Text

Forwards Drs Identified During Review Activities for Independent Corrective Action Verification Program.Drs Distributed IAW Communication Protocol,PI-MP3-01.Page 11 of 11 for DR-MP3-0763 Not Included
	ML20216E305
Person / Time
Site:	Millstone
Issue date:	04/13/1998
From:	Schopfer D; SARGENT & LUNDY, INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	9583-100, NUDOCS 9804160169
	Download: ML20216E305 (112)
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bg Sar gerht; 5'm Lundy"c V ::t T( Don K. Schopfer Senior Vice President 312-269-6078 April 13,1998 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 j I have enclosed the following two (2) discrepancy reports (DRs) identified during our review activities for the ICAVP. These DRs are being distributed in accordance with the Communication Protocol, PI-MP3-01. DR No. DR-MP3-1096 DR No. DR-MP3-1097 I have also enclosed the following twenty-one (21) DRs for which the NU resolutions have been reviewed and accepted by S&L. DR No. DR-MP3-0086 DR No. DR-MP3-0626 DR No. DR-MP3-0145 DR No. DR-MP3-0657 DR No. DR-MP3-0173 DR No. DR-MP3-0763 DR No. DR-MP3-0178 DR No. DR-MP3-0781 DR No. DR-MP3-0263 DR No. DR-MP3-0789 DR No. DR-MP3-0265 DR No. DR-MP3-0850 DR No. DR-MP3-0349 DR No. DR-MP3-1016 DR No. DR-MP3-0472 DR No. DR-MP3-1024 [ DR No. DR-MP3-0473 DR No. DR-MP3-1052 DR No. DR-MP3-0476 DR No. DR-MP3-1063 DR No. DR-MP3-0620 /w/ 9804160169 900413 PDR ADOCK 0500 3 P 55 East Monroe Street

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

1 1 n-e United States Nuclear Regulatory Commission April 13,1998 Document Control Desk Project No. 9583-100 Page 2 I have also enclosed nine (9) DRs for which the NU resolutions have been reviewed but not accepted. S&L's comment on these resolutions have been provided. DR No. DR-MP3-0434 DR No. DR-MP3-0983 l-DR No. DR-MP3-0464 DR No. DR-MP3-1032 DR No. DR-MP3-0477 DR No. DR-MP3-1033 ) DR. No. DR-MP3-0482 DR No. DR-MP3-1046 DR No. DR-MP3-0876 Please direct any questions to me at (312) 269-6078. Yours very truly, % of,,& D. K. Schopfer i Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies: E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU mNcevpWwA98WO413-a. doc o-i l

i i e N:rthea:t Utilities ICAVP DR ND. DR-MP3-1096 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR VALID Review Element: Correcove Action Procese j Diecipline: Mechanical Design O va i Diecrepancy Type: Corrective Action implementation @ No Syelen#rocese: DGX NRC Significance level: 4 Date faxed to NU: Date Published: N16/s6 Discrepancy: ASME Section XI Classification of EDG Fuel Oil System DacripHon: CR M3-97-1596, dealing with the Section XI classification of Emergency Diesel-Generator (EDG) auxiliary systems, was closed to CR M3-97-2546. One of the issues described in CR M3-97-2546 was that the Inservice inspection (ISI) Program Manual required a visual VT 2 examination of the Class 3 portions of the Emergency Diesel Fuel Oil System (EGF) System whereas the old FSAR Table 6.6-2 did not show any Class 3 requirements for this system. FSAR-MP3-472 was issued to correct the FSAR regarding the classification of these EDG auxiliary systems. New Section 6.6.1 states that new Table 6.6-1 lists the Class 2 and 3 systems to be included in the ISI Program. The new Table 6.6-1 does not list the EGF System as an ASME Section XI ISI System. Thus, the corrective action for CR M3-97-2546 does not appear to be implemented. If the Intention was to delete the EGF System from the ISI Program, this would contradict the commitment to Regulatory Guide 1.137, Revision 1, Cated October,1979 in Sections 1.6 and 9.5.4.1 of the FSAR (see Regulatory Position C.1.e and paragraph 7.3 of ANSI N195-1976). Review Valid invalid Needed Date Initiator: shepperd. R. P. O O O d*S8 VT Lead: Ryan, Thomes J G O O 4*se j VT Mgr: schopfer, Don K 8 0 0 Niorse IRC Chmn: Singh, Anand K B O O

15/S8 Date:

INVALID: Date: RESOLUTION: Previously identified by NU? O vos @ No Non Diecrepent Condition?O vos @ No Resolution Pending?O v.e @ No Receivisonunreeoiv.d?O vos @ No Review Acceptable Not AWh Needed Date g VT Lead: Ryan. Thomas J VT Mgr: schopfer, Don K IRC Chmn: Singh. Anand K Date: SL Commente: Printed N13/9610:56:o2 AM Page 1 of 1

~. t Northeast Utilities ICAVP DR No. DR44P31097 Millstone Unit 3 Discrepancy Report Rev6ew Group: System DR VAUD Review Element: Modtftcetion Design Discipline: Mechanical Design y Discrepancy Type: Ucensing Document g SysterWProcess: NEW NRC Signiscence level: 4 Date faxed to NU: i Date Published: #16/96 Discrepency: DCR M3-97102 Impact on FSAR Appendix 3B

== Description:== During review of DCR M3-97102 ECCS Limited Passive Failure Design Criteria a discrepancy regarding the impact of the 50 gpm leak on FSAR Appendix 3B environmental parameters was identified. The results of calculation T-01528-S3, Rev, O show that the temperature and relative humidity inside the RSS cubicles exceed the temperature and humidity shown in FSAR Appendix 3B. The impact of the increased temperature and humidity on equipment qualification was addressed in the DCR. The changes required to FSAR Appendix 3B for zone ES-05 are not addressed in the DCR. This is considered a level 4 documentation discrepancy. Review Valid invalid Needed Date initiator: Stout, M. D. 8 O O

sene VT Leed: Neri, Anthony A Q

Q N8/98 VT Mgr: Schopfer, Don K O O O Niores IRC Chmn: Singh, Anand K 8 O O

1 /se f

Date: INVALID: Date: RESOLUTION: Previously identified by NU? O vos (*) No Non Discrepent Condition?O Yes (*) No Resolution Pending?O vos

No Resolution Unresolved?O yes
No Review initletor: (none)

VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K D..: SL Comments: Printed N13/9810:5829 AM Page 1 of 1

i N::rthe:st Utilities ICAVP DR ND. DR-MP3-0086 Millstone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED j { Review Element: Test Procedure Potential Operability lasue { Discipline h O yo. Discrepency Type: 0 & M & T Procedure @) No System / Process: Oss NRC Significance level: NA Date faxed to NU: Date Published: 9/19/97 Discrepancy: Minimum density requirements for the Trisodium Phosphate in the TSP baskets cannot be verified. Descripuon: FSAR Section 6.2.2.2, Quench System Design, (Page 6.2-44) requires 947 cu. ft. of trisodium phosphate dodecahydrate (TSP) of minimum density of 54 lb. per cu. ft., stored in twelve porous baskets located on elevation (-)24'-6" of the containment structure. These requirements on the TSP will ensure that the water in the recircuation sump has a final pH of equal to or greater than 7.0, while not exceeding a spray pH of 10.5. No procedure or associated data forms to accomplish the density verification of the TSP could be located. Thus, it cannot be verified whether or not the density verification requirements are being met. Review Valid invalid Needed Date initiator: Urgeran. R. G 0 0 S' o'S7 VT Lead: Bass, Ken 8 O O 8'1SS7 VT Mgr: schopfer, Don K O O O 9e 2/97 IRC Chmr': singh, Anand K G O O 9/12/97 De INVAllD: Dah: 4/6/98 RESOLUTION: Disposition; l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0086, does not represent a discrepant condition. The bulk density of Trisodium Phosphate (TSP) was verified during initial installation by Stone & Webster in a QA test. In accordance with PDCR MP3-94-135 Attachment 4 test 2, the TSP bulk density is verified by measuring the weight of one liter of TSP. Refer to attached test results and SVEC memo regarding TSP density acceptance test. TSP level is verified every refueling to ensure proper volume per SP 3606.10-1, TSP Storage Basket Volume Check. The amount of TSP needed in the containment building is based on the mass of TSP required to achieve the desired pH. However, a required volume is specified, rather than mass, since it is not feasible to weigh the t>ntire amount of TSP in containment. The minimum required volume is based on the manufactured density of TSP. Due to settling, the volume may decrease during normal plant operation causing the density to increase. If the acceptance criteria of SP 3606.10-1 is not met, more TSP is added to the basket (NOTE: Initial procurement of the TSP accounted for settling so extra bags were ordered from the same lot number to ensure the same density.) This process of measuring volume and using the same Printed 4/13/98 8:30:16 AM Page 1 of 2

Northeast Utilities ICAVP DR Nr. DR-MP3-0086 Millstone Unit 3 Discrepancy Report TSP from initial psocurement (and initial acceptance test) ensures minimum density is always met. Significance Level criteria do not apply here as this is not a discrepant condition.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0088, does not represent a discrepant condition. Bulk j density is measured by an independent QA lab prior to delivery to Millstone. The entire order of TSP is manufactured out of the same lot to ensure consistent density. Subsequent surveillance testing checks level as a representation of volume. If the volume decreases, density would increase. Thus, minimum density is ensured. SignificMee Level criteria do not apply here t as this is not a discrepant condition. Previously identmed by NU7 O Yes @) No Non D6screpent CondM6on?ft) Yes O No Resolution Pending?O ve. @ No Resoiution unre.oivodeO ve. @ No Review inMiator: Speer, R. VT Lead: Bass, Ken VT Mgr: schopfer, Don K 1RC Clwnn: S@, Anand K Date: 4/6/98 SL Comments: l Printed 4/13/96 8:30:20 AM Pope 2 of 2

( l N:rtheart Utilitie3 lCAVP DR N3. DR-MP3-0145 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design pgg g,,,, y DisclPline: Piping Design Om Discrepency Type: Ceiculation @" No SystenVProcess: SWP NRC Signincance level: 4 Date faxed to NU: Date Published: 9/1N97 Descrepency: Br. sis for eliminating vapor gap closure force time histories not documented Descripuon: In the process of reviewing the following documents, (i) Pipe Stress Analysis Calculation 12179-NP(B) 346-XF, Rev. ) 0, CCN 1 (ii) Pipe Stress Analysis Calculation 12179-NP(B)-360 XF, Rev. O, CCN 3 (iii) Flow Transient Calculation 12179-NP(B)-271-FA, Rev. 4, 11/26/84 we noted the following discrepancy:

Background:

Interoffice Memorandum titled, ' Design forcing functions on service water system due to vapor gap closure' is incorporated in (i) and (ii). The memo states: Based on SWP hydraulic transient tests, and meeting discussions on 'SWP Hydraulic Transient Test Results' held on 12/1/84 at the Millstone 3 site, (1) Loads associated with Gap 2 may be eliminated. Gap 7 may also be eliminated provided the system start-up tests will assure by visual and audible observations that no vapor gap formation occurs by CCP heat exchangers. (2) The forcing functions due to Gap 6 closure must be considered in design but should be reduced by a factor of 2 for both upset and faulted conditions. The above modifications will be documented in a revision to the calculation (iii). ) l Discrepancy. I The load reductions proposed have been incorporated in the stress calculations. The fluid transient calculation (iii) has not been revised. The proposed modifications to the SWP water hammer analysis have not been documented. t No basis, other than the interoffice memorandum is provided for eliminating the forcing functions. j Calculation title of (i) CCN 3 has the following typographical error. ' Time History Analysis - Problem 1908 - Service Water Piping' chruM rand Printed N13/98 8:30 40 AM Pege 1 of 3

i ~. N:rthea:t Utilitie3 ICAVP DR ND. DR-MP3-0145 Millstone Unn 3 Discrepancy Report ' Time History Analysis - Problem 1907 - Service Water Piping'. Review Valid invalid Needed Date initiator: Prakash, A. O O O e<2arar VT Lead: Nerl, Anthony A B O O se2/97 VT Mgr: Schopfer, Don K O O O wBro7 IRC Chmn: Sangh, Anand K O O O SSS7 Date: INVALID: Date: 4/10/98 RESOLUTION: Response ID: M3-IRF-01575 Disposition: NU has concluded that Discrepancy Report, DR MP3-0145, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 Pl. 20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.

== Conclusion:== NU has concluded that Discrepancy Report, DR-MP3-0145, 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 M3-98-0515 has been written to develop and track resolution of this item per RP-4. Previously identifled by NU? () vos (n) No Non Discrepent condition?(,.) ves @ No R* dution Pending?O vee @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Date initiator: Prakash, A. gg VT Lead: Nort, Anthony A I B O " are8 VT Mgt: schopfer, Don K g [ N1o/98 1RC Chmn: singh, Anand K O O O Date: 4/10/98 st comments: The DR addressed three issues, two of which are strictly documentation issues. The third addressed the lack of a technical basis for eliminating forcing functions. The Wsis for el'c *eting the forcing functions is an interoffice memoi.1id directive which cites test data and meeting discussions. Neither the test data, nor the meeting notes are referenced. The fluid transient calculation references calculation NP(B)-280FA which is 'Model-Data Comparison of Service Water System Hydraulic Transient Test for Vapor Gap Closure'. The conclusions of this calculation orovide technicallustification Pnrted N13/98 8:30:56 AM Page 2 of 3

N:rrtheast Utilitie3 ICAVP DR No. DR-MP3 0145 Millstone Unit 3 Discrepancy Report for the IOM directions. But this calculation has been voided because "it is not used for any design input". Based on a review of the available documents, we concur with NU that the issues addressed by this DR do not have any technical impact and are primarily documentation issues. I i i ( l Printed 4/1%8 8.30.58 AM Page 3 of 3

N:rtheast Utilities ICAVP DR N2. DR-MP3-0173 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operatety issue Discipline: I & C Design Om Discrepancy Type: calcoletion g 1 System / Process: SWP NRC Significance level: NA Date faxed to NU: Date Published: 11/2ND7 Discrepancy: Discrepancy of data in calculation SP-3SWP-31 and various reference documents identified in calc.

== Description:== The purpose of this calculation SP 3SWP-31, Rev.1, is to determine low NPSH setpoint for pressure switches 3SWP*PS150A,B. These pressure switches prohibit operation of the control building air conditioning booster pumps 3SWP*P2A,B if suction pressure is too low. During the review of Calculation SP-3SWP-31, the following was discovered:

1. On page 7, Conclusion section applies calculated Total Error value of +/ 1.7 psig value from page 6, around the setpoint value of 3.2 psi. Based on this low actuation setpoint is shown to be at 1.5 psig. This is below the minimum NPSH requirement of 3.2 psig (or 7 feet) required by the pump manufacturer as identified on page 3. The Responsible Power System Engineer review note on page 7 indicate that the low actuation setpoint is acceptable. However, no justification for this acceptance is provided.

Review Valid invalid Needed Date Initiator: Hindia. R. G 0 0 11'1:vS7 VT Lead: Neri, Anthony A B O O 11/13/S7 VT Mgr: schopfer, Don K B O O 1 /1*S7 IRC Chmn: singh, Anand K B O O 11'1S/S7 Date: INVALID: Date: 4/8/98 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0173, has identified errors in a calculation in which NU had previously identified as containing errors and requiring revision. Although the specific errors in DR-0173 are not listed, ACR 96-1135 identified that the setpoints were incorrect. The corrective action was to revise the setpoint calculations and verify the results against the flow calculation (90-069-01116M3). The verification determined that operating conditions were such that pressure switches 3SWP*PS150A,B were no longer required. This resulted in their deletion per DCR M3-97097 and DCN-DM3-00-1730-97. Calculation SP-3SWP-31 has been voided and documented in ACR-M3-96-1135.

== Conclusion:== Printed N13a 6 8:35:14 AM Page 1 of 2

I N::rtheast Utilities ICAVP DR Ns. DR-MP3 0173 Millstone unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report, DR MP3-0173 has identified a condition previously discovered by NU which required correction. ACR M3-96-1135 identified errors in setpoint calculation SP-3SWP-31. However, as system changes were made, pressure switches 3SWP*PS150A,B were deleted and setpoint calculation SP-3SWP-31 has been voided. Previously identined by NU7 (8) Yes O No Non Discrepent CondMion?O Yes (9) No Resolution Pending?O Yee @ No ResolutionUnresolved?O Yee @ No Review Acceptable Not Acceptable Needed Date inMiator: Hind 6a, R. O VT Lead: Nerl, Anthony A g VT Mgr: Schopfer, Don K B O O

1
IRC chmn: Singh, Anand K O

O O Date: 4/8/98 SL comments: Calculation SP-3SWP 31 has been voided. \\ l l l Printed N13/98 8.35:18 AM Page 2 of 2

N:rtheast Utiliti:3 ICAVP DR ND. DR-MP3-0178 Millstone Unit 3 Discrepancy Report Rev6ew Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: 1 & C Design Ow Discrepancy Type: calculation g System / Process: SWP NRC Significance level: NA Date faxed to NU: Date Publ6shed: 11/2 # 97 Discrepancy: SP-3SWP 32 calculation data discrepancy Ducripoon: The purpose of calculation SP-3SWP-32, Rev. O, is to determine setpoint values for switches 3SWP*PS152A, B. 3SWP*PS152A, B control MCC & Rod Control Area Booster pumps 3SWP*P3A and B based on a positive indication of supply pressure from the main service water pumps.

1. Per PDCR MP3-91-068 & E&DCR T-C-03863, the Installed range for switch 3SWP'PS152A is 1.5 to 36psig. E&DCR T-C-07300 supplemented E&DCR T-C-03863. E&DCR T-C-07300 did not reflect the range change. This is discussed in the ACR M3-96-1145. ACR M3-96-1135 discusses revision to the setpoint calculation SP-3SWP-32 during design basis event. The calculation in its present form is done for the range of 1 to 18 psig, which is the span for switch 3SWP*PS1528. Since the calculation was performed using the lower range (1 - 18 psig),

the calculated inaccuracy is not conservative with respect to switch 3SWP*PS152A. Hence, on page 7, the dP1 component calculated is valid for 3SWP*PS152B only. This will have an impact on all other calculated values for the 152A switch.

2. In the static head calculation portion of the calculation (page 3 of the calculation), instrument elevation of 45.71'is used. Per reference 4 the switches are located at elevation 45'-10* (this translates in to elevation of 45.83').

Review Valid invalid Needed Date initiator: H6ndia, R. 8 O O 1 3'S7 VT Lead: Neri, Anthony A B O O 11/13'97 VT Mgr: Schopfer, Don K S O O 11'1

S7 IRC Chmn: Singh, Anand K 8

O O 11/19'S7 Date: lNVALID: Date: 4/8/98 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0178, has identified errors in a calculation in which NU had previously identified as containing errors and requiring revision. Although the specific errors in DR-0178 are not listed, ACR 96-1135 identified that the setpoints were incorrect. The corrective action was to revise the setpoint calculations and verify the results against the flow calculation (90-069-01116M3). Printed N1:W8 8:35:51 AM Page 1 of 2

N;rtheart Utilities ICAVP DR Ns. DR-MP3 0178 Millstone Unit 3 Discrepancy Report The verification determined that operating conditions were such that pressure switches 3SWP*PS152A,B were no longer required. This resulted in their deletion per DCR M3-97097 and DCN-DM3-00-1730-97. Calculation SP 3SWP-32 has been i voided and documented in ACR-M3-961135.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0173 has identified a condition previously discovered i by NU which required correction. ACR-M3-96-1135 identified errors in setpoint calculation SP-3SWP 31. However, as system { changes were made, pressure switches 3SWP*PS150A,B were j deleted and setpoint calculation SP-3SWP-31 has been volded. J Previously klentifled by NU7 @ vos O No Non Discrepent Condluon?O vos @ No Resolution Pending?O vee @ No Resolution Unresolved?O ve. @ No Review initiator: Hind 6e, R. VT Lead: Neri, Anthony A VT Mgt: schopfer, Don K 1RC Chmn: singh, Anand K Date: 4/8/98 sL Comments: Calculation SP-3SWP-32 has been voided. The reasons given for voiding the calculations are acceptable. Therefore, the DR resolution is accepted. ] I Pnnted N13/98 8:35:55 AM i-9e 2 of 2

1 N:rthea:t Utilitim ICAVP DR N2. DR-MP3-0263 Millstone Unit 3 Discrepancy Report Rev6ew Group: Accident Mitigation DR RESOLUTION ACCEPTED Discipline: Other Potential Operability lasue Ow I Discrepency Type: Licensing Document (g j System / Process: N/A NRC Signincance level:3 Date faxed to NU: Date Published: 1o/3/97 Discrepancy: Verification of the basis for the two second Fuel Drop Monitor { response time. j

== Description:== The ICAPV has reviewed the following documents in order to { evaluate the response time for the radiation monitors 3RMS*41&42 used in the postulated FHAIC: 1 A) Procedure SP3449E11, Rev. 4 Fuel Drop Rediation Monitor 1 (3RMS*RlY41 and 42) Analog Channel Operational Test with associated l&C Form 3449E11 1. B) Procedure SP3449E02, Rev.1 Containment Area Purge and Exhaust isolation Radiation Monitor Calibration (3RMS*RE42) with associated l&C Form 3449E021. C) Procedure SP3449E01, Rev. 3 Containment Area Purge and Exhaust isolation Radiation Monitor Calibration (3RMS*RE41) with associated l&C Form 3449E01 1 D) Technical Requirements Manual-Clarification 3.3.2 Rev. 6 Instrumentation, Engineered Safety Features Actuation System Instrumentation TRM Table 3.3.2-1 Engineered Safety Features Response Times E) FSARCR 97 MP3-4 Affecting Fuel Handlirg Accident in Containment F) Calculation 3-ENG-244 Rev.1 Analysis of Stroke Time for Containment Purge and Exhaust Dampers dated 5/30/97 G) Unit 3 Millstone FSAR Section 15.7.4 In reviewing the above documents, the ICAVP identifies the following discrepency: The two (2) second radiation monitor response time stated in ?% FSAR Section 15.7.4 and confirmed in item E cannot be verified by reviewing the operability procedure contained in item A or the calibration procedures contained in items B and C. This value can be extracted from Technical Requirements Manual (TRM)- Clarification Section 3.3.2 Rev. 6. " Instrumentation, Engineered Safety Features Actuation System Instrumentation". TRM Table 3.3.2 and item E both state that it takes 5.89 seconds for completing the action and item E states 3.89 seconds for closing the valve. However, there is no test data to confirm the two second Fuel Drop Monitor response time. Re;< sew Printed 4/1M8 8:37.53 AM Page 1 of 4

Nnrtheast Utiliti:s ICAVP DR N3. DR-MP3-0263 Miitstone Unit 3 Discrepancy Report Vaud invand Needed Date Initiator: sc>rartz, Barry 8 O O S/17/S7 VT Lead: Rahtje, Ral D 0 0 0 S/17/S7 VT Mgr: schopfer, Don K B O O se22/97 1Rc ctwnn: singh, Anand K 8 0 0 o<27/97 Date: INVAllo: Date: 4/2/98 RESOLUTION: (First Round NU Comments) Disposition: NU has concluded that Discrepancy Report DR-MP3-0263 has identified a condition previously discovered by NU for which correction is complete. ACRs M3-961119 and M3-96-1120 were issued on 11/8/96 to address this problem. Design Change DCR M3-97032, Fuel Drop Monitor 3RMS*RlY41/42 Hardware Change, was approved on 8/8/97, completed and tumed over to Operations on 9/10/97. This DCR included hardware changes to the monitor, a FSARCR and a change to the Technical Requirements Manual. The system is now operable, and significance level criteria do not apply as this is no longer a discrepant condition.

== Conclusion:== NU has concluded that Discrepancy Report DR-MP3-0263 has identified a condition previously discovered by NU for which correction is complete. Design Change DCR M3-97032, Fuel Drop Monitor 3RMS*RlY41/42 Hardware Change, was completed on 9/10/97. The system is now operable, and significance level criteria do not apply as this is no longer a discrepant condition. (Second Round NU Comments) Disposition: As stated in the previous response, M3-IRF-00537, NU has concluded that DR-MP3-0263 has identified a condition previously discovered by NU for which corrective action is complete. In this follow-up to M3-lRF-00537, three issues are addressed: (1) the conflict between the FSAR and other documents as to the instrument time response, (2) the issue date of calculation 3-ENG-244 and (3) how the monitors are verified to respond to a FHAIC within 9 seconds at the alarm setpoint of 0.92R/hr. Selection of these three issues is based on a telephone conference with S&L on 3/9/98. During this teleconference, S&L also stated that the response provided to DR-MP3-0159 was satisfactory with the exception of item 1. Since this item addresses the same question of response testing versus the alarm setpoint as discussed above, S&L intends to close DR-MP3-0159, deferring that issue to DR-MP3-0263. Printed 4/13/98 8:37;57 AM Page 2 of 4

i N:rthernt Utilities ICAVP DR N3. DR MP3-0263 Millstone Unit 3 Discrepancy Report Item 1 The two second time is stated in the FSAR Section 15.7.4 is no longer in the FSAR. FSARCR 97-MP3-362 changed this time to 9 seconds forinstrument response. This change has been incorporated into the FSAR. Item 2 Revision 1 to Calculation 3-ENG-244, Analysis of Stroke Time for Containment Purge and Exhaust Dampers was approved on 5/30/97. Item 3 Data used to determine containment purge isolation response to 3RMS*RE41 and 42 is obtained from SP 3613F.2, " Containment Purge and Exhaust Valve Operability Test," and SP3443E.10/20/30/40, *Four Channel RPS/ESFAS Time Response." This data is summed in SP31024, " Calculation of Reactor Trip and ESF Response Times,' and compared to the acceptance criteria. The time response test does not use the i alarm setpoint of 0.92 R/hr in determining the response time, since the approach described below is shown to be more i conservative. The Fuel Drop Area Radiation Monitors 3RMS*RE41 and 3RMS*RE42 consists of an lon chamber detector assembly which is conn 3cted to the a microcomputer (SCAM) via an lon Chamber interface board. The monitor's range is from 0.01 to 1.0E05 R/hr which is 7 decades wide. The detector output { current is in amps and is converted by the ion chamber interface board into digital data, a mantissa and an exponent, that the microcomputer can process. When a change in the detector output current is in the same decade, the interface board processes this change with a minimal time delay. When the output current of the detector changes over multiple decades, a time delay is intentionally introduced to allow the circuit to stabilize at the new level. This delay can be upwards of approximately 4.5 to 7 seconds based on the magnitude of the step chan08-The monitors are tested by inserting a current signal step change into the lon Chamber interface Board. The current steps from 1.55 E 11 amps, the current required to keep the monitor on scale (0.01 R/hr), to 5.5 E-05 amps, which corresponds to radiation level of 9.0 E04 R/hr. This large step change covers most of the range of the monitor, which due to the stabilization described above is more conservative than testing at the alarm value of 0.92 R/hr. Prev 6ously identified by NU? @ Yes O No Non Discrepent Condition?O Yes @ No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Schwartz, Barry N2/98 Printed N13S8 8:37;58 AM Page 3 of 4

o I N::rthext Utilities ICAVP DR N3. DR-MP3-0263 Millstone Unit 3 Discrepancy Report Rah.9,do 8 0 0 VT Lead: O = VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K oste: 4/2/98 sL comments: (S&L Response to First Round NU Comments) ICAVP has reviewed the NU response to this DR and has the following comments. NU issued LER 96-046-00 to the NRC by letter dated December 6,1996 reporting that the Containment Fuel Drop Radiation Monitors could not meet the monitor response time requirements of 2 seconds stated in the Technical Requirements Manual. NU's current position on travel time as referenced in Calculation 3-ENG 244 Rev.1 (Item F) is 9 seconds, which was calculated as 9.12 seconds. The corresponding valve closure time is calculated as 7 seconds or less. (Note, to the best of our knowledge Rev.1 to this calculation has not been approved by NU.) Since this calculation is a parametric study which provides a monitor respone time and a corresponding valve closure time, any combination of monitor response and valve closure time can be selected, provided the monitor responds within this time period to a FHAIC. We agree with the NU position of amending the FSAR, the Technical Requirements Manual and Procedure SP 31024 to be consistant with this new position. However, NU has not provided evidence that the monitor will respond to a FHAIC within 9 seconds with the established monitor setpoint of.92R/hr as discussed in DR-MP3-0159. Thus closure of this DR is linked to NU's response to DR MP3-0159. l Printed 4/13/98 8:38:00 AM Page 4 of 4 ]

