be revised to be consistent and show the correct manufacturer recommended value. This item will be tracked to completion by CR M3-98-0246 post startup.
NU has concluded that items 6 and 7 of Discrepancy Report, DR-MP3-0733, have identified conditions previously discovered by NU which require correction.
j For item 6 of the DR, dampers 3HVR* MOD 140A/B not shown in Printed 3t12/96 3:34:30 PM Page 3 or 6
Northe:st Utilities ICAVP DR N2. DR-MP3 4733 Millstone Unit 3 Discrepancy Report calculation 210E and the torque developed by the motors and required by the dampers not shown in specification 2170.430-140 or on vendor drawings 2170.430-140-200A or 2170.430-140-l 201B, this is a previously discovered item during the calculation assessment program associated with CR M3-97-0119 and LER 97-010. Calculation 210E has been superseded by calculation 97-ENG-01512-E3 which addresses damoers 3HVR* MOD 140A/B.
No further action is required.
For item 7 of the DR, calculational assumed values used for BHP, efficiency and power factor for various motors in SP-M3-EE-342 instead of the available actual values, this issue was previously identified for specific equipment in DR-MP3-0467 and was addressed generically with the corrective actions of CR M3-97-4061.
NU has concluded that items 1 and 3 of Discrepancy Report, DR-MP3-0733, do not represent discrepant conditions.
For item 1 of the DR, use of a 0.9 power factor for 3HVR*ACU1 A/B instead of the actual value, the methodology used in calculations is to allow for a conservative assumption (0.9pf) for mid size 460 volt motors. This is done to ensure uniformity. The specifications however carTy the exact figure from the manufacturer data sheet. This is not a discrepancy.
For item 3 of the DR, vendor supplied drawings showin0 a design brake horsepower different than that used in the historical purchase specification, the actual motor load is below the 75 BHP rating as shown on the attached certified performance curves. Therefore there will be no encroachment on the motor service factor and this does not represent a discrepant condition.
The only discrepant items are items 2,4 and 5 which are inconsistencies between documents and minor mathematical errors which do not prevent the equipment from meeting its licensing or design bases, therefore NU considers this DR to be Significance Level 4.
I Items 6 and 7 are prediscovered items which have either been corrected with the issuance of calculation 97-ENG-01512-E3 or addressed in the corrective actions of CR M3-97-4061 to be completed post startup. These items are Significance Level 4.
Items 1 and 3 are non discrepant items and Significance Level criteria do not apply.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MI'J-0733, has identified a condition not previously discovered by NU which require correction. The discrepant items identified 2,4 and 5 of l
the DR require correction. The approved corrective action plan for CR M3-98-0246 will correct PDDS data, correct the horsepower ratina on vendor drawina 2170.430-140-010 for Prtnted 3/12/96 3:34 40 PM Pa0e 4of 6
Northerst Utilities ICAVP DR N2. DR-MP3-0733 Millstone Unit 3 Discrepancy Report 3HVP*FN1 A/B/C/D and add the correct torque values for dampers 3HVR* MOD 46A/B to the active design documents.
Items 6 and 7 have been identified previously and addressed via the Corrective Action Program. Items 1and 3 are not considered j
valid.
The only discrepant items are items 2,4 and 5 which are inconsister.cies between documents and minor mathematical errors which do not prevent the equipment from reseting its licensing or design bases, therefore NU considers this DR to be Significance Level 4.
Items 6 and 7 are prediscovered items which have either been i
corrected with the issuance of calculation 97-ENG-01512-E3 or addressed in the corrective actions of CR M3-97-4061 to be completed post startup. These items are Significance Level 4.
j ltems 1 and 3 are non discrepant items and Significance Level criteria do not apply.
Previously identifled by Nu? O vee (e) No Non F---, " Condition?O vee (G) No ResolutionPending70 vos @ No Resonationunresoeved?O vee Ce)No Review Initiator: Kendell, D. J.
VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date:
3/5/98 sL Comments: ltem 1 - Since Calculations NL-025 and NL-038 use the word
" assume" when listing the power factor as 0.9, it is acceptable that the actual value was not used, as these motors are small and the impact is insignificant on auxiliary power loading. Sargent &
Lundy disagrees with NU's comment that the use of a 0.9 power factor is conservative, because this assumed power factor results in a KVA = (50*0.748)/(0.9*0.9) = 46 KVA which is less conservative than the KVA of (50*0.746)/(0.9*0.839) = 49 KVA if the actual power fac*.or was used.
Item 3 - Based on the performance curves which NU provided with their response to this DR, the discrepancy is a documentation issue and not a hardware issue and is changed to a Level 4 discrepancy. SarDent & Lundy disagrees with NU's statement that this is not a discrepant condition because the 3/5/98 run of GRITS still shows Specification 2176.430-141 as
" APP" (approved) and Vendor Drawings 2170.430-141-002 and 2170.430-141-004 as "ASB" (as-built), therefore, they are not historical documents but are active, according to GRITS.
Item 6 - NU states that this item was identified previously, however, Calculation 97-ENG-01512E3 was prepared on 11/13/97 which is after the 6/19/97 cutoff date and therefore is l
still a discrepancy. Sargent & Lundy's review of Calculation 97-ENG-01512E3 concludes that this issue has been adequately l
resolved and it has been changed to a Level 4 discrepancy.
Printed 3/1298 3:34:41 PM Page 5 of 6
Jrthe:st Utilities ICAVP DR N2. DR-MP3-0733 milistone Unit 3 Discrepancy Report item 7 - As noted by NU, this item is resolved by CR M3-97-4061 (DCN DM3-00-1769-97) which was issued in response to Discrepancy Report DR-MP3-97-0467 to 9enerically address data used in SP-M3-EE-342 for motor control center fed motors.
Since this CR was written in November 1997 and was after the 6/19/97 cutoff date, this is still a discrepancy.
Items 2,4 and 5 - NU has concluded that these items are discrepancies and will be tracked by CR M3-98-0246.
i i
l l
Printed 3/12/98 3:M:43 PM Page 6 of 6
Northerst Utilitie3 ICAVP DR N2. DR-MP3-0845 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED l
Review Element: System Design p
l Discipline: Structural Design Ow l
Discrepency Type: Calculation g
System / Process: HVX NRC Significance level: 4 Date faxed to NU:
l Date Putnished: 1/10/98 j
D6screpency: Duct Support Calculation Discrepancy
==
Description:==
We have reviewed the following duct support calculations:
(1) CALC. # 12179-NP(T)-Z507A-017, REV.3 (2) CALC. # 12179-NP(F)-Z545J-1036, REV.3 (3) CALC.# 12179-NP(F)-Z545D-479, REV. 4 (4) CALC. # 12179-NP(F)-Z545J-1252 REV.2 (5) CALC. # 12179-NP(F).Z507A-018, REV. 2 (6) CALC. # 12179-NP(F)-Z545J-1220, REV. 0 (7) CALC. # 12179-NP(F)-Z545J-1304, REV. 2 (8) CALC. # 12179-NP(F)-Z545J-1306, REV. 3 (9) CALC. # 12179-NP(T)-Z545B-245, REV. O Based on this review we have noted the following drafting &
mathematical errors:
(1) CALC. # 12179-NP(T)-Z507A-017, REV.3 PAGE # 6, GLOBAL AXES ARE INCORRECT.
PAGE # 11, AXIAL COMP. & BENDING INTERACTION SHOULD BE 0.54 ( NOT 0.88 )
PAGE # 13, WELD CHECK JT. # IS NOT MENTIONED.
(2) CALC. # 12179-NP(F)-Z545J-1036, REV. 3 PAGE # 8, FZ LOAD SHOULD BE 896 lbs (NOT 866 lbs).
(3) CALC. # 12179-NP(F)-Z545D-479, REV. 4 PAGE # 33 BASE PLATE BOLT LOCATION SHOULD BE 12.25,21.125 (NOT 13.281,12.125)
(4) CALC. # 12179-NP(F)-Z545J-1252 REV.2 PAGE # 13, FOR WELD CHECK "J/CO" SHOULO BE 13.73 (NOT 7.62).
(5) CALC. # 12179-NP(F)-Z507A-018, REV. 2 PAGE # 5, LOCATION PLAN NORTH DIRECTION IS NOT SHOWN.
PAGE # 6, GLOBAL AXES ARE INCORRECT Fort SECTION 1 1.
ALSO,SECTION 2-2 IS INCORRECT.
(6) CALC. # 12179-NP(F)-Z545J-1220 REV. O l
PAGE # 3, E & DCR # NOT REFERENCED.
PAGE # 10, REFERENCE IS NOT GIVEN FOR LOADS.
Printed 212/96 3:35;30 PM Page 1 of 2
Northert Utilitie3 ICAVP DR N2. DR-MP3-0845 Millstone Unit 3 Discrepancy Report (7) CALC. # 12179-NP(F)-Z545J-1304, REV. 2 PAGE # 5, LOCATION PLAN NORTH DIRECTION & SECTION l
1-1 TITLE IS NOT SHOWN.
l PAGE # 6, SECTION 3-3 TITLE IS NOT SHOWN.
(8) CALC. # 12179-NP(F)-Z545J-1306, REV. 3 l
PAGE # 18, J/C1 SHOULD BE J/C3.
(9) CALC. # 12179-NP(T)-Z545B-245, S.iV. O PAGE # 6, SHEAR STRESS FORMULA AS SHOWN IS INCORRECT.
Review Vend inveNd Needed Date initiator: Kleic, N O
O O
12isa/97 VT Lead: Nwl, Aleony A B
D 0
12/sse87 VT Mgr: schopfer, Don K B
O O
12/23/97 1RC Chmn: sinsh, Anand K B
O O
$2/31/87 Date:
INVAUD:
Date:
3/5/98 RESOLUTION NU has concluded that Discrepancy Report, DR MP3-0845, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the UL't 3 deferrsi criteria. CR M3-98-0967 has been written to develop and track resolution of this item per RP-4.
Previously identined by NU? O Yes (@) No Non Discrepent Condition?O Yes @) No ResolutionPending?O va @ No RedutionUnrudved?O va @ No Review initiator. Kleic, N VT Lead: Nort, Anthnny A 0
0 IS V' "'" S h P'"-
"k IRC Chmn: Singh, Anand K O
O Date:
SL Comments:
Printed 3/12/88 3:35 43 PM Page 2 of 2
. Northe:st Utilitie3 ICAVP DR N3. DR-MP3 0853 Millstone Unit 3 Discrepancy Report Review Group: Syelem DR RESOLUTION ACCEPTED Review Element: Hodification Design Disciplinr Mechanical Design O vos Discrepency Type: InmaammeM Implementation g
SystemrProcess: SWP NRC Significance level: NA Date faxed to NU:
Date Published: 1/22/96 Discrepency: PDCE 3-87101 Implementation and Test Requirements Discrepancies
==
Description:==
PDCE 3 101, which involved the replacement of an original field-welded joint with a flanged joint to facilitate maintenance, was reviewed and the following discrepancies noted.
- 1. Work order AWO M3-87-17097 was referenced in the PDCE as the implementing document for the work. This work order was reviewed in PMMS and found to indicate that it was to control the " cutting of the SW pipe" but made no reference to controlled procedures for either cutting or welding to the [ safety-related] service water pipe.
- 2. Neither the PDCE nor the above-referenced work order contained reference to hydrotest or leak test requirements to be perfctmed before retuming the system to service following completion of the modification.
i Review Valid invalid Needed Date initiator: Tonwinkel.J.L 8
0 O
12/22rs7 VT Lead: Nerl. Anthony A B
O O
12iiars7 VT Mgr: Schopfer, Don K 8
O O
52/23ro7 IRC Chmn: Singh. Anand K 8
O O
17/se Date:
INVALID:
Date: 3/11/96 RESOLUTION Disposition:
NU has concluded that the issue reported in DR-MP3-0853 does not represent a discrepant condition.
