ML20216G272
| ML20216G272 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/16/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9803190316 | |
| Download: ML20216G272 (67) | |
Text
- .
6% .
7 -
1 Sar 6X geMK Lundy"c DA'pf r
Don K. Schopfer Senior Vice President 2-2sH078 March 16,1998 Project No. 9583-100 Docket No. 50-423 4 1
Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document ControlDesk l
Washington, D.C. 20555 I have enclosed one (1) discrepancy report (DR) identified during our review activities for the ICAVP. This DR is being distributed in accordance with the Communications Protocol, PI-MP3-01.
DR No. DR-MP3-1083 I have also enclosed.the following ten (10) DRs for which the NU resolutions have been reviewed and accepted by S&L.
DR No. DR-MP3-0690 DR No. DR-MP3-0950 DR No. DR-MP3-0852 DR No. DR-MP3-0969 DR No. DR-MP3-0898 DR No. DR-MP3-1003 DR No. DR-MP3-0917 DR No. DR-MP3-1027 DR No. DR-MP3-0941 DR No. DR-MP3-1067 l/\
9803190316 980316 PDR ADOCK 05000423 p PDR 55 East Monroe Street . Chicago. IL 60603-5780 USA + 312-269-2000 j
-a[,.
United States Nuclear Regulatory Commission March 161998 Document Control Desk Project No. 9583-100 Psge 2 I have also enclosed the ten (10) DRs for which the NU resolutions have been reviewed but not accepted. S&L. comments on these resolutions have been provided.
DR No. DR-MP3-0580 DR No DR-MP3-0692 DR No. DR-MP3-0660 DR No DR-MP3-0701 DR No. DR-MP3-0675 DR No DR-MP3-0846 DR No. DR-MP3-0680 DR No DR-MP3-0873 DR No. D R-MP3-0684 DR No DR-MP3-0874 Please direct any questions to me at (312) 269-6078.
Yours very truly,
.T v D. K. Se opfer l Senior Vice President and j-ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/1) Deputy Director, ICAVP Oversight
. T. Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/1) NU m&svpbun9far03164. doc i
..J
r DR N;. DR-MP3-1083
- Northenct btilities ICAVP l
Millstone Unit 3 Discrepancy Report t
' Review Group: System DR VAUD Review Element: Correcove Action Procese Potential ability leeue Diecipune: uschenicei %
Discrepency Type: Corrective Action irnplementation SystemProcese: Rss g
! NRC C" Welevel: 4 Date faxed to NU:
Date Putdiohed 3/16/96 D6ecrepancy: ACR M3-97-0314 Corrective Action implementation
Description:
ACR M3-97-0314 addressed problems with the material condition and cleanliness of the containment sump, sump screens and sump cover. This ACR enumerated 13 of these issues with the RSS containment sump.
AR 97002740 was issued to implement the corrective actions for ACR M3-97-0314. The following documents were traceable from -
ACR M3-97-0314 and AR 97002740: 3DE-96-0009, AR 96033643, LER 96-039-00, AWO M3-96-13395, DCR M3-97580, l DCN DM3-00-0490-97, NSE 97-01, AR 97009899, TR 20M3151214, AWO M3-97-10839, AWO M3-13728, AWO MS-97-02630, TR21M3100340, AWO 97-10840, AWO M3-96-09729,
, AR 97002435, AR 96036350, AR 97015361. TR 12M33095400, AWO M3-96-13395, ACR M3-96-1372, AR 96036350,97003665, DCN DM3-S-903-96, and DCR M3-97045.
According to ACR M3-97-0314, AR 97002740-03 address the corrective actions for ACR M3-97-0314 issues #3 and #5. AR 97002740-03 was closed to TR 20M3151214, and TR 20M3151214 was closed to AWO M3-97-10839. TR 20M3151214 and AWO M3-9710839 correct item #5, the missing lower grating clip. Neither of these corrective action documents address item #3, various deck plate screws missing or not flush with deck plating. No documentation of the correction of item #3 was found among the corrective action documents listed above.
According to ACR M3-97-0314, AR 97002740-03 address the corrective actions for ACR M3-97-0314 Issue #10. AR 97002740-03 was closed to AWO M3-97-02630. This work orderis forthe removal of trash Orates for a surveillance to measure the coarse mesh screens, and to remove debris found between the trash grates and fine mesh screens and debris found in the sump behind the screens. This work order does not address item #10, to clean debris found in the sump trench outside the trash grates and screens. No documentation of the correction of item #10 was found among the corrective action documents listed above.
The documents referenced for closure of corrective action implementation for items #3 and #10 of ACR M3-97-0314 did not i
address these issues. Documentation for the closure of items #3 I or #10 was not found in ACR M3-97-0314, in AR 97002740, or in any other documents directly associated with ACR M3 97-0314 ,
or AR 97002740. !
Review i Valid invelid Needed Date ;
a =% w-w a r w mn i Printed 3/16/9611:31:16 AM Page 1 of 2 1
N:rthe::t Utilities ICAVP DR No. DR-MP3-1083 l
Millstone Unit 3 Discrepancy Report Initiator: Wakeland, .l. F. 3/12/98 l VT Lead: Nerl, Anthony A 3/12/98 VT Mgr: Schopfer, Don K 3/12/98 IRC Chmn: Sin 0h, Anand K 3/13/98 I Date:
INVALID:
Date:
RESOLUTION:
Prevhsly identified by NU? O Yee (S) No Non D6screpent Condition?Q Yee (#) No Reeolution Pending?O vee @) No ResolutionUnroeolved?O vee
- No Review ACC*Ptable Not Acceptable Needed Date initWor M
. IRC Chmn: Singh, Anand K
[
Date:
SL Commente:
l l
i l
l l
l l
l l
Printed 3/16/9811:31:19 AM Page 2 of 2
Northert Utilities ICAVP DR N2. DR-MP3-0690 uisistone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Electrical Design l Discrepancy Type: Calculation 9 No SystemrProcess: DGX NRC Slgnificance level: 3 Date faxed to NU:
Date Published: 12/20/97 i Discrepancy: 480 Volt Load Study (Calculation NL-025)
Descripuon: Calculation NL-025 documents the running loads on 480 volt unit substations and motor control centers under steady state full j load conditions, ensuring that none of the Safety Related or Non-Safety Related low voltage buses are overloaded. This information is used as input data to other calculations, such as NL-038, which calculates the voltages in the electrical auxiliary system.
Attachment 1 develops demand factors, which are really multipliers to be applied to rated horsepower to obtain the running brake power for each connected load. The development of these demand factors is described in detail, but the values of ;
the demand factors are not substantiated in a verifiable way with numerical data. The statement is made that the brake power for i pumps & fans (all sizes) is always less than the motor rated j horsepower. The issue of service factors is not addressed. The development presented would only be strictly correct if all motors l were 1.0 service factor. However, some types of motors are i normally provided with a service factor of 1.15.
No effort was made to determine what additional loads et the motor control centers may be running under accident conditions.
An assumption on page 4 states that the " loads are based on normal operating conditions". Since there are many systems that are provided strictly to mitigate the effects of an accident, the applicability of the calculated demand factors during accident conditions should be verified. Since the diversity factors are used as input data to the voltage drop calculations in Calculation NL-038, this issue is vital to assessing the adequacy of the auxiliary system design.
Attachment 2 lists diversity factors for various types of loads.
The development of the diversity factors for motor control centers is exp!ained. However, no explanation is given for the diversity factors for any other type of load.
On page 2 of Attachment 9, it is stated that the initial load measurements (December 29,1092 for Train A) were taken at 60% plant loading, and additional data (January 5,1993 for Train B, and May 13,1993 and May 14,1993 for Train A and Train B) were taken at 100% plant loading. However, no statement is made nor reference given as to how the plant loading on these dates was determined.
Some of the motor control centers had power factors over 90%,
but it is stated that 85% is used for all of the motor control
,_._ rs:- ,,m u u- a .,a.~.. + _ .x _..u .u- ...m.#. ~.w.
Printed 3/16r9811:23 04 /M ~ ""' " ' ' "" ~ ~" ~ ~ ~ "' "" 8 " " V ' " "v " ' " - r r gg, gyp,y 3
N:rthert Utilities ICAVP DR NO. DR-MP3-0690 Millstone Unit 3 Discrepancy Report to the motor control ceriters. Page 4 states that "The MCC power factor is assumed to be 0.85..." This is not used in this calculation. The power factors of the motor control centers do not have a role in this calculation. All kVA's of the loads and motor control centers are added using magnitude only (not )
vectors), regardless of the stated power factors.
i Page 4 of the calculation states that the, " transformer loading is based upon output rating, ignoring losses, since transfomiers are ]
typically 96-99% efficient." Apparently this applies only to 480-120/208V transformers, because the 4160-480 volt transformers do not appear here. This should be clarified.
Page 8 of the calculation gives the maximum permissible loading of the unit substations. However, no reference is given for verifying this information.
Based on the above discussion, a verifiable design basis for the demand and diversity factors for the 480 voit portion of the ,
electrical auxiliary system has not been provided. Since these l factors are used to calcdate the loading of the 480 volt buses of the auxiliary system, the loading of this portion of the electrical auxiliary system cannot be verified. This affects other calculations, such as NL-038.
Review Valid invalid Needed Date initiator: Bloethe, G.Winism B O O $2/i/97 VT Lead: Neri, Anthony A B O O $2/9/97 VT Mgr: schopfer, Don K B O O 12/11/97 IRC Chmn: Singh, Anand K B D 0 $2/16/97 Date:
INVALID:
Date: 3/10/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report DR-MP3-0690 has identified a condition previously discovered by NU which required and has been corrected.
The non-conservative nature of the calculation method for determining Class 1E 480V loading and its use with the load flow and voltage profile Calculation NL-038 was recognized during the 50.54 Assessment, which resulted in CR M3-97-0119 (6/1/96) being issued. This CR resulted in CCN #7 to revision 2 of NL-038 to be issued, which now assumes a 1.0 diversity factor for the Class 1E 480V MCC loads during an accident scenario. A review of the locd flow for Euses 32R and 32T in CCN #7, indicates an almost doubling in their respective !cading due to the increase in MCC diversity factor.
NU has concluded that the following issues reported in Discrepancy Report DR-MP3-0690 do not represent discrepant conditions.
Printed 3/16/9611:23:05 AM Page 2 of 3
ICAVP DR NL DR-MP3-0690 Northea:t Utilities Millstone Unit 3 Discrepancy Report Original purchase specifications prepared by Stone & Webster specified rated horsepower based on brake power or individual connected load. The generic demand factor values for specific groups of components presented in Attachment 1 of Calculation No. NL-025 were developed from a review of demand curves prepared in Calculation NL-033 or other applicable Calculations.
The issue of service factor is not addressed in Calculation NL-025. This is in conformance with the FSAR Section 8.3.1.1.4.6 which states motor loading does not exceed the motor nameplate (rating) regardless of the service factor. (NU notes <
the DR 0699 identifies an apparent exception to this FSAR !
statement. This issue is under evaluation and is believed to be an isolated case which has insignificant impact on our conclusion relative to Bus loading.)
Attachment 2 of Calculation NL-025 explains how the diversity factor for MCCs was developed. Other loads fed from Unit Substations have been assigned a diversity factor of 1.0, see Attachment #3 where loads are totaled. i
- The electricalloading data listed on pate 2 of Attachment 9 of Calculation NL-025 was obtained by actual measurements on the ,
dates listed in the calculation,. The larDest measured phase (
current was then considered for the calculation.
It is stated that the cumulative MCC power factor is 0.85 and isn't used in the calculation. Calculation NL-025 is a load summary calculation which does not require the power factor value to be taken into account. Calculation NL-0389 which calculates voltage drop, does take into account the effects of a component's power factor.
4160/480 VAC transformer loading is not part of the Calculation, because they are upstream of the 480V AC buses.
Significance level criteria does not apply as these issues are not discrepant conditions.
Previously identified by NU? @ Yes Q No NonDiscrepentCondition?O Yes @ No Resolution Pending70 Yes @ No Resolution unresolved?O Ye. @ No Review initiator: Wamer,l.
VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Date:
sL Comments:
~-
Printed 3/16S611:23:05 AM P229 3 of 3
~
- - - . . - - . _ - _ . - .--- L- - ---
i Northent Utilities ICAVP DR N2. DR-MP3-0852 Milistone Unit 3 Discrepancy Report Rev6ew Group: System DR RESOLUTION ACCEPTED Review Element: Modirication Design p
Discipline: Mechanical Design Ow Discrepancy Type: Installation Requirements g
System / Process: sWP NRC Significance level: 3 Date faxed to NU:
Date Published: 1/22/98 Discrepancy: PDCE 3-87-039 Installation Requirements Discrepancies
Description:
PDCE 3-87-039, which involved replacement of the primary service water strainer [3SWP* STRIA, B, C, D) tube sheets with tube sheets of attemate material for increased resistance to corrosion, was reviewed and the following discrepancies noted.
- 1. The PDCE did not address the tube sheet material change with respect to updating vendor documentation.
- 2. The PDCE did not contain reference to or specification of installation requirements or controlled procedures for disassembly, tube sheet changeout, and reassembly of the
[ safety-related) strainers. Work order AWO M3-87-16059, referenced in the PDCE as the implementing work order, was reviewed in PMMS, but no reference was found in the work order for procedures to control this work.
- 3. The strainers were specified in the PDCE to be determinated electrically in order to change out the tube sheets, and to be 4 reterminated electrically following completion of the changeout. l However, the PDCE does not contain reference to any testing i requirements to ensure operability of the strainers prior to retuming the equipment to service after the tube sheet '
changeout.
Review Valid invalid Needed Date initiator: Tenwinkel J. L. 8 O O 12/22/97 VT Lead: Neri, Anthony A B O O 12/19/97 VT Mgr: schopfer, Don K S O O 12/23f87 IRC Chmn: singh, Anand K B O O 5'17/S3 Date:
INVALID:
Date: 3/11/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR MP3 0852, has identified a condition previously discovered by NU which required correction. LER 96 04100 (11/22/96) documented the problem of continuous backwashing of the "A" SWP discharge strainer. The cause was excessive fouling of the strainer and the downstream Reactor Plant component Cooling (CCP) Heat Exchanger inlet screen. It was analyzed that the fouling became possible due to the changeout of the strainer tubesheets performed in the fall of 1988 in accordance with PDCE MP3-87-039.
Printed 3/16/9811:23A3 AM Page 1 of 3 a.n
ICAVP DR Nr. DR-MP3-0852 N:rthext Utilitie3 Millstone Unit 3 Discrepancy Report The chronology of this issue began on October 19th and 20th, 1996, when the "A" Service Water Pump Discharge Strainer (3SWP*STR1 A) was continuously backwashing on high differential pressure. An inspection of the SW pump discharge 3 strainers revealed extensive fouling with seaweed. ACR M3 96 1028 subsequently was issued (10/24/96) to document the condition. The ACR evaluation determined that the root cause of the problem was the replacement Monel strainer tube sheets, which were manufactured by the plant in 1988. It was )
determined that the new tube sheets were fabricated to incorrect j dimensions which resulted in a raw water bypass clearance in 1 excess of the design filtered particle size. Also at this time, ACR M3-96-1027 was issued to document that the strainers' Backwash Bearing Housing was identified in PMMS as Non QA.
NCR 396-492 (10/25/96) documented that the lower tube sheet to strainer element diametral clearances were 0.102" to 0.108" in all four strainers. The vendor recommendation for diametral clearance is 0.010". NCR 396-491 (10/24/96) recorded that mcorrect QA classification of the strainer backwash bearing housing.
