ML20216J711

Forwards Drs Identified During Review Activities for Independent Corrective Action Verification Program.Drs Distributed IAW Communications Protocol,PI-MP3-01

ML20216J711
Person / Time
Site:	Millstone
Issue date:	04/17/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9804210464
Download: ML20216J711 (150)

Text

i i

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ll b Sarger$t% Lundy c I/

pt Don K. Schopfer Senior Vice President 312 269-6078 l April 17,1998 l Project No. 9583-100 i

Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk l Washington, D.C. 20555 l

I have enclosed the following discrepancy reports (DRs) identified during our review '

activities for the ICAVP. These DRs are being distributed in accordance with the #

l Communications Protocol, PI-MP3-01.

l l I have enclosed the following thirty-one (31) DRs for which the NU resolutions have been

! reviewed and accepted by S&L.

l DR No. DR-MP3-0076 DR No. DR-MP3-0680 l

DR No. DR-MP3-0108 DR No. DR-MP3-0692 DR No. DR-MP3-0228 DR No. DR-MP3-0700 l DR No. DR-MP3-0360 DR No. DR-MP3-0701 DR No. DR-MP3-0365 DR No. DR-MP3-0737 DR No. DR-MP3-0387 DR No. DR-MP3-0767 DR No. DR-MP3-0490 DR No. DR-MP3-0817 DR No. DR-MP3-0500 DR No. DR-MP3-0905 DR No. DR-MP3-0550 DR No. DR-MP3-0921 DR No. DR-MP3-0566 DR No. DR-MP3-0923 DR No. DR-MP3-0572 DR No. DR-MP3-0924 l DR No. DR-MP3-0575 DR No. DR-MP3-0932 l

DR No. DR-MP3-0616 DR No. DR-MP3. 0990 DR No. DR-MP3-0619 DR No. DR-MP3-1021 DR No. DR-MP3-0642 DR No. DR-MP3-1071 DR No. DR-MP3-0675

..I1. I 9804210464 980417 PDR i

P ADOCK 05000423 pop ,

0 b5 East Monroe Street Chicago. IL 60603-5780 USA 312 209 2000

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l l United States Nuclear Regulatory Conunission April 17,1998 Document Control Desk Project No. 9583-100 Page 2 l

I have also enclosed the three (3) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.

DR No. DR-MP3-0097  !

DR No. DR-MP3-0697 DR No. DR-MP3-0890 l l

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Please direct any questions to me at (312) 269-6078.

Yours very truly,

%,T u_-

1 l

D.K.S opfer  ;

Vice President and ICAVP Manager i DKS:spr Enclosures Copies:

E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU m \icavpbm\97w0417-a. doc I

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ICAVP DR Ns. DR-MP3-0076 Nrrthext Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED

• W** Potential Operability issue Discipline: Piping Design g Discrepancy Type: Calculation System / Process: Rss Om NRC Significance level: NA Date faxed to NU:

Date Published. 8/31/97 ol crepancy: Max Operating Temperature Exceeds Allowable for Unsleeved Containment Penetrations 107 to 110

Description:

In the process of reviewing the following documents, (i) Containment Recirculation Spray System (RSS) Stress Data Package, Calc. No. SDP-RSS-01361M3, Rev. 4, Dated 5/29/97 (ii) Piping and Instrumentation Diagram, Low Pressure Safety injection / Containment Recirculation, Drawing No.12179-EM-112C-16 Rev.16 (iii) FSAR Section 3.8.1.1.4, Steel Liner and Penetrations (iv) Design Criteria for Containment Liner Penetrations, NETM-54, Issued May 1984 (v) Calculation No.12179-NS(B)-120 Rev. 2, CCN #9, ' Class 2 Unsleeved Penetrations' we noted the following discrepancy:

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Background:

Based on the stress data package (i), under operating condition {

7, the operating process ternperature for lines 3-Mss-uiu-o-2 l and 3-RSS-010-10-2 is 257 deg F. The corresponding pressure in these lines is 150 psig. This is an Emergency & Faulted condition which is described as follows ' Containment Recirculation Pumps take suction from the Containment ,

Recirculation Sump and discharge to the spray headers. A failure of one train of service water cooling to the Containment Recirc Coolers 3RSS*E1 A& C results in the affected RSS train (E1 A, C) discharging hot sump water (257 deg F) to the ring headers and the unaffected RSS train (E18, D) discharging cooled sump water to the headers'.

Since a failure of either train of service water (A or B) needs to be considered, the same operating condition of 257 deg F, and 150 psig needs to be considered for lines 3-RSS-010-20-2 and 3-RSS-010-9-2.

The P&lD (ii) shows that the four RSS lines penetrate the containment through Unsleeved penetrations marked 107,108, 109 and 110.

Based on the applicable section of the FSAR (ill), Unsleeved penetrations consist of piping installed through the containment wall that is thermally cold, and the process pipe is welded directly to the reinforcement plate.

Rncmd nn the Ancinn critarin inr enntninment finar nanatratinne

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l Printed 4/17/9811:16:32 AM Page 1 of 5

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l Ncrth:ast Utiliti;s ICAVP DR Ns. DR-MP3-0076 Millstone Unit 3 Discrepancy Report (iv), Unsleeved penetrations are used for thermally cold systems, where the operating temperature inside the process pipe is 200 deg F or less. Sleeved penetrations are used for all thermally hot systems, where the operating temperature inside the penetration is more than 200 deg F.

Discrepancy:

The operating process temperature inside Unsleeved penetrations 107,108,109 and 110 under one of the Emergency and Faulted conditions is 257 deg F. This exceeds the design criteria allowable temperature of 200 deg F for Unsleeved penetrations.

Larger thermal expansion induced loads due to the higher pipe-penetration assembly temperature have not been addressed in the penetration qualification calculation (v).

This discrepancy is classified as NRC Significance Level 3 because this condition may place the containment penetration outside the design basis.

Review Valid invalid Needed Date initiator: Prakash, A. 8 O O e/28/97 VT Lead: Nort, Anthony A @ C ] 8/28<s7 VT Mgr: Schopfer, Don K B O O e/29<s7 IRC Chmn: singh, Anand K 3 0 O s/29<s7 c,-.

INVAUD:

Date: 4/15/98 i RESOLUTION: First Response ID: M3-IRF-00361 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0076 does not represent a discrepant condition.

The identified discrepancy is incorrect with regard to the design basis reference for containment penetration temperature criteria.

Penetrations 107,108,109 and 110 are unsleeved penetrations for the RSS supply to the containment spray headers. RSS lines 3-RSS-010-10-2 and 3-RSS-010-5-2 have operating conditions as high as 257'F due a postulated single failure of cooling to the RSS heat exchangers subsequent to a LOCA event, which exceeds the long term design basis of 200'F for unsleeved penetrations. The basis for the 200 'F is provided in NETM-54 which is a referenced design input to the subject calculation and states that 200*F temperature is the maximum design temperature for normal operation or long term periods. The temperature limit of 200*F is necessary to ensure long term integrity of the adjacent concrete containment. Sustained temperatures above 200*F could result in a localized loss of Printed 4/17/5811:16.36 AM Page 2of 5

N:rtheast Utilities ICAVP DR N2. DR-MP3 0076 Millstone unit 3 Discrepancy Report concrete strength over an elongated period of time (i.e. a matter of days to weeks). NETM-54 allows up to 350*F for accident conditions or short durations. The duration of the temperature excursion above 200*F in these lines is less than two hours and therefore is considered not to adversely impact the containment concrete or the containment penetration qualification. This conclusion is consistent with the guidance provided in ACl-349 and ASME Section ill Division 2 Subsubarticle CC-3440.

Therefore, the penetration qualification calculation is consistent with design criteria provided in NETM-54.

The elevated thermal leads applied to the penetration assembly by the attached piping have been evaluated in the referenced penetration calculation. Significance level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0076 does not represent a discrepant condition. The identified discrepancy is incorrect with regard to the design basis reference for containment penetration temperature criteria. The referenced value is for normal operation, while NETM-54 allows up to 350*F during accident conditions. Significance level criteria do not ,

apply as this is not a discrepant condition.

Second Response ID; M3-IRF 01964 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0076 does not represent a discrepant condition. RSS lines 3-RSS-010-5-2 and 3-RSS-010-5-2 have operating conditions as high as 257F due to a postulated single failure of service water cooling to the RSS heat exchangers subsequent to a LOCA event, which exceeds the long term design basis of 200F for unsleeved penetrations. The temperature limit of 200F is necessary to ensure long term integrity of the adjacent concrete containment.

Sustained temperatures above 200F could result in a localized loss of concrete strength over an elongated period of time. The duration of the temperature excursion above 200F in these lines is less than two hours (NETM-54 allows up to 350F for accident j conditions or short durations), and therefore is considered not to adversely impact the containment concrete or the containment penetration qualification. This conclusion is consistent with the guidance provided in ACI 349 and ASME Section ll1 Division 2 Subsubarticle CC-3440.

In their response to M3-IRF-00361, Sargent & Lundy have raised a new unresolved issue. The unresolved issue is that the penetration pipe is restrained on both sides of the containment wall and with post LOCA 257F sump water passing through the penetration, thermal expansion of the piping is restrained. The referenced penetration calculations do not account for this Printed 4/17/9811:16:37 AM Page 3 of 5

I N:rtheast Utiliti:s ICAVP DR N3. DR-MP3-4076 Millstone Unit 3 Discrepancy Report additional loading. The following information is provided to show that the postulated additional loading due to restrained thermal expansion cannot occur.

Drawing 12179-EV-1M, details MB and MF show the penetrations are attached to the containment liner on the "inside )

of Containment end", and are anchored with Nelson studs as l shown on drawing 12179-EV-1J. On the "outside of Containment end", a collar plate is provided which is intentionally not anchored to the concrete structure. Axlal thermal growth is not restrained and therefore is not considered as a design load.

As far as load transfer from piping system analysis is concemed, the penetration analysis contained in calculation 12179-NS(B).

120 uses loads from the piping run which are developed at the piping face of the containment wall, and not at the interface of the penetration and piping. Accordingly no transfer of loads to the face of the wall is required. The methodology for initial sizing of the penetrations is contained in calculation 12179-NS(B)-L l LP1 which ensures the piping system will be the limiting

component and not the penetration.

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Conclusion:

! NU has concluded that Discrepancy Report DR-MP3-0076 does not represent a discrepant condition. As CR M3-98-1207 concluded, RSS piping containment penetrations 107,108,109, l t

and 110 are designed to relieve thermal stress post accident by not anchoring the outside collar plate in each penetration to the concrete containment. This arrangement allows thermal growtn of the penetration in the axial direction to relieve any potential j thermal stresses. Significance Level Criteria do not apply as there are no discrepant conditions.

l Attachments: ,

CR M3-98-1207 l l DWG's 12179-EV-1 M-8 l 12179-EP-79A-10 12179-EV 1J-8 1 12179-EP-79L-10 Previously identifled by NU? O Yes @ No Non Discrepent Condition?@ Yes O No Resolution Pending?O ve. @ No Re.oiution unt sv.470 va @ No Review initiator: Prakash, A.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K ptC Chmn: Singh, Anand K B O *18 2 O O Date: 4/15/98 st Commer.ts: First Response ID: M3-IRF-00361 We acknowledge and accept your disposition response related to Printed N17/9811:16:30 AM Page 4 of 5

ICAVP DR No. DR-MP3-0076 Nartheast Utilities Millstone Unit 3 Discrepancy Report the temperature limit of 200'F for the adjacent concrete containment, which is necessary to ensure long term integrity of the concrete. We also acknowledge and accept your disposition response that elevated thermalloads applied to the penetration assembly by the attached piping have been evaluated in the referenced penetration calculation. However the DR was not written to address either of these issues.

The unresolved issue is that the penetration pipe is welded on both sides of the 4'-6" containment wall. On the inside, the pipe is welded to a 1" thick collar plate, which is welded to the containment liner, and on the outside, the pipe is welded to a 1" thick embedded plate. Under the postulated condition,257'F sump water will pass thru the penetration pipe. Since the penetration pipe is anchored on both sides of the containment wall, thermal expansion is restrained. The resulting forces will be transferred thru the pipe / collar plate and pipe / embedded plate connections to the concrete wall. These forces will be applied to the penetration assembly in addition to the loads applied by the attached piping. The referenced penetration calculations do not address this combined load ccodition.

Second Response ID: M3 - IRF - 01964 NU has provided additional information to show that the postulated additional loading due to restrained thermal expansion cannot occur.

NU refers to Drawing EV-1M, details MB and MF. However, these details are not relevant to the penetrations in question. The relevant details for penetrations 107 to 110 are details MA and MG.

NU has provided Calculation NS(B)-L-2-LP1 for the initial sizing of the penetrations. This calculation states that the penetrating pipe sleeve is embedded in concrete, as such, only loads from within containment need to be considered.

Since the penetration sleeve is embedded in concrete, axial thermal growth of the sleeve is restrained by the concrete / sleeve friction, while radial expansion of the sleeve increases the frictional resistance. The sleeve is axially free to expand only if the frictional resistance is overcome. For the maximum short-term temperature in question (350F), frictional resistance will probably be sufficient to fully restrain the sleeve.

Based on a review of the penetration sizing calculations, and a further evaluation of the condition, we concur with NU that there is no discrepant condition.

Printed 4/17/9811:16:40AM Page 5 of 5 j

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N:rthent Utilities ICAVP DR Ns. DR-MP3-0108 Millstone Unit 3 Discrepancy Report Review Group; systern DR RESOLUTION ACCEPTED Rehw Eht systern %n Poterdial Operability issue Discipline: Piping Design Discrepancy Type: Calculation Ow System / Process: RSs

@ No NRC Significance level: NA Date faxed to NU:

Date Published: 9/1497 D6screpancy: Max Operating Temperature Exceeds Allowable for Unsleeved Containment Penetrations 93 to 95

Description:

In the process of reviewing the following pipe stress calculations for the Recirculation Spray System, (i) Calculation No.12179-SDP-RSS-01361M3 Rev. 4, dated 5/29/97 (ii) Piping and Instrumentation Diagram, Low Pressure Safety Injection / Containment Recirculation, Drawing No.12179-EM-112C Rev.16 (iii) Piping and Instrumentation Diagram, Low Pressure Safety injection, Drawing No.12179-EM-112A, Rev. 25 (iv) Calculation No.12179-NP(B)-X8200 Rev. 2, dated 8/9/84 with Calculation Change Notices (CCN's) 1 through 9. CCN 9 dated 12/4/96 (v) Calculation No.12179-NP(B)-X7102 Rev. 4, dated 6/8/90 with Calculation Change Notices (CCN's) 1 and 2. CCN 2 dated 3/25/97 (vi) FSAR Section 3.8.1.1.4, Steel Liner and Penetrations (vii) Design Criteria for Containment Liner Penetrations, NETM-

54. Issued May 1984 (viii) Calculation No.12179-NS(B)-120 Rev. 2, CCN #9, ' Class 2 Unsleeved Penetrations' we noted the following discrepancy:

Background:

According to the stress data package (1), operating condition 9, an Emergency & Faulted condition, is described as follows 'For a small break LOCA, the Containment Recirculation System may not be automatically actuated. Containment spray is not required and is not actuated resulting in a sump temperature of 215 deg F at time of recirculation. The operator manually actuates either 3RSS*P1 A or P1B which has a discharge temperature of 227 a deg F due to pump heat addition. Wrth a loss of service water to )

associated cooler (3RSS*E1 A or E18), the cooler discharges  !

water of 227 deg F to the reactor coolant system cold legs via the CHS and SHS pumps'.

The P&lD's (ii) and (iii) show that the flow path to the reactor coolant system cold legs inside containment is through lines 3 SIL-010-8-2 (through penetration 93),3SIL-008-130-2 (through penetration 95), and 3SIL-010-8-2 (through penetration 94).

These lines are analyzed in pipe stress analysis calculations (iv) and (v). The operating process temperature for these 1 nanntentinne innrinr ihn nhnun amarnanev

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A fatiltad imnditinn le l Printed N17/9811:17:52 AM Page 1 of 6 l

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N:!rtheast Utilities ICAVP DR N2. DR-MP3-0108 Millstone Unit 3 Discrepancy Report 227 deg F. Penetrations 93 to 95 are unsleeved.

Based on the applicable section of the FSAR (vi), unsleeved penetrations consist of piping installed through the containment wall that is thermally cold, and the process pipe is welded directly to the reinforcement plate.

Based on the design criteria for containment liner penetrations (vil), unsleeved penetrations are used for thermally cold systems, where the operating temperature inside the process pipe is 200 deg F or less. Sleeved penetrations are used for all thermally hot systems, where the operating temperature inside the penetration is more than 200 deg F.

Discrepancy:

The operating process temperature inside Unsleeved penetrations 93,94 and 95 under one of the emergency and faulted conditions is 227 deg F. This exceeds the design criteria allowable temperature of 200 deg F for unsleeved penetrations.

Larger thermal expansion induced loads due to the higher pipe-penetration assembly temperature have not been addressed in the penetration qualification calculation (viii).

Review Valid invalid Needed Date initiator: Prakash, A. O O O S'*7 VT Lead: Neri, Anthony A B O O S/4/S7 VT Mgt: Schopfer, Don K Q Q Q 9/5/Wr l lRC Chmn: singh, Anand K S O O S'S'S7 Date:

INVAUD:

Date: 4/15/98 RESOLUTION: First Response ID: M3-IRF-00362 Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0108, does not represent a discrepant condition.

Penetrations 93,94 and 95 are unsleeved penetrations for the RSS/SIL supply to the RCS loops. The lines associated with these penetrations have been analyzed in the referenced calculations to operating conditions as high as 230 'F due a l postulated single failure of cooling to the RSS heat exchangers l subsequent to a LOCA event, which exceeds the long tenn l design basis of 200 'F for unsleeved penetrations. The basis for I the 200 'F is provided in NETM-54 which is a referenced design input to the subject calculation and states that 200 'F temperature is the maximum design temperature for normal operation or long term periods. The temperature limit of 200 'F is necessary to ensure long terrn integrity of the adjacent concrete containment. Sustained temperatures above 200 'F Printed 4/17/9811:17:56 AM Page 2 of 6

ICAVP DR No. DR-MP3-0108 N:rtheast Utilitlis i Millstone unit 3 Discrepancy Report could result in a localized loss of concrete strength over an extended period of time (i.e. a matter of days to weeks). NETM-54 allows up to 350 *F for accident conditions or short duration.

The duration of the temperature excursion above 200 'F in these lines is short term and therefore is considered not to adversely impact the containment concrete or the containment penetration qualification. This conclusion is consistent with the guidance provided in ACI-349 and ASME Section ill Division 2 Subsubarticle CC-3440. Therefore, the penetration qualification calculation is consistent with design criteria provided in NETM- l

54. l l

The elevated thermal loads applied to the penetration assembly by the attached piping have been evaluated in the referenced i penetration calculation. Therefore, this issue should not be l considered a discrepancy.

Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0108, does not represent a discrepant condition. The referenced value of 200'F is for long term normal operation while NETM-54 allows up to 350*F during short term accident i conditions. Significance Level criteria do not apply here as this is  ;

I not a discrepant condition.

Second Response ID: M3-IRF-01968 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0108, does not represent a discrepant condition. Drawing EV-1M Detail MB and MF (attached) shows the penetrations are attached to the containment liner on the "inside of Containment end", which is anchored with Nelson studs as shown on drawing EV-1J (attached). On the "outside of Containment end" a collar plate is provided which is intentionally not anchored to the concrete structure. Axlat thermal growth is not restrained and therefore is not considered as a design load.

As far as load transfer from piping system analysis is concemed, the penetration analysis contained in calculation 12179-NS(B)-

120 uses loads from the piping run which are developed at the face of the containment wall and not at the interface of the penetration and piping. Accordingly no transfer to the face of the wall is required. The methodology for initial sizing of the penetrations is contained in calculation 12179-NS(B)-L-2-LP1 (attached) which ensures the piping system will be the limiting component, not the penetration.

Penetration 26 contains 3-CHS-003-72-2. The maximum Painted 4/17/9811:17.57 AM Page 3 of 6

N::rthe::st Utilities ICAVP DR N2. DR-MP3 0108 Millstone Unit 3 Discrepancy Report operating temperature for this line is 150 degrees F per SDP-CHS-01336M3 (attached). Calculation 12179-NS(B)-120 conservatively uses a higher design temperature which provides conservative allowable stresses. Since the line temperature is limited to 150 degrees F there is no concem for elevated concrete temperatures.

Penetration 115 contains line 3-SSP-750-29-2. This 3/4 Inch line is inside of the 2 inch pipe which forms the penetration, and has a maximum operating temperature of 617 degrees F. The line is separated from concrete by the air space and connected to the penetration 9 inches from the face of the Containment. Concrete temperatures are not of concem since the line is separated from concrete and only operates for a short duration for the purpose of sampling. Penetration sizing calculation 12179-NS(B)-L-2-LP1 indicates no thermal analysis is required for these types of penetrations.

Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0108, does not represent a discrepant condition. Drawing EV-1M Detail MB and MF (attached) shows the penetrations are anchored on the inside of containment and are not anchored on the outside of containment. Axial thermal growth is not restrained and therefore is not considered as a design load. The maximum operating temperature for penetration 26 is 150' F as documented in the Chemical and Volume Control System (CHS)

Stress Data Package (SDP) calculation SDP-CHS-01336M3, revision 12 (attached). Penetration 115 is a sleeved penetration as documented on Containment Structure Piping Penetrations drawing EV-1M, detail MB and MF. The line is separated from l the concrete by the air space and therefore, temperatures are not a concem.

Significance Level criteria do not apply here as this is not a discrepant condition.

Previously identified by NU? O Yes (#) No Non Discrepant Condition?(G) Yes O No Resolution Pending?O ve. @ No Re.oiution unre.oived?O ve. @ No Review Acceptable Not Acceptable Needed Date Initiator: Prakash, A.

O O *15S8 VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K e O

• SS8 i

IRc Chmn: Singh, Anand K G O O

• SS8 O O O Date: 4/15/98 sL comments: First Response ID: M3-IRF-00362 We acknowledge and accept your disposition response related to the temperature limit of 200*F for the adjacent concrete Printed N17/9811:17:58 AM Page 4 of 6

1 N:rthecct Utilitien ICAVP DR N;. DR-MP3-0108 Millstone Unit 3 Discrepancy Report I containment, which is necessary to ensure long term integrity of the concrete. We also acknowledge and accept your disposition 1

response that elevated thermalloads applied to the penetration assembly by the attached piping have been evaluated in the referenced penetration calculation. However tbs DR was not '

written to address either of these issues.

The unresolved issue is that the penetration pipe is welded on both sides of the 4'-6" containment wall. On the inside, the pipe is ,

welded to a 1" thick collar plate, v.91ch is welded to the containment liner, and on the outside, the pipe is welded to a 1" {;

thick embedded plate. Under the postulated condition,227'F j pump discharge water will pass thru the penetration pipe. Since '

the penetration pipe is anchored on both sides of the containment wall, thermal expansion is restrained. The resulting forces will be transferred thru the pipe / collar plate and pipe / embedded plate ,

connections to the concrete wall. These forces will be applied to '

the penetration assembly in addition to the loads applied by the ,

attached piping. The referenced penetration calculations do not i address this combined load condition.

t in light of NU's disposition, we reviewed calculation NS(B)-120 further and noted that there are several unsleeved penetrations which which have a design temperature that exceeds 200*F. In l most of these cases, the peak temperature is less than the "short j term" limit of 350*F. However, for the chemical and volume control system penetration (No. 26) the peak, presumably short 3

term, temperature is 560'F, and for the post accident sampling )

system penetration (No.115), the design temperature is 650'F, I ana Ine peak temperature is 01 rt . In Dotn or inese cases, Ine j stated short term temperature criteria of 350'F is violated. Yet no )

evaluation of these temperatures is provided.

Second Response ID: M3 - IRF - 01968 NU has provided additional information to show that the l postulated additional loading due to restrained thermal expansion i cannot occur.

NU refers to Drawing EV 1M, details MB and MF. However, these details are not relevant to the penetrations in question. The relevant details for penetrations 93 to 95 are details MA and MG.

NU has provided Calculation NS(B)-L-2-LP1 for the initial sizing of the penetrations. This calculation states that the penetrating pipe sleeve is embedded in concrete, as such, only loads from within containment need to be considered.

Since the penetration sleeve is embedded in concrete, axial thermal growth of the sleeve is restrained by the concrete / sleeve friction, while radial expansion of the sleeve increases the frictional resistance. The sleeve is axially free to expand only if the frictional resistance is overcome. For the maximum short-term temperature in auestion (350FL frictional resistance will PrWed 4/17/9811:18.00 AM Page 5 of 6

Ncrthsast Utilities ICAVP DR Ns. DR-MP3-0108 Millstone Unit 3 Discrepancy Report probably be sufficient to fully restrain the sleeve.

Based on a review of the penetration sizing calculations, and a further evaluation of the condition, we concur with NU that there is no discrepant condition.

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Printed N17/9811:18:00 AM Page 6 of 6

l N:rtheart Utiliti:a ICAVP DR No. DR-MP34228 Millstone Unit 3 Discrepancy Report q Review Group: Configuration DR RESOLUTION ACCEPTED Potential Operabilsty lasue Discipline: I & C Design Discrepancy Type: Installation 1.WT,ini;.taon Om System / Process: RSS g

NRC Significance level: 4 Date faxed to NU:

Date Published: 12/21/97 Discrepancy: Instrument Labeling Descripuon: The following labeling inadequacies with respect to design documents and requirements of Procedure OA-9," System and Component Labeling," were noted during system walkdowns.

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1. Instrument 3RSS-TE28A was to be retagged per Table 2, page 3 of Change Control Document T-C-0664C. The installed instrument is still identified as P683-TE28A.

2. Pressure transmitter 3RSS*PT25A as shown on drawing BK-16P-58-6 Rev. C was identified based on its location and connection to sensing line 3RSS*PT25A. The instrument is incorrectly tagged as " spare."

Review Valid invalid Needed Date

{

initiator: Server, T. L 8 0 0 $2/i/97 -

VT Lead: Neri, Anthony A B O O 52/s/97 VT Mgr: schopfer, Don K B O O 12/is/97 1RC Chmn: singh. Anand K B O O 12/11/97 Date INVALID:

Date: 4/15/98 l RESOLUTION INITIAL DISPOSITION:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0228, 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- 1 20 criteria and found to have no operability or reportability l concems and meets the Unit 3 deferral criteria. CR M3-98-0137 l has been written to develop and track resolution of this item per j RP-4.

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Conclusion:

i NU has concluded that Discrepancy Report, DR-MP3-0228, 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- l 20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0137 has been written to develop and track resolution of this item per Printed 4/17/98 i s:18.47 AM Page 1 of 3

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N rtheast Utilities ICAVP DR N2. DR-MP3-0228 Millstone Unit 3 Discrepancy Report RP-4, FINAL DISPOSITION:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR MP3-0228 does not represent a discrepant condition.

U3 PI 20 section 1.3.2 e defines the type of labeling discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of cttachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.NU concludes that the assignment of priority 4 is correct and in accordance with U3 PI 20 section 1.3.2 e.

Significance level criteria does not apply to the new issue as this is not a discrepant condition.The corrective actions in CR M3 0137 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4.

Conciusion; NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0228 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in CR M3-98-0137 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identified by NU7 O Yo. (#) No Non Di.crepant CondM6on?O Ye. (#) No Re.olution Pending70 Ye. @ No Re.oiuiion unre.oiv.d70 Ye. @ No Review  !

Initiator: Warner, t.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chrnn: singh, Anand K Date: 4/j$/g8 I st Cornrnents: INITIAL COMMENT Based on CR M3-98-0137 is is not apparent why the labeling changes can be deferred based on the deferral criteria.

" Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling Printed N17/9811:18:s0 AM Page 2 of 3

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N::rtheast Utilitias ICAVP DR No. DR-MP3-0228 Miiistone Unit 3 Discrepancy Report i I

discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred."

FINAL COMMENT: ,

We accept NU's justification for making the discrepancy a level 4.

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N::rtheart Utilitie3 ICAVP DR No. DR-MP3-0360 l Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED j Potential Operability lasue Discipline: Mechanical Design ]

Discrepancy Type: Component Data System / Process: Oss g

NRC Significance level: 4 Date faxed to NU.

Date Published: 1/17/98 Discrepancy: Specification 2362.200-164 & related drwgs are inconsistent for 3QSS*MOV34A,B l Descripuon: Vendor drawings 2362.200-164-002 Revision E and 2362.200-164-043 Revision C, compliment the data in specification 2362.200-164 through Addendum 1, but also contain conflicting )

information.

The following are the specification and drawing discrepancies:

Type oiOperator: l

i. Limitorque SMB-0002 per specification 2362.200-164

11. Limitorque SMB-0005 per drawing 2362.200-164-043C 4 lii. Limitorque SMB-0002 per drawing 2362.200-164-002E )

Review {

Valed invalid Needed Date  ;

initiator: Feingoid, D. J. G O O 2/ie/97 l

VT Leed: Nerl, Anthony A B D 0 2/17/97 VT Mgr: schopfer, Don K S O O $2/23/97 IRC Chmn: singh, Anand K S O O 1/ 3'S8 Date:

INVAUD:

Date: 4/15/98 RESOLUTION: Disposillon:

NU has concluded that Discrepancy Report, DR-MP3-0360, has identified a condition not previously discovered by NU which i i

requires correction. This discrepancy meets the criter.la specified l I

l In NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. CR M3-98-1696 has been written to correct the specification / drawings as appropriate, post startup.

I

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0360, 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 attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of US Pl 20 deferral criteria. CR M3-98-1696 has been written to correct the specification / drawings as appropriate, post startup.

. Previously identified by NU? ( ) Yes (9) No Non Discrepent Condition?C) Yes (G) No l Pnnted 4/17/9611:19:41 AM Page 1 of 2 J

Nertheast Utilities ICAVP DR No. DR-MP3-0360 Millstone Unit 3 Discrepancy Report

__ , _ . . > ....mm....., .__ ,,_ , , _ _ ~ . __._mm.. _, .__ ,,_

Resolution Pending?O vee @ No Resoldson Uniresolved?O vos @ wo Review j initiator: Feingold. D. J.

VT Lead: Nerl, Anthony A i VT Mgr: Schopfer, Dm K x

O O N15/98 i l

x N16/98 1 1RC Chmn: Singh, Anand K l Date:

D '

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SL Comments:

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N rthe st Utilities ICAVP DR N3. DR-MP3-0365 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED i Potential Operability lasue Discipline: I & C Design l

Discrepancy Type: Drawing Om g

system / Process: HVX NRC Significance level: 4 Date faxed to NU:

( Date Published: 11/2S 7 Discrepancy: Drawing Discrepancy - LSK-22 7C Descsipt'.on: Logic Diagram 22-7C, Rev 9 shows that dampers i 3HVP* MOD 20A, MOD 23A, MOD 26A and MOD 20C are l controlled automatically if either of the vent supply fans, 3HVP*FN1 A or FNIC,is running. Fans are 50% capacity fans per FSAR Section 9.4.6.2. Dampers are controlled automatically if both vent supDly fans are running per FSAR Section 9.4.6.5.

l Logic Diagrem shows that dampers are driven to a position opposite their failure positions if both vent supply fans are not running. Dampers are driven to o position opposite their failure posit' ions if either vent supply fan is not running per PalD EM-

150C-15. This would prevent the temperature controller from modulating the inlet, outlet and recirculating air dampers that would be required wiien only one supply fan is operating.

The Condition " Dampers Driven to Position Opposite Failure Position" has no Source inputs. t Keview I Valid invalid Needed Date J initiator: Pinelas. H. 9 O O 10/1as7 VT t.ead: Nort, Anthony A B O O 10<27/97 VT Mgr: schopfer, Don K B O O 10/28/97 IRC Chmn: Singh, Anand K B O O So?oS7 i

Date: l INVAllD: l Date: 4/16/98 RESOLUTION: Disposillon; NU has concluded that Discrepancy Report, DR-MP3-0365, has

! identified a condition not previously discovered by NU that

! requires correction. LSK 22-7C and ESKs 6ACL and ACM depict the correct logic for the fan and damper interiocks. When either l (or both) ventilation supply fan is running the temperature controller will modulate these dampers provided the diesel enclosure room temperature is above the nominal setpoint.

During a nonnal shutdown when both fans have been secured the outlet and inlet dampers (3HVP* MOD 20A, C, and 23A) close and recirculation damper (3HVP* MOD 26A) opens.

However, on a loss of power the outlet and inlet dampers open and the recirculation damper closes assuming their fall safe position.

The PalD incorrectly states that when either supply fan 3HVP*FN1 A(B) or 3HVP*FN1C(D) is not running the dampers will assume their opposite failure position. The P&lD should state Printed 4/17S611:20:21 AM Page 1 of 3

N:rtheast Utilities ICAVP DR No. DR-MP3-0366 Millstone Unit 3 Discrepancy Report  !

that when both supply fans 3HVP*FN1 A(B) and 3HVP*FN1C(D) are not running the dampers will assume their opposite failure position.

FSAR section 9.4.6.5 incorrectly states that when both supply l fans have started, the temperature controller modulates the inlet, recirculation and outlet dampers. This is inconsistent with the control logic as depicted on LSK 22-7C and ESKs 6ACL and ACM. The FSAR section 9.4.6.5 should state that when either supply fan starts the temperature controller modulates the inlet, recirculation and outlet dampers to maintain temperature below l 120 'F in the emergency generator enclosure. '

CR M3-97-3965 was initieted to document the P&lD and FSAR discrepancies. i l

The approved corrective action plan for M3-97-3965 will correct I the P&lD and FSAR discrepancies prior to startup. l Attachments:

M3-97-3965 approved corrective action plan )

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0365, has identified a condition not previously discovered by NU that requires correction. CR M3-97-3965 has been written with the corrective action plan approved to revise FSAR section 9.4.6.5 and the associated P&lD to reflect the correct emergency generator enclosure ventilation logic as depicted on the I applicable LSK and ESK drawings.

The approved corrective action plan for M3-97-3965 will correct l the P&lD and FSAR discrepancies prior to startup.

Previously identified by NU? O Yes (G) No Non Discrepent Condition?O Yes (S) No l Resolution Pending?O vee @ No nesoiutionunreeoived?O vee @ No Review Acceptable Not Acceptable Needed Date initiator: DeMerco. J. N16M VT Lead: Neri, Anthony A N162 VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K B O *16 5 O O O Date: 4/16/98 st. comments: The action plan appears to be correct with the following exception with regard to scheduled completion. The Corrective Action Plan (CAP) Form RP41 Rev. 5, Page 4 of 7, sheet 1 identifies AITTS Tracking No. 97027528-02 with a Sched. Ref. 06UO2 Mode: 4.

ICAVP Response Fonn Response ID: M3-IRF-00921 is dated 2/19/98. According to Portal G, Action Tracking viewed on 2/25/98, Panet TIMX291 for Task 02 of A/R 97027528 states "1/21/98 PROCESSED CHANGE FORM: CHANGE MODE FROM 4 TO 2." This change should have been noted in the attachments to the IRF.

Pnnted N17211:20:25 AM Page 2 of 3

N:rtheast Utilities ICAVP DR N2. DR-MP3-0366 Millstone unit 3 Discrepancy Report REDISPOSITIONED ON 4/16/98 - Changed Significance Level from 3 to 4 since only the affected P&lD and the FSAR required l updating to be in agreement with the associated logic diagram and electrical schematic.