N:rtheast Utilities ICAVP DR N2. DR-MP3-0265 Millst:ne Unit 3 Discrepancy Report Review Group: Systern DR RESOLUTION ACCEPTED p Potential OperWitty issue Discrepancy Type: Celculat6on @ No System / Process: N/A NRC Significance level: 4 Dete faxed to NU: Date Published: 10/10/97 Discrepency: Discrepancy in calculated natural frequency for free standing vents / drains and associated test data

== Description:== In the process of reviewing the following documents, i (i) Design and Installation of Small Bore Piping, NETM-24, Rev. 3 { (ii) Interoffice Memorandum, Review of Calculation 12179-NP(B)- 692-XD, From RFHankinson to GPMilley, February 2,1984 (iii) Calculation 12179-NP(F)-QSS-3-V56, Rev. 2 (iv) Calculation 12179-NP(B)-4061-ZC, Rev.1, g/24/85 we noted the following discrepancy:

Background:

According to (i): In the evaluation of vent / drain configurations, applicable seismic accelerations at the point of attachment (to header piping or equipment) are the higher of the values from computer analysis results (of the header piping) or the zero period acceleration (ZPA). ZPA values are obtained from the applicable ARS curve for the building and elevation where vent / drain is located. These seismic acceleration values, multiplied by a factor of 1.5, should be applied to calculate seismic reaction and stresser. Implicit in the above procedure is the assumption that the vent / drain configuration is rigid relative to the piping, as Indicated by the following excerpts from (ii): - If the vent / drain is rigid in comparison with the piping response, the vent / drain will experience the maximum piping response. If the vent / drain is not rigid in comparison with the piping response, the vent / drain will experience an amplification of the maximum piping response". - Piping is excited by the building response through its supporting media, and as the free standing vent / drain is not attached to the building there can be no defendable justification for using building response to qualify the vent / drain". In some instances, seismic accelerations at the point of vent / drain attachment to the header piping, as obtained from NUPIPE computer analysis, are lower than the building floor ZPA, see for example (iii). The calculated accelerations are lower than the ZPA because a sufficient number of rigid body modes have not been properly accounted for in the header piping response. For these cases use of the higher ZPA values is required. "The ranniremont thnt fran cinnriinn unnt/rtrain rmnfinurnfinnet hp Pnnted 4/13/98 8:38 4o AM ~ ~ Page 1 of 4

I~ ~ N:rtheast Utilities ICAVP DR NO. DR-MP3-0266 Millstone Unit 3 Discrepancy Report rigid relative to the piping is not explicitly stated in the design criteria document (ii). However, all venUdrain calculations in the review sample demonstrate that the natural frequency of the vent / drain configuration is > 33Hz. This is performed by comparing the span lengths of the vent / drain configuration with maximum allowable span lengths to insure that frequency > 33Hz, as provided in (iv). The allowable span length calculation (iv) also contains frequency data from tests performed on a small sample of as-built vent / drain configurations at the Millstone -3 site. The test results show that some of the tested configurations have natural frequencies as low as 7Hz. As there is no mention to the contrary, the span length criteria of (iv) is presumably satisfied for these configurations, and therefore their calculated frequency is > 33Hz. No interpretation of test results is provided in (iv). Discrepancy: The requirement that free standing vent / drain configurations be rigid relative to the piping, i.e. natural frequency > 33Hz, is not explicitly stated in the design criteria document (ii). Natural frequency of vent / drain configurations is shown by calculation to be > 33Hz. However, test results contradict the calculated results for several configurations. The discrepancy has not been addressed in (iv). Review valid invalid Needed Date initiator: Prokash, A. G O O st23rs7 VT Lead: Nort, Anthony A B D D s/23/97 VT Mor: schopfer, Don K G O O 8/30/87 BRC Chmn: singh, Anand K 8 0 0 50/2/s7 Date: INVALID: Date: 4/10/98 REs0LUTION: Response ID: M3-IRF-01197 Disposition: NU has concluded that Discrepancy Report, DR-MP3-0265, has identified a condition not previously discovered by NU which requires correction. Note an apparent typographical error in the DR, the design criteria document is reference (i) NETM-24, not reference (ii) Interoffice Memo. The discrepant condition should be reviewed in the context of the design process. As the design process evolved, the criteria for vent and drain qualification was enhanced. During the early design phase of MP-3, the criteria i applied to vent and drain connections did not require that the assembly be rigid (i.e. > 33 Hz) and applied a factor to account for potential amplification. Beginning with the reference (ii) Interoffice memo, Engineering attempted to develop a defendable position regarding appropriate amplification factors to l Printed 4/13,98 8:38.44 AM Page 2 of 4 i

N:rtheast Utilitica ICAVP DR N2. DR-MP3-0265 Millstone unit 3 Discrepancy Report be applied to non-rigid vent and drain configurations. During the final stress reconciliation process in mid 1985, it was determined that the qualification method to be utilized for vent and drain connections would require that rigidity be demonstrated or that the vent and drain connections be modified by either shortening the free !angth or providing " tie-back" supports, such that the potential for a " tuning fork" response with large amplifications wcold be precluded. Individual calculations were performed for each vent and drain configuration to document this process. However, NETM-24 should have been revised to reflect this enhanced design requirement. Revision 0 of the reference (iv) calculation was performed to provide a pre-qualified source for dernonstrating rigid response for frere ended vent and drain configurations. Revision 1 of this calculation inserted Attachment B which provided the results of a one time field test performed on about 200 vent and drain configurations to determine frequency response via a bump test method. The results were not interpreted in the test report, and in some cases, the lower frequencies reported can be attributed to feedback from the response of the main run pipe or electronic noise. However, subsequent calculations were performed for each vent and drain configuration to demonstrate rigid conditions by either calev'ation or test result. In cases where rigid conditions did not exist, design changes were implemented to correct the condition. Therefore, the test report is considered a snap shot in time, not required to be consistent with the modified configurations.The approved corrective action plan for CR M3 0302 (attached) will revise design criteria NETM-24 to clarify the design requirements for free ended vent / drain connections and to revise calculations NP(B)408-XD, NP(B)692-XD, and NP(B)4061-ZC to provide consistency.There is no impact on physical hardware or the individual vent and drain calculations. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

== Conclusion:== NU has concluded that Discrepancy Report, DR-MP3-0265, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan (attached) for Condition Report (CR) M3-98-0302 will revise design criteria NETM-24 to clarify the design requirements for free ended vent / drain connections and to revise calculations NP(B)408-XD, NP(B)692 XD, and NP(B)4061-ZC to provide consistency. There is no impact on physical hardware or the individual vent and drain calculations. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue. Attachments: CR M3-98-0302 Previously identified by Nu? U yes @ No Non D6screpent Condition?O Yes @ No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Printed 4/13/98 8:38,45 AM Page 3 of 4

Nsrtheast Utilities ICAVP DR No. DR-MP3 0265 Millstone Unit 3 Discrepancy Report C' We M Date initiator: Prakash, A. O O O

1 m VT Lead: Neri, Anthony A O

O

1 m VT Mgt: Schopfer, Don K O

O +1 m IRC Chmn: Singh, Anand K O O O D&: 4/10/98 ) sL Comments: l l l l l l l l Printed N1m 8:38:47 AM p,4 og 4

N:rtheasti ilitie3 ICAVP DR N2. DR-MP3 4349 Millstone Unit 3 Discrepancy Report 1 Review Group: syt'em DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: component Data g System /Procese: Rss NRC Significance level: NA Date faxed to NU: Date Published: t/10/96 Discrepancy: Specs SP-ME 784 is Inconsistent with PCDR 3-93-015

== Description:== Specification SP-ME-784 through Revision 2 only applies to valves 3RSS*MOV23A,B,C,0, as they were replaced via PDCR 3-93-015. However, the specification is misleading because it contains valve data sheets for valves 3RSS*MOV20A,B,C,D, 3RSS*MOV23A,B,C,D, and 3QSS*MOV34A,B, but PDCR 3 015 addresses only the replacemerit of valves 1 3RSS*MOV23A,B,C,0. No design change packages are identified to implement the replacement of valves 3RSS*MOV20A,B,C,D and 3QSS*MOV34A,B as defined in specification SP ME-784. j The design specifications SP ME 784 through Revision 2 and 2362.200164 through Addendum 1 for valves j 3RSS*MOV23A,B,C,D overiap each other but contain confilcting data. Specifications SP-ME-784, the more recent of the two specifications, is for the replacement of Pratt Butterfly Valves only, and not the associated motor operators. Specification 2362.200-164, the earlier specification, identifies the design requirements for both the butterfly valves and their associated motor operators. As such, this specification provides j synergistic requirements such as valve stroke time, motor-operator hammer blow feature, and equipment qualification with respect to electrical components, and other motor operator j features, The seismic loading of the motor operator is j addressed in PDCR 3-93-015. Specification SP ME-784 does not cross reference specification 2362.200-164 or any other motor-operator specification. Therefore, specifications SP-ME-784 and 2362.200-164 cannot be reconciled to fully define the design and performance requirements for valves 3RSS*MOV23A,B,C,D, relative to stroke time, equipment qualification, and operator hammer blow feature. Rev6ew Valid invalid Needed Date initiator: Feingold, D. J. O O O 12/is/97 VT Lead: Neri, Anthony A O O O 12/18/97 VT Mgr: schopfer, Don K O O O 12rza/97 1RC Chmn: singh, Anand K .O O $2 rat /97 Date: INVALlo: Date: 4/6/98 Printed 4/13/96 8 40:o3 AM Page 1 of 4

N:rthenst Utilitie3 ICAVP DR N2. DR-MP3-0349 Millstone Unit 3 Discrepancy Report RESOLUTION: First Response i Disposition: NU has concluded that Discrepancy Report, DR MP3- 0349, i does not represent a discrepant condition for the following reasons:

1. Specification SP-ME-0349 through revision 2 provides purchase and design requirements for replacement Henry Pratt valves. PDCR 3-93-015 provides the design change package for the actual replacement of valves 3RSS*MOV23 A,B,C,D only and references the specification as the source and design requirements of the new valves. There are no plans to install valves 3RSS*MOV20A,B,C,D and 3QSS*MOV34A,B.

When valves 3RSS*MOV20A,B,C,D and 3QSS*MOV34A,B are replaced, new design change packages must be issued.

2. Specification SP-ME-0349 purchased new style valves with field replaceable seats in lieu of seats bonded to the valve bodies, provided more restrictive service conditions, and expanded seismic requirements. After installation, DCN DM3-S-00139-93 required S&W Specification 2362.200-164 be revised to remove valves applicable to 3RSS*MOV23A,B,C,D.

Specification SP-ME-0349 will replace S&W Specification l 2362.200-164 as the replacement valves are installed.

3. This statement is correct.

4. DCN DM3-S-0957 93 revised the MOV Test Plan to VOTES Testing in accordance with the Corporate MOV Program (NRC Generic Letter 89-10). The design requirements identified in S&W Specification 2364.200-104 are deleted per DCN DM3-S-00139-93.5. S&W Specification 2362.200-164 and Specification SP-ME-784 are different specifications. Specification SP-ME-784 provides valve design requirements only. S&W Specification 2362.200-164 has been replaced by the Corporate i

MOV Program for valves 3RSS*MOV23A,B,C,D. Significance Level Criteria do not apply as this is not a discrepant condition.

== Conclusion:== } NU has concluded that Discrepancy Report, DR-MP3- 0349, has Identified a condition which is not discrepant. One specification is a NU procurement / design document applicable to replacement valves and the other is an original AE procurement specification which is being replaced as replacement valves are installed. Significant Level Criteria do not apply as this is not a discrepant condition. Second Response Printed 4/13/96 8.40:07 AM Page 2 of 4 J

I N:rthe:st Utilities ICAVP DR N3. DR-MP3-0349 Millstone Unit 3 Discrepancy Report Disposition: NU has concluded that Discrepancy Report DR-MP3-0349 does not represent a discrepant condition. Specification SP-ME-784 provided both procurement requirements and specific valve body design requirements for 3RSS*MOV23A,B,C,D. This specification also contained similar requirements for other ) replacement valves which have not been installed and remain in storage. DCN DM3-S-00139-93 requires Specification 2362.200-164 to be revised to remove the valve design parameters for 3RSS*MOV23A,B,C,D since this data now is contained in Specification SP-ME-784. Since only the valve bodies were changed, Specification 2362.200-164 still contains the design parameters for the motor operators for 3RSS*MOV23A,B,C,D. However, DCN DM3-S-0957 93 incorporated the Generic l.etter 89-10 analyses for 3RSS*MOV23A,B,C,D into the Corporate z MOV Program. j in response to the Note, Sargent & Lundy is correct about the j typographical error, j The replacement valve body design Information for RSS*MOV23A,B,C,D is contained in Specification SP-ME-784 which supersedes the valve body design information contained in Specification 2362.200-164. The original motor operators were re-installed on the new valve bodies so Specification 2362.200-164 continues to have applicable design information for the motor operators and torque tubes for 3RSS*MOV23A,B,C,D. See DCN DM3-S-00139-93, page 1, for revision to Specification 2362.200-164. Significance Level Criteria does not apply as this is not a discrepant condition.

== Conclusion:== NU has concluded that Discrepancy Report DR-MP3-0349 does not represent a discrepant condition. Specification SP-ME-784 procured the replacement valve bodies and contains the valve body design parameters. Specification 2362.200-164 contains the applicable design parameters for the motor operators for the replacement valves. The replacement valve body design informatlan is contained in Specification SP-ME-784 and the motor operator design information remains in Specification 2362.200-164 since the original motor operators were re-installed on the replacement valve bodies. DCN DM3-S-00139 93 revises Specification 2362.200-164 accordingly. Significance Level Criteria does not apply as this is not a discrepant condition. Previously identined by NU? O ves (*) No Non Discrepent Condition?(e) vos O No Resolution Pending7O ve. @ No Resolution Unresolved?O ve. @ Ne Review initiator: Femgold. D. J. Printed 4/13/98 8:40:00 AM Page 3 of 4

1 N:rthe st Utilitiea ICAVP DR N3. DR-MP3-0349 Millstone Unit 3 Discrepancy Report j 1 8 0 0 m i VT Lead: Nort, Anthony A G O O e vi Mgr: Schopfer, Don K O O

m IRC Chmn: Singh, Anand K O

O O Date: 4/6/98 SL Comments: Sargent & Lundy Comment on Northeast Utilities' First

Response

Note: In Nortbest Utilities' disposition, the reference to " Specification SP-ME-0349"is assumed to be a typographical error, where the actual reference is " Specification SP ME-784". "0349" is the number of the discrepancy report. It is unclear which design specification applies to the motor operators for valves 3RSS*MOV23A,B,C,D given the response that states: "DCN DM3-S-00139-9?.: quired S&W Specification 2362.200-164 to be revised to remove valves applicable to 3RSS*MOV23A,B,C,0. Specification SP-ME-0349 will replace i S&W Specification 2362.200-164 as the replacement valves are Installed." and "S&W Specification 2362.200-164 has been replaced by the Corporate MOV Program for valves 3RSS*MOV23A,B,C,D." Consequently, a determination cannot be made related to valve stroke time (FSAR Table 6.3-1), motor operator equipment qur!!fication, and motor operator hammer blow feature requirement (FSAR Section 6.3.2.2.5). Sargent & Lundy Comment on Northeast Utilities' Second

Response

None. Printed N13'98 8:40:09 AM Page 4 of 4

I N:rthext Utilities ICAVP DR N3. DR-MP3-0472 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p Discipline: Other Om Discrepancy Type: Calculation g System / Process: SWP NRC Signincance level: 4 Date faxed to NU: Date Published: 1o/26/97 ( Discrepancy: Conversion to proper units in Calc. No.12179-P(R) 1087 was not i performed i

== Description:== On page 17 of Calculation No.12179-P(R)-1087, Rev. O, l Change No.1," Control Building Flood Study," the flow rate used in the calculation of the width of the welr (open!ng in the pipe encasement in the mechanical equipment room at Elevation 4' 6") is cubic feet per minute when it should be in cubic feet per second. This portion of the calculation determined the width of I the opening in the pipe encasement that would be needed so that the maximum flow rate into the mechanical equipment room will exit via the pipe encasement opening. Review Valid invalid Needed Date initiator: Launt, c. M. O O O 10/14S7 VT Lead: Nort, Anthony A O O O 10/1*S7 VT Mgr: schopfer, Don K O O O 1o/2o/97 IRC Chmn: Singh, Anand K O O O 10/22/97 l Date: INVAllD: Date: 4/6/98 RESOLUTION: Disposillon: l l NU has concluded that the issue reported in Discrepancy Report, 1 DR-MP3-0472, has identified a condition not previously i discovered by NU which requires correction. The approved i corrective action plan for CR M3-4116 will correct Calculation No.12179-P(R)-1087 post startup. The incorrect units for the flow rate (cubic feet per minute) result in maximum flooding rate greater than would be calculated using the correct flow rate units (cubic feet per second). The weir opening is therefore larger than would be necessary for mitigating the flooding. As the current calculation is conservative with respect to the design and licensing basis, NU has concluded that this discrepancy is a Significance Level 4. ) NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0472 has identified a condition not previously l i discovered by NU which requires correction. The calculation will be corrected by CR MP3-97-4116 post startup. As the current calculation is conservative with respect to the design and licensing basis, NU has concluded that this discrepancy is a Significance Level 4. Previously identined by NU? O Yes (#) No Non Discrepent condition?O Yes (9) No Resolution Pending?O Yes

No Resolution Unresolved?O Ye.
No Printed 4/13/98 8Ao:39 AM Page 1 of 2

N:rtheant Utiliti2a ICAVP DR Ns. DR-MP3-0472 Millstone Unit 3 Discrepancy Report Review Date initiator: Launi, C. M. B O O e VT Lead: Neri, Anthony A O O = VT Mgr: schopfer, Don K IRC Chmn: Sin 0h, Anand K Date: 4/6/98 SL Comments: The NU response is acceptable. As noted in the NU response, the weor opening is larger than would be necessary for mitigating a flood. Therefore, the current calculation is conservative and the Significance Level can be revised to 4. l Printed 4/13S8 8:40:43 AM Page 2 of 2

I N:rtheast Utilities ICAVP DR N2. DR-MP3-0473 Millstone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED ReWw Eht, spem %n Potential Operability lasue l Discipline: Other Discrepancy Type: calculation g i SysterrVProcess: sWP NRC Significance level: 4 Date faxed to NU: Date Published: 11/20/97 Discrepancy: Closing the wrong SWP valve to terminate a break in line 3-SWP-753-245-3 Descripdon: To isolate a break in line 3-SWP 750-245-3, Calculation 12179 P(R)-1198, Rev. O, " Flood Source Termination Evaluation," states that either valve 3SWP*V835 or valve 3SWP*V834 l should be closed (page 13). A review of Drawing 25212-26933 i sheet 2, Rev. 34 concludes that valve 3SWP*V836 should be closed instead of 3SWP*V834 and both valves 3SWP*836 and 3SWP*835 shold be closed to mitigate the break. There are no AOPs or EOPs associat3d with this action. Review Valid lovalid Needed Date initiator: Launt, C. M. O O O 11 8 7 VT Lead: Nort, Anthony A B O O 11/$S7 VT Mgr: schopfer, Don K O O O 1 '10'S7 IRC Chmn: Singh, Anand K O O O 11/17/S7 Date: INVALID: Date: 4/7/98 RESOLUTION: Disposillon: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0473, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan in Condition Report M3-97-4910 will revise calculation 12179-P(R)-1198 to correct the valve designations. This corrective action will be performed post

startup, l

AOPs or EOPs are not associated with this calculation. The purpose of calculation 12179-P(R)-1198 was to evaluate the design of the system to provide forline break isolation. The calculation was not intended to provide operator instruction in the event of a line break Since administrative change to calculation 12179-P(R)-1198 does not impact licensing basis or design basis, NU has concluded that this discrepancy is a Significance Level 4.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0473 has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan in CR M3-97-4910 scheduled for completion post startup will correct the valve designations. The changes da not impact the design or licensing basis and PrWed 4/13/90 8 41;10 AM Page 1 of 2 1 I

N:rtheart Utilities ICAVP DR Ns. DR-MP34473 Millstone Unit 3 Discrepancy Report therefore NU has concluded that this discrepancy is a Significance Level 4 Previously identified by Nu? O Yee (9) No Non Discrepent CondMion?Q Yes (8) No Resolution Pending?O vee @ No Resolution Unresolved?O vee @ No Review inMietor: Launi, C. M. VT Leed: Nort, Anthony A VT Mgr: schopfer, Don K IRC chmn: singh, Anand K Date: 4/7/98 sL Comments: This response is acceptable. The calculation was used to evaluate the design of plant systems to determine if means existed to isolate line breaks. The calculation was not used as input to AOPs or EOPs. Therefore, this discrepancy is Significance Level 4. i I l l Printed 4/13/98 8:41:13 AM Pa0e 2 of 2

f N:sthert Utilitica ICAVP DR N. DR-MP3 0476 Millstone Unit 3 Discrepancy Report f Review Group: System DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: Other Om Discrepancy Type: Calculeton g System / Process: SWP NRC Significance level: NA Date faxed to NU: Date Published: 1o/26/97 Discrepancy: Input to Calc. No. 94-ENG-1013-M3 was revised but the calc. l was not revised i Descripoon: ANSI /ANS 56.11-1988 states that floor drains shall be assumed plugged. Based on this, Calculation No. P(R) 1194, Rev 1, "ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," was revised to remove all references and assumptions of flow through floor drains (Revision 2). Calculation No. 94-ENG-1013-M3, Rev. O, "ESF Building Flooding Rate - 4' 6" Elevation," references Rev.1 of Calculation No. P(R) 1194. Calculation No. 94-ENG-1013-M3, Rev. O takes l Into account flow through floor drains. Calculation No. 94-ENG- ) 1013-M3 needs to be reviewed to determine if it remahs valid and either voided or revised. Review Valid invalid Needed Date initiator: Launi. C. M. O O O 10/1*S7 VT Lead: Nerl. Anthony A O D D 10/1*S7 VT Mgt: schopfer, Don K B D D or2aeo7 IRC Chmn: singh, Anand K 8 O O 10<21/87 Date: 'l INVALID: Dete: 4/6/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0476, does not represent a discrepant condition. Calculation 12179-P(R) 1194 remains the calculation of record for flooding in the ESFBuilding and assumes floor drains are plugged. Calculation 94-ENG-1013-M3, which uses input from calculation 12179-P(R)-1194, was perfomled to assess the impact of proposed door modifications on the ESF Building flooding analysis for an adjacent cubicle. For added realism and conservatism this calculation assumed additional flow could be initiated from the open drain into this area. As such, calculation No. 94-ENG-1013-M3 is valid. However the purpose and title for calculation 94 ENG-1013-M3 is not clear in this case and by review of the calculation it apparently conflicts with calculation 12179-P(R) 1194. CR MP3-97-4117 has been initiated to add a clarification purpose statement to Calculation 94-ENG-1013-M3. l This will be completed post startup and requires no field work. Significance Level criteria do not apply here as this is not a l discrepant condition.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0476, does not represent a discrepant condition. The cciculations are for two different purposes. Calculation No. 94-Printed N13/98 8A1:40 AM Page 1 of 2

N:rtheast Utiliti;s ICAVP DR N3. DR-MP3-0476 Millstone Unit 3 Discrepancy Report ENG-1013 conservatively accounts for the additional flow from the floor drains to determine the adequacy of the door. Post start up CR MP3 4117 has been initiated to add a clarification purpose statement to Calculation 94-ENG-1013-M3. Significance Level criteria do not apply here as this is not a l discrepant condition. Previously identined by NU7 O Yes @ No Non Discrepent condition?@ vee O No Resolution Pending?O vee @ No ResolutionUnresolved?O vee @ No Review Initiator: Leuni, C. M. i VT Lead: Nort, Arr.hony A VT Mgr: Fe.hopfer. Don K IRC Ctwnn: Singh, Anand K Date: 4/6/98 st Comments: The NU response is acceptable. A CR has been initiated (CR MP3-97-4117) to add a clarification purpose statement to calculation 94-ENG-1013-M3. I 1 Printed 4/13/98 8:41:44 AM Page 2 of 2

1 N rthe:ct Utilitics ICAVP DR No. DR-MP3-0620 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Om Discrepancy Type: Component Dats @) No system / Process: Rss ~ NRC Significance level: NA Date faxed to NU: Date Published: 12/8/97 Discrepancy: Inconsistency with FSAR Table 6.3-1 motor operated valve closure time requirements

== Description:== FSAR Table 6.3-1 states that emergency core cooling system motor operated valves, larger than 8 inches, stroke in less than 49 inches per minute per inch of nominal valve size. This requirement appear to be more appropriately applied to gate and globe valves. If this requirement is applied to butterfly valves 3RSS*MOV20A,B,C,D and 3RSS*MOV23A,B,C,D, the required stroke time would be less than the design stroke time reported for these valves in design specification 2362.200-164 Revision

1. According to design specification 2362.200-164 Revision 1, these motor operated valves have a stroke time of 30 seconds.