The original PMMS work order, M3-87-17097, was written for cutting the pipe and installing the flanges as directed by PDCR 3-87-101. There are no cutting procedures, however, in accordance with AWG M3-87-17097, the ASME Section X!
Repair / Replacement Pier:, item 5 states, " Install flanges per BPS-401 and weld history card instructions. QC verifications shall be documented on SF-221." This is the welding instructions needed to perixm the work.
In accordance with AWO M3-87-17097, the ASME Section XI Repair / Replacement Plan, item 5, states, " Install flanges per BPS-401 and weld history card instructions. QC verifications shall be documented x SF-221." This is the welding instructions needed to perform the work. Cutting procedures are Printed 3r12/96 3:36:13 PM Pegw 1 or 2
N:rthenst Utilities ICAVP DR N2. DR-MP3-0853 i
Millstone Unit 3 Discrepancy Report not required. In some cases, unless the cut was made at an existing weld (as was the case here) a new weld number would be assigned in accordance with the design change program in order to enable the issuance of a weld card. Although the DR was not specific, other issues as a result of the cutting process would be addressed by the Millstone Work Control Procedures (WC Procedures). The WC procedures would address such issues as chemical classifications /oxclusions, foreign material concems and cleanliness rewireinents. These procedures are automatically invoked during the work order developmenet for any field work.
Throu0h a review of AWO M3-87-17097 and the requirements of PDCR 3-87-101, it was confirmed that the necessary welding methods and retesting requirements were addressed.
Significance Level criteria do not apply here as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that the issue reported in DR-MP3-0853 does not represent a discrepant condition.
Through the review of the attachments to AWO M3-87-17097, the section titled, ASME Section XI Repair / Replacement Plan, Jtem 5, indicates the required welding procedure, BPS-401. In the same section, item 41, this indicates the leak testing requirements including acceptance criteria. Therefore, NU concludes that the necessary welding methods and retesting requirements were address.
No corrective action is required, therefore, this is not a discrepant condition and significance Level criteria do not apply.
Previously idenH6ed by Nu? O vee @ No Non Discrepent Condition?@ Yes Q No Rooiuiwnp.ndina?O va @ No RemnuHonUnrn*ed?O va @ No Review A--
Not A- -- ~"
Needed Date TNA L VT Lead: Neri, Anthony A O
O O
3/isine IRC Chmn: singh. Anand K O
O O
Date:
3/11/98 sL Comments: S&L agrees that the documentation referenced by NU in the above disposition, and provided with the disposition package, adequately addresses the issues raised by the DR, and no further corrective action is required.
Printed 3/12/9e 3:36.16 PM Page 2 of 2
Northe st Utilities ICAVP DR NA DR-MP3-0868 Millstone unit 3 Discrepancy Report Review Group: system DR REsOLAJTioN ACCEPTED PotentialOperoidilty leeue O yes Discrepancy Type: Licensing Document g
systemfProcese: HVX NRC "',-7 m level: 4 Date faxed to NU:
Date Putdished.1/10/98 Discrepancy: Potential inconsistency between licensing documents and EOP Description' In the event of a fire in the control room, instrument rack room or cable spreading room, power must be removed from Dampers 3HPPMOD23A,20A,20C and 26A to cause the dampers to fall open to ensure ventilation to the orange emergency diesel generator enclosure. Procedure EOP 3503 deenergizes Circuit 6 in Panel 3SCPPNL250 located in the diesel generator enclosure. However, NERM 64, Rev. 2, calls for removing power to these dampers by opening the supply breaker at Panel SCPPNLR10 and FPER Section 7.2 states that power to the dampers is removed by removing the control fuses in the emergency switchgear room.
Review vend inveNd Needed Date insuster: Leuni. C. M.
B 0
O 52/1e/97 VT Lead: Nwi, Anthony A B
O O
$2/20e7 VT Mgr: schopfer, Don K B
O O
$2/23ro7 IRC Chmn: singh, Anand K B
O O
2/st/s7 Date:
INVALID:
Date: 3/11/98 REsOLUTIO' position:
I has concluded that Discrepancy Report, DR-MP3-0858, has suentified a condition not previously discovered by NU which requires correction. Procedure EOP 3503, " SHUTDOWN OUTSIDE CONTRL ROOM," and Fire Protection Evaluation Report (FPER) Section 7.2, " EMERGENCY DIESEL GENERATOR," differ in the methods used to de-energize control power dampers 3HVP* MOD 23A,20A,20C and 26A. These dampers are repositioned in the event of a main control room, instrument rack or cable spreading room disabling fire. EOP 3503 directs opening Circuit 6 in Panel 3SCV*PNL250 to fail the dampers to the correct position. FPER Section 7.2 directs removing control fuses located within the respective emergency switchgear room to reposition dampers.. The Discrepancy Report identifies dampers 3HVP* MOD 23A,20A,20C and 26A as failing open on loss of power whereas 3HVP* MOD 26A fails closed and 3HVPWOD23A,20A and 200 fails open on loss of power. The informa'io.1 presented in the EOP is correct and consistent with plant design. The approved corrective ac' ion plan for Con *n Report, M3 98-0337, will revise FPER Section 7.2 to revise prescribed method of de-energizing the damper control pown The FPER intended to identify actions necessary to support a shutdown from outside the main control room. The goal is to de-Printed 3ft2/Be 3.36A3 PM PeGe 1 or 3
l N:rthent Utilities ICAVP DR No. DR-MP3-0868 miisstone unit 3 Discrepancy Report energize the damper circuit causing the to reposition. The FPER incorrectly identifies the method as pulling fuses when opening a circuit breaker is the correct method. While the detail in the FPER needs to be corrected, the intent of de-energizing the damper circuit is the same and even with this error, the operators would not have been confused as the EOP is the document they utilize which provides the correct method. The change to the FPER is considered an enhancement since the EOP and BTP 9.5-1 are correct. This will be completed post startup.
Therefore, NU considers this a Significance Level "4" discrepancy.
The differences between EOP 3503 and NERM 64, rev 2, has been evaluated and NU has concluded that a discrepant condition does not exist. NERM 64, rev 2, was last updated in 1985 and is no longer a working document. NERM 64 has been i
supersceded by BTP 9.5-1 tev 1," Compliance Report." BTP 9.5-1 page 32 and 3.1-51 describes de-energizing damper control power by opening Circuit 6 in Panel 3SCV*PNL250 to fall the dampers to the correct position. This method is consistent with the requirements of EOP 3503 and plant design drawings. T his is not a discrepent condition. Significanes Level criteria do not l
apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-PP3-0858, has identified a condition not previously discovered by NU which requires correction. Emergency Operating Procedure, EOP 3503, and FPER Section 7.2 describe different methods of de-energizing control power to reposition emergency diesel; generator enclosure ventilation dampers. The approved corrective action plan for Condition Report, M3-98-0337, will revise FPER Section 7.2 to revise the method of repositioning the ventilation dampers. Completion of this corrective action will be deferred until after startup based on activity being a clarification to the FPER. NU believes that this is a significance level"4" discrepancy.
The EOP is consistent with current plant design. fJERM 64 is a historical document which does not get updated. it has been i
supersceded by BTP 9.5-1 rev 1 which describes the proper j
method for de-energizing the EDG enclosure ventilation 1
dampers. This is consistent with EOP 3503 and current plant j
design. Therefore, NU considers this a Significance Level"4" I
discrepancy.
1
.../ P;identined try Nu? O Yes @ Ne Non Discrepent Condition?O vos @ No j
p% r.amnetO vos @ No neemtionunroemed70 vos @ No ne*w i
inewor: Launi.c.u.
"' P
"'***d
"=
O O
O 3ris/96 ad Nwl, Anthony A B
O O
3/u/88 MF: Schapter, Don K g
g o
a c connn: sine. Anand K n
O O
O the=*
't/11 JtWt Printed 3/12/96 3:36:47 PM Pepe 2 or 3
Northeast Utilitieo ICAVP DR Ns. DR-MP3-0868 Millstone Unit 3 Discrepancy Report sL comments: The response is acceptable. The recommended corrective action
)
is to revise FPER Section 7.2 after startup. This is acceptable since EOP 3503 is correct. S&L agrees that the discrepant condition is Significance Level 4.
No discrepant condition exists conceming NERM 64, Rev. 2 since NU confirmed that this report ht n een w>ersceded by BTP 9.5-1 Rev.1," Compliance Report."
1 I
Printed 3/12Mie 3:36A6 PM Page 3 of 3
Northemt Utilities ICAVP DR N3. DR-MP3-0870 miliStone unit 3 Discrepancy Report Review Group: Syelem DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: Structural Design O va Discrepency Type: C*W g
System /Procese: HVX NRC s',J ---w level: 4 Date faxed to NU:
Date Putmehed.1/17/96 Discrepency: Duct Support Discrepancy
==
Description:==
We have reviewed the duct support calculation no.12179-NP(T)Z-545G-874,Rev.0, dated 10/18/82, which is a main frame calculation.
Based on this review we have noted the following discrepancy.
Loads from the small bore support No. CB647707 - H001 (BZ-747R) attached to the main frame have not been accounted for in the analysis.
Review Vend invalid Needed Dde initiator: IGeic, N O
O O
12tzase7 VT Leed: Neri, Anthony A B
O O
12rio/s7 VT Mgr: Schopfer, Don K 12f?3/s7 IRC Chmn: Singh, Anand K 0
1^ 3'S8 x
Date:
INVALID:
Date:
3/5/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0870, has identified a condition not previously discovered by NU whict requires correction. This discrepancy meets the criteria spec fled
)
in NRC letter B16901 and 17010. It has been screened per L 3 PI-l 20 criteria and found to have no operability or reportability concems and maets the Unit 3 deferral criteria. CR M3-98-Ob67 has been written to develop and track resolution of this item l er RP-4, Previously identined try NU7 Q Yes (8) No NonDiscrepen; Condition?O Yes (9) %
RaciWlon Poneng?O vos @ No Re-iunonunramved70 va Review initiator: Kleic, N
~~
VT Leed: Neri, Anthony A B
D 0
stiin IRC Chmn: Singh, Anand K O
O Date; SL Commente:
Printed 3/12/s0 3:37;17 PM Page 1 of I
Northe:st Utilities ICAVP DR N. DR-MP3-0872 Mmstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: Structural Design Om Descrepency Type: C*W g
SystemProcess: HVX NRC Signincence twel: 4 Date faxed to NU:
Date Putdished. iii7/96 rei. mi: Dud Support Calculation Discrepancy Description. We have reviewed the duct support calculation no.12179-NP(F)Z545J-1323,Rev.3, dated 2/5/85.
Based on this review we have noted the following discrel,ancy.
On page no.15 & 16 of this calc, Splice Plate analysis is based on the four bolt pattem in lieu of checking the actual three bolt configuration.
Review Vend invalid Needed Lt.td initiator: IGeic, N O
O O
12r22/97 VT Lead: Nerl, Anthony A B
O O
2r20s7 VT Mor: schapser, Don K B
O O
$2r2as7 NtC Chmn: Singh, Anand K E
O O
iisse Date:
INVALID:
Date:
3/5/98 RESOLUTION NU has concluded that Discrepancy Report, DR-MP3-0872, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or repostability concems and meets the Unit 3 deferral criteria. CR M3-98-0967 has been written to develop and track resolution of this item per RP-4.
Previously identified by NU7 U Yes @ No Non re- :;:1 Condition?O Yes @ ido R=oeuuon P.nane70 va @ No R=ammonunr=wved70 va @ No Review areafdh Not Aeear8h Needed Date VT Leeri: Nort, Anthony A y
O O
O aris/se IRC Chmn: Singh, Anand K O
O O
Date:
3/5/98 st Conenente:
Prtnted 3/12/96 3:30:53 PM Pope 1 of 1
NortheM Utilities ICAVP DR No. DR-MP3-0894 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design DiscipEne: Mechanical Desig" Om O'
. zi Type: Ucensing Document g
systenWProcese: DGX NRC signiacance level: NA Date faxed to NU:
Date Putdished.1/17/96 E'
. 4 EDG Fuel Oil Filters Seismic Enclosure Licensing Requirement Deecription. NRC Letter No.A05543 dated 1-17-1986, required Millstone -3 to install a seismically supported protective housing and drain piping around the EDG Fuel Oil Filters. A review of P&lD EM-117A and the EDG modifications, shows no design documents indicating that this requirement was incorporated into the design basis, or installed in the plant.