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N rtheist Utiliti:s ICAVP DR N3. DR-MP3 0387 Millstone Unit 3 Discrepancy Report I

Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Piping Design Discrepancy Type: Calculation Om System / Process: sWP g

NRc Significance levot: NA Date faxed to NU:

Date Published: 1/17FJ8 l Discrepancy: Containment Recirculation Cooler Nozzle Load Qualification l Discrepancy DucripUon: In process of reviewing the following pipe stress analysis calculations, l (1) Calculation NP(F)-1907 Rev. 4, CCN # 1:

(2) Calculation NP(F)-1908 Rev. 3, CCN # 1 l (3) Calculation NP(F)-7919 Rev. 2, CCN # 6 (4) Calculation NP(F)-7923 Rev.1, CCN # 5 (5) Calculation NM(S)-748-CZC-003 Rev. O, CCN # 4 The following discrepancy was noted :

Calculation (5) provides an Evaluation of stresses due to nozzle  !

loads for Containment Recirculation Coolers 3RSS*E1 A, B, C, D.

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Nozzle loads evaluated in Calculation (5) are not consistent with l the nozzle loads computed in calculations (3) & (4). Calculated i nozzle loads in (3) & (4) are larger than the qualified nozzle loads.

For nozzle load qualincation, Calculations (2) & (3) Incorrectly ,

refer Rev.1 of Calculation (5). l Calculations (1) & (4) provide no reference to nozzle loads l evaluation calculation.

l Review Valid invalid Needed Date initiator: singh, R. B 0 0 1/8/S8 VT Lead: Neri, Anthony A O O O 1/8S8 l VT Mgr: schopfer, Don K O O O 1'12/98 IRc Chmn: Singh, Anand K B O O 1/13S8 Date:

INVALID:

Date: 4/13/98 REs0LUTION. Disposition: Response ID: M3-IRF-01896 I NU has concluded that DR-MP3-0387 does not represent a l discrepant condition. DR-MP3-0387 rasies 3 issues, each of which is addressed as follows:1) The nozzle loads in referenced calculations 3 and 4 are consistent with the nozzle loads evaluated in calculation NM(S)-748-CZC-003 ( Reference attached copy of latest revisions of NM(S)-748-CZC-003 Rev.1 CCN #2, NP(F)- 7919 Rev 2 CCN # 8 ( See Transmittal M3-TRA-00187 ), and NP(F)-7923 Rev. 2 CCN1 ( See Transmittal M3-TRA- 00156) ).

Printed 4/17/9811:21:1o AM Page 1 of 2

)

ICAVP DR N2. DR-MP3-0387 N:rtheast Utilitiea Miiistone Unit 3 Discrepancy Report

2) The reference to Rev 1 of NM(S)-748-CZC-003 in calculations NP(F)-1908 Rev. 3, CCN # 1 and NP(F)- 7919 Rev 2, CCN # 6 is correct. Revision 1 of NM(S)-748-CZC-003 was issued on 10 /

18 / 96 and has been changed up to CCN 2 ( See Attached ).

3) Stress calculations NP(F)-1907 Rev. 4, CCN # 1 and NP(F)-

7923 Rev. 2 are input calculations to the nonle load evaluation calculation and, as such, are not required to forward reference.

The reference structure is correct as presented.

Significance level criteria does not apply as these issues are not discrepant conditions.

1

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0387 does j not represent a discrepant condition. As detailed in the j disposition, the nonle loads referenced in calculations I calculations 3 and 4 are consistent with the nonle loads l evaluated in calculation NM(S)-748-CZC-003 Rev 1 CCN2. The misunderstanding conceming loadings and reference level can be attributed to reviewing a superseded revision of NM(S)-748-CZC-003. Additionally, stress calculations NP(F)-1907 Rev. 4, CCN # 1 and NP(F)-7923 Rev. 2 are input calculations to the nonle load evaluation calculation and as such are not required I

to forward reference. The reference structure is correct as

?

presented.

l Significance level criteria does not apply as these issues are not discrepant conditions.

Attachments:

NM(S)-748-CZC-003 Rev.1, CCN # 1, CCN #2 ( 453 pages Total)

NP(F)- 7919 Rev 2, CCN # 8 ( Previously Transmitted See Transmittal M3-TRA-00187 )

NP(F)-7923 Rev. 2 CCN 1 ( Previously Transmitted See Transmittal M3-TRA-00156 )

Previously identifMKl by NU7 O vos (9) No Non D6screpent Condition?T) Yes O No Resolution Pending?O ves @ No ResolutionUnresolved?O yes @ No Review initiator: Jain. R. C.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K Date:

SL Comments:

I Printed 4/17/9811:21:14 AM Page 2 of 2

N:rthe:st Utilities ICAVP DR N2. DR-MP3-0490 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED i Potential Operability issue Discipline: Piping Design Discrepancy Type: Calculation Om -

l l SysterrVProcess: SWP g l NRC Significance level: NA Date faxed to NU:

Date Published: 1o/26/97 l l

Discrepancy: Bracket modifications for valve 3-SWP-MOV 24C not performed

Description:

During review of the following Service Water System calculations l (I) 12179-NP(F)- 835-XD-Rev 4, CCN 1 l (11) DCN DM3-S-0794-95 l l (Ill) 12179 NP(B)-X1910-Rev 1, CCN 7 '

l l we noted following discrepancy:

According to (1):

Page 3, item 3 - The bracket for 3-SWP-MOV-24C does not i meet the Pl-3 design basis criteria when subjected to piping-l

~

specific seismic accelerations.

Page 5 Bracket Evaluation Summary - Bracket for valve 3-SWP- j MOV-24C is "NG" (no good ) for the actual acceleration (g)  :

levels. )

l Page 4, Re' commendation item 2 - Modify the subject valve l l brackets to retum these valves to the design basis criteria as '

defined in PI-3.

l According to (II) DCN Problem Solution: The action recommended is a paper change only. No field work required.

Therefore, no work was performed on the valves and the DCN l l was closed.

Calculation (111) shows no documentation to indicate that any bracket modification work was performed on valve 3-SWP-MOV-l 24C. 1 Reviety valid invalid Needed Date Ininator: Jain, R. C. 8 O O 10/1'S7 I VT Lead: Neri, Anthony A B O O o'15'S7 VT Mgr: Schopfer, Don K B O O io/20t97 IRC Chmn: Singh, Anand K 8 0 0 10/21/97 Date:

INVALID:

Date: 4/16/98 RESOLUTION: Disposition : Response ID: M3-IRF-01008 o

NU has concluded that DR-MP3-0490 does not represent a discrepant condition.

The issue of concem for DR-MP3-0490 is thr.t calculation 12179-NP(B)-X1910 Rev 1 CCN 7 does not indicate that the brackets for valve 3-SWP-MOV-24C have been modified as Printed 4/17/961121:47 AM Page 1 of 2 1

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l N:rtheast Utiliti;s ICAVP DR No. DR-MP3-0490 l Millstone unit 3 Discrepancy Report recommended. The valve brackets were modified per DCN ,

DM3-S-0304-95 to resolve the concem of over stress ( Attached i AWOs confirm implementaiton of DCN DM3-S-304-95 ). DCN l DM3-S-0794-95 was issued solely for the purpose of updating i Specification 2282.400-568 to indicate that acceleration values l less than standard 3 g's, as developed in the piping evaluation, I were used to qualify the 115 valves. Calculations 12179-NP(F)-

835-XD and 12179-NP(B)-X1910 are not required to be updated to address the valve modifications, since these calculations are limited to pipe stress evaluation. The copy of the memo identifying the need for the valve bracket modifications is included in these calculations as reference only. Calculation 94103-C-27 ( transmitted in Transmittal Number 118 dated 10/7/97 ) qualifies the valve bracket modification.

Significance level criteria does not apply as this is not a discrepant condition.

Conclusion:

f NU has concluded that Discrepancy Report DR MP3-0490 does not represent a discrepant condition. As detailed in the disposition, the valve modifications were performed per DCN DM3-S-0304-95. The referenced DCN and calculations are correct and provide the proper documentation to allow traceability.

Significance level criteria do not apply as this is not a discrepant q condition. 1 Previously identifled by NU? O Yes @ No Non Discrepent condition?@ Yes U No

":::: "zi.;?C Yr @" "- :'f : '." .- _ ';;d? C Y;: @ 'd:

Review initiator: Jain. R. c.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K oste: 4/16/98 sL comments: it is recommended that the DCN DM3-S-0304-95 used to modify  !

valve bracket should be tracebate through the documents (i), (ii)

& (iii).

1 Note: Resolution acceptance of the DR is revised to correct marking of "Non Discrepant Condition".

It was inadvertantly marked " No

• now corrected to " Yes ".

The NRC significance levelis changed to N%.

1 Printed 4/17/9811:21:50 AM Page 2 of 2 l

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1 N:rthert Utilities ICAVP DR No. DR-MP3-0500 Miiistone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED j Review Element: System Design p Discipline: Electrical Design l

Discrepancy Type: Cam Om l

@ No .

System / Process: DGX l

NRC Significance level: 4 Date faxed to NU: 1 Date Published: 12/7/97 Discrepancy: Calculation NL-033 (Emergency Diesel Loading and Starting kVA

, Calculation) l

Description:

Calculation NL-033 determines the loading on the Division A l emergency diesel generator for various scenarios involving the l loss of offsite power combined with normal shut down, a small l break in the secondary side of the nuclear steam supply system, a large secondary side break, a small break loss of coolant i

accident (LOCA), and a large break LOCA. It also estimates the l transient voltage drop on the diesel generator to determine compliance with Regulatory Guide 1.9.

1 The following items were observed in this calculation:

The transient voltage and frequency dip information used in the calculation does not consider the effect of the steady state loading on the transient voltage and frequency dip, and the

steady state load used as the basis of the curve of page 12 of l Attachment D that is used to calculate the starting voltage dip is I l not stated. However, page 3 of Appendix B indicates that while I 3600 kW of load are required to produce a 0.7% frequency dip j on an unloaded machine, only 1253 kW are required to produce j i U.e 5&ne hquency dy, when the rnochinc is ccTy ng 3700 kW j of steady state load before the test load was added. There is a l similar variation in the voltage dip. (See the Electric Machinery i l Manufacturing Co. pamphlet "The ABC of Checking Voltage l Drop in Starting AC Motors".) The calculation should either take the steady state load at each step in the starting sequence into account or explicitly use bounding (worst case) values.

Appendix D calculates the per unit peak input power to the i component cooling water pump to reduce the calculated peak power demanded from the diesel engine and generator. The l peak power is calculated from the output torque and speed, as well as the motor efficiency. The implied assumption is made that the motor efficiency at breakdown conditions is the same as during steady state full load operation. However, the motor

current at breakdown torque conditions is much higher than

! during full load operation. This implies higher copper losses, and

! therefore lower efficiency. This can be seen by examining the calculated data for a two pole,700 hp,4000 voit motor:

Break Down Full Load Speed 3456 RPM 3582 RPM Torque 2644 ft Ibf 701 ft Ibf Printed 4/17/9e 2:18:49 PM Page 1 of 16

l N:rtheart Utilities ICAVP DR Ns. DR-MP3-0500 l Millstone unit 3 Discrepancy Report i

l Current 305 amp 53 amp Power Factor 0.702 0.939 i

! Efficiency 0.875 0.945 i

The effect of the increased transient loading should be examined.

i Page 13 indicates that an assumed power factor of 0.85 will be l applied to nore-motor loads. However, the heater loads, which

! have unity power factor are added arithmetically to the kVA of other non-motor loads. As a result, the 0.85 power factor will be applied to the heater loads. This will reduce their kW loading by a multiplier of 0.85, which is not conservative.

The running kVA of the motor control center loads is determined based on typical efficiencies and power factors with different values being used for loads larger than 50 hp and for loads 50 hp and smaller. However, the starting kVA is calculated using a single assumed conversion factor of 1 hp = 1 kVA. This is inconsistent. (The assumed efficiency and power factor values give a conversion factor of 1 hp = 0.921 kVA for loads larger than 50 hp,1 hp = 0.9973 kVA for-continuously running loads 50 hp and smaller, and 1 hp = 1.5224 kVA for motor operated

, valves.)

l Information about the brake powers of the various loads are given in more than one part of the calculation, e. g. Attachment S Ond ^"00hment E. E=mp!00 Of 'h000 in00nd!000!0S int!d the brake power given for the original Impeller of 3CCP*P1 A in Attachment B and the brake power given for the cut down impeller in Attachment E, the input power for 3HVK*CHL1 A on page 41 of Attachment B and the brake horsepower and efficiency given in Attachment E, and the values for the motor full load current of 3HVR*FN6A-B given in the motor data sheet of page 47 and the test report on page 49 of Attachment B.

Some of this information is inconsistent. Some information

! should be provided as to which of the conflicting information is valid and why.

Some of the motor data on pages 17 and 18 and the corresponding data on page 4 of Attachment A are inconsistent: ,

Load Quantity Value from Pages 17 and 18/

Value from Page 4 of Attachment A 3HVR*FN10A1&2 Power factor 0.85 / 0.92 3HVC*ACU2A Bhp 75/ 70 j Printed 4/17/98 2:18:s3 PM Page 2 of 16 l l

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l N:rtheast Utilities ICAVP DR Ns. DR-MP3 0500 Millstone Unit 3 Discrepancy Report 3HVR*FN6A Efficiency 0.928 / 0.902  ;

in addition to the difference in the efficiency of the motor for 3HVR*FN6A noted above, its efficiency is shown as 0.928 on page 9 of Attachment E and as 0.902 on page 47 of Attachment j

! B. )

i Appendix A, page 22 states that the " nominal level at which the RHR pumps auto trip and Si sump switchover" occurs is 25.42',

corresponding to 619,910 gallons of water remaining in the RWST. However, on page 23 of Appendix A, the calculation of the volume of water remaining in the tank at the time that the RHR pump trips is 479,005 gallons. This increases the length of time that the RHR pump is assumed to operate.

Statement 8 on page 9 of Appendix A states that one of the two RSS pumps will be shut down 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into the accident and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before the residual heat removal pump is started in the case of a large secondary system break. However, the input data given on page 43 of Appendix A states that both RSS pumps will operate until the residual heat removal pump is started. The difference should be explained.

Appendix A states that during a small break in a feedwater or main steam line that a bank of pressurizer heaters and the spent fue! ca^!!ng pum;' w"! M ene~;!M menue!'y eedy !a 'he e'/en' (typically 11 minutes after the beginning). However, page 7 of Attachment A (Table 3) indicates that these loads are started after the safety injection and residual heat removal pumps have been tumed off. Appendix A states that this will happen i hour after the beginning of the event. This difference should be explained.

On page 9 of Attachment A (Table 5) for a large break in a feedwater or main steam line, Motor Control Center 3EHS*MCC1 A3 is shown as starting after a residual heat removal pump is shut down. Appendix A states that the residual heat removal pump will be shut down about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the event begins and that the motor control center will be connected about 20 minutes after the event starts. Also, Table 5 shows that a service water pump is shut down, while Appendix A indicates that they are operated for the duration of the accident. Table 5 shows that the pressurizer heater group is energized much later than does Appendix A. Table 5 shows the fuel building exhaust fan and filter starting late in the event, while Appendix A indicates that they are started about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the start of the event. These differences should be explained.

Page 11 of Attachment A shows the spent fuel pump and Motor Control Center 2EHS*MCC1 A3 startino at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the Printed N17/96 2:18:s4 PM Page 3 of 16

N::rthe tt Utilities ICAVP DR N3. DR-MP3-0500 i

Millstone Unit 3 Discrepancy Report  !

start of a small break LOCA event. They would be expected to start sooner based on the information in Appendix A.

i Pages 13 and 14 of Attachment A (Tables 9 and 10) show Motor  !

Control Center 2EHS*MCC1 A3 energized 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the I beginning of a large break LOCA. The motor control center l would be expected to be energized sooner. (See the discussion )

in Attachment A.) l I

Page 17 of the calculation gives the runout brake power of j 3SlH*P1 A as 440 hp. However, the pump curve of Attachment B, page 12 shows a brake power no larger than 420 or 430 hp. ,

For the purposes of this calculation, the result is conservative. I Page 17 of the calculation also gives the flow rate of the

]

component cooling pump,3CCP*P1 A/C as 9600 gpm, while the memorandum that is page 14 of attachment B indicates that the flow is 10910 gpm. Using the latter vahie increases the brake power of the motor to 745 hp as shown on page 16 of Attachment B. I l

The memorandum of Attachment B, page 19 indicates that  !

3FWA*P1 A is described by pump test curve 37762. However, l pump curve 37761 is attached to the calculation instead.

l l

Information about the starting voltage dip and recovery time is I taken from page 12 of Attachment D. In the following cases, I there were errors in transcribing the data from the curve. On  !

page 10 of Attachment A, the recovery time for a 1044 kVA l 00rr00:0d et0rting kVA 100d ic 0.10 c000nd and the recev0r/F m for a 1491 corrected starting kVA load is 0.15 second. On pages 11 and 12 of Attachment A, the voltage dip for a 1657 corrected  !

kVA load is 4 %. On pages 11 and 12 of Attachment A, the voltage dip for a 2578 corrected starting kVA load is 7%. On -

I page 12 of Attachment A, the voltage dip for a 3133 corrected starting kVA load is 7.5% and the voltage recovery time of a 4099 corrected starting kVA load is 0.35 second. On pages 13 and 15 of Attachment A, the voltage dip for a 3133 corrected g starting kVA load is 7.5% and the voltage dip recovery time for a l 790 corrected starting kVA load is negligible.

The reference for the brake power of 3HVC*ACU2A should be Memorandum GMB-90-134, not GMV90-13, as stated in the calculation, j On Page 12 of Attachment A, the starting kVA values are crossed out for 3HVU*FN2A, but the revised values were not copied in.

On page 33 of Appendix A, the indicated addition gives a total loss of 2 589 kW for the small miscellaneous transformers, not 2.449 kW as shown. This is small compared to the total diesel loading. ,

i I

The addition indicated on page 21 gives a value of the " Total Non-Motor Demand Loads" of 115.18 kVA. not 114.0 kVA as  ;

Pnnted 4/17/96 2:18:54 PM Page 4 of 16  ;

I

N2rthenct Utilities ICAVP DR N . DR-MP3-0500 Millstone Unit 3 Discrepancy Report shown on page 22.

The peak kW for step 4 on pages 5 and 6 of Appendix A is 1991+ 2.2x800= 3751 kW, not 3359 kW as shown.

Review Valid invalid Needed Date initiator: Bioethe, G. Wil66am G O O tii e/87 VT Lead: Neri, Anthony A G O O 11/18/97 VT Mgr: schopfer, Don K G O O 11/21/97 1RC Chmn: singh, Anand K G O O 15/2sto7 Date:

INVALID:

Date: 4/6/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0500, has identified a condition in items 2,5,6,7,13,15,18 and 19 not previously discovered by NU which require correction.

Attachment I summarizes each of the issues identified in the DR and provides a disposition.

NL-033 determines the steady state loading on the Emergency Diesel Generator (EDG) under various plant accident / abnormal conditions, the steady state reactive power (KVAR) loading on the EDG during the worst kW loading condition and the transient loading capability of the EDG to automatically start the emergency loads in the required sequence, under design basis postulated accident conditions to verify the voltage and frequency limits, as specified in the procurement documents and as described in the Final Safety Analysis Report. The degree of refinement (pencil sharpening) in this calculation is a function of j the encroachment on margin and likelihood to exceed the l machine ratings for an extended time. The comments )

associated with DR-MP3-0500 speak to a higher level of l refinement than that used by NU or the original Architect i Engineer over the years from design to startup to today. In the l case of Millstone 3, we do not have a tightly loaded diesel generator. The Millstone 3 EDGs have the following ratings:

• Continuous 4986kW

• 2000hr. 5335kW

• 160hr. 5486kW

• 30 minute 5983kW The above ratings are maintenance cycle based with the engine having sufficient " brute" horsepower to drive the generator at the shortest duration / highest output rating. It is a matter of limiting the peaks to these durations within another longer duration, and for some of the ratings, doing maintenance more frequently.

Currently, the maximum steady state loading of the Millstone 3 EDG occurs at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> into the " Containment Depressurization Actuation plus Loss of Power, one train available" Design Basis Printed 4/17/98 2:18:56 PM Page 5 of 16

N:rtheast Utilitie3 ICAVP DR NO. DR-MP3-0500 Millstone Unit 3 Discrepancy Report Profile and is 5102kW. This value is below the 2000hr. rating of 1 5335kW. As such, there is nothing about Millstone 3's case that warrants the level of refinement relative to loading assumptions f

j that has been applied by Sargent and Lundy. We will, therefore, I group all of those issues failing into the " refinement" bin and discuss these in their totality, and separately address issues that amount to more than refinement.

Deficiency Nos 2,5,6,7,13,15,18 and 19 as defined on Attachment 1 are considered valid. These items are considered {

refinements and are minor or editorial in nature and do not affect the outcome of the calculation. The correction of these items are being tracked to completion via CR M3-97-4635. The approved corrective action plan for CR M3-97-4635 will track and correct these items post startup.  ;

in the net, however, NU has determined that none of the identified issues have impact on the design and/or license bases for the unit and the Significance Level of this DR should, accordingly, be downgraded to Significance Level 4. Our detailed discussion follows on Attachment 1.

NU has concluded that items 1,3,4,8,9,10,11,12,14,18,17 and 20 are not discrepant as indicated on Attachment 1, therefore Significance level criteria do not apply to these items.

Conclusion:

N tj has ennelndad that ninerannnev Rannrt, nR.MP3.nRnn hne identified a condition in items 2,5,6,7,13,15,18 and 19 not previously discovered by NU which require correction. Of the 20 items identified on the DR, only 8 are considered valid and require correction.

The addition indicated on page 21 gives a value of the " Total 1 Non-Motor Demand Loads" of 115.18 kVA, not 114.0 kVA as l shown on page 22. j

{

The peak kW for step 4 on pages 5 and 6 of Appendix A is 1991

+ 2.2x800= 3751 kW, not 3359 kW as shown.

Deficiency Nos 2,5,6,7,13,15,18 and 19 as defined on Attachment 1 are considered valid. The correction of these items are being tracked to completion via CR M3-97-4635. The l approved corrective action plan for CR M3-97-4635 will track l and correct these items post startup.

These items are either minor or editorial in nature and do not affect the outcome of the calculation, therefore NU considers these valid items to be Significance level 4 issues.

6 NU has concluded that items 1,3,4,8,9,10,11,12,14,16,17 and 20 are not discrepant as indicated on Attachment 1, therefore Significance level criteria do not apply to these items.

Printed 4/17/98 2:18:s7 PM Page 6 of 16

N:rtherst Utilities ICAVP DR N3. DR-MP3-0600 Millstone Unit 3 Discrepancy Report ATTACHMENT 1 Ite m 1 Synopsis The transient voltage and frequency dip information used in the calculation does not consider the effect of the steady state loading on the transient voltage and frequency dip, and the steady state load used as the basis of the curve of page 12 of Attachment D that is used to calculation the starting voltage dip is not stated. However, page 3 of Appendix B indicates that while 3600 kW of load are required to produce a 0.7% frequency j dip on an unloaded machine, only 1253 kW are required to q

produce the same frequency dip when the machine is carrying j 3766 kW of steady state load before the test load was added.

There is a similar variation in the voltage dip. (See the Electric Machinery Manufacturing Co. pamphlet "The ABC of Checking I Voltage Drop in Starting AC Motors') The calculation should I either take the steady state load at each step in the starting sequence into account or explicitly use bounding (worst case) values.

Disposition The CSKVA for each step is calculated in accordance with the l Colt /Fairbanks Morse Engineering Report contained in 1 Attachment C. If this report is reviewed, it will be e observed that pr:or loading on the machine is not included when .

c_nlenintinn thm OWVA fnr anch land etan i

The load and frequency dip information is taken farm test reports j supplied by the vendor and can be assumed to be valid. l Modeling a diesel generator for evaluation against transient load changes is extremely complex. However, it is quite conceivable that a frequency drop of 0.7Hz (not % as noted in the discrepancy) could occur under the test conditions used.

Because the engine is not linear in terms of the energy input versus the energy output over it's engine load carrying capability range, the change in fuel required to carry a load from no load to 1000kW at rated speed is smaller than that required to go from 4000kW to 5000kW. In tum, the overall govemor response to step load changes is longer as the machine carries more steady state load since,1) it requires more time to resolve error signals created by the controller feedback circuitry and,2) the amount of fuel rack movement is greater.

Based on the above, this item is not considered a discrepancy.

Item 2 Synopsis Appendix D calculates the per unit peak input power to the component cooling water pump to reduce the calculated peak power demanded from the diesel engine and generator. The peak power is calculated from the output torque and speed, as Printed N17/96 2:18:58 PM Page 7 of 16

f N:rthe:st Utilitica ICAVP DR N . DR-MP3-0600 Millstone Unit 3 Discrepancy Report well as the motor efficiency. The implied assumption is made that the motor efficiency at breakdown conditions is the same as during steady state fullload operation. However, the motor current at breakdown torque conditions is much higher than l during full load operation. This implies higher copper losses, and l therefore lower efficiency. This can be seen by examining the l calculated data for a two pole,700 hp,4000 volt motor:

I l

Disposition Because no data on motor efficiency was available at breakdown I torque, full load efficiency was used. Although stator losses are l Increased under these conditions, it is important to note that rotor l

Windage losses are less than rated since the motor has not achieved rated speed. The motor vendor has been contacted to see it efficiency data at breakdown torque is available. If it is not, it can be demonstrated that an assumed efficiency of approximately 0.87 will yield acceptable peak power values.

Based on the above, this item is considered a minor discrepancy and shall be rectified with the next calculation revision. This item is being tracked to closure by the corrective actions  ;

associated with CR M3-97-4634. i I

Break Down Full Load ,

Speed 3456 RPM 3582 RPM {'

l Torque 2644 ft Ibf 70t ft Ibf l Current 305 amp 58 amp

'";;^r 92T 0.?02 0.???

Efficiency 0.875 0.945 The effect of the increased transient loading should be examined, q i

! Item 3 {

Synopsis  ;

1 Page 13 indicates that an assumed power factor of 0.85 will be applied to non-motor loads. However, the heater loads, which have unity power factor are added arithmetically to the kVA of other non-motor loads. As a result, the 0.85 power factor will be applied to the heater loads. This will reduce their kW loading by a multiplier of 0.85, which is not conservative.

Disposition The power factor of 0.85 lag. is a composite power factor used to represent all non-motor loads including heaters, battery chargers, inverters, lighting transformers etc. that have various input power factors. The use of this power factor is explained in assumption 4.8.

Based on the above, this item is not considered a discrepancy.

Item 4 Synopsis Printed N17/98 2:18:59 PM Page 8 of iS t j

1 N::rthe:st Utilitiea ICAVP DR No. DR-MP3-0600 Millstone Unit 3 Discrepancy Report l l

The running kVA of the motor control center loads is determined l based on typical efficiencies and power factors with different l

values being used for loads larger that 50 hp and for loads 50 hp and smaller. However, the starting kVA is calculated using a single assumed conversion factor of 1 hp = 1 kVA. This is consistent. (The assumed efficiency and power factor values give a conversion factor of 1 hp=0.921 kVA for loads larger than 50 hp, ihp = 0.9973 kVA for continuously running loads 50 hp and smaller, and 1 hp = 1.5224 kVA for motor operated valves.)

Disposition The starting kVA for non-MOV motors is conservatively calculated using 1HP = ikVA. If the assumed power factors and efficiencies are used, less SkVA will be calculated and therefore a smaller voltage drop observed. MOV SkVA is calculated using locked rotor data. Non-MOV and MOV SkVA are then conservatively added arithmetically, since starting power factor is unknown. I Based on the above, this item is not considered a discrepancy, item 5 Synopsis Information about the brake powers of the various loads are given in more than one part of the calculation, e.g. Attachment B and Attachment E. Examples of these inconsistencies include ,

tha hrnka nnwar given fnr the original Imneller of 3CCP*P1 A in {

Attachment B and the brake power given for the cut down l impeller in Attachment E, the input power for 3HVK*CHL1 A on i page 41 of Attachment B and the brake horsepower and efficiency give in Attachment E, and the values for motor full load current of 3HVR*FN6A-B given in the motor data sheet of page 47 and the test report on page 49 of Attachment B. Some of this information is inconsistent. Some information should be provided as to which of the conflicting information is valid and why.

Disposition Appendix E reflects the revised figures as determined by Mechanical Engineering. Some of the information in Appendix B has been superseded. During the next calculation revision, documents containing old/ outdated values of BHP etc. will be either removed or designated as information only. This item is being tracked to closure by CR M3-97-4635.

Item 6 Synopsis 1

Some of the motor data pages 17 and 18 and the corresponding data on page 4 of Attachment A are inconsistent:

Printed 4/17/98 2:19:00 PM Page 9 of 16

I i

Ncrthe:Et Utilities ICAVP DR N2. DR-MP3-0500 Millstone Unit 3 Discrepancy Report l

l l

Load / Quantity /Value from Pages 17 and 18/Pages 4 of I Attachment A 3HVR*FN10A1&2 Power Factor 0.85/0.82 {

l 3HVC*ACU2A Bhp 75/70 3HVR*FN6A Efficiency 0.928/0.902  ;

l In addition to the difference in the efficiency of the motor for 3HVR*FN6A noted above, its efficiency is shown as 0.928 on

page 9 of Attachment E and as 0.902 on page 47 of Attachment l l B. l

! 1 Disposition l This information is minor in nature and does not affect the final outcome of the calculation. However, it will be resolved during the next calculation revision. This item is being tracked to I l closure by CR M3-97-4635.

l llem 7 Synopsis Appendix A, p[ age 22 states that the ' nominal level at which the RHR pumps auto trip and Si sump switchover" occurs is 25.42',

l corresponding to 619,910 gallons of water remaining in the l RWST. However, on page 23 of Appendix A, the calculation of the volume of water remaining in the tank at the time that the RHR pump trins is 479 005 gallnns This incranses the inngth cf time that the RHR pump is assumed to operate.

Disposition

)

Pages 22-25 of Appendix A are inconsistent in determining the l

length of time that the RHR and QSS pumps are in operation, although the final result (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) will be unchanged due to margin. Page 22 notes the nominallevel at which RHR pumps auto trip as 519,910 gallons (note that the DR author incorrectly l stated this as 619,910). The calc incorrectly operating times for the RHR and QSS pumps less than those used in the calculation, therefore the calc remains conservative and this l error has no affect upon the outcome.

l Note: US(B)-295 is now at revision 6 and these levels for switchover will be reviewed to this revision as part of the corrective action.

Recommended Corrective Action: Make corrections to pages 22-25 using the correct RWST levels. Verify that 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for RHR and QSS pump operation is still a conservative assumption, based upon Revision 6 of US(B)-295. These items are being tracked to closure by CR M3-97-4635.

Item 8 Printed 4/17/98 2:19:00 PM Page 10 of 16 l

1 1

N:rthe:ct Utilitie3 ICAVP DR Ns. DR-MP3-0500 Millstone Unit 3 Discrepancy Report l Synopsis i l

Statement 8 on page 9 of Appendix A states that one of the two RSS pumps will be shut down 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into the accident and 2 l hours before the residual heat removal pump is started in the l case of a large secondary system break. However, the input l data given on page 43 of Appendix A states that both RSS l pumps will operate until the residual heat removal pump is i started. The difference should be explained. )

i Disposition Attachment A,

• Emergency Diesel Generator Loading *, page 43 l contains conflicting statements. Paragraph 2 states that one j RSS pump is secured after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before RHR is l initiated). Item 8 recommends assuming that two RSS pumps are run until RHR is initiated. Page 10 (Table 6) which presents the motorloads, shows one RSS pump being secured at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> i which agrees with paragraph 2 on page 43. This also agrees l with page 9 of Appendix A,' Description of Long Term Engine Operation During an Accident

• Recommended Corrective Action: Delete the statement in item J 8 on page 43 of Attachment A which implies that 2 RSS pumps 1 are to be assumed to operate until RHR is initiated. This item is I being tracked to closure by CR M3-97-4635.

Item 9 l Synoosis Appendix A states that during a small break in a feedwater or i main steam line that a bank pressurized heaters and the spent fuel cooling pump will be energized manually early in the event (typically 11 minutes after the beginning). However, page 7 of Attachment A (Table 3) indicates that these loads are started after the safety injection and residual heat removal pumps have l been tumed off. Appendix A states that this will happen 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the beginning of the event. This difference should be explained.

Disposition Page 7 (Table 3) of Attachment A is the order in which equipment will be started in accordance with the EOPs.

Appendix A describes design basis information for all scenarios.

Page 8 (Table 4) of Appendix A describes design basis information for a small break secondary accident and is modeled after Appendix A. Both design basis and EOP, order / loading information is shown in this appendix so it can be demonstrated that the EOP order / loading of the EDGs is within the design basis criteria.

Based on the above, this item is not considered a discrepancy.

Printed 4/17/96 2:19:01 PM Page 11 of 16

ICAVP DR No. DR-MP3-0500 N:rthe=t Utilities Millstone Unit 3 Discrepancy Report .

Item 10 Synopsis On page 9 of Attachment A (Table 5) for a large break in a feedwater or main steam line, Motor Control Center 3EHS*MCC1 A3 is shown as starting after a residual heat removal pump is shut down. Appendix A states that the residual heat removal pump will be shut down about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the event begins and that the motor control center will be connected about 20 minutes after the event starts. Also, Table 4 shows that a service water pump is shut down, while Appendix A indicates that they are operated for the duration of the accident. Table 5 shows that the pressurizer heater group is energized much later than does Appendix A. Table 5 shows the fuel building exhaust fan and filter starting late in the he event, while Appendix A' indicates that they are started about i hour after the start of the event. These differences should be explained.

Disposition Page 9 (Table 5) of Attachment A is the order in which equipment will be started in accordance with the EOPs.

Appendix A describes design basis information for all scenarios.

Page 10 (Table 6) of Appendix A describes design basis information for a large break secondary accident and is modeled after Appendix A. Both design basis and EOP, order / loading information is shown in this appendix so it can be demonstrated that the EOP order / loading of the EDGs is within the design basis criteria.

Based on the above, this item is not considered a discrepancy.

Item 11 Synopsis Page 11 of Attachment A shows the spent fuel pump and Motor Control Center 2EHGS*MCC1 A3 starting at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the start of a small break LOCA event. They would be expected to start sooner based on the Generated 12/4/97 8:45:16 AM information in Appendix A.

)

Page 11 (Table 7) of Attachment A is the order in which equipment will be started in accordance with EOPs. Appendix A describes design basis information for all scenarios. Page 12 (Table 8) of Appendix A describes design basis information for a small break primary accident and is modeled after Appendix A.

Both design basis and EOP, order / loading information is shown in this appendix so it can be demonstratM that the EOP order / loading of the EDGs is within the design basis criteria.

1 Based on the above, this item is not considered a discrepancy.

Item 12 Synopsis Printed 4/17/96 2:19.02 PM Page 12 of 16 L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

l 1

ICAVP DR N2. DR-MP3-0600 N:rthea2t Utilities Millstone Unit 3 Discrepancy Report I

l Pages 13 and 14 of Attachment A (Tables 9 and 10) show Motor l Control Center 2EHS*MCC1 A3 energized 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the beginning of a large break LOCA. The motor control center would be expected to be energized sooner (See the discussion in Attachment A.)

Disposition Pages 13 and 14 (Table 9 & 10) of Attachment A describe the 1 l

existing and proposed EOP order in which equipment will be started. Appendix A describes design basis information for all i scenarios. Page 15 (Table 11) of Appendix A describes design basis information for a large break primary accident and is modeled after Appendix A. Both design basis and EOP, over/ loading information is shown in this appendix so it can be demonstrated that the EOP order / loading of the EDGs is within the design basis criteria.

Based on the he above, this item is not W"Ored a discrepancy.

Item 13 Synopsis Page 17 of the calculation gives the runout brake power of 3SlH*P1 A as 440 hp. However, the pump curve of Attachment B, page 12 shews a brake power no larger than 420 or 430 hp.

For the purposed of this calculation the result is conservative.