The LER committed to the following corrective actions:
- 1. The strainer tube sheets will be reworked or replaced as required to restore the tube sheets to conformance with design requirements.
- 2. The SW Pump Discharge Strainer sub-components have been evaluated and reclassified as safety related based on component function.
- 3. The work control procedures related to work order preparation will be reviewed and revised as needed to ensure necessary I requirements are provided conceming material replacement qualification and inspection criteria.
The first commitment was tracked and completed under A/R 96035008-01: the "A" strainer tube sheet was replaced by AWO M3-97-07204; the "B" strainer by AWO M3-97-07226; the "C" strainer by AWO M3 97-07228; the "D" strainer by AWO M3 07232. The second commitment was tracked and completed under A/R 96035006-02; the QA reclassification of strainer parts was completed per MEPL disposition MP3-CD-0930. The third commitment was tracked and completed under A/R 96035008-03: WPOM reviewed the work control procedures U3 WC1, Rev.1 " Unit 3 Work Management", and U3 WPC 2, Rev.1 "AWO Preparation and Work Scheduling" and has determined that current controls exist which would precluded this incident from occurring today....
MP3's current process fully integrates Design Engineering &
Performance Evaluation into the work control and l implementation process. Today's standards would not allow QA components to be modified without the required Engineering i Design Change Documents. The Espineering product which was .
provided to support the initial modification which aenerated this '
Printed 3/16f9811:23A3 AM Page 2 of 3 i
I
l N:rthert Utilities ICAVP DR N3. DR-MP3-0862 Millstone Unit 3 Discrepancy Report
! LER would not be accepted today.
Therefore, based on the LER, NCRs and ACRs, and their associated corrective actions, this DR is considered previously l discovered. Individualissues of the DR are addressed below.
l
- 1. The tube sheet material was changed from NI resist ductile iron to Monel. As noted in the PDCE, there were no detailed drawings of the tube sheet. One action of DCN DM3-02-1832-97 (12/17/97) was to enter strainer subcomponent drawings provided by the strainer vendor into the NU system. Sheets 9 -
12 of drawing 25212-29063 provide updated documentation !
regarding the SW pump discharge strainer Monel tube sheet. l (Drawing sheets are currently in *NEW" status in GRITS.) I
- 2. As noted in LER 96-041-00, at the time the PDCE was issued, the tube sheet replacement parts were classified non-safety related, and the work planning documents did not receive QA review. Therefore, QC inspection was not performed during fabrication or installation of the Monel tube sheets. The second corrective action of LER 96-041-00 listed above addressed this issue. This action was completed 9/22/97.
- 3. Although AWO M3-87-16059 does not reference any testing requirements, it does document a satisfactory functional verification (5/29/88) subsequent to tube sheet replacement.
Additionally, the third corrective action of LER 96-041-00, which was to review and revise work control procedures as needed, was completed 6/9/97.
LER 96-04100 and its associated corrective actions, which have already been completed, addressed this issue. NU agrees with the significance level of this DR.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0852, has identified a condition previously discovered by NU which required correction. LER 96-041-00 and its associated corrective actions, which have already been j completed, addressed this issue. NU agrees with the j significance level of this DR. l Previously identified by NU? (4) Yes O No NonDiscrepantCondition?U ves (9) No l
Resolution Pending?O ve. @ No Reeoiution unre.oived?O ve. @ No Review initiator: Tenwinkel, J. L a VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chrnn: singh, Anand K
)
l Date: !
SL Comments- !
> i 1
Printed 3/16/9811:23.44 AM Page 3 of 3 l- - -- . - . - _. . . - - -
I l
Northezt Utilitie3 ICAVP DR No. DR-MP3-0898 i
Ministone Unn 3 Discrepancy Report !
l Review Group: System DR RESOLUTION ACCEPTED
{
Review Element: System Design '
PMieloperablutyissue Discipline: Mechanical Design Discrepancy Type: DrW Om (e) No systemProcess: DGX NRc Significance level: 4 Date faxed to NU:
Date Published: 1/18/98 Discrepancy: The P&lD Review for the EGD subsystem of the Diesel Generators yleided discrepancies.
Description:
MNPS-3 FSAR, Section 3.3.2, page 3.2-5, states," As required )
by 100FR50, Appendix A, safety class boundaries only change at the isolation valves.* P&lD EM-116E indicates safety class breaks at expansion joints EB3A/B, at the reducer on the A and B trains between the emergency diesel generator crankcase and the oil separator and at the expansion joint between valve 3EGD*V2A/B and the oil separator.
The following EGD components were included on P&lD EM-116E, however, were not found in the PDDS/PMMS system:
l 3EGD*EJ4A 3EGD*EJ4B 3EGD*EJSA 3EGD*EJ5B Review Valid invalid Needed Date initiator: Hameetman, R. O O O 12/22/97 VT Lead: Neri, Anthony A 9 0 0 12/20/97 VT Mgr: Schopfer, Don K B O O 12/23/97 l lRC Chmn: Singh, Anand K @ [ Q 1/15/98 1 Date:
INVALID:
Date: 3/13/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR MP3-0898, has identified a condition not previously discovered by NU which !
requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 tt has been screened per U3 PI-20 criteria and found to have no operability or reportability I concems and meets the Unit 3 def erral criteria. CR M3-98-0648 has been written to develop and track resolution of this item per RP4.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0898, has ,
identified a condition not previously discovered by NU which l 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 M3-98-0648 has been written to. develop and track resolution of this item per RP-4.
Printed 3/16/9811:24 04 AM Page 1 of 2
- - ~ . . - . . . ~ .-. . - - . . - - . . - _ - - . - . - . . - - -_
ICAVP DR Nr. DR-MP3-0898 N rthert Utilitie3 Millstone unit 3 Discrepancy Report Previously identified by NU? U Yes @ No Non Discrepant Condition?U Yes (e) No ResolutionPending?O Yes @ No ResolutionUnresolved?O yes @ No Review initiator: Obersnel,Bojan.
O **
VT Lead: Neri, Anthony A O O **
VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/13/98 sL Comments: The safety clast, break as shown on P&lD is technically acceptable per ANSI /ANS-51.1 standard. The design is therefore acceptable and corrective action for this issue deferrable. Since the corrective action for the second part of the discrepancy also meets the deferral criteria, its disposition is acceptable.
Pnnted 3/1&981124:04 AM Page 2 of 2
ICAVP DR Ns. DR-MP3-0917 N:rthe:ct Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Component Data g System / Process: DGX NRC Significance level: 4 Date Faxed to NU:
Date Published: 1/17/98 Discrepancy: EGS System Component Data Discrepancies
Description:
Review of the EGS system components resulted in following discrepancies:
- 1. 3EGS*P2A/B, Jacket Water Circulating Pump PMMS data shows pump motor size at 3/4 Hp at 1745 RPM.
Vendor technical manual OIM-241, drawing 11907729 defines motor size as 3/4 Hp at 1750 RPM.
- 2. 3EGS*E1 A/B, Emergency Generator Diesel Engine Air Cooler Water Heat Exchanger The total heat exchanger heat transfer rate and temperature differential (water temperature increase / decrease while passing 1 through the heat exchanger) given in the FSAR Table 9.5-3 do not match those shown in the Heat Exchanger Specification l Sheet (drawing 2447.300-241-069C). Discrepancies are as follows:
FSAR Table 9.5-3 HX Specification Sheet Heat transfer rate (Btu /hr) 4,771,861 ;
4,338,055 l' Temp. Differential (deg.F), shell 11.2 10.8 Temp. Differential (deg,F), tube 12.5 4.6
- 3. 3EGS*E2A/B, Emergency Generator Diesel Engine Jacket Water Cooler The total heat exchanger heat transfer rate and tube side temperature differential (water temperature increase while passing through the heat exchanger) given in the FSAR Table 9.5-3 do not match those shown in the Heat Exchanger Specification Sheet (drawing 2447.300-241-0678).
Discrepancies are as follows:
FSAR Table 9.5-3 HX Specification Sheet Heat transfer rate (Btu /hr) 9,260,900 8,419,000 Temp. Differential (deg.F), tube 9 8.9
ICAVP DR N2. DR-MP3-0917 Northeast Utilities Millstone Unit 3 Discrepancy Report The total heat exchanger heat transfer rate given in the FSAR Table 9.5-3 does not match that shown in the Heat Exchanger Specification Sheet (drawing 2447.300-241-071 A). Discrepancy .
is as follows:
FSAR Table 9.5-3 HX Specification Sheet Heat transfer rate (Blu/hr) 1,801,800 1,640,000
- 5. 3EGS*H2A/B. Generator Space Heater This safety related heater is listed in the PMMS database.
Component is described as QA Cat.1 and seismic. However, no entry for this component was found in the PDDS, nor is this component shown on the system P&lD's EM-116A 27 and EM-116C-12.
- 6. 3EGS* HOSE 9A/B,10A/B, Bearing inlet and Oet!et Flexible Hoses The PDDS database shows that these hoses are per Specification 2447.300-241. However, they are not shown on the vendor technical manual OIM-241 drawing 11869458, Intercooler Water Schematic, nor was information about these hoses found anywhere else in the vendor technical manual. The hoses could not be found in the PMMS.
- 7. 3EGS*TCV50A/B, Jacket Water Temperature Control Valve FSAR Section 9.5.5.3 states that the design for the Jacket water temperature regulating valve is not covered by ASME lil, but that the valve is designed to diesel manufacturer's latest standards for reliability. However, per Colt Industries dwg.
11909934 (OlM-241) this valve is designed to ASME lit, Class 3 requirements.
- 8. 3EGS*RV32A/B, Jacket Water Heater Relief Valve Specification 2447.300-241, page 1-19 states that all skid cooling system components should be designed to ASME lil, Class 3 requirements. Per FSAR Section 9.5.5.3 the emergency diesel cooling water system is designed to ASME lil, Class 3 with the exceptions listed in the Section. This relief valve is not listed among the exceptions. No documentation was found to verify that the relief valve is ASME 111, Class 3.
- 9. 3EGS*V967A/B,V968A/B, Isolation Valves on Fresh Water Expansion Tank Sight Glass These two valves are apparently an integral part of the sight class. They are identified as alobe valves in PMMS and as cate Pnnted 356/9811:24:22 AM Page 2 of 4
DR N;. DR-MP3-0917 N:rthe:ct Utilitie3 ICAVP Millstone Unit 3 Discrepancy Report valves in PDDS.
- 10. 3EGS*V9608,V961B, Test Valves on Jacket Upper Header, Generator B Only These valves are shown on P&lD EM-116C-12 as angle valves.
They are described as angle valves in PDDS, and as globe valves in PMMS.
- 11. 3EGS*V985A, This valve is shown on P&lD EM-116A-27 in the 1/2" lube oil heat exchanger drain line. The PMMS describes it as 3/4" plug valve.
- 12. 3EGS*V3A/B, Three Way Themiostatic Mixing Valve Specification 2447.300-241, page 1-19 states that all skid cooling system components should I;e designed to ASME lit, Class 3 requirements. Per FSAR Section 9.5.5.3 the emergency diesel cooling water system is designed to ASME 111, Class 3 with the exceptions listed in the Section. This thermostatic mixing valve is not listed among the exceptions. No documentation was found to verify that this valve is ASME lil, Class 3.
- 13. 3EGS*EG1 A/B, Diesel Engine P&lD's EM-116A-27 and EM-116C-12 designate Diesel Engine with this equipment mark number. No PDDS or PMMS database entry was found for this equipment number.
Review Valid invalid Needed Date initiator: Obersnel,Bojan. O Q Q 12/30/97 VT Lead: Nerl. Anthony A O O O 12/31/97 VT Mgr: Schopfer, Don K O O O 1/12/98 j 1RC Chmn: Singh. Anand K O O O 1/13/98 i l
i Date:
INvAllD: j Dm*: 3/13/98 I RESOLUTION Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0917, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0495 l has been written to develop and track resolution of this item per RP-4.
Conclusion:
Printed 3/16/9811:24.22 AM Page 3 of 4
i !
I ICAVP DR N . DR-MP3-0917 N:rthert Utilities Millstone Unit a Discrepancy Report NU has concluded that Discrepancy Report, DR-MP3-0917, has 1 identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0495 has been written to develop and track resolution of this item per l RP-4. [
Previously identified by NU7 Q Yes W) No Non Discrepent Condition?O Yes (9) No j ResolutionPending?O Ye. @ No Resoiuiion unresoived?O v.s @ No Review initiator: Obersnel.Bojan.
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K yg IRC Chmn: singh, Anand K O O O 1 Date: 3/13/98 j SL comments: NU disposition is acceptable.
The disposition concludes that the identified discrepant condition meets the deferral requirements, and assigns CR M3-98-0495 to develop and track a resolution for the discrepancy. This CR was recommended to be closed to the binning CR M3-98-0217, which is to determine the required corrective action. S&L agrees with the disposition.
However, included with NU Response M3-IRF-01713 is an NU review of the DR, summarized in "lCAVP DR Response from MP3 Des Eng". NU found that two of 13 listed discrepancies are non-discrepant. S&L disagrees with regard to the non-discrepant finding for the discrepancy no. 7; the ' current" (before ICAVP ,
cutoff date) FSAR, page 9.5-31, April 1997 states: "Certain l engine-mounted components, not covered by ASME lll... These l i
components include:.. Jacket water temperature regulating valve." Thus the discrepancy exists. For the discrepancy no. 8, l S&L will accept NU disposition.
I i
Printed 3/16/9811:24:22 AM Page 4 of 4
i 1
N:rtheast Utilities ICAVP DR N3. DR-MP3-0941 Millstone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Reh EW: Test Pree Potential Operability lasue Discipline: Operations Discrepancy Type: Corrective Actkm implementation Om I System / Process: Oss
- No NRC Significance level: 4 Date faxed to NU:
Date Published: 1/22/98 l Discrepancy: Unable to confirm that commitment in LER 94-007-00 was met.
Description:
SP 31024, Calculation of Reactor Trip and ESF Response Times is the only procedure that matches the description of the procedure referenced in the subject LER. SP 31024, Attachment 9, Page 81, Reactor Trip and ESF Component Response Times, requires transferring data from other surveillances into one of three tables. The review concludes that this portion of the attachment cannot be completed as written.
The first and second tables reference data collected from the Quench Spray (Without LOP) surveillance OPS Form 3909.9-2.
The listed valves, QSS*MV34A & B, are apparently incorrect equipment numbers. Only valves 3QSS*AOV27 & 28 are listed on OPS Form 3909.9-2. If the correct valve numbers are QSS*MOV34A & B then the referenced forms should be OPS Form 3609.9-3 and 4.
The third table references data collected for valves 3OSS*MV34A & B from the Quench Spray (With LOP) surveillances. Again the valves referred to appear to have incorrect equipment numbers. No source document is identified for this information.
It is unclear, once the data has been collected for these valves, how the data is used to perform calculations or what requirement the calculations support.
The commitment also states that SP 31024 will be revised prior to its next use. SP 31024, Revision 10 through Change 3 were reviewed using OSCAR. None of the changes reference a revision to page 61. RFl 170, item 14 requested "SP 31024, Latest Results". The data provided is dated mid 1995 but Attachment 9 was not included with these documents. Therefore it cannot be resolved by this review if this commitment has been satisfied. l Review I Valid invalid Needed Date initiator: Tamtyn, Tom B O O 12/31/97 ,
VT Lead: Bass. Ken 0 0 0 1/6/98
)
VT Mgr: schopfer, Don K 8 O O 5/12/98 i
IRC chmn: singh, Anand K O O O 17/9e Date:
INVAUD:
Date: 3/2/98 RESOLUTION: Disposition:
Printed 3/16/9811:25:12 AM Page 1 of 3
Northert Utilitiea ICAVP DR N;. DR-MP3-0941 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-0941 describes a discrepant condition pre-discovered by NU for which corrective action is complete. Errors in procedure SP 31024 identified in the discrepancy report were found during procedure reviews and corrected with the issuance of SP 31024, Revision
- 3. Actions required by LER 94-007-00 have been completed such that acceptance criteria in QSS system valve stroke test procedures and SP 31024 now ensure implementation of the limits stated in the Technical Requirements Manual (TRM).