Containment recirculation system components are described in FSAR Section 6.3 to be included in the emergency core cooling system. 1 Review Valid invalid Needed Date initiator: Feingold, D J. 8 O O 11/17/87 VT Lead: Neri, Anthony A B D D 11/17/87 VT Mgr: schopfer, Don K 8 O O 12/i/97 BRC Chmn: singh, Anand K 8 0 0 12/4/o7 Date: INVALID: Date: 4/g/g8 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report, DR MP3-0620, represents a rFscrepant condition previously discovered by NU which has been corrected. FSAR Change Request, 97-MP3-325, (attached) was issued to revise Table 6.3-1 by the 50.54f FSAR Verification Team. FSARCR,97-MP3-325, removed the subject statement from CSAR Table 6.3-1.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0620, represents a discrepant condition previously discovered by NU which has been corrected. FSAR Change Request, 97-MP3-325, (attached) was issued to revise Table 6.3-f 1 by the 50.54f FSAR Verification Team. FSARCR,97-MP3-325, removes the subject statement from FSAR Table 6.3-1 Previously identified by NU? (#) Yes O No Non Discrepent Condition?Q Yes (9) No Printed 4/13/98 8:42:16 AM Page 1 of 2 1

1 N:rtheast Utilities ICAVP DR Ns DR-MP3-0620 Millstone Unit 3 Discrepancy Report Resolution Pending70 Yes (*) No ResolutionUnresolved70 ves (*) No Review M ACC*Pte W Needed Date inNietor: Femgold, D. J. 8 0 0 m VT Leed: Nerl, Anthony A G O O m VT Mgr: Schopfer, Don K O O

1 m IRC Chmn: Sin 0h, Anand K l

Date: SL Comments: i 1 1 l I l l Printed N13/98 8:42:20 AM P 2 of 2

l Northeast Utilities ICAVP DR N3. DR-MP3-0626 l Millstone unit 3 Discrepancy Report l Review Group: Programmatic DR REs0LUTION ACCEPTED Review Element: Correcuve Action Process Discipline: Materkel Dwign O v. Discrepency Type: Uceneino Document g SystenVProcess: N/A NRC Signincance level: 3 Date faxed to NU: Date Published: 11/17/97 Descrepency: Consistency Between Final Safety Analysis Change Request (FSARCR) 97 MP3-289 and Millstone 3 SER Ductlption: FSARCR 97 MP3-289 changes the time that the Reactor Coolant Pumps (RCPs) can operate without cooling water from 20 minutes to 10 minutes. The safety evaluation screening did not identify that the Millstone 3 SER (page 9-12) contains a response by the Licensee that the "RCPs can function satisfactorily for 20 minutes without component cooling water flow." Consaquently, the change is inconsistent with the Millstone 3 SER. Review Valid invalid Needed Date initiator: Neverro, Mark 8 0 0 15/12s97 VT Lead: Ryan, Thomes J B O O 11/12/97 VT Mgr: schopfer, Don K O O O $1'12/97 IRC Chmn: singh, Anand K O O O 11/12/97 Dei.: 1 INVAWO: Date: 3/31/98 REs0LUTION: Disposition NU has concluded that Discrepancy Report DR-MP3-0626 has identified a condition previously discovered by NU which required correction. The safety evaluation screening for FSARCR 97 MPO 289 did not consider the NRC SER when j resolving the, discrs cancy between FSAR Sections 7.3.2.3.1 and v.2.2.1.3. It should 'a noted that Sargent and Lundy received a copy of FSARCP 9" I tP3-289 while it was still in the review ) process. The sut.uquent technical review of FSARCR 97 MP3-289 determined on 9-26-97, prior to the issuance of this DR, that ) the proposed FSAR changes were not consistent with the licensing and design basis for the Component Cooling Water (CCW) system as dexribed in the NRC SER. This discovery resulted in FSARCR 97 MP3-289 being supen,eded by FSARCR l 97-MP3-537. j FSARCR 97-MP3-289 was initiated to propose a change to the i FSAR to resolve a discrepancy identified in OIR 85 between FSAR Sections 7.3.2.3.1 and 9.2.2.1.3 regarding the amount of time the Reactor Coolant Pumps (RCPs) can operate without CCW; FSAR Section 7.3.2.3.1 states the RCPs can run about 10 minutes after a loss of CCW while FSAR Section 9.2.2.1.3 states that in the event of a loss of cooling water supply, the RCPs can operate without the threat of seizure for about 20 minutes. FSARCR 97-MP3-289 recommended a change to FSAR Section Printed 4/1M810:53:53 AM Page 1 of 6

N:rthe::ct Utilities ICAVP DR No. DR MP3-0626 Millstone unit 3 Discrepancy Report 9.2.2.1.3 to indicate the RCPs can operate for 10 minutes without CCW instead of the 20 minutes it had previously indicated. The bases for this recommended change was Westinghouse letter NEU-955, dated 3-6 74, which indicated that the pumps can run for about 10 minutes after a loss of CCW before the motor bearing temperature exceeds the manufacturer's recommended max! mum bearing temperature. The technical review for FSARCR 97-MP3-289 identified that the NRC acceptance of the CCW system was based in part on the fact that the RCP motors could survive a loss of CCW cooling for 20 minutes, thereby, eliminating the need for automatic protection of the plant. This discovery resulted in FSARCR 97-MP3-289 being superseded, during its review cycle, by FSARCR 97-MP3-537. FSARCR 97-MP3 537 recommends a change to FSAR Section 7.3.2.3.1 to identify that the RCPs can operate for 20 minutes. The basis for this FSAR change is a commitment discussed in the MP3 SER which indicated that 20 minutes was achievable. This new FSARCR is currently in process and is being technically reviewed at this time. While in technical review, it was recognizeJ that additional analyses were required to support the closure U OIR 85 (AR 96009498). Westinghouse is conducting an engineering study to assess RCP motor performance for R minutes following a loss of component cooling water. FSAMR 97-MP3-537 will remain in technical review pending complete of this engineering study. Based on the above, NU has determined that the FSARCR issue described in this DR was discovered by NU well in advance of this DR, as part of our normal review process. While the initial screening process did not pick up the discrepancy, the defense in depth na^m of the overall review and approval cycle worked as des 4ned to prevent a defective FSARCR from being submitted to the NRC. Since the approval of the safety evaluation screening for FSARCR 97 MP3-289 on 6-28-97, NU has been actively involved in the improvement of the safety evaluation screening process and associated training as a result of two self assessments completed on 6 24 97 and 7-23-97. The findings and recommendations of these self assessments are documented in ESAR PES 97-0027, dated 6 24 97, and a report entitled " Industry Peer Evaluation of Millstone Safety Evaluation Process", dated 7-23-97. The corrective actions associated with the CRs that resulted from these self assessments included the following to improve the quality and standards utilized for safety evaluation screens: RAC 12, the new procedure that will govem the preparation of safety evaluation screens and safety evaluations, provides additional guidance on determining the documents that comprise the SAR. This procedure, which becomes effective on March 1, 1998, also notes that since information in SAR documents is often generalin nature, preparation of an adequate SE Screen or SE may require reviewing licensing and design Information not included in the SAR. The procedure indicates important sources Printed N13/9810:53:56 AM Pa0e 2 of 6

N:rtheast Utilitie3 ICAVP DR N. DR-MP3-0626 Millstone Unit 3 Discrepancy Report i of such information are NRC SERs, docketed correspondence, and records of safety and transient analyses. l ) Millstone management held several intervention meetings with l the approvers of safety evaluation screens to stress the importance of safety evaluation screens and to provide i management's expectations on how these documents should be l prepared. l The CRs and associated corrective actions that resulted from I these self assessments as well as ongoing activities to improve the safety evaluation screening process, including trending, are discussed in greater detail in NU Response M3-IRF-01450 to i Sargent and Lundy DR-MP3-0865. Additionally, CR M3-97-4022 was written on 11-13-97, to ensure no FSARCRs were approved that would have resulted in an unreviewed safety question due to an inadequate safety evaluation screening. The corrective actions for this CR included a review of approved FSARCR packages, with screenings completed from early 1996 through August of 1997 to ensure no unreviewed safety question exists as a result of an improper screening. Eatiy 1996 was chosen as the starting point of this review because CMP had performed a review of all FSARCRs from plant startup through early 1996. August of 1997 was chosen to ensure the review captured screenings l performed prior to the management intervention activities initiated in June 1997. The results of this review are documented in NU Memo NL 97 316, dated 1219 97, and show no packages were identified which would have resulted in an unreviewed safety question. Attachments: CR M3-97-4022 ESAR PES-97-0027, dated 6-24-97 Report entitled " Industry Peer Evaluation of Millstone Safety Evaluation Process" Conclusion NU has concluded that Discreparcy Report DR-MP3-0626 has identified a condition previously discovered by NU which required correction. The safety evaluation screening for FSARCR 97-MP3-289 did not consider the NRC SER. It should be noted that Sargent and Lundy received a copy of FSARCR 97-MP3 289 while it was still in the review process. The subsequent technical review of FSARCR 97-MP3-289 determined, prior to the issuance of this DR, that the proposed changes were not consistent with the licensing and design basis for the Component Cooling Water (CCW) system as described in the NRC SER. This discovery resulted in FSARCR 97-MP3-289 being superseded by FSARCR 97-MP3-537 which is currently in technical review, Printed 4/13/981o.53:57 AM Page 3 of 6 l l l

l l Northeist Utilities ICAVP DR Ns. DR-MP3 0626 Millstone Unit 3 Diss.*epancy Report Additionally, NU has been actively involved in the improvement of the safety evaluation screening process and associated training to improve the quality of the screens, to ensure adequate bases is provided to support the conclusions of the screening and to eliminate the risk that a required safety evaluation will not be perfom1ed due to an improper screening. l This involvement includes the performance of self assessments and trending to measure the success of corrective actions to date and to identify additional corrective actions that may be l necessary to ensure the quality of safety evaluation screenings is meeting the high standards being se* by management. NU's Second Response l Disposition NU has concluded that Discrepancy Report DR MP3-0626 has l identified a condition previously discovered by NU which has been corrected. The statement in NU's response to Discrepancy Report DR-MP3-0626 regarding the performance of an l engineering study by Westinghouse did not intend to imply that l there is a question concoming the ability of a Reactor Coolant l Pump (RCP) motor to survive a loss of Component Cooling l Water (CCW) cooling for twenty (20) m!nutes. This engineering study was performed due to the inability to locate technical l Information to support RCP operation for 20 minutes without l CCW. 1 OIR 85 was written to address the confilct between FSAR Sections 7.3.2.3.1 and 9.2.2.1.3 regarding the amount of time the RCPs can operate without CCW; FSAR Section 7.3.2.3.1 states the RCPs can run about 10 minutes after a loss of CCW while FSAR Section 9.2.2.1.3 states that in the event of a loss of I cooling water supply, the RCPs can operate without a threat of seizure for about 20 minutes. 1 FSAR Table 1.9 2, which is a historical table added via Amendment 1 in February 1983, documents the differences between the Millstone 3 FSAR and SRP. This table states in regards to SRP Section 9.2.2 that the Millstone 3 Reactor Coolant Pump has not, at this time, been tested to the 20-minute time requirements as specified in SRP 9.2.2, Paragraph II.3.e. The justification provided for this difference is a program that was underway by Westinghouse to comply with the testing l requirements. While developing the resolution for the discrepancy described in OIR 85, an unsuccessful attempt was made to locate the results of this Westinghouse RCP testing. Additionally, CR M3-97-1710 was written on 6-3-97 to address a possible confilci between calculation 678P(R) and the statement in the Millstone 3 Safety Evaluation Report that the RCPs can function satisfactorily for 20 minutes without component cooling water flow. This CR also recommended NU obtain the test results from Westinghouse that confirm the RCPs can survive for 20 mhutes without CCW. As documented in the CR, Westinghouse indicated it would be more difficult to try to compare the rnotor the test was run on than to run the specific Printed 4/13/9810:53:57 AM Page 4 of 6 I

Ntrthext Utilities ICAVP DR Ns. DR-MP3-0626 Millstone Unit 3 Discrepancy Report analysis for the Millstone 3 motors. Therefore, NU agreed to an engineering study by Westinghouse to demonstrate the capability of the RCPs. This CR determined there are no operability or reportability concems. Although not expected, if the engineering study had failed to demonstrate the RCPs could survive for 20 minutes upon a loss of CCW, a new CR would have been initiated to address the issue along with any operability and reportability concems. Westinghouse Letter NEU-98-518, dated February 26,1998, documents the results of the engineering study performed to assess RCP motor performance for 20 minutes following a loss of CCW. The study concludes that if CCW was not restored after 20 minutes, the RCPs could be shutdown, possibly incurring some bearing damage. Additionally, the study determined that if CCW is restored to the RCP motor at the end of a 20 minute loss of CCW transient, and the motor is retumed to steady state conditions, the RCP could continue to operate normally. This Westinghouse letter notes that the bases for the study conclusions and comparisons are actual motor tests performed on a RCP motor similar to the Millstone Unit 3 design. It should be noted that the correction to FSAR section 7.3.2.3.1 is being accomplished via FSARCR 97 MP3-537 and not FSARCR 97 MP3-587. Conclusion NU has concluded that Discrepancy Report DR-MP3-0626 has identified a condition previously discovered by NU which has been corrected. The statement in NU's response to Discrepancy Report DR-MP3-0626 regarding the performance of an engineering study by Westinghouse did not intend to imply that there is a question conceming the ability of a Reactor Coolant Pump (RCP) motor to survive a loss of Component Cooling Water (CCW) cooling for twenty (20) minutes. This engineering study was performed due to the inability to locate technical information to support RCP operation for 20 minutes without CCW. FSAR Table 1.9 2 indicates a program was underway by Westinghouse to comply with the testing requirements specified in SRP 9.2.2, Paragraph II.3.e that demonstrate the RCPs will withstand a complete loss of cooling water for 20 minutes. While developing the resolution for the discrepancy descaibed in OIR 85, an unsuccessful attempt was made to locate the results of this Westinghouse RCP testing. Additionally, CR M3-971710 I was written on 6-3-97 to address a possible conflict between calculation 678P(R) and the statement in the Millstone 3 Safety Evaluation Report that the RCPs can function satisfactorily for 20 minutes without CCW flow. This CR also recommended NU obtain the test results from Westinghouse that confirm the RCPs can survive for 20 minutes without CCW As documented in the CR, Westinghouse indicated it would be more difficult to try to compare the motor the test was run on than to run the specific analysis for the PrWed 4/13/9810:53:58 AM Pa0e 5 of 6

i N:rthert Utilities ICAVP DR NA DR-MP3-0626 Millstone Unit 3 Discrepancy Report Millstone 3 motors. Therefore, NU agreed to an engineering study by Westinghouse to demonstrate the capability of the l RCPs. The CR determined there are no operability or reportability concems. Westinghouse Letter NEU-98 518, dated February 26,1998, documents the results of the engineering study utilizing actual motor tests performed on a RCP motor similar to the Millstone Unit 3 design and confirms the RCP motor can survive for 20 minutes following a loss of CCW. Attachments: FSARCR 97-MP3-537 including Westinghouse Letter NEU ' 518, dated February 26,1998 CR M3-97-1710 Previously identined by Nu? (9) Yes V No Non Discrepent Condition?U Yes (9) No Resolution Pending?O vee G No Resoeuisonunrescoved70 vos @ No Review Acceptable Not accardaMa Needed Date initletor: Neverro, Me* G O O x3 tine VT Leed: Ryan, Thomas J B O O 4me VT Mgr: Schopfer, Don K G O O

1SS8 IRC Chmn: Singh, Anand K G

O O

11m Date:

3/31/98 st. comments: S&L's cornments to NU's first response: We acknowledge that NU had discovered (prior to generation of this DR) that FSARCR 97-MP3-289 did not flag the committment in the SER and that FSARCR 97-MP3 587 has been Initiated to correct FSAR section 7.3.2.3.1 to be consistent with the historical twenty minute committment stated in the SER. Related issues discussed below remain a concem. Based on NU's response Westinghouse is conducting an engineering study to assess RCP motor performance for twenty (20) minutes following a loss of component cooling water. The need for this engineering study implies that there is a question of the plants stated ability to meet the twenty minute committment which obviates the need for provision of automatic protective action. This results in an unreviewed or inadequately reviewed safety question and attendent reportability considerations since the tweny minute committment is not a proposed change but rather a committment which has existed since initial licensing of the plant. A discussion of Licensee actions regarding determination of USQ l and reportability for this specfic issue need to be provided as part. ] of your response to this DR. S&L's comments to NU's second response: NU's second responsa is acceptable. No further action is required. Printed 4/13/9810:54:00 AM Page 6 of 6

I N:rtheast Utilitie3 ICAVP DR N2. DR-MP3-0657 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Rehw EW: S#em Des @ Potential Operability issue Discipline: Electrical Design Om Discrepency Type: ucensing Document @ No SystenVProcess: DGX NRc Significance level: 4 Date faxed to NU: Date Published: 11/24/97 Discrepancy: Descrepancy between Reg Guide 1.9, Design Basis Summary Document & Differential Trip of Generator

== Description:==

Background:

Per Table 1.8-1 of the FSAR NU has committed to Revision 2 of REG GUIDE 1.9 " Selection, Design, and Qualification of Diesel. l Generator Units Used as Standby (Onsite) Electric Power I Systems at Nuciear Power Plants", Revision 2, December 1979 Section B. DISCUSSION states in part: I " Protection of the diesel-generator unit from excessive l overspeed, which can result from a loss of load, is afforded by the immediate operation of a diesel-generator unit trip, usually l set at 115 percent of nominal speed in addition, the generator differential trip must operate immediately in order to prevent substantial damage to the generator..." l Section C.7 of the Reg Guide states in part: 1 " in conjunction with Section 5.6.2.2, engine-overspeed and generator-differential trips may be implemented by a single-channel trip..." l l Paragraph 4.1.15 of Design Basis Summary 3DBS-EDG 001 states. j i "..lf protective features other than engine overspeed and I generator overcurrent are retained during a design basis l accident, two (2) or more independent measurements of these l parameters with coincident trip logic shall be provided." i l l Discussion: l Generator differential relay 87G trips the diesel via lockout relay 86HP. If a design basis event occurs (Sl&'CDA/ LOP) the lockout relay cannot be directly energized because it is blocked by a l contact from relay TSR. The lockout relay will energize through a contact from time delay relay 62G, but only after a delay of 0.05-3.0 seconds, depending on where the timer is set. l The Design Basis Summary Document implies that generator overcurrent and engine overspeed trips shall be treated alike. The I@an (antida indir nfoc thnt anninn nunrennad and nonerntnr ~ ~ Page 1 of 5 Printed 4/13/98 8:42:51 AM i

N:rthe:st Utilities ICAVP DR N:. DR-MP3-0657 Ministone Unit 3 Discrepancy Report j differential trips, not generator overcurrent, are to be treated alike. ] l Conclusion Section B: The second sentence in the paragraph states: "In addition, the generator differential trip must operate immediately in order to i prevent substantial damage to the generator " Since a condition can occur in which the diesel-generator will not immediately trip on a generator differential fault, there appears to be a discrepancy with the Reg Guide. Conclusion Section C.7: The Design Basis Summary Document (DBSD) and the Reg Guide appear to be in disagreement. This is based on a review of the following drawings: ESK-SDR Rev 18 Elem Diag 4.16kV [15G-14U 2] Emergency Diesel Gen Bkr [3 ENS *ACB-G-A] ESK-SDS Rev 18 Elem Diag 4.16kV [15G-15U-2] Emergency Diesel Gen Bkr [3 ENS *ACB-G-B] i ESK-7Q Rev 11 Emerg Diesel Generator Brkr 15G-14U [3 ENS *ACB-G-A] Aux Ckt ESK-7R Rev 11 Emerg Diesel Generator Brkr 15G 15U-2 [3 ENS *ACB-G-B] Aux Ckt ESK-8KC Rev 11 125V DC Emer Diesel Gen Start Ckt 3EGSA01 [3EGS*G A] ESK 8KD Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSAO3 [3EGS*G-A] f ESK-8KF Rev 12 125V DC Emer Diesel Gen Start Ckts Ckt 3EGSB01,2 [3EGS*G-B] ESK-8KG Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSB03 [3EGS*G-B] ESK 8KJ Rev 09 125V DC Emer Diesel Gen Shutdown Ckt 3EGSA06 [3EGS*G-A] ESK 8KK Rev 09 125V DC Emer Diesel Gen Shutdown Ckt l 3EGSBO6 [3EGS*G-B] R.' view Valid invalid h ded Date Initiator: Warner, l. Q [ 11/11197 r 11/11/97 VT Lead: Neri, Anthony A B O J VT Mgt: schopfer, Don K G O O $1'17/97 Printed 4/1398 8:42:55 AM Page 2 of 5

) l N rthext Utilities ICAVP DR N2. DR-MP3-0657 Millstone Unit 3 Discrepancy Report IRC Chmn: Singh, Anand K G O O t 1/'8/97 Date: INVAUO: l l Date: 4/6/98 RESOLUTION: INITIAL RESPONSE: Disposition: NU has concluded that first issue in Discrepancy Report, DR-MP3-0657, has identified a condition not previously discovered l by NU which requires correction. The Emergency Diesel Generator Design Basis Summary (3DBS-l EDG-001) states: "If protective features other than engine l overspeed and generator overcurrent are retained during a design basis accident, two (2) or more independent measurements of these parameters with coincident trip logic l shall be provided". It should have stated: "...... generator differential....". Condition Report (CR) M3-97-4463 was written to provide the necessary corrective action to resolve this issue. Approved Corrective Action Plan (CAP) (attached) and DCN DM3-S-00-190197 were issued to correct 3DBS-EDG-001. f i NU also has concluded that second issue in Discrepancy Report, 1 l DR MP3-0657, does not represent a discrepant condition. The { DR states : " generator differential trip must operate immediately In order to prevent substantial damage to the generator". A 0.2 see time delay (see Calc.12179GM-60-03.421CB, Spec. SPM3-EE 269) is employed, NU considers the 0.2 second trip to be "immediate"in the context of protection against substantial damage. Since the first issue of this DR is the only discrepancy and this is an adrainistrative issue only, NU considers this DR to be a Significance Level 4 issue. { l

== Conclusion:== { l \\ NU has concluded that first issue in Discrepancy Report, DR-MP3-0657, has identified a condition not previously discovered by NU which requires correction. Condition Report (CR) M3, 4463 was written to provide the necessary corrective action to resolve this issue. Approved Corrective Action Plan (CAP) (attached) and DCN DM3-d-00-1901-97 were issued to correct f 3DBS-EDG-001. 1 NU also has concluded that second issue in Discrepancy Report, DR-MP3-0657, does not represent a discrepant condition. The DR states : " generator differential trip must operate immediately in order to prevent substantial damage to the generator". A 0.2 sec time delay is employed, NU considers the 0.2 second trip to be "immediate"in the context of protection against substantial rinm ano Page 3 of 5 Printed 4/13/90 8 42.57 AM ~ ~~ E

N::rtheart Utilities ICAVP DR Ns. DR-MP3 0657 Millstone Unit 3 Discrepancy Report Since the first issue of this DR ls the only discrepancy and this is an administrative issue only, NU considers this DR to be a Significance Level 4 issue. SECOND RESPONSE: Disposition: NU has concluded that the issue reported in discrepancy report, DR-MP3-0657, does not represent a discrepant condition. Per Table 1.8-1 of the FSAR, NU did commit to revision 2 of Reg Guide 1.9. Since the time delay (0.05-3.0 seconds) introduced by relay 62G when a design event (SIS /CDA/ LOP) occurs, could be construed as not being an "immediate response"in relationship to Reg Guide 1.9, section 8.3.1.1.4.2.d of the FSAR defines NU's position. "Under accident conditions tripping of the emergency generator and emergency generator breakers are delayed to allow the emergency generator neutral breaker to clear ground faults and the differential relay to reset." If there was no explanation provided in the FSAR, explaining the variance to Reg Guide 1.9, this issue would have been considered a discrepancy. In Millstone 3 SSER 3 page 8-2, paragraph 8.3.17, it explains that the NRC has reviewed the diesel generator protective relaying which included drawing 12179-ESK-5DS (logic for relay 62G), under accident conditions and meets the staff position. Significance Level criteria does not apply to this issue as it does not represent a discrepant condition. However, the overall discrepancy remains as not previously discovered with a Significance level of 4.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0657, does not represent a discrepant condition. The FSAR clarifies NU's deviation to an immediate tripping of the diesel Generator. Significance Level criteria do not apply as this DR does not represent a discrepant condition. However, the overall discrepancy remains as not previously discovered with a Significance level of 4. Previously identined by NU? O Yes (e) No Non Discrepent Condition?O Yes (9) No Resolution Pending?O Ye. @ No Resolution unresolved?O ve. @ No Review initiator: Wamor, l. N6/98 Printed 4/13/90 8:42:58 AM Page 4 of 5

N:rthext Utilities ICAVP DR Ns. DR-MP3-0657 Millstone Unit 3 Discrepancy Report 8 O O e VT Lead: Nerl, Anthony A B O O e VT Mgt: Schopfer, Don K IRC Chmn: Singh, Anand K Dee: 4/6/98 sL conents: INITIAL COMMENT: Reg Guide 1.9 states: "In addition, the generator differential trip must operate immediately in order to prevent substantial damage to the generator..." Our interpretation of the word "immediate"in conjunction with the use of differential relays is that there is no intentional delay added after the differential relays operate. NU considers the 0.2 second trip to be "Immediate" in the context of protection against substantial damage. Because we can not find documentation that NU's definition of "immediate" is acceptable to the NRC we still consider the second Issue in the Discrepancy report a discrepant condition, l SECOND COMMENT: NU's response is acceptable, ) Printed 4/13/98 8:43:00 AM Page 5 of 5 l

N:rtheast Utilities ICAVP DR N3. DR-MP3-0763 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design p g Discipline: Electrical Design Ow Discrepancy Type: CN (0) No SystemfProcese: HVX NRC Significance level: 4 Date faxed to NU: Date Published: 1/11/98 Discrepancy: Discrepancies involving Voltage Drop Calculations 209E,210E, and 212E

== Description:== A. Comments Which Apply to All Three Calculations 209E (CCN

2, Rev. 0),210E (CCN #1, Rev. 0),212E (CCN #2, Rev. 0):

1. These calculations refer to Calculation NL-038 as the calculation of record conceming minimum motor control center bus voltage. However, Calculation NL-042 Rev. 2 CCN 5

(" degraded voltage") has lower voltage levels than NL-038 as shown below: MCC 209E/210E/212E NL-042 3EHS*MCC1A1 433 volts 427 volts 3EHS*MCC3A1 435 volts 427 volts 3EHS*MCC181 428.6 volts 424.1 volts 3EHS*MCC1A2 430 volts 428 volts 3EHS*MCC3B1 435 volts 430 volts 3EHS*MCC3A2 431 volts 428 volts j J lt is not clear why NL-038 and not NL-042 is referred to as the calculation of record.

2. These calculations state that they are for reference only ("not a living document"). They rio not state what calculation (3) control and evaluate the ehects of future additions, deletions, or changes, only that PDCRs which implement changes will address the voltage drop of the changed circuit.

3. Installed cable lengths, which are documented as attachments to these calculations, are often substituted for cable lengths listed in NU's cable raceway database "M3CBLRWY",

However, "M3CBLRWY" has not been updated to include these installed cable lengths, therefore, it is not clear how NU maintains control to guarantee that the same cable length is used for the same cable in all calculations. Examples of the differences in cable lengths (expressed in feet) are: CABLE NUMBER M3CBLRWY AS-BUILT 3HVPAOC500 15 8 3HVPBPC500 12 8 and 9 (see Calc 210E below) i 3HVPAOK515 175 105 l 3HVPACO516 295 275 3HVPAOC520 135 158 3HVRCOC500 10 8 3HVRAOC502 10 8 MWVRf'ANRio 974 107 A 17 A (cam Anti 9005: hainwi Printed 4/13/98 8:43:37 AM Page 1 of 7 l

r N:rthert Utilittra ICAVP DR N3. DR-MP3-0763 Millstone Unit 3 Discrepancy Report 3HVRCOC512 375 285 3HVRCOC511 630 590 3HVRCOC513 130 120 3HVRAOC595 230 175 ,i 3HVRAOC594 230 160 3HVRAOC591 110 100 3HVRAOC596 150 525 3HVRAOC598 100 100 3HVRBPC581 285 340 l 3HVRBPC580 65 15 i 3HVRCPC525 25 15 3HVRCPC526 228 282 3EGFBPK600 105 210 3BYSNOL600 60 40 3BYSNOL602 65 40 38YSNOL610 45 15 38YSNOL611 45 15 3BYSNOL620 45 30 3BYSNOL645 220 185 l 38YSNOL646 320 185 i 3BYSNPL600 75 40 { l 3BYSNPL602 75 40 3BYSNPL610 50 20 38YSNPL611 50 20 i l 38YSNPL645 180 160 38YSNPL646 180 160 j

4. The vendor drawings and calculations differ from the vendor l

drawings and from each other in the values used for full load current for the dampers. The calculations are not consistent in what type of current is used (i.e., full load or locked rotor) In computing voltage drop for the damper circuits, with Calculations 209E and 210E using fullload current and Calculation 212E j using locked rotor current. Calculation 209E uses the full load current value of 2.2 amps (based on minimum allowable voltage of 102 volts). Calculation 210E uses the fullload current value of 1.92 amps (based on 230 VA + 120 volts). Calculation 212E uses the locked rotor current value of 4.0 amps (based on a memo of a telephone conversation with the vendor attached to j the calculation as Attachment E). These calculation values do l not agree with Vendor Drawings 2472.900-594-2128 and l 2472.900-154-213B which reflect a fullload current value of 2.0 { amps and a locked rotor current value of 10.0 amps. j Calculations 209E and 210E should use the locked rotor current when performing the voltage drop calculations, just as Calculation 212E does, but using the vendors certified drawing data (as it is the most conservative). The test data included in 3 Attachment C of Calculation 212E (this is shown in Attachment H of Calculation 209E and Attachment F of Calculation 210E) indicates that the starting current (locked rator current) is 8.4 amps which disagrees with the data in the te;?ohone conversation. The data in the telephone convursation should only be used (in lieu of the data from the vendor drawings) if a justification is provided to indicate why it is more suitable than the vendors drawina data. Printed 4/13/98 BM40 AM Page 2 of 11

N:rthea:t Utilitie3 ICAVP DR Nr. DR-MP3-0763 Millstone unit 3 Discrepancy Report

5. When converting the primary cable impedance (this is the impedance from the motor control center to the panel step-down transformer) from the primary side of the transformer to the secondary side of the transformer, Calculation 210E considers the transformer boost but Calculations 209E and 212E do not.