Page 17 of the calculation also gives the flow rate of the comoonent coolina pump. 3CCP*P1 A/C as 9600 apm, while the memorandum that is page 14 of attachment B indicates that the flow is 10910 gpm. Using the latter value increases the brake power of the motor to 745 hp as shown on page 16 of Attachment B.

Disposition The Table on page 17 " Safety Related Pump Table", assembles the BHPs for each pump at normal operation, run out and q shutoff. A note above the table makes the following statement 4

" .. the motor efficiency references and pump performance 1 references are contained in Attachment B. Operating point )

calculations are not included, however the BHP at SA, P and R have been verified (See Attachment E)." The DR states that the ,

pump curve in Attachment B does not contain sufficient data to determine the BHP at runout. this is true, but memo GMB-90-R- ]

340 which is in Attachment E, specifies a BHP of 440 at runout.

Recommended Corrective Action: None, since a memo from I Mechanical Engineering specifies this value. Based on the above, this item is not considered a discrepancy [ discrepancy.

f ltem 14

( Synopsis l

The memorandum of Attachment B. Daae 19 indicated that PrWed N17/9e 2:19:03 PM Page 13 of 16 l J

ICAVP DR No. DR-MP3-0600 Nsrtheart Utilitica Millstone Unit 3 Discrepancy Report 3FWA*P1 A is described by pump test curve 37762. However, pump curve 37761 is attached to the calculation instead.

Dispusition Attachment B contains an IOC (page 19) which correctly states that the proper pump curves for the MDAFW pumps are 37761 &

37762. Pages 20 and 21 are pump curves but both pages are curve no. 37761 for pump 3FWA*P1 A. These pump curves are almost identical therefore duplicating one pump curve for both pumps did not affect the calculation results. The " runout' BHP is the same for both pumps and is specified in Engineering Memo PSM3-92-146, page 16 of Attachment E. The duplicated pump curve for pump A should be replaced with that for Pump B.

Recommended Corrective Action: Replace page 21 of Attachment B with Bingham Willamett Pump curve 37762 (See OIM-041-001C). This item is being tracked to closure by CR M3-97-4635.

The following table summarized the differences depicted in the discrepancies:

ATT. A PgJSkVA Deficiency Value Calculation Value I

10/1044 0.10s 0.15s 10/1491 0.15s 0.10s 11&12/1857 4.0% 5.0%

11&12/2578 7.0% 6.0% ,

12/3133 qunca 7.5%

nm 8.0%

o as

)

13&15/3133 7.5% 7.0%

13&15/790 neg. 0.3s Analysis of the above table indicates that with the exception of a few values, most of the recovery times are within 0.05s of each other. Because the SkVA curve is drawn on a grid that has vertical scale divisions of approximately 40 thousandths of an inch, it is somewhat difficult to determine whether or not a value is 0.1 or 0.15 etc.

The deficiency value of "7.0%" on pgs.11 & 12 for a SkVA of 2578, is incorrect. It is in fact 6.0% as stated in the calculation.

The deficiency value of "neg." on Pgs.13 and 15 for a SkVA of 790 is also incorrect. It is 0.is although the calculation uses 0.3s.

Since all of the recovery time and voltage drop values are far below the time stipulation in Reg.1.9, the outcome of the calculation remains unaffected.

Based on the above, this item is considered a minor discrepancy and shall be rectified with the next calculation revision. This item is being tracked to closure by CR M3-97-4635.

Item 16 Synopsis Printed 4/17/56 2:19:04 PM Page 14 of 16

l l

ICAVP DR N2. DR-MP3-0500 N rthert Utilities Millstone Unit 3 Discrepancy Report The reference for the brake power of 3HVC*ACU2A should be Memorandum GMB-90-134, not GMV90-13, as stated in the calculation.

Disposition The data was there in the electronic version but was outside the printable area.

Based on the above, this item is not considered a discrepancy.

1 Item 17 Synopsis l On Page 12 of Attachment A, the starting kVA values are crossed out for 3HVU*FN2A, but the rev! sed values were not copied in.

Disposition Attachment A was reviewed and the discrepancy as noted was not found. Appendix A was also reviewed in case " Appendix" was transcribed instead of " Attachment" but no discrepancies were found.

Based on the above, this item is not considered a discrepancy. l Item 18 Synopsis On page 33 of Appendix A, the Indicated addition gives a total loss of 2.589 kW for the small miscellaneous transformers, not 2.449 kW as shown. This is small compared to the total diesel loading.

Disposition l 2.589kW is the correct value. This information was taken form the previous revision and assumed to be correct. The outcome of the calculation remains unaffected.

Item 19 Synopsis The addition indicated on page 21 gives a value of the " Total Non-Motor Demand Loads' of 115.18 kVA, not 114.0 kVA as shown on page 22.

Disposition 115.18kVA is the correct value. The outcome of the calculation remains unaffected.

Page is of 16 Printed N17/98 2:19:04 PM

ICAVP DR Ns. DR-MP3-0500 N:rthe:st Utilities M1lIstone Unit 3 Discrepancy Report Based on the above, this item is considered a minor discrepancy and shall be rectified with the next calculation revision. this item is being tracked to closure by CR M3-97-4635.

Item 20 Synopsis The peak kW for step 4 on pages 5 and 6 of Appendix A is 1991= 2.2x800=3751 kW, not 3359kW as shown.

Disposition ,

The method used in the calculation is correct. Peak kW for this component is calculated in Appendix D. this is annotated with a note in the table.

Based on the above, this item is not considered a discrepancy.

Previously identified by NU? O Ye. (G) No Non Discrepent Condition?O Ye. (G) No Resolution Pending?O Ye. @ No Resolution Unresolved?O Ye. G No Review initiator: Wamer.l.

VT Lead: Neri, Anthony A O O em VT Mgt: schopfer, Don K IRC Chmn: singh, Anand K Date: 4/6/98 SL Comments: Issue 2, Motor behavior near breakdown torque:

NU states that "th; incict vender hcc been cent 2^'"d !c 500 F efficiency data at breakdown torque is available. If it is not, it cart be demonstrated that an assumed efficiency of approximately 0.87 will yield acceptable results." NU's response is satisfactcry.

However, it should be noted that the motor that we trAd as an example was selected because we had a complete set of data available for making a dynamic (transient stability) analysis. It was used as an illustration, but it may not be " typical" /Jata.

l l

l Printed 4/17/96 2:19:06 PM Page 16 of 16

i Nsrtheart Utilition ICAVP DR Ns. DR-MP3 4660 Millstone Unit 3 Discrepancy Report Review Group: Connguration DR RESOLUTION ACCEPTED Review Element: System Desagn ,,

Discipline: Electrical Design Discrepency Type: Drewing Om system /Precese: RsS g

NRC significance level:4 Date faxed to NU:

Date Published 11/9/97 Discrepancy: Drawings not in agreement

Description:

1. Several vented tray covers have been installed on control trays in contradiction to note 2 of drawing EE-34Q, Rev.13 which indices that that unless noted otherwise, all control tray l covers shall be flat. Potentially affected trays are: 3TC3030, .

I 3TC3040,3TC3050,3TC300P,

2. The Cable and Raceway Program (TSO2) indicates that tray 3TC3080,3TH3030, and 3TH3040 are 18 inch wide trays with vented covers. Tray location drawing EE-34Q Rev.13, depicts these as 18 inches wide. The field observed trays are 18 inches wide. Contrary to this, note 2 of the tray location drawing '

indicates all trays are to be 30 inches unless noted otherwise.

This note also indicates that control trays will have flat covers unless noted otherwise. No notation on the tray location drawing (EE-34Q) was identified to document this deviation.

3. The Cable and Raceway Program (TSO2) indicates that tray 3TC3050 has covers on top and bottom in the " Work in Progress" display. The tray cover location drawing (EE-34TE, Rev.2) does not indicate the added bottom cover nor are there any oumanumv cnanww uvuumanm io avu iiie uviivm vvvm.

4. Cable tray cover location drawing EE-34TE, Rev. 2 indicates ,

that trays 3TX310P,311P,312P, and 313P have covers top and bottom. This is irterpreted from Change Control Document (CCD) P-E 7366, which " split trays" 3TX300W,301W, and 302W adding the "P" numbers corresponding to the "W" trays which are shown with covers top and bottom The field observed tray has these covers. Contrary to this, the Cable and Raceway Program (TSO2) Indicates that this tray has no covers. Further, the CCD should be shown as affecting the tray cover location drawing (drawing has no CCDs).

5. Cable tray cover location drawing EE 34TE, Rev. 2 indicates that tray 3TX308N is not covered. The field observed tray does not have covers. Contrary to this, the Cable and Raceway Program (TSO2) indicates that this tray has one flat cover.

Review Vend invahd Needed Date initiator: Server, T. L B O O tor 2e/o7 1o/2s,87 VT Lead: Neri. Anthony A O O O VT Mgr: schopfer, Don K S O O 10/30/07 IRC Chmn: Singh, Anand K O O O 11/*S7 Date:

INVALID:

Printed N17/9611:22 22 AM Pepe 1 of 5

t ICAVP DR N3. DR-MP3 4550 N rtheast Utilities Millstone Unit 3 Discrepancy Report Date: 4/16/98 RESOLUTION INTIAL RESPONSE:

INITIAL RESPONSE:

Disposition:

NU has concluded that issues # 1,3,4 and 5 in Discrepancy Report, DR-MP3-0550, have identified conditions not previously discovered by NU which require correction.

I' issue #1 initially, the tray arrangement drawings had a dual purpose in providing a dimensional layout of the cable trays in various areas of MP3 buildings and ]

providing the mechanical protection requirements for these trays )

in accordance with the electrical installation specification 2400.000-350 (now SP-EE-076). As these requirements evolved and electrical separation became more of an issue, it became apparent that the arrangement drawings would be too crowded to show this information. E&DCR F-E-41151 was approved in 1985 to remove the tray cover mark numbers from the arrangement drawings and to use the tray identification drawings to document and track the electrical separation requirements for cable trays.

Later, E&DCR N-EC-03046 was approved to move this information to a separate series of drawings (i.e. EE-34TA thru 34TR). Parallel to this activity, the tray cover detail and cable wrap drawings (i.e. CE-54A, 54C, 540 & 54E) were approved to provide and expand on these installation requirements.

Tharafnrm the risulntlnne in tha nar arit trav cnver rnnuirements are tracked against the tray cover and detail drawings NOT the arrangement and identification drawings. However, to avoid any future confusion conceming tray covers, the note on the arrangement drawings that gives some generic tray cover guidelines shall be removed and replaced with a reference to the tray cover and installation drawings. Also, a generic note will be added to CE 540 to allow for the substitution of vented for flat covers on "C" and "X" service trays where cables transition to sleeves /ductlines/ openings, between vertical & horizontal trays, or tray overfill occurs since both types of covers are equivalent per FSAR Table 1.8-1 R.G.1.75. (Ref. E&DCRs N-EC-01944 & 1 02459). l l

Issue #3 Drawing EE-34TE was reviewed for cable tray 3TC3050 and found to require a cover for the top of this tray, only. This tray was walked down in the field and found to have a top cover installed in accordance with the referenced drawing. A ,

bottom cover was not found to be installed on this tray.  !

Therefore, update the Cable and Raceway Program (TSO2) to change the tray cover quantity from "2" to "1" for 3TC3050 to agree with drawing EE-34TE and the field conditions.

Issue #4 Cable tray identification details W-X1 & R-X on drawing EE-34BE are to be revised by E&DCR P-E-07366 to show a dual identification for the cable trays within these details. Since the tray cover drawings are a take-off from the tray identification Printed N17/9811:2225 AM Page 2 of 5

N rthemt Utilities ICAVP DR No. DR-MP3-0650 Millstone Unit 3 Discrepancy Report drawings and the tray cover drawings were developed after this E&DCR was approved, drawing EE-34TE has been missed for this change. As a result, drawing EE-34TE needs to be reviseo .

to add the dual identifications for the trays within Details W X1 &

R X as shown on E&DCR P-E-07366.

Also, TSO2 was reviewed to ensure that covers are accounted for in the dual identified trays mentioned in E&DCR P-E-07366 in accordance with the tray cover drawings. Tray covers have been added to TSO2 for all but 6 dual identified trays mentioned in E&DCR P-E-07366 requiring covers. Therefore the following 6 trays need to be updated in TSO2 to add covers similar to their attemate trays listed in parenthesis: 3TX310P (3TX300W), j 3TX311 P (3TX301 W), 3TX312P (3TX302W), 3TX313P l (3TX303W),3TX3100 (3TX302R) and 3TX3130 (3TX313R).

!ssue #5 Drawing EE-34TE was reviewed for cable tray 3TX308N and found not to require either a top or bottom cover. This tray was walked down in the field and found not to have either cover installed, as well. As a result, update TSO2 to change the tray cover quantity from "1" to "None" and tray cover tyi a from "F" to "None" for 3TC308N to agree with drawing EE-34TE and the j field conditions.  !

Condition Report (CR) M3-97-4403 was written to provide the necessary corrective actions to resolve issue # 1,3,4 and 5.

Approved Corrective Action Plan (CAP)(attached) and DCN DM3- l 001955-97 were issued to correct the drawings and the Cable {

and Raceway Program (TSO2).

Since only drawings and Cable and Raceway Control Program (TSO2) revisions are required in this DR, NU considers this DR to be a Significance Level 4 issue. This is an administrative issue only and does not affect the Plants Design Basis.

NU also concluded that the issue # 2 in Discrepancy Report, DR-MP3-0550, does not represent a discrepancy condition.

Issue #2 Drawing EE 34Q was reviewed for cable trays identified l as O-H81 (both trays),0-L82, l O-C6, L12, C & X4 and found not to denote these trays with a mark number. Applying Note 2 on EE 34Q, gives one the impression that these trays are 30 inches wide. However, these i trays are installed as 18 inch wide trays and TSO2 agress with the field conditions. NOTE: E&DCR F-E-42140 reidentified tray C8 located at the east end of the north tunnel to 0-C (3TC3430) and changed it to a 12 inch wide tray (dad-01) at the same time.

The referenced E&DCR is posted against EE-34Q for this change. As a result, revise drawing EE-34Q to add the mark number for an 18 inch wide tray (dhf-01) adjacent to trays identified as O-H81 (both trays) O-L82,0-C6, L12, C & X4.

As stated in the resolution to item 1 on this DR, the tray arrangement drawings are NOT the drawing of record to provide tray cover guidelines and track deviations. Therefore drawing EE-34TE was reviewed for cable tray cover information on PrWed N17/9611:22 26 AM Page 3 of 5

Nertheast Utilitl2s ICAVP DR No. DR-MP3-0660 Millstone Unit 3 Discrepancy Report l

3TC3080 and found to depict top and bottom tray covers. Cable tray 3TC3080 was observed in the field to have a combination of flat and vented covers on the top and bottom. Therefore the l GRITS Database was reviewed for drawing EE 34TE, where l

E&DCR N-EC-02466 was retrieved because it provided for the substitution of a vented for a flat cover on the top and bottom of this tray. As a result, no drawing changes are required by this issue.

I Significance Level criteria do not apply as this issue does not l represent a discrepant condition.

j

Conclusion:

l NU has concluded that issues # 1,3,4 and 5 in Discrepancy i

Report, DR-MP3-0550, have identified conditions not previously discovered by NU which require correction. Condition Report (CR) M3-97-4403 was written to provide necessary corrective l actions to resolve there issues. Approved Corrective Action Plan (CAP)(attached) and DCN DM3-00-1955-97 were issued to correct the drawings and the Cable and Raceway Program (TSO2).

l l Since only drawings and Cable and Raceway Control Program l

(TSO2) revisions are required in this DR, NU considers this DR to be a Significance Level 4 issue. This is an administrative issue only and does not affect the Plants Design Basis.

NU has also concluded that the issue # 2 in Discrepancy Report, DR.MP3 n64n dnac nnt renramant a dicerenant enndition.

Design Engineering reviewed GRITS Database and verified the -

field condition and found no changes are required by this issue.

Significance Level criteria do not apply as this issue does not represent a discrepant condition.

SECOND RESPONSE:

Disposition:

NU has concluded that item #2 has identified a condition not previously discovered by NU which has beery corrected.

NU's response to item # 2, conceming the discrepancy between cable tray width dimensions indicated on Cable Tray Arrangement Drawings #EE-34Q and TSO2, should have been identified as a discrepant condition.

The response provided in IRF01005 (DR-00550) supports this conclusion by stating:"As a result, revise drawings EE-34Q to add mark number for an 18" wide tray (dhf-01)."

The approved Correction action plan for CR-M3-98-1458 documents correction of Drawina EE-34Q.

Printed 4/17/93112:27 AM Page 4 or 5

r j N:rtheast Utilitir.s ICAVP DR No. DR-MP3-0550 i Millstone Unit 3 Discrepancy Report l

Conclusion:

1 NU has concluded that item #2 has identified a condition not I previously discovered by NU which has been corrected. '

The discrepancy between cable tray width dimensions indicated on Cable Tray Arrangement Drawing #EE-34Q and TSO2 has been corrected by CR M3-98-1458.

Previously identified by NU? O vos @ No Non Discrepent Condstion?U vos (G) No ResolutionPending?O va @ No RuduuonUnrudved?O vos @ so Review initiator: Wamer, l.

VT Lead: Nort. Anthony A O O *=

VT Mgt schopfer, Don K O O *m IRC Chmn: singh, Anand K Date: 4/16/98 l sL Comnents: INITIAL COMMENT:

Item 2 described a condition where, because there was no identification otherwise, a general note on the drawing required that a tray shall be 30 inches wide. The Cable and Raceway Control Program (TSO2) was in agreement with the installed conditions, however the drawing (EE-340), a valid design document describing the designed condition, was not consistent with the installed condition or TSO2. Further, the response indiwies a diawing correction io iaenmy me tray wnn a marx number indicating that it is 18 inches wide - not the 30 inches as required by the note - is necessary. Therefore, it appears that item 2 was indeed a discrepant condition not previously identified by NU that required correction regardless of conclusions to the contrary i

COMMENTS ON NU'S SECOND RESPONSE:

We have no comments on NU's second response.

1 i

i l

l l

Printed N17/9611:22:28 AM Page 5 of 5 a

ICAVP DR No. DR-MP3-0566 N:rthe:st Utilitie3 Miiistone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED

• Potential Operabihty issue Discipiirn: Mechanical Design Ow D4screpancy Type: Installation Requirernents g System / Process: HVX NRC Significance level: 4 Date Faxed to NU:

Date Published: 11/22/97 Discrepancy: Auxiliary Building Ventilation Ductwork Classification

Description:

During review of the Auxiliary Building Ventilation System a discrepancy in the classification for the ductwork between the missile hood on the auxiliary building roof and the ventilation vent on the turbine building roof was identified.

Specification SP-ME-576 specifies non-QA non-seismic duct construction for the 10 ft by 10 ft duct from the auxiliary building roof to the ventilation vent.

Specification 2170.430-565 specifies QA category 11 non-seismic duct construction for the 10 ft by 10 ft duct from the auxiliary building roof to the ventilation vent.

Attachment 1 of NU letter B11392 dated December 6,1984 from W. G. Council to B. J. Youngblood states "The ventilation ductwork associated with safety related portions of the Auxiliary Building Ventilation System is seismically qualified. This ductwork runs through the auxiliary building outside to the turbine building where it attaches to the turbine building vent ,

stack which is not seismically qualified." f i

Per FSAR Section 9.4.3.2 the plant ventilation vent is the release point for all ventilation exhaust air from the auxiliary, waste disposal, and fuel buildings, the containment structure, and contaminated portions of the service building. The i l

ventilation vent effluent point of release is at elevation 157 feet.

Per FSAR Section 6.2.3, the auxiliary building filtration units discharge to the environment via the ventilation vent on the roof of the turbine building.

Per FSAR Section 9.4.3.2, in the event of a SIS, the auxiliary building ventilation filter exhaust fans vent through the ventilation vent after filtration Per FSAR Section 6.5.1 the charging pump, component cooling water pump, and heat exchanger exhuast ventilation system is classified as an ESF filter system.

Per FSAR Table 3.21 and Section 9.4.3.1 the auxiliary building exhaust filtration system is ANS Safety Class 3 Per FSAR Section 9.4.3.3, the charging pump, reactor plant component cooling water pump, and heat exchanger ventilation and the filtration units including their fans are QA and Seismic Category 1.

Printed N17/961:02.56 PM Page 1 of 4

l )

l

)

l N::rtheast UtilitiIs ICAVP DR N3. DR-MP3-0566 l

Millstone Unit 3 Discrepancy Report Per FSAR Section 3.1.2.64, after a postulated accident, the safety related ventilation vent high range monitors and the safety related Millstone 1 stack monitors are used to monitor the j effluents from spa ^es contiguous to the containment structure. J Review Valid Inval6d Needed Date l

Initiator: stout, M. D. G O O 10/31/97 VT Lead: Nort, Anthony A B O O 11/4S7 l VT Mgt: schopfer, Don K G O O 11/10/S7 IRC Chmn: singh. Anand K O O O 1/1SS7 Date:

INVALID:

l Date: 4/15/98 RESOLUTION: First Response NU has concluded that Discrepancy Report, DR-MP3-0566, does not represent a discrepant condition. NU has reviewed the ]

referenced specifications and FSAR statements and determined that they are in agreement and correct.

~

We have concluded that there mEy be confusion with respect to '

the wording within NU letter B11392, specifically the relationship i between the two quoted sentences. The first seritence describes l that all ductwork associated with safety related portions of the Auxiliary Building Ventilation System is seismically qualified.

This is a true statement and the FSAR and specifications support  ;

It. The second sentence needs to be disassociated from the first i as it desc,ibes the enti.e run cf ductwc,-k which spans from the Auxiliary Building to the Turbine Bu'ilding ventilation stack and correctly states that it (the ventilation stack) is not seismically qualified. The specifications are more detailed in this respect and  ;

show that the associated ductwork between the Auxiliary Building l Roof and the ventilation stack are also Non-QA, Non-Seismic. In additon calculation 12179 NP(B) 334-ZD demonstrated (with various failure mechanisms) that a failure of the frame during an earthquake will result in an open, unblocked ventilation area. The calculation concludes that reclassification of this structure to a non-seismic category is acceptable. See the interoffice memo on page F2 of calculation 12179 NP(B) 334-ZD attached.

Significance Level criteria do not apply as this is not a discrepant condition.

l Attachments:

, Calculation 12179 NP(B) Z525A-001 Calculation 12179 NP(B) 334-ZD l Second Response NU has concluded that the issue reported in Discrepancy Report DR-MP3-0566 does not represent a discrepant condition.

The intended definition of " ultimate point of release" is Prir.ted 4/17/981:02:s0 PM Page 2 of 4 l

I l

ICAVP DR No. DR-MP3-0566 Nnrtheait Utilities Millstone Unit 3 Discrepancy Report i

I atmosphere, because FSAR section 15.6.5.4, Radiological Consequences, states:"The nuclides which become airbome are collected and released to the environment through the auxiliary building ventilation system HEPA and charcoal filtration units.

The releases are from above the turbine building, but are analyzed as ground level releases." There is no design requirement for the crossover duct to meet seismic requirements. (See specification SP-ME-576, page 218. Note that the memo referred to above, July 25,1984, from M. ,

Scanlon, is in error. A memo is not a Change Control Document {

and does not countermand specification requirements, or any l I

other design basis document). The approved correctiive action plan to CR M3-98-0872 will revise FSAR and DBS statements to clarify the ultimate point of release during an earthquake. AR 98003394-02 (copy attached) requires FSAR sec.15.6.5.4 l Containment Leakage Pathways be revised to include discussion l of this filtered ground / roof level release being bounded by the /

Turbine Bldg. vent stack dose analysis. A full LIST search will also identify any other statements in the FSAR that need to be j reviewed for consistency on this issue. Calculation NP(B)-334- 1 ZD, as stated in M3-lRF-01157, demonstrates that a failure of f

~

the frame during an earthquake will result in a sufficiently open l

unblocked ventilation area to support system operation.

Corrective action will be completed post startup.

The configuration of the ABVS exhaust duct is in compliance l with MP3 design basis / licensing basis. Since use of the term

" point of release

• is subject to misinterpretation, this term will be I clearly defined in those FSAR/DBS statements in which it is used l ee exp!eMad ehave.

I Since this issue is non-discrepant, Significance Level Criteria do i not apply Attachments:

CR M3-98-0872 with approved corrective action plan l AR 98003394-02

' Previously Identined by NU? U Yes (#) No NonDiscrepantcondition?Q Yes (*) Nc Resolution Pending?O Yee @ No Resolution Unresolved?O Yes @ No Review Acceptable Not Acceptable Needed Date initiator: stout, M. D.

VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K O O Dete: 4/15/98 SL comments: Comments on First Response NU's response does not fully address the issues identified in the DR regarding the classification of the auxiliary building ventilation ductwork between the missile hood and the ventilation vent.

FSAR Section 6.2.3 and 9.4.3.2 state that the auxiliary building Printed 4/17/961:03:01 PM Page 3 of 4

I l

N:rtheart Utilities ICAVP DR N3. DR-MP3-0666 Millstone Unit 3 Discrepancy Report filter exhaust fans discharge to the environment via the ventilation vent on the roof of the turbine building. FSAR Section 6.5.1 classifies the auxiliary building filter exhaust system as an ESF filter system and FSAR Table 6.5-1 states that the ductwork design and construction is in accordance with Reg. Guide 1.52 Rev. 2 position C.3.n. Reg. Guide 1.52, Rev. 2 position C.3.n requires the duct to be designed and constructed in accordance with ANSI N509-1976. ANSI N509-1976 section 5.10.1 requires the duct system to be designed and constructed to meet the  ;

structural and pressure loadings and leak-tightness requirements 1 of Section 4, while transporting a possible contaminated air or gas stream from the point (s) of collection to the point (s) of ultimate release. Seismic forces are one of the structuralloading items I identified in ANSI N509-1976 section 5.10.3 on structural l requirements. Since the auxiliary building filter exhaust system uses the ductwork between the missile hood on the roof of the auxiliary building and the ventilation vent the duct should be seismically designed and maintain its leak-tightness during  ;

l accident conditions. Calculation NP(B)-334-ZD concludes that during a seismic event the flex connection for the 10 ft x 10 ft l duct would rip which results in the leak-tightness of the duct being lost.

Interoffice Memorandum 'QA and Seismic Qualification of 10 ft. x 10 ft. Duct and Truss', dated July 25,1984 from M. Scanlon; states "ductwork upstream of the flexible connection is seismic and QA Category I"'. This does not agree with Specification SP-ME-576 pg 2-18. The specification does specify seismic medium pressure - low leakage (SM-LL) construction for the ductwork gnetrggm nf the flov ennngefinn hut rince nnt eneifv sa O A category for the roof ducts discharging to turbine building vent stack.

Based on the FSAR and Reg. Guide 1.52 requirements identified )

above and the 12/6/84 letter which states that ductwork associated with the safety related portions of the auxiliary builidng ventilation system is seismically qualified, the auxiliary building ductwork between the missile hood and the ventilation vent should be classified as QA Category l Seismic Category I ductwork.

l Comments on Second Response This is considered a Level 4 discrepancy as FSAR Section 6.2.3 and 9.4.3.2, which state that the auxiliary building filter exhaust l l

fans discharge to the environment via the ventilation vent on the l

roof of the turbine building, will be revised as part of the l corrective action for CR M3-98-0872 to note that the ventilation l vent is not the discharge point following a seismic event.

1 Printed 4/17/981:03:03 PM Page 4 of 4 i

1 1

Northeast Utilities ICAVP DR N3. DR-MP3-0572 Mitistone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED '

Discipline: Mechanical Design PotentialOperabil6ty issue Discrepancy Type: Caculation Om System / Process: RsS 4 No NRC Significance level: 4 Date faxed to NU:

Date Published: 11/20S7 Discrepancy: FSAR Question Q410.5: Waming Time for RWST Overflow

Description:

In response to FSAR Question No. Q410.5, NU committed to providing a high RWST level alarm which would alarm 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before overflow at the maximum RWST fill rate.

There is no basis for this function in the QSS system calculations.

The only calculation which addresses this issue, Calculation 357P, Rev. 0 (page 10), states that the high level alarm would provide a 60-minute waming prior to RWST overflow. This calculation does not provide any documentation to support this ,

statement. The 60-minute overflow waming time is based on a

{

maximum fill rate of 228 gpm from the CHS and SFC systems. '

No reference for this fill rate is provided. The 60-minute overflow waming time implies that there is 13,680 gal of RWST volume between the high level alarm and the overflow level. No data is provided f or the elevation of the high level alarm setpoint, the maximum setpoint drift / error, or the elevation at which overflow would occur. No reference for tank volume as a function of elevation is provided.

A Calculation needs to be performed to determine the waming time for RWST overflow provided by the RWST high level alarm.

Review Valid invalid Needed Date initiator: Wakeland, J. F.

8 O O 11/1'/S7 VT Leed: Neri, Anthony A B O O 11/1 /S7 VT Mgr: schopfw, Don K B O O 11/17/S7 IRC Chmn: Singh, Anand K @ [ [ 11/17/97 Date:

INVALID:

Date: 4/16/98 RESOLtTDON: l FIRST RESPONSE: l l

DISPOSITION: )

NU has concluded that DR-MP3-0572 does not represent a  !

discrepant condition. The alarm 3QSS-LIS60 " Refueling Water Storage Tank Manual Make-up Start / Stop Overflow Alarms" performs the function of notifying the operations staff of potential overflow at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to occurance. The ability of this alarm to meet the commitment in FSAR Question Q410.5 can be a derived from Calculation 3-ENG-167 Rev.1. Utilizing the input Printed 4/17/9611:24:41 AM Page 1 of 4

N:rthe :tt Utilities ICAVP DR No. DR-MP3-0572 Millstone Unit 3 Discrepancy Report data to 3-ENG-167, it can be shown that, assuming 80 gpm l makeup to the RWST as prescribed in OP 3304C, the 3QSS-LIS60 alarm provides 2.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> notification prior to overflow.

The demonstrative calculations necessary to confirm the adequacy of this alarm are as follows:

Alarm Notice Calculations:

Inputs:

RWST Volume per inch = 1704.3 gal / Inch ( Page 8 of 3-ENG-167 ) = RV Tank Height based upon Tech Spec Maximum Volume = 59.02 ft (Page 8 of 3-ENG-167) 3QSS-LIS60 T/S Volume Uncertainty = 2.5 inches or 0.21 ft (Page 9 of 3-ENG 167)

RWST High Level Setpoint = 58.15 ft (Page 5 of 3-ENG-167)

Calculations:

Height Differential between 3QSS-LIS60 Hi Setpoint and Tank Overflow Tank height minus (RWST High Level Setpoint plus Volume Uncertainity) = delta H delta H = ( 59.02 ft - ( 58.15 ft + 0.21 ft )) = 0.66ft = 7.92 inches Volume ( V ) associated with height differential between tank overflow and RWST HI Level Alarm V = delta H ( RV ) = 7.92 inches ( 1704.3 gal / inch ) = 13,498.1 gal The normal Auto or Manual Makeup rate ( MUR ) to the RWST as prescribed in operations procedure OP 3304C Rev 18 is 80 gp- ( S:: Pagee 9 en 14 ef OP ??M C .^" ch-d ). Lh!!!9; th!:

makoup rate and the volume associated with height differential between tank overflow and RWST HI Level Alarm it is possible j to calculate the time differential (delta T) between alarm j annunciation and tank overflow. i delta T = V / MUR = 13,498.1 gal / 80 gpm = 168.7 minutes = l 2.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Summary:

The current MP3 RWST level indicating and alarm system  !

adequately addresses FSAR Question Q410.5. Aditionally, it should be noted that the flow path from the Spent Fuel Cooling system is through valve 3SFC-V49 which is locked closed at all times ( See Attached Locked Valve List page 51 ). Flow from the SFC system should not be considered during alarm 3QSS- ,

LIS60 assessment. I Significance level criteria does not apply as this is not a discrepant contition.

CONCLUSION: l l

NU has concluded that DR-MP3-0572 does not represent a discrepant condition. The alarm 3QSS-LIS60 " Refueling Water Storage Tank Manual Make-up Start / Stop Overflow Alarms" performs the function of notifyino the operations staff of potential Printed 4/17/9611:24:44 AM Page 2 of 4

3 Nerthecst Utilities ICAVP DR ND. DR-MP3-0672 Millstone Unit 3 Discrepancy Report overflow at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to occurance. The ability of this alarm to meet the commitment in FSAR Question Q410.5 can be derived from Calculation 3-ENG-167 Rev.1. Utilizing the input data to 3-ENG-167, it can be shown that, assuming 80 Opm makeup to the RWST as prescribed in OP 3304C, the SQSS-LiS60 alarm provides 2.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> notification prior to overflow. I Additionally, it should be noted that the flow path from the Spent Fuel Cooling system is through valve 3CFC-V49 which is locked closed at all times ( See Attached Locked Valve List page 51 ).

Flow from the SFC system should not be considered during i alarm SQSS-LIS60 assessment. '

Significance level criteria does not apply as this is not a discrepant contition.

I SECOND RESPONSE:

]

l DISPOSITION:

! I NU has concluded that Discrepancy Report DR-MP3-0572 has l identified a condition not previously discovered by NU which I requires correction. Condition Report ( CR ) M3-98-01731 ( See l Attached ) was written to provide the necessary corrective action  !

to resolve this issue. The corrective action to correct this issue l Is to CCN calculation 357P to incorporate the RWST Overflow l Alarm Notice Calculation. This corrective action is for

! comniatanau of documentation only and does not impact the MP3 LB / DB. NU considers DR-MP3-0572 to be a level 4 discrepancy. This corrective action will be completed post MP3 restart.

CONCLUSIONS:

NU has concluded that Discrepancy Report DR-MP3-0572 has identified a condition not previously discovered by NU which

! requires correction. The corrective action necessary to resolve the issue detailed in DR-MP3-0572 will be implemented and tracked under the auspices of condition report M3-98-1731 ( See Attached ). The corrective action outlined in Condition Report

M3-98-1731 necessary to correct this issue is to CCN calculation l 357P to incorporate the RWST Overflow Alarm Notice i l Calculation. This corrective action is for completeness of documentation only and does not impact the MP3 LB / DB. NU considers DR-MP3-0572 to be a level 4 discrepancy. This corrective action will be performed Post MP3 Startup. j Previously identmed by NU7 U Yes @ No Non Diecrepent Condluon?O Yes @ No l nosoiunon Pendino70 Y= @ No P%Untmolved?O Ya @ No

n. view initiator: Waketend, J. F.

O O **

VT Lead: Nerl, Anthony A Printed 4/17/9611:24 45 AM Pope 3 of 4

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ICAVP DR N3. DR-MP3-0672 1 Ntithenst Utilitie3 Millstone Unit 3 Discrepancy Report

n. r- i, m ,m , n {

vi Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K g

O O -

Date: 4/16/98 sL Comments:

FIRST RESPONSE: l I

Sargent & Lundy concludes that DR-MP3-0572 is a discrepant j condition. There is no documented basis for the response to )

FSAR Question Q410.5. This response is part of the Millstone

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Unit 3 licensing basis. Therefore a documented basis is required. l Because NU's evaluation in M3-IRF-01444 concludes that the Millstone Unit 3 would meet the FSAR Q410.5 requirement, DR- j MP3-0572 is an NRC Significance Level 4 discrepancy and i revising calculation 357P, or issuing a calculation change notice l l

to 357P may be deferred until after Unit 3 restart. l

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SECOND RESPONSE: l l

NU's second response to DR-MP3-0572 correctly addresses all of Sargent & Lundy's comments on NU's first response to DR-MP3-0582.