The tables contained in Attachment 9, page 81 of SP 31024, Rev. 2 have become Attachment 2 and 3, Tables 13 and 14 in SP 31024, Rev. 3. The following has been corrected in Revision 3:
(1) The equipment numbers have been corrected to i
3OSS*MOV34A/B, which is consistent with the system flow I diagram, f
(2) Revision 2 incorrectly referenced OPS FORMS 3609.9-1 and i 2 to obtain valve response times. Revision 3, Table 13 correctly directs the user to the chart recorder printout attached to OPS FORM 3646A.8-3 as the source.
The discrepancy report stated that it is unclear how the data !s used. The data is collected in accordance with the instructions of Section 4.1 of SP 31024, Rev. 3, and is then transferred to Attachment 1 as directed by Step 4.4.9. Data for the QSS valves is evaluated in Attachment 1, pages 25 and 28. Note that i the acceptance criteria is consistent with the TRM.
Closure of LER 94-007-00 is stated in Commitment Record 18440, which identifies SP3609.9, TRM Table 3.6.3-1 and TRM Table 3.6.3. Revision 3 of SP 31024 is consistent with the requirements stated in the TRM. I
Conclusion:
NU has concluded that Discrepancy Report DR-MP3-0941 describes a discrepant conTon pre-discovered by NU for which corrective action is comphs;.. Errors in procedure SP 31024 identified in the discrepancy report were found during reviews of the surveillance procedures and corrected with the issuance of SP 31024, Revision 3. Actions required by LER 94-007-00 have been completed such that acceptance criteria in QSS system valve stroke test procedures and SP 31024 now ensure implementation of the limits stated in the Technical Requirements Manual. Instructions in SP 31024 direct the collection, compilation and evaluation of data.
Previously identified by Nu? O Yes (9) No Non Discrepant Condition?U Yes (9) No Resolution Pendng?O ve. @ No Re.oiution unre.olved?O ve. @> No Review Acceptable Not Acceptable Needed Date b S R.
VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Printed 3/16/9811:25:12 AM Page 2 of 3
N rthert Utilities ICAVP DR ND. DR-MP3-0941 Millstone Unit 3 Discrepancy Report
-.....,,,,,-,__m O O Date:
SL Comments:
Pnnted 3/1G9011:25.12 AM Page 3 of 3
I 1
ICAVP DR NO. DR-MP3-0950 Northert Utilities Millstone Unit 3 Discrepanc,y Report 1 Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design n Discrepancy Type: Component Data v Yes Systern/ Process: DGX NRC Signifbcance level: 4 Date faxed to NU:
Date Published: 1/25/98 Discrepancy: Maximum Operating Conditions for Emergency Diesel Generator Fuel Oil System
Description:
The FSAR Table 3.6,3," Moderate Energy Systems Outside Containment Remote from Essential Systems, Components, and Structures" states that the maximum operating conditions for the Emergency Generator Fuel system are 40 degrees F and 29 psig. Per calculation SDP-EGF-01344M3, Rev. 3, " Emergency Generator Fuel Oil (EGF) Stress Data Package", the maximum operating conditions for this system are 31.5 psig and ambient ,
temperature. The system is exposed to three ambients with I maximum temperature no less than 90 degrees F, and as high as 120 degrees F.
Review Valid invalid Needed Date l Initiator: Obersnel,Bojan. 8 O O 1' d/98 .
VT Lead: Neri, Anthony A O O O '14/S8 l VT Mgr: Schopfer. Don K B O O 1'1S'S8 I 1RC Chmn: Singh. Anand K S O O si2 sis 8 Date:
INVALID:
Date: 3/13/98 RESOLUTION: Disposition: l NU has concluded that Discrepancy Report, DR-MP3- 0950, has been previously discovered by NU. Specifically, FSARCR 97-MP3-585 revised Table 3.6-3 to delete Emergency Generator Fuel operating conditions and added the maximum operating conditions to Table 3.6-4. Approximate maximum operating values of 120 F and 32 psig have added to Table 3.6-4. FSAR will be revised after startup.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0950, has identified a condition previously discovered by NU. FSARCR 97-MP3-585 revised Table 3.6-4 to include approximate maximum operating conditions. The FSAR will be revised after startup.
Previously identified by NU7 O ves (G) No Non Discrepant Condition?Q Yes (G) No Resolution Pending?O yes @ No Resolution Unresolved?O ves @ No i Review initiator: Obersnel,Bojan.
I VT Lead: Nerl. Anthony A VT Mgt: Schopfer. Don K gg IRC Chrnn: Singh, Anand K O O Date: 3/13/98 Printed 3/16/9811:25:33 AM Page 1 of 2
N:rther:t Utilities ICAVP DR No. DR-MP3-0960 Millstone Unit 3 s Disc,repancy Report at commerns: While the FSARCR 97-MP3-585 does address and correct the discrepant condition, the FSARCR is dated prepared 12/16/97, j after the DGX cutoff date of 7/17/97, Therefore, this condition is still considered a discrepancy not previously identified by NU.
l Printed 3/16/9811:25:34 AM Page 2 of 2
Northe::t Utilitien ICAVP DR N . DR-MP3-0969 Miiistone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Modircation installation Discipline: Other Discrepancy Type: Installation Requirements System / Process: SWP NRC Significance level: NA Date faxed to NU:
Date Published: 1/25/98 Discrepancy: Equipment declared operable without test requirements being completed per PDCR package
Description:
Retest Requirements for PDCR MP3-91-044 require:
(from page following NEO 3.03, Page C4 of 4)
- 1. Establish baseline for a heat exchangerjust put back on line by averaging the data from SP3626.13. !
- 2. After Installation of the new screens, perform SP3626.13 to determine the effect of the screens on differential pressure and flow.
- 3. Monitor vibration of the heat exchangerwhen placing in service after screen installation.
- 4. Engineering to evaluate screen application to determine if any adjustments to SP3626.13 are required with the screens !
installed.
RFI-0824 was initiated to request the documents that confirm the above test requirements since they were not included as part of the PDCR package.
A review of the documents provided by RFl-0824 did not confirm that the retest requirements were completed for the following reasons:
- 1. No documents were provided that contained pressure and flow readings for the heat exchangers "just put back on line" that could be used to established the "before" or" baseline" readings.
- 2. Only one set of "after" readings were provided for heat exchanger 3CCP*E1 A. There was no "after" data provided for heat exchangers 3CCP*E1B or 3CCP*E1C.
- 3. No vibration data was provided.
- 4. No engineering evaluation was provided that compared the "before" and "after" readings. There was a handwritten note on Page C4 of 4 of NEO 3.03, Step 8.2 that stated "dp did not change" but this does not constitute an engineering evaluation particularly since there was no data available to support this conclusion.
This is a discrepancy because:
- 1. There is no evidence that the testing was ever performed.
- 2. There is no evidence that the engineering evaluations were ever completed.
- 3. There is an apparent lack of involvement of a quality review to assure that the package is complete.
- 4. From documentation provided for the review, the station closed the PDCR and declared the heat exchangers operable without the testing requirements being satisfied.
. .m Printed 3/16/9811:25:55 AM Page 1 of s
ICAVP DR N2. DR-MP3-0969 N*rthert Utilitie3 Millstone Unit 3 Discrepancy Report Valid invalid Needed Date initiator: Tamtyn, Tom B O O i'1
- VT Lead: Bass, Ken B O O '*
VT Mgr: schopfer, Don K B O O 1'1
- IRC Chmn: Singh, Anand K B O O 1*
Date:
INVALID:
Date: 3/13/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-0969 does not represent a discrepant condition The DR references RFI 0824 as the S&L document that requested documentation which confirmed the test requirements of PDCR MP3-91-044 were met. RF1-0826 is the correct information request. PDCR MP3-91-044 delineated the testing requirements j as follows:
- 1. Establish baseline for a heat exchangerjust put back on line by averaging the data from SP3626.13 j
- 2. Afterinstallation of the new screens, perform SP3626.13 to determine the effect of the screens on the differential pressure and flow
- 3. Monitor Vibration after screen installation
- 4. Evaluate screen application to determine if adjustments to SP3626.13 are required item 1 of the DR states that there was not any evidence that the testing was ever performed. The DR further states that the IRF 01307 response to RFI 0826 did not contain the pressure and flow readings for the heat exchangers "just put back on line" that could be used to establish the "before" or " baseline" readings.
The post modification funct;onal testing requirements were based on SP3626.13 " Service Water Heat Exchangers Fouling Determination"which was specified as part of the implementing AWO, M3-91-11829. This procedure verifies each heat exchanger flowrate, inlet and outlet pre ,sures, and inlet and outlet temperatures. The documentati.pn including the records of the surveillance testing data are maintained in NDS. In the case where the SP was used as part of a maintenance or modification restoration, the testing results are appended to the AWO and filed in NDS. The post modification test documentation from this SP was included in the RFI-0826 response for 3CCP*E1 A.
Item 8.2 on page C4 of 4 of the PDCR documentation package provided the note that "the detta P did not change". While the basis for this statement was not documented in a formal report as part of the PDCR close-out, the pre modification baseline of the heat exchanger is clear considering the extensive test results which have been collected through the weekly performance of SP 3626.13. To illustrate this, the Baseline "before mod" l readings for the heat exchangers are evaluated below based on the weekly testing and trend curves that are developed through the implementation of the weekly Service Water System Surveillance Testing (SP 3626.13). Documentation of this Printed 3/16/9811:25:56 AM Page 2 of s
ICAVP DR N:. DR-MP3-0969 N;rthe:st Utnie3 Millstone Unu J Discrepancy Report testing is also included in the attached graphical plots for the time period of January,1990 to July,1991 for all three CCP heat exchangers. The range of values for these plots is tabulated below to illustrate the that no relative difference existed between the readings before and after the screen additions per PDCR MP3-91-044.
The pre / post-modification testing recorded the following:
Parameter Post Mod Value Alert / Action Limit Pre Mod Value Pre Mod Range (1)
Differential Pressure 11 Psi 15/20 Psi 11-12 Psi 10-13 Psi Delta Temperature 6EF 15/20EF 5-6EF 2-9EF l 9000 gpm 7500/6642 I Flow gpm 8250-9000 gpm 8900gpm f (1) CCP*1A heat exchanger- Excludes readings in the Alert Range The other two heat exchangers were not specifically tested based on the PDCR test requirement to test "a heat exchange". .
Each screen assembly and its installation was the same and therefore the functional testing of a single heat exchanger after 1 I
the installation of the screening was adequate because the differential pressure, temperature and flow would result in the .
same relative delta as was seen on the component tested.
Additionally, the SP3626.13 weekly interval testing would have uncovered any abnormalities. For this reason AWOs M3 91 11832 (3CCP*E1B) and M3 91 11833 (3CCP*E1C) was annotated N/A thus Indicating that an additional functional testing was not required. While this justification process was not l i
delineated in the testing section of the AWO, and the testing method and documentation may not be representative of the today's expectation level ands standards, the practices used at the time of the screen modifications are both technically justified and the results considered acceptable.
Similar to the flow / pressure testing conditions discussed above, the documentation and data resulting from the vibration testing is not specifically delineated in the PDCR close-out packages. The AWO M3 91 11829 close out package contained in M3-IRF-1 01307 was annotated on page 3 of 3 that " vibration cut was SAT". A separate package which documented the actual vibration test data / report could not be located. The annotations included in the close-out package which relate to the satisfactory ,
completion of the required testing, attest to the fact the testing l was done and was determined to be adequate. The mere lack of documentation does not indicate an unacceptable condition.
Additionally, the fact that there has not been a reported vibration problem since the screen installation is additional testimony a vibration issue did not and does not exist.
Item 2 of the DR states that there is no evidence that the Page 3 of 5 Prtnted 3/16981125:56 AM
ICAVP DR No. DR-MP3-0969 Norther.ct Utilitiea Millstone Unit 3 Discrepaficy Repoft engineering evaluations required by the PDCR were ever completed. As can be seen from the above discussion, the surveillance procedure and PDCR/AWO signoffs verified the functionality of the components post modification. This data and the Note ("lP did not change') included on the copy of the PDCR close-out package (transmitted in M3 IRF-01307) adequa.ely documents the acceptability of the heat exchanger modification and that no changes in the surveillance procedures we :s required. A separate document was not necessary based on the pre and post modification testing which was performed and filed in NDS.
Item 3 of the DR states that there is an apparent lack of involvement of a quality review to assure that the package is complete. The basis for this contention in the DR appears to be from the fact that the test data was not included with the PDCR package. The documentation of the test data would be included in a separate package from the PDCR and typically with the results of the Completed Surveillance Procedure. These documentation packages would be stored in NDS which is where the information attached to this response wa', located. While the justification process was not specifically c,utlined in the testing section of the AWO, and the testing method and documentation may not be representative of the today's expectation level, the practices used at the time of the screen modifications are both technically justified and acceptable. All required sections are signed and/or initiated by the responsible person who conducted and/or approved the close-out activity.
)
ltem 4 of the DR states;'"From documentation provided for the J review, the station closed the PDCR and declared the heat exchangers operable without the testing requirements being satisfied" Based on the information and discussions of items 1, 2, and 3 (above) this DR conclusion should be revised.
Significance Level criteria do not apply here as this is not a discrepant condition.
1 L
Conclusion:
NU has concluded that the issues reported in Discrepancy '
Report DR-0969 does not represent a discrepant conditions. The post modification functional testing requirements were based on SP3626.13 " Service Water Heat Exchangers Fouling Determination" which was specified as part of the PDCR and the implementing AWO, M3-91-11829,11832 (3CCP*E1B),11833 (3CCP*E1C). This procedure verifies each heat exchancer flowrate, inlet and outlet pressures, and inlet and outlet temperatures. A separate vibration monitoring was specified as part of the PDCR and AWO noted above. The annotations included in the NDS copy of the AWOs, document the testing results to a level appropriate for the time. The documentation l including the records of the surveillance testing data are maintained in NDS. The required expectations / standards for the modification and its close-out documentation would be different for a modification developed under today's standards. However, these same documer.tation standards did not exist at the time of Page 4 of 5 Printed 3/169811:25:56 AM
ICAVP DR Nr. DR-MP3-0969 N:rthert Utilities Millstone Unit 3 Discrepancy Report PDCR MP3-91-044. Six (6) years of satisfactory performance is further evidence that the post modification functionality of the heat exchanger is not an issue. An acknowledgment of the satisfactory results for each of the required PDCR tests is provided in the PDCR and AWO documentation and therefore no corrective action is necessary.
Significance Level criteria do not apply here as this is not a discrepant condition.
References
- 1. Surveillance Test Report dated 7/8/91(includes graphical plots of Hx test data for the time period of January,1991 to Ju~y, ,
1991)
- 2. AWO M3 91 11829 (3CCP*E1 A) (includes post mod test data and approval)
- 3. AWO M3 9111832 (3CCP*E1B)
- 4. AWO M3 9111833 (3CCP*E1C)
Previously identified by NU? U Yes (@ No Non Discrepent Conddion?(#) Yes Q No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: spear, R.