Calculations 209E and 212E should be revised.

6. The transformer impedance of the panel step-down transformer neglects the tolerance when determining the ohmic value. A justification for neglecting this tolerance should be stated or the tolerance should be included.

7. These calculations state in their CCN " Reason for Change" that they extracted panel voltages from Calculation 154E, i

however a review of Calculation 154E indicates that it is only a f loading calculation and does not provide voltages. This note [ should be revised. i

8. The current at the panelloads is based on using the nominal 120 voit current rating. This current may not be constant as the panel voltage dips below 120 volts. The current should be based on actual device terminal voltage.

B. Calculation 212E (CCN #2,Rev. 0)

1. Attachment A Page 72 shows the 120 volt source for Dampers 3HVR* MOD 49A,3HVR* MOD 50A,3HVR* MOD 49C1, and 3HVR* MOD 50C1 as Panel 3SCV'PNLR10 which is fed from Motor Control Center 3EHS*MCC1 A2. This disagrees with the One Line Diagram EE 1CC (Rev. 31) and with Calculation 212E, Pages 23-29 which show these dampers as fed from Panel 3SCV*PNL50 (which in tum is fed from Motor Control Center 3EHS*MCC3A2). This appears to be a documentation discrepancy with no impact on the calculation's results.

2. Attachment A, Page 72 shows the 120 volt source for Dampers 3HVR* MOD 498, 3HVR* MOD 49C2, 3HVR* MOD 508, and 3HVR* MOD 50C2 as Panel 3SCV*PNLR1P which is fed from Motor Control Center 3EHS*MCC182. Panel 3SCV*PNLR1P is

) shown on ESK-6AEA (Rev. 6) and ESK-6AEB (Rev. 3) as feeding the relays associated with the dampers. This disagrees with Schematic Diagrams ESK-6AEA and ESK-6AEB which show these dampers as fed from Panel 3SCV*PNL9P. The One Line Diagram EE-1CC also shows these dampers as fed from Panel 3SCV*PNL9P (which in tum is fed from Motor Control i Center 3EHS*MCC3B1), which is the power source used in Calculation 212E, Pages 37-50. This appears to be a documentation discrepancy with no impact on the calculation's results.

3. The minimum voltage used for Motor Control Center 3EHS*MCC3B1 is 435 volts (Pace 39). but Attachment A Pace Printed 4/1398 8:43:41 AM Page 3 of 11

N:rtheast Utilities ICAVP DR N. DR-MP34763 Millstone Unit 3 Discrepancy Report i 72 of Calculation 212E indicates that the voltage used for i 3EHS*MCC3B1 should be 429 volts when evaluating Damper 3HVR* MOD 46B. This would have a nonconservative effect of reducing the voltage at the damper's terminals.

4. On Page 39, the bus-to-neutral voltage is shown as 112.34 volts for Panel 3SCV*PNL9P, but it is shown as 112.33 volts on Page 40. This should be corrected, but this has no impact on the J

results of the calculation, j

5. Page 67 shows Circuit 11 as spare, but One Line Diagram EE-1CG (Rev. 22) and Calculation 154E (Rev.1. CCN 1) shows the loads 3SWP*STR1B and 3SWP*STR1D connected to this circuit. This circuit and the effect of this load on the panel's voltage should be analyzed.

6. The impedance of #12 AWG cable at 90 degrees C is shown in NUSCO Spec. SP-EE-269 as 2.2155 ohms per 1000 feet, but this calculation has used a value of 2.1515 ohms per 1000 feet tnroughout (e.g., Pages 19,20,22, etc.). Since this is a non-conservative error, the computations should be redone.

C. Calculation 210E (CCN #1, Rev. 0)

1. Calculation 210E Page SE shows that, when evaluating Dampers 3HVR* MOD 28A and 3HVR* MOD 46A, the voltage at Motor Control Center 3EHS*MCC3A1 is 431 volts. However, Pages 49A and 59A show the voltage of Panel 3SCV'PNL90 as 112.67 volts which is derived from a motor control center voltage of 435 volts (Page 45), not 431 volts. This leads to less conservative results.

2. Calculation 210E Page 49A has omitted a routing point.

Wiring Diagram EE-12F (Rev. 9) shows Cable 3HVRAOC225 terminating at Junction Box 3JB*2519 (not at Junction Box 3JB*2507 as shown in the calculation), but it also includes Cable 3HVRAPC224 (which is not shown in the calculation) as connected between Junction Boxes 3JB*2519 and 3JB*2507. Cable 3HVRAPC224 is 25 feet in length, has a Cable Mark Number of NHT-32, and is size #14 AWG. This additional cable will reduce the voltage at the damper's terminals.

3. The installed length of Cable 3HVPBPC500 is shown as 8 feet long on Page 82 and 9 feet long on Page 77A.

4. Page 91 shows Circuit 20 as spare, but One Line Diagram EE-1CC (Rev. 31) and Calculation 154E shows loads (e.g.,

3RSS*LE2281) connected to this circuit. This circuit and the i effect of this load on the panel's voltage should be analyzed.

5. Circuit 20 of Panel 3SCV*PNL90 indicates that the current is one amp for load 3SWP*RlY60A, but Calculation 154E shows this load as 2 amps. The appropriate calculation should be Printed 4/13/98 8:43:42 AM Page 4 of 11

N:rthe::t Utilitie3 ICAVP DR No. DR MP3-0763 Millstone Unit 3 Discrepancy Report revised to reflect the actualload current. Note: Using a 2 amp load would reduce the voltage at the load to 103 volts which still satisfies the minimum allowable voltage requirement of 98 volts.

6. On Page 52A, the cable mark number shown for Cable 3HVRAOC674, Mark Number NHN-40, does not exist in the NU Cable Database M3CBLRWY. The mark number for this cable, according to M3CBLRWY, is NHN-48. The calculation should be l

revised to reflect the actual cable installed. Note that the cable size used in the computations agrees with the size in M3CBLRWY (i.e., #14 AWG).

7. On Page 76, the cable Mark Number NHT 77 (triplex 500 MCM) showr for Cable 3SCVBPK045 does not agree with the mark number shown in M3CBLRWY which is NHP-82 (triplex #8 AWG). The calculation should be revised to reflect the actual cable installed. Note that the cable size used in the computations agrees with the size in M3CBLRWY (i.e., #8 AWG).

8. Page 83A Steps 4 and 6 compute the circuit impedance by taking twice the cable length. This is the way to compute impedance for a single phase circuit, however this is a three phase circuit and the circuit impedance for these steps is equal to one times the cable length (Step 8 converts impedance to line-to-line).

9. On Page 76, the primary cable impedance is computed for a

6 AWG cable, but the cable is a #8 AWG cable. The impedance computations shown in Steps 3 and 5 should be deleted as Page 76A now computes these values and, in effect, supersedes Page 76.

D. Calculation 209E (CCN #2, Rev. 0)

1. In Calculation 209E, the minimum voltage for Motor Control Center 3EHS*MCC1 A1 is shown as 432 volts in Step 2 on Page 38 but is shown as 433 volts in Step 8 of Page 38 and on Page 60 of Attachment A.

i

2. The voltage drop is computed by Calculation 209E for the circuit with the longest run from Junction Box 3JB*8609 to j

Dampem 3HVP* MOD 20A,3HVP' MOD 20C,3HVP* MOD 23A, j and 3HVP* MOD 26A. Page 39 uses the cable length of 90 feet for Damper 3HVP* MOD 23A because it states that this damper has the longest circuit length. However, Attachment D (attached i to Calculation 209E as Page 72) states that the length of Cable 3HVPAOC520 from Damper 3HVP* MOD 20A to Junction Box i 3JB'8609 is 158 feet. Since the length of Cable 3HVPAOC520 is longer than the cable from 3JB*8609 to Damper 3HVP* MOD 20A, Cable 3HVPAOC520 should be used. Therefore, the resulting voltage drop of Calculation 209E is not conservative. The effect of using 158 feet instead of 90 feet from Junction Box 3JB*8609 to the dampers is that the damper terminal voltaae is 107.9 volts instead of 108.7 volts, which is Printed 4/13/90 8:43:43 AM Page 5 of 11

1 1 Nrrtheast Utilitiss ICAVP DR N3. DR-MP34763 Millstone Unit 3 Discrepancy Report j still above the minimum allowable of 102 volts and is acceptable.

3. The installed length of Cable 3HVRCOC510 is shown as 197 I

t l feet long on Page 76 and 175 feet long on Page 77. l l

4. Unlike Calculations 212E and 210E, Calculation 209E does not use the panel load from Calculation 154E but instead uses a value greater than the load in Calculation 154E but less than the panel's step-down transformer rating. Calculation 209E should state how this load value is determined (i.e., the basis), since it is I

a different percentage of the transformer rating for the various panels. j

5. There are several numerical errors involving impedances and l

currents in this calculation (as well as Calculations 210E and 212E). For example, on Page 8 Step 3, the primary impedance is computed as 0.2 ohms but should be 0.1 ohms (conservative). On Page 54, Circuit 32 shows the load as 5 amps, but it is shown in Calculation 154E as 0.5 amps (Calculation 209E is conservative).

6. On Page 36 Step 6, the circuit impedance is computed by taking twice the cable length. This is the way to compute Impedance for a single phase circuit, however this is a three phase circuit and the circuit impedance for Step 6 is equal to one times the cable length (Step 8 converts impedance to line-to-line). In Step 8, the drop (4.16 amps times the impedance) should be multiplied by the square root of 3 (reference Page 83 of Calculation 210E). In addition,in Step 4 the primary impedance does not include the effect of the transformer boost when referring it to the secondary side of the transformer. In Step 5 Line 3, the voltage 208 should be squared (it has been squared in the result shown in Step 5, Line 4).

Review Vaud invand Needed Date 4 initiator: Kendelt, D. J. 8 O O 12rin7 VT Lead: Nort, Anthony A B D D 12/9/97 VT Mgr: schopfer, Don K B D D 12/11/97 IRC Chrnn: singh, Anand K g Q [ 1/5/96 Date: INVALID: Date: 4/8/98 RESOLUTION: First Disposition: NU has concluded that Discrepancy Report, DR-MP3-0763,has identified conditions previously discovered by NU which have been corrected. As a result of the corrective actions of CR M3-97-0119 and LER 97-010, numerous problems and inconsistencies were noted in the 120VAC calculations. Consequently, calculations 209E,210E and 212E have been suoerseded by a new calculation 97-ENG-01512E3(attached). All of the items identified are minor in nature and have no effect on the overall outcome of the calculation. These items are not being Printed 4/13/98 8:43:44 AM Page 6 of 11

I N:rthext Utiliti:s ICAVP DR No. DR-MP3 4763 Millstone Unit 3 Discrepancy Report addressed individually since calculation 97-ENG-01512E3 is new and has reverified information and documented allinputs, l methodology and conclusions using today's standards. Therefore, since the inconsistencies in the calculations referenced were prediscovered and the calculations have been replaced, this not a discrepant condition. First

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0763,has identified conditions previously discovered by NU which have been corrected. As a result of the corrective actions of CR M3-97-0119 and LER 97-010, numerous problems and inconsistencies were noted in the 120VAC calculations. Consequently, calculations 209E,210E and 212E have been superseded by a new calculation 97-ENG-01512E3(attached). All of the items identified are minor in nature and have no effect on the overall outcome of the calculation. These items are not being addressed individually since calculation 97 ENG-01512E3 is new and has reverified information and documented allinputs, methodology and conclusions using today's standards. Therefore, since the inconsistencies in the calculations referenced were prediscovered and the calculations have been replaced, this not a discrepant condition. Second Disposition NU has concluded items C.1.a. C.1.b, C.1.c and C.1.e of Discrepancy Report, DR MP3-0763, have identified conditions not previously discovered by NU which require correction. The discrepancies identified on the original submittal of DR-MP3-0763 relcted to calculations 209E,210E and 212E were previously discovered and corrected by the issuance of new calculation 97 ENG-01512E3 and the superseding of the subject calculations. This response addresses those issues identified by Sargent and Lundy's revised Discrepancy Report. summarizes each of the issues identified as " Items Which Are Discrepancies And Are Not Resolved"In the revised DR and provides a disposition to each. Item numbers C.1.a, C.1.b, C.1.c and C.1.e as defined in Attachment 1 are considered valid. The approved corrective action plan for CR M3-I 981610 will revise calculation 97-ENGy01512E3 post startup. As identified in the disposition to Attachment 1, these errors are minor in nature and have no impact on the conclusions of the calculation or the design or licensing basis. Therefore, NU considers these discrepancies to be Significance level 4. NU has concluded that items C.1.d and C2 of Discrepancy Report, DR MP3-0763, do not represent discrepant conditions as indicated on Attachment 1, thorefore, Significance level criteria does not apply to these items. 1 I Second

Conclusion:

PrWed 4/1348 8:43:46 AM Page 7 of 11

1 N:rtheart Utilities ICAVP DR N2, DR-MP3-0763 Millstone Unit 3 Discrepancy Report NU has concluded items C.1.a. C.1.b, C.1.c and C.1.e of Discrepancy Report, DR-MP3-0763, have identified conditions not previously discovered by NU which require correction. The discrepancies identified on the original submittal of DR-MP3-0763 related to calculations 209E,210E and 212E were previously issuance of new calculation 97-ENG-01512E3 and the superseding of the subject calculations. This response addresses those issues identified by Sargent and Lundy's revised Discrepancy Report. Attachment i summarizes each of the issues identified as " items Which Are Discrepancies And Are Not Resolved"in the revised DR and provides a disposition to each. Item numbers C.1.a, C.1.b, C.1.c and C.1.e as defined in Attachment 1 are considered valid. The approved corrective action plan for CR M3-98-1610 will revise calculation 97 ENG-01512E3 post startup. As identified in the disposition to Attachment 1, these errors are minor in nature and have no impact on the conclusions of the calculation or the design or licensing basis. Therefore, NU considers these discrepancies to be Significance level 4. NU has concluded that items C.1.d and C2 of Discrepancy Report, DR-MP3-0783, do not represent discrepant conditions as indicated on Attachment 1, therefore, Significance level criteria does not apply to these items. discovered and corrected by the issuance of new calculation 97 ENG-01512E3 and the superseding of the subject calculations. The originalitems were considered prediscovered and non-discrepant. This second submittel provides information required to address those issues identified by Sargent and Lundy's revised DR which placed the DR in " Follow Up" status. summartzes each of the issues identified as " Items Which Are Discrepancies And Are Not Resolved"in the revised DR and provides a disposition to each. Item numbers C.1.a. C.1.b, C.1.c and C.1.e as defined in Attachment 1 are considered valid. As identified in the disposition to Attachment 1, these errors are minor in nature and have no impact on the conclusions of the calculation or the design or licensing basis. Therefore, NU considers these discrepancies to be Significance level 4 and they will be tracked to completion post-startup by the approved corrective action plan for CR M3-98-1810. NU has concluded that items C.1.d and C2 are not discrepant as indicated on Attachment 1. Attachments - Attachment 1 DR MP3-0763 Followup Response, CR M3-98-1610. Previously identined by NU? U Yes (G) No Non Discrepent Condition?O Yes (9) No Resolution Pending?O Ye.

No Resolution Unresolved?O Yes G No Review Initiator: Kandall, D. J.

VT Lead: Nort, Anthony A Printed 4/13/98 8:43:47 AM Page 8 of 11 J

r N:rtheast Utilities ICAVP DR N3. DR-MP3-0783 Millstone unit a Discrepancy Report ,,m. , ~ '" O O O "8*8 i VI Mgr: schopfw, Don K O O O wicroe IRC Chmn: singh, Anand K O O O Date: 4/8/98 SL commentu: First Response: l l A. ITEMS WHICH ARE DISCREPANCIES AND ARE I RESOLVED: l l l

1. Items A1, B3, C1, and D1: the motor control cen'er vo!! ages have been updated based on CCNs made to Calculations NL-038 (Duke Engineering # VN4500-F02-001) and NL-042 (Duke Engineering # VN4500-F02-003) which were prepared on 7/22/97 through 11/6/97. NU states that thesa items were previously identified, however, these CCNs were prepared after the cutoff date of 6/19/97, therefore, these items are still discrepancies.

2. Items A2, AS, A6, A7, C7, C8, C9, D3, D4, and D6: these items are no longer applicable because Calculation 97-ENG.

t i 01512E3 eliminated the computation of voltage drops from the l motor control centers to the distribution panels (this is now done l by Calculation NL-038). NU states that these items were previously identified, however, Calculation 97-ENG-01512E3 was prepared on 11/12/97 which was after the 6/19/97 cutoff date, therefore, these are still discrepancies.

3. Items A4, AB, B1, B2, B4,85, B6, C2, C3, C4, C5, D2: these items have been resolved by Calculation 97-ENG-01512E3. NU states th.~.hese items were previously identified, however, Calculation 97-ENG-01512E3 was prepared on 11/12/97 which was after the 6/19/97 cutoff date, therefore, these are still discrepancies.

l B. ITEMS WHICH ARE NON DISCREPANT CONDITIONS: I lte m C 6: the damper associated with this item has been disconnected, therefore, Sargent & Lundy concurs with NU that this item is not a discrepant condition. C. ITEMS WHICH ARE DISCREPANCIES AND ARE NOT l RESOLVED: l

1. Item D5: Although Calculation 97 ENG-01512E3 resolved the numerical discrepancy examples cited in DR-MP3-0763 conceming Calculations 209E,210E, and 212E, Calculation 97-ENG-01512E3 has several numerical and formula discrepancies ofits own:

a. The formula shown on Page 12 for determining the voltage across the load device is incorrect. The formula shown is VD1 =

(VS

ZD1) / (ZC1 + ZD1), but it should be VD1 = (VS'
ZD1) /

l Pnnted N13GB 8:43.49 AM Page 9 of 11 i l 1

N:rthe:st Utilities ICAVP DR N2. DR-MP3-0763 Millstone Unit 3 Discrepancy Report (ZC1 + ZD1) based on the following algebraic manipulations: VS' = 11 * (ZD1 + ZC1) = (VD1/ ZD1) * (ZC1 + ZD1) or I VD1 = (VS'

ZD1) / (ZD1 + ZC1)

) Note that VS does not equal VS'. NU should verify what impact this has on the results of { Calculation 97 ENG-01512E3. Sargent & Lundy has reviewed nine random circuits and concludes that this formula must not have been used as Sargent & Lundy's results agree with the results shown on Attachments D1, E1, F1,11, and J1. i f

b. Page 13, Article 4 "Accep%nce Criteria", states that the computed voltage at the device should exceed the minimum voltage required by the device. Most of the voltages at the devices meet this criteria, however, Page 7, Article 2.12 states that it is acceptable for devices to 11 ave computed voltages 0.3 volts below the minimum voltage required by the device due to assumed conservatism in the manufacturer's required minimum voltage requirements. Sargent & Lundy does not believe it is acceptable to have a firm acceptance criteria (such as shown in Article 2.12) but not adhere to it (such as Article 2.12) without adequate justification. The statementin Article 2.12 needs to be substantiated by documented evidence (e.g., manufacturer's written concurrence) or propose a different and substantiated argument (e.g., ambient temperature is lower than the 40 or 90 degree C value which the calculation is based on, the device's power factor is below the assumed 0.8, the unscheduled cable length is less than the assumed 15 feet, etc.) in order to confirm that these safety related devices will be able to function,

c. Page 2a omits Panel 3SCV'PNLR10 (it is shown as 3SCV*PNLP10).

d. Article 2.7 states that the length of unscheduled cable is considered to be 15 feet (or 30 feet of circuit length), however, the resistance used for Panel 3SCV*PNLR1P Circuits 19,20,21, and 22 assumes a 15 foot circuit length (0.0029 W/ foot times 15 feet = 0.004 W) which is non-conservative. Compare the resistance of these circuits with those of Circuit 13 and 23 of l

I Panel 3SCV'PNLR10 (or the other panels) which use 0.09 W.

e. The effective device impedance "Zd" is shown as 30.06 W for 3HVR*RlY10A/RE10A and 3HVR*RlY10B/RE10B in Attachment 11 and 59.41 W for 3HVR*P'.fi9A/RE19A and 3HVR*RiY19B/REibC !. Attachment F1. These values should be essentially the same, however, Attachment 11 incorrectly computes "Zd" by using a device impedance of 60 W for the 'RE" type devices instead of 6000 W (60 W in parallel with 60 W is 30 W; 60 W in parallel with 6000 W is 59 W).

2. Item A3: As far as Calculations 209E. 210E. 212E. and Printed 4/13/96 8:43.51 AM Page 10of it

l \\ l N::rthert Utilitie ICAVP DR No. DR-MP3-0781 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED W'* Potential Operabliity issue Discipline: Mechanical Deshn Om Discrepancy Type: component Data g Systern/ Process: Rss NRC Significance level: 4 Date faxed to NU: ) Date Published: 1/10/98 Discrepancy: Inconsistency betwn design spec & calc for max diff press for RSS motor operated valves l l Descripuon: 3RSS*MOV20A,B,C,D Specification 2362.200-164 Revision 1 shows the maximum design differential pressure for valves 3RSS*MOV20A,B,C,D to be 275 psid. However, calculation CRS-MOV-1382-M3 Revision l 0 identifes the maximum differential pressure to be 295 psid l based on the containment recirculation spray pump shutoff hea1. l l l 3RSS*MOV38A,B Specification 2282.050-676 Revision 1 shows the maximum design differential pressure for valves 3RSS*MOV38A,B to be 275 psid. However, calculation CRS-MOV-1382 M3 Revision 0 identifes the maximum differential pressure to be 295 psid based on the containment recirculation spray pump shutoff head. 3RSS*MOV8837A,B & 3RSS*MOV8838A,B Specification 2282.050-676 Revision 1 shows the maximum design differential pressure for valves 3RSS*MOV8837A,B & 3RSS*MOV8838A,B to be 600 psid. However, calculation CRS. MOV 1382-M3 Revision 0 identifes the maximum differential pressure tc be 626 psid based on the residual heat removal pump shutoff head. Review Valid invalid Needed Date initiator: Feingold, D. J. O O O 12/i2/97 VT Lead: Neri, Anthony A O O O 12/is/97 ( VT Mgr: schopfer, Don K B O O 12/23s7 IRC Cl mn: singh, Anand K G O O 12/31/97 Date: INVALID: Date: 4/9/98 RESOLUTION: Northeast Utilities' First Response Disposition: NU has concluded that Discrepancy Report, DR MP3-0781, has Printed 4/1396 8:44:20 AM Page 1 of 4 )

l { N:rthert Utiliti;s ICAVP DR N. DR-MP3-0781 Millstone Unit 3 Discrepancy Report j identified a condition not previously discovered by NU which requires correction. Approved corrective action plan for CR M3-98-0439 has been issued to revise valve specification 2362.200-l 164 and 2282.050-676 to show the maximum differential pressures from calculation CRS-MOV-1382-M3. This will be completed post startup. The significance Level is concluded to be Level 4 since there is no impact on DB or LB analyses or plant equipment.

== Conclusion:== NU has concluded that Discrepancy Report, DR MP3-0781, has identified a condition not previously discovered by NU which requires correction. The valve specifications will be comp!eted post startup. CR-M3-98 0439 will track this discrepancy. The significance Level is concluded to be Level 4 since there is no impact on DB or LB analyses or plant equipment. Northeast Utilities' Second Response Disposition: NU concluded that Discrepancy Report DR-MP3-0781 identified a condition not previously discovered by NU which requires correction. Calculation CRS-MOV 1382-M3, rev 0, determined maximum differential pressures for valves 3RSS*MOV20A,B,C,D; 3RSS*MOV38A,B; 3RSS*MOV8837A,8; and 3RSS*MOV883A.B. However, specifications 2362.200-164, rev 1 and 2282.050-676, rev 1 were not revised to show the new differential pressures. The approved correct!ve action plan for CR M3-98-0430 has been issued to revise valve specifications 2362.200-164 and 2282.050-676 to show the maximum differential pressures from calculation CRS-MOV-1382-M3. This will be completed post startup. The Significance Level was concluded to be Level 4 since there was no impact on DB or LB ) analyses or plant equipment. In their response to M3-lRF-01448, S&L has requested addit'onal { I justification to demonstrate that the valves can operate a(.nst the maximum differential pressure identified in calculation CRS-MOV-1832-M3, rev 0. The following information is provided as justi'ication that the valves will operate at required. The maximum differential pressures identified in calculation CRS-MOV-1382-M3 for which the motor operated valves can i operate ag0lnst have been included as design inputs in the ( Millstone Motor Operated Valve Program analysis of the performance of each MOV. The appropriate MOV program calculation for each group of valves are the following: 3RSS*MOV20A.B.C.D Calculation 89-094-1030ES rev 2 Pnnted 4/13,98 BR23 AM Page 2 of 4

N:rtheast Utilities ICAVP DR No. DR-MP3-0781 i Millstone unit 3 Discrepancy Report i 3RSS*MOV38A,B Calculation 89-094-0987ES rev 3 3RSS*MOV8837A,B Calculation 89-094-0899ES rev 6 3RSS*MOV8838A,0 Calculation 89-094-0899ES rev 6 All of the above calculations are attached.

