ML20217B224

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Forwards Discrepancy Rept Identified During Review Activities for Independent Corrective Action Verification Program.Dr Distributed in Accordance W/Communications Protocol,PI-MP3-01
ML20217B224
Person / Time
Site: Millstone Dominion icon.png
Issue date: 03/24/1998
From: Schopfer D
SARGENT & LUNDY, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9803250447
Download: ML20217B224 (124)


Text

r as W aL Sar gerutsA. L. undy"c Don K. Schopfer Senior Mce President 312-269-6078 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed one (1) discrepancy report (DR) identified during our review activities for the ICAVP. This DR is being distributed in accordance with the Communications Protocol, PI-MP3-01.

DR No. DR-MP3-1086 I have also enclosed the following thirty-one (31) DRs for which the NU resolutions have been reviewed and accepted by S&L.

9003250447 980324 PDR ADOCK 05000423 P PDR DR No. DR-MP3-0045 DR No. DR-MP3-0554 ,

DR No. DR-MP3-0063 DR No. DR-MP3-0571 l DR No. DR-MP3-0131 DR No. DR-MP3-0583 DR No. DR-MP3-0146 DR No. DR-MP3-0613 -

DR No. DR-MP3-0266 DR No. DR-MP3-0666 DR No. DR-MP3-0268 DR No. DR-MP3-0710  !

DR No. DR-MP3-0273 DR No. DR-MP3-0785 gg  !

DR No. DR-MP3-0341 DR No. DR-MP3-0792 DR No. DR-MP3-0453 DR No. DR-MP3-0856 Di DR No. DR-MP3-0454 DR No. DR-MP3-0457 DR No. DR-MP3-0931 DR No. DR-MP3-0961 N

DR No. DR-MP3-0493 DR No. DR-MP3-0988

' DR. No.DR-MP3-0518 DR No. DR-MP3-1014 DR No. DR-MP3-0523 DR No. DR-MP3-1025 i DR No. DR-MP3-0526 DR No. DR-MP3-1058 DR No. DR-MP3-0547 55 East Montce Street

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

United States Nuclear Regulatory Commission March 24,1998 Document Control Desk Project No. 9583-100 Page 2 I have also enclosed the eight (8) DRs for which the NU iesolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.

DR No. DR-MP3-0130 DR No DR-MP3-0695 DR No. DR-MP3-0572 DR No DR-MP3-0713 DR No. DR-MP3-0608 DR No DR-MP3-0929 DR No. DR-MP3-0688 DR No. DR-MP3-1066 Please direct any questions to me at (312) 269-6078.

Yours very truly, l t

}f __ k.  % --

D. K. hopfer Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:

E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU nrkevpM8WO328+duc

1 Northe:st Utilities ICAVP DR N3. DR-MP3 0046 Misistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operebility issue Diecipline: Structure! Design Discrepancy Type: Calculehon Om System / Process: RSS gg J

NRC Sign 6Scence level: 4 Date faxed to NU:

Date Published: ar28/97 D6ecrepancy: Pipe support calculation discrepancy Deecription: We have reviewed pipe support calculation no.12179-NP(F)-

Z798-148, Rev. 3, CCN No. 2. Based on this review we have noted the following discrepancy.

The allowable bolt load =40.6 kips, is used on page-S of the calculation. For plate material A-36 ( FU=58 ksi), the allowable load is 36.3 kips per AISC,9th ed., page 4-7.

Review Valid invalid Needed Date initiator: Patel, A.

8 0 O e/20s7 l

VT Lead: Nwl, Anthony A O O O ar2ars7

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VT Mor: Schopfer, Don K B O O ar22/97 IRC Chmn: Singh, Anand K -

0 0 a/22/97 Date:

INVALID:

Date: 3/23/98 j i

RESOLUTION NU has concluded that Discrepancy Report, DR-MP3-0045, has identified a condition not previously discovered by NU which requires correction. CR M3-97-2944 has been initiated to address this condition. There is no impact to the pipe support calculation conclusions as there exists margin in the design. The calculation will be revised to correct this error.