Reference REQ-MP3-DGX-0729 Review Vend invalid Needed Date initiator: Homeetmen. R.
2 O
O 2t22/o7 VT Lead: Nort. Anthony A B
O O
12/2ae7 VT Mer: Schophr, Don K B
O O
12/23 7 1Rc Chan: Singh, Anand K O
O O
itsee Date:
INVAI.lD:
Date:
3/3/98 REsOLUTloN. Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0894, does not represent a discrepant condition. Piping and instrumentation Diagram (P&lD) EM-117A would not reflect modifications of this type to the EDG. However, a search against the Fuel Oil Filters identification Mark Numbers in PDDS indicates they are on the Manufacture's Drawing series under 2447.300-241. A search in the Generation Records Information Tracking System (GRITS) against these drawings reveals E&DCR's T-P-07513 and T-P-07134 (attached) both of which reference and resolve DDR-550 (attached). This DDR described the potential problem caused by a fuel oil filter outlet line failure and the need for a protective splash guard and drain line for the Fuel Oil Filters. The disposition to item 4 of this DDR noted that this was an unresolved NRC ltem. These two E&DCR's detailed and installed an Enclosure around the EDG Fuel Oil Filters on both Diesels and were incorporated onto the applicable design drawings (EB-78, attached) and appropriately posted aga!nst drawing 2447.300 241.
Further, a search by Licensing against the date mentioned in DR-MP3-0894 revealed a response by the NRC, Docket No. 50-423, dated Jan.17,1986 that, on Page 6 indicates an item for the "EDG Fuel Oil Filter Located in an Area Which Could Be a Fire Hazard" was " Closed". The References given on Pg. 6 of Docket No. 50-423 for this item are E&DCR's T-P-07134. T-P.
Printed 3<12/98 3:41:35 PM Page 1 of 2 y
N:rthe=t Utilities.
ICAVP DR Nr. DR-MP3 0894 milistone Unit 3 Discrepancy Report 07513 and DDR-550 which corresponds to the search done above. The later discussion indicates : "The Licensee has twsponded by installing a protective housing around the filters.
The housing is sealed and drained. Housing and drain piping are seismically supported. The inspector has no further questions on this item." The System Engineer also confirms that the Protective Housings as detailed on the E&DCR's are installed.Therefore, the seismically supported housings are installed and posted against the applicable documents.
Significance Level criteria do not apply here as this is not a discrepent condition.
==
Conclusion:==
NU has concluded that the issue reported in Dbcrepancy Report, DR-MP3-0894, does not represent a discrepant condition.
E&DCR's T-P-07513 and T-P-07134 detailed an Enclosure around the EDG Fuel Oil Filters on both Diesels and were incorporated onto the applicable design drawings or appropriately posted against the applicable drawings.
i The NRC reviewed this installation and in their inspection report 50-423/85-69, which was attached to their letter of January 17, 1986, reported as follows: "The licensee has responded to the Unresolved item by installing the additional filter on both Emergency Diesel Generators. Both of the filters for each unit are mounted off-skid on independent foundations. The installations are complete and one of the EDGs has been retested with the (flushed) modified system.
Significance Level criteria do not apply here as this is not a discrepent condition.
Previoussy idenoned by Nu? O Yes @ No NonDiscrepentconmuon?@ Yss U No
- + PenenetO Y=
@m p % unt===dtO Y=
@' No
- n. view accardaMa Not "- - ^'
Needed Date VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K unc chmn: Singh, Anand K oste:
3/3/98 SL commente Based on information submitted by NU with the disposition in the Response MS-lRF-01430, S&L agrees tha* the issue reported in the DR-MP3-0894 is not a discrepant condition.
i I
Printed 3/12/98 3:41:30 PM PeGe 2 or 2
Northe:st Utilities ICAVP DR No. DR-MP3-0897 Millstone Unit 3 Discrepancy Report RevRw Group: System DR RESOLUTION ACCEPTED Rasw'!.tsment: System Design Potential Operability lasue thciplinei MechaniJ Design O Yes Discrgmc51 TYPE: DriwinD 9 No sggyd;5mprJGX NRC Signis*4.4evtt 4 Date faxed to NU:
Date Published 1/17/98 D6screpancy: The P&lD ReviEfor the EGO subsystem of the Diesel Generators yielded discrepancies.
==
Description:==
The following EGO components listed in the PDDS system were not included on P&lD EM-116A or EM-116C:
3 EGO *LS26C 3 EGO *LS26D.
The following EGO components listed in the PMMS system were not included on P&lD EM-116A or EM-116C:
3 EGO *PSA SEGO*PSB The following components listed in PDDS with the 3 EGO prefix should be designated with a 3EGS prefix:
l 3 EGO *V23A SEGO*V23B 3 EGO *V24A 3 EGO *V24B The following EGO components were identified twice in the PDDS system. Once as safety related, the other as non-safety relataxt:
3 EGO *STR3A & 3 EGO-STR3A 3 EGO *STR3B & 3 EGO-STR3B 3 EGO *STR4A & 3 EGO-STR4A SEGO*STR4B & 3 EGO-STR4B 3 EGO *TS30A & 3 EGO-TS30A SEGO*TS30B & 3 EGO-TS30B The following EGO component was listed in PDDS, however not located on P&lD EM-116C:
3 EGO *V9968 The following EGO component was shown on P&lD EM-116C, however not listed in PDDS:
3 EGO *V9958 The following EGO components were included on the P&lD's, however, were not found in the PDDS/PMMS system:
3 EGO-Pl42A M:nn. pia?R Printed 3/12/96 3.42:27 PM Page 1 of 3
-l I
Northert Utilities ICAVP DR No. DR-MP3-0897 Millstone Unit 3 Discrepancy Report 3 EGO 1S40A 3EGOtS40B The safety class tresk should be on the other side of valves 3 EGO *V19A/B.
Review VaM Invalid Needed Date initiator: Hameetman, R.
Q Q
12/23/97 VT Lead: Nwl, Anthony A O
O O
12/23/97 I
VT Mor: Schopfer, Don K Q
Q 1/12/98 Ntc Chmn: singh, Anand K O
O O
$/13/SS Date:
INVALID:
Date:
3/3/98 RESOLUTION Disposition:
NU has concluded that Discrepancy Report, DR MP3-0897, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0495 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0897, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0495 has been written to develop and track resolution of this item per RP-4.
Previously :.%ntified by NU7 O Yes @ No Non Discrepent Condition' 0 Yes (9) No 7
Re.aunon P.adias70 va @ No Re.duuon unr.asv.d70 va @ No Review a-- 5"":
Not Acceptable Needed Date VT Lead: Nerl, Anthony A y
VT Mor: Schopfer, Don K O
mm IRC Chmn: singh, Anand K O
O O
Date:
3/3/98 st Comments: NU disposition is acceptable.
S&L agrees with the NU Response M3-IRF-01709 that the identified discrepancies meet the deferral criteria, and the required corrective action can be determined after startup. The Response package includes a DR Review Screen for DR-MP3-0897 which seems to indicate that item 7 of the discrepancy is "OK as is", and that item 8 is "not a discrepancy". S&L disagrees with both statements.
Printed 3/1248 3A2:31 PM Page 2 of 3 i
N:rthert litilities ICAVP DR No. DR-MP3-0897 Millstone Unit 3 Discrepancy Report
% 3/12S6 3.42:33 PM Page 3 or 3
Northe:st Utilities ICAVP DR N3. DR-MP3-0911 Ministone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Diecipline: Mechanical Design Om Discrepancy Type: Corrective Action g
SystwWProcese: N/A NRC SignificaKee levet: NA Date faxed to NU:
Date Putdiohed: 1/22/96 D6screpency: Insufficient Information for Delay of Evaluations
==
Description:==
UIR 2455, dealing with the replacement of a section of Service Water piping, and UIR 2545, dealing with an unqualified worker performing maintenance on an emergency diesel generator, are scheduled to be resolved after ctart-up of Unit 3.
There is insufficient information presented in the UIRs to determine whether the delay of these evaluations is justified.
- 1. PDCE MP-90-137 contains no retest requirements for the Service Water piping and states " leak testing is not possible due i
to piping configuration and need to keep pipe vented". iWA-5214 of ASME Section XI requires a hydrostatic test after replacing 3" safety-related piping. Case N-416-1 allows a pressure test to be substituted provided a VT-2 visual examination is performed prior to or immediately upon retum to service. Has the structuralintegrity of the piping been maintained per Technical Specification 3.4.10.c?
- 2. UIR 2545 does not describe the particular equipment the unqualified worker maintained nor does it describe how l
unqualified the worker was. What mitigating circumstances allow delaying the resolution of this problem until after start-up?
Review vesid invand Needed Date initletor: shepperd. R. P.
O O
O 12/23/97 VT Leed: Ryan, Thomas J B
O O
2/24s7 VT Mor: schopfer, Don K O
O O
1/12/96 1
1RC Chmn: Singh, Anand K O
O O
5'17/S8 Date:
INVALID:
Date: 3/10/98 RESOLUTION Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0911, does not represent a discrepant condition.
1.
UIR 2455 - The UlR was voided, and therefore requires no further action or evaluation. The UiR Number was issued electronically but limited information entered. An excerpt from an Expert subcommittee letter (MP3-DE-97-0970) identifies the reasons why UlRs were voided during the origination process.
The UIR incorrectly stated that a section of 3" diameter Service Water pipe was replaced, in accordance with PDCE M3-90-137, as a result of Erosion / Corrosion damage. Review of PDCE MP3-Printed 3/12/06 3M02 PM Page 1 of 3
Northe:st Utilities ICAVP DR No. DR-MP3-0911 Millstone Unit 3 Discrepancy Report 90-137 and DCN DM3-P-112-90 identifies the replacement of piping section 3SWP-750-402-3 to be limited to a 3/4" diameter line. ASME IWA-5214 (Repairs and Replacement) (a) refers to IWA-4400 (Pressure Test). lWA-4400 provides a list of exceptions to the hydrostatic testing requirement. Item (5),
" Component connections, piping. and associated valves that are 1 in. nominal pipe size and smaller," exempts this repair from hydrostatic testing requirements since the line is 3/4 in. Work Order, M3-89-20733, documents the repair activity and subsequent post maintenance testing. Upon retuming the system to service, the welds were verified to be leak free at system pressure.
2.
UIR 2545 - The UIR was voided, and therefore requires no further action or evaluation. The UlR Number was issued electronically but limited information entered. An excerpt from an Expert Panel subcommittee letter (MP3-DE-97-0970) identifies the reasons why UIRs were voided. durin0 the origination process. The issue of an unqualified worker performing tasks under AWO M3-96-09036, was voided after realizing that the workers were in fact qualified to perform emergency diesel generator tasks. The lead worker of the team was in fact qualified 4/13/95 well before the work was performed.
UlRs which do not have information filled out and were not approved by a supervisor are not valid UIRs. Therefore, review of these UIRs is unnecessary since they do not represent real discrepancies nor were they actually issued.
Significance Level Criteria do not apply here as they are not discrepant conditioqs.
==
Conclusion:==
j NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0911, does not represent a discrepant condition.
UIRs which were never issued officia!!y require no action as they are not valid UIRs. Based on Expert Panel review of the UIRs identified in this Discrepancy Report, the issues have been property voided in accordance with PI-20 " Unit 3 Startup item Administrative Instruction." issues that were voided contained limited information and the issue was found to be without technical merit. Therefore NU does not consider this to be a discrepent condition.
Significance Level Criteria do not apply as these are not discrepant conditions.