== Conclusion:== NU has concluded that Discrepancy Report DR MP3-0781 has identified a condition not previously discovered by NU which requires correction. The valve specifications will be revised after startup to include the maximum differential pressures. The approved corrective action plan for CR M3-98-0439 will track this discrepancy. Calculations justifying the ability for the valve operators to function against the maximum differential pressures of calculation CRS-MOV 1382-M3 are attached. The Significance Level is concluded to be Level 4 since there is no impact on DB or LB analyses or plant equipment. Previously identined by NU? O Yes (*) No Non Discrepant Condition?U Yes (#) No Resolution Pending?O vee @ No Resolution Unresolved?O ve. @ No Review initletor: Feingold. D. J. VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chrnn: singh, Anend K Dete: 4/9/98 sL cornments: Comment on Northeast Uti!lties' First Response Changing the purchase / design specification for the valves does not assure that the valves will operate against the maximum differential pressures identified in calculation CRS-MOV-1382-M3 Revision 0. Additional justification is needed to demonstrate the valves can operate against the differential pressures in calculation CRS-MOV 1382-M3 Revision 0. Comment on Northeast Utilities' Second Response Calculation 89-0944-1030ES Revision 2 uses 45 psid as input for the differential pressure for valves 3RSS*MOV20A,B,C,D. According to NUs resolution to DR-MP3-1047, a 45 psid differential pressure is acceptable because 45 psid is the highest possible " safety relatco" differential pressure for these valves. The opening stroke for valves 3RSS*MOV20A,B,C,D is not considered a safety related function t'ec.1use these valves are normally open prior to receipt of a CDA signe.l. It should be noted that the safety related CDA signal to open valves 3RSS*MOV20A,B,C,D is superfluous because the valves are not qualified to stroke open when the RSS pumps are running; i.e., Printed 4/13/98 8:4424 AM Pege 3 of 4 I L

I N:rth:ct Utilities ICAVP DR N2. DR-MP3-0781 l Millstone Unit 3 Discrepancy Report ) not qualified to the maximum possible valve differential pressure l of 295 psid. I I The closing stroke for valves 3RSS*MOV20A,B,C,D is considered l safety related. The maximum safety related valve differential pressure during valve closure is considered to be 45 psid. This appears to be based on the condition wihere the RSS pumps are not operating and the containment is at maximum pressure. Consequently, valves 3RSS*MOV20A,B,C,D are not qualified to close while the RSS pumps are operating. This is considered i adequate because the valves would require closure only for (1) containment isolation and for (2) emerDency core cooling without containment spray. Containment isolation is a safety related function. Core cooling without containment spray was a safety related alignment prior to implementation of DCR M3-97045. In either case, qualified closure of the valves can be accomplished if the corresponding RSS pump is stopped prior to closing its respective valve. After each valve is closed, the respective RSS pump can be restarted if desired. For containment isolation, both the RSS pump suction and i isolation valves are closed at the same time, thereby negating the effect that the RSS pump has on downstream pressure. For switchover to emergency core cooling prior to DCR M3-97045, the RSS pumps were not stopped prior to closing valves 3RSS*MOV20A,B (Reference procedure EOP 35 ES-1.3 Revision 6). However, valves 3RSS*MOV20A,B are no longer operated in this manner, therefore, closure of these valves a0ainst RSS pump discharge head is no longer a safety related function. Even though Northeast Utilities'second response is found to be acceptable, Sargent & Lundy recommends that calculation 89-0944-1030ES be revised to qualify valves 3RSS*MOV20A,B,C,D for a maximum differential pressure of 295 psid, consistent with j valves 3RSS*MOV8837A,B and 3RSS*MOV8838A,8. As a result of implementing this recommendation, valves 3RSS*MOV20A,B,C,D would be qualified for all possible operating modes, not just safety related operating modes. I l l f Prtnted 4/13/98 e.44:26 AM Page 4 of 4

N:rthea:t Utilitie3 ICAVP DR No. DR-MP3-0789 MmstOne Unit 3 Discrepancy Report j Review Group: System DR RESOLUT)oN ACCEPTED Review Elernent: System Design Potential Operab4Hty issue Discipline: Electrical Design Qy, j Discrepancy Type: calculation @ No l System / Process: DGX NRC Signiccance level: 4 Date faxed to NU: Date Published: 1/11/98 Discrepancy: Discrepancies involving 120 Volt Panel Calculations 151E, 154E,182E, and 211E j l

== Description:== A. Calculation 151E (CCN #6, Rev.1)- VBA Panel Loading {

1. Pages 4,43,82, and 110 of Calculation 161E show the voltage of the regulating transformers as 480-240/120 volts.

This disagrees with the One Line Diagram EE 1BA (rev. 21) which shows the voltage of these trans' ners as 480-120 volts. Calculation 151E needs to be revised. inis discrepancy has no impact on the results of this calculation. j

2. The load on Circuit #6 of Vital Bus Panel 3A (Page 100) is incorrect. Item C multiplies 3 lights by 5 VA per light and arrives at 10 VA, not 15 VA. The load of Circuit #6 should be 65 VA, not 60 VA, which causes the load on Pages 82 (Circuit #1) and 94 (Circuit #6) to be 2496 VA instead of 2491 VA and the total Panel 3VBA*PNL-VB3 load on Page 82 to be 6001 VA instead of j

5996 VA. { B. Calculation 154E (CCN #1, Rev.1)- Dist Panel Loading i

1. Dampers 3HVR* MOD 45B1,3HVR* MOD 45C1, 3HVR* MOD 45B2 and 3HVR* MOD 45C2 are shown as air operated dampers ("AOD"), not motor operated dampers on (Pages 2 & 10), Attachment 10 (Pages 2 & 12),

and Attachment 19 (Items 50 and 62). Note that One Line Diagram EE-1CC (Rev. 31) also shows 3HVR* MOD 4581 and 3HVR* MOD 45C1 as "AOO", but Schematic Diagram ESK 7QZ (Rev. 8) shows then' v ",iOD*, The appropriate documents should be revised tu t. set the correct identification. e

2. Calculations 209E (Rev. O, CCN 2),210E (Rev. O, CCN 1),

and 212E (Rev. O, CCN 2) use load currents or panel loads which are less than those shown in Calculation 154E for the transformers or panels shown below:

a. Calculations 210E (Page 68) and 209E (Page 43) use a load of 12 KVA for Transformer 3SCV*XD10 but the transformer load is 12.983 KVA in Calculation 154E (Calculations 209E and 210E need to use this for the primary current only),

e Calculations 209E (Page 8) and 212E (Page 8) use a load of l 12 KVA for Transformer 3SCV*XD1P but the transformer load is 12.906 KVA in Calculation 154E (Calculations 209E and 212E need to use this for the primary current only). n Entenintinn 910F fPnnoc 7A nrvi 7AA) neme n innii nf 19 KVA Pnnted 4/13/98 8:45:58 AM ~ Page 1 of 10

1 N:rthe:st Utilities ICAVP DR N2. DR-MP3-0789 Millstone Unit 3 Discrepancy Report for Panel 3SCPPNL25P but the panel load is 2.846 KVA in Calculation 154E. i

d. Calculation 210E (Pages 45 and 45A) uses a load of 4.9 KVA for Panel 3SCPPNL90 but the panel load is 5.383 KVA in Calculation 154E.

e. Calculation 212E (Page 39) uses a load of 5 KVA for Panel 3SCPPNL9P but the panel load is 6.221 KVA in Calculation 154E.

f. Calculation 210E (Pages 83 and 83A) uses a load of 12.9 KVA for Panel 3SCPPNLH2B but the panel load is 13.341 KVA in Calculation 154E.

g. Calculations 209E,210E, and 212E should be revised to use the above values from Calculation 154E. This will reduce the voltage at the panels (a non-conservative effect).

The impact of the above discrepancies need to be assessed. C. Calculation 182E (Rev.1, CCN 1)- Panel Voltage Profile

1. In Attachment 1, Pages 55 and 57, the load current at 240 volts is shown as 20.2 amps for 3SCVPNLR10. Calculation 154E (Rev.1, CCN 1) shows that the load is 7,342 VA which equals 30.6 amps at 240 volts. Since the value in Calculation 182E is nonconservative, Calculation 182E should be revised to reflect the actual load from Calculation 154E.

2. In Attachment 1. Pages 59 and 60, the load current at 240 volts is shown as 29.2 amps for 3SCV'PNLR1P. Calculation 154E shows that the load is 7,225 VA which equals 30.1 amps at 240 volts. Since the value in Calculatbn 182E is nonconservative, Calculation 182E should be revised to reflect the actual load from Calculation 154E.

3. Attachment 1 Column 6 is titled "V MIN / KV", however, half of the sheets compute the minimum panel voltage and half of the sheets compute the maximum panel voltage. To avoid confusion and possible misinterpretation of data, Attachment i should be reldentified so that the sheets which compute maximum panel voltage ars labelled as such. An attemative would be to add a clarifying statement to the body of the calculation.

4. Several computed values in Attachment 1 have been incorrectly entered into Tables 2,7 and 8a. In Table 2, the minimum voltage for 3SCV*PNLH2A should be 192.5 volts and not 194 (see Att.1, Page 56), and the minimum voltage for 3SCV*PNLH2B should be 192 volts and not 193 (see Att 1, Page 59 which computes the voltage as 192.5 which should be rounded down for the

minimum voltage" entry). In Table 7, the minimum voltage for 3VBA*PNL-VB3 should be 101 volts and not 118 (see Att.1. Paae 55). In Table 88. the minimum voltaae Printed N13/96 8A6:01 AM Page 2 of 10

f 1 l N:rthea:t Utilitica ICAVP DR N3. DR-MP3-0789 ) Millstone Unit 3 l Discrepancy Report I for 3VBA PNL-6B should be 199 volts and not 200 (see Att.1, Page 51 which computes the voltage as 199.5 which should be counded down for the " minimum voltage" entry) and the maximum voltage should be 201 volts and not 200 (see Att.1, { Page 52). S. In Table 7, the minimum voltage for 3SCA-PNL9N should be 214 volts and not 215 as Attachment 1 computes the voltage for this panel as 214.5, and it should be rounded down for the " minimum voltage" entry.

6. Tables 7 and 8 are misleading in that for some panels, the

" minimum" panel voltage is greater than the " maximum" panel voltage (this is due to the fact that the panes current is sometimes larger for the " minimum" voltage run than for the " maximum" voltage run - see 3VBA*PNL-VB1 for example). The numbers in these tables are not really the minimum and maximum panel voltages but rather the panel voltages when NL-038 is run at the minimum and maximum runs (611 and 603, respectively).

7. In Attachment 11 Page 30, Transformer 3SCV*XD24P is shown as a 480-120/208 transformer, but One Line Diagram EE.

1 AE shows this as a 480-240/120 volt transformer. This node sketch should be cotTected and,if the program is based on the Page 30 configuration, then the program needs to be corrected as well.

8. In Attachment ll Page 33, Transformer 3VBA-XRC-6 is shown as a 60 KVA transformer, but One Line Diagram EE-1BA shows this as a 75 KVA transformer. This node sketch should be corrected and,if the data in the OPAL program is based on the Page 33 sketch, then the program needs to be corTected as well.

9. This calculation uses the results of Calculation NL-038, but Calculation NL-042 is now the calculation of record for minimum bus voltage and should be used for minimum bus voltages (NL-038 should still be used for maximum bus voltages).

10. Assumption #6 provides the demand factors assigned to the panels in this calculation but does not provide the basis for these demand factors. A reference to a calculation such as Calculation NL-025 should be made to identify the basis for the demand factors used in Calculation 182E.

D. Calculation 211E (CCN #3, Rev. 0)- VBA Panel Voltage Drop l

1. This calculation states that it is for reference only ("not a i

living document"). It does not state what calculation (s) control and evaluate the effects of future additions, deletions, or changes, only that PDCRs which implement changes will address the voltage drop of the changed circuit.

2. In CCN #3. the inrush current is considered for the JiO relays Printed 4/13/98 8Mo2 AM Page 3 of 10 l

i Northeast Utiliti:a ICAVP DR Ns. DR-MP3-0789 Millstone Unit 3 Discrepancy Report { ( in Circuit #22 of Panel 3VBA*PNL-VB1 and Circuit #20 of Panel l 3VBA*PNL-VB2. There is no documentation to indicate that l Inrush current has been considered in other circuits, even though l other circuits have relays with inrush currents (e.g., Panel i i 3VBA*PNL VB1 Circuit #10, Panel 3VBA*PNL-VB2 Circuits #10 l and #20. and Bus 1 A Circuit #5 also have J10 relays). The effect of inrush current needs to be addressed for those circuits which have devices with inrush currents.

3. The loading in Calculation 211E does not agree with Calculation 151E (Rev.1, CCN #1). The latest loads are:

j 3VBA*PNL VB1: 11,694 VA ( 97.45 amps @ 120 volts) 3VBA*PNL-VB2: 12,210 VA (101.75 amps @ 120 volts) 3VBA*PNL VB3: 6,001 VA (50.01 amps @ 120 volts) 3VBA*PNL VB4: 2.098 VA (17.48 amps @ 120 volts)

4. These loads will decrease the panel voltage for Panels 3VBA*PNL VB1 and 3VBA*PNL-VB2 as follows (using the I

inverter tolerance of 2.4 volts and the Impedance of 0.083 W / 1000 feet for a #4/0 AWG cable): j 3VBA*PNL-VB1: 117.6 - 1.6 = 116.0 V 3VBA*PNL-VB2: 117.6 - 1.2 = 116.4 V The effect that these lower voltages have on the panet loads needs to be assessed.

5. Calculation 211E computes the panel current using the nominal 120 volt output rating of the Inverter (e.g., see top of Page 19) as opposed to using a reduced voltage of 117.6 volts when incorporating the inverter's tolerance. Calculation 211E considers a reduced inverter output voltage elsewhere in the calculation (e.g., see bottom of Page 19), therefore, the reduced voltage should be used when computing current (both overall panel curTent as well as that of individual load devices), unless it can be documented that the loads fed from the panels are I

constant-current devices (i.e., current is not affected by voltage variations).

6. Using the latest load data from Calculation 151E and the 2.4 voit inverter tolerance, the voltage at 3HVR*FS278 is 104.7 volts and at 3HVR*FSS2B/988 is 104.96 volts (CCN #2 Page 6) which are less that the voltage of 105 required on Page 15 of CCN #2. Note that these occur during a transient condition.

6. On CCN #2 Page 12, the cables used to determine the voltage drop from 3HVR*PNL4B to 3EHS*MCC3B1 and from l

3EHS*MCC3B1 to 3JB*1314 are size #12 AWG cables, however CCN #2 Page 11 shows that the cable from 3EHS*MCC381 to 3JB*1314 is a #14 AWG cable (this was confirmed by review of cable database M3CBLRWY) Using the appropriate cable impedance, plus the latest load data from Calculation 151E and the -2.4 volt inverter tolerance, the voltage at 3HVR*FS52A/98A is 104.96 votts (CCN #2 Paae 12) which is less that the voltaae Printed 4/13/98 8M02 AM Page 4 of 10 l U

N::rthnst Utilitl2s ICAVP DR NA DR-MP3-0789 Millstone Unit 3 Discrepancy Report of 105 required on Page 15 of CCN #2. Note that this occurs during a transient condition.

7. The cable length used on Page 13 for Cable 3RPSAOC505 is shown as 321 feet, however cable database M3CBLRWY shows this cable length as 267 feet. Calculation 151E shows the load for this circuit as 112 VA, not 89 VA. These two discrepancies have no impact on the results of this calculation.

8. On Page 16, the cable number for Circuit #19 is 3VBA10C810 (verified by M3CBLRWY and One Line Diagram EE-11 A, Rev.13).

9. The cable description is missing for Cable 3VBANOK510 (Page 18, Circuit 21). It is 2/C, #12 AWG,1000V, CU.

10. Circe!t #2 on Panel 3VBA*PNL-VB2 is shown as " SPARE" but is shown in Calculation 151E as a 360 VA circuit

] (3RPS*RAKSET6). Therefore, the voltage at the load for this circuit is indeterminate because it has not been evaluated.

11. On Page 25, the cable sizes for Cables 3RPS2WK800, j

3RPS2WK801,3RPS2WV802, and 3RPS2WK803 are shown as

6 AWG, but a review of M3CBLRWY shows that these cables are #12 AWG. This reduces the load voltage to 116.8 volts (Circuit #7) and 112.6 volts (Circuit #8) which are still above the minimum required voltage.

12. On Page 26, the load for Circuit #10 is shown as 89 VA, but Calculation 151E shows this load as 112 VA. This discrepancy has no impact on the results of this calculation.

13. On Pages 36 and 37, the Cable Mark Number is shown as NHP-98, but a review of M3CBLRWY shows that the Cable Mark Number is NHP-97. This discrepancy has no impact on the results of this calculation.

Review Valid invalid Needed Date Intuator: Kendall, D. J. 8 O O 2/18/97 VT Lead: Neri, Anthony A B O O 12/18/97 VT Mgr: schopfer, Don K G O O 12/23es7 IRc Chmn: singh. Anand K Q O O /5'88 Date: INVALID: Date: 4/7/98 RESOLUTION: First Disposition: NU has concluded that Discrepancy Report, DR-MP3-0789, has identified a condition not previously discovered by NU which requires correction. Attachment 1 summarizes each of the issues identified in the DR and provides a disposition. Deficiency Numbers 2,17,18,22,23,26,27,29,31,32,33 and Phnted 4/13/98 6Mo4 AM Page s of 10 l

N:rthe:st Utiliti::s ICAVP DR No. DR-MP3-0789 Millstone Unit 3 Discrepancy Report 34 as defined in Attachment 1 are considered valid. These items are either minor or editorial in nature and do not affect the outcome of the calculation, therefore NU considers these valid ) items to be Significance level 4 issues. The approved corrective action plan for CR M3-98-0378 will track and correct these items post startup. ) NU has concluded that items 1,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,19,20,21,24,25,28 and 30 are not discrepant as l ( indicated on Attachment 1, therefore Significance level criteria l do not apply to these items. ( First Conclusion-i NU has concluded that Discrepancy Report, DR-MP3-0789, has identified a condition not previously discovered by NU which requires correction. Of the 34 items identified on the DR, only 12 are considered valid and require correction. I Deficiency Numbers 2,17,18,22,23,26,27,29,31,32,33 and j 34 as defined in Attachment 1 are considered valid. These items are either minor or editorial in nature and do not affect the outcome of the calculation, therefore NU considers these valid l Items to be Cignificance level 4 issues. The approved corrective action plan for CR M3-98-0378 will track and correct these items post startup. I NU has performed a general calculation review for electrical I calculations to identify significant issues which would require correction prior to restart. While there are clarifications and cleanup items that can be made as well as consolidation and l simplification, these issues do not require completion before I restart and are considered enhancements. l l NU has concluded that items 1,3,4,5,6,7,8,9,10,11,12,13, l 14,15,16,19,20,21,24,25,28 and 30 are not discrepant as l Indicated on Attachment 1, therefore Significance level criteria l do not apply to these items. i l Second Disposition: NU has concluded that Discrepancy Report, DR-MP3-0789, has identified a condition not previously discovered by NU which requires correction. Attachment 1 of M3-lRF-01339 summarizes each of the issues identified in the original DR and provides a disposition. Deficiency Numbers 2,17,18,22,23,26,27,29,32,33 and 34 as defined in Attachment 1 to MS-IRF-01339 are considered valid. These items are either minor or editorial in nature and do not affect the outcome of the calculation, therefore NU considers these valid items to be Significance level 4 issues. The approved corrective action plan for CR M3-98-0378 will track and correct these items post startup. Printed 4/13/98 8 4605 AM Page 6 of 10

N:rthert Utiliti:3 ICAVP DR No. DR-MP3 0789 Mill:t:ro unit 3 Discrepancy Report NU has concluded that items 1,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,19,20,21,24,25,28 and 30 are not discrepant as indicated on Attachment 1 to M3-lRF-01339, therefore Significance level criteria do not apply to these items. This second submittal provides information required to address item 31 identified in Sargent and Lundy's revised DR which placed the DR in ' Follow Up" status. The load currently shown on circuit 2 of 3VBA*PNL-VB2 is shown on circuit 6 of the same panel with circuit 2 shown as " spare". This can be seen in Revision 0 of calculation 211E. The calculation,211E, has never been updated to show the correct configuration. It is not clear why this configuration error occurred. Thus, the circuit in question was analyzed as circuit 6 and the circuit voltage was determined to be acceptable. A CR Change Form has been initiated to CR M3-98-0378 to identify that the load shown on circuit 6 should actually be associated with circuit 2 in calculation 211E, and that the circuit has been analyzed for voltage drop considerations. The corrective action to CR MS-98-0378 will update calculation 211E and ensure that this as well as the other ] identified discrepancies are corrected post startup. There is no Impact to the conclusion of the calculation as the overallloading is unchanged. Item 31 identified in the DR second submittal is a discrepant condition of Significanco level 4 since the licensing and design basis for the circuit involved are unaffected. Second

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0789, has identified a condition not previously discovered by NU which requires correction. Attachment 1 of M3-lRF-01339 summarizes i each of the issues identified in the original DR and provides a disposition. J Deficiency Numbers 2,17,18,22,23,26,27,29,32,33 and 34 as defined in Attachment 1 to M3-IRF-01339 are considered valid. These items are either minor or editorial in nature and do not affect the outcome of the calculation, therefore NU considers these valid items to be Significance level 4 issues. The approved corrective action plan for CR M3-98-0378 will track and correct these items post startup. NU has concluded that items 1,3,4,5,6,7,8,9,10,11,12,13, 14,15,16,19,20,21,24,25,28 and 30 are not discrepant as indicated on Attachment 1 to M3-IRF-01339, therefore Significance level criteria do not apply to these items. l ltem 31 identified in the DR second submittal is a discrepant l condition of Significance level 4 since the licensing and design I basis for the circuit involved are unaffected. The load currently { shown on circuit 2 of 3VBA*PNL VB2 is shown on circuit 6 of the same panel with clicult 2 shown as a

spare". This can be seen in Revision 0 of calculation 211E. Thus, the circuit in question was analyzed as circuit 6 and the circuit voltage was determined to be acceptable. The corrective action to CR M3-98-0378 will Printed 4/13f98 8:46.06 AM Page 7 of 10 l

N::rthert Utilities ICAVP DR No. DR-MP3-0789 Millstone Unit 3 Discrepancy Report update calculation 211E and ensure that this as well as the other identified discrepancies are corrected post startup. There is no impact to the conclusion of the calculation as the overallloading is unchanged. l Attachments - CR Change Form To CR M3-98-0378, Calculation 211E and CCNs 1 through 4 Previously klentified by NU? O Yes @ No Non Discrepent Condition?O Yes (#) ho Resolution Pending70 Yeo @ mo Resoiuinoa un,. iv.d70 Y6: @ No I Review initiator: Kended, D. J. VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K i IRC Chmn: singh, Anand K Date: 4/7/98 sL Comments: First Response: NU states in the disposition and conclusion sections of DR-MP3-l 0789 that items 2,17,18,22,23,26,27,29,31,32,33, and 34 l as defined in NU's Attachment 1 are discrepancies and that CR M3-98-0378 will track and correct these 12 discrepancy items l l post startup. NU's disposition block states that Attachment 1 provides a disposition for each item, however, Attachment 1 does not identify items 26 or 33 as discrepancies and it clearly identifies item 27 as not a discrepancy, therefore, Attachment 1 and the disposition / conclusion do not agree. A copy of CR M3 0378 is attached to DR-MP3-0789, and the attachment to CR M3-98-0378 identifies Items 2,23,26,27,33, and 34 as non discrepant (leaving only 6 items as discrepancies, not the 12 stated in the disposition / conclusion blocks of DR-MP3-0789). Section 5 of CR M3-98-0378 identifies items 23,26,27,33, and 34 as non discrepant (leaving only 7 items as discrepancies, not j the 12 stated in the disposition / conclusion of DR MP3-G769). Since NU's disposition / conclusion states that CR M3-98-0378 will track and correct the discrepancies, NU should ensure that CR j M3-98-0378 is consistent with the disposition / conclusion blocks of DR-MP3-0789. A. ITEMS WHICH ARE NON DISCREPANT CONDITIONS: Items 1,3,24,25, and 30 - Based on clarification provided in NU's response to DR-MP3-0789, Sargent & Lundy concurs that these items are non discrepant conditions. B. ITEMS WHICH ARE DISCREPANCIES AND ARE RESOLVED:

1. Items 4,5,6,7,8,9, and 10: These items have been resolved by Calculation 97 ENG-01512E3. NU states that these Printed N13/98 8A6:07 AM Page 8 of 10 I

N:rthea:t Utilities ICAVP DR No. DR-MP3-0789 Millstone Unit 3 Discrepancy Report items were previously identified, however, Calculation 97 ENG-1 01512E3 was prepared on 11/12/97 which was after the 6/19/97 cutoff date, therefore, these are still discrepancies. (NU states that CR M3-97-0119 and LER 97-010, which were prepared on 1/13/97 and 2/28/97, respectively, pre-discovered these discrepancies, however, these documents addressed auxiliary i power degraded voltage concems and not the specific ] discrepancies identified in items 4,5,6,7,8,9, and 10 of this discrepancy report which are resolved instead by Calculation 97-ENG-01512E.)

2. Item 21: This item has been resolved by CCN #4 to j

Calculation 211E. NU states that this item is not a discrepancy as a result of Calculation 211E CCN 4, however, a search of PORTAUG2 indicates that CCN 4 to Calculation 211E was prepared in December 1997 which was after the 6/19/97 cutoff date, therefore, this is still a discrepancy.

3. Items 11,12,13,14,15,16,19, and 20: These items are no longer applicable because Calculation 97-ENG-01512E3 eliminated the computation of voltage drops from the motor control centers to the distribution panels. The distribution panel voltages are now computed by CCNs 7,8,9, and 10 made to Calculation NL-03 (Duke Engineering #VN4500-F02-001) which were prepared on 7/22/97 through 11/6/97. NU states that these items are not discrepancies because of updated (i.e., CCNs 7,8, 9, and 10) voltage drop and load flow calculations in Calculation NL-038, however, since these CCNs were prepared after the 6/19/97 cutoff date, these items are still discrepancies. (NU refers to CR M3-97-0119 and LER-97-010, which were prepared on 1/13/97 and 2/28/9, respectively, but the specific discrepancies l

Identified in items 11,12,13,14,15,16,19, and 20 of this discrepancy report are resolved instead by Calculation NL-038.) NU's response states that Calculation 182E has been superseded by Calculation NL-038, however, NL-038 Revision 2 CCN 10 still lists Calculation 182E as a reference (see Page 1 of NL-038 CCN 10 and Reference #6.1.17 in NL-038), and a 3/10/98 search of PORTAUG2 shows that (1) 182E is still valid, and (2) NL-038 only supersedes Calculation 227E, not Calculation 182E. 1 C. ITEMS WHICH ARE DISCREPANCIES AND ARE NOT RESOLVED: ltems 2,17,18,22,23,26,27,28,29,31,32,33, and 34 : NU has concluded tnat these items are discrepant conditions and will be tracked and cornpleted under CR M3-97-0378. Since item 31 involves a safety related circuit that has not been evaluated, it remains a Level 3 discrepancy because the results are indeterminate. (Item 31 is the only Level 3 discrepancy in DR-MP3-0789.) Second Response: Printed #13/90 8A629 AM Page 9of io I

N rth2ast Utiliti2a ICAVP DR N3. DR-MP3-0789 Millstone Unit 3 Discrepancy Report l l Based on clarification provided in NU's second response to DR-l MP3-0789, Sargent & Lundy concurs that item 31 can be l l reclassified as a Level 4 discrepancy. NU's second response to DR-MP3-0789 satisfactorily addresses and confirms the population of discrepancies which are considered valid. 1 I l 1 i l l \\ l l f Printed 4/13/98 BA8:09 AM Page 10 of 10 i

f N:rtheart Utilities ICAVP DR No. DR-MP3-0850 MillstDne Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Test Procedure p Discipline: Other Discrepancy Type: Procedure implementaten g l SystenVProcess: DGX NRC Significance level: NA Date faxed to NU: 1 Date Published: 1/22/96 Discrepancy: Procedures for load testing emergency DG use a loading range above that in the Tech Specs l l

== Description:== Per Technical Specification Manual Volume 1, Section 4.8.1.1.2, Paragraph a.6), during the monthly surveillance test it is required ) that the generator is gradually loaded in accordance with manufacturer's recommendations between 4800-5000kW and i operates with a load between 4800-5000 kW for at least 60 l minutes. The operating ban is meant as guidance to avoid routine overioading of the diesel. In Procedures SP 3646A.1," Emergency Diesel Generator A Operability Test" and SP 3646A.2, " Emergency Diesel Generator B Operability Test," it states in Step 4.4.3.c that the generator be l loaded over approximately 10 minutes to between 5000 and l 5100 kW. The procedures contain a caution not to exceed 5100 kW to prevent exceeding the accident rating of 5310 kW and l require that the Engineering Department be informed if the load is greater than 5100 kW (Step 4.4.5). This is outside the range set in the Technical Specifications. It appears that either the procedure or the Technical Specifications should be revised. Review Valid invalid Needed Date initiator: Launi, C. M. O O O $2/18/97 VT Lead: Neri. Anthony A B O O 2its/97 VT Mgr: schopfer, Don K B O O 2/23/97 l lRC Chmn: singh, Anand K O O O 1117/98 Date: INVALID: Date: 4/6/98 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report DR-MP3-0850 does not represent a discrepant condition. l Sargent and Lundy did not have the latest revisions of SP 3646A.1 and SP 3646A.2 when performing their review of these procedures against Technical Specification Surveillance Requirement 4.8.1.1.2.a.6. Sargent and Lundy was provided Revision 12, Change 4, of both procedures SP 3646A.1 and SP 3646A.2 in response to request RFI-009. This was the latest revision of these procedures in effect at that time they were copied on 6-5-97. However, these procedures were in the process of being revised at that time to incorpora. changes ti.;t resulted from Technical Specification Amendmer.t 137. The Printed 4/13/98 8:46:50 AM Page 1 of 3

[ N:rthea:t Utilities ICAVP DR N3. DR-MP3 0850 Discrepancy Report Millstone unit 3 I required changes were subsequently incorporated via Revision 13 to SP 3646A.1 and Revision 12, Change 5, to SP 3646A.2 which were effective on 6-12-97. These revisions were consistent with the current diesel loading range identified in 1 l l Surveillance Requirement 4.8.1.1.2.a.6. The effective date of l the revisions to these procedures was consistent with the implementation date of the amendment (6-12 97). Prior to the issuance of Amendment 137 to Technical r l Specifications, Surveillance Requirement 4.8.1.1.2.a.6 required I the diesel loading to meet or exceed 4986 kW which was consistent with the revisions of procedures SP 3646A.1 and SP 3646A.2 provided to Sargent and Lundy. Amendment 137, l approved by the NRC on 415-97, changed the diesel loading l requirement from a range of greater than or equal to 4986 kW to I the present range of 4800 to 5000 kW. The changes to procedures SP 3646A.1 and SP 3646A.2 were properly implemented, in conjunction with Technical Specification l Amendment 137, within the required 60 days. A review of the latest revision of procedures SP 3646A.1 and SP 3646A.2 (Revision 13, Change 3 and Revision 13, Change 2, respectively) found both are in agreement with Technical l Specification Surveillance Requirement 4.8.1.1.2.a.6. Section 4.4 of each procedure limits the loading of the diesel to between 4800 and 5000 kW and includes a caution that the diesel should l not be loaded to greater than 5000 kW to prevent exceeding the i manufacturer's continuous rating.