Previously identined by NU7 O Yes (s) No Non Diacropont Condit6on?O Yes (y) No Resolution Pending?O vee @ No Resolut6on Unresolved 70 ve. @ No Review i Initiator: Palet, A.

VT Lead: Nwl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/23/98 SL Comments:

i l

Printed 3/24/96 2:17:01 PM Page 1 of 1

i Northeast Utilities ICAVP DR N . DR-MP3-0063 Millstone Unit 3 Discrepancy Report Review Group: Corfgurstm DR RESOLUTION ACCEPTED Review Element: System tretellotm p Diecipline: EW Deelen Discrepency Type: Instegetion implementatbn O vee SystesWProcese: SWP gg NRC Significance level: 4 Date faxed to NU:

Date Published; af31G7 D6ecrepancy: Conduit Support Drawing does not reflect all attached conduits Dacription: Conduit support ES-135 has three safety related conduits attached and one lighting conduit. The lighting conduit is unscheduled and field supported. The Conduit Support Log for ES 135 (drawing 12179-FSK-ES-135 Rev. 2) with no outstanding change documents, does not included the lighting conduit in the tabulations of conduits. It does show the conduit in the section detail, however, the depiction of conduits has been previously noted as information only. Further, previously reviewed support drawings have included the lighting conduits in the tabulations.

The Electrical Installation Specification E350 (Section 3.5.12) indicates that lighting conduits shall comply with applicable requirements of the specification. The Specification (Section 3.1.3.11, item 5) requires that all non-seismic conduit, which j should include non-essential lighting such as this, shall not be attached to tray hangers without engineering approval. Since the conduit is not shown on the support drawings, there is no evidence of this approval and it is, therefore, unclear if all support loads are correctly calculated.

Review Valid invalid Needed Date initiator: Server, T. L 9 0 0 ar27/97 VT Lead: Nerl. Anthony A B O O ar2as7 VT Mgr: Schopfer, Don K O O O st28/97 1RC Chmn: Sin $, Anand K O O O ar2as7 Date:

INVALID:

Date: 3/23/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0063, has identified a condition not previously discovered by NU which requires correction. CR # M3-97-2983 has been initiated to I address this condition. A DCN shall be initiated to correct the I drawing to 'As Built condition in the field and bring into compliance with the Electrical Specification E350 ( now SP-EE-l 076 Section 3.3.19.1 item 5 and Section 9.3.6).

Previously identified by NU? O vos @ No Non Discrepent Condition?O ves @ No R-owsonPenana?O va @ No RuoMionUnruolved?O va @ No Review  ;

initiator: Kleic, N VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:

Printed 3/2N96 2:17:42 PM Pope 1 or 2 l

ICAVP DR N3. DR-MP3 0063 Northe "_t Utilitis3 Millstone Unit 3 Discrepancy Report SL Comments:

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PrWed 3/2498 2:17:40PM Page 2 of 2

l Northe:st Utilities ICAVP DR No. DR-MP3-0131 Millstone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: correctrve Action Procese Diecipihe: Ppng

  • D6ecrepancy Type: Cormeth Action O vee Syste NProcese: SWP fe) No NRC S; =.r.s level: NA Date faxed to NU:

Date Published: 9/19/97 Diecrepancy: No Safety Evaluation or Substantial Safety Hazard evaluation for NCR dispositioned "Use-as-Is"

Description:

CR M3-97-0915 identified a substandard coating thickness for inlet screen 3EGS*E18. NCR 397-046 was initiated and dispositioned USE-AS-IS since the thickness was judged to be sufficient to perform the required function (prevent corrosion).

No Safety Evaluation, or Substantial Safety Hazard Evaluation as required by procedure NGP 3.05, was performed for this change.