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Printed N17/981124:47 AM Page 4 of 4

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N:rthentt Utilities ICAVP DR No. DR-MP3-0675 l

Millstone Unit 3 Discrepancy Report l

Review Group: System DR RESOLUTION ACCEPTED Reh EW. S%em W Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Component Data Ow System / Process: HVX

$ No l NRC Significance level: 4 Date faxed to NU:

Date Published: 11/15/97 Discrepancy: Auxiliary Building Filter Unit Charcoal Adsorber Face Velocity

Description:

During review of the auxiliary building ventilation system (ABVS) exhaust filter units 3HVR*FLT1 A/1B a discrepancy regarding the face velocity, residence time, and efficiency was identified.

FSAR Table 1.8-1 Regulatory Guide 1.52, Rev. 2 position C.3.1 exception states that the dwell time for the minimum 2 inches of the carbon adsorber unit is 0.21 sec. All filters use a 4-inch thick charcoal bed. Testing of the charcoal is based on a maximum face velocity of 46 fpm.

FSAR Table 1.8-1 Regulatory Guide 1.52, Rev. 2 position C.6.a exception states that the activated carbon adsorber section has a 4 inch bed and operating face velocity of 47 fpm (0.43 sec residence time). Table 2 of RG 1.52, Rev. 2 assigns a 95%

decontamination efficiency for activated carbon sample having a methyl lodide penetration of less than 1%. It will be verified that within 31 days after removal, a 4 inch laboratory sample from the installed sample canisters will demonstrate a removal efficiency of 99% for methyllodide when tested in accordance with ANSI N510-1980.

FSAR Section 9.4.3.2 states that the charcoal adsorber is designed for a 0.21-second dwell time per 2-inch depth for gases at a flow velocity of 47 fpm. Four-inch depth of charcoal is provided. The impregnated charcoal is capable of removing in excess of 99 percent of methyllodide and 99.5% of elemental lodine.

Technical Spection Section 4.7.9 requires that a laboratory analysis of a representative carbon sample meets the laboratory testing criteria of Regulatory Position C.S.a of Regulatory Guide 1.52, Revision 2, for a methyl lodide penetration of less than 0.175 %.

Specification 2170.430-065 Charcoal Adsorber Cells Design and Construction section states that the auxiliary building filters have a face velocity of 46 fpm and a minimum residence time of 0.22 sec. per 2 in of bed thichness. The bed depth shall be a nominal 4 in. thickness.

l The laboratory test acceptance criteria shown in FSAR Table 1.8-1 and Technical Specification Section 4.7.9 do not agree with j each other. j Review I

Valid invalid Needed Date i001#07 l JDill*'" h d M fi i Printed 4/17/981:05:07 P.*2 Page 1 of 3 i

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1 Nsrtheast Utiliti::s ICAVP DR No. DR-MP3-0575 Millstone unit 3 Discrepancy Report initietor: stout. M. o. O O O tcv2ii97 VT Lead: Neri, Anthony A 8 O O 11/357 VT Mgt; schopfer, Don K G O O 11/5/87 NtC Chmn: singh, Anand K O O O 11/1 /87 Date:

mvAuo:

Date: 4/13/98 RESOLUTION First Response NU has concluded that Discrepancy Report, DR MP3-0575, has I

identified a condition previously discovered by NU which requires correction. The first question of this DR, relating to the velocity of the air entering the filters, is addressed in complete detailin UIR 1005. The UIR Closure Request details the changes required to correct those items that are the subject of l

the DR. FSARCR 97 MP3-531 implements those changes. The l corrective actions are in process and will be completed prior to I

startup.The second question relates to the efficiency and the test acceptance criteria for charcoal. The FSAR and the Tech Specs are consistent with the Reg. Guide 1.52 Table 2. A rating of 99%

i efficiency is assigned when a sample tests to <0.175%

j penetration. The FSAR discusses the efficiency rating of 99% of l methyliodide and 99.5% of the elementaliodine. Tech Specs specifies the testing method and acceptance criteria. Field work is not required.

Attachments:

Tccr..-Jcc: Opcencet!= Srec!!!=cc Rc';9cmrt ' '.9 l UIR1005 Closure Request l Engineering Evaluation M3-EV 970224 Rev 0

FSARCR 97 MP3-531 Specification 2170.430-065, Special Filter Assemblies, page 1-21 Regulatory Guide 1.52 pages 1.52-6 and 1.52-7 ,

1 Second Response NU has concluded that Discrepancy Repri DR-MP3-0575 has identified a condition not previously discovered by NU which j requires correction.

l l S&L is correct in stating that the laboratory acceptance tests stated in FSAR Table 1.8-1 and Technical Specification section 4.7.9 do not agree. NU has generated CR M3-98-0923 to address this inconsistency. The approved corrective action plan for the CR requires evaluation and revision of FSAR Table 1.8-1,as it addresses RG 1.52, Paragraph C.6.a/b, to agree with Table 2 of RG 1.52 for a methyl iodide penetration of less than 0.175%. Since the Technical Specification section 4.7.9 references Table 2 of RG 1.52 for a methyl iodide penetration of less than 0.175%, the Technical Specification is more conservative than the FSAR. Therefore, the licensing / design basis is not affected. This corrective action will be completed post startup.

Printed 4/17/981:05:10 PM Page 2 of 3

l ICAVP DR No. DR-MP3-0575 N::rtheast Utilities Millstone Unit 3 Discrepancy Report As agreed in our meeting of 2/10/98, this issue is reclassified to Significance Level 4.

Attachments:

CR M3-98-0923 with approved corrective action plan.

Previously identified by NU? O Yes (#) No Non Discreperd Condition?O Yes (#) No Resolution Pending?O vee @ No ResolutionUnresolved?O vee @ No Review initiator: stout, M. D.

O O **

VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K l Date: 4/13/98 sL corrvnents: Comments on First Response Agree with NU's response that the charcoal adsorber face velocity discrepancy was previously identified by NU.

! Disagree however with NU's response regarding the charcoal laboratory test acceptance criteria. The 1% methyl lodide i penetration stated in the FSAR is assigned a 95% efficiency in Table 2 of RG 1.52. The 0.175% methyl iodide penetration stated in the Technical Specification is assigned a 99% efficiency in Table 2 of RG 1.52. Therefore, the Technical Specification and FSAR acceptance criteria do not agree. This is considered a Level 4 discrepancy as the Technical Specification acceptance criteria is more stringent than that identified in the FSAR.

Comments on Second Response i None l

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ICAVP DR N3. DR-MP3-0616 l N rthe st Utilities Millstone Unit 3 Dit.crepancy Report Review Group: System DR RESOLUTK)N ACCEPTED Review Element: System Design p Discipline: Mechan 6 cal Design Om Discrepancy Type: Licensing Document g System / Process: RSs NRC Significance level: 4 Date FAXeri to NU:

Date Published: 11/15/97 j Discrepancy: RSS Pump Actuation Time in Design Basis Summary Document

Description:

3DBS-NSS-003, Rev. O states that in a LOP event, the RSS pumps will be energized from the EDG load sequencer in no more than 19 seconds.

The discrepancy is that a 19-second actuation time is not consistent with the design basis of the RSS system:

1. According to LSK-24-9.4A, the emergency generator load sequencer delays the start of RSS pumps A and B 650 seconds after receipt of CDA signal and delays the start of RSS pumps C and D 660 seconds after receipt of CDA signal. The load sequencer delays start of the RSS pumps to allow an adequate supply of water to accumulate in the containment sump. l l

2. According to TS Surveillance Requirement 4.6.2.2.c, the l maximum allowable error in the emergency diesel sequencer timer for RSS is 20 seconds.

3. According to Attachment B to US(B)-253," Documentation of l LOCTIC Data Deck for Millstone Unit #3 LOCA Analysis," the maximum iime icyuh eu ivi ilm e6ieisenCi dlooel g; ,;;;t07 l0 start, come up to speed and connect to the essential bus is 14.0 l

seconds.

Therefore the maximum actulation time for RSS pumps A and B is 684 seconds (650 sec + 20 sec + 14 sec). For RSS pumps C and D lt is 694 seconds (660 sec + 20 sec + 14 sec).

Review Valid invalid Needed Date initiator: Wakeland, J. F. G O O 11/2/97 VT Lead: Neri, Anthony A O O O 11/3/S7 VT Mgr: Schopfer, Don K 8 0 0 11/8/S7 1RC Chmn: Singh, Anand K S O O 11'11'S7 D.te:

INVAUD:

Date: 4/16/98 RESOLUTION:

FIRST RESPONSE:

DISPOSITION:

NU has concluded that the issue reported in Discropancy Report, DR-MP3-0616, does not represent a discrepant condition. This is Printed 4/17/9811:26:01 AM Page 1 of 5

l N::rthenct Utilities ICAVP DR ND. DR-MP3-0616 l

Millstone unit 3 Discrepancy Report '

based on the following discussion:

RSS pump actuation times are covered in the following paragraphs in DBS-NSS-003:

8.6 "... diesel start time (conservatively assumed to be 14 seconds), sequencer time (655 seconds, time delay after CDA (containment depressurization actuation) signal for pump start),

and an allowance for sequence timer tolerance (20 seconds)..."

12.2.6 " Containment recirculation spray pumps shall start automatically 660 seconds (2 a timer tolerance of twenty (20) seconds) following receipt of a CDA signal..."

12.2.7 "On a LOP event, the containment recirculation spray pumps shall be energized from the emergency diesel generator load sequencers. .. . . The start time used in the current analysis is nineteen (19) seconds (fourteen (14) seconds for the diesel )

generator start plus five (5) seconds for the load sequencer )..." 1 12.2.11 "On a LOP event, the containment recirculation spray 1

l pumps shall be energized from the EDG load sequencer in less-than-or-equal-to nineteen (19) seconds (fourteen (14) seconds for diesel generator start plus five (5) seconds for the load sequencer."

i LSK 24-9.4A depicts the following:

heirentatinn Pumn A minrt at 850 seconds and Recirculation Pump C start at 660 seconds after Diesel Generator breaker close under either CDA or CDA and LOP combined. This is further depicted on LSK-24-9.4Q and R and encompasses DBS paragraphs 8.6 and 12.2.6 requirements. l l Recirculation Pump A starts at 0 seconds and Recirculation

! Pump C starts at 5 seconds after Diesel Generator breaker close under LOP with the CDA recirculation mode signal present. This is further depicted on LSK-24-9.4Q and R and encompasses DBS paragraphs 12.2.7 and 12.2.11 requirements.

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Technical Specification 4.6.2.2.c says to verify that on a CDA test signal, each recirculation spray pump starts automatically ,

after a 660

• 20 second delay. This verifies DBS paragraphs 8.6 and 12.2.6 requirements.

DBS paragraph 8.6 uses the average sequencer time of 655 seconds (650 and 660 seconds) for the Recirculation Spray pumps instead of the worst case value as depicted in the other sections listed above. However, since it is being used in that section to establish a conservative requirement for spray header fill time rather than establish actual start times it is considered acceptable to use the average value.

Start times for the RSS pumps can vary from 19 seconds (14 Printed N17/9611:26:04 AM Page 2 of 5 I

ICAVP DR N3. DR-MP3-0616 Nsrtheast Utilities Millstone unit 3 Discrepancy Report seconds for diesel start time plus 5 seconds for sequencer time) to 694 seconds (14 seconds for diesel start time plus 660 seconds for sequencer time plus 20 seconds timer tolerance) for conditions which vary from LOP during a CDA while in l recirculation mode to LOP during a CDA prior to recirculation.

i Therefore, the design basis for tM RSS actuation times is correct as presented in the DBS. There does appear to be some ambiguity in the DBS with respect to the varying scenarios and their effect on the time for starting the recirculation spray pumps on LOP. CR MP3-97-4493 has been initiated to clar!fy these scenarios in the applicable DBS paragraphs.

l Significance Level Criteria do not apply here as this is not a l discrepant condit!on.

CONCLUSION:

i NU has concluded that the issue reported in Discrepancy Report,

! DR-MP3-0616, does not represent a discrepant condition. The design basis for the RSS actuation times is correct as presented in the DBS. Two separate scenarios exist which key on whether the LOP occurs with or without RSS in recirculation mode which

! results in different actuation times. However, since it does I appear there is some ambiguity in the DBS with respect to the time to start the recirculation spray pumps on LOP after initiation l of the recirculation mode, CR MP3-97-4493 has been initiated as an enhancement to have the applicable paragraphs in the DBS revised to make these two different scenarios clear. Significance Level criteria do not acoly here as this is not a discrepant condition.

l SECOND RESPONSE:

i DISPOSITION:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0616, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-97-4493 (attached) will clarify the applicable paragraphs in 3DBS-NSS-003 post startup with l respect to the time credited to start the recirculation spray pumps l under the different design basis conditions. NU concurs that the overall classification of DR-MP3-0616 to be Significance Level 4.

CONCLUSIONS:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0616, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-97-4493 (attached) will clarify the applicable paraaraphs in 3DBS-NSS-003 post startup with Printed 4/17/9611:2Ro5 AM Page 3 of 5 j i

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ICAVP DR No. DR-MP3-0616 Ntriheast Utiliti:s Millstone Unit 3 Discrepancy Report respect to the time credited to start the recirculation spray under i the different design basis conditions. NU concurs that the l overall classification of DR-MP3-0616 to be Significance Level 4.

Previously identifled by NU? O Yes @ No Non Discrepent condition?O Yes @ No

! Resolution Pending?O ve. @ No ResolutionUnresolved?O vee @ No Review initiator: Waketend, J. F.

O **

VT Lead: Nort, Anthony A l VT Mgr: schopfer. Don K IRC Chmn: singh, Anand K l Date: 4/16/98 SL comments: -

! FIRST RESPONSE:

Sargent & Lundy concurs that, following a postulated LOCA, if there were a LOP after ECCS suction switchover is completed, l RSS pumps A and B would restart immediately upon EDG breaker closure (14 seconds) and RSS pumps C and D would be sequenced to start 5 seconds after EDG breaker closure (19 seconds). This, however, does not change our interpretation of DBS-NSS-003, Sec.12.2.7 and 12.2.11.

The statements in Sec.12.2l/ and 12.2.11 of the RSS des'gn basis summary document are incorrect: )

l Sec.12.2.7 states that the start time used in the containment temperature i piussum scoyvuse anaiysis is 19 seconds. The I start time used in the analysis (prior to modification M3-97045) I l was 689 seconds. j Sec.12.2.11 states that the start time following LOP is 19 seconds, but the design basis LOP occurs simultaneously with a )

LOCA resulting in RSS start times of no more than 684 seconds for the A and B pumps and no more than 694 seconds for the C and D pumps. It is not part of the Millstone Unit 3 design basis to assume that a LOP commences after ECCS suction switchover following a postulated LOCA. The only way to interpret Sec.

12.2.11 of the RSS design basis summary document is that the RSS pumps start within 19 seconds of a simultaneous LOP /LOCA.

Sargent & Lundy concludes that DR-MP3-0616 is a discrepant condition.

i Sargent & Lundy has determined that the NRC Significance Level l

should be downgraded to level 4. This is because the

! discrepancy is only an editorial issue in the design basis summary documents. There is no error on this issue in the design drawings, calculations or evaluations which form the design basis of the RSS system. Therefore, closeout of CR MP3 97-4493 and issuance of change documents to correct DBS-NSS-003 may be deferred until after Unit 3 restart.

Printed 4/17/9611:26:06 AM Page 4 of 5 l

N:rtheast Utiliti::s ICAVP DR N2. DR-MP3-0616 l Millstone Unit 3 Discrepancy Report i

SECOND RESPONSE: .

1 NU's second response to DR-MP3-0616 addresses all of Sargent

& Lundy's comments on NU's first response to DR-MP3-0616.

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ICAVP DR No. DR-MP3-0619 Northenst Utilities l

Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design Discipline: Electrical Deeg" Ow l Discrepancy Type: Calculation g System / Process: DGX NRC significance level: NA Date faxed to NU:

Date Putillehed: 11/24/97 Discrepancy: Coordination Between EDG Neutral Circuit Breaker and Lockout for Bus and EDG DifferentialTrips Description Calculations 420CB and 421CB give the time delay between the l time that the generator neutral circuit breaker is opened until all of the circuit breakers on the bus or emergency diesel generator are tripped by the bus or generator differential relay. The l

operation of a differential relay Indicates that there is a short I circuit inside the protection zone of the differential relay.

Calculation 420CB concems the bus differential relay (87). Its l

protective zone is the entire bus of a Class 1E 4.16 kV l

switchgear. It trips all circuit breakers at the bus.

Calculation 421CB concems the emergency diesel Generator (EDG) differential relay (87G). Its protective zone is the emergency diesel generator and its connections to the switchgear. It trips the diesel Generator circuit breaker.

Time delay relay 62E is associated with the bus differential relay.

! Time delay relay 62G is associated with the generator differential relay, if either differential relay operates, the diesel generator

C lb g;;;d ; h = 0"0 C t0 9 2";" "'d??""" "'"

l most likely type of short circuit. If this fails, all of the circuit breakers on the bus are opened and locked out if 62E operates and the diesel generator breaker is opened if 62G operates. A 0.2 second time delay is provided for both relays. However the discussion on Section 14.2.2 of IEEE 2421986 suggests that this time interval is somewhat short to guarantee reliable l

j coordination. The neutral circuit breaker is normally rated to I

open in 5 cycles (0.083 s). The auxiliary relay used to open the breaker will require another 0.004 s. Additional time is required l

l to allow the PVD bus differential relay to drop out if opening the l

neutral breaker successfully clears the fault. (See the note on l page 5 of General Electric instruction leaflet GEK-45405C concemin0 the dropout time of the 87L unit within the PVD relay.) The adequacy of the 0.2 second coordination time interval should be verified. A coordination time interval of 0.3 i second is used elsewhere at Millstone and should be adequate.

• "lRC Comment : Correction of spelling error **"

Review Valid invalid Needed Date initiator: Bioethe, G. Williern 8 0 0 11/15'S7 VT Lead: Neri, Anthony A B O O 11ria/97 VT Mgt: schopfer, Don K G O O 11/18/97 IRC Chmn: Singh, Anand K 8 O O 11' S'S7 Printed 4/17/961126:56 AM Page 1 of 6

l ICAVP DR No. DR-MP3-0619 N:rthe st Utilities Millstone Unit 3 Discrepancy Report l Date:

WVAUO:

oste: 4/16/98 RESOLUTION. jNITIAL RESPONSE:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0619, does not represent a discrepant condition.

The Emergency Diesel Generators (EDG's) are protected by a differential scheme (87G) against severe short circuits intemal to the machines.

The 4.16 KV Switchgear is also protected by a differential scheme (87H) against severe short circuits within the switchgear The above protection is fast and willisolate any severe fault i before any serious damage to either the generator or the Switchgear.

The Generator is connected to the ground via a grounding resistor to limit any ground fault current to values harmless to the generator. A ground fault relay (51N) picks up the fault current and trips a Neutral Circuit Breaker therefore isolating the ground fault and in essence converting the system to an ungrounded j system. This will allow the continous use of the generator during an accident condition (SIS). In addition, a time delay of 0.2 sec j was introduced in the differential schemes to delay their j activation (during an accident SIS) to make sure that any ground j fault is alreacy clearea anc tne N6Wfhi t5reaker opened io l prevent a false actuation of a differential relay.

The EDG will continue operating (as an ungrounded system) and j providing power to the Class 1E equipment required to mitigate the accident.

The time required for the 51G relay to trigger the timer to actuate and the breaker to trip is estimated as (0.5+0.5+6.5) 7.5 cycles or 0.125 sec. This leaves a margin of 0.085 secs.

However, the maximum ground fault magnitude of the neutral i ground circuit is outside the range of the differential protective scheme, because the ground fault current is limited by the 6 ohm ground limiting resistor (see AC Elementary 12179-EE-21Q).

Per calculation 421CA (SP-EE 269), the 1200/5 CT's on the Diesel Generator differential relays will not pickup a current of such a small magnitude which makes the 0.2 sec's delay unnecessary, therefore there is no need to add to the time delay. The time delay is a conservative approach to assure that l the safety related Diesel Generator does not trip on false currents.

From the above discussion it is clear that no discrepancies exist l

. The calculation successfully balances the need to protect the Page 2 of 6 Printed N17/981127:00 AM

N:rtheast Utilities ICAVP DR N3. DR-MP3-0619 Millstone unit 3 Discrepancy Report EDGs against severe faults (short circuits) while extending their availability to mitigate an accident under small ground faults in one phase. NU has concluded that this issue regarding Discrepancy Report DR-MP3-0619 does not represent a discrepent condition.

Note: Calculations GM-60-03.0420CB & .0421CB have been revised and voided, data can be found in Specification SP-EE-269.

SECOND RESPONSE:

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0619, does not represent a discrepant condition. This IRF supersedes M3-IRF-01094 in its entirety. The initial NU response to DR No. 619 was in error. The response relied upon the operation of the back-up EDG ground overcurrent relay 51N(G) which has a built in time delay to coordinate with the 4160V system feeder circuit 50GS devices. This response needs to be replaced with the following:

At issue is whether to raise the 0.2 second time delay setting presently used in the 4160 volts bus and diesel differential relay control logic circuits to 0.3 second to achieve greater time coordination margin.

The flmo ript:ay in niteetinn it cinnifirunnt nniv in the cresence of a SIS signal where the diesel is the only 4160 volt power supply, in any other system configurations the time delay in question is insignificant since the timing relay is intentionally shunted out of the control circuits by either the 'b" contacts of SIS relay or the

'b' contacts of the 4160 volt bus supply breakers.

With the diesel as sole source of 4160 volt power (accident mode), the magnitude of fault currents available for faults within either the diesel or the bus differential zones are small. The diesel generator neutral grounding scheme limits ground faults to approximately 400 amperes.

In the above scenario, the relaying logic incorporates a time delay of 0.2 seconds before tripping of either the diesel output or bus feeder breakers following a fault. The reasoning here has been, if the fault includes a ground, opening of the diesel neutral breaker should isolate the fautt and thereby leave the diesel available to supply the plant safety loads.

The 0.2 second time delay is requircJ to address the processing of the trip signal to the EDG neutral breaker.

5 cycles Diesel Generator Neutral Breaker ,

tripping l l

0.5 cycle AR relay actuation (94G or 94EBE)

Printed 4/17/9811:27:01 AM Page 3 of 6

ICAVP DR No. DR-MP3 0619 N:rtheast Utilities Millstone Unit 3 Discrepancy Report 1.5 cycles 87 reset time (87G or 87BE)

The worst case scenario could require 7 cycles (5 + 1.5 + 0.5) before the SAM timer resets. The present 12 cycles time delay setting (0.2 second) for coordination time Interval allows 5 cycles margin against undesired operation for single phase-to-ground faults. Raising the coordination time interval to 18 cycles (0.3 second) increases this margin to 11 cycles. Extending the time delay would delay the lockout relay operation for the more severe multi-phase faults. The present setting of 0.2 seconds is l an acceptable balance in the protective relaying schemes. .

I This accurate replacement of the NU response to DR No. 619 remains a non-discrepant condition.

Significance level criteria do not apply here as this is not a discrepant condition. i l

Conclusion:

l NU has concluded that the issue reported in Discrepancy Report, j DR-MP3-0619, does not represent a discrepant condition. This IRF supersedes M3-IRF-01094 in its entirety.

= The n 9 car'nnd firna daltw is rannired to address the orocessina of the trip signal to the EDG neutral breaker.

5 cycles Diesel Generator Neutral Breaker tripping l

0.5 cycle AR relay actuation (94G or 94EBE) l l

1.5 cycles 87 reset time (87G or 87BE)

The worst case scenario could require 7 cycles (5 + 1.5 + 0.5) before the SAM timer resets. The present 12 cycles time delay l setting (0.2 second) for coordination time interval allows 5 cycles margin against undesired operation for single phase-to-ground faults. Raising the coordination time interval to 18 cycles (0.3 second) increases this margin to 11 cycles. Extending the time delay would delay the lockout relay operation for the more severe multi-phase faults. The present setting of 0.2 seconds is j an acceptable balance in the protective relaying schemes.

Significance level criteria do not apply here as this is not a discrepant condition.

Previously identified by NU? O vos (#1 No Non D6screpent Condition?@ ves Q No Resolution Pending?O vos @ No Resoiuison unresoived?O ves @ No Review Printed 4/17/9811:27;o2 AM Page 4 of 6

ICAVP DR Nr. DR-WIP3 0619 Nsrtheast Utilities Millstone Unit 3 Discrepancy Report initiator: Wamer,l.

O **

VT Lead: Neri, Anthony A O O em VT Mgr: schopfer, Don K IRC Chmn: singh, Anend K Date: 4/16/98 SL Comments: INITIAL COMMENTS:

We have reviewed NU's response and after evaluating the response and the associated questions we have defined additional issues: ,

Issue 1:

l NU states that "the maximum ground fault current j magnitude of ,

the neutral ground circuit is outside of the range of the )

differential protective scheme, because the ground fault I current !s limited by the 6 ohm grounding resistor (see AC Elementary 12179-EE-210)".

The 6 ohm diesel generator neutral resistor on the 2400/4160 volt system limits the ground fault current to 2400/6 = 400 amperes.

Calculation 421CA states that the minimum current to activate the diesel generator differential relays is 46.2 amperes.

Therefore, line to ground short circuits can be expected to operate the diesel generator differential relay.

Since the differential relays may operate during a line to ground fault, NU's statement appears to De in error.

l Issue 2:

NU states that the " time required for the 51G relay to trigger the timer to actuate ar.d the breaker to trip is estimated as (0.5+0.5+6.5) 7.5 cycles or 0.125 sec."

As a basis to this issue we have assumed that relay 51G referred to in the response is the same relay (51N) defined in the drawings and in Calculation 422CB.

This calculation shows that relay 51N takes 0.6 second to operate with the rated ground fault current of 400 amperes. Because of the time delay required for relay 51N to operate, NU's statement on the operating time of the neutral breaker appears to be in error. Also, Section 8.3.1.1.4.d of the Millstone FSAR states that the neutral breakers will be allowed to trip before the generator is tripped by the generator differential relay (87G).

If our assumptions are correct, the existing relaying arrangement appears to violate the FSAR and the statement in the DR response.

Printed 4/17/9811:27:03 AM Page 5 of 6

l l l I N rth:a:t Utilities ICAVP DR N . DR-MP3-0619 ,

L r Millstone Unit 3 Discrepancy Report l Based on the above discussion, this DR is reclassified as Level 3.

l COMMENTS ON NU'S SECOND RESPONSE:

We have no comments on NU's second response.

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Printed N17/9811:27:04 AM Page 6 of 6

N::rtheast Utilities ICAVP DR Ns. DR-MP3-0642 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design p g Discipline: Mechanical Design Diecrepancy Type: component Data Om System / Process: HVX

@ No NRC Significance level: 4 Date faxed to NU:

Date Published: 11/22/97 Discrepancy: SLCRS and ABVS Fitler Unit Fire Protection Piping and Deluge Valves

Description:

During review of the fire protection interface with the Supplementary Leak Collection System (SLCRS) filter units 3HVR*FLT3A/3B and the Auxiliary Building Ventitation System (ABVS) exhaust filter units 3HVR*FLT1 A/1B a discrepancy regarding the classification of the deluge valves (3FPW-FV70, 71,72,73) and piping was identified.

Regulatory Guide 1.52, Rev. 2, Posit!on C.2.c requires that all components of an engineered-safety-feature atmospheric cleanup system should be designated as Seism!c Category I if failure of a component would lead to the release of significant quantitles of fission products to the working or outdoor environments. FSAR Table 1.8-1 does not take exception to this requirement.

The PMMS database identifies valves 3FPW-FV70,71,72,73 as non-seismic non-CAT 1 components.

rhe de!uge ve!ve end fire prder49 piping hatwoon ihn rialmne valve and the filter unit were provided by specification 2103.460-363 Special Hazard Fire Extinguishing System in accordance with NFPA 15. The specification does not identify any seismic requirements for the deluge valve or piping.

The deluge valve and piping form part of the pressure boundary for the filter units. Failure of these items to maintain their pressure integrity post accident would result in air bypassing the demister, prefilter and HEPA filter. There is also the potential for air bypass of the charcoal adsorber in the filter units.  !

Review l Valid invalid Needed Date initiator: stout, M. D. 8 O O 11/10/S7 VT Lead: Nort, Anthony A G O O 11'10/97 VT Mgr: schopfer, Don K 8 0 0 1 110/87 IRc Chmn: singh, Anand K B O O 11/18/S7 Date:

INVALID: )

Date: 4/10/98 RESOLUTION NU has concluded that the Discrepancy Report, DR-MP3-0642, has identified a condition not previously discovered by NU which requires correction.

DR-MP3-0642 identifies that the design of the fire protection j Printed 4/17/981127:37 AM Page 1 of 4 {

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ICAVP DR N2. DR-MP3-0642 l N:rtheast Utilitizo Millstone Unit 3 Discrepancy Report 1

system which interfaces with the SLCRS and ABVS filter units j does not meet RG 1.52, Rev. 2, seismic and quality requirements. As stated in the MNPS-3 FPER, section 4.1.2.1.2,

" Automatic and Manual Operating Spray Systems," the water j spray systems for the SLCRS and ABVS filter units are manually operated deluge type systems employing open spray nozzles located within the filter housing. A manually operated, j recyclable deluge valve is provided between the supply header (

and the distribution piping. The manual deluge valve is operated j by local manual electric pushbuttons or by a signal from the j control room main fire panel. Upon manually opening the I isolation valve and manually initiating deluge valve opening, l water flows into the distribution piping and discharges from all l spray heads for a controlled period of time followed by automatic i closing of the deluge valve.

Regulatory Guide 1.52, Rev. 2, " Design , Testing, and Maintenance Criteria for Post Accident Engineered Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light Water Cooled Nuclear Power Plants,"

does not apply to the Fire Protection System including the filter I unit water spray system. The filter unit water spray system is designed to meet the requirements of NFPA 15. " Standard for Water Spray fixed Systems for Fire Protection," per specification 2103.460-363, "Special Hazard Fire Extinguishing System," and the Millstone 3 Fire Protection Evaluation Report (FPER).

Therefore, FSAR Table 1.8-1 does not require a change to take exception to RG 1.52, Rev. 2, position C.2.c requirements regarding the filter unit water spray system.

1 The PMMS database quality indicators for valves 3FPW-FV70, 71,72,73 are correct and reflect MEPL determination MP3-CD-1105. MEPL MP3-CD-1105 classifies the valves as FPQA in accordance with specification SP-ST-ME-944 and the Fire Protection Program. CR M3-98-0922 was initiated to document the discrepancies identified in DR-MP3-0328 and DR-MP3-0642 regarding the classification of the ABVS/SLCRS filter units and filter unit fire protection system. The CR M3-98-0922 corrective action plan requires a revision to MEPL MP3-CD-1105 to clarify the determination with regard to pressure and leakage integrity.

The clarification to the MEPL determination will not change the classification of the filter unit water spray components.

The filter unit water spray system was installed in accordance with NFPA 13 " Piping and Components Supports." NFPA 13 section," Protection of Piping Against Damage When Subject To Earthquakes," addresses sorinkler systems piping installation and supports. The piping support, hanger, and anchor requirements for the fire protection system are provided in specification 2103.460-363. The deluge valves and piping are supported by 4"x4" tube steel, angle iron and 2" U-bolts as shown on Specification 2103.460-363 drawings 610D and 656B.

In addition, Millstone Unit 3 Safety Evaluation Report (SER),

Supplement No. 4, dated 12/6/85, and Supplement No. 5, dated 2/14/86 evaluated NU's seismic interaction proaram.

Page 2 of 4 Printed 4/17/9811:27Ao AM

ICAVP DR Ns. DR-MP3-0642 N:rthext Utilitie3 Millstone Unit 3 Discrepancy Report l

Supplement 5 conduded that "the non-seismic Category I piping systems will maintain their structural integrity and will not adversely affect the ability of the seismic Category I piping and equipment to perform their safety functions. The NRC condusions were based,in part, on an audit of the seismic interaction program results at the offices of Sargent & Lundy on 1/9/86. Therefore, it is not postulated that the filter unit water spray system piping would fail to maintain its structural integrity during and after a seismic event. Specification 2103.460-363 does not require a revision to include additional seismic requirements.

The filter units water spray system is a manually operated system. The filter unit water spray system isolation valves (3FPW-V120,119,123 and 122) and deluge valves (3-FPW-V69, V69, V70, V71, V72, V73) are normally closed. These valves will remain closed post accident unless they are manually opened to mitigate a fire or provide cooling in the filter unit at which time the piping will be full of water. Therefore, there is no post accident failure of the filter unit water spray system that would allow air to bypass the charcoal filters.

NU considers the issues identified in DR-MP3-642 to be a significance level 4 based on the clarification to MEPL MP3-CD-1105 for CR M3-98-0922. The clarification to the MEPL will not change the classification of the filter unit water spray system l components.

Conclusion:

NU has concluded that the Discrepancy Report, UR-MF3-064Z,  ;

has identified a condition not previously discovered by NU which 1 requires correction.

DR-MP3-0642 identifies that the design of the fire protection system which interfaces with the SLCRS and ABVS filter units does not meet RG 1.52, Rev. 2, seismic and quality requirements. The filter unit water spray system is a manually operated system which is part of the Fire Protection system.

Regulatory Guide 1.52, Rev. 2, does not apply to the Fire Protection System including the filter unit water spray system.

The filter unit water spray system is designed to meet the requirements of NFPA 15 and NFPA 13 per specification 2103.460-363 and the MNPS-3 FPER. Based on SER Supplements 4 and 5, the filter unit water spray system piping will maintain its structural integrity during and after a seismic event.

The PMMS database quality indicators for valves 3FPW-FV70, 71,72,73 are correct and reflect MEPL determination MP3-CD-1105. CR M3-98-0922 corrective action plan requires a revision to MEPL MP3-CD-1105 to clarify the determination with regard to pressure and leakage integrity.

The filter unit water spray system isolation and deluge valves are normally closed and will remain closed post accident unless they are opened to mitiaate a fire. There is no post accident failure of Printed 4/17/9811:27A1 AM Page 3 of 4

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N:rtheast Utilitige ICAVP DR No. DR-MP3-0642 Millstone Unit 3 Discrepancy Report the filter unit water spray system thst would allow air to bypass the charcoal filters.

NU considers the issues identified in DR-MP3-642 to be a significance level 4 based on the clarification to MEPL MP3-CD-1105 for CR M3-98-0922. The clarification to the MEPL will not change the classification of the filter unit water spray system components.

Attachments:

CR M3-98-0922 Previously identified by NU? O Yes (8) No Non D6screpent CondiUon?O Yes (8) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: stout, M. D.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anend K Date: 4/10/98 SL Comments: Based on the arrangement of the spray headers above the charcoal bed, the charcoal filling instructions in the filter unit vendor manual, and CVI's Febmary 20,1998 letter (attached to CR M3-98-0922), failure of the non-seismic fire protection piping i would not result in air bypass of the charcoal adsorber.

CR M3-98-0922 corrective action plans requires revision to MEPL ]

iviP3-CD-i105 iu dcisify iim ueterminetien ini rega.t to premic '

and leakage integrity. This is considered a Level 4 discrepancy.