VT Lead: Bass, Ken O O mm VT Mge: schopfer. Don K IRC Chmn: singh, Anand K Date: 3/12/98 j sL Comments: S&L bases their acceptance of NU's resolution to Discrepancy j Report MP3-0969 on the following facts.
The non-safety related screens have been installed in the heat exchanges since 1991 with no apparent problems or concems.
The heat exchangers are included in a weekly fouling surveillance.
NU's acknowledgment that what was acceptable in 1991 may not be representative of today's expectations. l Completing the tests now would not have any value-added to the heat exchangers or the service water system.
I Page 5 of 5 Printed 3/16/9611:25:56 AM
Northert Utilities ICAVP DR N3. DR-MP3-1003 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Test Procedure p .
Discipline: Maintenance Discrepancy Type: 0 & M & T implernentation Om g
System / Process: sWP NRC Significance level: 4 Data faxed to NU:
Date Published: 2/5/98 Discrepancy: Adequate information was not provided to verify annual inspections of epoxy coatings.
Description:
Various modifications included applying epoxy coatings to portions of the service water system piping and component surfaces to prevent future corrosion. A requirement that this coating be visually examined annually to assure its integrity was included the PDCR's. Adequate information was not provided to verify that all coating areas are inspected annually and that an i acceptance criterial for the visual inspection has been established.
This is considered a generic programatic discrepancy.
l J
A partiallisting of PDCR's that included application of an epoxy coating includes:
PDCR 3-94-064 PDCR 3-91-024 PDCR 3-91-044 PDCR 3-94-040 PDCR 3-86-083 PDCR 3-93-220 PDCR 3-91-056 PDCR 3-94-094 Review Valid invalid Needed Date 1/2a,98 initiator: spear, R. O O O VT Lead: Bass, Ken 8 O O 1/28/98 VT Mgr: schopfer, Don K B O O 1/29/98 IRC Chmn: singh, Anand K 8 O O 2/2/98 Date:
INVALID:
Date: 3/12/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-1003, 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 M3-96-1142 has been written to develop and track resolution of this item per RP-4.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-1003, has identified a condition not previously discovered by NU which Printed 3/16/9611:26:11 AM Page 1 of 2
l ICAVP DR N . DR-MP3-1003 l Northea:t Utilities l
Millstone Unit 3 Discrepancy Report
- requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-1142 has been written to develop and track resolution of this item per RP-4.
Previously identified by NU? O Yes @ No Non Discrepent Condition?O ves @ No Resolution Pending?O ve. @ No Re osutioaunre.olved?O ve. @ No Review initiator: Spear, R.
Ce c@ Date VT Lead: Bass, Ken 0 0 0 S1 m O O Si m VT Mgt: Schopfer, Don K O O wm IRC Chmn: Singh, Ant *K O O O Date:
SL Comments:
l l
I Printed 3/16/9611:26.11 AM Page 2 of 2 1
,e ICAVP DR N2. DR-MP3-1027
- Northe st Utilitie3 Ministone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potennal Operability lasue Diecipline: Mechanical Design Ow Discrepancy Type: Calculation g System / Process: NEW NRC SigniScance level: 4 Date faxed to NU:
Date Published: 2/7,96 Diecrepancy: Revision of Calculation 97-ENG-01430-M3 for DCR M3-97042
Description:
The purpose of Calculation 97ENG-01430-M3, Rev. O is to determine the allowable time Pumps 3RSS*P1C and D can operate during their new quarterly 4.0.5P ISTs For the quarterly ISTs, the C and D pumps operate in recirculation through test lines installed under DCR M3-97042 and the heatup of RWST water is limited to 200F, This calculation also determines the effect on the RWST temperature of pumping water the heated water back to the RWST after each IST.
One discrepancy was identified in Calculation 97ENG-01430-M3:
On page 7, the calculation assumes that the volume of water in an RSS pump is 63.29 ft3, which is 473 gallons. However, page 23 of Calculation ES-232, Rev. 2, states that each RSS pump has an intemal volume of 385 gallons. If the smaller volume is valid, this would be a non-conservative error.
Review Valid invalid Needed Date Initiator: Wakeland. J. F. G O O 2/2/98 VT Lead: Nerl, Anthony A B O O 2/2/98 VT Mgt: Schopfer, Don K B O O 2/2/98 IRC Chmn: Singh, Anand K B O O 2/3/98 Date:
INVALID:
Date: 3/12/98 RESOLUTION: DISPOSITION:
NU has concluded that Discrepancy Report, DR-MP3-1027, 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 M3-98-1280 has been written to develop and track resolution of this item per RP-4.
CONCLUSION:
NU has concluded that Discrepancy Report, DR-MP3-1027, 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 M3-98-1280 Page 1 of 2 Printed 3/16/9811:26.42 AM
- . . . . . ~ . --- -._ - - - . - - - -- --- . - -
ICAVP DR Nr. DR-MP3-1027 N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report has been written to develop and track resolution of this item per RP-4.
Previously identified by NU? O Yes (#) No Non Discrepant Condition?U Yes (#) No Resolution Pending?O Yes @)No Resoiution vor.soived?O Yes # No Review initiator: Wakeland. J. F.
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K Date: 3/12/98 sL Comments: Given the current period allowed for operating an RSS pump in recirculation during its monthly 4.0.5P suveillance test, decreasing the volume of water in the RSS pump to the correct value will not increase the maximum water temperature in the pump to more than 260F, the pump and piping system design temperature, based on the following bounding calculation: 50F +
(473 gal /385 gal)(200F-48F) = 207F.
Therefore, Sargent & Lundy agrees that correction of this calculation error may be deferred until after Unit 3 restart.
l l
l 1
l Page 2 of 2 Printed 3/16/9811:26:43 AM
ICAVP DR Ns. DR-MP3-1067 N:rtheart Utilitie3 MillstDne Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: Modircation Design p Discipline: Mechanical Design Ow Discrepancy Type: Licensing Docurnent g j System / Process: NEW NRC significance level: NA Date faxed to NU:
Date Published: 2/28/98 Discrepancy: DCR M3-97102 and FSAR CR 97 MP3-569 are not consistent with each other.
Description:
FSAR Section 6.3.2.5 requires that a 50 gpm leak in the Engineered Safeguards Features (ESF) Building, excluding the pipe tunnels, be capable of being detected and isolated within 30 minutes. FSAR CR 97 MP3-569 changes the requirement to state that a 50 gpm leak is capable of being detected and isolated within approximately 30 minutes.
DCR M3-97102 does not achieve the requirement in FSAR Section 6.3.2.5, before or after FSAR CR 97-MP3-569.
Engineering Evaluation M3-EV-970281 provides the support for the conclusions in DCR M3-97102 and is attached to the DCR.
According to engineering evaluation M3-EV-970281, paragraphs '
1 & 2 on page 4, a 50 gpm seal failure in the RHS, RSS & SlH pumps would be detected in approximately 11 minutes. The same evaluation on page 7, states that prior to the modification a 50 gpm passive faliure between the pipe tunnel and the CHS pumps would not be identified for a significantly longer time.
Page 7 of the evaluation states that after the modification, a 50 gpm passive failure between the pipe tunnel and the CHS pumps would be detected within 48 to 68 minutes. The detection time of 48 to 68 is not within the approximately 30 minutes as stated in FSAR CR 97-MP3-569.
Review Valid Invalid Needed Date initiator: Feingold, D. J. 8 O O 2/19<98 VT Lead: Nerl, Anthony A G O O 2/21/98 VT Mgr: schopfer, Don K @ Q Q 2/21/98 IRC Chmn: Singh, Anand K B O O 2r2.s98 Date:
INVALID:
Date: 3/13/98 RESOLUTION, Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1067, does not represent a discrepant condition. The attached copy of FSAR CR 97-MP3-569 was revised prior to PORC approval to state "approximately - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for leaks in the Auxiliary Building", thereby making the FSAR change consistent with DCR-97102 and Engineering Evaluation M3-EV-970281.
Significance Level criteria do not apply here as this is not a discrepant condition.
Printed 3/16/9811:26:59 AM Page 1 of 2
)
)
ICAVP DR No. DR-MP3-1067 NIrthea:t Utilities Millstone Unit 3 Discrepancy Report
Conclusion:
i NU has concluded that the issue reported in Discrepancy Report, j DR-MP31067, does not represent a discrepant condition The !
attached copy of FSAR CR 97-MP3-569 was revised prior to j FORC approval to state "approximately - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for leaks in the l Auxiliary Building", thereby making the FSAR change consistent with DCR 97102 and Engineering Evaluation M3-EV 970281, l Significance Level criteria do not apply here as this is not a i
discrepant condition. l Previously identifled by NU? O Yes @ No NonDiscrepentCondition?@ Yes Q No l
Resolution Pending?O ve. @ No ResolutionUnresolved?O ve. @ No Review initiator: Feingold, D. J.
VT Lead: Nerl, Anthony A
, VT Mgr: schopfer, Don K 1RC Chmn: Singh, Anand K Date:
SL comments:
I l
l l
[
l Printed 3/16/9611:26:59 AM Page 2 of 2
st Utinties ICAVP DR N2. DR-MP3-0580 Milistone unit 3 Discrepancy Report Review Group: System DR RESOt.UTION REJECTED Review Element: system Design Diecipune: Mechanical Design g y ,,
Discrepancy Type: Ucensing Document systemrProcess: Mvx O No NRC SignMicencelevA 3 Date faxed to NU:
Date Putdished: 11/22/97 h . 3 Secondary Containment Drawdown with SLCRS and ABVS Deectfption: During review of the Supplementary Leak Collection and Release System (SLCRS) and the Auxiliary Building Ventilation System (ABVS) discrepancies regarding the required secondary containment drawdown time were identified.
Secondary containment drawdown requirements in the FSAR are:
FSAR Section 6.2.3.3 states that the SLCRS in conjunction with the auxiliary building filter system draws down the pressure to the minimum 0.4 inch negative pressure in 110 seconds from the time of emergency diesel generator breaker closure.
FSAR Section 6.2.3.3 states that the SLCRS and ABVS is required to drawdown the SLCRS areas to a negative pressure within 120 seconds after the accident. The negative pressure is measured at the Auxiliary Building 24-6 elevation and maintained per technical specifications at greater than or equal to 0.4 inches of water guage after a design accident.
FSAR Table 1.9-2, SRP 6.5.1 B.5 states that the SLCRS draws down enclosures contiguous to the containment to a minimum negative pressure of 1/4 iwg in 60 seconds after SIS.
SER Section 6.2.3 states that the capacity of the SLCRS is sufficient to reouce and maintain a pressure of -0.25 iwg throughout the enclosure building and contiguous buildings within 1 minute after the accident, assuming a wind velocity of 22 mph.
The calculations that determine the secondary containment drawdown time and SLCRS airflow are calculations:
P(B)-843, Rev. O Supplementary Leak Collection and Release System P(B)-1089, Rev. O Establish Acceptance Criteria for Air Leakage Through Pipe and Electrical Penetrations The objective of calculation P(B)-843 was to determine the required capacity of SLCRS and the time required for SLCRS to achieve a negative pressure of 0.25 iwg in the containment enclosure building and contiguous buildings. The results of the calculation indicate that with a 9,500 cfm SLCRS fan capacity the drawdown time to -0.25 iwg is 30 seconds. Review of the calculation identified the following discrepancies:
i 1. Calculation does not provide references for the building l
. ..s. . _ . ..a w ss_ nu. .ww
' ~ ~ " ~ ~ ~ - ~ ~ " ' " ~ " ' - ' ~ "
Printed 3/16/9611:16:13 AM Page 1 or 8
1 l
l ICAVP DR N3. DR-MP34580 Northezt Utilitie3 '
Millstone Unit 3 Discrepancy Report
- 2. Calculation does not adequately account for differer.ces in air density between the outside air (infiltration into building) and at the inlet to the SLCRS exhaust fan. The air density at the fan inlet is lower than the infiltrating air due to heat gains in the l building and the electric heater in the SLCRS filter unit.
- 3. Assumes that fan flow is constant because the fan is equiped with variable inlet vanes. Neither P&lD EM-148E-12 nor specification 2176.430-141 show inlet vanes and associated controls for fans 3HVR*FN12A/128.
- 4. Calculation does not Eddress wind effects on leakage through the containment enclosure.
Calculation P(B)-1089 determines the allowable leakage rates and exhaust airflows for the areas exhausted by the SLCRS fans. Review of the calculation identified the following discrepancies:
- 1. Calculation determined that an exhaust rate of 130 cfm was required for the hydrogen recombiner building,4950 cfm for the containment enclosure building and 1350 cfm for the main steam valve building. P&lD EM-148E-12 shows the exhaust openings for the hydrogen recombiner building being blanked off, no airflow exhausted from the main steam valve building, and 6430 cfm exhausted from the containment enclosure.
- 2. Calculation does not address wind effects on leakage through the containment enclosure. This results in under estimating the leakage through the containment enclosure.
In response to M3 RFl-00472 that requested the calculation (s) that determine the secondary containment drawdown time with the SLCRS assisted by the ABVS, NU in M3-IRF-00622 transmitted IST 3-93-45 and IST 3-93-46 which presented SLCRS and ABVS test data and calculation 92-071-339M3, SLCRS Drawdown Test Pressure Correction Factor Calculation.
NU stated that the combination of these documents satisfies the request for the secondsry containment draw down time with SLCRS and ABVS. Review of IST 3-93-045 SLCRS & ABVS Restest of PDCRs MP3-93-200 & 205 and IST 3-93-046 SLCRS
& ABVS Restest of PDCRs MP3-93-200 & 205 in Winter Mode from an engineering perspective identified the following discrepancies:
- 1. Plant conditions at time of the test did not correspond to postulated post-LOCA conditions. Therefore, not all heat loads that would be present during the postulated accident were present. The tested drawdown time needs to be adjusted to address areas such as the main steam valve building that have the non-safety ventilation system that provides cooling during normal plant operating isolated on a SIS. Due to differences in heat gains present during test and accident conditions the tested draw down time will be faster than the accident condition time.
~
Page 2 of 8 Ponted 3/169811:16:14 AM
9 ICAVP DR No. DR-MP3-0580 Northe:st Utilities Millstone Unit 3 Discrepancy Report
- 2. Test did not record differential pressures and times for the recombiner building which is inside the secondary containment boundary.
- 3. Test results de not identify SLCRS or ABVS system airflows during test. Technical Specification 4.6.6 .1 states that the SLCRS is considered operable with a flow rate of 7600 cfm to 9800 cim. Results need to be adjusted to correspond to minimum airflow conditions since the draw down time is directly affected by the SLCRS airflow rate.
- 3. The acceptance criteria of a 2.5 minute drawdown time to 0.4 iwg negative pressure in IST 3-93-045, Rev. O, Change 7 and IST 3-03-046 Rev. O, Change No.1 do not agree with FSAR drawdown times show above.
NU letter B15028 dated December 14,1994 submitted a proposed revision to Technical Specifications for the Supplementary Leak Collection and Release System. The proposed Section 4.6.6.1.d.3 Surveillance Requirement is
" Verifying that each system produces a negative pressure of greater than or equal to 0.1 inch Water Guage in the Auxiliary Building at 24'6" elevation within 60 seconds after a start signal and a negative pressure of greater than or equal to 0.4 inches Water Guage in the Auxiliary Building at 24'6" elevation within the next 120 seconds." On page 6 of the letter NU states "Wdh the proposed negative pressure criteria for the secondary containment, it could be assummed that all leakage into the secondary containment is filtered, since a sufficient negative pressure is achieved within one minute and the final required negative pressure is achelved within the next two minutes."
When the difference between accident and test heat loads, wind effects, and correction factor for the measured differential pressure are accounted for, not all areas within the containment 1
enclosure will be at a negative pressure within 60 seconds.