Prevksdy Menuned by NU7 O vos @ No NonDiecrepentCondluon?@ ves O No n.emuon Pending?O va @ No nes*nonunr d70 vos @ No Review A-:-: /
Not "O,"
Needed Date p
VT Lead: Ryan, Thomas J W Mgr: Schopfw, Don K Printed 3/12'96 3.43:05 PM Page 2 of 3
Ntrthea:t Utilities ICAVP DR N3. DR-MP3-0911 Milistone Unit 3 Discrepancy Report 8
O O
3'$ a RC Chmn: Singh. Anand K Date:
SL Comments:
l 1
i Page 3 v 3 Printed 3/12/96 3M07 PM
l Northe:st Utilities ICAVP DR Nc. DR-MP3-0926 Millstone Unit 3 Discrepancy Report Review Group: Conrgurshon DR RESOLUTION ACCEPTED Review Element: System Installabon p
g D6scipline: Elechical Design O v=
Discrepancy Type: Installation imp 6ementahon
@ No systemerocess: HVX NRC Significance level: 3 Date Faxed to NU:
Date Published: 1/18/98 Discrepancy: Electrical Installation not in accordance with Derign Documents
==
Description:==
The following deviations from installation standards and design q
documents were observed during system walkdowns.
- 1. Electrical Installation Specification E350 requires that ground conductors be routed along with flexible conduits when terminating to equipment and that raceways be bonded via a Ground conductor. Furtherwhen terminated at l
equipment / instruments, there should be 3-inches of slack in the ground wire. Contrary to these requirements the following items were observed during system walkdowns: Flex conduits to 3HVR* MOD 49C1 and C2 do not have the required 3-inches of j
slack.,
- 2. Electrical Installation Specification E350, Rev. 9 section 3.1.3.9 limits the length of flexible conduit to equipment to 6 feet. Installed flexible conduit 9CC2070A3 was observe to be longer than six feet.
- 3. Electrical installation Specification E350 indicates that all equipment should be grounded. Contrary to this requirement, panel grounds were not observed for 125 Vdc distribution Panel 3BYS-PNL34F and 125 Vac distribution panel 3VBA*PNL-VB1.
- 4. Drawing EE-11 A, Rev.13, shows a neutral bus within 125 Vac distribution panel 3VBA*PNL-VB1. There is no neutral bus installed.
- 5. Drawing EE-9ES Rev.11 does not reflect actual field conditions. Cable from MCC181 Compartment 2C to Compartment 1D terminates at a Terminal strip in compartment 1D and then is extended to second ACB for pump 3EGF*P1D,
- 6. The actual installed fuses installed in 125 Vdc panel 38YS*PNLDG2F can not be verified without removal. However, markings on the fuse holders / blocks 1 and 2 are not in agreements with the ratings shown on drawing EE-100 Rev. 6,
- 7. Contrary to the separation requirements of Specification E076 for safety and non-safety related wiring within panels of a minimum of 6 inches, non-safety cabling / wiring from 3HVR-FE10 is within inches of safety related wiring inside Panel 3HVR*RlY10A
- 8. Specification E-076 provides separation requirements for safety and non-safety related cabling within panels. This specification does not permit the bundling together of safety re!:'ed and non cefe'y re!:' d de/c Mc. Cc2crj tc thy a ymy pg
Northe:st Utilitica ICAVP DR No. DR-MP3-0926 Millstone Unit 3 Discrepancy Report safety related and non-safety related wiring within panel 3CES*lPNLCB1P is bundled (ty-wrapped) together.
- 9. In the area near support A336-016, one orange cable has been pulled beyond the confines of the tray 3TC1350 as it makes a slight tum to the south (E-W run).
- 10. Conduit 3CK1060H is wrapped with Sil-temp for approximately 8 feet of its run. The reason for this wrapping and the desiQn document providing for such, could not be located.
Typically for separation purposes, the non-safety related cables with in a foot would need to be wrapped not a conduit which, as such, already is provided with a barrier. (Reference location 51.3 - F.3; elevation 24'-6")
- 11. Penetration opening for cable tray 3TC163N is not sealed.
Seal appears to have degraded. (Reference location St.3 - F.3 el. 34'-6")
- 12. Per drawing EE-34Y Rev. 9 and TSO2, tray 3TL2030 is a mark number (commodity type) DAK-01 indicating that the tray is 30 inches wide. The installed tray was observed to be 24 inches wide.
- 13. There are two tray section installed in the fle!d which carry the same identificatien. These two risers are separated by a significant distance and require additional raceway to connect them to provide for routing of cables. The tray Identity is 3TK2080. The first of the two trays is shown on drawing EE-l 34Z, Rev.11; the second is a riserlocated at the end of trays 3TK2040/3TC2060 Several rays and conduits of C and K services levels connect to these trays and it is not clear that service level separation is maintained as required by the Cable and Raceway Control Program manual on pa0e 20. The Program manual also indicates that unique identification should be used for individual raceways.
- 14. Specification E-076 requires separation be maintained between safety and non-safety related raceways. For covered trays, this minimum spacing can be as little as an inch. Contrary to this requirement, the tray cover on tray 3TL102P was found to be in direct contact with tray 3TJ102N.
The following material conditions were noted during the system walkdowns. These are not configuration management issues.
- 1. The ground wire running with the flexible portion of conduit 3CL2040E1 is not connected at the connection to the rigid conduit.
- 2. Junction box 3HVR-TS109A appears to be missing a bolt and spacer plate.
- 3. The ground cable for the flexible conduit connection to 3HVR-TS109B is not connected.
Printed 3/12/96 3.4423 PM Page 2 of 6 l
Northert Utilities ICAVP DR N2. DR-MP3-0926 Millstone unit 3 Discrepancy Report m.
- 4. Junction box 3FPW-JB07A was found in the field / out a cover.
Review Yaud invalid Needed Date Initiator: Server, T, L B
O O
si2/9e VT Leed: Nerl, Anthony A B
O O
1/58'e VT Mgr: schopfer. Don K B
O O
sii2ais IRC Chmn: singh, Anand K B
D D
1/154'8 Dele:
INVALID:
Dele:
3/6/98 RESOLUTION. Disposition:
NU has concluded that items 3,5,9,12 and 13 and material condition items 1,3 & 4 in Discrepancy Report, DR-MP3-0926, have identified conditions not previously discovered by NU which require correction.
Item 3) A field walkdown reveals that panel 3BYS*PNL34F has no extemal ground connection, other than the rigid conduit connection. Therefore this is a discrepant condition. The FIN Team will generate AWOs for TR # 09M3132905 and will track work to completion.
A field walkdown reveals that panel 3VBA*PNL-VB1 has a ground connection from the station ground grid to the top of the cabinet. Therefore this is not a discrepant condition.
Item 5) A field walkdown reveals that in 3EGF*TRS1B, compartment 2C, there is a terminal block not shown on the drawinD EE-9ES. Therefore this item is discrepant, DCN DM3-00-0122-98 has been issued to show the as-built condition on Engineering drawings.
Item 9) A field walkdown reveals that there is a cable that extends above the side rails of tray sections 3TC1350.
1 Therefore this is a discrepant condition. Work has been j
completed by AWO M3-98-02932.
i item 12) Drawing EE-34Y and TSO2 indicates that tray 3TL2030 is a mark number DAK-01 Indicating the tray is 30 inches wide. A field walkdown reveals that the installed tray is 24 inches wide.
Therefore this is a discrepant condition and a DCN DMS-00-0122-98 has been issued to correct the drawing and TSO2 error, item 13) A field walkdown reveals that there are two trays with the identification 3TK2080. Therefore this is a discrepent item, DCN DMS-00-0114-98 will be issued to verify / correct labelling of both trays.
Material item 1) A field walkdown reveals that the ground bond for flex conduit 3CL2040E1 was disconnected. Therefore this is a discrepant condition. Work has been completed by AWO M3-Printed 3/12/9e 3M24 PM Page 3 or 6
N:rtheart Utilities ICAVP DR N2, DR-MP3-0926 Millstone Unit 3 Discrepancy Report 98-02932.
Material item 3) A field walkdown reveals that the ground cable for the flexible conduit connection to 3HVR-TS109B was not connected. Therefore this is a discrepant condition. Work has been completed by AWO M3-98-02932.
Material item 4) Junction Box 3FPW-JB07A, an empty spare Junction box mounted on 3HVR*FLT-3A, is missing it's cover.
Therefore this is a discrepant condition. CR M3-98-0591 was written to resolve this issue. Condition Reports (CR) M3-98-0497 and M3-98-0591 were written to provide the necessary corrective actions to resolve these issues.
The Approved Corrective Action Plans for CR M3-98-0497 and M3-98-0591(attached) will issue DCNs/AWOs to correct these discrepancies. These corrections will be completed post startup.
NU believes that this DR is a Significance Level 4 discrepancy, since the discrepant conditions have no impact on the design and/or license basis for the unit.
NU has concluded that items 6,7,8,10, and 14 in Discrepancy Report, DR-MP3-0926 have identified conditions previously discovered by NU which require correction.
Item 6) This item describes markin0s on the fuse blocks in 3BYS*PNLDG2F not being in agreement with Design Drawings.
ACR M3-97-0003, dated 1/2/97, noted that fuse stickers are not controlled or updated. AWOs M3-97-08854,08855,08856, 08857,08859,08860,08861,21946,21947,21948,21949, 21950 and 21951 removed labels that had been installed. A field walkdown reveals that there are no markings visible on fuse blocks 1 and 2 of 38YS*PNLDG2F.
Item 7) Within cabinets and panels, a minimum of six (6) inches is required between exposed contacts and terminals of Class 1E circuits or Class 1E and Non-Class 1E circuits and the minimum separation between Class 1E wire bundles or Class 1E and Non-Class 1E wire bundles is one (1) inch. Therefore, one (1) inch between Class 1E and Non-Class 1E wire bundles within 3HVR*RlY10A is an acceptable configuration. Note: ACR No.
12850, dated 05/03/96, identified a discrepancy, in that, the si0nal output from 3HVR-FT/FE10 to 3HVR*RlY10A was not electrically isolated. DCR No. M3-97003 installed a qualified isolator to alleviate this problem.
Item 8) CR M3-97-2851, dated 08/29/97, identified safety to non-safety wiring separation issues in 3CES*1PNLCB1P that were corrected immediately upon discovery. A walkdown of the panel found it to be in order. This item was prediscovered by NU, and repaired and is no lon9er discrepant. There is no further action required by Design En0ineering.
Item 10) E&DCR N-EC-02083 identified and accepted this confiouration. The electrical separation criteria for Class 1E to Pnnled 3/12/96 3:44:26 PM Page 4 of 6
Northe:st Utilities ICAVP DR No. DR-MP3-0926 Millstone unit 3 Discrepancy Report m
. x, non-Class 1E circuits is to enclose either circuit in a qualified barrier (conduit, tray cover-vented or flat, or Sil-Temp protective wrap) and having one (1) inch between the barrier and the circuits not enclosed. A variation to this criteria is allowed for
)
i "X",'C', and "K" service circuits, in that, if both circuits are
)
l enclosed in a qualified barrier, the separation distance can be
{
reduced to 1/8 inch between them.
l Also, as part of the corrective action for ACR No. M3-96-1016, l
dated 10/23/96, and LER No.96-045, FSAR No. 97-MP3-461, 1
SE S3-EV-97-0257, M3-EV-970136, and DM3-00-0992-97 were generated and these documents identified, analyzed and accepted these deviations to the electrical separation criteria.
These deviations will be listed in section 11.10 of SP-EE-076, Rev. 6. The " wrapped
- conduit 3CK1060H was one of the l
acceptable deviations.
Item 14) CR M3-97-1634, dated 05/23/97, identified electrical separation violations between 3TL102P and 3TJ101N/3TJ102N.
DCN No.'s DM3-00-1440-97, DM3-01-1440-97 and AWO No. MS-97-18275 addressed and corrected the electrical separation violations associated with cable trays 3TL102P and j
3TJ101N/3TJ102N.