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Printed 4/17/9811:27:43 AM Page 4 of 4

i N :rtheast Utilities ICAVP DR No. DR-MP3-0676 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOi.UTioN ACCEPTED [

Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation Om l SystemProcess: DGX g !I NRC Signincance level: 4 Date faxed to NU: I Date Published: 1/2596 Discrepancy: Discrepancies for Calculation SDP-EGS-01345M3, Rev. 05 Decription: 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. Operating Condition 3 assumes that the valve 3EGS*AOV43A/B falls in the full bypass mode. Valve 3EGS*AOV43A/B is not shown on the EGS system P&lD's EM-116A-27 and EM-116C-12, and it could not be fcund in the PDDS data base. Valves 3EGS*AOV43A/B appear to have been replaced by valves 3EGS*TCV50A/B. (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 MisceManeous Information 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 ill 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 j 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 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 coriditions (pages 11 and 12).

l 5. Calculation Attachment 1 provides flexible hose information.

l On page 2 cf this Attachment Young's modulus for the 0.5 in.

i 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, referencer/ sources, units) for selected equation and its parameters. This apparent error was then propagated in t

the ensuing calculation of shearing modulus. Also, Page 1 of this Attachment refers to Ref, a (for hose stiffness) and Ref. b (f07 h0S6Mht); 00hh0i Of "'OC 70f0l0COc010 pr0t'id0d r pg gig g 3h AM of 4 l l

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Nsrtheatt Utilities ICAVP DR No. DR-MP3-0676 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 vand invaud Needed Date initiator: Obersnei.sokn. O O O 1' S'se VT Leed: Neri, Anthony A Q Q Q 1ris/s6 VT Mgr: schopfer, Don K O O O 1itsese IRC Chmn: Singh, Anand K O O O 1/21/se Date:

INVALID:

Date: 4/15/98 RESOLUTION First 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 MS-98-0599 has been issued to correct the discrepancies after startup. Specifically the first discrepancy determined the incorrect control valve 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 innrth dierannncv will ha corracind by ornvidinn the nrnnar reference for the number of cycles for the Operating Conditions.

The last discrepancy noted a mathematical error in the I

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 M3-98-0599 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.

Second Disposition:

NU has concluded that issues 4 and 5 of Revised Discrepancy Report DR-MP3-0675 represent discrepant conditions. In reply to the S&L discrepancy 4 response, the postulated failure in the stress data package for condition 3 assumes the control valve fails which bypasses the Jacket water heat exchanger causing the cooling water temperature to rise. The failure of the control valve is only meaningful with the Emergency Diesel Generator Printed 4/17/s611:28:48 AM PeGe 2 of 4

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ICAVP DR N3. DR-MP3-0676 N:rtheart Utilities Millstone Unit 3 Discrepancy Report j operating. The maximum number of equivalent full temperature cycles the ASME Code section NC-3000 allows is 7,000 cycles for a stress range reduction factor of 1.0. Thus, the assumed 40 cycles for Condition 3 is acceptable since it is orders of magnitude less than 7000 cycles and therefore, no stress reduction is required. There is no impact on the pipe stress calculation results. A formal reference for the 40 cycles will be added to the SDP by the approved corrective action plan for CR-M3-98-0599 post startup..For S&L reply discrepancy 5, the value of Young's Modulus and Shear Modulus determined in the attachment to calculation SDP- EGS-01345 was not used in the calculation since the flexible hose vendor provided qualification data for the flexible hoses. The SDP will be revised to delete this information per the approved corrective action plan for CR-M3-98-0599 post startup. The Significance Levelis concluded to be Level 4 since there is no impact on the calculation conclusions. The revised DR-MP3-0675 identified additional discrepancies which the approved corrective action plan for CR M3-98-0599 will correct after startup. The Significance Level for DR-MP3-0675 is Level 4 since there is no impact on LB, DB, or plant equipment.

Conclusion:

NU has concluded that the issues reported in Revised Discrepancy Report DR-MP3-0675 identify discrepant conditions in addition to those previously identified. The Approved j Corrective Action Plan for CR-M3-98-0599 will correct these discrepancies after startup by providing a reference for the number of assumed cycles and deleting the Young's Modulus l ano snear Moaulus calcuiation since mese vaiues were nui )

used.The discrepancies do not impact the results of the stress calculations. The Significance Levelis concluded to be Level

4. The Significance Level for Discrepancy Report DR-MP3-0675 remains a Level 4 since there is no impact on LB, DB or plant equipment.

Previously identined by NU? O ves (9) No Non Discrepent Condition?O vos (#) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Movicw

• • **E

• initiator: Obersnel,Bo}sn.

VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K l lRC Chmn. singh, Anand K Date: 4/15/98 sL Corrm eds: S&L comments for first disposition:

S&L agree.s with the disposition of the first three discrepancies, but requires rnore 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.

Printed 4/17/9011:28:50 AM Page 3 of 4

N:rtheast Utilities ICAVP DR N2. DR-MP3 0675 Millstone Unit 3 Discrepancy Report 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.

S&L comments for second disposition:

Based on the additional information provided by NU with the second disposition, S&L finds the disposition for items 4 and 5 of this Discrepancy Report acceptable.

S&L agrees that the determination and documentation of the number of operating cycles (Discrepancy Report item 4) is extremely unlikely to affect the piping stress analysis. Based on the anticipated modes and frequency of operation of the Emergency Diesel Generator cooling system (EGS), it is anticipated that the totaMumber of equivalent full temperature cycles over the system service life will be well below ASME Code allowable of 7000 for the stress range reduction factor of 1.0.

Therefore, S&L agrees that the corrective action for this discrepancy is deferrable.

S&L accepts NU's statement that the calculated Young's Modulus and Shear Modulus for flexible hoses were never used in design i documentation, and agrees with the NU disposition to delete this l Information from the calculation. ,

L The above disposition of the items 4 and 5, and previous disposition of other items of this Discrepancy Report show that i the noted discrepancies do not impact licensing or design basis, l or operability of the system. Therefore, the Significance Level for this DR was reduced from 3 to 4. l I

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Printed 4/17/9811:20:51 AM Page 4 of 4 i

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N:rtheast Utilitia ICAVP DR No. DR-MP3-0680 Millstone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED Reh EW: Sp W Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation Ow I System / Process: DGX gg i

NRC Significance level: 4 Date faxed to NU:

Date Published: 1/22/96 I 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.

(blank) was performed in 1984. Since, the EGA has been modified, primarily a dryer with an aftercooler has been added on the air compressor discharge side and the relief valve 3EGA-RV20A1,A2,81 B2 set point has been raised to 500 psig (as  !

shown on the system P&lD's). This significantly changes system I operating conditions. The scope of the calculation has been l changed by changing piping configuration, and added line I 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 piping considered in the calculation does not match the off skid lines as listed on the EGA Line List and as shown on the system PalD's (EM-116B-25 l and EM-116D-5). The calculation does not include lines with l sequentialline numbers 60 and beyond (lines 60,61,62,63,64, l 65,86,87,88,89,90, and 91 are ASME Section Ill, Class 3); for  ;

the SDP Condition 1 lines wkh 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 l (on the air compressor discharge) set point is considered to be I 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).

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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 Printed 4/17/9811:29:35 AM of 6 I

ICAVP DR N3. DR-MP3-0680 N:rthnast Utilitica 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 1 to temperatures of the air exiting air compressor. However, this  !

mode of operation is not addressed in the calculation.) l T

4. No supporting justification is provided in the calculation or by reference for the number of cycles for SDP Conditions 3,4, and

5.  ;

1

5. Air compressor discharge relief valve is OA Cat. 2 (per PDDS l database). On pages 5 and 10 of the calculation the valve is l identified with valve number 3EGA*RV20A1,*RV20A2,*RV20B1,

• RV20B2.

Review l Valid invalid Needed Date j Initiator: Obersnel,Bojan. 8 O O 12/2/97 i VT Lead: Neri, Anthorr/A B O O 12iie/97 j VT Mgt: schopfer, Don K G O O 12/23/97 l IRC Cnmn: singh, Anand K B O O /17/88

)

D.te.

)

INVAUD:

1 Date: 4/j4/98 )

RESOLUTION: First Disposition:  ;

NU has concluded that Discrepancy Report, DR-MP3-0680 has l identified a condition not previously identified by NU that ramaras entractinn e ntentatinn prit1042. a deslan Inout to l

calculation SDP-EGA-01342M3 does not reflect plant  !

modifications and operating configurations as changed since f startup and requires revision. However, the plant design basis is j i

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 MP3-92102 and supported by calculation 3-92102-263M, 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 the change to 500 psi identified in item Printed 4/17/9811:29:39 AM Page 2 of 6 s

Ntrtheast Utilities ICAVP DR Ns. DR-MP3-0680 Millstone Unit 3 Discrepancy Report

! 2 are addressed in Stress Data Package calculation SDP-EGA-l l 01342M3, reflected on P&lDs EM-133B/D and supported by l PDCRs MP3-86-038 & MP3-92-102. Calculation P(T)-1042 l requires update.

l item 3 is addressed by SDP condition 2 which was analyzed l without credit for aftercoolers. l i ltem 4 number of cycles for SDP upset conditions 3,4, and 5 l are 1/yr or 40 total each as given in SDP-EGA-01342M3.

Relief valve designations identified in item 5 require revision l In calculation P(T)-1042 to QA Cat. 2, consistent with P&lDs EM-l 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.

i CR M3-98-0477 was written for this discrepancy. The corrective action revises calculation P(T)-1042 to reflect the current system I configuration and design pressure increase in calculation 3 102-263-M3 and will be confirmed with calculation SDP-EGA-01342M3. The CCN is schedul6d for completion post startup.

Calculation P(T)-1042, as an input calculation to the SDP, should I have been reviewed and revised as part of the 50.54f effort. As part of the CR investigation relating to this DR, a sampling of i other PI 31 system calculation reviews indicated that SDP input '

calculations were reviewed and revised. As the operating l 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 thle ge g ginnificant m f numt a riier ronnnev

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 l evaluation. The CCN is scheduled for completion post startup.

l NU considers this a Significance Level 4 discrepancy based on l the above generic review and since the design basis of the diesel l

start air system is currently supported by plant documentation including calculation SDP-EGA-01342M3.

Second Disposition:

NU has concluded that Discrepar cy Report, DR-MP3-0680, has identified a condition not previously ejiscovered by NU which Printed 4/17/9811:29:40AM Page 3 of 6 l

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I N:rthea;t Utilitus ICAVP DR N2. DR-MP3-0680 Millstone Unit 3 Discrepancy Report I

requires correction. As stated in the S&L comment description, S&L concurs with the disposition of items one, two and five provided in the NU response M3-IRF-01734. Responses to items three and four of the original IRF were not concurred with and are dispositioned as follows:

ltem 3: In acco, dance with the corrective actions outlined in CR l M3-98-0575 ( See Attached ), which was generated in response l to S&L DR-MP3-692 ( See M3 IRF-1577 ), the justification for the number of cycles for each of the operating modes will be i

provided in the stress data package. it should be noted that the pipe stress calculations for this scenario would only be impacted if the number of cycles exceeded the ASME Code section NC-3000 allowable number of equivalent full temperature cycles of 7000 for a stress reduction factor of 1.0. There is no impact on the pipe stress calculations since the assumed number of cycles

( 40 ) is orders of magnitude less than the 7000 cycles cut off value in the ASME code.

l Item 4:In accordance with the corrective actions outlined in CR M3-98-0575 ( See Attached ), which was generated in response l to S&L DR-MP3-692 ( See M3-IRF-1577 ), the approved corrective action plan for CR M3-98-0575 will provide a reference for the present number of cycles.

Pursuant to discussions with S&L for clarification of a similar DR

( DR-MP3-0692 ), the dispositions detailed above were agreed to bring this issue to closure. Based upon the preceding discussions, the LB / DB of MP3 is not impacted by this d! Sci?^?"?y 'herefer? MU C?"S!d?N th!! '""? ?? M e !?"?! '

discrepancy. These corrective actions will be performed post MP3 restart.

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Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0680, has identified a condition not previously discovered by NU which requires correction. As stated in the S&L comment description, S&L concurs with the disposition of items one,two and five provided in the NU response M3-IRF-01734. Responses to items three and four of the original IRF were not concurred with and are dispositioned as follows: j ltem 3: In accordance with the corrective actions outlined in CR l M3-98-0575 ( See Attached ), which was generated in response l to S&L DR-MP3-692 ( See M3-IRF-1577 ), the justification for l the number of cycles for each of the operating modes will be j l provided in the stress data package. It should be noted that the j pipe stress calculations for this scenario would only be impacted l

if the number of cycles exceeded the ASME Code section NC-  !

3000 allowable number of equivalent full temperature cycles of 7000 for a stress reduction factor of 1.0. There is no impact on the pipe stress calculations since the assumed number of cycles j

( 40 ) is orders of magnitude less than the 7000 cycles cut off  !

value in the ASME code. I Item 4:In accordance with the corrective actions outlined in CR Pdnted 4/17/9811:29:41 AM Page 4 of 6 i

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N:rtheast Utilities ICAVP DR No. DR-MP3-0680 Millstone Unit 3 Discrepancy Report M3-98-0575 ( See Attached ), which was generated in response i to S&L DR MP3-692 ( See M3-IRF-1577 ), the approved l corrective action plan for CR M3-98-0575 will provide a reference for the present number of cycles.

Pursuant to discussions with S&L for clarification of a similar DR

( DR-MP3-0692 ), the dispositions detailed above were agreed to l

bring this issue to closure. Based upon the preceding l discussions, the LB / DB of MP3 is not impacted by this

discrepancy therefore NU considers this issue to be a level 4 l discrepancy. These corrective actions will be performed post MP3 restart.

Previously identified by NU? O Yes (8) No Non Discrepant Condition?O Yes (S) No Resolution Pending?O Ye. @ No Resolution Unresolved?O Ye. @ No Review Initiator: Obersnel,Bojan.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC ctenn: singh, Anand K O O O Date: 4/14/98 SL cornments: S&L comments for first disposition:

S&L agrees with the disposition to the first, second and fifth discrepancy in this DR, and requires additional information to complete evaluation of disposition for the third and fourth discrepancy. In particular:

OaL cg;;; with the dbpc:niica cf the 5r01 twc $ccrepenc!ec cnd finds the corrective action of CR-M3-98-0477 acceptable.

S&L recognizes that the calculation defined Condition 2 is defined conservatively and agrees that the dryer bypass operating l 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.

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 l Stress Data Package, in tum, cannot be a reference to this ]

calculation, as implied in the disposition. The number of cycles for affected operating conditions should be based on other design documents, where this parameter has been calculated, or otherwise determined based on design requirements. See l Response no. M3-IRF-01577 to DR-MP3-0692. l i

S&L agrees with the disposition to the fifth discrepancy.  !

S&L comments for second disposition: )

NU disposition for items 3 and 4 of this DR is acceptable.

I Printed 4/17/9811:29:42 AM Page 5 of 6 1

DR No. DR-MP3-0680 Nsrtheast Utiliti;a ICAVP Millstone Unit 3 Discrepancy Report The original scope of the DR item 3 was previously dispositioned by NU, and the disposition partially accepted by S&L. The remaining scope of item 3 and the item 4 both address adequacy of, and justification for the number of cycles assigned to the Operating Conditions defined in the calculation. NU disposition will document the justification for number of cycles in accordance with the corrective action outlined in CR M3-98 0575. S&L agrees that the determination of the number of operating cycles is extremely unlikely to affect the piping stress analysis. Based on the anticipated modes and f,equency of operation of the Emergency Diesel Generator starting air system (EGA), it is anticipated that the total number of equivalent full temperature cycles over the system service life will be well below ASME Code allowable of 7000 for the stress range reduction factor of 1.0.

Therefore, S&L agrees that the corrective action for this discrepancy is deferrable.

Based on the disposition of all items of this Discrepancy Report, it is concluded that the discrepancies noted in the DR do not impact the design or licensing basis, or operability of the system. For this reason S&L has reduced the Significance Level for this DR from Level 3 to Level 4.

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l Page 6 of 6 l Pdnted 4/17/9611:29:44 AM i

Nsrtheast Utilities ICAVP DR No. DR-MP3-0692 uitistone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design PotentialOperability issue Discrepancy Type: Calculation Qy Systern/ Process: DGX 9 No NRC Significance level: 4 Date Faxed to NU:

Date Published: 1/25S6 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 referenced (Ref. 3a) in the subject calculation.

Calculation P(T)-1042 assumes that the isolation valves 3EGA*V995, *V994, *V982 and *V981 are inadvertently closed ,

for this operating condition.

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,B1,B2)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 invalid Needed Date initiator: Obersnel,Bojan.

@ O O 1/848 VT Lead: Neri, Anthony A B O O 1SS8 VT Mgr: schopfer, Don K G O O 1/19/S8 IRc Chmn: singh, Anand K B O O 1f21/96 Date:

INVALID:

Date: 4/15/98 RESOLUTION: First 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 4/17/9611:30:11 AM Page 1 of 4 I

N rtheast Utilitiea ICAVP DR No. DR-MP3-0692 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 j concluded to be Level 4. j i

Conclusion NU has concluded that Discrepancy Report, DR MP3-0692, has j identified a condition not previously discovered by NU which l requires correction. The approved corrective action plan for CR M3-98-0575 will revise the calculation after startup. The q discrepancies alter inputs to three Operating Conditions but do not impact the calculation conclusion. The Significance Level is l

concluded to be Level 4. '

Second Disposition:

NU has concluded that the issue reported in Revised Discrepancy Report DR-MP3-0692 has identified additional ,

discrepancies. In response to the first discrepancy, the Intended I condition is to assume the manual isolation valves are inadvertently closed, consistent with calculation 12179-P(T)-1042 condition 3," Single Error of Operator". The approved corrective pb lcr CR M3 OS 0575 #" rede c&6t!cn SO* EGA 01342M3 after startup to remove the discrepant valve numbers listed on page 11 of the calculation and incorporate the correct manual valve numbers. This change will not have any impact on the piping stress analysis since the temperatures used in the piping stress analysis are consistent with this scenario.

In reply to second discrepancy, the response indicated the 130F degrees was the piping system design temperature. The 130F temperature is actually the piping system operating temperature. When the air receiver tank relief valve falls open, the system runs in the normal operating mode causing the 130F temperature which has no effect on the piping stress calculations. Failure of the relief valve on the air compressor also causes the system to operate in the normal mode with no affect on the piping rtress calculations.

In reply to the third 35crepancy, the pipe stress calculations for this scenario wouto only be impacted if the number of cycles exceeded the ASME Code section NC-3000 allowable number of equivalent full temperature cycles of 7000 for a stress reduction j factor of 1.0. Although the source for the present number of I cycles of 40 is not documented, the approved corrective action plan for CR M3-98-0575 will provide the needed reference.

There is no impact on the pipe stress calculations since the assumed number of cycles is orders of magnitude less than the 7000 cycles cut off value in the ASME code. The approved corrective action plan for CR M3-98-0575 will provide the reference after startup. The Slanificance Level is concluded to Printed 4/17/96 it:30:1s AM Page 2 of 4

ICAVP DR No. DR-MP3-0692 Ncrtheast Utiliti:s Millstone Unit 3 Discrepancy Report be Level 4.

The revised DR-MP3-0692 identified additional discrepancies.

The additional discrepancies do not change the conclusions of the calculations. The Significance Level for DR-MP3-0692 is Level 4 since there is no impact on LB, DB, or plant equipment.

Conclusion:

NU has concluded that the issue reported in Revised Discrepancy Report DR-MP3-0692 has identified additional discrepancies. The approved correction action plan for CR M3-98-0575 will revise calculation SDP-EGA-01342M3, rev. 2, after startup to (a) correct the previously identified discrepancies; (b) reference the correct isolation valves postulated to be inadvertently closed by an operator; and (c) provide a reference for the number of cycies for the Operating Conditions. The additional discrepancies do not change the conclusions of the ,

I calculations. The Significance Level for DR-MP3-0692 is Level 4 since there is no impact on LB, DB or plant equipment.

Previously identified by NU7 O Yee (8) No Non Discrepent Conditicn?U Yee (*) No Resolution Pending7O Yee @ No Reeoiuison unreeoived70 Yee @ No Review Initletor: Obersnel,Bojen.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 4/15/98 SL Cornments: S&L comments for first disposition:

NU disposition is not acceptable.

S&L does not agree with the disposition of the first discrepancy. l 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 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 temperature, as it is in this case (600 vs.130 degrees F, for the design temperature see table on page 14 of 21 of the calculation). Please provide specific corrective action and demonstrate that the piping stress analysis will not be affected.

S&L will agree with u a NU disposition of the third 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 be revised.

Printed 4/17/9611:30:17 AM Page 3 of 4

N:rtheast Utilities ICAVP DR No. DR-MP3 0692 j Millstone Unit 3 Discrepancy Report l S&L comments for second disposition: l S&L finds NU's second disposition for this Discrepancy Report l acceptable. In particular.

The disposition for item i is to revise the calculation to assume that for the Operating Condition 3 the manual isolation valves are inadvertently closed. Since the calculation presently defines the system conditions as if that was the case, the conclusion of the calculation will not be affected.

Regarding item 2, S&L agrees that in a case the air receiver tank relief valve is postulated to fail open, the operating conditions for the normal system lineup will have an insignificant effect on the system safety related piping temperature cycling, and thus will not I affect the piping stress analysis. S&L also agrees that the I corrective action for this discrepancy is deferrable. It is noted that the non safety related piping between the air compressor and the dryer (which is included in the calculation) will experience high pressure and temperature. S&L postulates that the calculation revision will also address this issue. Currently, the defined operating conditions for this failure correspond more closely to the conditions anticipated for the failure of the air compressor relief valve (this failure is postulated in the reference calculation P(T)-1042).

S&L agrees that the determination of the number of operating cycles (Discrepancy Report item 3) is extremely unlikely to affect i the piping stress analysis. Based on the anticipated modes and '

frequency of operation of the Emergency Diesel Generator

,tofJag air system (EOA), it l0 cat lcipcted that the icic! numbcr cf equivalent full temperature cycles over the system service life will be well below ASME Code allowable of 7000 for the stress range reduction factor of 1.0. Therefore, S&L agrees that the corrective

! action for this discrepancy is deferrable.

l Based on the NU disposition, S&L agrees that the calculation discrepancies noted in this Discrepancy Report do not affect either design or licensing basis, or operability of the system. The DR Significance Level was therefore reduced from Level 3 to Level 4. I i

Printed 4/17/9611:30:18 AM Page 4of 4 ,

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t ICAVP DR No. DR-MP3-0700 j N:rtheart Utilities Miitstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Discipiirw.: Electrical oesign Diecrepar,cy Type: Calculation System / Process: DGX NRC Significance level: 4 Date faxed to NU:

Date Published: 12/1N97 Discrepancy: Diesel Generator Wattmeter Accuracy (Calculation NL-41GE)

Descripuon: Calculation NL-041GE calculates the uncertainty associtated with the diesel generator wattmeters that are located on the main control panel and the diesel generator local panels as well as the plant computer, The range of instrument readings that could be indicated when the diesel generators are operated at important load limits are also calculated. We have the following comments on this calculation:

The calculation considered the ratio error of the instrument transformers. However, the phase errnt was not considered.

Since the wattmeter needs to perfomi vectorial multiplication of the voltage and current, phase errors also contribute to the inaccuracy of the measurement. In effect, the phase errors represent an error in the measured power factor (cosine of the angle between the voltage and current vectors) where the power is proportional to the magnitude of the voltage times the magnitude of the current times the power factor.

Section 4.14 of the calculation calculates the error due to the uncertainty of interpolatina between minor divisions when reading the analogue instruments (main control room wattmeter and diesel generator local panel wattmeter). The calculated error, taken to be % of a minor division is 1.15% for the wattmeters on the main control board and 1.25% for the wattmeter at the diesel generator local panel. The calculation then states " Calculated Readability error R using one-half of the minor division is greater than 1% of full scale, therefore,1% will be used". The calculation needs to justify reducing the calculated uncertainty.

The calculation states that temperature error is not applicable.

While it is true that the instruments are calibrated in a " normal environment" in which the normal temperature is in the lower 20's Celsius, typical indoor areas at Millstone can experience temperatures of 50-120*F (10-49'C), a range of nearly 40'C. l The temperature effect over such a temperature range can be 1 significant. Unless specific steps are taken to eliminate ,

temperature variations, any decision to neglect temperature j variations needs to be based on a review of the temperature  ;

range in the area that the equipment is located in and l Information on how the accuracy of equipment such as transducers is affected by temperature variations. i The calculation considers the measuring and testing error of the l instrument used to determine the transformation ratio of the l voltage transformers that drive the wattmeters and watt j Printed N17/9811:30.s9 AM l

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I N:rtheart Utilitica ICAVP DR N3. DR-MP3-0700 Millstone unk 3 Discrepancy Report l i the same instruments was also measured, and the measured error was used in the calculation. However, the measuring and l testing error associated with the current transformer ratio j measure was excluded from the calculations. The calculation should justify not considering the measuring and testing error i l associated with the current transformer ratio measurements. l l l The ratios of the voltage and current transformers were I measured under no-load conditions. The calculation includes an i

additional error to account for the effect of the instrument l l transformer burden. The burden errors are treated as random errors. However, the error from the current transformer burden will take the form of increased excitation current (except for unusual burdens). This will always act to reduce the output of the l current transformer. The error due to the burden on the voltage l l transformer will take the form of IZ voltage drop, which will reduce the output of the voltage transformer for normal burdens.

The calculation should take the unidirectional behavior of the l burden error into account.

Most of the input data has a nominal tolerance in the order of tenths of per cent. This implies four significant figures. However, some of the test data and the calculations use fewer significant

! figures.

Review Valid invalid Needed Date l

i Initiator: Bloethe, G. William B O O 1 r2 ara 7 VT Lead: Neri, Anthony A B O O 11r2in7 VT Mgr: schopfer. Don K G O O 12/ss7 IRc Chmn: Sngh, Anand K y ] ] iLGe7 Date:

INVALID:

Date: 4/16/98 RESOLUTION: INITIAL RESPONSE:

NU has concluded that issues #2,3 and 5 in Discrepancy Report, DR-MP3-0700, have identified conditions not previously discovered by NU which require correction.

Issue # 2 The objective of the calculation is to determine the use of the l Instrument (wattmeter in the MCB, EDG or the plant computer) that has the least uncertainty to conduct Technical Specifications Surveillance 4.8.1.1.1.2 testing of the EDG's.

l NU agrees that the calculation needs to be modify to justify reducing the calculated uncertainty. This is considered a clanfication change as the slight reduction of the uncertainty does not affect the result of the calculation.

Printed 4/17/9811:31:03 AM Page 2 of 7

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N:rtheast Utilitie3 IC VP DR No. DR-MP3-0700 Millstone Unit 3 Discrepancy Report i issue # 3 1 l l The ambient temperature of all three types of wattmeters is that l of the Main Control Room for the wattmeter on the MCB and the I computer point and the Diesel Generator Room. The temperature environment within these rooms will not be a factor affecting the uncertainty of the devices. These wattmeters are installed in a ' mild" environment for temperature per Engineering Specification SP-M3-EE-0333. A ' mild" environment is an i environment that would at no time be significantly more severe l l

than the environment that would occur during normal plant

! operation or during anticipated operational occurrences.The i calculation modification will justify why temperature error is not l applicable and more clarification will be added to the calculation.

l Issue # 5 NU believes that the additional error of 0.3% to account for the error due to loading is adequate.

l The revised calculation will demonstrate that the additional error l 1

(0.3%) taken in the calculation is sufficient to cover burden error. J Condition Report (CR) M3-97-4709 was written provide necessary corrective actions to resolve the issues #2,3 and 5.

The approved corrective action plan for CR M3-97-4709 will 7020 00:00! 'J03 NL 00CE t0 ^^ndehe 0^00t!"tM ^^d temperature effects. These corrections will be completed post startup. These errors are not significant and corrections are considered enhancements which will not affect the result of the l calculation. Therefore, NU considers this to be a Significance Level 4 issue.

l NU also concluded that issues # 1 and 4 in Discrepancy Report ,

DR-MP3-0700, do not represent discrepant conditions.

Issue # 1 The power factor error ( phase error) is already included as part of the CT, PT and wattmeter error.

Issue # 4 Section 4.17 : Other effects states : "the average wattmeter circuit CT ratio error for the three phases is 1.3% for the 'A' EDG and 1.6% for the 'B' EDG and the average computer circuit CT

) ratio error is 0.8% for the 'A' EDG and 0.3% for the 'B' EDG .

Based on the test results this error is predicted to be on the negative side and will be added algebraically as bias error." On the 4th paraaraoh of the same section the total bias error is Printed 4/17/9811:31:04 AM Page 3 of 7

r Ntrtheast Utilities ICAVP DR N2. DR-MP3-0700 Millstone Unit 3 Discrepancy Report computed as follows:"The total bias error TBE is the sum of the l average CT and PT ratio errors. Therefore TBE in wattmeter '

circuit is 1.7% (1.3+0.4) for EDG 'A' and 2.0% (1.6+0.4) for EDG l

'B' and TBE in computer circuit is 1.2% (0.8+0.4) and 0.7%

(0.3+0.4) for EDG 'B'. .

1 in summary, the limits are:

Limits =[EDG Rating +/- (Error x Full Meter Scale))- [EDG Rating x TBE]

Therefore the CT ratio errors are included in the Calculation.

Based on the above, Significance Level criteria do not apply as

issues # 1 and 4 do not represent a discrepant condition.

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l 1 l SECOND RESPONSE:

Disposition:

l l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0700, has identified conditions not previously j discovered by NU which require correction. j I

Calculation NL-041GE " Wattmeter Circuit Accuracy for Diesel l Generator Rating" determines the instrument uncertainty errors

s:::::::d ;dth th: E, :crgency Dl:: ! C : rcter:: (ECD)

~

wattmeter circuits. These uncertainty errors are used to l determine which indication (e.g., Main Control Board (MCB),

EDG, or Plant Process Computer) provides an operating band above the Technical Specifications limits while not exceeding ,

the manufacturer rated limits. Considering the resulting uncertainty errors, the calculation concluded that the plant process computer provided the desired indicating band that l should be used in the EDG loading surveillance to verify Technical Specifications Limits.

I While reviewing calculation NL-041GE It was determined that non-conservative assumptions and methodologies were used in establishing the instrument uncertainty errors. Condition Report (CR) M3-98-1818 dated April 6,1998, was written to document l and provide the necessary corrective actions to resolve these I

calculation discrepancies. Additionally, the Operability Determination (attached) for the CR recalculated the instrument  :

uncertainty errors preliminary to determine the magnitude of the ,

instrument uncertainty errors and the impact on the DG 1 surveillance as a result of these non-conservative assumptions and methodologies. Using conservative assumptions and  ;

methodologies to bound the instrument uncertainty errors for 1 both EDGs it was concluded that the indication provided by the plant process computer is still within the Technical Specifications  !

limits while not exceeding the manufacturer rated limits. The  ;

chanae in instrument uncertaintv errors due to these non- l Printed 4/17/9811:31:05 AM Page 4 of 7  !

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ICAVP DR No. DR-MP3-0700 N::rtheast Utilities Millstone Unit 3 Discrepancy Report conservative assumptions and methodologies are predominantly associated with the MCB wattmeter indication circuit. Therefore, the Technical Specification surveillance testing criteria for the EDGs was not adversely impacted.

The approved Corrective Action Plan for M3-98-1818 will revise calculation NL-041GE to correct the non-conservative assumptions and methodologies and to clearly identify the basis for the instrument uncertainties that must be included in the calcu!ation. Issues 1 and 4 raised by Sargent & Lundy in the follow-up response will be considered while revising the calculation. These corrections will be completed post startup.

These errors do not change the conclusions of the calculation.

Therefore, NU considers this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0700, has identified conditions not previously discovered by NU which require correction. Condition Report M3 98-1818 has been written with its corrective actions approved to revise calculation NL-041GE to correct the non-conservative ,

assum-ptions and methodologies and to clearly identify the basis  !

for the instrument uncertainties that must be included in the I calculation.

O'!nO CONS?V?!b!? 999'm^H^n? 9nd mothndninnix in hnund ,

the instrument uncertainty errors for both EDGs it was concluded  ;

that the indication provided by the plant process computer is still within the Technical Specifications limits while not exceeding the manufacturer rated limits. The change in instrument uncertainty errors due to these non-conservative assumptions and methodologies are predominantly associated with the MCB wattmeter indication circuit and not the plant process computer. l Therefore, the Technical Specification surveillance testing criteria for the EDGs was not adversely impacted by using these non-conservative assumptions and methodologies. These errors do not change the conclusions of the calculation. Issues 1 and 4 raised by Sargent & Lundy in the follow up response will be considered while revising the calculation. Base on this corrective  ;

actions will be implemented post startup.NU considers this to be I i

a Significance Level 4 issue.

Previously identined by NU? O Yes @ No Non Discrepant Condition?O Yes @ No I

Resolution Pending?O ve. @ No ne.oiution unre.oived?O ve. @ No Review initiator: Wamer, I.

VT Lead: Neri, Anthony A VT Mgt: schopfer, Don K IRc chmn: Singh, Anand K Date: 4/18/98 Printed 4/17/9811:31:06 AM Page s of 7 l

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N::rtheast Utilities ICAVP DR N2. DR-MP3-0700 Millstone Unit 3 Discrepancy Report sL comments: INITIAL COMMENT:

l

! We concur with NU's statement:

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" Condition Report (CR) M3-97-4709 was written provide necessary corrective actions to resolve the issues #2,3 and S.

l l The approved corrective action plan for CR M3-97-4709 will revise calculation NL-041GE to consider the uncertainties and temperature effects. These corrections will be completed post startup. These errors are not significant and corrections are considered enhancements which will not affect the result of the calculation. Therefore, NU considers this to be a Significance Level 4 issue."

We do not concur with NU's statement that Issue's # 1 and 4 do not represent a discrepant condition.

NU states:

Issue # 1 .

The power factor error (phase error) is already included as part i of the CT, PT and wattmeter error.

We re-reviewed the calculation and could not determine where the power factor error is included in the calculation.

To-eddren th!: !!!ue, MU "eedS !^ Sp"C!Sc?!!y def ne where la the calculation power factor error is included.

Issue # 4 NU states: Section 4.17 : Other effects states : "the average wattmeter circuit CT ratio error for the three phases is 1.3% for the 'A' EDG and 1.6% for the 'B' EDG and the average computer circuit CT ratio error is 0.8% for the

'A' EDG and 0.3% for the 'B' EDG . Based on the test resuits this error is predicted to be on the negative side and will be added algebraically as bias error." On the 4th paragraph of the same section the total bias error is computed as follows: "The total bias error TBE is the sum of the average CT and PT ratio errors. Therefore TBE in wattmeter circuit is 1.7% (1.3+0.4) for EDG 'A' and 2.0% (1.6+0.4) for EDG 'B' and TBE in computer circuit is 1.2% (0.8+0.4) and 0.7%

(0.3+0.4) for EDG 'B'.

It's not clear from NU's response how Measuring and Testing Error is addressed in the response.

COMMENT ON NU'S SECOND RESPONSE:

l We have no comments on NU's second response. l Printed N17/9e 11:31:07 AM Page 6 of 7 1

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Printed N17/9611:31:08 AM Page 7 of 7

i N:rthe::t Utilities ICAVP DR N2. DR-MP3-0701 Millstone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED l Potential Operability issue ,

Discipline: Electrical Design l

Discrepancy Type: Licensing Document Om System / Process: DGX g

l l NRC Significance level: NA Date faxed to NU:

Date Published: 1/3/96 Discrepancy: Discrepancy with Branch Tech Pos PSB Adequacy of Station Electric Distribution System Voltages

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 from the offsite power system..

Discussion:

When iho ihaiiinio delay Goiay ^2H-)iniico ewi end en ed,,doni 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 f ESK-07L Rev 24 Elementary Diagram - 4.16kV Bus 34D j

IV Alct*RW(4.R1 Any ('irr nit Printed 4/17/9611:31:33 AM Page 1 of 4

I N:rthrast Utilities ICAVP DR Ns. DR-MP3-0701 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 l

l 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 3EGSA01 [3EGS*G-A] j ESK-08KF Rev 12 125V DC Emer Diesel Gen Start Ckts

! Ckt 3EGSBO1,2 [3EGS*G-B]

l Calculation NL-040 Rev1 Undervoltage Protection Scheme ,

Relay Settings for Millstone 3 I Calculation NL-042 ReV 2 Mills .ne Unit 3: Degraded l

Voltage Protection Scheme Relay Settings i Review i Valid invalid Needed Date i Initiator: Wamer,1.