Other Discrepancy Reports that address related issues:
DR MP3-0514 Containment Enclosure Building Negative Pressure DR-MP3-0030 Drawdown Times for Rod Ejection Accident and LOCA Review Valid invalid Needed Date 1o/2+97 Initiator: Stout, M. D. O O O VT Lead: Nerl. Anthony A O O O 1 o/31/97 VT Mgr: Schopfer, Don K S O O 5 '">/S7 IRC Chmn: Singh. Anand K B O O 11i18/97 Date:
INVAUD:
Date: 3/10/98 RESOLUTION: NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0580, do not represent discrepant conditions.
Page 3 of 8 Printed 3/16/9611:16:14 AM
l ICAVP DR N2. DR-MP3 0580 Northext Utilitin Millstone unit 3 Discrepancy Report DR-MP3-580 identifies issues with regard the Secondary l Containment drawdown times provided in the FSAR, Technical 4 Specifications and design calculations.
FSAR Section 6.2.3.3 The referenced FSAR Section 6.2.3.3," Safety Evaluation,"
provides a description of the Secondary Containment drawdown requirements. The statements regarding the drawdown times have been reviewed per the CMP Annotation Process and are correct and consistent with the Technical Specifications.
Therefore, no FSAR changes with respect to drawdown times are required.
Amendment No. 87 issued on 12/8/93 changed the Technical Specifications to increase the required drawdown time from 60 i seconds to 120 seconds and increased the required negative pressure of 0.4 in. wg.
Amendment 10 issued on 8/24/87 changed the Technical Specifications to increase the emergency diesel startup time ,
from 10 seconds to 11 seconds to avoid declared diesel l I
generator failures for fractions of a second beyond 10 seconds.
The Amendment No.10 changes do not impact the ESF response time requirements. In addition, Technical Specification Bases, Section 4.6.6.2 states that the time to achieve the required negative pressure is 120 seconds, with a loss-of-offsite power ccp cident with a SIS. Therefore, the 110 seconds from the time of emergency diesel generator breaker closure plus the emergency diesel startup time is correct and consistent with the total drawdown time of 120 seconds.
FSAR Table 1.9-2, SRP 6.5.1.B.5 4 The statements in this section were compiled for use by the NRC l I
for review during the request for FTOL stage for MP3. FSAR Section 1.9 and the associated tables are considered historical in nature and are not updated. FSARCR 97-MP3-95 was initiated as a result of the CMP FSAR Annotation process to clarify FSAR Section 1.9 as historical. FSARCR was completed on 6/30/97.
SER Section 6.2.3 The MP3 Safety Evaluation Report (NUREG-1031) was issued on 8/2/84 by the NRC. Amendment No. 87 issued on 12/6/93 changed the Technical Specifications to increase the required drawdown time from 60 seconds to 120 seconds and increased the required negative pressure from 0.25 in wg. to 0.4 in, wg.
Amendment 87 supersedes SER, dated 8/2/84, section 6.2.3 with regard to drawdown time and required vacuum.
Calculation P(B)-843 CR M3-97-2187 was initiated on 7/14/97 to track potential FSAR deficiencies which were identified during the CMP FSAR annotation process. CR M3-97 2187 corrective action plan required calculation P(B)-843 to be revised. CCN 01 to calculation P(B)-843, Rev. O, was approved on 10/30/97 and closed CR M3-97-2187. CCN 01 states that the SLCRS is a unique system in that its sizina is not based on rioorous Page 4 of 8 Printed 3/16/9611:16:14 AM
J ICAVP DR No. DRUEP3-068F Northeast Utilities Millstone Unit 3 Discrepancy Report methodology. To do so would require postponing the design until construction is complete and then a rigorous analysis would determine its capacity based on "as constructed" leakage paths, concrete cracks vendor data, etc. To avoid such delays, secondary containment leakage determination is based on " rule of thumb" design criteria derived form previous experience. The criteria adopted on Millstone Unit 3 were three volume changes per day for the containment enclosure and one volume change per day for the balance of the secondary containment. A rigorous computation and system analysis is unwarranted considering the uncertainty of the basic design input. The installed equipment is periodically tested and proven to the defined operating parameters. Therefore, the initial design capacity information in calculation P(B)-843 is considered historical and no additional changes to calculation P(B)-843 are required.
Note that the variable inlet vane is manually fixed by the vendor supplied lever. The vendor drawings 12179-2170.430-002G and 12179-2170.430-004 showing the fan, VIV and lever control.
Calculation P(B)-1089
- 1) DR MP3-509 and DR-MP3-580 have identified similar issues regarding the presentation of P&lD general area exhaust flow paths and calculation P(B)-1089. The following is the response tu DR-MP3-509 which applies to item 1 of calculation P(B)-1089 issues in DR-MP3-580.
DR-MP3-0509 identifies that P&lDs EM-148E, EM-148A, and EM-1528 do not provide the general area exhaust flow paths required to maintain the Secondary Containment under a negative pressure following a LOCAl The format and content of the MP3 P&lDs are established in procedure EDI 30255, "MP3 Piping and Instrumentation Diagrams Detailed Instructions for Format and Content." EDI 30255 does not require MP3 P&lDs to reflect the actual building arrangement. The P&lDs provide the l systems configuration required to maintain the Socondary l Containment under a negative pressure following a LOCA. The !
P&lDs are not required to provide general area exhaust flow rates, therefore, changes to P&lDs EM-148E, EM-148A, EM1528 are not required.
The Secondary Containment is comprised of the containment enclosure building, the auxiliary building, and sections of the engineered safety features building, the main steam valve bulloing, and the hydrogen recombiner building. The interior walls of the engineered safety features building, the main steam valve building, and the hydrogen recombiner building which separate the areas contiguous to the containment from the remainder of the buildings serve as the secondary containment boundary. The areas that are not directly exhausted by an exhaust duct and registers located within the area are interconnected with adjacent areas that contain exhaust ducts and registers. The Secondary Containment Boundaries are identified on S&W EM-60 series drawings,
- Plant Fire Radiation and Pressure Boundaries." The areas of the hydrooen Printed 3/16/9611:16:14 AM Page 5 of 8
ICAVP DR N:. DR-MP3-0580 Northe:st Utilitie3 Millstone Unit 3 Discrepancy Report recombiner building that contain the capped off ducts are not part of the Secondary Containment Boundary The areas of the main steam building arid hydrogen recombiner building that are within the Secondary Containment boundary are drawn down through the enclosure building by the SLCRS.
Calculation P(B)-1089," Establish Acceptance Criteria for Air Leakage Through Pipe and Electrical Penetration Seals,"
provides a summary table for the exhaust flow rates for the applicable areas. The summary table shows the exhaust flow rate for the containment enclosure building as 4950 cfm, the hydrogen recombiner building as 130 cfm and the main steam valve building as 1350 cfm. P&lD EM-148E indicates the total exhaust flow from these areas through the 36' X 18' screened opening as 6430 cfm.
As an enhancement, CR M3-97-4557 was initiated to clarify the air flow rates on all of the MP3 P&lDs. CR M3-97-4557 corrective action requires a review of all air flows and notes on HVAC P&lDs, related Technical Specifications, and FSAR Sections. Based on the evaluation results, the P&lDs will be revised to include clarifying notes or remove air flow information and revise EDI 30225, if required.
2)The containment enclosure was purchased under Specification 2190.371-442. The Specification addresses wind effects on leakage through the enclosure bui! ding by assuming a 22 MPH wind at .0195 cfm/ft2. The wind effects result in~a total allowable leakage of 2,830 cfm for the enclosure building. The containment enclosure leakage was not computed i,. calculation P(B)-1089, as stated on page 9. With the wind effects addressed in the specification, no changes to the calculation are required.
IST 3-93-45 and 3-93-46 1)The heat gain in the MSVB and other areas of the Secondary Containment during the first 120 seconds post LOCA does not have a significant impact on the test results. The drawdown test is typically performed during refueling outages but has been performed at 100% power. The test results are not significantly different between the testing during refueling outage and the testing during 100% with the MSVB ventilation system isolated.
Therefore, the test method and results are satisfactory.
- 2) The area the hydrogen recombiner building that is within the q Secondary Containment boundary is shown on the S&W EM-60 series drawings. This area is drawn down through the enclosure building by the SLCRS. SER to Amendment No. 87 concludes that SLCRS (with ABVS)is capable of attaining the required !
negative pressure of 0.4 in, wg. within 120 seconds and that i
utilizing the single measurement location in the auxiliary building a the 24' B' level is suitable.
3)SLCRS and ABVS airflows are taken once a month to verify Page 6 of 8 Printed 3/164811:16:14 AM i
ICAVP DR N2 DR-MP3-0680 N:rthert Utilities ministone Unit 3 Discrepancy Report fan performance per SP 36141 and SP 3614A. The drawdown test is a functional test of the system and a verification of boundary integrity. There is no requirement to adjust the drawdown time to correspond to the minimum air flow rate.
Technical Specification Bases, Section 4.6.6.2.2 states that since SLCRS fan flow rates are verified to be acceptable on a more frequent basis than the drawdown test surveillance, and by means of previous testing the minimum flow rate is acceptable, verifying a flow rate during the drawdown test would not provide an added benefit.
- 4) Acceptance criteria of these tests were based on a proposed licensing change. The proposed licensing change was amended to a 2 minute drawdown after the tests were completed. The change to the 2 minute drawdown was based on the test results meeting the required negative pressure of 0.4 in wg. criteria within 2 minutes.
SER for Amendment No. 87, dated 12/8/93, concludes that j SLCRS (ABVS) is capable of attaining the required negative pressure of 0.4 in. wg. within 120 seconds based on the test results.
PTSCR 3-16-94, dated 12/14/94 I The last paragraph in DR-MP3-580 describes a proposed revision to TS. This revision to the Technical Specifications is being reviewed by the NRC, therefore, is not part of MP3 license.
Attachments:
CCN 01, Calculation P(B)-843, Rev. O CR M3-97-2187 Previously klennaed by Nu? U Yes @ No Non Discrepent Condition?O Yes @ No naduuan Pendino?O Ya @ No nadutionUnradwd?O va @ No
- n. view
- nog ; - needed cue initiator stod. M. D. yg VT Lead: Neri, Anthony A yg VT Mgr: Schoprer, Don K O wm NtC Chmn: singh, Anand K O O O *1596 Date: 3/10/98 sL comments: 1. Agree with NU's response that FSARCR 97-MP3-95 identifies FSAR Table 1.9-2 as historical data and that that SER for Amendment No. 87 supersedes SER dated 8/2/1984.
- 2. The secondary containment drawdown time is a function of the l boundary leakage, building volume, heat gain the the building, !
and the exhaust flow rate. One set of surveillance tests verifies SLCRS and ABVS airflows are within limits and another set of surveillance tests verifies that secondary containment drawdown )
time is less than or equal to 120 seconds. Neither of the tests establish the secondary containment boundary leakage as stated in Branch Technical Position CSB 6-3 B.3. Since drawdown tests do not measure the SLCRS and ABVS airflows the ability of the SLCRS and ABVS systems to drawdown the secondary Pnnled *1651611:16:15 AM PeGe 7 of 8
ICAVP DR No. DR-MP3 4580 N:rthea:t Utilities Millstone Unit 3 Discrepancy Report containment within 120 seconds at the lowest Technical Specification allowable airflows is not verified by test nor analysis.
NU's response should address why they do not consider this to be a discrepant condition.
- 3. Calculation P(B) 1089 determines the allowable leakage rates and exhaust airflows for the areas exhausted by the SLCRS fans.
The results of calculation P(B)-843 are used as input for establishing the exhaust flow rates. Calculation P(B)-1089 needs to be revised to address the use of unverified data from
" historical" calculation P(B)-843, CCN1.
- 4. Calculation P(B)-843, CCN 1 states that the secondary containment leakage criteria adopted for Millstone 3 was three volume changes per day for the containment enclosure and one volume change per day for the balance of the secondary containment. The CCN does not provide adequate justification for not performing the pressure response analysis identified in Branch Technical Position CSB 6-3 B.2 and B.4.
I l
l I
i Page 8 of 8 Prirded 3/16/9811:16:15 AM
ICAVP DR Ns. DR-MP3-0660 N:rthert Utilities Millstone unit 3 Discreparicy Report Review Group: System DR RESOLUTION REJECTED Review Element: System Design p, gy ,,,,
Discipline: Mechanical Design Discrepancy Type: Calculation Om
@ No System / Process: HVX NRc significance level: 3 Date faxed to NU:
Date Published: 12/8/97 Discrepancy: Emergency Generator Enclosure Maximum Temperature Calculation
Description:
During review of calculation P(B)-953, Rev. 2
- Emergency Generator Enclosure Ventilation' a discrepancy in the determination of the room temperature was identified.
The results of the calculation show that at the extreme maximum outside air temperature of 103*F the temperature in the silencer room is 121'F. This is higher than the 120*F maximum temperature stated in FSAR Section 9.4.6.1.
The calculation uses an airflow rate of 120,000 cfm and an air density of 0.075 lb/ cubic feet in calculating the temperature rise between the supply air and exhaust air in the room. At the design outside air temperature of 86*Fdb/75'Fwb the density of air is 0.0708 lb/ cubic feet. Since the supply fans are a constant volume device the 0.075 !b/ cubic feet air density used under estimates the temperature rise in the room by 1) approximately 6% at the design outside air temperature of 86*Fdb/75'Fwb, and
- 2) by approximately 9% at the extreme maximum outside air temperature of 103'Fdb.
Review Valid invalid Nseded Date initiator: Stout, M. D. O O O 11/22/97 VT Lead: Nerl. Anthony A B O O 11/22/97 VT Mgr: schopfer, Don K B O O 12i1/97 1RC Chmn: singh, Anand K O O O 12/4/97 Date:
INVALID:
Date: 3/2/98 RESOLUTION: NU has concluded that Discrepancy Report DR-MP3-0660 has identified a condition not previously discovered by NU which requires correction.
The reference to the maximum outdoor temperature of 103'F and the resulting 121*F as the maximum indoor temperture was made in the calculation to establish a tie with the temperature values of the environmental zones that appear in Appendix 3B to section 3.11 of the FSAR. It now appears that making that reference was a mistake as it has no benefit and only leads to confusion. It is, therefore, proposed to delete the maximum temperature values given for the sliencer room and the Enclosure as a single zone from the calculation. In any case, the operability of the emergency diesel generator is not in question, since the maximum diesel generator room temperature is Printed 3/16/9811:16.39 AM Page 1 of 3 l
l
ICAVP DR N2. DR-MP3-0660 Northext Utilitie3 iilliisone linit 3 ~ Discrepancy Report conservatively estimated at 117.2*F when the outdoor temperature is 103'F whereas the specified maximum temperature in specification 2447.300-241 (E 241), Emergency Diesel Generators, is 120*F. The concept of operability due to temperature does not apply to the silencer.
Regarding the second issue of the DR, it is common practice to use standard air density and to not use density correction factors in HVAC calculations when the temperature changes are not very large and the inputs are so grossly overestimated (the margin in the estimated waste heat from the diesel engine alone given by the vendor in attachment A to the calculation is in the order of 40%, or,16% of total room load) . Nevertheless, using the density correction factors of the DR, the room temperatures at outdoor design temperature and outdoor maximum temperature change from 100.2*F to 100.6*F and from 117.2*F to 118.5'F, respectively. The indoor temperature of 100.6*F is still in compliance with the revised FSAR statement. The indoor maximum temperature of 118.5'F still does not affect operability. The 118.5'F is, however, overestimated because of the simple rerating of the Dt by the density correction factors. A rigorous recalculation is expected to result in a temperature not much different than 117'F since a higher room temperature will reduce the heat gains into the room and increase transmission losses to the outside.