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report DR MP3-0850 does not represent a discrepant condition. I Sargent and Lundy did not have the latest revisions of SP l 3646A.1 and SP 3646A.2 when performing their review of these l procedures against Technical Specification Surveillance l Requirement 4.8.1.1.2.a.6. Sargent and Lundy was provided the latest revision of these procedures in effect at that time they j were copied on 6-5-97. However, these procedures were in the i process of being revised at that time to incorporate changes that resulted from Technical Specification Amendment 137. The i required changes were subsequently incorporated via Revision 13 to SP 3646A.1 and Revision 12, Change 5, to SP 3646A.2 which were effective on 6-12 97. These revisions were l consistent with the current diesel loading range identified in l Surveillance Requirement 4.8.1.1.2.a.6. A review of the latest revision of procedures SP 3646A.1 and SP 3646A.2 (Revision 13, Change 3 and Revision 13, Change 2, respectively) found both are in agreement with Technical Specification Surveillance Requirement 4.8.1.1.2.a.6. Section 4.4 of each procedure limits the loading of the diesel to between 4800 and 5000 kW and includes a caution that the diesel should not be loaded to greater than 5000 kW to prevent exceeding the manufacturer's continuous rating. Previously identmed by NU7 Q Yes (*) No Non Discrepant condition?(*) Yes U No Printed 4/13/90 8.46:54 AM Page 2 of 3 1

r l N::rtheast Utilities ICAVP DR No. DR-MP3-0850 Millstone Unit 3 Discrepancy Report l Resolution Pending?O Yes (*) No Resolution Unresolved?O vs. (*) No l Review initiator: Launi, C. M. VT Lead: Neri, Anthony A O e VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anend K Date: 4/6/98 st Comments: A review of the latest revisions of procedures SP 3646A.1 and SP 3646A.2 confirms the NU position that this is not a discrepant condition. These procedures have been revised so that they are r ow consistent with Section 4.8.1,1.2 paragraph a.6) of the l echnical Specifications. Section 3.4.3 of these procedures that die generator should not be loaded to greater than 5000 kW and Section 4.4.4.c limits the loading of the generator during the suivellance test to between 4800 and 5000 kW, 1 l l l l l l l Printed 4/13/98 8 46 56 AM Page 3 of 3

N:rthemt Utilitlea ICAVP DR N3. DR-MP3-1016 Millstone Unit 3 Discrepancy R9 port Review Group: system DR RESOLUTION ACCEPTED Reh Ehnt: SW W Potential Operability issue Discipline: Mechanical Decjgn Om Discrepancy Type: Calculation @ No System / Process: N/A NRC Gignificance level: 3 Date faxed to NU: Date Published: 2/23/98 Discrepancy: Secondary Containment Bypass Leakage Penetrations

== Description:== During review of calculation P(R) 1150, Rev. O " Containment Bypass Leakage Penetrations" the following discrepancies were identified:

1. On page 20 of calculation P(R)-1150, penetration 121 was not considered as a bypass leakage path because a blind flange is attached to the opening of the containment vacuum test line inside the containment. P&lD EM 153A-19 shows the blind flange installed on line 3-CVS-002-34-4. Since this is a class 4 line, penetration #121 should have been considered as a bypass leakage path similiar to penetration #35 & 36,

2. On page 17 of calculation P(R)-1150, penetrations 93,94,95:-

a) calculation references FSAR section 6.3.2.8 for minimum elapsed time from a LOCA signal to the recelpt of the RWST low-low level signal instead of referencing a design calculation.- b) calculation does not provide a reference for the 25'-5" low-low RWST water level. c) Calculation uses a containment pressure of 0 psig at 1000 sec (max ESF) and 2000 sec (min ESF) based on calculation US(B)-273 Rev. 3. Calculation US(B) 273 Rev. 5 & 6 shows a containment pressure of approx. 5.5 psig at 2000 sec (m5 ESF). The top elevation of the piping in the containment is approximately 19'. Calculation needs to address the impact of the higher containment pressure and elevation of the piping Inside containment has on the differential pressure across check valve *V9 and *V3. d) Calculation does not address the time it takes for the upstream and downstream pressure at valve *V9 (or *V3) to equalize and if it occurs before isolation valve *MV8809A/B is manually closed. With stagnant conditions and the isolation i valves open, diffusion of radionuclides back to the RWST should be addressed. I l

3. On page 18 of calculation P(R)-1150, penetrations 91 & 92:-

Calculation uses justification for penetrations 93,94, & 95 to exclude penetrations 91 and 92 as bypass leakage penetrations. Comments on 93,94, & 95 also apply to penetrations 91 & 92.

4. FSAR Table 6.2-65 " Containment Penetrations" identifies bypass leakage penetrations. The table does not include the followlag penetrations that are identified in calculation P(R) 1150 as bypass leakage penetrations: #24,27,39,59,60,99,100, Printed 4/1:V98 8.47:32 AM ab 3

1

i N:rthenct Utilitie3 ICAVP DR No. DR-MP3-1016 M111 stone Unit 3 Discrepancy Report i l 124. l

5. OPS Form 3273 - 3/4.3.6.1.2 Table 3.6.1.2-1 ' Secondary Containment Boundary Bypass Leakage Paths

does not include the following penetrations that are identified in calculation P(R)-

1150 as bypass leakage penetrations: #24,27,28,29,39,99, 100,102,103,104,105,109,110,iii,112,113,114,115,and ) 120. 1 Review Valid invalid Needed Date initiator: Stout, M. D. G 0 0 2ti3ree VT Lead: Nort, Anthony A B O O 2/1x98 VT Mgr: Schopfer, Don K S O O 2tteine IRC Chmn: Singh, Anand K B O O 2/1o/98 Date: INVALID: l Date: 3/30/98 RESOLUTION: NU has concluded that Discrepancy Report, DR MP3-1016, has identified a condition not previously discovered by NU which requires correction. A CCN must be issued to calculation P(R)- 1150 to clarify that penetration 121 is a bypass leakage path, provide correct references for elapsed LOCA signal time duration from receipt of low-low RWST level signal and the elevation for the low-low RWST water level, and the effect of positive containment pressure transient post LOCA on check valves 3RSS*V9 and 3RSS*V3 and reevaluate penetrations 91 and 92 as bypass leakage penetrations. Calculation US(B)-273 provides the containment pressure response follcuing a LOCA. FSAR Table 6.2-65 must be revised to include all of the bypass leakage penetrations determined in calculation P(R)-1150, OPS Form 3273-3/4.3.6.1.2 Table 3.6.1.2-1 must be likewise revised to include all bypass feakage penetrations. The approved corrective action plan for CR M3-98-1048 will track these activities to completion before startup. The discrepancies of CR M3-98-1048 were determined to be reportable to the NRC and will be included in LER 98-007-00 now in preparation for CR M3-98-0467. The Significance Level is considered to be Level 3. Attachments: CR M3-98-1048 w/ approved correction action plan Previously identified by NU7 O Yes (e) No Non Discrepant condition?O Yes (8) No Reeolution Pending?@ Y.. O No Reewunonunreedved?O Yee @ No Review initiator: Stout, M. D. VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/30/98 Printed 4/13/90 e:47:37 AM Page 2 of 3

Nsrtheart Utiliti:s ICAVP DR No. DR-MP3-1016 l e Millstone Unit 3 Discrepancy Report \\ sL comments: Results of CCN to calculation P(R)-1150 are required to determine the final classification level of the DR. l i l l f I i f PrWed 4/13FA 8.47:38 AM Page 3 of 3

i I N rthertt Utilities ICAVP DR No. DR-MP3-1024 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTK)N ACCEPTED Review Element: corrective Action Process p g Discipline: Mechanical Design Om Discrepancy Type: corrective Action implementation gg System / Process: SWP NRC Significance level: NA Date faxed to NU: Date Published: 2/7/98 Discrepancy: Incomplete Closure of UIR 210 and ACR 12880 l

== Description:== UIR 210 identified 3 issues relative to the ability of MOVs, used to isolate the RSS heat exchangers, to close. Issue 1 concemed a discrepancy between the IST flowrates and the MOV cale flowrates. Issue 2 concemed the closure sequence of the inlet and outlet valves. Issue 3 concerned a discrepancy between Chapters 6 and 9 of the FSAR relative to minimum required flowrates. The UlR Form Indicated that Final Disposition of the UlR was to disposition via ACR 12880. ACR 12880 was generated and the Corrective Action Plan referenced A/R 96007043 along with Action numbers -02,-03, and -04. The closure package for ACR 12880 included Discrepancy Closure Request forms for 96007043-01 (the base A/R) and 96007043-02 which addressed part of issue 1 from UlR 210, dealing only with the MOV calcs, but the package did not include the revised calculations. In addition, no closure documents were included in the closure package for ACR 12880 for 96007043-03 or 96007043-04, both of which are required to close out the remainder of Issue i from UIR 210, and are required before startup. In addition to the statement in the UIR that ACR 12880 was to disposition it, another A/R (97009493) was issued. The UIR closure packeage contained a Closure Request Form for 97009493-01 which stated that that ACR 12880, A/R 96007043 - 02, -03, and -04 would address issue 1 of the UlR. Issue 2 of the UIR was to be addressed by an " Attachment 7". This item was identified as A/R ltem 97009493-02 and dealt with a potential change to procedure to specify MOV closure sequence based on the results of items 96007043-02, -03, and -04. Since -03 and - 04 were not closed, there was no closure documentation in the UIR package for 97009493-02. Finally, Issue 3 of the UlR was to be addressed by another Attachment 7 to follow the FSARCR process to completion. An approved FSARCR with backup Info v.as included in the package, but no documentation to indicate closure. Review Valid invalid Needed Date initiator: Tonw6nkel, J. L Q Q 2/2/98 ) VT Lead: Nerl. Anthony A O O 2/2/96 l P h of 3 Printed 4/13/98 8:48:02 AM t i

I N::rtherst Utilities ICAVP DR N2. DR-MP31024 Millstone Unit 3 Discrepancy Report VT Mgr: Schopfer, Don K 8 O O IRC CFmn: Singh. Anand K e O O Date: i INVALID: I Date: 4/g/g8 RESOLUTION: 1st Response: Disposition: NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1024, do not represent discrepant conditions, j ACR 12880 is attached and cleariy contains closure paperwork for A/R 96007043-03. A/R 96007043-02 closure paperwork references calculation SWS-MOV-1380-M3-00, SWS System and Design Basis Review for Motor Operated Valves, which is attached. The calculation determines, in accordance with the Specification for MP3 MOV Program Motor Operated Valve Design Basis Review Calculations, # SP-M3-ME-015, the system and functional design basis condition for Motor Operated Valves (MOVs) in the Service Water System. The calculation shows flow raies at the inlet and outlet RSS heat exchanger to be the same and there was no special sequencing of the valves required. A/R 96007043-04 is not completed to date but is a restart required item. ACR 12880 is not closed and will not be closed until this item is completed. FSARCR 97 MP3-188 has been officially approved and is attached as part of the PI-20 package for UIR 210. A hand written note on the closure package that the item was completed on 7/23/97 making an Attachment 7 unnecessary. Significance level criteria does not apply here as this is not a discrepant condition.

== Conclusion:== NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1024, do not represent disemoant conditions. ACR 12880 is attached and cleariy contains closure paperwork for A/R 96007043-03. A/R 96007043-02 closure paperwork references calculation SWS-MOV-1380-M3-00, SWS System and Design Basis Review for Motor Operated Valves, which is attached. The calculation determines, in accordance with Specification for MP3 MOV Program Motor Operated Valve Design Basis Review Calculations, # SP-M3-ME-015, the system and functional design basis condition for Motor Operated Valves (MOVs)in the Service Water System. A/R 96007043-04 is not completed to date but is a restart required item. ACR 12880 is not closed and will not be closed until this item is completed. FSARCR 97 MP3-188 has been officially approved and is attached as part of the PI-20 package for UlR 210. Significance level criteria do not apply here as this is not a dierenant ennditinn Printed 4/1308 8:48:06 AM Page 2 of 3

N:rthenct Utilities ICAVP DR No. DR-MP3-1024 Millstone unit 3 Discrepancy Report Attachments - Calculation SWS-MOV-1380-M3, ACR 12880, PI-20 Closure Package UlR 210 2nd Response: { Disposition: j NU has concluded that the issue reported in Discrepancy Report, i DR-MP3-1024, does not represent a discrepant condition, in j accordance with the 4/1/98 conference call held with NU and j S&L, evidence that A/R sut> assignment 96007043-04 is a Mode 2 scheduled activity is sufficient to classify DR MP3-1024 as "Pending" status until verification of completion of the action is provided. Attached is the 810 report showing that 96007043-04 is a Mode 2 scheduled item. ]

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, i l DR-MP3-1024, does not represent a discrepant condition. A/R l 9607043-04 is a Mode 2 scheduled activity. DR-MP3-1024 l should be placed in "Pending" status until verification of l completion of the action is provided. Previously identified by NU7 O Yee @ No Non D6screpent Condition?@ Yee O No Resolution Pending?O vee @ No Resolution unresolved?O vee @ No Review l initiator: Tenwinkel. J. L VT Leed: Nerl. Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Dete: 4/9/98 st.Commente: 1st Response: The corrective actions specified by NU, including those completed to date, are acceptable. However, this DR cannot be closed out until all items required for startup have been completed. Per the NU Disposition, item A/R 96007043-04 has not yet been completed. Therefore, this DR will remain open until that item has been submitted and reviewed. Note: If the remaining item is a Mode 2 issue, NU is requested to identify it as l such in the Disposition so that it may be deferred. 2nd Response: S&L concurs with NUs 2nd response which appropriately revises the completion for the only remaining item, i.e. A/R 9607043-04, to a Mode 2 scheduled activity which is outside of the scope of ICAVP. Printed 4/13/98 8.48:07 AM Pege 3 of 3

l N:rthea:t Utilities ICAVP DR Nr. DR MP3-1062 Millstone Unit 3 Discrepancy Report Review Group: Prograrnmatic DR RESOLUTION ACCEPTED l Review Element: Corrective Action Process p Discipline: Mechancel Design Ow Discrepancy Type: Corrective Action implementatbn g l SystenVProcess: DGX NRC Significance level: 4 Date Faxed to NU: Date Published: 2/19/98 Discrepancy: Closure Request for UIR 438 not completely supported by l documents included in closure package j j Descripuon: 1. Closure Request which was provided for UlR 438 (NU tracking i No. 96008116-01) documents that post installation vibration checking during D/G run was not made when AWO MP3 0720 was implemented. To address this item Closure Request j states that vibration of engine, generator and associated systems is checked per per OPS Form 3346A-14 &15. Contrary to the above, OPS forms 3346A-14 &15 provided in the closure package do not contain a check for excessive vibration of engine, generator or associated systems during D/G run.

2. Work performed under AWO M3-92-15905 involved the replacement of lube oil tubing. Vendors (Colt's) letter #948-3800/91, dated 1/15/91 states "the higher frequencies of the stainless tubing runs could possibly be excited by the engine. I therefore believe you should continue your practice of observing the new tubing to detect any such new resonances". Additionally, letter MP-3M-90-87 dated 12/10/90 from NU to Vendor (Manager-Beloit Customer Services), states in part,"when it is Installed, our retest requirements are to observe the tubing during a diesel

{ run to assure vibration is not excessive, i.e., to eliminate any concem of work hardening the stainless steel". Contrary to the above, documentation could not be found in the closure package to show that AWO M3-92-15905 post installation vibration check was made during D/G run. Note: There was evidence of post tubing installation vibration check during subsequent D/G run for the other tubing replacements documented in the closure package Review Valid Invalid Needed Date initiator: Navarro, Mark 8 0 0 2se<9e VT Lead: Ryan, Thomas J B O O 2/s/98 VT Mgt: schopfer, Don K B O O 2/12/98 IRC Chmn: Singh, Anand K 8 0 0 2ri4/98 Date: INVALID: Date: 4/1/98 RESOLUTION: Disposition: NU has concluded that Discrepancy Report DR-MP3-1052 has identified a condition not previously discovered by NU which Printed 4/13/98 8:48.38 AM Page 1 of 2

I N:rthe:st Utilities ICAVP DR N2. DR-MP3-1052 1 Millstone Unit 3 Discrepancy Report requires correction. OPS Forms 3346A-14 & 15 do not address vibration checks. However, during the monthly surveillance runs of the EDG's, the Preventive Maintenance Program for the Emergency Diesel Generators requires inspections to be performed in accordance with procedure MP 3720CB. Specifically, procedure section 4.2, Monthly inspection and Maintenance, requires all extemal tut'ing and piping be checked for signs of chafing. Chafing would be indicative of unusual vibration of the tubing or piping. Given the length'/ time duration from the referenced AWO's in question (1987 and 1992) and the numerous monthly EDG surveillances which have been l performed over this timo duration, it can be concluded that if any excessive tube vibration concems resulting from the work activities of the referenced AWO's, such tube vibration would have been identified and corrected by now. Also, the EDG System Engineer visually monitors almost every EDG run and would initiate Trouble Reports as appropriate based upon his inspection. The approved correction act;on plan for CR M3 4361 will revise the Closure Request for U;R 438 by referencing Procedure MP 3720CB after startup. The G!gnificance Level is concluded to be Level 4, {

== Conclusion:== NU has concluded that Discrepancy Report DR MP3-1052 has 1 identified a condition not previously discovered by NU which requires correction. The Closure Request for UIR 438 will be revised to reference Procedure MP 3720CB to inspect for EDG tube vibration. Subsequent numerous EDG inspections from the i time AWO M3-92-15905 and MP3-87-0720 work was completed I until now indicate no unacceptable tube vibration has occurred as a result of these work orders. The approved corrective action plan for CR MP3-98-1223 will revise the Closure Request for I UIR 438 after startup. The Significance Level is concluded to be j Level 4. Attachments: CR M3-98-1223 w/ approved corrective action plan / Procedure MP 3720CB ) Pre'viously identined by NU? O vos (8) No Non Discrepant Condition?O vos (#) No Resolution Pending?O ve. (*) No Resolution Unresolved 70 ve. @ No Review initiator: sheppard, R. P. VT Lead: Ryan, Thomes J VT Mgr: schopfer, Don K IRC Clwnn: singh, Anand K Date: SL Comments: Printed 4/1398 8 48.42 AM Page 2 of 2

N rthenst Utilitie3 ICAVP DR N2. DR-MP3-1063 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: corrective Action Process p Discipline: Mechanical Design Om Discrepancy Type: Correcove Action implementation g System / Process: Rss NRC Significance level: 4 Date faxed to NU: Date Published: 2/23/98 Discrepancy: Closing MOV20s for Long Term Recirculation

== Description:== UIR 1189 requests clarification of the closing stroke for Valves 3RSS*MOV20A/B/C/D. The valves close for containment isolation and for long term recirculation. Forlong term recirculation: Calculation NM-027-ALL states that two of the valves are closed during switchover. The Pump and Valve Testing Basis Document states that the valve closes if the associated train is rerouted. The UIR changed this document to state that the A & B valves close for { recirculation. The SFR Manual states that only the A & B valves are closed and only valves 3RSS*MOV8837A/B open. The three documents are now in agreement. However, Modification DCR 97045 changed the logic for the system. Valves 3RSS*MOV8838A/B (RSS Loops C & D) may be open for injection or long term recirculation. The modification does not change or address any of the above documents with respect to this issue. Review Vai6d lovalid Needed Date initiator: Langst,D. O O O 2/is/98 VT Lead: Nort, Anthony A B O O 2/17/9e VT Mgr: schopfer, Don K O O O 2/18/98 IRC Chmn: singh, Anand K O O O 2/1me Date: INVALID: Date: 4/6/98 RESOLUTION: Disposition: NU has concluded that Discrepancy Report DR MP3-1063 has identified a condition not previously discovered by NU which requires correction. Contrary to the statement made in DR-MP3-1063 DCR M3-97045, Revision 0, does consider the impact of the changes to l valves 3RSS*MOV8838A-B on plant documents including Calculation NM-027-ALL and the Pump and Valve Testing Basis Document. However, DCR M3-97045 does not identify the need to revise the SFR DBDP. DCM Form 3-2B, for DCR M3-97045, Revision 0, identifies calculations that are affected by the changes made by this DCR Printed 4/13/98 8:49:11 AM Page 1 of 4

N:rthenct Utilities ICAVP DR N2. DR MP3-1063 Millstone Unit 3 Discrepancy Report and provides a description indicating how they are affected. Calculation NM-027 ALL is locluded in this list of affected calculations along with a statenient indicating valves 3RSS*MOV8838A-B have been changed from " Passive" to i " Active" and are now included in Revision 2 to the calculation (

Reference:

DCM Form 3-28, Page 21 of 37). Calculation NM-027-ALL, Revision 3, correctly identifies valves 3RSS*MOV8838A-B as active valves and indicates that they are required to be opened remote manually on the switchover to cold j leg recirculation. ] The Miilstone Unit 3 Pump and Valve Testing Basis Document, Revision 1, Change 2, which was approved 2-6-98, shows valves 3RSS*MOV8838A-B have a safety related function in tha open { position to provide cold a...d hot leg injection flow. A reference to DCR M3-97-045 is provided in the basis document for valves 3RSS*MOV8838A-B. The MP3 Inservice Testing Program was also revised, prior to the issuance of this DR, as a result of DCR M3-97-045 to identify the ASME Section XI testing requirements I for valves 3RSS'MOV8838A-B. I DCR M3-97045 does not identify the need to revise the SFR DBDP. CR M3-98-1023 was written to investigate this discrepancy and to develop corrective action. AR 98003937-02 was generated to track the issuance of a DCN to DCR M3 97045 j to address the required changes to the SFR DBDP. This q assignment is not required to be completed prior to startup. No field modifications will be required. The investigation of CR M3-98-1023 found calculation NM-027-ALL and the Pump and Valve Basis Document still require revision to change the statements for valves 3RSS*MOV20A-D that indicate two of these valves will be remote manually closed during switchover to long-term recirculation. The DCN to DCR M3-97045, that is being tracked via AR 98003937-02, will also address the required changes to the Pump and Valve Basis Document and calculation NM-027-ALL in regards to valves 3RSS*MOV20A D. Valves 3RSS*MOV8838A-B comply with both their licensing and design bases. These valves are correctly identified in plant documents as active valves and are properly included in the inservice testing program. The administrative change required to the system description section of the SFR DBDP to describe the positioning of these valves post accident does not impact the ability of these valves to perform their required functions. It should be noted that DCR M3-97045 is still in progress and has not been tumed over. The DCM allows up to 90 days after the tumover of a system to operations to revise affected f documents. As such, this discrepancy is considered a significance level 4. j Additionally, the required changes to calculation NM-027-ALL and the Pump and Valve Basis Document for valves 3RSS*MOV20A-D, identified during the investigation of CR M3-98-1023. are also considered administrative in nature and do not Printed 4/1398 8A3:14 AM Page 2 of 4

\\ Nnrthea::t Utiliti:o ICAVP DR No. DR-MP3-1063 Millstone Unit 3 Discrepancy Report f impact the ability of these valves to meet their design and licensing basis or perform their required functions. l

== Conclusion:== NU has concluded that Discrepancy Report DR MP3-1063 has identified a condition not previously discovered by NU which requires correction. DCR M3-97045, Revision 0, did consider the impact of the l changes to valves 3RSS*MOV8838A B on Calculation NM-027-1 ALL, and tF oump and Valve Testing Basis Document but did not identify O'. need to revise the SFR DBDP. CR M3-98-1023 was written to westigate this discrepancy and to develop I I corrective action. The investigation of CR M3-98-1023 found l calculation NM-027-ALL and the Pump and Valve Basis Document still require revision to change the statements for valves 3RSS*MOV20A-D that indicate two of these valves will be remote manually closed during switchover to long-term recirculation. AR 98003937-02 was generated to track the issuance of a DCN to DCR M3-97045 to address the required changes to the SFR DBDP, the Pump and Valve Basis Document, and calculation NM-027 ALL. This assignment is not required to be completed prior to startup No field modifications will be required. Valves 3RSS*MOV8838A-B comply with both their licensing and design bases. These valves were correctly identified in plant documents as active valves and are properly included in the Inservice testing program prior to the issuance of this DR as a result of DCR M3-97045. The administrative change required to the system description section of the SFR DBDP to describe the positioning of these valves post accident does not impact the ability of these valves to perform their required functions. It l I should be noted that DCR M3-97045 is still in progress and has not been tumed over. The DCM allows up to 90 days after the tumover of a system to operations to revise affected [ documents. As such, this discrepancy is considered a j significance level 4. Additionally, the required changes to calculation NM-027-ALL j and the Pump and Valve Basis Document for valves J 3RSS*MOV20A-D, identified during the investigation of CR M3-98-1023, are also considered administrative in nature and do not j Impact the ability of these valves to meet their design and i licensing basis or perform their required functions. Previously identifled by NU? O vos (S) No Non Discrepent Condition?Q vos

No Resolution Pending?O vee

No Resolution Unresolved?O ve.

CS) No Review Acceptable Not Acceptable Needed Dete g VT Lead: Nei, Anthony A VT Mgr: Schopfer, Don K IRC Chrnn: Singh, Anand K Printed 4/13/96 *:49:15 AM Page 3 of 4 L

N rthetst Utilitiss ICAVP DR No. DR-MP3-1063 Millstone Unit 3 Discrepancy Report m...... e m.. -, ~,' O O Date: sL Comments: i l l l I l r l PrWed 4/13/98 8:49:17 AM Page 4 of 4 l l l l

Northe:st Utilities ICAVP DR N3. DR-MP3 0434 milistone Unit 3 Discrepancy Report Review Group: P,w. G DR RESOLUTION REJECTED Review Element. Correcove Action Process Diecipline: Operatione O vee Discrepency Type: Correcove Action 9 No System /Procese: Oss NRC Sleniacance level: 3 Date faxed to NU: Date Putdished: 12/7/97 Discrepancy: Conclusions Documented in Technical and Reportability Evaluations for ACR No. 012327

== Description:== Discussion: The subject ACR was written to document that the TSP baskets were found with a volume at less than the fill line that specifies the minimum Technical Specification volume per surveillance procedure SP 3606.10. The Reportability Evaluation relies entirely on a Technical Evaluation MP3-TS-96 210 and it was determined that the issue is not reportable. The followin0 observations form the basis for this discrepancy report: Tiv., eva'uation documents that the baskets were initially filled to me ' tuli line' during RF05 and that there has been " expected settling", although the amount of settiin0 " expected'is not mentioned. The conclusion is made that "since there are no signs of leakage around the baskets, the total mass is still in place, and the baskets are still capable of performing its function *.

1. We disagree (based on the documentation provided in the ACR and Technical Evaluation /Reportability Evaluation) that lack of ' signs of leakage' Is sufficient basis to conclude that the

' total mass is still in place and the baskets are still capable of performing its function". The analysis lacks the necessary confirmation that the initial charge (mass) of TSP was in fact adequate for meeting the functional requirements. This could be done by review of past records (also not mentioned). Had the settling been correctly anticipated, the initial fill would have been Greater to prevent encountering this situation where settling has now occurred to the point that the minimum Technical Specification volume (fill line) is not met. TMs oversight is sufficient to warrant verification that the correct mass was initially charged.