8 O O 12/s/97 VT Lead: Neri, Anthony A G O O 12/11/97 VT Mgr: schopter, Don K O O O 12/11/97 1RC Chmn: singh, Anand K 8 O O 12/24/97 ,

Date:

INVAUo: l Date: 4/16/98 RESOLUTION: INITIAL RESPONSE:

Disposition: l NU has concluded that the issue reported in Discrepancy Report 1 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 willimmediately separate the Class 1E distribution (Buses 34C & 34D) from the offsite power system (NSST) which is the intent of the statement in the FSAR.

Printed 4/17/9611:31:37 AM Page 2 or 4

i 1

N:rthert Utilitie3 ICAVP DR No. DR-MP3-0701 l Millstone Unit 3 Discrepancy Report The logic path described in the " Discussion" section of the DR is i a description of the relay events that occur in the tripping and 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.

SECOND REPSONSE Disposition:

NU has concluded that the issue reported in Discrepancy Report, j DR-MP3-0701, does not represent a discrepant condition.

Millstone 3 is in full compliance with Regulatory Guide 1.93 which discusses that the Limiting Conditions for Operation with respect to available electric power sources is an electric power system that satisfies General Design Criterion 17 (GDC-17),

" Electric Power Systems, of Appendix A, General Design Criteria for Nuclear Power Plants, of 10CFR50 by including the following i electric power sources: (1) two physically independent circuits l from the offsite transmission network, each of which is either {

continuously available or can be made available within a few seconds following a loss of coolant accident (LOCA), (2) redundant onsite a.c. power supplies, and (3) redundant onsite l d.c. power supplies. R.G.1.93 requires that both connections to the offsite power system be automatically available. The first conneci!cn !c through 'he MSST "'he generator Lverker opened. The second connection is through the RSST. Since the only automatic transfers available (clow and fast) are from ine NSST to the RSST, Millstone 3 must operate normally on the NSST. Technical Specification 4.8.1.1.1.b surveillance ,

requirement specifically requires that the unit power supply be i transferred from the normal to the attemate power supply both manually and automatically once every 18 months. Clearly the NSST is the normal supply and alignment for unit power. LCO 3.8.1.1.a action statement limits the time one offsite circuit may be Inoperable before adhering to the actions of the LCO statement. This clarification does not change the conclusion of the initial DR disposition. ,

I Significance level criteria does not apply here as this is not a l discrepant condition.

Conclusion:

l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0701, does not represent a discrepant condition.

R.G.1.93 requires that two connections to the offsite power system be automatically available. The first connection is through the NSST with the generator breaker opened. The second connection is throuah the RSST. Since the only Printed 4/17/9811:31:38 AM Page 3 of 4

Nsrthext Utilities ICAVP DR No. DR-MP3-0701 Millstone Unit 3 Discrepancy Report automatic transfers available (slow and fast) are from the NSST to the RSST, Millstone 3 must operate normally on the NSST.

LCO 3.8.1.1.a action statement limits the time one offsite circuit i may be inoperable before adhering to the actions of the LCO '

statement. This clarification does not change the conclusion of i the initial DR disposition.

Significance level criteria does not apply here as this is not a discrepant condition.

Previously identified by NU7 O vee @ No Non Diecrepant Condition?@ vee U No Resolution Pending?O vee @ No Resolution Unresolved?O vee @ No Review initiator: Warner, l.

VT Lead: Nerl, Anthony A O O **

VT Mgt: Schopfer, Don K 1RC Chmn: Singh, Anand K pate: 4/16/98 st Comnents: INITIAL 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 ESF (possible tech spec time clock) or that the FSAR statement 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 primary and backup feeds?

COMMENTS ON NU'S SECOND RESPONSE.

We have not comments on NU's second response. j l

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Printed 4/17/9811:31:40AM Page 4 of 4 o

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N:rthertt Utilities ICAVP DR N3. DR-MP3-0737 Millstone Unit 3 Discrepancy Report  ;

l Review Group: Conriguraten DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: I & C Design Discrepancy Type: Installation Irnplernentaten Om {

1. No .

l system / Process: Qss NRC significance level: 4 Date faxed to NU:

l Date Published: 1/3/9e Discr*Poney: Instrument Labeling l l

Description:

The following labeling inadequacies with respect to design f documents and requirements of Procedure OA-9, " System and i i

Component Labeling," were noted during system walkdowns and i drawing review.

l Instrument 3QSS-FTE328 does not have an identification tag.

The sensing line, however, is identified. The installation is shown on drawing BK 16F-54-1 Rev.10.

i This drawing, BK-16F-54-1 Rev.10, (NUSCO number 25212-28889-00054) has had it number altered such that it now reads BK-16F-54-10. This is in consistent with its identification is GRITS and common numbering for this type of drawing.

Review Valid invalid Needed Date initiator: sarver, T. L B O O 2/i/97 VT Lead: Nort, Anthony A B O O 12/9/97 VT Mgt: schopfer, Don K O O O 12tts/97 l IRC Chmn: singh, Anand K B O O $2/2+97 c ..

INVALID:

Date: 4/16/98 RESOLUTION: INITIAL DISPOSITION:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0737, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0511 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0737, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0511 Printed N17/9611:32:23 AM Page i of 3

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ICAVP DR N3. DR-MP3-0737 l Ncrthent Utiliti:2 l Millstone Unit 3 Discrepancy Report has been written to develop and track resolution of this item per RP-4.

FINAL DISPOSITION:

l l Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0737 does not represent a discrepant condition.

l U3 Pl 20 section 1.3.2 e defines the type of labeling discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.NU concludes that the assignment of priority 4 is correct and in accordance with U3 Pl 20 section 1.3.2 e.

Significance level criteria does not apply to the new issue as this is not a discrepant condition.CR M3-98-0511 was closed to CR l M3-98-0165. The corrective actions in CR M3-98-0165 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4.

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR MP3-0737 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in CR M3-98-0165 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identified by NU? O ves (#) No Non Discrepant Condition?U ves (G) No Resolution Pending?O ve.

• No Resolution Unresolved?O ve. @ No l Review I Acceptable Not Acceptable Needed Date

! VT Lead: Neri, Anthony A I VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 4/16/98 sL comments: INITIAL COMMENT:

Based on CR M3-98-0737 it is not apparent why the labeling changes can be deferred based on the deferral criteria.

" Plant labeling discrepancies which have a direct impact on plant Printed N17/9611:32 27 AM Page 2 of 3

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ICAVP DR N3. DR-MP3-0737 N:rtheart Utilities Millstone Unit a Discrepancy Report i

configuration, operation or pr ,onnel safety. Other labeling i discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred."

FINAL COMMENT:

We have no comments on NU's second response.

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f Nutheart Utilities ICAVP DR N3. DR-MP3-0767 Millstone Unit 3 Discrepancy Report Review Group: sptem DR RESOLUTION ACCEPTED Re h h e s

• W Potential Operability Issue Discip'ir,e: Mechanical Design Discrepancy Type: Licensing Document O ws Systern/ Process: Rss @ No NRC Significance level: NA Date faxed to NU:

j Date Published: 1/22/96 Discrepancy: Use of 1187 gpm as the RSS Flow Supplied to the HHSI Pumps l

for ECCS Cold Leg Recirculation Mode

Description:

Sections 8.2,8.3, and 12.2.2 of 3DBS-NSS-003, Rev. O require the RSS system to supply a minimum of 1187 gpm to the HHSI {

l pumps during ECCS Mode B, Cold Leg Recircirculation (REQ- j MP3-RSS-0417,0527, and 0528). This requirement is based on )

Calculations US(B)-253,266,273 and 342. (

US(B)-342, Rev.1/CCN 1, references a telephone conference memo from Westinghouse Fluid System's Bob Magee, dated 1-28-86," Safety injection Flows from the HHSl and Charging Pumps." This telephone memo states that the total flow for the ECCS cold leg recirculation mode is 1187 gpm per train. US(B)- l 342 uses this flow to determine the RSS heat exchanger UA for l min. ESF (Case 3) and max. ESF (Case 4).

Calculation US(B)-253, Rev. 4, also references the telephone conference memo from Westinghouse Fluid System's Bob Magee, dated 128-86 as the basis for assuming a 1187 gpm l flow for each train of ECCS for the cold leg recirculation mode. I US(B)-273, iiuv. 5 usca 1187 upm ivi iiic min. ESF iivw ivi ECCS cold leg recirculation mode in the design basis analysis of containment pressure and temperature after a postulated LOCA. ,

(

The US(B)-273 cites US(B)-342 and 253 as the references for this flow.

US(B)-266, Rev. 2 uses twice 1187 gpm, or 2374 gpm, for the max. ESF flow for ECCS cold leg recirculation mode in the '

design basis analysis of containment pressure and temperature after a postulated MSLB. The US(B)-266 cites US(B)-342 and 253 as the references for this flow.

RSS hydraulic calculations US(B)-245, Rev. 0/CCN 3 and US(B)-

311, Rev. 0/CCN 1 do not provide information on this operating mode. No basis, except the Westinghouse telephone memo, was found for using 1187 gpm as the flow for each train of HHet during ECCS cold leg recirculation mode (see DR-MP3-0710).

A telephone memo is not an appropriate basis for this type of infom1ation.

Review Valid invalid Needed Date Initiator: Wakeland, J. F. 8 O O 12ii2/97 VT Lead: Nort, Anthony A B O O 12/is/97 VT Mgr: schopfer, Don K G O O 1/12/98 O O ' 7/S8 1RC Chmn: singh, Anand K G Printed 4/17/9811:32:56 AM Page 1 of 4

i ICAVP DR No. DR-MP3 0767 N rtherst Utilitle3 i Millstone Unit 3 Discrepancy Report  !

cate:

lNVAUo:

Date: 4/1/98 REsOWTION: DISPOSITION:

NU has concluded that the issue reported in Discrepancy Report, l DR-MP3-0767, does not represent a discrepant condition. The I records were examined to verify that the value of 1187 gpm was valid at the time. This parameter represents the minimum value of flow in this condition. It is the sum of the minimum value of safety injection pump flow and the minimum value of charging pump flow. The value of 650 gpm safety injection pump flow is l j

taken from the Plant Technical Specifications, and is the lesser l of the A and B required flow values. The value of 537 gpm charging pump flow was taken from the Startup Test Report (see attached pages of the completed T3304AP002). Test criteria 2.6 for the test calls for the weakest pump to deliver 457 gpm. (Note that this was modified from 470 gpm by change #43) This flow rate, plus 80 gpm for seal flow required by test criteria 2.5, results in a minimum of 537 gpm drawn from the containment sump. Test results recorded on 3/22/85 show a total flow of 539.13 gpm and seat flow of 79.45 gpm. The net flow of 458.68 ,

gpm falls within the +3-0 gpm tolerance set in the criteria. These j results validate the use of 537 gpm as the minimum value of j flow that is expected under the circumstances. Thus, the sum of I the two flow values,650 gpm + 537 gpm = 1187 gpm, is indeed the 1187 gpm which was related in the subject telecon. Thus no adverse condition was introduced by this telecon.

The practice of transrnitting key input data for calculations by telephone is regrettable. However, in 198611was an accepted industry practice. Today it is not an acceptable method, and l NU's Design Control Manual makes this clear (DCM, Chapter 8, Engineering Vender Interfaces).

This particular value of flow is developed by Westinghouse in conjunction with the ECCS calculations. It is transmitted by Westinghouse to Stone & Webster, who use it as an input to various containment calculations. The value in use has been changed at least twice since 1986, as a result of differing assumptions and conditions. In the current set of calculations Westinghouse has transmitted values of flow resistance, and allows Stone & Webster to develop their calculations based on this data. Westinghouse letter NEU-97-247 formally transmitted the latest values to S&W. This was verified by obtaining the attached copy from the S&W files in Boston. This establishes that current practices do indeed meet the DCM requirements in this case. The values of flow included in this letter are only slightly different from the 1986 values, as follows:

1986 650 gpm + 537 gpm = 1187 gpm 1997 675 gpm + 540 gpm = 1215 gpm Significance level criteria do not apply here as this is not a Printed 4'17/9611:33.00 AM Page 2 of 4

r ICAVP DR No. DR-MP3-0767 N:rtheast Utilities Millstone Unit 3 Discrepancy Report discrepant condition.

CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0767, does not represent a discrepant condition. The sources of the data involved have been identified and verified to have been correct at the time. Since then, changes in methods of analysis have led to small changes. The value used presently is 1215 gpm, or 28 gpm greater. The current data was transmitted by letter, in accordance with NU's procedures on this subject, which postdate the telecon.No discrepancy was introduced through the use of the data in this telecon. In the future no design data will be transmitted in this manner, so the problem is not expected to reoccur. Significance level criteria do not apply here as this is not a discrepant condition.

Previously klentifled by NU? O Yes (#J No Non Discrepent Condition?(P) Yes Q No R muon Pendina?O vee @ No Res&uon Unroe&ed?O vos @ wo Review Acceptable Not are.ps.haa Needed Date inMiator: Wakeland, J. F.

N1/96 VT Lead: Neri, Anthony A N162 VT Mgr: schopfer, oon K IRC Chmn: Singh, Anand K B O N16m O O O Date: 4/1/98 l sL Comments: Sargent & Lundy concurs that DR-MP3-0767 is not a discrepant condition. In 1986, it was the industry practice, on some l occaisions, to accept unsignea telepnone memos as design L.=

transmittals. The current design basis ECCS flow for containment pressurization analysis is provided by Westinghouse Letter NEU-97-247, dated 6-25-97: 1233.6 gpm for the Min. ESF l

t cold leg recirculation mode and 1215 gpm for the Min. ESF hot leg recirculation mode.

l The ECCS recirculation flows computed using Stone & Websters hydraulic model are very close to the flows identified in the conclusions of the Westinghouse hydraulic evaluation, SAE/FSE-l C-NEU-0143, transmitted by Westinghouse Letter NEU 97-327E.

Calculation US(B)-361, Rev. 2 documents this comparison. The Min. ESF ECCS recirculation mode cases of the two models were l not compared; however, the close agreement of the two cases l which were compared indicates that Stone & Websters calculation of ECCS flow is consistent with the Westinghouse design basis.

t Stone & Websters hydraulic model in US(B)-361 is used as input to the containment pressurization analysis. Westinghouse's hydraulic model in SAE/FSE-C-NEU-0143 provides input to the Appendix K ECCS analysis.

In the containment design basis, the worst-case ECCS cold leg reciculation mode condition is 1176 gpm flow to the cold legs, from US(B)-361, Rev. 2, Case 9, minimum RSS flow to Page 3 of 4

_ Printed N17/9611:33.01 AM

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N:rthext Utilities ICAVP DR N3. DR-MP3-0767 Millstone unit 3 Discrepancy Report containment. US(B)-273, Rev. 6/CCN 2, the LOCA containment pressurization analysis, uses 1175 gpm as the flow to the cold legs for this worst case scenario. This 1 gpm error was accepted in the ICVAP review of US(B)-273 because it is an insignificant transcription error (and is conservative for the purposes of calculating the maximum containment pressure and temperature).

The ICAVP review of modification MS-97045 did not determine if the RSS system design basis summary document was updated to reflect the new design basis ECCS cold leg recirulation flow.

Changes to the FSAR and design basis summary documents are being held by NU for final approval. NU plans to issue these change documents within 30 days of the modification closeout, as allowed by administrative procedure, l

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N:rtheast Utilities ICAVP DR N3. DR-MP3-0817 Millstone unit 3 Discrepancy Report Review Group: Configurabon DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: I & C Design Discrepancy Type: Installation Implementabon System / Process: Qss NRC Signmcance level: 4 Date faxed to NU:

Date Published: 1/1o/98 Discrepancy: Instrument labeling

Description:

Procedure OA-9 Revision 1 provides the directions for the correct pisnt labeling procedure for all components. The procedure provides guidance to maintain a standanjized Labeling Program for Millstone Station and indicates that all field devices be labeled. Contrary to these requirements, as part of the physical plant walkdowns, the following instruments were found to not be labeled in the field.

DO3OSS*LS54B OO3RSS-PS41A O O3RSS-PS41B )

O O3QSS-LD/931 i OO3OSS-LD/932 l Review l Valid invalid Needed Date )

initiator: Sarver, T. L 8 O O 2/1 T/97 VT Lead: Neri, Anthony A B O O 12/18/97 l VT Mgt: Schopfer, Don K B O O 12/23/97 l

1RC Chmn: singh, Anand K O O O 12/31/97  ;

I r&

INVAllD:

Date: 4/16/98 j RESOLUTION: Disposition:

INITIAL RESPONSE:

NU has concluded that Discrepancy Report, DR-MP3-0817, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0511 has been written to develop and track resolution of this item per R P-4.

1

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0817, 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 M3-9S 0511 Printed 4/17/9811:33:42 AM Page 1 of 3

ICAVP DR N2. DR-MP3-0817 N::rtheact Utilities Milistone Unit 3 Discrepancy Report has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0817 does not represent a discrepant condition.

U3 Pl 20 section 1.3.2 e defines the type of labeling discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

NU concludes that the assignment of priority 4 is correct and in accordance with U3 Pl 20 section 1.3.2 e. Significance level criteria does not apply to the new issue as this is not a discrepant condition.

CR M3-98-0511 was closed to CR M3-98-0165. The corrective actions in CR M3-98-0165 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4.

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0817 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in i CR M3-98-0165 will correct these issues post startup. NU  !

considers the overall classification of the DR to be significance level 4.

Previously identifled by NU? O Yes (n) No Non Discrepant Condition?O Yes (I) No l Resolution Pending?O Y @ No Re.oiution unr.soiv.d?O Ye. @ No Review initiator: Wamer,1. l VT Lead: Neri, Anthony A l VT Mgr: schopfer, Don K , l 1RC Chmn: s@, Anand K O O -

Date: 4/16/98 l sL Comments: INITIAL COMMENT:

Based on CR M3-98-0511 is is not apparent why the labeling changes can be deferred based on the deferral criteria.

Printed 4/17/9611:33:46 AM Page 2 of 3

Nerthenst Utilitie3 ICAVP DR No. DR-MP3-0817 Millstone Unit 3 Discrepancy Report

" Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred."

COMMENTS ON NU'S SECOND RESPONSE:

We have no comments on NU's second response.

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Printed N17/9811:33:47 AM Page 3 of 3

i N:rthenst Utilitie3 ICAVP DR No. DR-MP3-0905 Millstone Unit 3 Discrepancy Report Review Group: Configurabon DR RESOLUTION ACCEPTED l Review Element: System Installation Potential Operabliity lasue l Discipline:I & C Design Discrepancy Type: Instaastion implementation Om System &rocess: HVX

@ No NRC Signincance level: 4 Date faxed to NU:

Date Published: 1/2596 Discrepancy: Component Labeling not in accordance with requirements.

Description:

Procedure OA-9 Revision i requires the labeling of all plant components. Contrary to these requirements, the following discrepancies were observed during system walkdowns:

1. Recorders 3HVR*RR10A,3HVR*RR108 and 3HVR*RR16A

located in panel 3RMS*RAK1 A and Recorders 3HVR*RR19A, 3HVR*RR198 and 3HVR*RR16B located in panel 3RMS*RAK1B do not have an identification tag showing this Numbers. These instruments have vendor identifications tag numbers RIC 184, RIC 2&5, and RIC 3&6, however, the vendor identification tag numbers called for on drawing 2474.030-624-193 Rev F is REC 184, REC 2&S, and REC 3&6.

2. Based on design documents, the instnJments listed below are in panel 3CES*lPNLl20 at the indicated locations. There is no nest identification and/or card identification as shown on drawing 2472.710-392-519 Rev C in the panel.

3HVP*TY29A2, Nest 1, Slot 3 3HVP*TY29A4, Nest 1 Slot 5 3HVP*TY29A5, Nest 1, Slot 6 3HVP*TY29A7, Nest 2, Slot 9 3HVP*TY29A8, Nest 2, Slot 10 3HVR*TY45A1, Nest 2, Slot 2 3HVR*TY45A10, Nest 1, Slot 9 6 3HVR*TY45A12, Nest 3, Slot 1 l 3HVR*TY45A2, Nest 2, Slot 4 j 3HVR*TY45A6, Nest 2, Slot 8 3HVR*TY45A7, Nest 1, Slot 6 .

3HVR*PY104A1, Nest 2, Slot 6 3HVR*PY104A2, Nest 3, Slot 1 3HVR*TY29A6, Nest 1, Slot 7 3HVR*TY45A, Nest 2, Slot 3 3HVR*TS45A1 3HVR*TS45A2 l l

3. The instruments listed below are located in panel 3CES*lPNLl21 and there is no nest identification and/or card identification as represented on drawing 2472.710-392-520 Rev D:

3HVR*PY104B2, Nest 1, Slot 10 3HVR*TC458, Nest 2, Slot 3 3HVR*TS45B1, Nest 4, Slot 1 3HVR*TS45B2, Nest 4, Slot 1 o u.u. o. ,. r. v. ,' 6W. , "_". .'.-~ . " "' ' I g ..

p g4

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Nsrthe:st Utiliti2s ICAVP DR No. DR-MP3-0905 Millstone Unit 3 Discrepancy Report 3HVR*PY104B1, Nest 2, Slot 1 3HVR*TY45B10, Nest 2, Slot 7 3HVR*TY45811, Nest 1, Slot 9 3HVR*TY45B12, Nest 1, Slot 10 3HVR*TY45B13, Nest 3, Slot 7 3HVR*TY4582, Nest 2 Slot 4 3HVR*TY45B3, Nest 2, Slot 6 l 3HVR*TY4584, Nest 2, Slot 5 3HVR*TY4585, Nest 2 Slot 6 3HVR*TY45B6, Nest 2 Slot 8 3HVR*TY45B7, Nest 2, Slot 6 1 3HVR*TY45B8, Nest 2, Slot 5 3HVP*TC29B, Nest 1, Slot 2 ,

3HVP*TY2981, Nest 1, Slot 1 l

3HVP*TY2982, Nest 1, Slot 3 1 3HVP*TY29B3, Nest 1, Slot 4 3HVP*TY2984, Nest 1, Slot 5 3HVP*TY2985, Nest 1. Glot 6 l

3HVP*TY29B6, Nest i . ilot 7 i 3HVP*TY2987, Nest 2, Slot 9 i

3HVP*TY2988 Nest 2, Slot 10 In addition, instrument cards marked 3HVR*PDS208A and l 3HVR*TY45A13 were observed in nest 3, slot 3 and nest i slot 10 respectively. PDS208A was to be discontinued per PDCR 92-l 103 and TY45A13 is an "A" train component. These instruments are not shown in these location on the referenced drawing.

l 4. Instruments 3HVR-TC185A and 3HVR-TC1858 are not Mc:15cd ccrrectly !" the 50!d. ]

5. Procedure OA 9, paragraph 1.14 provides the specific instructions for labeling of abandon equipment. Instruments 3HVR*FS27A,3HVR*PDT208A, and 3HVR*PDT208B have been abandoned in place and they do not have the required labeling.

6. The following differences between the installed components that the requirement of the referenced design documents were i noted during system walkdowns for field installed instruments: l 3HVR TIS 109A,1098,109C, and 110. Vendor drawing 1179-2472.900-609-249, Rev. B, indicates that an expanded metal (16 gauge) protective screen is to be mounted over the sensing bulb and that the sensing bulb is to be mounted using a % inch conduit clamp, with insulating tape sleeve, and in an upward direction. The protective screen could not be found and the instrument is not as described on the Vendor drawings.

Review l Valid invalki Needed Date initiator: server, T. L 8 0 0 iii2/se 1'1 *S8 VT Leed: Neri, Anthony A G O O VT Mgr: schopfer, Don K G O O 1i sese IRC Chmn: singh, Anand K 9 0 1/22/98 Date:

INVALID:

Printed N17/9e 11:34:37 AM Page 2 of 4 E.

N rtheast Utilities ICAVP DR No. DR-MP3-0905 Millstone Un!t 3 Discrepancy Report I

Dde: 4/16/98 RESOLUTION: INITIAL RESPONSE:

l Disposition:

l NU has concluded that Discrepancy Report, DR-MP3-0905 nas 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 I concems and meets the Unit 3 deferral criteria. CR M3-98-0654 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0905 has identified a condition not previously discovered by NU which i requires correction. This discrepancy meets the criteda 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 M3-98-0654 has been written to develop and track resolution of this item per RP-4.

I SECOND RESPONSE:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0905 does not represent a discrepant condition.

U3 Pl 20 section 1.3.2 e defines the type of labeling l

discrepancies which will be completed during the next refuelmg outage or later. Attachment 11 defines the type of labeling issues ,

which will be completed prior to startup. The intent of attachment l 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

NU concludes that the assignment of priority 4 is correct and in accordance with U3 Pl 20 section 1.3.2 e. Significance level criteria does not apply to the new issue as this is not a discrepant condition.

CR M3-98-0654 was closed to CR M3-98-0165. The corrective actions in CR M3-98-0165 will correct these issues post startup.

NU considers the overa'l classification of the DR to be significance level 4.

Conclusion:

Printed 4/17/9611:34.38 AM Pege 3 of 4

ICAVP DR No. DR-MP3-0905 N:rthaart Utilitira Milistone unit 3 Discrepancy Report NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0905 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The cotTective actions in CR M3-98-0165 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identifled by NU? O Yes (G) No Non Discrepant Condition?Q Yes (G) No Resolution Pending?O ve. @ so Re.oiution unre.oived?O ve. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nett, Anthony A VT Mgr: schopfer, Don K lRC Chmn: singh, Anand K Date: 4/16/98 st Comments: INITIAL COMMENTS:

Based on CR M3-98-0654 is is not apparent why the labeling changes can be deferred based on the deferral criteria.

" Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred."

COMMENTS ON NU'S SECOND RESPONSE:

We have no comments on NU's second response.

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1 i Printed 4/17/9611:34:30 AM Page 4 of 4

f ICAVP DR No. DR-MP3-0921 N rthest Otilitica Miiistone unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System installation Potential Operability issue Discipline: Electrical Design Qy, Discrepancy Type: Installation li@wW G No System / Process: HVX NRC significance level: 4 Date faxed to NU:

Date Published: tr25/90 Discrepancy: Conduit Support Spans in Excess of Allowable

Description:

Drawing 12179-BE-52AS, Rev. 4, Note 65 provides guidance on the use of flexible conduit mid-run and requirements for such applications. The maximum allowable length of flex is 4 feet, maximum distance to the first support is 2 feet and the maximum distance to the next support is 3 feet ( the " rigid back l span"). With respect to these requirements, the following field l conditions were noted.

1. Rigid back span of conduits shown on FSK AB-3331, Rev.1 A is 4'-10". Rigid part of flex span is 1'-10" but is limited to 1'-0".

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2. Conduit 3CC2070G 3" as shown on FSK-AB-3876, Rev.1 A has flex span of 5'-6" and the rigid back span is 4'-0".

3. Rigkl back span for conduit shown on FSK-AB-4253, Rev. 3A is 6'-0".

4. Rigid back span for conduit shown on FSK-AB-4936, Rev. 3 is 3'-8".

5. The conduit shown on FSK-AB-5210, Rev.1 nas a nglo DaCK span of 44 inches.

6. Rigid back span of 3" conduit 3CX936PA as shown on FSK-AB-5669, Rev. 2 is 5'-0"

7. All conduits that transition to flex from support shown on FSK-AB-5717, Rev. 2A have rigid back span of 5'-6" l

8. Conduit 3CX104PF8 as shown on drawing FSK-AB-5746, l Rev.1B has rigid back span of 5'-0".

9. Conduit shown on drawing FSK-AB-5972, Rev.1 has a rigid i back span of 3'-6".

10. Conduit shown on drawing FSK-AB-6224, Rev.1 has a rigid back span of 5'-0"

11. Condait 3CX935PQ shown on drawing FSK-AB-5623, Rev.

3A has a rigid back span of 3'-6".

12. Conduit shown on drawing FSK-AB-8509, Rev.1 has a rigid back span of 4'-6"

13. Conduit 3CX1060G1shown on drawing FSK MA-693, Rev.

18 has a rigid back span of 7'-0".

Page 1 of 8 Printed 4/17/9611:35:19 AM

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N rthe st Utilities ICAVP DR N2. DR-MP3-0921 Millstone Unit 3 Discrepancy Report

14. Conduit shown on drawing FSK-MA 1063, Rev.1 has a rigid back span of 8'-6".

15. Conduit shown on drawing FSK-MA-1137, Rev. 3 has a rigid back span of 6'-6".

16. Conduit shown on drawing FSK-MA 1370, Rev.1 has a rigid and flex span of 6'-0" exceeding the aliowable of 5'-0".

17. Conduit 9CC205 PDC has span of 2'-3" rigid with 2'-9" flex (Reference FSK-AB-1291, Rev.1 A). General Note 65 limits rigid length to 2*-0".

18. Estimated spans for conduit shown on Drawing. 25212-34011 ,

SH AB-8719, Rev.1are 7'-6" and 6'-0".

19. Rigid span of conduit 3CC207PH as shown on FSK-AB-525, l Rev. 4 is 5'-2". j

20. Rigid span of conduit 3CC935PD as shown on FSK-AB-4805, Rev. 2 is 4'-2". l Review l Valid invalid Needed Date bitiator: Server, T. L B O O 1/15/98 VT Lead: Neri, Anthony A B O O 1/18/S8 ,

iT Mgr: schopfer, Don K G O O 1/ S/S8 l IRC Chmn: Singh, Anand K G O O 1i22/se l Det.: ,

myiu.ii Date: 4/10/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0921 identified 20 concems, of which item 1(b) represents a condition not previously discovered by NU which requires correction. CR M3-98-0674 was written to develop the corrective actions associated with this DR.ltem 1(a) and the other 19 items are not considered by NU to be discrepaat conditions.

Reference Drawing 12179-BE 52AS, Rev. 4, " Note 65':

The generic answer to the description conceming Note 65 on Drawing 12179-BE-52AS is that this note is for conduit support systems utilizing " ANACONDA

• Flexible Metal Conduit.

The requirements invoked by this note do not apply to "BOAFLEX" Flexible Metal Conduit. Note 63 on the same drawing reads,

• ANACONDA METAL HOSE (NUCLEAR WIRING CONDUlT) TYPE NWC FLEXtBLE LIQUID TIGHT

! WIRING CONDUlT MAY BE USED AS A SUBSTITUTE FOR BOAFLEX FOR CONDUlT SIZE 3/4" ONLY (SEE NOTES 64 &

65)".

In all cases, except for the substitution allowed by Note 63, BOAFLEX type flexible metal conduit has been utilized on Unit

3. Therefore, utilizing the criteria of Note 65 as a basis for all of the installations reported on this DR is incorrect since any conduit larger than 3/4" with mid-run flexible metal conduit are Printed 4/17/9811:35:23 AM Page 2 of 8

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ICAVP DR N3. DR-MP3 4921 N::rthertt Utilitie3 Millstone Unit 3 Discrepancy Report BOAFLEX and governed by General Notes 22,23,24,39,42, 43,46 and 48. To identify items in DR-MP3-0921 that are installed as BOAFLEX, and thus not applicable to Note 65, a review of each Conduit Support Log (CSL's) mentioned in this DR was conducted and the size of each conduit was noted as shown on the attached Table. If a conduit is larger than 3/4",

then it is BOAFLEX and govemed by the General Notes listed above and the allowed span of the installed support type of the first and second support from the flex connection is govemed by i the conduit material (Steel or Aluminum) and the support type. l Direct Concrete Attachments are govemed by the table on BE-52CA and all others are based on a Maximum span of 8'-0*. If a conduit is listed as 3/4", a determination was made as what type of flex is installed and what criteria is applicable and whether an undocumented violation of the criteria has occurred.

Only the second part of item 1 is considered an actual discrepancy and described as follows :

l Resolution to item 1 (b):

For item 1(b), the cantilevered portion of Conduits 3CC934PBS and 3CC934PB7 from support AB-3331 do exceed the allowable of 1'-0* per the criteria given in Note 39 on BE-52AQ. However, based on the actual span betweeri the adjacent supports being less than the allowable (approx. 4'-10' compared to 5'-6" i allowable) and the excess capacity of Support AB-3331 (3.5 #/ft l Actual compared to 10.0 #/ft Allowed) and the cutoff frequency in this area of the Auxiliary Bldg. at 22 CPS as shown on BE-52EA (compared to 33 CPS for the allowable spans), the as-installed condition is acceptable., NU has concluded that this issue in Discrepancy Repwi, DR-iviF5-GG2i has iucidifiud a ccndiben not previously discovered by NU which requires correction. CR M3-98-0674 was written to develop the corrective actions associated with this DR.

Items 1(a) through 20 of DR-MP3-0921 are not considered by NU to be discrepant conditions. See resolutions below. l Resolution to item 1(a):

Item 1(a) states the rigid back span of conduits shown on FSK-AB-3331, Rev.1 A is 4'-10* and part two states the rigid part of flex span is 1'-10" but is limited to 1'-0*.

For item 1(a), see attached Table for comparison of allowed span versus actual span as measured.

The requirements invoked by this note do not apply to "BOAFLEX" Flexible Metal Conduit. Note 63 on the same l

drawing reads,

• ANACONDA METAL HOSE (NUCLEAR WIRING CONDUlT) TYPE NWC FLEXIBLE LIQUID TIGHT WIRING CONDUlT MAY BE USED AS A SUBSTITUTE FOR BOAFLEX FOR CONDUlT SIZE 3/4" ONLY (SEE NOTES 64 &

65)".

In all cases, except for the substitution allowed by Note 63, BOAFLEX type flexible metal conduit has been utilized on Unit

3. Therefore, utilizing the criteria of Note 65 as a basis for all of the installations reported on this DR is incorrect since any conduit larger than 3/4" with mid-run flexible metal conduit are BOAFLEX and aoverned by General Notes 22. 23. 24,39,42.

Printed 4/17/9611:3s24 AM Page 0 of 8

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ICAVP DR No. DR-MP3-0921 l Ncrthea:t Utilities l Millstone Unit 3 Discrepancy Report 43,46 and 48. To identify items in DR-MP3-0921 that are I

installed as BOAFLEX, and thus not applicable to Note 65, a review of each Conduit Support Log (CSL's) mentioned in this DR was conducted and the size of each conduit was noted as shown on the attached Table. If a conduit is larger than 3/4*,

then it is BOAFLEX and governed by the General Notes listed above and the allowed span of the installed support type of the i first and second support from the flex connection is govemed by the conduit material (Steel er Aluminum) and the support type.

Direct Concrete Attachments are govemed by the table on BE-52CA and all others are based on a Maximum span of 8'-0*. If a I

conduit is listed as 3/4*, a determination was made as what type of flex is installed and what criteria is applicable and whether an 1 l

l undocumented violation of the criteria has occurred. l' Only the second part of item 1 is considered an actual

! discrepancy and described as follows :

Resolution to item 1 (b):

For item 1(b), the cantilevered portion of Conduits 3CC934PBS and 3CC934PB7 from support AB-3331 do exceed the allowable of 1'-0* per the criteria given in Note 39 on BE-52AQ. However, I

based on the actual span between the adjacent supports being less than the allowable (approx. 4'-10' compared to 5'-6*

allowable) and the excess capacity of Support AB-3331 (3.5 #/ft Actual compared to 10.0 #/ft Allowed) and the cutoff frequency in this area of the Auxiliary Bldg. at 22 CPS as shown cn BE-52EA l I (compared to 33 CPS for the allowable spans), the as-installed condition is acceptable.. NU has concluded that this issue in l

Discrepancy Report, DR-MP3-0921 has identified a conditien not previousiy discovmed uy NU wiih (wies ceriscGcG. OR M1 98-0674 was written to develop the corrective actions associatoo with this DR.