The approved corrective action plan to CR M3-97-4788 requires re-evaluation of the temperature values for the silencer room, and a re-evaluation of the air density correction factors effect on indoor room temperatures. The assignment is being tracked by AR 97030723-02. Since the silencers are in separate rooms and are not affected by temperature and the operability of the diesel generator is not in question, completion of corrective action has been deferred to post startup.
Because this issue has no effect on licensing basis / design basis, '
NU considers this a Significance Level 4. 4 Attachments:
CR No. M3-97-4788 with approved corrective action plan.
Previously identified by NU? O Yes (e) No Non Discrepent Cond6 tion?Q Yes @ No Resolution Pending?O Y.. @ No ResolutionUnresolved?O Yes @ No Review initiator: Stout, M. D.
VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K gg IRC Chmn: singh. Anand K we l O O O Date: 3/2/98 SL Comments: Agree that correcting the air density used in the calculation has a small impact (-0.5'F) on resulting room temperature and that l based on information in Attachment A to calculation P(B)-953, Rev. 2 that diesel engine heat loss values are conservative. This should be addressed in the calculation.
Printed 3/169811:16:39 AM Page 2 of 3 i
i
[
l ICAVP DR Na DR-MP3-0660 l Northext Utilitien Millstone Unit 3 Discrepancy Report Assumption 5 in calculation P(B)-953, Rev. 2 states that a purpose of the calculation is to determine the temperature in the vicinity of the isolation transformer, which is at the upstream end of the silencer. The function of this component and the impact of slightly higher temperatures would have needs to be addressed in NU's response.
FSAR Section 9.4.6.1 Design Basis item 3. states that the emergency generator enclosure maximum Indoor air temperature is 120*F. As the silencer room is inside the enclosure building, the 120'F maximum temperature stated in the FSAR is applicable to the maximum temperature in the silencer room.
The approved corrective action for CR M3-97-4788 states
" Evaluate the referencc to the temperature values for the silencer room and delete if appropriate. Evaluate the effect of air density correction factors on the indoor room temperature and revise calculation as required. (Ref calc. P(B)-953, rev. 2)". The corrective action does not address the discrepancy between the calculated temperatures in the silencer room and 120*F maximum temperature stated in the FSAR.
l l
f Ponted 3/16/9811:16:39 AM Page 3 of 3
ICAVP DR N2. DR-MP3 0675 N:rthert Utilitie3 i Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operability issue Discipline: Mechanical Design I Om Discrepancy Type: calculation g SystenvProcess: DGX NRc Significance level: 3 Date faxed to NU:
Date Published: 1/25/98 Discrepancy: Discrepancies for Calculation SDP-EGS-01345M3, Rev. 05
Description:
Review of the calculation " Emergency Diesel Jacket Water and Intercooler Water (EGS) SDP" (Stress Data Package), calc. no.
SDP-EGS-01345M3, Rev. 05 resulted in the following discrepances:
1
- 1. Operating Condition 3 assumes that the valve 3EGS*AOV43NB falls in the full bypass mode. Valve 3EGS*AOV43NB is not shown on the EGS system P&lD's EM-116A-27 and EM-116C-12, and it could not be found in the PDDS data base. Valves 3EGS*AOV43NB appear to have been replaced by valves 3EGE*TCV50NB. (This discrepancy was also noted in a reference to this calculation, calculation P(T)-
0997, as documented in the Discrepancy Report # DR-MP3-0646.) Valve number 3EGS*AOV43A/B is also listed on the Miscellaneous infcrmation Sheet, Section e., page 19 of the calculation.
- 2. The table System Design Conditions, page 14 of the calculation was apparently constructed using the Line Designation Table (Reference 1). However, unlike the System Design Conditions table, the Millstone til Line Report of 8/12/97 has no entry for design pressure for piping from the fresh water expansion tank to plant drainage, and piping from 3EGS*RV32A/B drain funnel to the floor drains. No supporting justification, either directly or by reference, was found in the calculation for this design pressure.
- 3. Line no. 3-EGS-500-26-3 in the System Design Specification l Sheet (page 15) is not shown on the system P&lD. Line List i entry for the location of the line indicates that the line runs from the Diesel Generator A (3EGS*EG-A) to the hose 3EGS* HOSE 6B on the Diesel Generator B, which is not supported by the P&lD.
- 4. No justification or reference is provided for the number of cycles for operating conditions (pages 11 and 12).
- 5. Calculation Attachment 1 provides flexible hose Information.
On page 2 of this Attachment Young's modulus for the 0.5 in.
hose is calculated; execution of the given numerical equation does not yield shown result (1352 vs. 2120). The equation could not be reproduced because of lack of supporting information (assumptions, references / sources, units) for selected equation and its parameters. This apparent error was then propagated in the ensuing calculation of shearing modulus. Also, Page 1 of this Attachment refers to Ref. a (for hose stiffness) and Ref. b Printed 3/169811:19:54 AM fof 3
ICAVP DR Ns. DR-MP3-0675 N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report in the Attachment or the main body of the calculation. Further, the Attachment refers to data obtained from Aeroquip. However, no supporting document is either enclosed or referenced.
Review Valid invalid Needed Date initiator: Cbersnel,Bojan. B 0 0 1'18/S8 VT Lead: Nerl, Anthony ^ B O O 5/18/S8 VT Mgr: Schopfer, Don K B O O siie/sa WtC Chmn: Singh, Anand K B O O 1/25/98 Det.:
INVAL10:
Date: 3/11/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0675, has identified a condition not previously discovered by NU which requires correction. Approved corrective action plan for CR M3-98-0599 has been issued to correct the discrepancies after startup. Specifically the first discrepancy determined the incorrect control vaive type was used in Operating Condition 3.
The assumed failure mode of full bypass is valid for the new valves. The second discrepancy noted that drain lines have justification for the design pressure (atmospheric pressure) and temperature provided, but the Line Report does not have these design parameters. The justification for the parameters will be provided and the Line Report revised. Discrepancy 3 has been addressed by M3-IRF-01730 in response to DR-MP3-0822. The fourth discrepancy will be corrected by providing the proper reference for the number of cycles for the Operating Conditions.
The last discrepancy noted a mathematical error in the !
calculation and the use of the erroneous parameter later in the calculation. The calculation will be corrected. However, the conclusions of the calculation are not altered by this error. Also, proper reference to Aeroquip data will be provided.The Significance Level is concluded to be Level 4 since there is no impact on the calculation conclusions.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0675, has identified a condition not previously discovered by NU which requires correction. Approved corrective action plan for CR MS-98-0599 has been issued to correct the discrepancies after startup. The discrepancies alter inputs to two Operating Conditions but do not impact the calculation conclusion. The Significance Level is concluded to be Level 4.
Previously kierrufled by NU7 O Yes @ No Non Discrepent Condition?U Yes @ No Resolution Pending70 ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Obersnel,Bojan.
VT Leed: Nerl, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Printed 3/16/9811:10 s5 AM Page 2 of 3
ICAVP DR N2. DR-MP3-0676 N:rtherct Utilitie2 Millstone unit 3 Discrepancy Report
.m....... m,..~~"
O O O x1x98 Date: 3/11/98 SL comments: S&L agrees with the disposition of the first three discrepancies, but requires more information to complete evaluation of the disposition for the fourth and fifth discrepancy. In particular:
Regarding the first discrepancy, S&L agrees that the assumed failure mode is applicable for the new valve, thus leaving calculation results unaffected. Corrective action of CR M3 0599 is acceptable.
The second discrepancy has also no impact on the reported stress data, since the design pressure for the particular lines is insignificant. S&L agrees with the NU disposition and the corrective action for the particular discrepancy.
S&L agrees that the third discrepancy has been addressed by M3-IRF-01730 in response to DR-MP3-0822. The disposition of this discrepancy in M3-IRF-01730 was found acceptable.
The fourth discrepancy concems lack of Justification or reference for number of cycles for operating conditions addressed in the calculation. S&L will agree with the NU disposition for this discrepancy provided that NU can demonstrate that supporting documentation for number of cycles for operating conditions exists and that piping stress analysis will not have to be revised.
S&L requires further information to properly evaluate the disposition of the fifth discrepancy. S&L agrees that the calculation should be corrected to address this discrepancy.
However, the disposition does not provide sufficient evidence to conclude that "the conclusions of the calculation are not altered by this error." Please indicate how is the affected information being used and demonstrate that the conclusions of the user based on the erroneous data are not adversely impacted.
Page 3 of 3 Printed 3/16/9611:19:55 AM
I ICAVP DR No. DR-MP3-0680 l N:rthert Utilities MilistOne Unit 3 Discrepancy Report l Review Group: System DR RESOLUTION REJECTED ]
- ** Potential Operability issue i Discipline: Mechanical Design Discrepancy Type: Calculabon g j r
System / Process: DGX NRC Significance level: 3 Date faxed to NU:
Date Published: 1!22/98 Discrepancy: Discrepancies in Calculation P(T)-1042, Rev. (blank)
Description:
Calculation
- Operating Conditions in the Emergency Diesel .
Generator Air Starting System (EGA)", calc. no. P(T)-1042, Rev. l (blank) was performed in 1984. Since, the EGA has been j modified, primarily a dryer with an aftercooler has been added ;
on the air compressor discharge side and the relief valve 3EGA-RV20A1,A2,81,82 set point has been raised to 500 psig (as shown on the system P&lD's). This significantly changes system l operating conditions. The scope of the calculation has been changed by changing piping configuration, and added line l numbers. More specifically, following discrepancies between the calculation and current system configuration were noted:
- 1. Objective of this calculation is to determine the operating pressures and temperatures of EGA. The pipin0 considered in !
i the calculation does not match the off skid lines as listed on the EGA Line List and as shown on the system P&lD's (EM-1168-25 and EM-116D-5). The calculation does not include lines with sequentialline numbers 60 and beyond (lines 60,61,62,63,64, 65,86,87,88,89,90, and 91 are ASME Section Ill, Class 3); for the SDP Condition 1 lines with sequential line number 44 and beyond are not included (page 4 of the calculation).
- 2. In this calculation the relief valve 3EGA-RV20A1,A2,B1,B2 (on the air compressor discharge) set point is considered to be 450 psig (page 5 of the calculation). Since the calculation was completed the relief valve set point has been reset at 500 psig (as shown on the system P&lD). This higher relief valve set point will affect maximum operating pressure and, consequently, operating temperature for piping upstream of the air receiver tank for operating modes due to an operator error or a control component failure. This willimpact calculation SDP Conditions 3 (p. 8), and 4 (p. 9).
- 3. During the air receiver tank charging operation mode (SDP Condition 2, page 5 of the calculation) the compressed air leaving the air compressor at high temperature normally passes through the aftercooler and the dryer before entering the air receiving tank. The aftercooler reduces air temperature to 130 degrees F max. (SWEC Spec. 2520.300-730, Add.1; per this Specification, Section 3.5, the maximum inlet air temperature for air dryer components downstream of the aftercooler is 130 degrees F). Thus, during normal air charging operation, the lines with line sequential numbers 1,3, 5,11,13, and 15 will see air operating temperature of 130 degrees F max. In this calculation, however, for this mode of operation the operating temperature for lines between the dryer and the air receiving tank is set at of 4 Printed 3/16/9811:20:25 AM
r ICAVP DR N3. DR-MP3 0680 N rthert Utilitie3 Millstone unit 3 Discrepancy Report the air compressor at 425 psig. (The system design allows for bypassing the dryer via normally closed valve in the bypass line.
Under such conditions, the above listed lines could be exposed to temperatures of the air exiting air compressor. However, this mode of operation is not addressed in the calculation.)
- 4. No supporting justification is provided in the calculation or by i l reference for the number of cycles for SDP Conditions 3,4, and 5.
- 5. Air compressor discharge relief valve is QA Cat. 2 (per PDDS ,
database). On pages 5 and 10 of the calculation the valve is !
identified with valve number 3EGA*RV20A1,*RV20A2,*RV20B1, j
- RV20B2. l Review Valid invalid Needed Date initiator: Obersnel,Bojan. 8 O O 2/2/s7 1 l
VT Laad: Nerl. Anthony A B O O 12/16/87 VT Mgr: Schopfer, Don K O O O 12/23/97
'" 7=>
BRC Chmn: Singh, Anand K B O O Date:
INVAUo:
I Dele: 3/11/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0680 has identified a condition not previously identified by NU that requires correction. Calculation P(T)-1042, a design input to calculation SDP-EGA-01342M3 does not reflect plant modifications and operating configurations as changed since startup and requires revision. However, the plant design basis is supported and reflected by current plant documentation including stress data package calculation SDP-EGA-01342M3. This calculation was reviewed and issued in accordance with Desktop Instruction 3DE-EDI-97-004 during MP3s 50.54f project.
Major modifications to the diesel air start system include the addition of air dryers and increased system design pressure on the non safety related portion of the system. The design for air dryer components indicated in the DR were documented by PDCR MP3-86-038 as supported by calculation NM-038-EGA.
The increased system pressure was implemented by PDCR MP3-92-102 and supported by calculation 3-92-102-263M, which supersedes calculation NM-038-EGA. The SDP calculation SDP-EGA-01342M3 references system modification calculation 3 102-263M as well as the original system operating conditions calculation P(T)-1042 as an input and thus represents current plant configuration.
Specifically the five (5) items identified in the DR are addressed as follows:
The conditions for the additional lines identified in item 1 and I the change to 500 psl identified in item Pope 2 of 4 Printed 3/16/9811:20:26 AM
ICAVP DR N2. DR-MP3-0680 N:rthert Utilities Millstone Unit 3 Discrepancy Report 2 are addressed in Stress Data Package calculation SDP-EGA-01342M3, reflected on P&lDs EM-133B/D and supported by I PDCRs MP3-86-038 & MP3-92-102. Calculation P(T)-1042 requires update. ;
Item 3 is addressed by SDP condition 2 which was analyzed without credit for aftercoolers.
Item 4 number of cycles for SDP upset conditions 3,4, and 5 i
are 1/yr or 40 total each as given in SDP-EGA-01342M3.
Relief valve designations identified in item 5 require revision I in calculation P(T)-1042 to QA Cat. 2, consis*ent with P&lDs EM- ,
133B/D and PMMS. The resetting of the non-safety relief valves l from 450 psi to 500 psi has been evaluated in PDCR MP3 l 102.
CR M3-98-0477 was written for this discrepancy. The corrective action revises calculation P(T)-1042 to reflect the current system configuration and design pressure increase in calculation 3 102-263-M3 and will be confirmed with calculation SDP-EGA-01342M3. The CCN is scheduled for completion post startup.
Calculation P(T)-1042, as an input calculation to the SDP, should .
l haye been reviewed and revised as part of the 50.54f effort. As part of the CR invectigelion relatin0 to this DR, a sampling of other Pl 31 system calculation reviews Indicated that SDP input calculations were reviewed and revised. As the operating conditions of the diesel air start system is supported by the existing documentation and other system input calculations were reviewed, this is not a generic condition. As such, NU considers this as a Significance Level 4 discrepancy.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0680 has identified a condition not previously identified by NU that requires correction. Calculation P(T)-1042, a design input to calculation SDP-EGA-01342M3 does not reflect plant modifications and operating configurations as changed since startup and requires revision. However, the plant design basis is supported and reflected by stress data calculation SDP-EGA-01342M3, P&lDs, PMMS and PDCRs.
CR M3-98-0477 was written for this discrepancy. The corrective action revises calculation P(T)-1042 to reflect the current system configuration and design pressure increase in calculation 3 102-263-M3 and will be confirmed with calculation SDP-EGA-01342M3. No generic condition issue was identified by the CR evaluation. The CCN is scheduled for completion post startup.