Review Valid invalid Needed Date initletor: Wrone, S. P. O O O S5/S7 VT Lead: Ryan. Thomme J B O O S/3/87 VT Mgr: Schopfer, Don K O O O S/S/S7 IRC Chmn: singh, Anand K O O O S/12S7 1 Dele:

INVALID:

Date: 3/20/98 RESOLUTION Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0131, does not represent a discrepant condition. NGP 3.05 requires a SSH evaluation be performed if ,"the suspected deviation, defect, or noncompliance could exceed a technical specification, or cause a major reduction in public health and safety if installed in the plant. The ARCOR coating is applied to the structural portions of the inlet screen for 3EGS*E1B to isolate the potential galvanic cell between the screen and the heat exchanger channel head and tube sheet. The dry film thickness attained as reported in the NCR (17.9 mils) was determined to be sufficient to perform this function. The thickness of the ARCOR coating is a corrosion and equipment life issue. This does not meet the standard of NGP 3.05 or NGP 2.01 for when a SSH is required. Additionally the NCR form was checked by the responsible supervisor indicating that no SSH evaluation was required. This is what is required by the procedure. There was and is no requirement that a safety evaluation be performed for an NCR at the time this NCR was initiated.

Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0131, does not represent a discrepant condition. The ARCOR coating is applied to the structural portions of the inlet screen for 3EGS*E1B to isolate the potential galvanic cell Printed 3/24/98 2.18:15 PM Page 1 of 2

Northe:st Utilities ICAVP DR Nr. DR-MP3-0131 Miiistone unit 3 Discrepancy Report between the screen and the heat exchanger channel head and tube sheet. The dry film thickness attained as reported in the NCR (17.9 mils) was determined to be sufficient to perform this function. The thickness of the ARCOR coating is a corrosion and equipment life issue. This does not meet the standard of NGP 3.05 or NGP 2.01 for when a SSH is required. There was and is no requirement that a safety evaluation be performed for an NCR at the time this NCR was initiated.

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

Previously identined by NU7 U Yes (G) No Non Diecrepent Condition?@) Yes O No Resolution Pending?O Yes @ No ResolutionUnresolved?O Yes # No Review Ac ri % Not Acceptable Needed Me Miete New M =

VT Leed: Ryan, Thomes J O O VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Date:

{

SL comments:

Printed 3/2498 2:18:24 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3 0146 Mmstone Unit 3 Discrepancy Report Revk w Group: Picy . . 3c DR RESOLUTION ACCEPTED PotentialOperabiNty leeue DiecipNne: I a c Desig" O von Discrepency Type: Licensing Document g System /Procese: DGX NRC Signmcance level: NA Date faxed to NU:

Date Published: 9/11/97 Diecrepency, incomplete response to ACR # M3-96-0928

Description:

Condition Report has a Significance Level of "B" and requires a Root Cause Analysis; however, only an Apparent Cause Analysis was attached to the package.

Review Valid inveNd Needed Date initiator: Dombroweid, Jim B O O e/2/97 V7 Lead: Ryan. Thomes J B D D e/2/97 VT Mgr: schopfer, Don K B O O S'$S7 1RC Chmn: Singh, Anand K 8 0 0 S'S'87 Date:

INVALID:

Dete: 3/20/98 RESOLUTION NU has concluded the the issue reported in Discrepancy Report, DR-MP3-0146, does n >t represent a discrepant condition. ACR M3-96-0928 was close d to ACR M3-96-0924 which addressed the following NRC Esc alated Enforcement items eel 423/96-201-02,04,06,07 &O8 which were apparent violations identified in NRC IR 96-201 (Vergilio Report).

The specific issue addressed in ACR M3-96-0928 was eel 423/96-201-07 which was the failure to perform a safety evaluation for a set point change to the Emergency Diesel Generator (EDG) low room temperature alarm for MP3. A Common Cause Assessment of the Apparent Violations at Millstone identified in NRC IR 96-201 was performed in association with ACR M3-96-0924. The Common Cause Assessment addressed the apparent violations in NRC 1R 96-201 and determined the common root cause for these violations. The Common Cause Assessment is an approved equivalent method to perform the root cause evaluation.