Items 1(a) through 20 of DR-MP3-0921 are not considered by NU to be discrepant conditions. See resolutions below.

Resolution to item 1(a):

Item 1(a) states the rigid back span of conduits shown on FSK-AB-3331, Rev.1 A is 4' 10* and part two states the rigid part of flex span is 1'-10' but is limited to 1'-0*.

For item 1(a), see attached Table for comparison of allowea spar' versus actual span as measured.

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Resolution to item 2 (a)(b):

I l Item 2(a) states conduit 3CC2070G - 3* as shown on FSK-AB-3870, Rev.1 A has a flex span of 5'-6* and 2(b) states the rigid back span is 4'-0". A search for E&DCR's against the Conduit l Support Logs (CSL's) indicates there is an E&DCR F-E-39469 listed on the Junction Box support AB-3906 which allows the l

' deviation from the requirement of a max. span of 5'-0* (1'-0* rigid  ;

l and 4'-0* flex) between Direct Attachments and a Junction Box.

Calculation 12179-SE-52.124 is referenced as the basis of approval. i For item 2(b), see attached Table for comparison of allowed span versus actual span as measure:1.

Page 4 of 8 PrWed 4/17/9611:35:25 AM

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1 Ncrthenst Utilities ICAVP DR No. DR-MP3-0921 Millstone Unit 3 Discrepancy Report Resolution to item 3:

This item states the rigid back span for conduit shown on FSK-AB-4253, Rev 3A is 6'-0*.

l For item 3, see attached Table for comparison of allowed span l versus actual span as measured.,

l Resolution to item 4:

This item states the rigid back span for conduit shown on FSK-AB-4936, Rev 3 is T 8".

! For item 4, see attached Table for comparison of allowed span l Versus actual span as measured.

i Resolution to item 5:

l This item states the rigid bact. span for conduit shown on FSK-AB-5216, Rev 1 is 3'-8*.

i For item 5, see attached Tabfe for comparison of allowed sps versus actual span as measured.

l ResolutioMo i;em 6: 1 This item states the rigid back span for 3' conduit 3nX936PA

< shown on FSrMP-5669, Rev 2 is C-0*. For item 6, see .

l attached T ibk f..r cc.nparison of allowed span verses actual span as measu.ed.

l ResoWtion to item 7. .

This hem states

• conduits that tran:.ition to flex from FSK-AB- l 5717, Rev 2A, have a rigid back span of 5'-0*. For Item 7, see l l attached Table for compansen of allowed span versus actual l span as measured. See 1ko, Note 4 on the Table, which j indicatec the 3/4" condu! !:00 vecre fe!d WFed te M t BOAFLEX.

Resolution to item 8:

This item ctates the rigid back span for cor.duit 3CX104PF8 shown on FSK-AB-5746, Rev !B is 5'-0*. For item 8, see attached Tehle for comparison c' allowed span versus actual span es measured.

Resolutio:1 to :lem 9:

Tnis item states the rigH back span for conduit shown on FSK-AB-5972, Rev 1 is 3'-6".

For item 9, set, attached Table for companson of allowed span l versus actual span as measured. j i

RescNtion to item 10:

This item states the rigid brck span for ccnduit shown on FSK-AB-6224, Rev 1 is 5'-0*.

For Itom 10, see attached Table for comparison of allowed span versus actual span as measured.

l P.esolution to item li:

l This item states the rigid back span fc! conduit 3CX935PQ shown on FSK AB 5623, Rev 3A is 3'-6".

For item 11, see attached Table for comparison of allowed span versus actual span as measured.

Resolution to item 12:

Printed N17/9e 11*3s:26 AM Page s of 8 i

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1 DR N2, DR-MP3 0921 Nerthemt Utilities ICAVP Millstone Unit 3 Discrepancy Report i This item states the rigid back span for conduit shown on FSK-AB-8509, Rev 1 is 4'-6*.

For item 12, see attached Table for comparison of allowed span ,

versus actual span as measured. ]

i Resolution to item 13:

This item states the rigid back span for conduit 3CX1060G1 )

l i shown on FSK-MA-693, Rev 1B is 7'-0".

For item 13, see attached Table for comparison of allowed span versus actual span as measured. l l Resolution to item 14:

1 This item states the rigid back span for conduit shown on FSK-l MA-1063, Rev i is 8'-6*.

For item 14, a search against MA-1063 indicates E&DCR F-E- 1 l 32867 which addresses and documents the span deviation up to  !

9'-0* max. and this is not a discrepancy. See attached Table for (

comparison of allowed span versus actual span as measured.

l See also Note 5 of the Table which provides information on the allowed deviation for the 9'-0* span.

Resolution to item 15:

This item states conduit shown on FSK-MA-1137, Rev. 3 has a l rigid back span of 6'-6*, Field verified lengths of the two conduits i have an actual span between supports MA-1137 and MA-1138 of 6'-0* for 3CX931YA3-2* and 6'-8* for 3CX104PM-3* between MA-l 1137 and its next support. See attached Table for comparison of allowed span versus actual span as measured and also Note 6 of i

the Table.

Rosiuiivn is lieni 11.

This item states conduit shown on FSK-MA 1370, Rev.1 has a rigid and flex span of 6'-0*, exceeding the allowable of 5'-0*. For item 16, field verification indicates the actual span of flex is 1'-9*

for 3CX108PB and 2'-6* for 3CC143PH, which is less than the allowed 4'-0* max. per the applicable General Note 39. Also, field measurements show the rigid span of each conduit is 1'-0*

or less at each end, which is also within the allowed criteria and l

this is not a discrepancy.

Resolution to item 17:

This item states conduit 9CC205 PDC (conduit number is actually 9CC205PD6);1as a span of 2'-3* rigid and 2'-9' flex (Reference FSK-AB-1291, Rev 1 A). General Note 65 limits rigid to length of 2'-0*. Field verification indicates the extension of conduit 9CC205PD6 from the face of support AB-1291 is 2'-0* which is l

consistent with the requirements of General Note 46, which is the l applicable note for BOAFLEX Type flexible conduit from a cantilevered support. See also the Note 8 of the Table.

Resolution to item 18:

This item states an estimated span for conduits shown on 25212-34011 Sh. AB.3719, Rev.1 are 7'-6* and 6'-0*. For item 18, see suached Table for comparison of allowed span versus actual span as measured.

! Resolution to item 19:

Printed 4/17/0411:35:27 AM Page 6 of 8 i

ICAVP DR No. DR-MP3-0921 N:rthea:t Utilities Millstone Unit 3 Discrepancy Report This item states the rigid back span for conduit 3CC207PH shown on FSK-AB-525, Rev 4 is 5'-2*. For item 19, see attached Table for comparison of allowed span versus actual span as measured.

Resolution to item 20:

This item states the rigid back span for conduit 3CC935PD shown on FSK AB-4085, Rev 2 is 4'-2*.

For Item 20, see attached Table for comparison of allowed span versus actual span as measured.

For item 1(b), CR M3-98-0674 was written to develop the corrective actions. Design Engineering willinitiate a DCN and l I

qualifying documents for the span of 1*-10* for the cantilevered portion of conduits 3CC934PBS and 3CC934PB7 from support AB-3331 and update the applicable drawings and Actual Loads l

as necessary. Since this condition does not affect Licensing or Design Basis, NU considers DR-MP3-0921 to be a Significance Level 4. The Corrective Action will be completed after unit restart. No field modification will be required Previously identified by NU? O Yes (*) No Non Discrepant Condition?U Yes (#) No Resolution Pending?O ve. @ No Resolution Unresolved?O yes @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K l Date: 4/10/98 sL comments: We accept NU's response to all items with the following clarification for item 2a:

NU's response stated that the maximum allowable flex span has been increased to 5'-0" which is still LESS than field measured span of 5'-6".

However, based on the review of the reference calculation no. SE-52.124, Rev.0, the maximum flex conduit span that has been justified in the analysis is equal to 6'-0".  !

i item ib has been accepted as a discrepancy by NU. Conduit span calculation update is required to address 10" overspan I

condition. Based on the review of design margins inherent in the conduit allowable span calculations, S & L has concluded that the l I revised calculations will demonstrate acceptability of 10" overspan condition without overstress conditions.

The resolution for the remaining 18 items not being discrepant l conditions has been accepted by S & L based on the review of the following documents:

- Drawing no. BE 52CA I

- E&DCR F-E-39469 and E&DCR F-E-32867

- Table for response to DR MP3 0921, page 8 of 8, Attachment 3 titled " (CAVP Response Form "

Page 7 of 8 Printed 4/17/9811:35:28 AM 1

i N:rthent Utilities ICAVP DR No. DR-MP3-0921 Millstone Unit 3 Discrepancy Report Based on the review of the responses, there are no restart issuer, and significance level has been revised to level 4.

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Prtnted N17/9811:35:29 AM Page 8 of 8

ICAVP DR No. DR-MP3-0923 N:rtheast Utilities Millstone Unit 3 Discrepancy Report Review Group: confguration DR RESOLUTION ACCEPTED Review Element: system Installation Potential Operability lasue Discipline: Electncal Design Ow Discrepancy Type: Installabon implementation gg System / Process: HVX NRC significance level: 4 Date faxed to NU:

Date Published: 1/2598 Discrepeacy: CONDUlT SPANS EXCEED ALLOWABLE

Description:

Standard Conduit support detail drawings (12179-BE-52 series drawings) provide the criteria and generalinstallation notes for i conduit supports. The following span criteria violations were j observed during system walkdowns l

1. Conduit shown on drawing FSK-AB-6057. Rev.1has a span of 1 6'-0" exceeding the allowable 4'-6" for 1" AL conduit per table CA.

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2. Conduit shown on drawing FSK-AB-6078, Rev.1 A has spans j of 8'-6" exceeding allowable of 7'-9" for 4" AL conduit per table 1 CA.

3. Conduit shown on drawing FSK-AB-6124, Rev.1 has a span of 6'-0* exceeding allowable of 5'-6" for i %" AL conduit per  ;

table CA. )

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4. Conduit shown on drawing FSK-AB-6327, Rev. 2 has a span )j of 4'-10" exceeding allowable span of 4'-6" for 1" AL conduit per table CA. Conduit shown on drawing FSK-AB-6653, Rev.1 has a l span of 4'-6" exceeding allowable of 4*-3" for %" STL conduit per table CA. Conduit shown on drawing FSK-MA-1290, Rev.1 has .

a span of 8'-0* exceeding allowable span of 7'-9" for 4" AL conduit per table CA.

5. Conduit shown on drawing FSK-MA-1401, Rev.1 has a span of 7'-5" exceeding allowable span of 6'-6" for 2" STL conduit per table CA

6. Flex spans for conduits shown on drawing FSK-AB-4584, Rev.

2 from box are estimated by field observation to be 5'-0".

Standard Detail Drawings (12179-BE52) General Note 24 limits spans to 4'-0".

7. The flex span from the box to conduit shown on drawing 25212-34011 SH AB-8738 Rev.1 is 4'-6".

8. Conduit shown on drawing FSK-AB-3905, Rev. 2 has a span to box of 4'-0". Note 6 on drawing BE 52YS limits span to 3'-0".

9. The conduits shown on FSK-AB-3603, Rev. 3G have estimated spans exceeding the limits for %" and 1" conduits as listed in Table CA of drawing 12179-BE 52CA.

10. The conduits shown on FSK-AB-1250, Rev. 2B has a span of 5'-6" which exceeds maximum allowed for 1" AL per table CA of drawing 12179 BE-52CA. Allowable is 4'-6".

PNnted 4/17/9811:35:57 AM Page 1 of 6

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! J N::rtheast Utilities ICAVF DR Ns. DR-MP3-0923 Millstone Unit 3 Discrepancy Report 1

11. Spans for 3" AL conduit are limited to 7'0" by Table CA.

Field estimated span for conduit shown on support drawing FSK-AB-8217, Rev. 3 is 7'-6".

l j 12. Conduit shown on drawing FSK-MA-937, Rev. 2 has a span of 8'-3" exceeding maximum allowable span of 8'-0" per General Note 3.

13. The first support on conduit 3CC133PA2 from 3JB*3663 is more than the allowable 3 feet as specified in the Eledrical installation Specification E350.

Review Valid Invalid Needed Date initiator: server, T. L. G 0 0 1/15'S8 VT Lead: Neri, Anthony A 8 O O 1'16/98 VT Mgr: schopfer, Don K B O O 1/19/S8 l S

IRC Chmn: singh, Anand K O O 1/22/98 Date:

INVALID:

Date: 4/14/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0923, has identified eleven concems, (Items 1,2,3,4,5,6,8,10,11,12 and 13),

that represent discrepant conditions not previously discovered by NU which require correction. CR M3-98-0697 has been written to develop the corrective actions associated with these items.

NU has concluded that 2 items, (ltems 7 and 9) do not represent discrepant conditions.

The Description for this DR states that Standard support detail drawings (12179-BE-52 Series Drawings) provide the criteria and generalinstallation notes for conduit supports. The following span criteria violations were observed during system walkdowns. The DR goes on to list 13 Items observed as conduits which seem to exceed the allowable span criteria.

Many items refer to conduit support details which utilize the span criteria give in Table CA on drawing BE 52CA, Rev. 3. The maximum spans given in referenced Table CA represent spans where the cut-off frequency is 33 CPS (reference Calculation 12179-SEO-SE-52.7). During construction and/or during the initialinspection of tne originalinstallation of conduit supports there were instances identified where the maximum allowed spans were exceeded. To address the overspan covered in Table CA, Calculation 12179-SEO-SE-52.98, Rev. O was produced which expands the spans shown in Table CA based on various cut-off frequencies This Calc. was used on a case-by-case basis as a reference document whenever possible.

A search in GRITS against drawing BE-52CA reveals E&DCR's and N&D's which utilized Calc.12179-SEO-SE-52.98, Rev. O as a basis for acceptance of many overspan cases. However, during this search only a few of the instances mentioned in this DR were found to be prediscovered. Even though a rnore extensive search may produce additional documentation for other apparent violations, the response to this DR will be to Printed 4/17/9811:36:01 AM Page 2 of 6

i N::rtheast Utilitin ICAVP DR No. DR-MP3-0923 Millstone Unit 3 Discrepancy Report assume there is no documentation and a CR will be initiated to i track the apparent violation and to update any applicable drawings to document the overspan conditions. A review of each item in this DR has been made and where a discrepancy has been identified, the described overspan based on the criteria from Table CA has been evaluated against the larger spans qualified in Calc.12179-SEO-SE-52.98. This review has been documented in the attached Table, and items which are considered discrepancies, but are acceptable based on the spans of the referenced Calc.NU concludes that discrepancy report DR-MP-09231 has identified items 1,2,3,4,5,6,8,10, 11,12 and 13 of DR-MP3-0923 as eleven conditions not previously discovered that require correction. CR M3-98-0697 has been written to develop the corrective actions associated with these items.

The Corrective Action items will be completed after restart. No field modification will be required. Since a preliminary review of the discrepancies, relative to the allowable spans given in the expanded table of Calc.12179-SEO-SE-52.98, indicates that the spans are acceptable as-is, in all cases meeting their licensing and design basis, as noted below, NU considers this DR to be a Significance Level 4 Resolution to item 1; No documentation could be found to substantiate the apparent overspan. From field observation, the overspan is actually between supports AB6056 and AB-3898 and is estimated to be close to the 6'-0* span described in this item. The 6'-0" span exceeds the expanded allowable of 5'-8* given in Calc.12179-SESSE-5198 by A" However, d"e te 'he prevh"!!y of 'he aeM support, AB-6057, at approximately 2'-0" on one side, and a span ,

of 2'-0" to the junction box support AB-3894 on the other side, l the conduit is adequately supported and acceptable. The as- l Installed configuration will be documented and the applicable drawings updated.

Resolution to item 2; No documentation could be found to substantiate the apparent overspan. However, the conduit and supports are acceptable, per the expanded allowable spans given in Calc.12179-SEO-SE-52.98. See the attached Table for comparison of expanded allowed span versus actual span as measured.

, Resolution to item 3; No documentation could be found to substantiate the apparent overspan. However, the conduit and supports remain acceptable, per the expanded allowable spans given in Calc.

12179-SEO-SE-52.98. See the attached Table for comparison I

of expanded allowed span versus actual span as measured.

Resolution to item 4; No documentation could be found to substantiate the apparent overspan for the three items under item 4. However, the conduits and supports remain acceptable, per the expanded allowable spans given in Calc.12179-SEO-SE-52.98. See the attached Table for comparison of expanded allowed span versus Printed 4/17/9811:36:02 AM Page 3 of 6

I N:rtheast Utilities ICAVP DR N2. DR-MP3-0923 Millstone Unit 3 Discrepancy Report f

f actual span as measured.

Resolution to item 5; No documentation could be found to substantiate the apparent overspan. However, the conduit and supports remain acceptable per the expanded allowable spans given in Calc.12179-SEO-SE-52.98. See the attached Table for comparison of expanded allowed span versus actual span as measured.

Resolution to item 6; I No documentation could be found to substantiate the apparent overspan. However, the estimated extra length of flex conduit l will not add significant load to the junction box or the support, and by a review of 12179-SE-52.124, the as-installed configuration is acceptable.

The as-installed configuration will be documented and the applicable drawings updated.

Resolution to item 8; No documentation could be found to substantiate this apparent overspan. However, the load imposed onto the junction box and its support due to the additional 1'-0* span of 1-1/2* Aluminum conduit is insignificant and will not adversely effect the structural integrity of the support or box. The as-installed configuration is acceptable. The as-installed configuration will be documented and the applicable drawings updated.

Resolution to item 10; No documentation could be found to substantiate the apparent overspan. However, the conduit and supports remain acceptable M Cs s,Enucu usuwu' vie spans gIven in vasc. u1/v-sEO-sE-52.98. See the attached Table for comparison of expanded allowed span versus actual span as measured.

Resolution to item 11; No documentation could be found to substantiate the apparent overspan. However, the conduit and supports remain acceptable per the expanded allowable spans given in Calc.12179-SEO-SE-52.98. See the attached Table for comparison of expanded allowed span versus actual span as measured.

Resolution to item 12; No documentation could be found to substantiate the apparent overspan. However, the additionalload added due to the increase of 3* is negligible and conduit and supports are structuraly adequate and acceptable.

Resolution to item 13; Item 13 contained incorrect information regarding the junction box identification which was subsequently clarified by Sargent and Lundy. Field verification revealed the overspan mentioned j

t in this item for conduit 3CC133PA2 is actually from Box l

3JB*2660 and was determined to be a discrepancy not

' previously discovered. A review of the existing support configuration indicates the actual span to the first support from 3JB*2660 on 3CC133PA2 is 4'-1" which exceeds the maximum 3'-0* required per Spec SP-ME-076 (Formerly E350). However, the conduit. lunction box support and the first support are Pnnted 4/17/9811:36:03 AM Page 4 of 6

Narthert Utilitie3 ICAVP DR N2. DR-MP34923 Millstone unit 3 Discrepancy Report acceptable due to the reduced rigid span criteria of this area of the Aux. Building shown on BE-52EA (22 CPS verses 33 CPS) and the excess capacity of the first support from the box ( 0.98

1. /ft Actual verses 25 #/ft Allowed).

Civil / Mech. Design will initiate a DCN to document the as-installed conditions described in items 1,2,3,4,5,6,8,10,11, 12 and 13 and update the applicable data bases and drawings as necessary.

Upon further review of this item, there were inconsistencies I within the Cable and Raceway Program and on Drawing EE-48J conceming conduit 3CC133PA2 and the conduits entering Junction Box 3JB*26SO, as well as the Conduit Support Logs I (CSL's), which should have been listed against conduit j 3CC133PA2, but were actually incorrectly listed against conduit 1 3CC2070M2.

1 Electrical Design will clarify the conflicting information on  !

drawing EE-48J with respect to the conduits entering Junction Box 3JB*2660, and possibly others in the immidiate area, and initiate a DCN to update the applicable data bases and drawings i as necessary. l NU has concluded that the issues reported in items 7 & 9 in j discrepancy Report DR-MP3-0923 do not represent discrepant '

conditions.

Resolution to item 7; l This !!em states the f!ex span 4em box to cond'dt showa ea 25212-34011 Sh. AB-8738, Rev 1, is 4'-6". For item 7, a search against this support reveals that DCN DM3-S-0862-93 issued the 1 details for this new Junction Box Support and the Project (

Instruction Sheet on Pg. 50 indicates the flex may span to the j Unit Heater without additional support.

Resolution to item 9; A search against the drawing revealed that N&D 15272 accepted the overspan condition associated with support AB-3603. l Previously identified by NU7 O Yes (9) No Non Discrepant Condition?U ves (#) No Resolution Pending70 ve. @ No Resolution Unresolved 70 ve. @ No Review Ac.ceptable Not Acceptable Needed Date O O O *1 *Se VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K g Nis/98 .

IRC Chmn: sngh, Anand K B O *m I O O O Date: 4/14/98 st. comments: S & L has reviewed the referenced documentation provided for items 7 and 9 and concurred that these to items are not discrepant conditions.

S & L has also reviewed reference calculation no. SEO-SE-52.98 as well as the proposed corrective actions for discrepant Printed N17/9811:3604 AM Page s of 6

N:rthesst Utiliti23 ICAVP DR N3. DR-MP3-0923 Millstone Unit 3 Discrepancy Report I conditions described in items 1,2,3,4,5,6,8,10,11,12 and 13.

Based on the review of the NU's dispositions, the available design margins are sufficient to offset the impact of the discrepant conditions on the adequacy of the components. Therefore, the ,

Significance Levelis revised to the Level 4 and there are no start- I up issues related to the aforementioned discrepancies.

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Printed 4/17/9611:36:06 AM Page 6 of 6 L

1 Neert utilitiea ICAVP DR N2. DR-MP3-0924 );

Millstone Unit 3 Discrepancy Report i

! Review Group: Conrguration DR RESOLUTION ACCEPTED j Potential Operability issue Discipline: Electrical Design l

Discrepancy Type: Installation implementation Ow l l

System / Process: HVX gg i j

NRC Significance level: 4 Date faxed to NU:

Dcte Published: if2s/98 l l Discrepancy: Improper Labeling of Raceway j Descripuon: Procedure OA-9 and Electrical Installation Specificadon E350, Rev. 9 rcquire the correct labeling of con:pc.nents and l raceways. The following labeling anomalies were noted with j regard to these requirements l

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1. %" conduit listed on drawing as 3CC834PB3 has no tag in field and is no; listed on raceway schedule. Conduit routes to non-safety related box 3JB2522, yet also routes to box near l equipment that also contains the "P" safety-related conduit. 1 (Reference drawings FSK-AB-8065, Rev. 2 and FSK-AB-8113, l Rev. 2) t 2. Conduit is listed as 3CK1060Gion drawing FSK-MA-1017,

! Rev. 2A. TSO2 and field walkdown determine correct ID is 3CX1060G1.

l 3. The field tag on this support is 1259 which is a duplication of another support nearby. (Reference drawing FSK-MA-1039, Rev. 3)

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a a m_..* *

.6.

as 3CCP*JB19A. Tag in field is 3CCP*JB197A.

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5. Drawing FSK-AB-4484, Rev. 3 identifies supported J-Box as l 3JB-2624. Field tag is 3JB*2624.

6. Conduits 3CX9260G and 3CX9260G7 are not identified in l field.

7. Junction box 3HVP'JB26B is not identified in the field.

8. The wire way 3CES-RK12-8 is not tagged in the field.

l Conduits to this raceway from instruments 3HVR-PDIS91B,93B,

' and 94 B,157A,1578 do not show the wireway as a from/to for the conduits; but shows the from/to as "end".

9. Conduit 3CC1150D did not have an identification tag installed.

10. Junction boxes 3HVR*JB1-1 A and 3HVR*JB12A have erroneous instrument information listed on the box in the field.

The boxes are also mis-identified on drawing EB-45G Rev. 9.

Field and drawing indicate boxes are for 3HVR*TS175A-1/ A-2 and 3HVR*TS175A-3/ A-4 respectively. The correct designations for these boxes are 3HVR*TS175A-1 and A-2 respectively. Similar situation exists for instruments 3HVR*175B-1 and B-2.

Printed 4/17/9811:38:32 AM Pape 1 of 3

ICAVP DR Ns. DR-MP3-0924 N:rthea:t Utilitie3 Millstone Unit 3 Discrepancy Report

11. Junction boxes 3JB*2518 and *2516 appear to be mis-labeled in the field. Based on the conduit attachments shown in the Cable and Raceway Control Program (TSO2) and on drawing 48H, Rev.10 the tags have been swapped.

Review Valid invalid Needed Date initiator: Server, T. L. 9 0 0 1/15/S8 VT Lead: Neri, Anthony A B O O 1/18/88 VT Mgt: schopfer, Don K S O O 1/158 IRC chmn: singh, Anand K G O O 1/22/98 Date:

INVALID:

Date: 4/16/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

l NU has concluded that Discrepancy Report, DR-MP3-0924, has I 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 i concems and meets the Unit 3 deferral criteria. CR M3-98-0808 l has been written to develop and track resolution of this item per I RP-4.

bUllbiubiUli.

NU has concluded that Discrepancy Report, DR-MP3-0924, 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 M3-38-0808 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0924 does not represent a discrepant condition.

l l U3 PI 20 section 1.3.2 e defines the type of labeling I discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

Printed 4/17/9811:38.36 AM Page 2 of 3 L

ICAVP DR NO. DR-MP3-0924 N:rtheast Utilitie3 ,

Millstone Unit 3 Discrepancy Report j I

l NU concludes that the assignment of priority 4 is correct and in  !

accordance with U3 Pl 20 section 1.3.2 e. Significance level criteria does not apply to the new issue as this is not a discrepant condition.

CR M3-98-0808 was closed to CR M3-98-0137. The corrective actions in CR M3-98-0137 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4. i

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0924 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in CR M3-98-0137 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identifled by NU? U Yee @ No Non Discrepant Condition?O Yee @ No Resolution Pending?O vee @ No ResolutionUnresolved?O vee @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgt: schopfer, Don K IRC Chmn: singh, Anand K Date: 4/18/98 SL Comments: INITIAL COMMENTS:

Based on CR M3-98-0924 it is not apparent why the labeling changes can be deferred based on the deferral criteria.

" Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred."

l COMMENTS ON NU'S SECOND RESPONSE:

1 We have no comments on NU's second response.

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Page 3 of 3

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Printed 4/17/9811:38:37 AM

DR No. DR MP3-0932 j N::rtheazt Utilitiea ICAVP Millstone Unit 3 Discrepancy Report l Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System Installation Potential Operability issue l Ow Discipline: Electrical Design Discrepancy Type: Installation implementation g g, system / Process: DGX j NRC Significance level: 4 Date Faxed to NU:

Date Published: 1/18/96 Discrepancy: Electrical Installatics not in accordance with Standards.

Description:

Procedure OA-9, Rev.1 and Electrical Installation Specification E350, Rev. 9 require that components, cables, and raceways be tagged with a unique identification when installed. Specification E350 also requires that flexible conduits be provided with a ground wire that is termint.ted at the equipment. This ground wire is to have 3 inches of slack. Contrary to these requirements, the following was observed during system walkdowns.

1. Junction box 3JB-8623 does not have a permanent label affixed; identification is written with marker.

2. Cable 3EGEBPX400 in control room panel 3CES*MCB-MB8 as shown on drawing EE-34TZ Rev. 4, does not have a cable identification tag as required by Electrical Installation Specification E350 Rev. 9.

3. Flexible Conduit 3CC863NA is routed to level switch 3EGF-LS34A. ElectricalInstallation Specification E350 requires a ground wire with 3 inches of slack be provided for termination of raceway at instruments; contrary to this requirement, no slack is provided. Further, the switch is mounted 3 inches above an acc m wmunu ucs Cis 1 C,lZ,I 2 2l!! !!TN and has no mechanical protection. Instrument installation Specification 212 requires protection be provided for I instruments / tubing. A similar mechanical protection situation exists for the "B" switch.

4. The component identification tag on 3EGS*TS30A indicates that the switch is non-safety related by including a dash (" ") in lieu of an asterisk ("*"). P&lD EM-116A Rev. 27 shows the switches as safety related.

5. The component tags on 3EGS-TS28A and B indicate the instruments are safety related by including an asterisk ("*")ln lieu of a dash (" "). P&lD EM 116A Rev. 27 shows the switches as non-safety related.

6. Cables 3EGPAOC405 and 3EGPBPC405 do not have identification tags installed.

7. Conduits 3CC83081 and B2 were completely painted and their identification covered or removed. Conduit no longer has identification as required by installation Specification E350.

8. Cables 3SWPAOH350 and 3SWPCOH350 are routed through tray 3TH4050 and through ductbank (3DH900035) to the pumphouse. This tray (and the tray within the pumphouse) is not bonded to the ductbank nor is a ground routed with the power cables The following material conditions were noted during system Printed 4/17/981149:00 PM

/ e-noW@ahmanSW %Lh1 a of 3

ICAVP DR No. DR-MP3-0932 N:rthe:st Utilities Millstone Unit 3 Discrepancy Report

1. The A train DG cable trench shows signs of significant water ,

Intrusion. Many of the bottom support members, bracing and l

tray covers are severely rusted.

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2. The ground wire run in parallei with the flexible conduit associated with 3CK926PE at 3EGF*TRS1B is not tight -Just stuck into the screw slot. (

3. Miscellaneous parts and jumper leads were observed stored i inside of panel 3EGD-PNLB.

Review Valid invalid Needed Date initiator: Sarver, T. L 8 0 0 12/30/97 VT Lead: Neri, Anthony A B O O 12/31/97 VT Mgt: schopfer, Don K G O O si12se IRC Chmn: Singh, Anand K O O O '/15S8 Date:

INVALID:

Date: 4/16/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0932, 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 coricems and meets ihe i.inii 5 duico ai u hne. CR Wr^0-0^4,0 has been written to develop and track resolution of this item per RP-4.

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Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0932, 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 M3-98-0968 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR MP3-0932 does not represent a discrepant condition.

U3 Pl 20 section 1.3.2 e defines the type of labeling discrepancies which will be completed during the next refueling Printed N17/9812:49.03 PM Page 2 of 3

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ICAVP DR N2. DR-MP34932 N rthea:t Utilitle3 Miiistone unit 3 Discrepancy Report outage or later Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis. )

l NU concludes that the assignment of priority 4 is correct and in I accordance with U3 PI 20 section 1.3.2 e. Significance level criteria does not apply to the new issue as this is not a discrepant condition.

CR M3-98-0968 was closed to CR M3-98-0137. The corrective actions in CR M3-98-0137 will correct these issues post startup.

l NU considers the overall classification of the DR to be significance level 4.

Conclusion:

NU has concluded that the new issue reported in Discrepancy l Report, DR-MP3-0932 does not represent a discrepant condition.

NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in CR M3-98-0137 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identified by NU7 O Yes (*) No Non Discrepant condition?Q Yes (9) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K I

IRC Chrnn: singh, Anand K Date: 4/16/98 st. comments: INITIAL COMMENTS: ,

i Based on CR M3-98-0932 it is not apparent why the labeling l changes can be deferred based en the deferral criteria. l

" Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels) i may be deferred."

COMMENTS ON NU'S SECOND RESPONSE:  ;

We have no comments on NU's second response.

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Printed 4/17f3812:49:05 PM Page 3 of 3

ICAVP DR N3. DR-MP3-0990 N:rtherst Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED

• Potential Operability issue ,

Discipline: Mechanical Design Om Discrepancy Type: Installation Requirements g System / Process: NEW NRC Significance level: NA Date faxed to NU:

Date Published: 1/29/98 Discrepency: DCR M3-97045 has a test plan that is inconsistent with the modification design.

Ducription: Flow transmitter 3RSS*FT38A-B and 3RSS-FT40C-D, and flow Indicata s 3RSS-Fl38A-B and 3RSS-Fl40C-D are respanned by DCR M3-97045. However, no instrument loop calibration or testing is identified in Section 7.0, Test Plan, of this modification I package.

Review Valid invalid Needed Date j Initiator: Feingold, D. J. G 0 0 1/22/90 VT Lead: Neri, Anthony A B O O 1/22/98 1/22,58 VT Mgr: Schopfer, Don K 8 O O IRC Chmn: Singh, Anand K B O O 1/23/98 Date:

INvAllD:

1 Date: 4/16/98 )

RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0990, does not represent a discrepant conoiuon uun mi-s ugs, mv v, (attached) provides the detailed Test Plan. Previous revisions to l DCR M3-97045 applicable for early release for construction l I

Indicated all proof of performance testing would be included in the final revision of the DCR The Test Plan contains both Instrument loop calibration and testing criteria. Significance I

Level Criteria do not apply as this is not a discrepant condition.

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Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0990,does l not represent a discrepant condition. Revision 0 to DCR M3- l l

97045 provides instrument loop calibration and testing requirements. Significance Level Criteria do not apply as this is ,

1 not a discrepant condition.

Previously identifled by NU? O vos (8) No Non Discrepant Condition?(9) vos O No ResolutionPending?O vos @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Peeeded Date

• 16/88 VT Lud: Neri, Anthony A B O O VT Mgr: Schopfer, Don K g N16/98 gg IRC Chmn: Sbgh, Anand K O O O Date: 4/16/98 Page 1 of 2 Printed N17/9812 49:34 PM

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ICAVP DR N3. DR-MP3-0990 N:rthert Utiliti:3

Millstone Unit 3 Discrepancy Report mama l

SL Comments: The test plan attached to the Northeast Utilities response to this discrepancy report was not originally provided with or referenced in the modification pacl(age, DCR M3-97045, provided to Sargent

& Lundy for review.

However, the attached test plan adequately addresses the discrepancy identified by DR-MP3-990.

."------- - New issue of Discrepancy Report Resolution The originally approved Northeast Utilities' response to this discrepancy report was inadvertently marked "No" for Non-Discrepant Condition. This release of the discrepancy report correctly marks "Yes" for Non-Discrepant Condition.

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Printed 4/17/9812:49:38 PM Page 2 of 2

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N:rthe:st Utilitie3 ICAVP DR No. DR-MP3-1021 )

l Milistone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Piping Design Ow l

Discrepancy Type: Calculation g SystenVProcess: NEW l NRC Significance level: 4 Date Faxed to NU:

1 Date Published: 2#/98 Discrepancy: Typographical error and an unsubstantiated assumption in Calc NP(B)-163-FA {

I l DescripHon: In the process of reviewing the following documents, (i) NP(F)-163-FA Rev 3 we noted the following discrepancies:

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1. The equation Mr the calculation of stress in the orifice plate, {

page 7E, has a typographical error. The term a on the right hand  !

should be a^2. l

2. Units for M, the maximum moment, should be (Ib) not (Ib/ft).

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3. On page 27E, the shutoff pump TDH is taken as 540ft, and on page 27F, the shutoff TDH is 580ft. The discrepancy should be corrected. Also, proper units should be shown in the detta P calculation.

4. Assumption 8 on page SA:It is assumed that segment forces are proportional to the segment lengths of the same branch of (ALA;ruiu augmv mnant i n nt anid dvnnmicallv similar locations". The assumption is used in Sec. 7.8 to determine the unknown segment forces for Loops B, C and D based on Loop A loads, which are computed using WATHAM, and the segment length ratios.

I in some cases, the segment lengths for Loops B, C and D are l significantly smaller than the corresponding Loop A segment length. Therefore, based on this assumption, the corresponding segment force is calculated to be significantly smaller, and is unconservative. No justification for the assumption is provided.

Note: The calculation has been revised as part of modification M3-097045.