NU considers this a Significance Level 4 discrepancy based on the above generic review and since the design basis of the diesel start air system is currently supported by plant documentation including calculation SDP-EGA-01342M3.
Previously identified by NU? O Yes (,9) No Non Discrepant condition?O Yes (G) No Resolution Pending?O Ye. @ No Resolution Unresolved?O ve. CG)No samview Printed 3/169811:20:26 AM Page 3 of 4
1 l
DR N2. DR-MP3-0680 I N:rthezt Utilities ICAVP Millstone unit 3 Discrepancy Report 1 _ l Initiator: Obersnel,Bojan. '
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/11/g8 ,
SL Comments: S&L agrees with the disposition to the first, second and fifth l discrepancy in this DR, and requires additional information to complete evaluation of disposition for the third and fourth discrepancy, in particular: ;
l S&L agrees with the disposition of the first two discrepancies and f finds the corrective action of CR M3-98 0477 acceptable. {
S&L recognizes that the calculation defined Condition 2 is defined f conservatively and agrees that the dryer bypass operating condition, which is not specifically addressed in the calculation, is enveloped by the Condition 2. Addressing both of these conditions together may affect the number of cycles for Condition
- 2. Please address the number of cycles for the " combined" operating condition, if combining the two operating modes is your intent. 1 The disposition to the fourth discrepancy is correct, although not acceptable. The calculation subject to this discrepancy is a reference to the Stress Data Package SDP-EGA-01342M3. The Stress Data Package, in tum, cannot be a reference to this f calculation, as implied in the disposition. The number of cycles for affected operating conditions should be based on rAher design documents, where this parameter has been calculated, or otherwise determined based on design requirements. See Response no. M3-IRF-01577 to DR-MP3-0692.
S&L agrees with the disposition to the fifth discrepancy.
4 Page 4 of 4 Printed 3/16/9811:20:26 AM
_.m ._.- ._._ _ _ _ _ _ _ _ _ . . __ _ _ _ _ _ . . . _ _ _ _ . . _
ICAVP DR N3. DR-MP3 0684 Northert Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED PotentialOperablitty issue Discipline: Electncal Design Ow Discrepancy Type: Calculation g SystemIProcess: DGX NRC Significance level: 3 Date faxed to NU:
Date Published: 12/20/97 Discrepancy: Setting of 4160 voit Protective Relays for Safety Related Unit Substations (Calculation 413CA)
Description:
Calculation 413CA determines the settings of the protective relays for the safety related unit substations. !
The setting of the 480 volt tie breaker is different from that shown in Calculation 818CA. If the settings in Calculation 818CA l
apply, then there is probably a lack of coordination between the 4 kV breaker and the tie breaker. This will reduce the reliability of the supply to safety related loads since a fault that should be cleared by the bus tie breaker will result in the loss of the entire unit substation.
The time current curve indicates that the unit substation transformers have a short circuit capability of 4.5 seconds, while ANSI C57-12.01 requires a short circuit capability of only 2 seconds. The reason for this difference should be documented by an appropriate reference, such as manufacturer's data.
Review Valid invalid Needed Date initiator: Bloethe, G. William 8 O O 12/i/97 VT Lead: Nerl, Anthony A B O O 12/5/97 VT Mgr: schopfer, Don K 8 O O 12/ itis 7 12ti6/97 1RC chmn: Singh, Anend K 8 O O Date: l INVALID:
Date: 3/10/98 RESOLUTION: Disposition:
NU has concluded that issue #1 in Discrepancy Report DR-MP 0684 has identified a condition not previously discovered by NU which requires correction.lssue #1: Calculation 413CA shows the coordination curves for the primary supply 4160VAC circuit breaker, the main secondary Disposition:480VAC circuit breaker, and the tie 480VAC circuit breaker.
The tap settings were changed for the tie 480VAC circuit breaker, however, its coordination curve in calculation 413CA was not updatid, which is the reason for issue #1.
Calculation 818CA shows the updated coordination curve for the tie 480VAC circuit breaker, and the main secondary 480VAC circuit breaker. Because of the tap change to the tle 480VAC Printed 3/16/9611:20A0 AM Page 1 of 3
q i
i I
ICAVP DR N2. DR-MP3 0684 Northea:t Utilitie3 umstone unit 3 Discrepancy Report 1 circuit breaker, calculation 818CA now shows that better l
' coordination exists between these two protection devices and the ,
tie 480VAC circuit breaker would trip before the main secondary I i
480VAC circuit breaker.
The coordination curve for the primary supply 4160VAC circuit breaker is shown in calculation 413CA, but not in 818CA. In ,
reviewing calculation 413CA it can seen for most cases the main secondary 480VAC circuit breaker will trip before the primay supply 4160VAC breaker would trip. As a consequence, the tie ]
480VAC circuit breaker will trip before primary supply 4160VAC ]
circuit breaker. l l
i From the update coordination curves shown on calculation -
818CA, proper coordination is maintained between the prirnary supply 4160VAC circuit breaker and the tie 480VAC circuit breaker.
Calculation 413CA will be updated to reflect the new coordination curve for the tie 480VAC circuit breaker. Corrective action plan for CR-M3-98-0408 has been approved to update calculation 413CA. This item will be completed prior to startup.
Since the conclusion of the calculation has no effect on the design basis, NU considers this to be a Significance Level 4 issue.
The frequent damage curve in NU has concluded that issue #2 in Discrepancy Report DR-MP3-0684 does not represeat a discrepant condition.
Issue #2:
Calculation 413CA, indicated a transformer short circuit capability of 4.5 seconds verses ANSI's 2 second requirement.
The 1000KVA transformer damage plot curve was added to calculation 413CA to demonstrate that the ITE 1000KVA transformers were properly protected by transformer primary and 1 secondary protection devices against transformer pass-through faults. The solid line segments define the damage time / current ,
curve for frequent faults, while the extended dotted line segment j represents the damage time / current curve for infrequent faults.
As shown in calculation 413CA, the solid line for frequent fault curve is plotted to the 2 second limit which is in conformance with ANSI and IEEE standards.
The infrequent fault curve is plotted to the 4.5 second limit.
Frequent faults represent faults that occur more than 10 times in a transformer's lifetime. Infrequent faults represent faults that I occur not more than 10 times in a transformer lifetime.
Significance level criteria does not apply, as this is not a discrepant condition.
Printed 3/16/9611:20Ao AM Page 2 of 3
.- . .- -~- - . . . . . - -- - -. - - - ---._._ - - __.. -
N;rthea:t Utilitie3 ICAVP DR N3. DR-MP3-0684 Millstone Unit 3 Discrepancy Report l
Conclusion:
j NU has concluded that issue #1 in Discrepancy Report DR-MP 0684 has identified a condition not previously discovered by NU which requires correction. The coordination curve for the 480VAC tie circuit breaker in calculation 413CA needs to be updated to which will then show proper coordination with the transformer primary breaker.Since the conclusion of the calculation has no effect on the design basis, NU considers this to be a Significance Level 4 issue. NU has concluded that Issue
- 2 in Discrepancy Report DR-MP3-0684 does not represent a discrepant condition.The transformer frequent damage curve has the appropriate time coordinate of 2 seconds as required by ANSIC57.
Previously identified by Nu? O Yes (G) No Non Discrepant Condition?O Yes (9) No Resolution Pending?O Ye. @ No ResolutionUnresolved?O ve. @ No Review initiator: Warner, I.
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 3/10/98 SL corrrnents: We concur with NU's response for all of the questions. However, ,
during our review of the response, an additional issue was i discovered.
1 Rev.1 of the time-current characteristic curve (calculation l 818CA) shows an acceptable margin between the long time i setting for the largest motor and the long time setting for the tie i breaker. In Rev. 2 that margin has disappeared.
Since we don't see an explanation for the lack of margin we are leaving the discrepancy level at 3 pending receipt of additional Information.
Printed 3/169811:20:41 AM Page 3 of 3
- - - . . ~ - . . - - - - - - - - . . - . ...- - - -. -
N;rthert Utilities ICAVP DR N3. DR-MP3-0692 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operability issue l
Discipline: Mechanical Design Om
! Discrepancy Type: Calculetkm g SystemProcess: DGX j NRc Significance level: 3 Date faxed to NU:
Date Published: 1/25/96 Discrepancy: Discrepancies in Calculation SDP-EGA-01342M3, Rev.02
Description:
Reviewing the calculation " Emergency Generator Air (EGA)
Stress Data Package", calc. no. SDP-EGA-01342M3, Rev. 02 following discrepancies were noticed:
- 1. Operating Condition 3 postulates inadvertent closing of the excess flow valves 3EGA*V983 through *V986 (page 11). This is not in agreement with the calculation no. P(T)-1042, Rev. O, ,
which is reterenced (Ref. 3a) in the subject calculation. 1 Calculation P(T)-1042 assumes that the isolation valves 3EGA*V995, *V994, *V982 and *V981 are inadvertently closed for this operating condition. 1
- 2. Operating Condition no. 5 postulates that the air receiver tank relief valve (3EGA*RV24A1,A2,81,B2) fails open. This mechanical failure is different from the failure postulated in the referenced calculation P(T)-1042, where the air compressor relief valve (3EGA RV20A1,A2,81,82)is postulated failed open.
Postulated failure of the air receiver relief valve will keep the air compressor running, supplying air receiver tank with the air above ambient temperature. The System Design Specification Sheet (page 15 of the calculation) shows the temperatures for the Operating Condition 5 to be ambient (AMB) throughout the system.
- 3. No justification is provided for the number of cycles for Operating Conditions.
Review Valid inval6d Needed Date initiator: Obersnel.Bojan. 8 0 0 5/8'88 VT Lead: Nerl, Anthony A B O O 1'S/S8 VT Mgr: schopfer, Don K B O O 5/19/S8 IRC Chmn: singh, Anand K S O O 1/21/98 Date:
INVALID:
Date: 3/U98 RESOLUTION Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0692, has
! identified a condition not previously discovered by NU which requires correction. Corrective action plan for CR M3-98-0575
( has been approved to correct the calculation after startup.
The first discrepancy indicates that excess flow check valves 3EGA*V983 through *V986 failures have been used in place of an operator closing manual valves 3EGA*V995, *V994, *V982, Printed 3/16/9611:20:s4 AM Page 1 of 3
ICAVP DR Nr. DR-MP3 0692 Northerst Utilities Millstone unit 3 Discrepancy Report or *V981. Although different valves are postulated to close, the overall effect of the stoppage of air flow is the same for input into the calculation. The second discrepancy noted that the operating temperature will be above ambient with the air receiver relief valve failed open which in tum would keep the compressor operating. However, in this situation, the compressor after cooler and dryer will also function normally and will keep the air flow temperature below the line design temperature of 130 F. The justification for the number of cycles for Operating Conditions will be provided. The discrepancies do not impact the conclusion of the calculation. The Significance Levelis concluded to be Level 4.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0692, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0575 will revise the calculation after startup. The discrepancies alter inputs to three Operating Conditions but do not impact the calculation conclusion. The Significance Level is concluded to be Level 4.
Previously identined by NU? O Yes (9) No Non Discrepant Condiuon?Q Yes (G) No Resolution Pending?O ve. @ No Resoluuon Unresolved?O ve. @ No Review Initiator: Obersnel,Bojan.
VT Lead: Nerl. Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/7/g8 sL comments: NU disposition is not acceptable.
S&L does not agree with the disposition of the first discrepancy.
The operating mode conditions (pressure) for the lines between the two valves are different depending on which of the valves is postulated closed. As is, per the calculation the conditions in i these lines are set as if the manual isolation valve was !
inadvertently closed, and not as if the excess flow valve failed closed, as postulated in the calculation. Please provide specific corrective action in this case, and demonstrate that the piping stress analysis will not be affected.
S&L also does not agree with the disposition of the second discrepancy. The input to the stress analysis will normally be the operating condition, and not the design condition, particularly when the design temperature is significantly higher then operating l temperature, as it is in this case (600 vs.130 degrees F, for the l design temperature see table on page 14 of 21 of the l 1
calculation). Please provide specific corrective action and demonstrate that the piping stress analysis will not be affected.
S&L will agree with the NU disposition of the third discrepancy provided that NU can demonstrate that supporting documentation !
for number of cycles for operating conditions exists and that Pnnted 3/16/98 it20:54 AM Page 2 of 3
ICAVP DR No. DR-MP3-0692 N:rthe=t Utilities Millstone Unit 3 Discrepancy Report
! piping stress analysis will not have be revised.
I l
f i
I i
{
1 l
l l
l l
Page 3 of 3 PrWed 3/169811:20:55 AM
ICAVP DR N3. DR-MP3-0701 N:rthe ct Utilitie3 milistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED
- Potential Operetdlity issue Discipline: Electrical Design Discrepency Type: Ucensing Document Ow
- No SystenVProcess: DGX NRC Significence level: 3 Date faxed to NU:
Date Published: 1/3/96 D6screpancy: Discrepancy with Branch Tech Pos PSB Adequacy of Station Electric Distribution System Voltages .
DescripUon:
j Background.
Page 8.3-21 of the FSAR states:
The second level of protection is in addition to the undervoltage scheme which also employs a two-out-of-four coincidence logic to prevent spurious trips of the offsite power source. Two separate time delays are incorporated in the degraded voltage scheme. The first time delay establishes the existence of a sustained degraded voltage on the bus. Following the delay, an alarm in the control room alerts the operator to the degraded condition. The subsequent occurrence of an accident signal (SIS ,
or CDA) Immediately separates the Class 1E distribution system l from the offsite power system... l l
Discussion:
When the first time delay (relay 62H-) times out and an accident condition is present, relay 27Y2 and timer 62Y- are energized. A contact from 27Y2 trips the bus tie breaker and a time delay closed contact from 62Y- energizes relay 27Y1. The reserve breaker is then tripped by a contact from 27Y1.
Based on calculation NL-042, revision 2, timer 62Y- is set to time out at 5 seconds.
Conclusion:
The FSAR states that the Class 1E distribution system is immediately separated from the offsite power system in the event of an accident signal and a degraded voltage condition.
Based on a review of the schematics it appears that there is a 5 second delay between the time a degraded voltage condition is proven coincident with an accident condition and the Class 1E distribution system is separated from the offsite power system.
Drawings reviewed:
ESK-07J Rev 20 Elementary Diagram - 4.16kV Bus 34C
[3 ENS *SWG-A) Aux Circuit ESK-07L Rev 24 Elementary Diagram - 4.16kV Bus 34D fvNR*AWC.R1 Auv Aircuit
~
Page 1 of 3 Printed 3/16/9611:21:15 AM
ICAVP DR N2. DR-MP3-0701 N::rthert Utilities Millstone Unit 3 Discrepancy Report ESK-07SX Rev 11 Elem Diag 4.16 kV Bus 34C
[3 ENS *SWG-A] Undervoltage (Hi Stpt) Trip Ckt i
ESK-07SY Rev 11 Elem Diag 4.16 kV Bus 34D
[3 ENS *SWG-B] Undervoltage (Hi Stpt) Trip Ckt ESK-08KC Rev 11 125V DC Emer Diesel Gen Start Ckt 3EGSAO1 [3EGS*G-A)
ESK-08KF Rev 12 125V DC Emer Diesel Gen Start Ckts Ckt 3EGSB01,2 [3EGS*G-B)
Calculatien NL-040 Rev1 Undervoltage Protection Scheme Relay Settings for Millstone 3 Calculation NL-042 Rev 2 Millstone Unit 3: Degraded Voltage Protection Scheme Relay Settings Review Valid invaud Needed Date initiator: Wamer. l. 8 O O 2/a/97 VT Lead: Neri, Anthony A B O O 52/is/97 VT Mgr: Schopfer, Don K B O O 12/11/97 IRC Chmn: Singh. Anand K G O O 12/24/97 Date:
iNvAUO:
Date: 3/10/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report DR-MP-3-0701 does not represent a discrepant condition.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report DR-MP 3-701 does not represent a discrepant condition. Relay 27Y2 will trip offsite power immediately, and relay 62Y has a 5 sec. delay. Significance level criteria do not apply as this is not a discrepant condition.