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

CONCLUSION:

- NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0146, does not represent a discrepant condition. The necessary causal assessment was performed as part of ACR M3-96-0924.

ACR M3-96-0928 was closed to ACR M3-96-0924 and r Common Cause Assessment was performed which addressed the issue discussed in ACR M3-96-0028. The Common Cause Assessment is an approved equivalent method to perform the Printed 3/24/96 2:19.03 PM Page 1 or 2

ICAVP DR No. DR-MP3-0146 )

Northeast Utilities millstone unit 3 Discrepancy Report l l

root cause evaluation.

Significance level criteria do not apply here as this is not a discrepant condition Previously klentmed by NU7 U Yes @ No Non Discrepent Condmon?(#j Yes O No n okmonP.nane70 Ya @ No naduuanuaradved70 Y @ No nevi M ." "- Nd hardh Needed Date VT Leed: dyan, Thomas J VT Mor: Schopfer, Don K NtC Chmn: Shgh, Anand K Deke: 3/17/98 sL comments: Since ACR 928 was closed to ACR 924, ACR 924 should have been included / submitted as the dispositioning document to ACR 928. S&L agrees that the condition is not discrepant.

PrWed Y2N96 2:19:06 PM Pege 2 of 2

ICAVP DR No. DR-MP3-0266 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operabilty leeue D6scipline: uncheniced Design O vee D6screpancy Type: Licensing Document g SysterWProcese: QSs NRC SL =n.e level: 3 Date faxed to NU:

Date Published. 11/17/97 D6screpency: Minimum RWST Level During ECCS Suction Switchover in FSAR and in US(B)-295 Description. CCN 1 to Calculation US(B)-295, Rev. 5 calculates the RWST drawdown time from the minimum ECCS suction switchover level to uncovery of ECCS suction by using the value of 19'-2" from FSAR Figure 6.3-6 as the minimum ECCS suction switchover level.

FSAR Section 6.3.2.2.3 and FSAR Figure 6 3-6 state that the minimum RWST level during ECCS suction switchover is 19'-2".

The discrepancy is that the minimum RWST level during ECCS suction switchover is 18.90 ft, calculated from the inputs to US(B)-295 as follows:

MINIMUM VALUE FOR RWST LOW-LOW LEVEL TRIP (It is assumed to trip only one the two RHS pumps due to single fa!!ure in control system):

Inside Diameter of RWST = 59'-0" RWST Volume level = (59'-0"/2)^2(3.14159)(1 ft)(1728 cuin/cuft)/(231 cuin/ gal)

= 20.451 gal /ft level Low-Low Level Setpoint = 25.417 ft Level Switch / Trip Circuit Accuracy = - 2.000 ft Minimum Low-Low Level Trip = 23.417 ft MAXIMUM RWST OUTFLOW AFTER* THE LOW-LOW LEVEL TRIP:

2 CHS pumps = 320 gpm 2 Si pumps = 890 gpm 2 QSS pumps = 6500 gpm TOTAL = 8210 gpm

  • The manual ECCS suction switchover from RWSTsuction to RSS/ sump suction is assumed to take 10 minutes 1 RHS pump" = 5100 Opm

" It is assumed that one RHS pump does not automatically trip on low-low level and it is assumed that the operator response time to manually identify and trip it is 2 minutes.