NU has concluded that items 1,2,4,11 and material condition item 2 issues reported in Discrepancy Report, DR-MP3-0926, do not represent discrepent conditions.
Item 1) This item discusses the Electrical Installation Spec E350 I
requirement to have 3" allowable movement in the ground bond for flex condult. A walkdown of the conduits associated with 3HVR* MOD 49C1 & C2 reveals that the p ound bor:d is securely fastened to the flex conduit with tie wraps. The conduit does have sufficient extra length to allow for 3' of movement, therefore, the ground bond is of sufficient length.
Item 2) A field walkdown reveals that the flex portion of conduit 9CC2070A3 is not longer than 6' as stated in the DR. item 4)
PNL 3VBA*PNL VB1 was verified as part of Self Assessment DE-3-96-008. The neutral bus was found to be in place and unused as per vendor drawing 2424.200-637-011. Therefore this is not a discrepant condition and this item considered closed.
item 11) Afield walkdown by Civil / Mechanical design reveals that no degradation of the seat for tray 3TC200N/3TC163N.
Therefore this is not a discrepant condition and this is item is considered closed.
l Material item 2) A field walkdown reveals that the Junction box associated with 3HVR-TS109A is mounted securely to the wa!!
with a spacer behind it.
Significance Level criteria do not apply to items 1, 2,4,11 and material item 2 as there are not a discrepant conditions.
Prmted 3/12/98 3M26 PM Page s or 6
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\\
Northe st Utilities ICAVP DR Nr. DR-MP3-0926 umstone Unit 3 Discrepancy Report
==
Conclusion:==
NU has concluded that items 3,5,9,12 and 13 and material condition items 1,3 & 4 in Discrepancy Report, DR-MP3-0926, have identified conditions not previously discovered by NU which require correction.
Condition Reports (CR) M3-98-0497 and M3-98-0591were written to provide the necessary corrective actions to resolve these issues.The Approved Corrective Action Plans for CR M3-98-0497 and M3-98-0591(attached) will issue DCNs/AWOs to correct these discrepancies.These corrections will be completed post startup.
i NU has concluded that this DR is a Significance Level 4 discrepancy, since the valid discrepant conditions have no j
impact on the design and/or license basis for the unit.NU has concluded that items 6,7,8,10, and 14 in Discrepancy Report, DR-MP3-0926 have identified conditions previously discovered j
by NU which requires correction. ACRs M3-97-0003,12850, CRs M3-97-1634 and M3-97-2851 have previously identified these issues.
NU has concluded that items 1,2,4,11 and material 2 issues reported in Discrepancy Report, DR-MP3-0926, do not represent discrepant conditions. Design Engineering reviewed and verified i
the field condition and found no changes are required by these issues.
Significance Level criteria do not apply here as these are not discrapant conditions.
Previously identiced try NU? U ves (9) No Non Discrepent Condition?Q vos (9) No ResoluuonPending?O vos @ No ResolutionUnresolved?O vos @ No Review initletor: Womer, l.
VT Lead: Neri, Anthony A j
VT Mgr: Schopfer, Don K utc chmn: Singh, Anand K y
Date:
3/6/98 SL Comments: This DR remains at a level three because of item 8. Item 8 defined a separation violation that was addressed by CR M3 2851, dated 8/29/97. Although this discrepancy has been closed out it was not identified until after the ICAVP audit cutoff date.
Printad 3/12/96 3:4428 PM Page 6 of 6
i i
J Northert Utilitka ICAVP DR No. DR-MP3-0956 Ministone Unit 3 Discrepancy Report J
Review Group: System DR RESOLUTION ACctiPTED Potential Operetniity issue
@ Yes Discrepancy Type: Calculation Om SystemProcess: SWP NRC Signincance level: NA Date faxed to NU:
Date Published: 1/25/9e Discrepancy: Engineer supplied nozzle loads to the vendor do not match with piping analysis loads.
Ducription: The vendor seismic qualification report for four strainers 3SWP*STR1 A/B/C/D wac reviewed and following discrepancy was identified.
The engineer supplied nozzie loads to the vendor for the strainers qualification do not match with the nozzle loads determined in the piping stress analysis calculaiton#12179-NP(B)-X1900/X1901, This may underestimate actual stresses.
Review Valid invalid Needed Date initiator: Patel, Ramesh 8
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1'S'S8 VT Lead: Neri, Anthony A B
D 0
iii2/se VT Mgr: sc mpfer, Don K O
O O
1/15"S8 a
IRC Chmn: Singh, Anand K B
O O
1/22/9e Date:
INVALID:
+
Date:
3/9/98 RESOLUTION NU has concluded that it
., reported in Discrepancy Report, DR-MP3-0956, does nt..,,.esent a discrepant condition.
During the initial plant design the vendor suppiled a seismic qualification report for the strainers. This was matched with the piping analysis, NP(B)-X1900/X1901. This demonstrated that the loads placed on the strainer nozzles by the attached piping were less than the vendor allowed loads. Subsequently, for any later changes that were made to the Service Water piping, a calculation was performed to reconcile the revised nozzle loads.
The latest nozzle loads are reconciled in calculation 12179-NM(B)-697-CZ-002 (attached). The piping loads for these nozzles of the Service Water strainers are acceptable based on calculated stresses.
Significance Level criteria do not apply here as this is not a discrepant condition.
Previouwy identthod by NU7 O Yes @ No Non Discrepent Condition?@ Yes Q No Re.wii n P.amna70 Y=
@ No Roomuon uar=*ed70 Y=
@ No Review Acceptable Not Acceptable Needed Date g
j VT Lead: Neri, Arthong A f
9 n
O 3/11/S8 Prinrod 3/12/98 3:45:10 iW ""'"" *" W "'""* "
Pa0e 1 of 2
N:rthenst Utilities ICAVP DR ND. DR-MP3-0956 4
Millstone Unit 3 Discrepancy Report O
D 0
mu unmn. smen ~
Date:
SL Comments:
i Printed 3/12/96 3.45:13 PM Page 2 of 2
1 I
Northe:st Utilitie3 ICAVP DR No. DR-MP3-0996 Millstone Unit 3 Discrepancy Report Review Group: Programmebc DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p
Discipline: Mechanical Design Om Discrepancy Type: Correcthe m p
@ No System / Process: HVX NRC Signif6cence level: NA Date faxed to NU:
Date Published: 2/5/98 Discrepancy: Closure documents for Adverse Condition Report ACR 10855
==
Description:==
The closure documentation submitted by NU (via IRF 1377) for the subject ACR was not sufficient to verify closure in particular, the status of AR 96005676 involving Reg. Guide 1.47 panel lights is not indicated. Additionally, the signoff sheet (NUC PI-20 Clo'.cre Request form) indicating that ACR 10855 closure was app Jved by the unit project management was not included.
Review vand invalid Needed Dete inittstor: Neverro, Mark 8
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tr23/se VT Lead: Ryan, Thomes J B
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1r23/98 VT Mgr: schopfer, Don K B
O O
ir2s/se IRC Chmn: cingh, Anand K O
O O
5t27/98 Dete:
INVALID:
Date: 3/11/98 RESOLUTION Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0995, does not represent a discrepant condition. IRF 1377, mentioned in this DR, provided a list of ten ACRs and their associated A/Rs for the pt pase of establishing a status based on a verbal request. ACR W855 and its associated A/R (96005676) recommended that the panel status light logic be modified to impmve system bypass indication. A/R 96005676 was closed out since A/R 97000217 tracked the development of the modification under DCR-M3-96-057. A/R 97000217 is now closed after the DCR was issued forimplementation. A/R 95051783-02 is now tracking the implementation of the modification. Most of the physical work has been completed with the exception of some minor painting. A/R 95051783 is a P.,de 2 restraint item and therefore no approved Closure Request form is available. NU does not consider this to be a discrepant condition.
Significence Level Criteria do not apply here as these are not discrepant conditions.
i Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0095, does not represent a discrepant condition. The Closure Request form indicating ACR 10855 closure was approved by the Unit Project Management was not included since the modification detailed in DCR M3-96-057 have not been Printed 3/12/98 3:45:47 PM Page 1 of 2
Northert Utilities ICAVP DR N3. DR-MP3-0995 Milistone Unit 3 Discrepancy Report complete. Therefore, NU does not consider this to be a discrepent condition.
NU Recommends that this issue be put into the *Pending" status for the NRC to close. Significance Level Criteria do not apply as these are not a discrepant conditions.
Previoush identif6ed by NU? O vos (#) No Non Discrepent Condition?(#) vos O No ResolutionPending?O v
@ No R mutionunr av.d?O v
@ No Review initiator: Navarro, Mark VT Lead: Ryan, Thones J VT M Tar Don K IRC C
.tund K O
O O
Date:
3/11/98 sL Comments: Mode 2 items are within the NRC scope of review. Since this corrective action is not yet scheduled to be closed, DR will be closed.
Printed 3/12/98 3:45:51 PM Page 2 of 2
Northe:st Utilities ICAVP DR N2. DR-MP3-0068 Milistone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION REJECTED Rwlew Element: system l* htlon Dieciplips: Electne' sign Om Discrepancy Type: Instena a implementation g
SystemfProcese: SWP l
NRC Signiecence level: 4 Date Faxed to NU:
Date Published: 1o/30/97 D6ect spency: Cable Tray Cover not installed in Accordance with Drawing l
==
Description:==
Drawing EE-34TE Rev.1 (H-5) indicates the cover on tray riser 3TL7530 shall extend from elsvation 29' 3' to 35' 8*. The installed cover starts at elevation 22' extending upward to the end of the tray. The additional cover may affect the ampacity of the included power cables.
Review Valid invalid Needed Date Inkator: Server, T. L 8
O O
10/17/S7 VT Leed: Nort. Anthony A B
O O
'0/17/87 VT Mor: schapter, Don K G
O O
sor20f97 i
IRC Chmn: sin 0h, Anand K O
O O
ior27/97 Date:
INVALsD:
Date: 3/10/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0068, does not represent a discrepant condition.
Drawing EE-34TB depicts the tray cover to be installed on the top of the tray from EL 29'-3" to EL 35'-8" for separation purposes. Note 1 of EE-34TB references the general notes and legend on EE-34TA; or: which Note 3 states:" Tray covers are detailed to minimum lengths and shall be installed to meet or exceed the specified lengths". Tray 3TL7530 is designed and installed with a ventilated cover vertically on the G.7 line wall in the ESF Bldg, from EL 18'-0" to EL 38'-0"in accordance with drawings EE-34AN & EE-34AU. When cable trays are continuously covered for more then 6 feet with solid, unventilated covers, the cable ampacity rating should be de-rated as required by the NEC, (National Electrical Code) Section 318. NEC section 318-11(a), exception No.1 states: "Where Cable trays are continuously covered for more than 6 feet (1.83m) with soli:1 unventilated covers, not over 95 percent of the allowable ampacities of Tables 310-16 and 310-18 shall be permitted for multiconductor cables." From this reference it can be concluded t;1at it is not necessary to derate the cables installed iri cr.ble trays with ventilated covbrs.
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-MP3-0068, does not represent a discrepant condition. Tray Printed 3/12/98 3A6:30 PM Page 1 of 2
l Northe:st Utilitie3 ICAVP DR N3. DR-MP3 0068 Millstone Unit 3 Discrepancy Report covers are detailed to minimum lengths and shall be installed to meet or exceed the specified lengths. Tray 3TL7530 is designed and installed with ventilated cover for separation purposes in accordance with drawings EE-34AN & EE-34AU and will not affect the ampacity of the included power cables. NEC (National Electrical Code) section 318-11(a), exception No.1 states:
"Where Cable trays are continuously covered for more than 6 feet (1.83m) with solid unventilated covers, not over 95 percent of the allowable ampacities of Tables 31016 end 310-18 shall be permitted for multiconductor cables." From this reference it can be concluded that it is not necessary to derate the cables installed in cable trays with ventilated covers. Sign! nance Level criteria do not apply as this DR does not represent a discrepant condition.