Review of the Logic Flow Diagram presented in Calculation NL-042 describes the following events. When the DGV time delay relay 62H times out concurrent with an accident signal, relay 27Y2 will energize, and a contact from 27Y2 will trip the bus cross tie breakers as stated in the FSAR page 8.3-21. The bus cross tie breakers 3 ENS *ACB-TA & TB will immediately separate the Class 1E distribution (Buses 34C & 34D) from the offsite power system (NSST) which is the intent of the statement in the FSAR.
The logic path described in the " Discussion" section of the DR is a description of the relay events that occur in the tripping and Page 2 of 3 Printed 3/16/9611:21:15 AM
l l
N:;rthert Utilitie3 ICAVP DR N2. DR-MP3-0701 l Millstone Unit 3 Discrepancy Report locking out of the RSST circuit breakers which incorporates the 5 sec, time delay action of relay 62Y. The 5 sec. time delay is
' intended to permit a slow transfer to the RSST if power is available. Significance level criteria does not apply as this is not a discrepant condition.
Previously identif6ed by NU7 U Yes @) No Non Discrepent Condition?U Yes @) No R auuon e.adiao70 Y.. @ wo ne.oivuon unce.sv.d70 Ye. @ wo Review initiator: womw, L VT Lead: Nei, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K I Date: 3/10/98 SL Comments: Our concem with the second level undervoltage transfer scheme is as follows:
The FSAR statement does not distinguish between normal and reserve feeds to the ESF bus. If the ESF bus is powered from the NSST, then the FSAR statement is correct. If, however, the ESF bus is powered from the RSST during the condition described in ,
the FSAR then the FSAR statement is incorrect. ]
To close out this DR we are looking for documentation that confirms that the RSST is not to be used as a primary feed to the i ESF (possible tech spec time clock) or that the FSAR statement j will be revised to more clearly define the timing options for tripping.
In other words, if immediate tripping of the NSST feed is desirable, why isn1 immediate tripping of the RSST feed (when functioning as the primary feed) also desirable? And if it is not desirable, what is the justification for not conforming to Branch ]
Technical Position PSB-1 which does not distinguish between i primary and backup feeds? l 1
l :
Page 3 of 3 Printed 3/16/981121:15 AM
ICAVP DR ND. DR-MP3-0846 Northe st Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operability issue '
Discipline: Electrical Design Om Discrepancy Type: Calculation g systemerocess: N/A i NRc Significance level: 3 Date faxed to NU:
Date Published: 1/1o/98 Discrepancy: Documentation to verify " associated circuits" statement in FPER could not be located
Description:
Section 6.3.1.3.1, Page 6-10 of the FPER states:
" Associated circuits - The final concem raised by power cable faults relates to the potential for an electrical fault, which is not properly cleared, to damage adjacent or nearby circuits which are required in the safe shutdown situation (common enclosure).
As part of the Appendix R review the ICAVP review team attempted to ferify this statement. The types of power circuits analyzed fall into the following categories:
- 1. 4 kV power circuits (
- 2. 480V switchgear power circuits
- 3. 480V MCC power circuits 4.125V DC switchgear control circuits 5.120V AC control circuits (MCC control power transformer fed) 6.120V AC miscellaneous power / control circuits 7.125V DC miscellaneous power / control circuits l In the review we determined: i i
- 1. 4 kV power circuits have the necessary documentation to determine relay settings, but a potential question exits with respect to transient temperature during fauit conditions - See )
discrepancy DR-MP3-0787.
- 2. 480V switchgear power circuits have the necessary documentation to determine relay settings.
- 3. For power cabic fed from MCCs, discrepancy M3-DR-00765 was issued because we could not locate documentation of the actual setting of the equipment and we could not confirm that the proper breakers and overloads settings were, in fact, installed.
4.125V DC switchgear control circuits are ad fused at the switchgear. We could not identify a calculation which verified that the control circuit fuses would adequately protect the control circuit cable from damage.
5.120V AC control circuits (MCC control power transformer fed) are all fused and the control transformer sizes are small enough that cable damage is not a credible issue.
Printed 3/15981121:45 AM Page 1 of 4
Northert Utilitie3 ICAVP DR N . DR-MP3-0846 Millstone Unit 3 Discrepancy Report 6.120V AC miscellaneous power / control circuits fed from distribution panels may be fused or protected with circuit breakers. We could not identify a calculation which verified that the cable protected by the fuse / breaker was adequately protected.
]
l 7.125V DC miscellaneous power / control circuits fed from l distribution panels may be fused or protected with circuit breakers. We could not identify a calculation which verified that the cable protected by the fuse / breaker was adequately protected.
Conclusion:
We could not locate calculations or data required to verify the FPER statement.
Review Valid invalid Needed Date initiator: Wamer, l. B O O 12/18/97 VT Lead: Nerl. Anthony A B O O 12/1ers7 i VT Mgr: Schopfer, Don K B D 0 12/23/97 BRC Chmn: Singh, Anand K B O O $2r31/97 Date:
INVALlo:
Date: 3/5/98 RESOLUTION: Disposition:
NU has concluded that the issue reported Discrepancy Report.
DR-MP3-0846, does not represent a discrepant condition.
Attachment 4.2 of Specification SP-M3-269 Rev.1 demonstrates adequate circuit breaker coordination for all circuits that share a common enclosure or power supply with Appendix R circuits (those circuits required to bring the plant to a cold or hot shutdown condition after a fire). Significance level criteria do not apply as this is not a discrepant condition.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report DR-MP3-0846 does not represent a discrepant condition. Attachment 4.2 of Specification SP-M3-269 Rev.1 demonstrates adequate circuit breaker coordination for all circuits that share a common enclosure or power supply with Appendix R circuits, and covers items 1-7 of the Discrepancy Report. Significance level criteria do not apply as this is not a discrepant condition.
~
Previously identifled by NU7 O Yes (S) No Non Discrepent Condition?Q Yes (#) No ResolutionPending?O Yes
- No ResolutionUnresolved?O ve.
- No Review trhtor: Warner, I. _
Printed 3r16/9811:21:4s At A P447of4 W
j j
ICAVP DR N2. DR-MP3 0846 N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report O 8 0 =
VT Lead: Nwl, Anthony A VT Mgr: schopfw, Don K 1RC Chmn: singh, Anand K Date: 3/5/98 SL Comments: We concur that SP-M3-EE-269 demonstrates coordination of the 4kV power circuits - with respect to each other. The unresolved issue regarding the 4kV circuits is how NU addressed the issue of cable temperatures exceeding 250 deg. C in the event of a fault.
DR-MP3-0787 addresses this issue and NU's response to the DR was:
"NU has concluded that Discrepancy Report, DR-MP3-0787, has identified a condition previously discovered by NU which has been corrected. The issues identified in this Discrepancy Report involving incorrect short circuit current values used in Calculation 178E, '5KV & 8KV Power Cable Temperature Under Fault :
Condition" with potential associated circuit problems will be !
addressed via corrective actions identified in existing CR No. M3-97-2358 & M3-97 3413."
Because the CR does not identify how the issue will be addressed, we lack information to verify that there are no associated circuit problems.
We concur that SP-M3-EE-269 demonstrates coordination of the 480V power circuits, as long as the largest MCC feeder breaker is no larger than a 150A trip. The unresolved issue regarding the 480V circuits is how NU confirms breaker settings. DR-MP3-0765 addresses this issue and NU's response to the DR was:
" While verifying the breaker settings and TOL sizes is time consuming and tedious, the settings and sizes can be determined and field verified. The cumbersome process does not represent a discrepant condition."
Because the DR response does not provide any confirmation of breaker sizes we lack information to verify that there are no associated circuit problems.
Item #6 - 120V AC Vital Distribution Panels We questioned whether or not the cable associated with these panels were properly protected. This question was not directly answered, but with the fault current identified as appro.vimately 1100A, this does not appear to be a problem. Please note, that SP-M3-EE-269 Section SE and Section 8 conclude that adequate breaker coordination is provided for these panels. Based on curve 12, for any fault between 600 and 1100A, coordination does not exist.
General- One portion of this DR questioned whether or not cable wne nds.mentnfu nrntnefnd nnnInct in,ilfe esir h thnt nn neenr intad
~ ~ ~ " ' "'' " ~~~ ~ ~~~ ~~~' ~~
Printed 3/16/9811:21:46 AM Page 3 of 4
i ICAVP DR N2. DR-MP3-0846 N:rthenct Utilitie3 Millstone Unit 3 Discrepancy Report circuit problems could possibly arise. Since NU's response did not address that question and since the items discussed above are still unanswered, this DR is still classified as a level 3 deviation.
I I
l I
l I
l 4
1 Printed 3/16/9811:21:46 AM Page 4 of 4 j
r,--
Northert Utilities ICAVP DR Nr. DR-MP3-0873 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: systern Design p ; ggy g,,,
Di.cipiine: uechanica Desgn Discrepancy Type: Calculation o y,, {
Systern/ Process: Oss @ No i NRC Significance level: 3 Date faxed to NU:
]
Date Published: 1/17/96 i Discrepancy: Static load test for MOVs does not consider 3g acceleration in 3 orthogonal directions.
Descripuon: The seismic qualification reports D-0057-1 thru 5 ,
for Henry Pratt butterfly valves 3QSS*MOV34A/B !
and 3RSS*MOV20A-D were reviewed against their specificatio:1 requirements The review identified the following discrepancy.
As per specification 2362.200-164, pages B32 thru B41, the j equipment shall be designed to be capable of continued l operation with all of the specified loads considering i' 3g acceleratior. In all three orthogonal directions acting simultaneously whereas, above valves are tested I (qualified) using loads due to 3g acceleration in least rigid direction only.
Review i Valid invalid Needed Date initiator: Patet, Ramesh 8 O O 12/22/97 VT Lead: Neri, Anthony A B O O 12/20/97 VT Mgr: schopfer, Don K B O O 22/23/97 IRC Chmn: singh, Anand K 9 O O 1'13/98 Date:
INVALID:
Date: 3/9/98 REs0LUTION: NU has concluded that Discrepancy Report, DR-MP3-0873, does not represent a discrepant condition. Two different valve qualification criteria have been combined. The section of specification 2362.200-164 referenced pertains to the analyses for the seismic qualification of the valve including specified loads of 3g's in all orthogonal directions acting simultaneously. The Operability Testing Program, pages 46 and 47, of the same specification requires actual static loading at the center of gravity of the operator so as to impose the maximum deflection in the direction of the weakest axis to demonstrate satisfactory valve operation.
Significance Level Criteria do not apply as this is not a discrepant condition.
Previously identified by Nur O Yes @ No Non Discrepent Condition?O Yes @ No Resolution Pending?O yes @ No Resoiutionunresoeved70 vos @ No Review initiator: Johnson, Jay VT Lead: Nerl, Anthony A Printed 3/16/9611:22:02 AM Page 1 of 2
- ~ __. _ -. _ _ . . _ . . _ . . . . _ _ . _ . . _ _ . . . _ . _ . _ .__ . _ . _ - . . _ _ . _ . _ . _ . . . _ _
F 1 l
l Northert Utilities ICAVP DR N2. DR-MP3 0873 Millstone Unit 3 Discrepancy Report l
T 5 Lusts. HTI4, ni su u ry M VT Mor: schopfer, Don K 1RC Chmn: Singh, Anand K Date: 3/9/98 sL Comments: As sinted in Specification 2362.200-164, the imposed deflection for tte static load test must, as a minimum, equal the deflection determined by seismic analysis or testing as representative of the SSE condition. The SSE condition, as defined by this specification, is an acceleration of 3.0 g in three orthogonal directions acting simultaneously. I 11 is noted that identical requirements were specified in Specifications 2475.110-185, SP-ME-784 and 2282.050-676. The selsrnic reports provided for each of these specifications include a static deflection test where the SSE accelerations were considered in three directions simultaneously.
l l
l l
l Pnnted 3/16/981122:02 AM Page 2 of 2
Northert Utilitie3 ICAVP DR NA DR-MP3-0874 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLtfrlON REJECTED Review Element: System Design Potential Operabillty issue Discipline: Mechanical Design Discrepancy Type: calculation
@ Yes System / Process: sWP O No NRC Significance level: 3 Date faxed to NU:
Date Published: 1/17/98 D6screpancy: Static load test for MOV's does not consider 3g acceleration in 3 orthogonal dkections.
Descripion: The seismic qualification reports D-0057-4,5&B for Henry Pratt butterfly valves 3SWP'MOV54A-D,57A-D, 3SWP*MOV71 A/B and 3SWP*MOV50A/B were reviewed against their specification requirements The review identified the following discrepancy.
As per specification 2362.200-164, pages B32 thru B41, the equipment shall be designed to be capable of continued operation with all of the specified loads considering 3g acceleration in all three orthogonal directions acting simultaneously whereas, above valves are tested (qualified) using loads due to 3g acceleration in least rigid direction only.
Review Valid invalid Needed Date initiator: Patel, Ramesh 8 O O 12/22/97 VT Lead: Nerl, Anthony A G O O 12/20/97 3 VT Mgr: Schopfer, Don K G O O 12r23/97 l 1RC Chmn: Singh, Anand K G O O $'13/98 Date:
INVALID:
i Date: 3/9/98 l i
RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0873, does not represent a discrepant condition. Two different valve qualification criteria have been combined. The section of specification 2362.200-164 referenced pertains to the analyses for the seismic qualification of the valvo including specified loads j of 3g's in all orthogonal directions acting simu!;aneously. The '
Operability Testing Program, pages 46 ar.d 47, of the same specification requires actual static loading at the center of gravity of the operator so as to impose the maximum deflection in the direction of the weakest axis to demonstrate satisfactory valve operation.
Significance Level Criteria do not apply as this is not a discrepant condition.
Previously identifled by NU7 O Yes (9) No Non Discrepent Condit6on?O Yes ($) No ResolutionPending70 Yes @ No ResolutionUnresolved70 Yes @ No Review Cce a AcceMable Meded Date initiator: Johnson, Jay VT Lead: Nort, Anthony A O G O 3/9/98 Printed 3/16/9811:22:15 AM Page 1 of 2
N:rthemt Utilities ICAVP DR NL DR-MP3-0874 Millstone Unit 3 Discrepancy Report
.,m. , - . ~ " ' "
VT Mgr: schopfer, Don K O O O 3'*8 IRC Chmn: Singh, Anand K O O O 3/1 /S8 O B O 3/13/98 Date: 3/9/98 st Comments: As stated in Specification 2362.200-164, the imposed deflection for the static load test must, as a minimum, equal the deflection determined by seismic analysis or testing as representative of the SSE condition. The SSE condition, as defined by this specification, is an acceleration of 3.0 g in three orthogonal i directions acting simultaneously, it is noted that identical requirements were specified in Specifications 2475.110-185, SP-ME-784 and 2282.050-676. The seismic reports provided for each of these specifications include a static deflection test where the SSE accelerations were considered in three directions simultaneously.
l l
1 l
l Pnnted 3/16/9811:22:13 AM Page 2 of 2
_ _ _ _ _ _ _