THE MAXIMUM VOLUME OF WATER TAKEN FROM THE RWST AFTER THE LOW-LOW LEVEL TRIP:

/A91n "'nnmilin mini + (Minn nnmit?

mini = 09 ann nnt

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Printed #2N98 2:19A0 PM Page 1 of 3

Northeast Utilities ICAVP DR No. DR-MP3-0266 milistone unit 3 Discrepancy Report THE MAXIMUM RWST DRAWDOWN AFTER THE LOW-LOW LEVEL TRIP; 92,300 gal / 20,451 gal /ft level = 4.513 ft The inputs to US(B)-295 imply that the minimum RWST level during ECCS suction switchover is:

23.417 ft - 4.513 ft = 18.90 ft This discrepancy in minimum RWST level during ECCS suction switchover also affects the minimum RWST drawdown time that is calculated in CCN1 to US(B)-295 of 33.4 minutes from the minimum RWST level at the termination of manual suction switchover to the top of the ECCS suction. This drawdown time is also affected by the use of urealistically high QSS flows as discussed in DR-MP3-0440, but the effect is to compute a conservatively short drawdown time.

Review Valid invalid Needed Date initiator: Wakeland, J. F. O o' 3'S7 O O VT Lead: Nerl. Anthony A B O O 'o/14/S7 VT Mgr: schopfer, Don K O O O or2alo7 IRC Chmn: singh, Anand K B O O 11/13/87 Date:

INVALID:

Date: 3/17/98 RESOLUTION DISPOSITION:

NU has concluded that DP-MP3-0266 identifies a condition previously discovered by NU which requires correction.

This item is considered previously discovered as ACR M3 0499 was raised on 8/1/96 to clarify and define the basis for RWST level at which the RHR pumps shuts off. Part of the corrective action for this ACR is to re-evaluate calculation US(B)-

295. Revision 6 of the calculation, dated 10/14/97, resulted in a new value for RWST lower bound level for ECCS pump operation, due to changes in various input parameters, including pump flow values. The calculation is currently in the process of revision as a result of Design Change Request (DCR) 97106.

This DCR will change RWST/QSS level setpoints and revise the FSAR to include the new values.

Design change modification DCR M3-97106 installation and testing is scheduled to be completed prior to Startup. AR 96028013 will track the necessary revisions to FSAR Figure 6.3-6 and Section 6.3.2.2.3.

CONCLUSION:

NU has concluded that DR-MP3-0266 identifies a condition previously discovered by NU which requires correction.

Printed 3/24/96 2:19.44 PM Page 2 of 3

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Northe:st Utilities ICAVP DR No. DR-MP3 4266 Millstone Unit 3 Discrepancy Report This item is considered previously discovered as ACR M3 0499 was raised on 8/1/96 to clarify and define the basis for RWST level at which the RHR pumps shuts off. Part of the corrective action for this ACR is to re-evaluate calculation US(B)-

295. Revision 6 of the calculation, dated 10/14/97. resulted in a new value for RWST lower bound level for ECCS pump operation, due to chan9es in various input parameters, including pump flow values. The calculation is currently in the process of revision as a result of Desi9n Change Request (DCR) 97106.

This DCR will change RWST/QSS level setpoints and revise the  ;

FSAR to include the new values.

Design change modification DCR M3-97106 installation and testing is scheduled to be completed prior to Startup. AR 96028013 will track the itecessary revisions to FSAR Figure 6.3-6 and Section 6.3.2.2.3.

Previously identifled by Nur (S) Yes O No Non Diecrepent ConditionrO Yes (SJ No ResolutionPending?O voa (3) No Resoiuison vareceived70 vee 's) No Review initietor: Wokelend, J. F.

VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anend K Dete: 3/17/98 sL Comments: Sargent & Lundy concurs that NU identified this issue on 8-1-96 in ACR M3-96-0499. The corrective action plan, AR 96028013-03, directly addresses the issue raised in DR-MP3-0266. The ICAVP review of modification M3-97106 and US(B)-295, Rev. 7 i concluded that this issue has been corrected.