2. With regard to the corrective action for ACR 012327 which was to add more TSP, Safety Evaluations MP3-94-135 Rev.1(Mech./MatJChem.) and ISE/MP3-94-054 Rev.1 which are contained in PDCR MP3-94-135 state in part that a maximum pH of about 11.0 will occur...and a pH of less than 10.5 would be achieved after about 18 minutes. ISE/MP3-94-054 Rev.1 further concludes that "the transit >nt pH behavior does not adversely affect metals, coatings and elastomers in the Containment and the parformance of safety functions is not affected." This statement is based on the conclusions documented in Safety Evaluation MP3-94-135. As noted in Safety Evaluation MP3-94-135, "the important time periods to be munhinted arm ihnca decedhad nhnum when rM le notelda nf the Printed N1MI610:54:38 AM Page 1 of 7

=, N rtheast Utilities ICAVP DR No. DR-MP3 4434 l Millstone Unit 3 Discrepancy Report 1 qualified conditions (i.e.....pH above 10.5), and when the low pressure injection pH is higher than before."

a. Based on NU's conclusion in ACR 012327 documentation that I

the original required mass was still in place, and subsequent addition of TSP to 1/2 inch above the fill line (from the as-found level which was below the fill line), the new greater mass of TSP should be considerd for its potential impact on the peak pH which would be achieved in a DBA requiring recirculation spray. Such consideration is prudent to ensure that conclusions reached in the safety evaluations remain valid after addition of TSP. 1

b. In addition, while periodic makeup of TSP due to compaction or settling was contemplated in the modification (MP3-94-135),

the safety evaluations for the mod do not indicate if the maximum calculated pH (and resultant conclusion of acceptability) included consideration of the additional mass which would be added periodically to account for settling.

c. With regard to the maximum pH which was evaluated to be acceptable in the safety evaluations, it is not clear what initial boron concentration was assumed. it is noted that the maximun tech spec boron concentration of 2900 ppm was used to conservatively define the minmum amount of TSP which would raise pH to greater than or equal to 7.1, however use of the maximum allowable tech spec RWST concentration would not j

be conservative when evaluating the maximum pH for acceptability.

3. In conjunction with items 1 and 2 above, NU should re-evaluate the reportability and significance level of this ACR.

Although the condition was discovesed in Mode 5 when the TSP l baskets function is not required to be operable, all 12 TSP l baskets were initially specified as iNOP by the Shift Supervisor. Then a technical evaluation and reportability evaluation took place. The need to perform these evaluations ( aimed at ensuring that safety functions would be met when operability is questioned or questionable and at determining resultant recostability) Justifies an initial higher significance (eg. at least j level C) especially if there was reason to suspect (and no evidence is provided to the contrary) that the unanalyzed condition could heve existed in an operating mode where the TSP baskets were required to be operable. Review Valid invalid Needed Date initiator: Neverro, Mark G O O iir2oro7 VT Lead: Ryan, Thomes J B O O tir2+s7 VT Mge: Schopfer, Don K G O O 12/i/97 1RC Chmn: Singh, Anand K B O O 2r3/97 Date: 11/19/97 INVAUO: Date: 4/10/98 RESOLUTION: Disposillon Printed N13/9610:54:41 AM Page 2 of 7

Northeast Utilitin ICAVP DR Ns. DR-MP3 0434 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-0434 has i identified a condition not previously discovered by NU which l requires correction. NU has concluded that Discrepancy Report DR-MP3-0434 identifies three concems, one that has not been l l previously discovered by NU which requires correction, and two l that do not represent discrepant conditions. NU concurs with the I significance level 3 assi0ned by Sargent & Lundy for the discrepant condition. Each of these concems is discussed in l detail below. l NU has concluded that item 2 identified in Discrepancy Report DR MP3 0434, relative to the lack of consideration regarding the potential impact of adding one and one-half inches of TSP on the maximum transient pH, is a condition not previously discovered by NU which requires correction. The corrective actions associated with ACR 12327 focused on ensuring compliance with l Technical Specification LCO 4.5.5; the minimum required volume of 974 cubic feet of TSP, was satisfied. The corrective actions for ACR 12327 filled the baskets one-half Inch above the l fill line in anticipation of any future settlement. The corrective actions were accomplished without considering the impact of this additional TSP on the maximum trs,nsient pH. CR M3-98-0459 was written on 128 98 as a result of DR MP3-0434 to address this condition and to develop corrective acuons. The investigation of CR M3-98-0459 found the inpact of the additional mass of TSP on the maximam transient pH was j negligible; however, this determination was based on a calculation that included a mathematical error and a l nonconservative assumption. CR M3 98-1517 was written on 3-19-98 to reevaluate the impact of the additional TSP on the maximum transient containment sump pH to ensure the conclusions reached in Safety Evaluations MP3-94-135, Revision 1, and ISE/MP3-94-054, Revision 1, remain valid. AR 98005945 02 was Generated as part of the approved corrective action plan for CR M3-98-1517 to track the issuance of a l revision to Calculation US(B)-350 to document the increase in mass resulting from the addition of TSP to the TSP baskets. Additionally, this revision will provide a discussion of the affects of the maximum transient pH. This AR will be completed after startup based on the justification, included within NU Memo MP-DE-96-0511, dated 7-16-96, for the acceptalsility of limited exposures of epoxy coatinos to a pH as hi0h as 13.9. No field modifications are required. The investigation of the discrepancy included under item 2 also identified that FSARCR 97-MP3-451 had incorporated a EQ pH range of 4.4 to 11.0 into FSAR Section 3.11B and Appendix 38. The FSARCR utilized Safety Evaluations MP3-94-135, Revision 1, ISE/MP3-94-054, Revision l 1, and the Radiological Safety Evaluation / Significant Hazards l Consideration For MP3 PTSCR 3-16-94, PTSCR 3-29-94 and { PDCR 3-94-135, Revision 1, as the basis for the change. Safety Evaluation MP3-94-135. Revision 1, indicates under

Malfunctions Evaluated" that the pH will be about 11 at the outset and will remain above 10.5 for 3-8 minutes until mixing l

occurs. A reference is made to Stone and Webster Letter SRE-MP3-9402. dated 11 15-94. This letter states the maximum Printed 4/13/961oM42 AM Page 3 of 7 l m

N:rtheast Utilitira ICAVP DR No. DR-MP3-0434 milistone Unit 3 Discrepancy Report recirculation spray pH was evaluated informally and was not documented in a QA Category I calculation since it was outside of the scope of work. The letter further indicates that calculations found the outer recirculation spray suctions in the sump could be pumping solution with a pH above 11 for several minutes after the pumps start which is acceptable due to the short term nature of the transient. The letter also states that if they assume 100% of the spray water is drawn from the vicinity of the TSP baskets, which maximizes the initial spray pH as well as the TSP mixing, the initial spray is somewhat greater than 11 and it remains above 10.5 for approximately 5 minutes. This discrepancy was also included in CR M3 98-0459 for further investigation and the development of corrective actions. AR 98002149 04 was generated as part of the approved corrective action plan for CR M3-98-0459 to track a revision to the FSAR to indicate that the maximum anticipated pH for the initial minutes of the transient is approximately 11. FSARCR 98 MP3 39 was approved on 3/12/98 to complete this corrective action. NU has concluded that item 1 identified in Discrepancy Report DR-MP3-0434, relative to the lack of necessary confirmation that the initial charge of TSP was in fact adequate for meeting the j functional requirements, does not represent a discrepant j condition. NU did confinn, during the Investigation of ACR 12327 that the TSP baskets had been filled to the fill line. NU Memo MP3-TS-96-210, dated May 2,1996, states that when the TSP baskets were initially filled during RFOS, they were only filled up to the fill line. This statement was based on the investigator's review of the completed AWO which not only confirmed the initial charge was to the fill line but also showed that the baskets were not filled above the fill line in anticipation of any settlement. This memo was referenced in the Reportability Evaluation for ACR 12327 as the evaluation that determined that the settling of the TSP since the initial fill in RFO5 had not reduced the mass of TSP available. As indicated in the bases for Technical Specification 3/4.5.5, the required amount of TSP to maintain the containment sump pH above 7.0 is based on mass, however, a required volume is specified, rather than mass, since it is not feasible to weigh the entire amount of TSP in containment. The minimum required volume is based on the manufactured density of TSP. The Technical Specification bases acknowledges that TSP has a tendency to agglomerate from high humidity in the containment building thereby, resulting in an increase in density and a decrease in volume. The bases concludes that estimating the minimum volume of TSP in containment is conservative with respect to achieving a minimum required pH. It should be noted that the location of the fill line, as determined by calculation 3-93-038-0108203, Revision 1, assures a minimum volume of 975 cubic feet is provided when the TSP baskets are filled to the fill line. NU has concluded that item 3 identified in Discrepancy Report DR-MP2-0434, relative to the significance level assigned to ACR 12327 and whether the reportability evaluation for ACR 12327 reached the proper conclusion, does not represent a discrepant condition. The reportability determination performed for CR M3-PrWed 4/13/9810:54:43 AM Page 4 of 7

N:rthenst Utilities ICAVP DR N2. DR-MP3-0434 Millstone unit 3 Discrepancy Report w-0459 (attached) reviewed the bases for the original reportability evaluation performed for ACR 12327 and confirmed the 'non-reportable' conclusion was valid. Regarding the significance level of ACR 12327, procedures RP 4, Revision 1, and NGP 2.40 Revision 1, were utilized to determine the significance level as they were in affect at the time the ACR was written. RP 4, Revision 1, refers to NGP 2.40 cs the Significance Level Model to be used in the ACR process. l l Utilizing the criteria included in NGP 2.40, Revision 1 ACR l 12327 was correctly assigned Significance Level D. This significance level is supported by the initiator's assessment that there were no visible signs of leakage and that the condition was believed to have resulted from settlement which had been l anticipated (

Reference:

Bases for Technical Specification 1 4.5.5). As there was no loss of TSP mass, the safety function would still have been fulfilled. This determination was later confirmed via the Reportability Evaluation for ACR 12327. ( Conclusion NU has concluded that Discrepancy Report DR-MP3-0434 has identified a condition not previously discovered by NU which l requires correction. NU has concluded that Discrepancy Report DR-MP3-0434 identifies three concems, one that has not been previously discovered by NU which requires correction, and two that do not represent discrepant conditions. NU concurs with the l significance level 3 assigned by Sargent & Lundy for the discrepant condition. NU has concluded item 2 identified in Discrepancy Report DR. I l MP3-0434, relative to the lack of consideration regarding the potentialImpact of adding an inch and a half of TSP on the maximum transient pH, is a condition not previously discovered by NU which requires correction. CRs M3-98-0459 and M3 i l 1517 were written to investigate the impact of adding TSP on the maximum transient containment sump pH and to develop l corrective action. AR 98005945 02 was generated as part of the appoved corrective action plan for CR M3-981517 to track the issuance of a revision to Calculation US(B) 350 documenting the increase in mass resulting from the addition of TSP. Additionally, the revision to this calculation will provide a l discussion of the affects of the maximum transient pH. This AR l will be completed after startup based on the justification, included within NU Memo MP-DE 96-0511, dated 716-96, for l limited exposures of epoxy coatings to pH's as high as 13.9. No field modifications are required. The investigation of the I discrepancy included under item 2 identified that FSARCR 97 MP3-451 had incorporated a EQ pH range of 4.4 to 11.0 into I FSAR Section 3.118 and Appendix 3B, although the referenced safety evaluations indicate the transient pH will be about 11 and the document that supported the referenced safety evaluations indicates that a pH of greater than it may be experienced for a short duration. This discrepancy was included in CR M3 0459 for further investigation and the development of corrective actions. AR 98002140 04 was aenerated as part of the approved Printed 4/13/3810:54:44 AM Page 5 of 7 i (

N:rthenst Utilitie3 ICAVP DR N3. DR-MP3-0434 Millstone Unit 3 Discrepancy Report l corrective action plan for CR M3-98-0459 to track a revision to the FSAR to indicate that the maximum anticipated pH for the initial minutes of the transient is approximately 11. FSARCR 98-MP3-39 was approved on 3/12/98 to complete this corrective l action. NU has concluded items 1 and 3, identified in l Discrepancy Report DR-MP3-0434, do not represent discrepant conditions. Regarding item 1, NU confirmed during the investigation of ACR 12327 that the TSP baskets had been filled initially to the fill line and documented this in NU Memo MP3-TS-96-210, dated May 2, 1996. Regarding item 3, the reportability determination i performed for CR M3 98-0459 l reviewed the bases for the original reportability evaluation performed for ACR 12327 and confirmed the 'non-reportable' conclusion was valid. Additionally, the significance level D assigned to ACR 12327 was reviewed by NU and determined to i be correct based on the criteria contained in NGP 2.40, Revision 1, which was in affect at the time the ACR was written. This significance level is supported by the initiator's assessment that there were no visible signs of leakage and that the condition was believed to have resulted from settlement which had been anticipated (

Reference:

Bases for Technical Specification l 4.5.5). As there was no loss of TOP mass, the safety function would still have been fulfilled. This determination was later confirmed via the Reportability Evaluation for ACR 12327. Previously identified by NU7 Q Yes (@ No Non Discrepent Condition?O Yes (9) No Resolution Pending?O yee @ No Resoiution unresoeved?O ves @ No Review initiator: Neverro, Mark O VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 4/10/98 st. commente: Sargent & Lundy concurs with NU's dispositions for items 1 and 3 of this DR. We do not agree with NU's disposition for item 2 as discussed below:

1. NU has Indicated that the AR which was issued to track revision of the calculation US(B)-350 will be completed after startup based on the justification included within NU Memo MP-DE-96-0511 dated 7-16-96. Since the results and impacts of NU's revised calculation are not yet known, the calculation revision (including NU's review / acceptance of results) should be completed before startup to ensure no unacceptable impact on SSCs important to safety, nor impact on the changes described in FSARCR 98-MP3-39.

2. In addition, NU's reportability determination which was performed for CR M3-98-0459 states under item No. 2

" Evaluations into the maximum transient pH following a large break LOCA are on-going, however, there are presently no calculational results which confirm that the unit would be outside its design basis during or after a DBE. If future calculation (s) Printed N13/9810:54:45 AM Page 6 of 7

Northeast Utilities ICAVP DR N3. DR-MP3-0434 Millstone Unit 3 Discrepancy Report determine otherwise, a new condition report and reportability evaluation will be Initiated". A similar statement is made with respect to NU's on going " engineering evaluations to investigate less severe DBE's to confirm both maximum transient pH and ultimate pH are within design basis". Since NU agrees that the issue needs resolution and a calculation revision is required, we do not agree that this design basis issue can be deferred until after startup.

3. Moreover, the NRC has documented in their safety evaluation related to amendment No.115 to MP3 facility operating license NPF-49 (section 2.2) that "the staff reviewed the licensee's calculations and performed its own independent verification."

Accordingly, the results of NU's revised calc may require NRC

review, l

l l l l l Printed 4/13/9810:54:47 AM Page 7 of 7 i

Northeast Utilities ICAVP DR No. DR-MP3-0464 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operatnlity issue Discipline: Mechanical Desi0n Om Discrepancy Type: Calculation g System / Process: Qss NRC Significance level: 3 Date faxed to NU: Date Published: 11/1597 I Discrepancy: Spray Area Calculation ES-229

== Description:== Calculation ES-229 (Rev.1; CCN 1) determines the spray area for each QSS and RSS spray header at standard containment l pressure and at an elevated containment pressure.

1. Pege 12 of the calculation introduces a friction factor. The friction factor is the effectiveness of the spray due to steam, air and other particulates in containment. This factor comes from i

l SWEC Safeguards Generic Calculation PE-125. This calculation l was requested by RFI MP3-278. Response M3-IRF-00222 l l Indicated that Calculation PE 125 could not be found in the NU l System. The conclusions of the calculation appear to be i consistent with the purpose, methodology and inputs. However, i a final conclusion cannot be drawn since Calculation PE 125 is not available. t

2. The calculation modeled the spray pattem for all nozzle l

configurations as circular. The SPRACO charts show that the spray pattem is circular for nozzles pointed straight down. For nozzle configurations pointed 45',60* and 75' up from i horizontal, the spray pattem is elliptical with the width greater i than the length of the spray. The length is in the spray direction. The width is perpendicular to the spray direction. For all other l nozzle configurations, the spray pattem elliptical with the length greater than the width of the spray. The calculation of the spray area for nozzles pointed 22.5' up, l horizontally,22.5* down,45' down and 67.5' down is unaffected by the elliptical spray pattem. The calculation uses the length of spray for the circle diameter. The nozzle configurations as located on each header provide overlapping sprays. Therefore, this is not a concem. I I However, the calculated spray area for nozzles pointed 45' up is overestimated. The calculation uses the average of the length and width of spray for the circle diameter. This overestimates the spray diameter which affects the coverage area. Review Vand invalid Needed Date initiator: Langel, D. O O O 11/3/S7 VT Lead: Neri. Anthony A B O O 11rSS7 VT Mgr: Schopfer, Don K O O O 11/6/S7 IRC Chmn: singh, Anand K G O O 11/11/S7 Date: INVALID: Printed 4/13/9810.55.13 AM Page 1 of 3

f N:rtheast Utiliti s ICAVP DR No. DR-MP3 0484 Millstone Unit 3 Discrepancy Report I i Date: 4/6/g6 RESOLUTION: Disposition: Discrepancy Report, DR MP3-0464, has identified two separate 6 issues. NU has concluded that the second issue (the overestimate of pay pattem coverage for QSS nozzles pointed at 45' up) reported in Discrepancy Report, DR-MP3-0464, has identified a discrepent condition not previously discovered by NU which requires correction. Using an average diameter to represent the actual elliptical pattem for the nozzles spraying 45' up inward will result in a spray pattem which extends further from the header than that supported by the laboratory data. Spray coverage will not be affected if ellipses are drawn in strict accordance with the actual nozzle manufacturer data since these pattems overiap pattems from the adjacent QSS header. Nozzles which are aimed at an angle 45' up are present on QSS header 3-QSS-010-30 2(Z-) at Elevatior: 153 ft (see sawings 12179-EP 79C & D). These nozzles spray inward, toward the center of the containment. The spray pattems created by these l nozzles overlap the spray pattems created by the nozzles aimed outward at an angle 45' down on QSS header 3-QSS-006 ! 2(Z-) at Elevation 168 ft, which is concentric and inside the header at Elevation 153 ft. These headers are separated radially by 23.5 feet. Coverage would be complete even if the smaller l elliptical dimensions had been used for both the 45' up and the j 45' down nozzles. This has been determined based on the radial separation between the headers and on the nozzle spray pattoms from attachment 1 of calculation 12179-ES-229. CR M3-96-0421 has been issued to develop the corrective actions associated with this DR. The corrective action, which will resolve this discrepancy, is to issue a CCN to the calculation using a conservative spray diameter for the 45' up spray nozzles. This is scheduled to be completed after restart. NU considers this to be a significance level 4 discrepancy: this is a minor error that does not significantly affect the results of the calculation. NU has concluded that the first issue (the unavailability of calculation PE-125 to verify a friction factor in calculation ES-229) reported in Discrepancy Report, DR-MP3-0464, does not represent a discrepart condition. PE-125 is a Stone & Webster proprietary calculation provided to support several calculations, potentially for different utilities; therefore, this calculation would not be included in the NU Records System. The calculation is availaNe for viewing in Stone & Webster's Boston office.

== Conclusion:== Discrepancy Report, DR MP3-0464, has identified two separate conditions. NU has concluded that the second issue, regarding the spray coverage for a 45' up QSS nozzle, has ideritified a discrepant ccndition not previously identified. CR M#-98-0421 a o. s -, i.....a em a.mimm es em ,u.m ooumm.... moi. a Printed N13/9610:56:16 AM Page 2 or 3 " - - ' ' " ' ~ ~ ~ ~ " - ' ' ' " ' " - ~ ' ' ' ' ' ' ~ -

\\ l Nrrtheast Utilitiss ICAVP DR No. DR-MP3-4464 Millstone unit 3 Discrepancy Report with this issue. The corrective action to resolve this discrepancy is scheduled to be implemented after restart. NU has concluded that the first issue (the unavailability of calculation PE-125 to verify a friction factor in calculation ES-229) reposted in Discrepancy Report, DR-MP3-0464, does not represent a discrepant condition. The calculation is proprietary and is available for view in Stone & Webster's Boston office. Previously identined by NUr O Yes (9) No NonDiscrepentcondition?Q Yes (9) No Resolution Pending70 vos @ No neemison unres*ed70 vos @ No Review AWN Nt Needed Date initiator: :. angel, D. VT Lead: b ori, Anthony A O m f VT Mgr: S:hopfer, Don K f IRC Chmn: f mgh, Anand K Date: 4/6/96 l l sL commente: 1. The input for the friction factor was substantiated from l Calculation PE-125 by a telephone call with Mr. Frank Ella of l Stone & Webster. Mr. Ella Indicated that the friction factor is really a drag coefficient and is applied to the distance from the i nozzle. Mr.Ella also indicated that there are two curves for the i didg coefficient; one for atmospheric containments and one for sub atmospheric containments. The coefficient for sub-atmopedc containments is 0.54 at 275 'F as reported in the calculation. The coefficient for atmospheric containments is 0.48 at 275 *F. Millstone Unit 3 was a sub-atmospheric containment; i however, this has been changed and the containment is j maintained around atmospheric pressures. Therefore, the i calculation should use 0.46 for the drag coefficient. This results In a smaller spray diameter which is not conservative. l l

2. It is agreed that this error is minor. Updating the calculation l

may be deferred. l l l. l l l i \\ 1 Printed 4/13/9610:55:17 AM Pa0e 3 of 3

l \\ l N rthe:st Utilities ICAVP DR N. DR-MP3-0477 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: System Design p Discipline: Other Om Discrepancy Type: Calculation (S)No System / Process: SWP NRC Significance level: 3 Date faxed to NU: Date Published: 1o/26/97 Discrepancy: Possible improper assumption about leak tightness of fire barriers

== Description:== Calculations No.12179-P(R)-1087, Rev. O, " Control Building Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break,"12179-P(R)-1073, Rev. O, " Maximum Flood Levels i and Effect on Safety-Related Equipment in the Dies! Generator Building," P(R) 1194, Rev. 2, " ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," and 12170-US(B)-287, "PRA Bounding Estimated of Intemal Flooding," calculate the potential flood levels in the various plant buildings. These calculations assume that all fire barriers are water tight. For this assumption to be valid, all of the features in the barrier (penetration seals and fire doors) would need to have a test or analysis demonstrating that they are water tight. In addition, fire doors are usually not water tight and any changes made to a fire door to make it water tight may invalidate the qualification as a fire barrier. Review Valid invalid Needed Date initiator: Leuni. C. M. O O O 10/18'87 VT Lead: Nort. Anthony A 8 O O 10/18/S7 V r Mgr: Schopfer, Don K G O O 1o/2o/97 1RC Chmn: Singh, Anand K B O O 1o/22/97 l Date: INVALID: Date: 4/2/98 RESOLUTION: Disposition: NU has concluded that the issue reported in discrepancy report, DR MP3-0477, does not represent a discrepant condition. No leakage from a building is a conservative position assumption when calculating maximum flood height, therefore, this is not a licensing or design basis concem. However, CR MP3-97 4725 has been initiated as an enhancement to provide the rationale for this assumptionin these calculations. Significance Level Criteria do not apply here a this is not a discrepant condition.

== Conclusion:== NU has concluded that the issue reported in discrepancy Report, DR-MP3-0477, does not represent a discrepant condition. No leakage from the building is a conservative asumtion when calculating maximum flood height. CR MP3-97-4725 has been initiated as an enhancement to review the calculations and clarify assumption selecton. Significance Level Criteria do not apply here as this is not a discrepant condition. Previously identified by NU? U Yee (0) No Non Discrepent Condition?Q Yes (G) No Printed 4/13/9810.55:42 AM Page 1 of 2 l

N::rthe:st Utilities ICAVP DR N:. DR-MP3-0477 Millstone Unit 3 Discrepancy Report Resolution Peexting?O Yee (*) No Resolution Unresolved?O Yee (e) No Review "**d*d initiator: Launi, c. M. O O O = VT Lead: Nerl, Anthony A O O O m VT Mge: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 4/2/98 sL comments: While it is true that assuming that the fire barriers are leak tight is a conservative position for the room where the leak originated, it is not conservative when it comes to flood effects in adjacent rooms especially if the adjacent room contains redundant safety related equipment. The issue of this DR involves the adjacent I rooms and areas. l k l I l l l l l l l I l Printed 4/13/9810.55:46 AM Page 2 of 2

N:rthe st Utilities ICAVP DR N3. DR MP3-0482 Millstone Unit 3 Discrepancy Report Review Group: Syoiem DR RESOLUTION REJECTED Review Element: System Design Potential Operabilityleeue Diecipline: Other Q yo. Diecrepancy Type: Caiculation (G') No system /Procese: SWP NRC significance level: 3 Date faxed to NU: Date Published: 10/26/97 Discrepancy: The floor area for Cubicles Q,T and U is smaller than calculated resulting in a greater flood height

== Description:== As a result of a review of Drawing 12179-EM-28, Rev.14, the floor area of Cubicle "Q" is approximately 442 sq. feet instead of the 599 sq. feet calculated in Calculation No. P(R) 1194, Rev. 2, "ESF Bido Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 24. The dimensions used for the cubicle in the calculation appear to include the wall thickness. Using a floor area of 442 sq. feet results in a flood height of 9.5 feet. Calculation No. P(R) 1194 calculated a flood height of 7 feet. As a result of a review of Drawing 12179-EM48, Rev.14, the floor area of Cubicle "T" is approximately 690 sq. feet instead of the 1121 sq. feet calculated in Calculation No. P(R) 1194, Rev. 2,"ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 28. The dimensions used for the cubicle in the calculation appear to include the wall thickness. Using a floor area of 690 sq. feet results in a flood height of 27 feet. Calculation No. P(R) 1194 calculated a flood height of 22 feet. As a result of a review of Drawing 12179-EM 28, Rev.14, the floor area of Cubicle "U" is approximately 1359 sq. feet instead of the 1465 sq. feet calculated in Calculation No. P(R) 1194, Rev. 2. "ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 28. The dimensions used for the cubicle in the calculation appear to include the wall thickness. Using a floor area of 1359 sq. feet results in a flood height of 18.5 feet. Calcu;ation No. P(R) 1194 calculated a flood height of 17 feet. For Cubicles "T" and "U," this does not change the conclusions of the calculation (pages 30 32). However, Calculation No. P(R) 1194 requires that the wall between Cubicles "Q" and "R" and Cubicles "Q" and "S" be water tight to a height of 7 feet. With the potential of flooding Cubicle "Q" to a height of 9.5 feet above the floor, Cubicles "Q," "R" and "S" could be flooded. Cubicle "R" contains the Loop A RHR pump and Cubicle "Q" contains the Loop B RHR pump. Technical Specifications 3.4.1.4.1 and 3.4.1.4.2 require at least one loop of RHR be operational during Mode 5. A flood in Cubicle "Q" to a height of 9.5 feet would submerge the Loop B RHR pump. Assuming an unsealed penetralon a little more than 7 feet above the floor, the potential exists to flow 1100 cubic feet of water to Cubicle "R." This would flood Cubicle "R" to a height of annrnvimatalv 9 fant nhnum the finnr run in Finuntinn A 8i fanti Printed 4/13/9810:56:22 AM Page 1 of 3

l l Ncrtherst Utiliti:o ICAVP DR Ns. DR-MP3-0482 Millstone Unit 3 Discrepancy Report The Loop A RHR pump is located at Elevation 9' 3 3/4" (See Calculation No. P(R) 1194, Rev. 2, Attachment 2, page 3) or 4' 9 3/4" above the floor. Therefore, both RHR pumps would not be affected by such a flood. The floor areas in this calculation were also used as input to Calculation No. 94-ENG-1013-M3, Rev.1. Review VeW Invalid Needed Date initiator: Launi, c. M. O O O 0/' *S7 VT Leed: Neri, Anthony A B O O 10/15/07 VT Mor: schopfer, Don K O O O ior2oe97 8 O O io/2iro7 IRC Chmn: Sin 0h, Anand K Date: i INVAUO: 1 Date: 4/7/98 RESOLUTION: Disposition: l NU has concluded that the issue reported in Discrepancy Report, l DR MP3-0482, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-97-4360 will correct calculation 12179-P(R)-1194 to address the reduction in floor area due to wall thickness post startup. The specific discrepancy noted for i i cubicle 'Q* has been reviewed. As a result of other conservatism in the calculation it has been determined that there is no impact on the flood elevation in cubicle "Q'. On page 24 of the calculation it is noted that the segment of the floor area l adjacent to the containment structure was neglected iri the calculation, apparently for the ease of calculation. Add!ng this l aies which was neglected and subtracting the area occupied by the wall thickness results In a gross area equal to that presented In the exist..,g calculation and accordingly there is no change in ~ floodilig level for cubicle 'Q'. NU concurs with S&L that the area discrepancies for cubicles "T" and 'U' do not impact the l calculational results. Therefore there is no impact on the licensing or design basis and NU has concluded that this i discrepancy is a Significance Level 4. l l

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR MP3-0482 has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-97-4360 will correct calculation 12179-P(R)-1194 to address the reduction in floor area due to wall thickness post startup. It has been determined that the discrepancies do not affect the conclusions of the flooding calculations and therefore do not impact the licensing or design bases. NU has concluded that this discrepancy is a Significance Level 4. Previously identifled by NU? U Yes @ No Non Discrepant Condition?U Yes @ No Resolution Pending?O vos @ No Resolution Unresolved?O vos @ No Review Printed N13/9010:56:26 AM Page 2 of 3

N::rthe:st Utilities ICAVP DR N3. DR-MP3-0442 Millstone Unit 3 Discrepancy Report Initletor: Leuni, C. M. O b b VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K utc chmn: Singh, Anand K i Date: 4/7/g8 l sL cormwnts: This response is not acceptable. A review of drawing 12179-EB-10D (25212 24121) indicates that the floor area adjacent to the l containment structure neglected in calculation 12179-P(R)-1194 is smaller than the area of the wall thickness included in the calculation. The calculation should be revised to determine the effect of not including the wall thickness and including the area adjacent to the containment structure or confirmig that there are no penetrations or unsealed penetrations above the calculated 7 foot flood height. The Significance Level remains at 3. l l l 1 1 l i l Printed 4/13,9010.56:29 AM Page 3 of 3 ) J

N rtheast Utilities ICAVP DR No. DR-MP3-1044 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operstwitty leeue Diecipline: Mechanical Design Om Discrepency Type: Component Date g System / Process: NEW NRC SWe level: 3 Date faxed to NU: Date Putwished: 2/23/96 Discrepancy: New valves added by DCRs M3-97042,97045, & 97094 l

== Description:== The FSAR contains specific requirements with respect to design of valves in the emergency core cooling systems. l New valves have been added to the containment recirculation l spray system as follows: 1. DCR M3-97094 adds new safety related gate valves 3RSSN890,891,892,893. II. DCR M3-97042 adds new safety related gate valves 3RSSN895,897, 111. DCR M3-97045 adds new safety related gate valves 3RSSN899,901,902,903, 904,905,906, and safety related check valves 3RSSN907,908, 909,910. l l The valves listed above are procured to design specification SP-1 ME 574. Design drawings for these valves, excluding valves j 3RSSN890,891,892,893, have not been entered into the Millstone Unit 3 drawing system. Drawing 2282.150 713-016 is added by DCNs DM3-00187197 and DM3 00-1872 97 for valves 3RSSN890, 891,892,893. Based on the information in specification SP-ME 574 Revision 0 and the available drawings for the new valves, discrepancies against system requirements are identified as follows:

1. Use of stainless steel is in accordance with Regulatory Guide 1.44.

(FSAR Section 6.1.1.1, and Tables 1.8 1 & 1.8N-1) Compilance with the requirement for all new valves cannot be confirmed.