Previously klontifled by NU? O Yes @ No Non Discrepent Condition?O Yes @ No Resolution Ponding?O Yo.
@ No ResolutionUnresolved70 Yes @ No Review initiator: Womer, l.
VT Lead: Nort, Anthony A VT Mgr: Schopfer Don K y
IRC Chmn: singh, Anand K Date:
3/10/98 sL Comments: The applicable drawing for the installation of tray covers is EE-34TB. This drawing indicated the tray cover for this tray is i
approximately 6 feet long. The installed cover is over 20 feet in length. A margin or tolerance to facilitate installation and to assure QA/QC acceptance L, standard practice, however, it seems unreasonable to assume that the referenced note citing minimums was intended to cover the installation of tray covers in excess of 300 percent of the 'as designed" length.
This situation is not consistent with configuration management requiraments in that the design drawings are not consistent with the installed condition (i.e., a discrepancy exists and should be corrected).
l Printed 3/12/96 3M43 PM Page 2 of 2
~. _.
i
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Northe st Utilitie3 ICAVP DR No-DR-MP3-0077 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLtJTION REJECTED Potential OperabiNty issue Discipione: Mechanical Design O vos D6screpancy Type: Calculatbn
@ No systerWProcess: OsS NRC Significance level: 4 Date faxed to NU:
Date Published: 9/29/97 Discrepancy: Discrepancies in QSS Effective Time, Actuation Time and EDG Start Time.
==
Description:==
Licensing documents and calculations contain discrepancies with respect to Quench Spray System (QSS) spray effective time, QSS spray actuation time, and Diesel Ger erator start time.
QSS Spray Maximum Effective Reference Time (sec)
FSAR Sec 6.2.2.2 approximately 68.2 without offsite power 3DBS-NSS-002 no more than 70.2 without offsite power US(B)-253 Rev 4 71.2 without offsite power US(B)-225 Rev 6 70.2 without offsite power FSAR Table 6.2-16 71.5 with minimum ESF Orig SER Sec 6.2.2 64.0, power availability not provided FSAR Sec 6.5.2.2 less than 65.0, power availability not provided FSAR Sec 6.2.1.1.3.7 max of 57.2 with offsite power 3DBS-NSS-002 no more than 52.2 with offsite power US(B)-253 Rev 4 57.2 with offsite power US(B)-225 Rev 6 52.2 with offsite power QSS Spray Maximum Reference Actuation Time (sec)
FSAR Sec 6.2.2.2 16 without offsite power, I
diesel generator starting, sequencer delay 3DBS-NSS-002 19 without offsite power, diesel generator starting, sequencer delay Diesel Generator Start Time References (sec) i TRM Table 3.3.2.1
< 12 l
3DBS-NSS-002 14 I
US(B)-225 Rev 6 14 l
FRAD % A 9 9 9 11 P inted 3/12/98 3:47:06 PM Page 1 or 7 l
i Northerst Utilities ICAVP DR No. DR-MP3-0077 Millstone Unit 3 Discrepancy Report Notes:
Calculation US(B)-225 provides the predicted times based on system operating parameters.
Calculation US(B)-253 provides the times used in the design basis Loss of Coolant Analysis.
Revlow Vaud invand Needed Date initiator: Fein0old, D. J.
O O
O sttaro7 VT Lead: Nwl, Anthony A B
O O
attator VT m r: schopfw, Don K Q
Q Q
9/19/97 o
wic chmn: singh. Anand K O
O O
9/2s/97 Date:
j NWALID:
Date: 2/24/96 RESOLUTION. Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0077, does not represent a discrepant condition. DR-MP3-0077 identifies potential inconsistencies between design and licensing documents for the quench spray effective times.
Some of these differences can be attributed to the revision of the calculation (US(B)-225) determining the system response times.
The evaluation of the differing values conceming QSS effective time, is based upon the following:
Calculation US(B)-225 determines the fill time for tha QSS piping system. This information was then input into US(B)-253 which establishes inputs to the containment analyses, US(B)-273 and US(B)-266. These calculations determine the peak containment pressures and temperatures post LOCA (US(B)-
273) or following an MSLB (US(B)-266). These evaluations use the QSS MAXIMUM response time to determine the rate of containment depressurization fcilowing an accident. The response time used in these calculations is the value important for the safety analysis. Since it is the ability of the QSS system to depressurize the containtant which is analyzed, it is more conservative to assume a longer response time.
For all calculations associated with the containment depressurization analysis a conservative 14 second diesel start time is assumed. The maximum allowable diesel start time as defined in the Technical Specifications is 11 seconds. Technical Specifications Surveillance Procedure SP 3646.15 assures that this is met by specifying a 10 second acceptance criteria..
One of the reasons Calculation US(B)-225,
- Quench Spray Effective Times" was revised is to include degraded pump curves for determination of maximum system response times.
This revision calculated slightly faster system fill times resulting j
in faster system response times, which is favorable for reduction of containment pressure following a LOCA or secondary line break. Based upon this, revision of the containment analysis Printed 3/12/98 3:47.11 PM Page 2 or 7 l
Northe:st Utilities ICAVP DR N2. DR-MP3-0077 Millstone Unit 3 Discrepancy Report using these faster response times and revision of the FSAR is not necessary since the new values are bounded by the old.
However, the following will address each item listed in DR-MP3-0077 with respect to this latest calculation note revision:
Reference:
FSAR 6.2.2.2, " Containment Heat Removal System:
System Design" Statement: The QSS becomes effective in approximately 68.2 seconds, assuming loss of offsite power andonly one pump operating. (This paragraph then identifies how 68.2 is determined)
Response: Using the new system fill time from US(B)-225, and the maximum Tech spec DG start time of 11 sec, the system effective time is 1 sec less, or 67.2 sec. The present FSAR uses a longer time therefore it is conservative.
Reference:
3DBS-NSG-002, " Design Basis Summary for the Quench Spray System" Statement: "... containment accident analysis spray time shall be no greater than 52.2 see with offsite power available and no l
greater than 70.2 sec with offsite power unavailable..."
Response: These values are the same as Rev 6 of calculation US(B)-225.
Reference:
US(B)-253 Rev 4," Documentation of LOCTIC Data Deck for Millstone Unit #3 LOCA Analysis" Statement: Min ESF:QSS Effective Time; Assuming LOP =52.2 sec (system fill + motor start time)+ 14sec (D5 start time) + 5 sec (sequencer)= 71.2 Response: Using the new system fill time from US(B)-225, the system effective time becomes 1 sec less, or 70.2 sec, the present LOCA analysis uses a longer time, therefore it is conservative.
Reference:
US(B)-225 Rev 6, " Quench Spray Effective Times" i
Statement: Max QSS effective Time = 50.2 sec (system fill)+14sec (DG start)+5sec (sequencer)+1sec (pump accel)=70.2 f
sec Response: This is the latest revision to the calculation.
Reference:
FSAR Ttsble 6.2-16 " Accident Chronology Pump Suction DER with Min ESF" Statement: 71.5 s Quench Spray System becomes effective Response: This comes from the containment analysis, US(B)-
' 273, page 22. This value was input from US(B)-253 which contains a more conservative value than that resulting from revision of US(B)-225.
l
Reference:
SER 6.2.2 Statement: The QSS is actuated automatically on receipt of the CDA signal, and spray flow becomes effective within 64 sec after the signal is received.
Response: This statement was appropriate for the original FSAR analysis. The original FSAR, Section 6.2.2 and Table 6.2-16 reported a 64 second QSS response time, therefore the original NRC SER value of 64 seconds stated in the oriainal NRC SER Prmted 3/12/96 3A7:13 PM Page 3 of 7
-- - - 1
Northe:st Utilitie3 ICAVP DR N3. DR-MP3 0077 Millst:ne Unit 3 Discrepancy Report was appropriate. The analysis has since been revised.
Reference:
FSAR 6.5.2.2, " Containment Sprays as a Fission Product Cleanup System" Statement: The QSS becomes effective in less than 65 seconds after the postulatMi event.
Response: This statement is true for offsite power available.
Reference:
FSAR 6.2.1.1.3.7," Main Steam Pipe Break Results" Statement: The maximum time required to start the pumps and fill the headers is 57.2 seconds for both one and two pump with off-site power available operation.
Response: This is the value used in US(B)-253 which is. input to the containment analysis US(B)-266. US(B)-266; Main Steam Line Break: " Containment Integrity and Temperature Evaluation" assumes 71.2 sec. Because the analysis uses a longer response time it is more conservative.
I
Reference:
3DBS-NSS-002 Statement: no more than 52.2 with offsite power.
Responc3: These values are the same as Rev 6 of calculation US(B)-225.
Reference 0 3(B)-253 Rev 4 Statement: 4,7.2 with offsite power Response: Using the new system fill time from US(B)-225, the system effective time becomes 5 sec less, or 52.2 sec, the present LOCA analysis uses a longer time therefore it is conservative.
Reference:
US(B)-225 Rev 6 Statement: 52.2 with offsite power Response: This is the latest revision to the calculation.
Reference:
FSAR 6.2.2.2 Statement: DG start + seg = 16 sec Response: 11 sec tech spec start time + 5 sec sequencer time
Reference:
3 OBS-002 Statement: DG start + seg = 19 sec Response: 14 see safety analysis DG start time + 5 sec sequencer time
Reference:
TRM Table 3.L.2.1, " Technical Requirements Manual, ESF Response Times" Statement: DG start time <12 sec Response: The Technical Requirements Manual contains a " start diesel generator" time of < or equal to 12 seconds following certain initiation signals. This acceptance criteria is based upon signal response times as well as the diesel start time. Ref SP31024 and SP 3646A.15.
Reference:
3DBS-NSS-002 Statement: DG start time 14 sec Response: The maximum diesel generator start time in the Technical Specifications is 11 sec. Containment Printed 3/12/98 3.47:13 PM Pege 4 or 7 I
i
Northert Utilities ICAVP DR N2. DR-MP3-0077 ministone Unit 3 Discrepancy Report depressurization analysis calculations assume a longer diesel start time which results in accident mitigation equipment starting later in the accident, providing more conservative results.
Reference:
US(B)-225 Rev 6 Statement: DG start time 14 sec Response: This is the latest revision to the calculation.
As noted above, the items are applicable to later revisions of calculations and are conservative with respect to the Safety Analysis and Technical Specifications. Significance Level criteria do not apply here as this is not a discrepant condition.
QSS Spray Maximum EffectiveReference References Time (sec)
FSAR Sec 6.2.2.2 approximately 68.2 without offsite power 3DBS-NSS-002 no more than 70.2 without offsite power US(B)-253 Rev 4 71.2 without offsite power US(B)-225 Rev 6 70.2 without offsite power FSAR Teble 6.2-16 71.5 with minimum ESF Orig SER Sec 6.2.2 64.0, power availability not provided FSAR Sec 6.5.2.2 less than 65.0, power availability not provided FSAR Sec 6.2.1.1.3.7 max of 57.2 with offsite power 3DBSPSS-002 no more than 52.2 with offsite power US(B)-253 Rev 4 57.2 with offsite power US(B)-225 Rev 6 52.2 with offsite power QSS Spray MaximumReference References Actuation Time (sec)
FSAR Sec 6.2.2.2 16 without offsite power, diesel generator
- starting, sequencer delay 3DB3-NSS-002 19 without offsite power, diesel generator
- starting, sequencer delay Diesel GeneratorReferences References Start Time (sec)
TRM Table 3.3.2.1
< 12 3DBS-NSS-002 14 14US(B)-225 Rev 6 14 FSAR Sec 6.2.2.2 11 Notes:
Calculation US(B)-225 provides the predicted times based on system operating parameters.