Printed 3/24/98 2:19 46 PM Pt3a 3 of 3

1 NortheOst Utilities ICAVP DR No. DR-MP3-4268 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Deegn Diecipline: Structural Design Discrepency Type: Calculation O Yee systemfProcess: N/A g

NRC Significence level: NA Date faxed to NU:

Date Published: 10/18/97 Discrepency: Pipe Support Design Criteria Discrepancy

Description:

Technical Procedure no. EMTP 9.13-0,Rev.0,Section 7.1.6 states " Supports that utilize multiple welded attachments shall include in their analyses consideration that the load may not be I distributed evenly. This may be done by considering that the entire load is taken by each attachment.. ."

Calculations for pipe supports with two welded attachments which were reviewed, consider either 50%-50% or 60%-40% load distribution among the two attachments. The calculations do not provide the references or document the justifications for this load distribution.

Review Velid invalid Needed Date initietor: Kleic, N O O O 1o<2/97 VT Leed: Nort, Anthony A B O O So'3/S7 VT Mgr: schopfer, Don K B D 0 o/13'87 1RC Chmn: Singh, Anand K G O O o/13/S7 Deie:

INVAllO:

Date: 3/j7/98 RESOLUTION NU has wncluded that DR-MP3-0268 does not represent a discrepant condition. The percentage of load sharing is discretionary and requires the engineering judgment of the analyst, the independent reviewer and approver of the calculation. Generally a 50/50 load sharing is appropriate for ,

fully welded anchors with comparable stiffness. A 60/40 load I sharing is considered appropriate for parallel snubbers or struts l attached to structures with comparable stiffness. A 100/0 load  !

sharing is considered appropriate when gaps are present such as two opposing trunnions captured by box frames where one trunnion could be fully loaded prior to the opposing trunnion closing it's gap. Significance level criteria does not apply as this is not a discrepant condition.

Previously identified by NUF U Yes @ No Non Diecrepent Condition?@ Yee O No ResolutionPending7O vee @ No Reeosution unr.coev.d70 vee @ No Review in4tietor: Kleic, N VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K lRC Chmn: Singh, Anand K Date: 3/16/98 {

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Printed 3/24/98 2:20:12 PM Page 1 of 2  ;

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ICAVP DR No. DR-MP3-0268 N:rthert Utilities Millstone Unit 3 Discrepancy Report I

PrWed 3/2498 2:20:16 PM Page 2 of 2

ICAVP DR No. DR-MP3-0273 i

Northeast Utilitie0 Ministone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p Discipline:I a c Design g y ,,

D6ecrepancy Type: Calculebon System /Proceae: SWP gg NRC Significence level: 4 Date faxed to NU:

Date Published: 10/18/97 Discrepancy: Calculation SP-3SWP-27 is not in compliance with Reg. Guide 1.105 requirements.

DescripHon: Calculation SP-3SWP-27, Rev. O in its present form does not comply with the requirements of Reg. Guide 1.105. The calculation, dated 5-11-84, does state in a note that NUSCo is developing radiation level setpoints. However,there is no evidence that this calculation was prepared.

A setpoint calculation in accordance with Reg. Guide 1.105 is required based on the following:

1-A review of the PMMS database; Technical Requirement Manual- Clarification, section 3TRM-3.3.3.9; , titled Radioactive Liquid Effluent Monitoring Instrumentation'; and Technical Specification section 3.3.3.9, titled 'Radiactive Liquid Effluent Monitoring Instrumentation'; indicates these instruments are Tech. Spec. related.

2-Millstone Design Basis Response to Reg. Guide 1.97, Rev. 2; i FSAR table 7.5-1, titled ' Safety Related Display instrumentation l (PMS); and document DBD-BOP-001, titled ' Service Water System'; indicate these Instruments are Reg. Guide 1.97 related.

A review of applicable corrective action database for Millstone 3 has not identified any pending change notice items that will l incorporate calculation revision to SP-3SWP-27.