Review Valid Invalid Naadej Date Intuator: Prakash, A. B 0 0 2r2/98 VT Lead: Nerl. Anthony A @ O O 2/2/98 VT Mgt: schopfer, Don K 8 0 0 2/2/9e 0 0 2rsse IRc Chmn: singh. Anand K 8 Date:

INVALID:

Date: 4/14/98 RESOLUTION: Response ID: M3-IRF-01855 Printed 4/17/9612:s0:11 PM Page i of 4

DR N3. DR-MP3-1021 N:rtheast Utilitica ICAVP Miiistone Unit 3 Discrepancy Report Disposition:

NU has concluded that the issues reported in items 1,2 and 3 of Discrepancy Report, DR MP3-1021, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0814 (attached) will correct Calculation NP(B)-163-FA with respect to each of the three discrepancies identified. The revised results will then be carried forward into the calculations and documents which use results from NP(F)-163-FA as an input.

NU has concluded that the issue reported in item 4 of Discrepancy Report, DR MP3-1021, does not represent a discrepant condition. As discussed in an April 1,1998 conference call, item 4 is only a request for clarification of the assumption used. This clarification is attached.

CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action will be completed by May 31,1998, and will ensure that the errors in NP(F)-163-FA are clearly identified and addressed. The corrective action plan for CR M3-98-0814 is tied to CR M3 0619 by AR 98002805.

As part of the ICAVP program, trending CR M3-98-1132 has been written to ensure that any process-related issues related to these calculations are clearly identified and are being dealt with.

This assessment is scheduled to be co,npleted prior to Startup.

Each of the discrepancies in DR-MP3-1021 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR MP3-98-1021 significantly affect the results of the RSS related calculations, and do not affect the conclusion that the RSS '

system meets its design basis. In addition, each of these discrepancies has been reviewed by NU design engineers, who have further determined that none of the discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

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Conclusion:

NU has concluded that the issues reported in items 1,2 and 3 of l Discrepancy Report, DR-MP3-1021, have identified conditions not previously discovered by NU which require correction. The ,

approved corrective action plan for CR M3-98-0814 (attached) will correct Calculation NP(F)-163-FA with respect to each of the three discrepancies identified. NU has concluded that the issue reported in item 4 of Discrepancy Report, DR-MP3-1021, does noi represent a discrepant condition. Item 4 is a request for clarification of an assumption made in the calculation, and this clarification is attached. In addition, an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure that these issues are clearly Page 2 of 4 Printed 4/17/9812:so:14 PtA

ICAVP DR No. DR-MP3-1021 N rthe=t Utilities Millstone Unit 3 Discrepancy Report identified and addressed.

Each of the discrepancies identified in DR MP3-98-1021 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS system meets its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

1 Attachments. )

CR M3-98-0814 l CR M3-98-0619 )

Clarification to Assumption 8 of Calculation NP(F)-163-FA )

Clarification to Assumption 8 of Calculation NP(F)-163-FA:

1 Assumption 8 states that segment forces determined using the l WATHAM computer program are proportional to segment l lengths. This assumption is used to determine segment forces )

on Loops B, C, and D (not modeled using WATHAM program) from segment forces for Loop A (modeled using the WATHAM program) at fluid dynamically similar locations. As documented in the Functional Description portion of the WATHAM manual for the determination of segment forces, the segment force is directly proportional to the fluid density, fluid acceleration, and pipe segment volume (pipe flow area x pipe segment length).

Therefore, it is acceptable to use segment forces determined via WATHAM for Looo A on Loops B. C. and D by ratioing segment lengths at fluid dynamically similar locations between Loop A and Loops B, C, and D.

Previously identifled by NU? O Yee @ No Non Discrepant Condition?O Yes @ No Resolution Pendmg?O vee @ No Resolution Unresolved?O vee @ No l l Review Acceptable Not Acceptable Needed Date p

VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K i IRc chmn: Singh, Anand K O O O Date: 4/14/98 sL comments: We concur with NU's resolution of items 1,2 and 3, and that I thesa items address Significance Level 4 issues.

l Regarding item 4, NU has provided the requested clarification for the assumption, namely that "the segment force is directly proportional to the fluid density, fluid acceleration, and pipe segment volume". We concur with this clarification, especially for the system fill-up transient. For technical completeness, the discussion could be expanded for the system going water solid transient. This is a much faster transient event, for which segment forces may not be directly proportional to the segment lengths, and are more likely to be proportional to the fluid density, the change in fluid velocity, and the finite celerity of the pressure Printed 4/17/9812:so 16 PM Page 3 of 4

ICAVP DR No. DR-MP3-1021 N:rtheast Utilities Millstone Unit 3 Discrepancy Report wave. l l

Regarding the use of segment length ratios, since some segment  !

forces will be larger and others smaller, the overal! effect will not alter the final conclusions of the analysis. To account for the uncertainty, the ratioed segment forces have been increased by a factor of 10%. We, therefore, concur with NU that item 4 is not a discrepant condition.

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ICAVP DR N . DR-MP3-1071 N::rth:34t Utiliths Millstor e Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: I & C Design g Discrepancy Type: Ucensing h O No System / Process: NEW NRC Significance level: NA Date Faxed to NU:

Date Published: 3/1N98 j Discrepancy: Failure modes of instrumentation not fully addressed.

DescripUon: During the review of the safety evaluations for DCRs M3-97042 l l

and M3-97045, the failure modes of the flow instrumentation (3RSS*FT38A,B) which controls 3RSS*MOV38A,B did not appear to be adequately addressed.

Areas of concem:

1. Possible impact of lowerirg the vortex supression grating on  ;

the RSS sump level monitoring instrumentation.

2. Possible nonfunctional aspects of the High Flow Switches. j Examples of the above concems are identified below from Safety Evaluation Number E3-EV-97-0043 Revision No. 0:

1. Section 2.1.1, Pages 7.2-8&9:

The way the logic is stated in this evaluation and per the DCR logic change, the high flow switch will not cause the *MOV38A/B to close unless actual flow is high and there is a failure in the full open position switch contact of the associated spray isolation veive (3RGG'MOV20A/0),2cc in the acimc! !!neup the

• MOV20A/B is always full open before the pump starts. If

• MOV20A/B is closed for pump testing, the flow will not be high enough for the high flow switch to function unless there is some l other failure.

2. Section 2.1.2.d Page 7.212 Prior to the modification, the RSS sump level monitoring probe  !

and float assembly passed through the vortex suppressor  ;

grating. As part of the modification, the vortex suppressor grating was lowered by 12 inches. After the modification, the lower end of the RSS sump level monitoring probe is lower than ,

the new elevation of the grating. There is no discussion of the l impact of the vortex suppressor grating elevation change {

regarding the capability of this instrumentation to function.

3. Section 2.1.4, Page 7.216, third paragraph:

Per calculation NSP-101-RSS Rev.1 states that the range of operation of the high flow switch is between 2118 and 2437  !

gpm. Per calculation US(B)-361 Rev. O, the flow is expected to  ;

reach only 2283 gpm during spray. If the high flow switch function is not removed from the logic, it is possible that the high flow switch may not be able to actuate due to actual flow being less than the upper range of actuation of the high flow switch.

These items have not been addressed in the safety evaluation.

Printed N17/9812:50'.43 PM Page 1 of 4 i

I Ntrtheart Utiliti:s ICAVP DR ND. DR-MP3-1071 Millstone Unit 3 Discrepancy Report l NC Y ,WW valid invalid Needed Date initiator: DeMarco, J.

B 0 0 3/5/98 VT Lead: Neri, Anthony ^ O O O 3/e/98 VT Mgt; schopfer, Don K G O O 3/5/98 IRC Chmn: Singh, Anand K O O O 3/10/S8 Date:

i INVALID: l Date: 4/1/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1071, does not represent a discrepant condition. In item (1) of the Discrepancy Report, Safety Evaluation Number E3-EV-07-0043 Revision 1 was issued 1/30/98. The current reading of the Safety Evaluation concerning failure of the interlock in the mini-recirculation valve logic is as follows: "As part of the RSS orifice modification, an interlock will be installed between the pump mini-recirculation valves (3RSS*MOV38A/B) and the RSS spray header containment isolation valves (3RSS*MOV20A/B).

Upon a CDA , a signal is sent to open valves MOV20A/B (these valves are normally fully open). When the valves are confirmed fully open, a confirmatory signal is sent to close the corresponding mini-recirculation valves, MOV38A/B (these i valves are normally closed). This logic ensures that full flow is I always available to the spray headers. There is only one I condition where an RSS pump could be started with both the l spray valve and mini- flow valve in the closed position, and that I is a manual action during pump testing. The pump testing j procedure will be updated by the CiCR process to require manual  ;

opening of the mini-flow valve prior to pump start. A failure of l both circuits in the control logic leading to a spurious valve l actuation is not considered credible. The circuit will be Installed and tested according to QA procedures. Train separ_ation will be maintained in the design." NU believes that the logic changes l are adequately addressed in the Safety Evaluation and that this I

item does not represent a discrepant condition. Significance level criteria does not apply here as this is not a discrepant condition.

In item (2), the current level switch function and operation is l unchanged by the lowering of the vortex suppression grating.

l The level switches and transmitter are used for level indication l only. The mounting and installation of the Gems level indicating transmitters continues to consist of a float which moves up and down a guide tube with the liquid level. Within the tube a voltage divider is varied within the transmitter, across which a remote meter is connected to provide a continuous readout of liquid level. The operation of this device is unaffected by where the

( normal operating level in the sump is or where the Vortex suppression grating is located. As a result, the Safety Evaluation did not evaluate the impact of the change on the level instrumentation. NU does not consider this item as a discrepant condition. Significance level criteria does not apply here as this is not a discrepant condition.

Printed 4/17/9812:50:47 PM Page 2 of 4

ICAVP DR No. DR-MP3-1071 N:rthea:t Utilitie3 Millstone Unit 3 Discrepancy Report in item (3) of the Discrepancy Report, the high flow switch 3RSS*FT38A/B signal has no effect if the Spray Header Isolation valve is open, thereby causing the miniflow valve to automatically close. The selection of the Low Flow setpoint and the High Flow setpoint must be evaluated against the normal design flow, maximum design flow and the potential for miniflow valve cycling due to corisecutive activation of the low flow and high flow switches. Based on the analysis in calculation NSP-101-RSS Rev.1, there is approximately 131 gpm margin between the design flow point and the low flow setpoint with instrument uncertainty added. Based on the uncertainty range for the high flow switch of 2118 to 2437 gpm, the design flow rate is within the high flow switch uncertainty range. Increasing the high flow (

setpoint further would reduce the utility of the switch, since the  !

setting of 2244 gpm is at the high end of the flow range. Further, l the sole function of the high flow switch is to cause the miniflow {

valve to close on a high flow condition. This high flow condition  !

can only be caused when both the isolation valves (MOV20A/B) l and the mlniflow valves (MOV38A/B) are open at the same time. )

Since the control circuits have been modified such that when l ever the isolation valves are fully open, the associated miniflow valve automatically goes closed, the flow rate will have no effect on the operation of the miniflow valves. The other factor considered in the design was the potential for valve cycling due to consecutive activation of the low flow and high flow switches.

The potential for cycling the minif ow valve is related to the flow capacity in the miniflow line. As shown in NSP-101 RSS Rev.1, the flow capacities for the mini flow line are less than the bistable uncertainty range values, therefore, the potential for ryrHnn m in ennwentivn nrtundnn of the low flow and hiah flow switches is minimal. Based en the above design considerations and the interlocking of the isolation and miniflow valves NU concludes that this does not represent a discrepant condition. Significance level criteria does not apply here as this is not a discrepant condition.

Safety Evaluation E3-EV-97-0040 for DCR M3-97042 addressed the installation of test recirculation lines on the RSS pumps and the installation of ultrasonic flowrate transducers on those recirculation lines. These devices are part of the 3RSS-FTS1 A,B,C,D loops. There is no need for this Safety Evaluation to address the failure modes of 2RSS*FT38A/B, the lowering of the vortex suppression grating and possible impacts, logic interlocks between the isolation and miniflow valves or the setpoint of the high flow switch in the 3RSS*FT38A/B loops as these were not the subject of this DCR.

Safety Evaluation E3-EV-97-0043 references several other Safety Evaluations as well as other documents. Some of the evalutions were written from the broadest prespective while others focused more narrowly on different aspects of the Design Change Request. It is not the intent of the Safety Evaluation to detail all the trade offs and design considerations made during the development of a particular Design Change Package, but rather to make a qualitative assessment of the safety of the activities while referrina the reador to the various desian Printed 4/17/9812:50:48 PM Page 3 of 4 l

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ICAVP DR No. DR-MP3-1071 N:rtheast Utilities Millstone Unit 3 Discrepancy Report 1 I documents or other references used to support the validity of the design. When viewed in this context, E3-EV-97-0043 along with all it's references adequately addresses the design features of l DCR M3-97045 such that a judgement on the safety of the DCR l l

activities can be made.

l

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, i

DR-MP3-1071, does not represent a discrepant condition. There are multiple Safety Evaluations for DCRs M3-97042 and M3-

]

97045, as well as multiple references to other Safety Evaluations )

and other documents. It is not the intent of the Safety Evaluation i to detail all the trade offs and design considerations made during the development of a particular Design Change Package, but ratherto make a qualitative assessment of the safety of the activities while referring the reader to the various design documents or other references used to support the validity of the i design. When viewed in this context, the Safety Evaluations for l l DCRs M3-97042 and M3-97045 along with all there references l i adequately address the design features of the DCRs such that a j judgement on the safety of the DCR activities can be made, f Previously identified by NU? O Yes @ No Non Discrepant Condition?@ Yes O No l

Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Dete

]

g g y f VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K l

~

Date: 4/1/98 sL comments: The RSS orifice modification added the interlock between the MOV20A/B and the MOV33A/B to ensure that MOV38A/B will close if MOV20A/B is full open, if the full open position switch of l MOV20A/B malfunctions, the probability that the high flow switch will function property is only about 50% as shown below-High flow switch actuation band -- 2118 gpm to 2437 gpm, l Maximum system design flow -- 2283 gpm,  !

(2283 gpm - 2118 gpm) / (2437 gpm - 2118 gpm) = 165 /

l 319 = 0.517 Retalning the high flow sw!!ch in the circuitry as a backup to the position switch interlock, based on the above, may require additional consideration regarding its usefulness, but does not impact the safety aspects cf the modification.

Printed 4/17/9812:5o:49 PM Page 4 of 4 J

f Narthenst Utilities ICAVP DR No. DR-MP3-0097 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Potential Operaldity lseue Discipline: Plping Design Discrepancy Type: Calculatmn Om SystenVProcess: QSS g

NRC significance level: 4 Date faxed to NU:

Date Putnished: 9/11/97 Discrepancy: Calculation NP(F)-X7926 - Pipe Supports and valve accelerations not evaluated for current loads

Description:

In the process of reviewing Calculation 12179-NP(F)-X7926 Rev.

2, including Calculation Change Notice (CCN) No,'s 1 through 6 we noted the following discrepancies:

(i) CCN #6, dated 9/13/96 revised the piping stress analysis to incorporate containment dicplacement effects associated with j various accident scenarios, as defined by Calculation No.12179-  !

l NS(B)-168, Rev.1, ' Containment Displacement Profiles'. The l NUPIPE piping model has been reanalyzed to address the l containment displacement effects. Consequently pipe support j loads are revised based on the new analysis. However, no i support summary has been provided in the calculation, and there  ;

l is no Indication that the revised support loads have been transmitted to Pipe Support Engineering for evaluation.

l (ii) CCN #6, dated 9/13/06 references Stress Data Package SDP-l QSS Rev. O, dated 1 14 83. However, CCN :#3, dated 9/17/85 already evaluated the impe.ct of revisions 1 through 3 of the Stress Data Package. CCN#6 does not reflect the appropriate revisien Of the 5Ue53 data packagc.Thc 'atcs; recica cf the Data Package is Rev. 6.

(iii) CCN #1, dated 7/16/S5 states that ' valve accelerations due to time history forces exceeded allowables of 3.0 g's for valves 3QSS*V7 and 3OSS*V3. The calcuation recomputes reduced acceleration values, however, the reduced acceleration levels reported in CCN #1 still exceed the allowable of 3.0 g's.There is l no justification provided for accepting these higher acceleration

! values.

I Review Valid Invalid Needed Date initiator: Jain, R. C. O O O 8/29/97 VT Lead: Nort, Anthony A B O O 9/2/97 VT Mgr: Schopfer, Don K G O O 5F8/S7 IRC Chmn: Singh, Anand K O O O 5v8'S7 D.te:

INVALID:

Date: 4/16/98 RESOLUTION: Response ID: M3-lRF-00433 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0097, items Printed 4/17/961151:38 PM Pege 1 of 4

N:rtheast Utilities ICAVP DR No. DR-MP3-0097 Millstone Unit 3 I Discrepancy Report (ii) and (iii) have identified conditions not previously discovered by NU which requ!re correction. Condition Report (CR) M3 3247 was written to provide the necessary corrective actlans to resolve these issues. The calculation will be revised to propeny I f

address the identified conditions. NU has also concluded that item (i) does not represent a discrepant condition.

CCN Number 6 to Calculation 12179-NP(F)-X7926 Rev. 2 was 1 prepared in accordance with the OSS, RSS and SI stress reconci!iation program established in 1996 te address the l increased containment ambient temperature affects on those j systems. That program was based on a phased approach to I calculations. Phase 1 ce!culations were used as a preliminary design input to allow revicu and disposition of potential modifications for equipment and pipe support commodities in parallel with the stress analysis calculation preparation. Phase ll calculations were prepared as interim documents, usubily CCN's, which would document the final design, including the independent review, but which would not include all of the information typically provided in a calculation of r6 cord, information which enhances the auditability of the document.

Phase ill calculations are in process of t'eing prepared and will satisfy the Design Control Manual requirement to be comprehended without an assisted review. The subject CCN 6 is a Phase 11 calculation wh2h is scheduled to be updated to a Phase Ill status approximately November 1997. Support loaa l summaries were therefore not included in CCN 6; rather they l were provided to the appropriate engineering parties via l controlled transmittals. Load summaries will, however, be l included in the Phase lil ca'culation. Refer to NU letter CES 21R /mttnrhd} fnr def nHn nf the rwod nnnrnnch fnr r.nlenilation preparation. Significance level criteria do not apply to item i as this is not a discrepant condition.

As stated in Item si, Calcu!ation X7926 CCN 6 has an incorrect reference to the OSS-SDP When the change was issued, QSS-SCP Rev. 4 was the latest issued revision for the Stress Data Package (SDP). Revisions 5 and 6 of the SDP calculation were issued after CCN 6 to the rtress calculation, as part of the review and update process for ah CDPs, and as stated in pages 3 and 5 of the SDP calculation. This formal process was performed on all QA Category 1 SDPs as a function of the Configuration Management Program (C'1P) to re-institute the SDPs as the controlled input for QA Cr egory I stress calculations. As explained in the SDP calce'ations, before start of the CMP, SDPs were frozen in 1980 and were not kept current. Since the current SDPs were reviseJ as a tackfit, the reference to the SDP provided in the associated stress calculations is outdated. This was understood as part of the backht piogram and is explained in the current revisions to the SD?s. Therefore, this discrepancy is limited to the referenced calcuhtion, and do not represent a programmatic weakness With respect to item lii, the process used for determining acceptable valve accelerdions is documented in the project criteria document NETM-49,' Procedure for Verification / Resolution of Ruipment Nozzle Loads and Valve Accelerations.' which incl "es incructions for resolvina valve Printed 4/17/9612:51:41 PM Page 2 of 4

= -

1 N:rtheast Utilitie3 ICAVP DR No. DR-MP3-0097  !

Millstone Unit 3 Discrepancy Report i accelerations which exceed the 3.0 g threshold requirement.

l Resolution of valve acceleration acceptability issues was documented in the Valve Acceleration Index controlled by the Mechanical Equipment Group. T here was no requirement to update the stress calculation if the valve acceleratiotis were determined to be acceptable. In this case, however, the technicaljustification contained a mathematics error which invalidates the conclusions. Therefore the discrepancy is valid due to an error in calcu!a'ing combined accelerations, ar'd not due te a programmatic deficiency.

! l l

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0097, items (ii) and (iii) have identified conditions not previously discovered by NU which require correction. Condition Report (CR) M3 3247 was written to provide the necessary corrective actions to resolve these issues. The calculation will be revised to proper 1y address the identified cond!! ions. NU has also concluded that item (i) does not represent a discrepant condition.

Response ID: M3-IRF-01125 Disposition:

This IRF is a follow-up to IRF-MP3 0483. Condition Report (CR) l M3-97-3247 corrective ccien plan has been approved to ensure l that calculation 12179-NS(0)-168 wi:1 be revised to correct the deficient conditions. Tite justificctions for the 3OSS*V3 and V7 unlue nrPmfornfinne v#! hn tendn',d tn nrnu!rio tho hnele frsr j acceptance. The calculatica will be revised to reference the appropriate revision of the Stress Data Package. The oisposition l l Of item (i) remains as stated in IRF-MP3-0483.

Conclusion:

This IRF is a follow-up to IRF-MP3-0483. Condition Report (CR) l M3-97-3247 corrective acticn pian has been approved to ensure l that calculation 12179-NS(0)-168 will be revised to correct the i deficient condition. The justifications for the 3OSS*V3 and V7 valve accelerations will be updated to provide the basis for acceptance. The calcu!alico will be revised to reference the appropriate revision of the Stress Data Package. The disposition of item (i) remains as stated in IRF-MP3-04R3.

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N rtheast Utilities ICAVP DR No. OR-MP3 0097 Millstone Unit 3 Discrepancy Report I

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l Page 3 of 3 l Previously identifled by Nu? O Yes (8) No Non Discrepant Condition?O Yes (G) No Resolution Pending?O yes @ No nesoiution unresolved?O vos CG)No Review Acceptable Not Acceptable Needed Date

! VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K l IRc Chmn: singh, Anand K Dete: 4/6/98 SL Comments: Note: The Following discrepancies required corrective action on l the response provided in Response ID: M3-IRF-01125.

i 1. Nu response in Ms-ixt -u11zb incorrecuy iaentities l calculation 12179-NS(B)-1CS.

The correct calculation number is 12179-NP(F)-7926 Rev. 2,CCN-

6. CR-M3-97-3247 does identify the correct calculation but lebels this a pipe support calculation. The subject calculation is a pipe stress calculation.

2. Reportability Evaluation CR No. M#-97-3247 page 1 of 1 SRSS Of the seismic plus time history accelerations in each of the l 3 directions yields 3.85,2.63,3.22 ( worst case is OBE not SSE )

! g's in the X, Y and Z directions respectively. SRSS of these 3 components yields a vector accleration of 5.66 ( not 5.39 ) g's versus 5.19 g's allowable. Ceismic qualification report D0057-1,3,4 and 5 shows enough margin for valve stresses But the operaror has been qualified only for a 3g acceleration (Seismic

! qualification envelope B-0037).

l We concur with NU that there is no programatic requirement for l l updating the stress calculation provided that the acceleration l levels were determine to be acceptable.However, no tracable path for the resolution is previded in the Seismic Qualification  !

Report, or in the stress ca'culation. l l

Printed 4/17/9812:51:43 PM Page 4 of 4

N:rtheast Utilities ICAVP DR No. DR-MP3-0697 Millstone Unit 3 Discrepancy Report m

Reyww Group: system DR RESOLUTION REJECTED Potential Operability lasue Discipline: Mechanical Design Discrepancy Type: Component Data Om Systen@rocess: HVX @ No NRC significanca level: 4 Date F Axed to NU:

l Date Published: 12/8/97 l Discrepancy: ABVS and SLCRS Fire Dampers

Description:

During review of the auxiliary building ventilation system (ABVS)

( and supplementary leak co!!cction and release system (SLCRS) l fire dampers discrepancies regarding fire damper sizes were identified.

l The sizes of the following fire dampers shown on specification )

2170.430-565 data sheets do not match the available fire  !

damper sizes shown on DCN DM3-01-1296-96 and DCN DM3 l 12986-96 (drawings 25212-29565 sh. 555 and 556):

i 3HVR*DMPF6 41"x17"with minimum of 2 sections j 3HVR*DMPF7 41"x17" with minimum of 2 sections l l 3HVR*DMPF8 33"x21" 3HVR*DMPF18 50"x24"with minimum of 2 sections 3HVR*DMPF23 54"x36"with minimum of 2 sections l 3HVR*DMPF24 34"x36" with minimum of 2 sections 3HVR*DMPF25 54"x36" with minimum of 2 sections 3HVR*DMPF26 20"x10" w!!h minimum of 2 sections l 3HVR*DMPF29 15"x30" l 3HVR*DMPF30 30"x30"with minimum of 2 sections 3HVR*DMPF31 10"x10" w:!h minimum of 2 sections 3HVR*DMPF32 14"x12" with minimum of 2 sections 3HVR*DMPF44 15"x30" 3HVR*DMPF60 8"x5" with minimum of 2 sections 3HVR*DMPF61 9"x7" with minimum of 2 sections 3HVR*DMPF62 10"x9" with minimum of 2 sections 1 3HVR*DMPF64 8"x4" with minimum of 2 sections l The maximum UL rated sincie damper section size of 36"x36" shown on drawings 25212-23565 sh. 555 and 556 is exceeded for the following fire dampers 3HVR*DMPF10 48"x46" requires a minimum of 4 sections compared to 2 listed in data sheet 3HVR*DMPF12 48"x48" requires a minimum of 4 sections compared to 2 listed in data sheet.

! 3HVR*DMPF14 48"x4S" requires a minimum of 4 sections compared to 2 listed in data sheet.

3HVR*DMPF16 48"x4E" requires a minimum of 4 sectimes compared to 2 listed in data sheet.

The sizes for the following f:re dampers shown on the data sheets and in PMMS do not match 3HVR*DMPF17 38"x32"-vs- 50"x24" 3HVR*DMPF8 33"x21"-vs.17"x42" Printed 4/17/9812:s2:16 PM Page 1 of 4 l

N:rthe=t Utilities ICAVP DR No. DR-MP3-0697 Millstone Unit 3 Discrepancy Report l 3HVR*DMPF6 41"x17" -vs- 17"x42" l

Review Valid invalid Needed Date initietor: stout, M. D. O O O i/21/97 ,

VT Lead: Neri, Anthony A O O i /22/97 O l VT Mgr: schopfer, Don K O O O 12/1/97 IRC Chmn: sinGh, Anand K O 12/va7 O O Date:

l>NAll0:

Date: 4/16/98 I RESOLUTION: First Response NU has concluded that Discrepancy Report DR MP3-0697 has identified a condition not previously discovered by NU which requires correction.

The sizes given in the purchase specification data sheets for

• DMPF17; 8; 7; and 6 do nct match the sizes given in PMMS for the same dampers. NU acknowledges this discrepancy. It should be noted that PMMS is not the MP3 design data base; PDDS is. The approved corrective action plan for CR M3 4572 will correct the PMMS errors post startup.

NU has concluded that the remaining two issues reported in Discrepancy Report DR MP3-0G97.do not represent discrepant  ;

conditions.  !

l Ine minimum z secuons specmea in me camper aata sneets in 2170.430-565 for safety related fire dampers is intended to l prevent the failure of one single fire damper section from impairing the safety function of the system. The specification approves two manufacturers for Cat i fire dampers; Air Balance Co. and Ruskin Mfg Co. Af stoved mfg. drawings 25212-29565, sh. 555 and 556 show that 4"x4is the minimum available single l size and 36"x36"is the largt st available single size. It should be l understood that the manufa:turers, Air Balance Inc. and Ruskin I had the option of fabricating the finished assemblies of fire l dampers from more than 2 single sections, and remain in compliance with the requirements of 2170.430-565.

1 The maximum UL rated sinr!e damper section size of 36" x 36" shown on drawings 25212-23565, sheets 555 and 556 is not exceeded by the sizes given for "DMPF10; 12; 14; and 16. Each of these is a 48" x 48" (overall) fire damper constructed from four (equal size) single damper c:ctions. Although the purchase specification data sheets s!: ta that each of these dampers must l be made from a minimum c: 2 Ingle damper sections, to meet l the single failure criterion, the emper supplier may, for manufacturing or fabricating cunniderations, supply fire dampers made of more than 2 single sett:ons and still comply with the requirements of 2170 430-C5 In this case, Air Balance Inc.

specifies a maximum sing lc sect;on size of 36"x36", so a 48"x48" fire damper assemt iy must be made from more than 2 Printed 4/17/9812:52:20 PM Page 2 of 4 I

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_. i N:rtherst Utilitie3 ICAVP DR No. DR-MP3-0697 )

Millstone Unit 3 1 Discrepancy Report i I

sections..

l The errors found in PMMS do not affect licensing basis or design )

basis and have no technical significance with regard to periodic l

testing of safety related fire dampers. NU, therefore, considers this a Significance Level 4 ircue, j 1

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Attachments:

l CR M3-97-4572 with correctivo action plan 1

Second Response (M3-IRF-C2113) l J

NU has concluded that the r~mted problem reported in l Discrepancy Report DR-MP 2-LC97 does not represent a l discrepant condition. l l Dampers 3HVR*DMPF10,12. t 4, and 16 were purchased on l P.O. number 12179-15335. This purchase order lists these j l dampers as item numbers 13,15,17, and 19. The data sheets j l for each of these dampers date that they are made up of two i minimum sections (item F), in accordance with the requirements l of specification 2170.t,30-5C 5, however, the manufacturer's model number given for ean cf these units is 319ALV. The manufacturer's drawing atta'h ed to the purchase order displays this model as a four section nsembly. Copies of the data sheets ,

! and the Air Balance Inc. dre .i m of the model 319ALV multi- l l section fire damper are atta ched.

! The information given in drrwings 25212-29565, sh. 555 and 556

!S genet te ?!! 'he * *M c ' . ~ ' eri 'i re ri e m ne re 'h' a 'M i information on each of these d:mpers can be found in the

! purchase orders issued to the two approved vendors, Ruskin and Air Balance. I Configuration of the safety r WM fire dampers is in accordance with the MP3 design basis e d : censing basis. NU considers l this issue non-discrepant. I"J i rrevious response stated in M3-

! IRF-01205, concluded that & . ' MMS database was in error and would be revised per the af mwrd corrective action for CR M3-97-4572. NU, therefore, c mi' ors this issue Significance Level 4.

Attachments:

P.O. No.12179-15335, pam 0 through 13, and dwg. Mi-2566-2 Previously identified by NU7 O ves fS) No Nor ,r r pant Condition?O vos (9) No Resolution Pending?O vos @ No r' eMion Unresolved?O vos @ No Review initletor: stout, M. D.

VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: s@, Anend K O O O oste: 4/16/98 sL Comments: Comments on First Responee Printed 4/17/9812:s2:22 PM Pege 3 of 4

N:rtheast Utilities ICAVP DR No. DR-MP3-0697 Millstone Unit 3 Discrepancy Rer. ort Dampers 3HVR*DMPF10,1.b & 16 require a minimum of 4 sections inorder to meet the ' 1 maximum section size limits.

Provide vendor submittal d- s or other documentation that confirms that these damper a fabricated with 4 sections.

Drawings 25212-29565 sh. E C 0 cod 556 and spec data sheets should be revised to reflect tha' the dampers require a minimum of 4 sections.

NU's response did not adeqqntc!y address the differences in damper sizes shown on the <.'ata cheets and drawings 25212-29565 sh. 555 and SEG. Doc'!metation on the damper sizes and number of sections fabricate ! ca1 installed are needed.

Comments on Second Resr^nse Agree with NU's response ti. t C&W PO 12179-15335 calls out i Air Balance Model 319ALV rr vertical fire dampers l (3HVR*DMPF10,12,14, an ! 1() and that Air Balance drawing Mi-l 2566-2 shows a four section : re damper. Since these dampers l require 4 sections to meet tr,xnr um section size limits drawings l 25212-29565 sh. 555 and SC 3 r nJ specification data sueets I

should be revised to reflect !?nt the dampers require a minimum of 4 sections. This is cons;d "e:I a Level 4 documentation l discrepancy.

l l NU's response did not addrm the differences in damper sizes l shown on the specification r ' : rneets and DCN DM3-01 1296-96 (drawings 25212 29565 r n '2 5 and 556). This is considered a LcVc! 4 di.,ciCpancy.

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N:rtheast Utilities ICAVP DR No. DR-MP3-0890 Millstone Unit 3 Discrepancy Report Review Group: System CR RESOLUTION REJECTED Potential Operability issue I Discipline: Mechanical Design Discrepancy Type: Component Data Ow I System / Process: DGX ft) No NRC Significance level: 4 Date Faxed to NU:

Date Published: 1/22/98  :

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Discrepancy: Design' Data for the EDG Cy!inder Liner Jackets & Turbochargers j

Description:

FSAR Table 9.5-3 " Design Data for Components in the l

l Emergency Generator Cooling Water Systems" defines the

)

j following for the Engine Cy!: der Liner Jackets and j Turbochargers: J I

Temperature Differential = 15 degrees F normal ; 18 degrees F i maximum Design Heat Removal Rate = 6,781,000 BTU /hr Design Margin = 678,100 BTU /hr Total Design Heat Remova! Rate = 7,459,100 BTU /hr A review of the purchase specification (2447.300-241), P&lD's j (EM-116A & EM-116C), the vendor drawings and the Operating ]

Instruction Manual OIM-241, was not able to confirm this '

information.

Reference REQ-MP3 DGX-E']7 Review Vahd invalid Needed Date Initiator: Hameetman, R. O O O 12/22/97 l VT Lead: Neri, Anthony A B O O 12/20/97 VT Mgt: schopfer, Don K O O O 12/23/97 IRC Chmn: singh, Anand K O O O 1'17/88 Date:

INVAUO:

Date: 4/2/98 RESOLUTION: Disposition:

NU has concluded that Disempancy Report DR-MP3-0890, has identified a condition not preCously discovered by NU which l requires correction. The appreved corrective action plan for CR M3-98-0764 (attached) will provide the following:

1. Reorganize the Table to show that some of the Design Heat Removal Rates stated in the Table are actually Heat Rejection Rates and that their sum can be compared with the Heat Exchanger's heat removal rr.tes to show mar 0in.

2. Revise Table 9.5-3 to not1 that margin was provided in the design rating of the Intercoc'er and Jacket Water Coolers by sizing them at 110% Load (Wf. Coltec Engineering Report R-5.00-0260 dated 12/15/93).

FSAR Table 9.5-3 will be revised prior to entering Mode 2.

Conclusion:

l NU has concluded that Discrepancy Report DR-MP3-0890, has l identified a condition not pro !cusly discovered by NU which Printed 4/17/9812 s2:s4 PM Page 1 of 2 l

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r N::rthesst Utilitbs ICAVP DR No. DR-MP3-0490 Millstone Unit 3 Discrepancy Report requires correction. The approved corrective action plan for CR l M3-98-0764 (attached) re-organize FSAR Table 9.5-3 and revise the table to note that margin was provided in the design rating of the intercooler and Jacket Water Coolers by sizing them at 110% Load. FSAR Table 9.5-3 will be revised prior to entering Mode 2.

Previously identmed by NU7 O Yes @ No Non Discrepant Condition 7U Yes @ No Resolution Pending?O Yes @ No Resolution unresolved 70 Ye. @ No Review Acceptable Not Acceptable Needed Date OWW VT Lead: Nort, Anthony A VT Mgr: Schopfw, Don K IRC Chnm: singh, Anand K Date: 4/2/98 sL Comments: S&L agrees with the NU's CR M3-98-0764 Corrective Action #2 that the FSAR Table 9.5-3 should be revised. However, please indicate how will the revised Table be supported by design 4 documents and/or vendor information. S&L also assumes that when FSAR Table 9.5-3 is revised, the revision will include a resolution to DR-MP3-0917, items 2,3, and 4 as well. NU resoonded to the DR-f/J3-0917 with the Response M3-IRF-01713.

In addition, to complete the verification of the disposition for this Discrepancy Report further information is required. Based on the documentation submitted with the NU resporise M3 IRF-01847, we were unable to conclude that the design of the air cooler water heat exchanger and incket water cooler supports diesel oenerator operation during the 30 min. load rating (5983 kW).

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