2. Cold-worked austenitic stanless steels do not have a yield strengh in excess of 90,000 psi.

(FSAR Section 6.1.1.1) Compliance with the requirement cannot be confirmed for components of gate valves 3RSSN895,897,899, 901,902,903,904,905,906, and check valves 3RSSN907,908,909,910, (excluding the body & bonnet of the gate valves and excluding the body of the check valves). The valve stem and bonnet studs for valves 3RSSN890,891,982,893 are ASTM A-564 Type 630. The yleid stress for this stainless steel is greater than Printed N13/9810:57:06 AM Pege 1 of 5

N:rtheart Utliitias ICAVP DR Ns. DR-MP3-1046 Millstone Unit 3 Discrepancy Report

3. Valve stem materials are corrosion & scoring resistant I

and have hi0h tensile strenQth. (FSAR Section 6.3.2.4) l Compliance with the requirement cannot be confirmed for i gate valves 3RSSN895,896,899,901,902,903,904, l 905,906.

4. Valve seating surfaces are hard faced with Stellite number 6 or equivalent.

(FSAR Section 6.3.2.4) Compliance with the requirement cannot be confirmed for gate valves 3RSSN895, 897, 899, 901, 902, 903, 904, 905,906, and check valves 3RSSN907,908,909,910. j S. Check valves are spring loaded lift piston for sizes 2 inches & smaller. (FSAR Section 6.3.2.2.5) Compilance with the requirement cannot be confirmed for check valves 3RSSN907,908,909,910.

6. Manual gate valves employ a straight through wedge desiQn with either split or solid wed0s.

(FSAR Section 6.3.2.2.5) Compliance with the requirement cannot be confirmed for ] gate valves 3RSSN895,897,899,901,902,903,904, 905,906, 7, Aluminum and zinc are not used in safety related components that function post accident. (FSAR Section 6.1.1.2) Compliance with the requirement cannot be confirmed for components of gate valves 3RSSN895,897,899,901, 902,903,904,905,906 and check valves 3RSSN907, 908,909,910, (excluding the body & bonnet of the gate valves and excluding the body of the check valves).

8. Materials employed for components of ESF systems are in accordance with FSAR Table 6.1-1.

Compliance with the requirement cannot be confirmed for components of gate valves 3RSSN895,897,899,901, 902,903,904,905,906 and check valves 3RSSN907, 908,909,910, (excluding the body & bonnet of the gate I valves and excluding the body of the check valves). The valve yoke nut, packing nuts, and bonnet studs for valves 3RSSN890,891,982,893 are ASTM B-183, i A 582, and A 564 Type 630, respectively. These materials do not conform to FSAR Table 6.1-1 for their respective parts. Printed 4/139810:57.0e AM Page 2 of 5

N:rthestt Utilities ICAVP DR No. DR-MP3-1046 Millstone unit 3 Discrepancy Report

9. High quality coatings are applied to items with small surface areas (e.g., valve hand wheels).

{ (FSAR Section 6.1.2.2) Compliance with the requirement cannot be confirmed for gate valves 3RSS*V895,897,899,901,902,903,904, 905,906.

10. Manual gate valves have backseat and outside screw and yoke constnJction. Containment recirculation i

system valves are selected to reduce potential leakage. (FSAR Sections 6.3.2.2.5 & 6.2.2.2., respectively) Compliance with the requirement cannot be confirmed for j gate valves 3RSS*V895,897,899,901,902,903,904, i 905,906. No backseat can be identified on valves 3RSS*V890, 891,982,893. Review Valid invand Needed Date initiator: Feingold. D. J. O O O 2iisse VT Lead: Nort, Anthony A B O O 2ti7/se VT Mgt: schopfer, Don K B O O 2/1a/9e lRC Chmn: Singh, Anand K B O O 2tisse Date: INVALID: Date: 4/6/98 RESOLUTION: Disposition: NU has concluded that Item # 2 of Discrepancy Report DR-MP3-1046 has identified a condition not previously discovered by NU which requires corTection. The approved corrective action plan for CR M3-98-1025 requires the FSAR to be revised after startup to clarify the appropriate appilcability or exclusion of the material limitations within the ECCS per the response to DR MP3-0613 (MS-IRF-01153). The DB or LB of MP3 is not impacted by this discrepancy and the Significance Level is considered to be Level 4. NU has concluded that identified items 1 and 3 thru 10 of Discrepancy Report DR-MP31046 are not discrepant, but reflect work in progress. These items will be verified as part of the individual project close-out per the Design Control Manual prior to startup. However, the approved corrective action plan for CR M3-98-1025 will provide an additional assurance of completion of the verification of each item by requiring review of the valve design data shown on the valve drawings and re-verifying compliance to the FSAR criteria, items 1 and 3 thru 10 will be completed prior to startup. The valve characteristics required to determine compliance with the FSAR criteria is contained in the following DCN's. Those DCN's which have been transmitted to S & L are so indicated. DCR's M3-97094, - Printed 4/13/9810:57:10 AM Page 3 of 5

N:rthmst 'Jtilities ICAVP DR N2. DR-MP31048 Mill'M

3 Discrepancy Report 97042, and - 97045 remain open and will be closed out prior to startup.

3RSSN890,891: DCN DM3-00-187197, RF1-833/lRF-1718, TRA-215,2/7/98 3RSSN892,893: DCN DM3-00-1872-97, RF1-833/lRF-1716, TRA-215,2/7/98 3RSSN895,897: DCN DM3-00-814 97 & DCN DM3-00-613-97, both sent RFI 843/lRF 1423, TRA 207,1/30/98 3RSSN899,901,902,903,904,905,906: DCN DM3-001926-97 Attached to this IRF 3RSSN907,908,909,910: DCN DM3-01 1926-97 Attached to this IRF Significance Level Criteria does not apply to items 1 and 3 thru 10 since there are no discrepancies.

== Conclusion:== NU has concluded that item #2 of Discrepancy Report DR-MP3-1046 has identified a condition not previously discovered by NU which requires correction. Discrepant item 2 will be Implemented after startup as described in the response to DR-MP3-0613 (M3-IRF-01153). The DB or LB of MP3 is not impacted by this discrepancy and the Significance Level is concluded to be Level 4. NU has concluded that items 1 and 3 thru 10 of Discrepancy Report DR MP3-1046 has identified conditions not considered to be discrepant but reflect work in progress. These items will be verified as part of the project closed-out per the Design Control Manual prior to startup. The approved corrective action plan for CR M3 98-1025 for items 1 and 3 thru 10 will provide additional assurance of verification by requiring the review of valve design data and re-vorification of compliance to the FSAR criteria. S!anificance Level Criteria does not apply since there are no discrepancies. Previously klentined by NU7 O Yes @ No Non Discrepent Condition?O Yes @ No Resolution Pending?O vos @ No Resolution Unresolved?O vos @ No Review initiator: Feingold, D. J. VT Lead: Neri, Anthony A VT Mgr: setgfer, Don K 1RC Chmn: singh. Anand K Date: 4/6/98 SL Comments: Confirmation cannot be made that the subject modifications comply with the listed FSAR requirements without knowing the design details for the new valves added by the modifications. These design details would normally be provided by vendor drawings and/or purchase specifications. This information is not provided for the referenced valves added by the subject modifications. Printed 4/13/9810:57:12 AM Page 4 of 5

N:rthertt Utilities ICAVP DR N. DR-MP3-1046 Mllistone Unit 3 Discrepancy Report Northest Utilities states that the missing design Information is not required at this time because the modifications are still in progress, according to the Design Control Manual. Design Control Manual Revision 5, page 22 of Chapter 3, states, " Design change close-out shall be completed within 90 days of final Engineering Release for Operction". Page 6 of Chapter 1 states that this close-out includes procedures, lists, and databases. DCM Form 3-2B, Section IV, is the Design Change Close Out. No items In this section apply to update of vendor drawings or purchase specifications. No statements can be identified in the Design Control Manual that apply the 90 day close-out period to vendor drawing and purchase specification changes and additions. According to NU, vendor I drawings are updated in the same manner as other design drawings. Therefore, Sargent and Lundy considers the Design l Control Manual to require inclusion of identified vendor drawings and purchase specification additions and revisions in modification j l DCNs prior to issue for implementation. Only after these l documents are updated can an evaluation be completed on the i new valves with respect to the FSAR requirements l l l Printed N13/9610:57:13 AM Page 5 of 5

N:rtheast Utilities ICAVP DR No. DR-MP3-0876 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED RevMW: S#em W Potential Operability lasue Discipline: Mechanical Design Ow Discrepancy Type: Calculation @ No System / Process: HVX NRC Significance level: 3 Date faxed to NU: Date Published: 1/17/98 Discrepancy: Seismic reports are not available for ICAVP review for the following equipments.

== Description:== (1) 3HVR*RE10NB,19NB: Seismic report # K-84 50/16435 does not qualify the equipment mounting. (2) 3HVR* MODI 40A/B. Report requested per RFl#756, item #3. NU response in IRF#1175 provided qualification report j number 730.1.140. This report does not address seismic qualification of this equipment. (3) 3HVR*RlY10NB,19NB Seismic report #K 84 50/16435A Report requested per RFl#669, item #3 & RFl#814, item #1 Reports received per NU IRF#1098 and 1246 do not address the seismic qualification of these equipments. i Review Valid invol6d Needed Date initiator: Patel. Ramesh 8 O O 1/7/88 VT Lead: Neri, Anthony A B O O 1/1/98 VT Mgr: Schopfer, Don K O O O 1/12/98 1RC Chmn: Singh, Anand K O O O 1/13/S8 j D.i.: INVALID: Date: 3/30/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report ) DR-MP3-0876 does not represent a discrepant condition. (1) 3HVR*RE10NB,19A/B, are Wall Mounted Microprocessors. Report No.16435-A, Revision 1, dated 10/09/81, " Qualification of Digital Radiation Monitoring Microcomputer System" states on page 1 in Section 1.2, " Objective" that this report presents the testing methods and technical justifications for the qualification of the KEM microcomputer. Section 7.1," Testing Mounting" on page 38 states that the test fixture will be mounted in a manner which simulates as closely as possible its service mounting. (2) Qualification of 3HVR* MOD 140A/B: ITT General Controls Engineering Report No. 730.1.140, Revision 1, dated 4/24/84 shows Mark Numbers 3HVR* MOD 140NB in Section 2, pages 1 to 4. These component replacement schedules state the equipment type as an Electro-Hydraulic Actuator, Model NH-92. ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89, on page 4 of 57, Table I shows NH90 Printed 4/13/98 8:50:28 AM Page 1 of 3

( l N::rthenst Utiliti:3 ICAVP DR No. DR-MP3-0876 Millstone unit 3 Discrepancy Report Series Actuators with NH92 listed. ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89 on page 36 of 57, Section 4.3 " Extension of qualification by Similarity" states in item 4.3.1.4, "Model NH92" that "The model NH92 actuator is identical to the Model NH94 tested....". ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89, page 20 of 57, Section 3.2.10 states the seismic testing was performed in accordance with ITT General Controls Report 730.1.128, Revision 4. Appendix A of ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89 presents ITT General Control Report No. 730.1.128, Revision 4, dated 2-12-82 Test Plan for Requalification of ITT GC NH-90 Series Hydramotor Actuators. (3) Qualification of 3HVR*RlY10NB,19A/B: These devices are normal range vent microprocessors. Report No.16435-A, Revision 1, dated 10/09/81, " Qualification of Digital Radiation Monitoring Microcomputer System" states on page 1 in Section 1.2, " Objective" that this report presents the testing methods and technicaljustifications of the KEM microcomputer. Significance Level criteria do not apply here as this is no a discrepant condition, j Previously identined by NU? O Yes (e) No Non Discrepent CondMion?Q Yes (G) No t Resolution Pending?O Yes @ No Resolution Unresolved?O Yes @ No Review initiator: Johnson, Joy VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 3/30/98 sL Comments: (1) HVR*RE10NB,19NB: The mounting of the microprocessors has been addressed; however, the mounting of the radmonitoris not complete. The isokinetic nozzle associated with 3HVR*RE10A/B,19NB is installed inside the duct as shown in Kaman Drawing No. 400325, Rev. E and Sketch No. B-313-5. No calculation has been provided for Details B and C on Sketch B-313-5 which show the details for mounting the isokinetic nozzle, or for Kaman Drawing No. 410808-TAB which shows the nozzle support socket. These items need to be addressed. (2) 3HVR* MOD 140NB: ITT General Controls Engineering Report No. 730.1.140 adequately addresses the seismic qualification of the actuator. However, it does not address the damper itself. Seismic Printed 4/13/98 8:50;32 AM Page 2 of 3

N:rtheast Utilitlis ICAVP DR No. DR-MP3-0876 Millstone Unit 3 Discrepancy Report qualification of the damper needs to be addressed. (3) 3HVR*RlY10A/B,19A/B: Selsmic qualification of these microprocessors has been addressed; however, their mounting is not addressed. 3HVR*RlY10A/B is mounted on a steel support frame and 3HVR*RlY19A/B is mounted to a concrete wall or column. Calculations addressing the steel support frame and attachrnent to the building structure are needed. j l l l ? I l l ) PrWed N13/98 8.50:33 AM Page 3 of 3

1 I N:rtheast Utilities ICAVP DR N3. DR MP3 0983 { Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: System Design Potendal Operability issue Discipline: Piping Design Qy Discrepancy Type: Calculation @ No System / Process: HVX NRc Significance level: 4 Date faxed to NU: Date Published: 1/25/96 Discrepancy: Mounting detail qualification for ductmounted radmonitor can not be verified Descripuon: Calculations for the qualification of pipe lines 3HVR 006-36-3, 3HVR-006039-3,3HVR 750-46-3 and 3HVR 750-49-3 could not be located. These lines are used to protect leak tight radiation monitor sample points in ductwork. The lines are identified on Sketches B-313A 5 and B-313B-6, Specification SP ME 573. Qualification of the connection of these lines to the ductwork, as shown on the above noted sketches, can not be verified. Review Valid invalid Needed Date initiator: Prakash, A. 8 0 0 /18/S8 VT Lead: Neri, Anthony A B O O 5/1e/se VT Mgr: schopfer, Don K B O O 1/2o/9e IRC Chmn: singh, Anand K B O O /22/9e Dete: INVALID: Date: 4/6/98 RESOLUTION: Response ID: M3-IRF-01838 NU has concluded that Discrepancy Report DR-MP3-0983 has identified a condition not previously discovered by NU for which corrective action is complete. As a result of investigation into Condition Report (CR) M3-98-0666, standard calculation 12179-NM(S)-767-CZC has been located. Results of this calculation were translated during plant design into the document of origin for these connections, which is SWEC specification 2280.000-627, pages 105 and 106. The drawings in the SWEC specification were later translated into Sketches B 313A-5 and B-313B-8, Specification SP-ME-573. Since the document of origin has been available to the station, and only the supporting calculation was needed, this issue is considered a level 4 significance.

== Conclusion:== NU has concluded that Discrepancy Report DR-MP3-0983 has identified a condition not previously discovered by NU for which corrective action is complete. As a result of investigation into Condition Report (CR) M3-98-0666, standard calculation 12179-NM(S)-767-CZC has been located. Since the Engineer's design drawings have been available and the installation is consistent with the drawings, only the source calculation was needed. Therefore this issue is a level 4 significance. Attachments: Printed 4/13/9e 9:00.05 AM Page 1 of 2

I N rtheast Utilities ICAVP DR No. DR-MP3-0983 Millstone Unit 3 Discrepancy Report Condition Report M3-98-0666 containing: Calculation 12179-NM(S)-767-CZC SWEC Specification 2280.000-827, pages 105 and 106 j Previously identified by NU? U Yes (*) No Non D6screpent Condition?O Yes (ej No Resolution Pending?O Ye. @ No Resolution unresolved?O Ye. @ No Review l initiator: Join, R. C. O O O e VT Lead: Neri. Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date: 4/6/98 j sL conwnents: Calculation 12179-NM(S) 767-CZC Rev.0 was performed to l qualify nozzles for 3 CMS *RE22NB and 3HVR*RE19 B. This addresses line 3HVR-006-039-3 but nothing has been mentioned about the qualification of lines 3HVR-006-36-3,3HVR 750-46-3 and 3HVR 750-49-3. The qualification of these lines is presumably similar to those addressed by the calculation, { therefore we concur with NU that this issue is a level 4 i significance. The calculation should be revised to include the quiafication of these lines. Printed 4/128 9:00:09 AM Page 2 of 2

N:rtheast Utilities ICAVP DR N2. DR-MP3-1032 Millstone Unit 3 Discrepancy Report Review Group: system DN I:F. SOLUTION REJECTED Potential Operability issue Discipline: Mechanical Design O ve. Discrepancy Type: Installation implementation g System / Process: NEW NRC Significance level: 4 Date faxed to NU: Date Published: 2/12/9b Discrepancy: DCR M3-97042 does not provide for adding new vendor drawings & manualinto Millstone documentation. Descripuon: Modification DCR M3-97042 installs nev, test lines for the containment recirculation spray pumps 3RSS*P1C and 3RSS*P1D. The new test lines contain new manual valves, 3RSSN895 and 3RSSN897. The modification also installs clamp-on ultrasonic flow instrumentation, made by Controlotron, to measure flow during inservice testing of all four containment recirculation spray pumps. DCNs DM3-00-613-97 and DM3-00-614-97 identify and reference Contro!otron drawing 990TNDM-78. However, no documentation shows that this drawing is being added to the Millstone Unit 3 drawing system. No documentation is identified that adds the Controlotron vendor ) l manual for the new flow instrumentation to the Millstone Unit 3 l vendor manual system. j I DCNs DM3-00-613-97 and DM3-00-614-97 identify Westinghouse draw:ng 8374D02 for the new manual valves 3RSSN895 and 3RSSN897. However, no documentation is 1 ideritified that adds this drawing to the Millstone Unit 3 drawing system. Review Valid invalid Needed Date initiator: Feingold, D. J. O O O 2ase VT Lead: Nort, Anthony A O O O 2390 VT Mgr: schopfer, Don K S O O 2/ev98 1RC Chrnn: Singh, Ar,and K 8 O O 2n/se Date: INVALID: 4 Date: 4/6/98 RESOLUTION Disposition: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1032, does not represent a discrepant condition. Design Change Request (DCP) M3-97042 is en ongoing design change. Attachment 1 of form 3-28," Design Change Administrative Checklist", in the Design Change Manual (DCM) requires that all vendor manuals and drawings needed with the addition of components to a system be added to the vendor manual system and/or the drawing system prior to closure of the DCR. Fdnted 4U/98 8:51:46AM Page 1 of 2

l ) i, o N rthext Utilitie3 ICAVP DR N3. DR-MP3-1032 ullistone unit 3 Discrepancy Report All field modifications for DCR M3-97042 have been made. DCR M3-97042 is scheduled for administrative closure within 90 days. Significance Level criteria do not apply here as this is not a discrepant condition. i

== Conclusion:== NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1032, does not represent a discrepant condition. Design Change Request (DCR) M3-97042 is an ongoing design change. Attachment 1 of form 3-28," Design Change Administrative Checklist", in the Design Change Manual (DCM) requires that all vendor manuals and drawings needed with the l addition of components to a system be added to the vendor manual system and/or the drawing system prior to closure of the DCR. Significance Level criteria do not apply here as this is not a discrepant condition. Previously identified by NU? O vos @ No Non Discrepent Condition?O vos @ No I Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review inittetor: Feingold. D. J. l VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K l IRC Chmn: singh, Anand K Date: d3/98 sL conenents: Desiq., Control Manual Revision 5, page 22 of Chapter 3, states, " Design change close-out shall be completed within 90 days of l final Engineering Release for Operation". Page 6 of Chapter 1 states that this close-out includes procedures, lists, and databases. DCM Form 3-2B, Section IV, is the Design Change Close Out. Item IV.4 is tumover of any required Vendor Manual changes or additions. Northeast Utilities response is with respect to vendor manuals is acceptable, assuming item IV.4 is included in the Items slated for close-out within 90 days after final Engineering Release for Operation. No items can be identified in Section IV of DCM Form 3-2B, or any other part of the Design Control Manual, that apply to update of vendor drawings. According to NU, vendor drawings are updated in the same manner as design drawings. Therefore, Sargent and Lundy considers the Design Control Manual to require inclusion of identified vendor drawing additions and revisions in modification DCNs prior to issue for implementation. l l Prailed N13/96 8:51:50 A>A P.0e 2 of 2

\\. N:;rtheast Utilities ICAVP DR N2. DR-MP3-1033 Millstone Unit 3 Discrepancy Report l Review Group: System DR RESOLUTION REJECTED f Review Element: Change Process Potential Operability issue ] Discipline: Mechanical Design O vos [ Discrepancy Type: Installetion implementation (8) No System / Process: NEW l NRC Sign!ficance level: 4 Date faxed to NU: Date Published: 2/12/98 l Discrepancy: DCR M3-97045 installs new valves w/o their respective drawings l being added to the drawing system. I l

== Description:== Modification DCR M3-97045 adds new cate and check valves 3RSS*V899, 900, 901, 902, 903, 904, n#05, 906, 907, 908, 909, j 910 via DCNs DM3-00-1680-97, DM3-00-1569-97 and DM3 1569-97. No documentation is identified that adds drawings for l these new valves to the Millstone Unit 3 drawing system. Review Valid invalid Needed Date initiator: Feingold, D. J. O O O 2t3/98 VT Lead: Nort, Anthony A B O O 2ta/98 VT Mgr: Schopfer, Don K 8 O O 2/e/se IRc Chmn: Singh, Anand K 8 O O 2tr/se Date: INVAUD: Date: 4/6/98 RESOLUTION: Disposition: l l NU has concluded that the issue reported in Discrepancy Report, ) DR-MP3-1008, does not represent a discrepant condition. This is a duplicate issue. Discrepancy Report, DR-M3-1046, reports that design drawings l for the new safety related valves added by DCRs M3-97094, M3-l 97042 and M3-97045 have not been entered into the Millstone l Unit 3 drawing cystem. In ICAVP Response Form, MS-IRF-01903 it was reported that modifications per DCR M3-97045 are in progress and all updates will be completed before close-out l per the Design Control Manual. Significance Level criteria do not apply here as this is not a discrepant condition.

== Conclusion:== NU has concluded tr at the issue reported in Discrepancy Report, DR-MP3-1008, does not represent a discrepant condition. Issue has been identified on separate DR, DR MP3-1046, and consists of work in progress. Significance Level criteria do not apply here as this is not a discrepant condition. Previously klentified by NU7 U Yes @) No Non Discrepent Condition?O Yes (9) No Printed 4/1398 e;52:30 AM Page 1 of 2

A. t N:rtheast Utiliti:3 ICAVP DR N3. DR-MP31033 Millstone Unit 3 Discrepancy Report Resolution Pending?O yes (*) No Resolution Unresolved?O vee (*) no Review initiator: Feingold, D. J. VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Clwnn: singh, Anand K Date: 4/6/98 SL cornrnents: In their response, NU has concluded that the issue reported in " Discrepancy Report, DR-MP3-1008, does not represent a discrepant condition." Sargent & Lundy assumes this to be a typographical error where DR MP3-1033 is the subject discrepancy report. Design Control Manual Revision 5, page 22 of Chapter 3, states, "Desi0n change close-out shall be completed within 90 days of final Engineering Release for Operation", Page 6 of Chapter 1 ststes that this close-out includes procedures, lists, and l databases. DCM Form 3-2B, Section IV, is the Design Change Close Out. No items in this section apply to update of vendor drawings. No statements can be identified in the Design Control Manual that I l apply tha 90 day close-out period to vendor drawing changes and additions. According to NU, vendor drawings are updated in the same manner as design drawings. Therefore, Sargent and Lundy considers the Design Control Manual to require inclusion of ] l identified vendor drawing additions and revisions in modification l DCNs prior to issue for implementation. I l l l l l Printed 4/13/96 8.52:34 AM Page 2 of 2}}

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