Calculation US(B)-253 provides the times used in the design basis Loss of Coolant Analysis.
i%1ted 3/12/98 3:47:14 PM Page 5 of 7
e Northea:t Utilities ICAVP DR N2. DR-MP3-0077 Millstone Unit 3 Discrepancy Report I
i i
I
==
Conclusion:==
l NU has concluded that Discrepancy Report, DR-MP3-0077, does not represent a discrepant condition. The items identify values I
used in analyses which are conservative with respect to the Technical Specifk:ations and are bounded by the Safety l
Analysis. Significance Level criteria do not apply here as this is not a discrepant condition.
Previously identified by NU? O Yes (G) No Non Discrepent Condition?O Yes (G) No Resolution PendingrO Yo.
@ No ResolutionUnresolved?O Yes
- No Review initletor: Feingold, D. J.
VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date:
2/24/98 sL comments: The QSS System Effective Time Calculation, US(B)-225, Rev. 6 is a design basis ceculation which should be consistent with other design calculations, the FSAR and the DBSDs.
l US(B)-225, Rev. 6 does not reach the conclusion that the revised OSS fill times are less limiting than Rev. 5 (or Rev. 4). It does not provide a Justification for why downstream design documents do not need to be updated. Because it does not reach this conclusion, US(B)-255, Rev. 6 no longer substantiates the old values for QSS effective time of Rev. 5 (or Rev. 4).
Containment pressurization calculations US(B)-253, Rev. 4 US(B)-273, Rev. 5 and US(B)-266, Rev. 2 do not justify the use of outdated values for QSS effective time, (i.e., values that are different from the controlled, design basis information provided by US(B)-225, Rev. 6).
The design basis containment pressurization calculations and the FSAR (FSAR Sec. 6.2.1.1.3.7. 6.2.2.2 and 6.5.2.2 are the only references to QSS effective time identified in this DR) should have used the correct QSS effective times of 52.2 seconds for Max ESF with no LOP and 70.2 seconds for Min ESF with a LOP. 3DBS-NSS-002 was property updated to reflect these values for QSS effective time.
The same comment applies to the QSS Spray Pump actuaW,n
)
time in FSAR Sec. 6.2.2.2. The QSS and containment design j
l basis start time for the diesel generator is 14 seconds, as l
identified in US(B)-225, Rev. 6, US(B)-253, Rev. 4 and US(B)-
266, Rev. 2. This time should be used in the FSAR to indicate j
that the QSS Spray Pump actuation time is 19 seconds after a LOP /LOCA or LOP /MSLB. 3DBS-NSS-002 reflects the correct l
value for the QSS Spray Pump actuation time.
Pnnted 3/12118 3A7:15 PM Page 6 of 7
Northert Utilitie3 ICAVP DR No. DR-MP3-0077 Millstone Unit 3
. Discrepancy Report These discrepancies are currently being addressed in calculation revisions and FSARCRs resulting from Modification M3-97045.
However, this modification commenced in response to a condition (reported in LER 97-028) that NU discovered after the May 17, 1996 design audit of the OSS/RSS systems began.
Therefore, S&L concludes that differences between the QSS effective times in the FSAR, DBSD and design basis calculations are a discrepant condition, j
Printed 3/12/9e 3:47:17 PM Page 7 of 7
NortheIt Utilities ICAVP DR NS. DR-MP3-0598 Millstone unit 3 Discrepancy Report Revlow Group: System DR RESOLUTION REJECTED Potential Operetdlityissue Discipline: Mechancel Design O ves Discrepency Type: Instelletkm implementation
- No SystemProcess: SWP NRC Significence level: 4 Date faxed to NU:
Date Putdished: 1/1048 Discrepency: PDCR MP3-91-056 Did Not Adequately Address Breached Barrier nor Pump Assembly Requirements Dacription: PDCR MP3-91-056 was initiated to change the shaft and coupling materials on 3SWP*P1C from the original Monel 400 to Nitrolic 50 for Improved resistance to corrosion.
With respect to removal and reinstallation of pump intemal parts, no procedures were referenced to control this work. Drawings referenced in the package were not included with the package, and are designated in GRITS as void, with later drawing revisions noted for each, and indicating that they are not available on aperture cards.
It should be noted that even though this PDCR was generait j
no closeout documentation was included with the PDCR, and i.
therefore cannot be determined whether or not these activities actually took place.
Review Valid invalid Needed Date initiator: Tenwinkel, J. L.
8 O
O 2r22/97 VT Leed: Nwl, Anthony A B
O O
12r20s7 vr Mgr: Schopfw, Don K O
O O
12t2347 IRC Chmn: Singh, Anand K O
O O
2isiro7 Date:
INVALID:
Date: 3/11/98 RESOLUTION. Disposition NU has concluded that Discrepancy Report, DR-MP3-0598, das identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specitte,1 in NRC letter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0513 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0598, has ideritified a condition not previously discovered by NU which j
requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability i
concems and meets the Unit 3 deferral criteria. CR M3-98-0513 i
Pnneed 3/1296 3:47:40PM Page 1 of 2 I
N:rtheast Utilitie3 ICAVP DR N2. DR-MP3-0698 Millstone Unit 3 Discrepancy R9 port has been written to develop and track resolution of this item per i
l RP-4.
Previously identified by NU7 Q Yes (9) No Non Discrepent Condition?Q Yes (9) No eautionunre.sved70 va @ No Re.aution Pending70 va @ wo Review j
initiator. Tonwinkel,J.L C
VT Leed: Neri, Anthony A VT Mgr: Schopter, Don K 1RC Chmn: Singh, Anand K Date:
3/11/98 SL omments: The NU disposition, including attachments, does not indicate I
corrective action to resolve the discrepancy. The DR Review l
Screen states only that the *PDCR is still in progress," even l
though the PDCR is over 6 years old.
l l
l l
l l
Printed 3/12/96 3:47:53 PM Page 2 of 2 l
l 1
l
l I
Northe:st Utilities ICAVP DR N2. DR-MP3-0831 Millstone Unit 3 Discrepancy Report Review Oroup: Configuration DR RESOLUTION REKCTED Potential Operability issue Diecipline:I & C Deegn Om Discrepancy Type: Installation implementation g
SystenWProcess: SWP NRC SL '" =n.e level: 4 Date faxed to NU:
Date Putsshed: 1/10S8 Discrepency: Inappropriate Sealing of Instrument Connection
==
Description:==
The following documents state that the use of Teflon Tape for sealin9 of instnJment connections is forbidden and that grafoil tape shall be used as the thread sealant: l&C Technical Bulletin
Contrary to the above requirement the following instruments i
were observed, during the system walkdowns, to have Teflon Tape applied to their threaded connections: 3SWP*FIS36A, 3SWP*PDIS163, 3SWP-Pl134A, and 3SWP-P1134B.
Review Valid invalid Needed Date initiator: server, T. L O
O O
12/sars7 VT Lead: Nerl Anthony A O
O O
s2/se/97 VT Mor: schopfer, Don K O
O O
2/23/97 IRC Chmn: singh, Anand K O
O O
2/31/97 Date:
INVAUD:
Date:
3/6/98 RESOLUTION Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0831, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0511 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0831, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0511 has been written to develop and track resolution of this item per RP-4.
PreviouePy identmed by NU? O Yes @) No Non D6screpent Condition?U Yes (G) No ResolutionPending?O Yes @ No Resoiution unr. iv.orO Yes G No Review Acceptetdo Not Acceptatne Needed Date g,,,
j O
9 O
3/6/98 Printed 3/s2/98 3:46:26 PM' ' ~ '""' """ ~"' "
Pope 1 of 2
~.. _ _ _ _ _. _ _
Northe ct Utilities ICAVP DR NA DR-MP3-0831 Millstone Unit 3 Discrepancy Report 1.
-n, n. -' "
O O
O 3"oS8 VT Mgr: Schopfer, Don K O
O O
3'11/S8 IRC Chmn: S$, Anand K O
O O
Date:
3/6/98 sL comments: DR-MP3-0831 identifies four components which have teflon tape used as a thread sealant. Teflon tape tape is expressly prohibited for seaiing of instrument connection because it is known that teflon tape can break off and inhibit / prevent correct operation of the instrument.
One of the four components cited in the DR is 3SWP*FIS36A,,
which is used to detect service water low flow to the Control Building Air Conditioning Water Chiller 3HVK*CHL1 A. Upon detection of this low flow condition, this chiller is stopped.
I Due to the required functionality of this chiller, it is not acceptable to postpone rework of the installation of 3SWP*FIS36A until after startup.
I l
i i
Printed 3/12/98 3 48.30 PM Page 2 of 2
l Northeact Utilities ICAVP DR No. DR-MP3-1044 millstone Unit 3 Discrepancy Report Review Group: System DR VAUD Review Element: system Design g
r"<. ; i & C Design Ow Discrepancy Type: m g g, SystemProcess: Oss NRC Significance level: 4 Date faxed to NU:
Date Published
- 3/14/98 Discrepancy: Use of obsolete / superseded references in various l&C j
calculations i
Description Various calculations use references to obsolete / superseded design documents. It is recognized that during the preparation of 4
the calculation this input might have been verified but the historical tracking of the input to the superseded calculation for future use is lost with this action. This can become a potential configuration control problem. Some of the examples of this are as follows:
- 1. Calculation 3451801-1231. Rev. 0: Reference 3.4 (calculation
{
3-ENG-099, Rev. 2) is identified as an input reference for Boron l
Concentration in the RWST tank. The same input is used for calculation 3451B03-1232E3, Rev. O. Per calculation 3-ENG-099
)
Rev. 3, this calculation has been superseded by calculation j
3451B01-1231, Rev. O. From the copy of calculation 3-ENG-099 Rev. 3 it is not clear what considerations were used in deriving the boron concentration or what references were used in deriving the number. Calculation 3451B01-1231, Rov. O has used the results of boron concentration value from the calculation 3-ENG-99 without showing actual methodology.
- 2. Calculation 3451803-1232E3, Rev. 0: Reference 3.7 (calculation 3-ENG-111, Rev.1) is identified as an input document for " Calibration Data for Procedure SP3451B03 RWST Level Interlock Calibration". Review of latest revisions on World View for l&C Forms 3451B03-1,3451B04-1,3451B05-1
& 3451B06-1 indicate references to calculation 3-ENG-111, Rev.
- 1. Calculation 3451803-1232E3, Rev. O was issued to account for a 24 months fuel cycle. The values used in the l&C forms listed above could be in less conservative direction if 3ENG-111, Rev.1 calculation is base on 18 months fuel cycle.
j NOTE: A copy of latest revision of 3ENG-111, calculation was requested under RF1-306, item 1 (IRF# M3-IRF-00248), but was not received due to its superseded status. Hence, the fuel cycle period used in that calculation could not be verified.
I
- 3. Calculation NSP-101-RSS, Rev.1 is a setpoint calculation for the instrument loop associated with 3RSS*FT38A and B.
Procedure IC3481 A08, Rev. 6 is identified as a design input (reference 21) to this calculation for defining drift uncertainties associated with the flow transmitters. Scope of this procedure is to provide calibration instructions for Rosemount Model 1153 and 1154 differential pressure transmitters. Per PMMS database and procurement specification 2472.510-662 the model number of the transmitters 3RSS*FT38A and 38B is Rosemount 11MT)PARN Mnwavar NNN 1 rdntad 7MQ/Qaiin the nrnendirro Printed 3/12/96 3403 PM Page 1 of 2
_ l
Northea:t Utilities ICAVP DR N2. DR-MP3-1044 Millstone Unit 3 Discrepancy Report IC3481 A08 removed 3RSS*FT38A and B from its Scope. The procedure taking place of IC3481 A08 is not identified.
R. view Valid invalid Needed Det.
Initiator: Hindia, R.
0 3r*S8 VT Lead: Neri, Anthony A B
O O
& 4/98 VT Mgr: Schopfer. Don K 8
0 0
3di/S8 IRC Chmn: Singh. Anand K B
O O
3/10'S8 Dm.:
INVALID:
Date:
RESOLUTION Pr.viously identified by NU? U Yes (9) No Non Discrepent Condition?U Yes (S.) No R.sowon P.ndingtO Ya @ No R.sowon unr.coev.d?O Ya @ No R.vi a+m No Acc.pteMe N d.d Det.
VT Lead: Neri, Anthony A VT Mgr: Schopfer. Don K b
IRC Chmn: Singh, Anand K O
D.
SL Comments:
Printed 312/96 3AO:07 PM Pope 2 of 2
Northe:st Utilities ICAVP DR N2. DR-MP3-1067 Millstone Unit 3 Discrepancy Report Review Group: Syedem DR VAUD Review Element: System Desion Potential obihty leeue Diecipune: I a C w Discrepancy Type: Design Cortrol Procedure Om System / Process: Oss NRC Signinconce level: 4 Date faxed to NU*
Date Published: 3/14/96 D6screpancy: FSAR specified accuracy for the containment does not match Westinghouse supplied basis calculation
==
Description:==
Per FSAR section 7.3.1.2 (page 7.3-61) required containment l
pressure signal accurecy for a steam break protection is +/- 1.8 percent of full scale.
Per Table 3-32 on page 66 of WCAP-14353, dated July,1995, titled " Westinghouse Setpoint Methodology for Indication, Control and Protection Systems for Millstone Nuclear Power Station Unit 3,24 month fuel cycle evaluation", the main control board indication (normal environment) channel statistical allowance for the containment pressure indication is 4.0% of full scale. Since, the part of the signal of interest is control part, the indication accuracy portion can be discounted from the 4 percent accuracy figure.
Even after discounting for uncertainties for readability (1% FS),
and drift components for sensor drift (1% FS), rack drift (2% FS) from 30 months to 24 months, the channel allowance is higher than +/-1.8% specified in the FSAR.
Review Valid invalid Needed Date initiator: Hindia, R.
O O
O 3/ arse VT Lead: Nort, Anthony A B
O O
3/4/S8 VT Mgr: schopfer, Don K B
O O
3
- 88 IRC Chmn: singh, Anand K B
O O
3'10'S8 Date:
INVAUD:
Date:
RESOLUTION Previously identifled by NU7 Q Yes (9) No Non Descrepent Condition?U Yes (9) No ResolutionPending?O vos @ No Resoiutionunre ev.d70 ves @ No Review Initiator: (none)
VT Lead: Neri. Anthony A VT Mgr: Schopfer, Don K g
IRC Chmn: singh, Anand K O
O 8
Dee:
SL Comments:
Printed 3/12/96 3.49:37 PM Page 1 of 1
. - ~..._
Northe:st Utilities ICAVP DR N3. DR-MP3-1071 Ministone Unit 3 Discrepancy Report Review Group: System DR VALID Pctential Operability lsene Discipline: 1 & C Design g
Discrepancy Type: 1.icensing Document Om Systen#rocess: NEW j
NRC SW level:3 Date Faxed to NU:
Date P Jblished: 3/14/96 D6screpancy: Failure modes of instrumentation not fully addressed.
]
==
Description:==
During the review of the safety evaluations for DCRs M3-97042 and M3-97045, the failure modes of the flow instrumentation (3RSS*FT38A,B) which controls 3RSS*MOV38A,B did not appear to be adequately addressed.
Areas of concem:
- 1. Possible impact of lowering the vortex supression grating on the RSS sump level monitoring instrumentation.
- 2. Possible nonfunctional aspects of the High Flow Switches.
Examples of the above concems are identified below from Safety Evaluation Number E3-EV-97-0043 Revision No. 0:
- 1. Section 2.1.1, Pages 7.2-8&9:
The way the logic is stated in this evaluation and per the DCR logic change, the high flow switch will not cause the *MOV38A/B to close unless actual flow is high and there is a failure in the full open position switch contact of the associated spray isolation valve (3RSS*MOV20A/B), since in the normal lineup the
- MOV20A/B is always full open before the pump starts. If
- MOV20A/B is closed for pump testing, the flow will not be high enough for the high flow switch to function unless there is some other failure.
- 2. Section 2.1.2.d, Page 7.2-12 Prior to the modification, the RSS sump level monitoring probe and float assembly passed through the vortex suppressor grating. As part of the modification, the vortex suppressor grating was lowered by 12 inches. After the modification, the lower end of the RSS sump level monitoring probe is lower than the new elevation of the grating. There is no discussion of the impact of the vortex suppressor grating elevation change regarding the crspability of this instrumentation to function.
- 3. Section 2.1.4, Page 7.2-16, third paragraph:
Per calculation NSP-101 RSS Rev.1 states that the range of operation of the high flow switch is between 2118 and 2437 gpm. Per calculation US(B)-361 Rev. O, the flow is expected to reach only 2283 gpm during spray, if the high flow switch function is not removed from the logic, it is possible that the high flow switch may not be able to actuate due to actual flow being less than the upper range of actuation of the high flow switch.
These items have not been addressed in the safety evaluation.
Printed 3't7.#.:50:05 PM Page 1 of 2~
I N:rtheart Utilitie3 ICAVP DR N3. DR MP3-1071 Millstone Unit 3 Discrepancy Report Valid inveild
'M Date initiator: DeMarco, J.
x e
3/5/98 VT Leed: Nort, Anthony A 3 6/98 x
VT Mgr: Schopfer, Don K Q
3/6/DB x
I 1RC Chmn: Singh, Anand K 3/10/98 x
Date:
INVALID:
Date:
RESOLUTION Previously identitled by NU7 O vos (#) No Non Discrepent Condition?O vos (#) No R uion P.nding70 va @ No Reemtionunr.ew.470 va @ No Review Acc Y h Not AceYh Needed Date VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Date:
SL Comments:
l Printed 3/12/98 3.50:00 PM Page 2 of 2
1 Northe:st Utilities ICAVP DR No. DR-MP3-1077 mmstone Unit 3 Discrepancy Report l
Review aroup: system DR VAUD Review Element: Correceve Acuan Process Diecipune: 1 & C Desien gg F-,
s Type: Correceve Acuan implementebon Om systemerocese: NEW NRC 4 '
=s level:3 Date faxed to NU:
Date Putdehed. 3/14/9e D6screpancy: ACR M3-96-0335 Corrective Action item 2 is a pre-startup issue but is scheduled for post-startup.
Ducription: The second Corrective Action states:
" Perform an engineering evaluation per EDI No. 30010 of MP3 Systems, using the PMMS Data Base and Loop Calibration Reports, for PT's, PS's, LT's, and LS's operating in QA systems at less than 5 psi, where the monitored equipment is under one ambient pressure and its PT, PS, LT, or LS is under another.
Or,ce these systems have been identified generate an EWR to evaluate how a change in ambient presure [ sic] may affect instrument accuracy and system operability."
This item was assigned tracking A/R 96026443-02 with a due date of 5/31/97 which is consistent with the potential severity of this unknown condition. There are safety systems other than the EDG Fuel Oil Day Tank Level Control System, for which ACR M3-96-0335 was issued, that operate in the 5 psi and below range that should be evalutted prior to startup (e.g. Narrow Range Containment Pressure, the containment personnel alriock system, etc.).
The Action Tracking Report currently shows A/R 96026443-02 as due for completion post-startup which, given the stated concem of a potential system operability status (and possible personnel injury because of unexpected containment hatch behaviour), this action should be completed prior to startup.
Review Valid invalid Needed Date initiator: Reed, William.
O O
O 3*se VT Lead: Nerl, Anthony ^
O O
O 3*S8 VT Mgr: schapter, Don K O
O O
3*se IRC Chmn: singh, Anand K O
O O
3/ o/88 Date:
IPNALID:
Dets:
Resolution.
Previously identified by Nu? O Yes (S) No Non Discrepent Condition?O vos (S) No R.soiononPeaana70 vos @ No munresoeved70 vos @ No Review initiator: (none)
'~
Not V ' "
M Date VT Lead: Neri, Antnony A Printed 3/12/9e 3:50:37 PM PaSe 1 of 2
1 Northert Utilities ICAVP DR N3. DR-MP3-1077 Milttone Unit 3 Discrepancy Report vi.
,,.u,---,,n O
O O
VT Mgr: Schopfer, Don K O
O j
IRC Chmn: Singh, Anand K O
O 8
i Date:
1 SL Comments-
)
i Printed 3/12/96 3M41 PM Page 2 of 2
l Northe:st Utilities ICAVP DR N:. DR-MP3-1081 i
Millstone Unit 3 Discrepancy Report Review Group: System DR VAUD Discipline: Mechanical Design Potential Operability lseue Om Discrepency Type: Licensing Document g
j SysterrWProcess: NEW NRC Significance level: 4 Date faxed to NU:
Date Published: 3/1498 Discrepency: Incomplete Failure Modes Analysis in S3-EV-98-0021 attached to DCR M3-98008
==
Description:==
Safety Evaluation S3-EV-98-0021, Modification of RSS Pumps' Seal Water Coolers, is the safety evaluation for DCR M3-98008.
Section 2.0 of the safety evaluation identifies two failure modes analyzed. They are:
- 1. Failure of RSS pump outboard seal.
- 2. Fallure of newtubing.
The safety evaluation does not address the three following failure modes:
- 1. Failure of the RSS pump inboard seal.
- 2. Failure of the pressure chamber on the RSS pump mechanical seal.
- 3. Failure of the new valves to maintain the RSS pump seal pressure boundary.
Therefore, the failure modes analysis in the safety evaluation is considered to be incom,olete.
Review Valid invalid Needed Date initiator: Feingold. D. J.
8 O
O 3/10/S8 VT Lead: Neri, Anthony A O
O O
3/to'S8 VT Mgr: Schopfer, Don K B
D D
3/15/S8 IRC Chmn: Singh, Anand K B
O O
3/iisse Date:
INVALID:
Date:
RESOLUTION Previously idenufled by NU? O Yes fy) No Non D6screpent Condition?O Yes (9) No ResolutionPending?O vos @ No R.soiotion unresoev.d?O vos @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
SL Comments:
Pnnled 3/12/98 3:52:05 PM Page 1 of 1
~.
Northeast Utilities ICAVP DR No. DR-MP3-1082 milistone Unit 3 Discrepancy Report Review Group: Programmehc DR VAllO Review Element. Corrective Action Process p
O vee Discrepancy Type: Corrective Action implementation g
System / Process: DGX NRC SW
=-3 level:4 Date faxed to NU:
Date Published: 3/1498
)
Discrepancy: Insufficient Documentation to Verify Corrective Action for CR M3-97-0729.
==
Description:==
In the implementation review of CR M3-97-0729 the following was noted; i
- 1. Corrective action #1 for CR M3-97-0729 was to " revise applicable drawings".
- 2. AR No. 97005927-02 assignment completion notes state
" revised applicable drawings to correct the drafting error and j
added EDG ratin9s under DCN #DM3-00-0372-97 as part of the corrective action plan." This DCN No. is also indicated on CR Form RP4-1, pa9e 5 of 9 in the CR package.
- 3. CR M3-97-0729 Action Closeout Form RP4-4 (for Aft 97005927-02) also indicates in part, under steps 5 & 6 that DCN
- DM3-00-03'"? 97 is the DCN which addresses the concem in the CR.
Contrary to the above, our review of DCN #DM3-00-0372-97 (copy which was included in the CR closeout package) indicates that this DCN did not address the concems documented in the CR.
Review Valid invalid N aled Date initiator: Caruso, A.
B 0
0 3/11/88 VT Lead: Ryan, Thomas J B
O O
3riorse VT Mgr: Schopfer. Don K B
O O
3tiiise 1RC Chmn: singh, Anand K B
O O
3/11/88 Date:
INVALID:
Dele:
Resolution Previously identifled by Nur () Yes @ No Non Discrepent Condition?(.) Yes @ No Resolution Ponding?O v.s
@ No Reemtion unresoived70 ve.
@ No Review Acceek Not AccepteW Needed Dh VT Leed: Ryan, Thomas J VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K O
O 8
Date:
SL Comments:
Printed 3/12/9e 3:52:44 PM Page 1 of 1
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