Review Velid invalid Needed Date initiator: Hindle, R. 8 O O 5or2/97 VT Lead: Nwl, Arthony A B O O ior2/97 10'13'S7 VT Mgr: Schopfw, Don K G O O O O o'1 *S7 IRc Chmn: Singh, Anand K O Date:

INVALID:

Date: 3/17/98 RESOLUTION Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0273, does not represent a discrepant condition.

Calculation SP-3SWP-27, Rev 0 provided radiation setpoints for use during startup testing to provide the vendor with initial values to program into the Radiation Monitoring System EPROMs.

While it is still an active calculation in the MP3 calculation database, and was valid for initial plant testing, it is not the basis Printed 3r24/98 2:20 40 PM Page 1 of 3

Northe:st Utilities ICAVP DR Nr. DR-MP3 0273 Millstone Unit 3 Discrepancy Report for the present radiation monitor setpoints.

The present MP3 radiation monitor setpoints were established and are controlled via the Millstone Radiation Monitoring Manual (RMM) as noted in Specification SP-ST-EE-329

  • Standard Specification For: Use and Control of Master setpoint index". l The basis for both the Alert and Alarm setpoints of l 3SWP*RE60A&B are contained within the RMM. These setpoints are then implemented through specific l&C calibration /

surveillance procedures 3490B12 and 3408A09-1. These instruments are identified in the Reg Guide 1.97 program as C2 variables. The instruments provide alert and alarm functions in monitoring effluent discharges but do not provide any automatic actions for mitigation of releases. As such, their setpoints are chosen to accomplish these monitoring functions and the addition of a detailed uncertainty analysis beyond the basis l provided within the Radiation Monitoring Manual is unnecessary.

Instruments 3SWP*RE60A&B are not part of Technical Requirements Manual 3TRM-3.3.3.9 or the Millstone Unit 3 Technical Specifications 3.3.3.9 table 3.3.-12. j l

The calculation SP-3SWP-27 discrepancy was discovered during i l

the 10CFR50.54(f) calculation verification process. A Calculation Change Notice (CCN) package was initiated to issue revision 1 that has VOIDED the calculation.

CR M3-97-2238 identified the issue with calculations and setpoint controlin the RMM. The approved Corrective Action Plan (CAP) is to develop and obtain approval of a new procedure for Radiological set point control. The activity is being tracked by the NU Action item Tracking and Trending System (AITTS) as A/R 97000404-04.

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-MP3-0273, does not represent a discrepant condition.

Calculation SP-3SWP-27, Rev 0 provided 3SWP*RE60A&B radiation setpoints for use during original startup testing. The calculation SP-3SWP 27 discrepancy was discovered during the 10CFR50.54(f) calculation verification process. A CCN was initiated to void this calculation during the 10CFR50.54(f) calculation verification process. Today the Radiation Monitoring Manual in conjunction with the applicable l&C calibration and surveillance procedures 3490812 and 3408A09-1 provide the setpoints for these radiation monitors. The channels 3SWP*RE60A&B are not Tech Spec related.

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

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l Northeast Utilities ICAVP DR N2. DR-MP3 0273 I

Millstone Unit 3 Discrepancy Report r,--,--.,-, .- 4 Resolution Pending?O vos @ No Resoiutionunresoeved?O vee <!)No Review initiator: Hindia, R.

VT Leed: Nerl, Anthony A VT Mor: schopfw, Don K NtC Chmn: Singh, Anand K Date: 3/17/93 sL comrnente: NU has generated CR-97-2238, dated 9-8-97 to void calculation SP 3SWP-27. Since this is past the wave 1 discovery date, the discepancy identified is considered to be a valid discrepancy.

Per NU disposition setpoints for the 3SWP*RlYBOA and B radiation monitors will be controlled by Radiation Monitoring )

Manual. A copy of the pages from this manual was supplied with I the NU response to this DR. We have reviewed the methodology in this manual .

Based on this review, the approach to determining the monitor setpoint is conservative and adequate. The level of the discovery is reduced to level 4, since this an administrative issue.

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ICAVP DR N3. DR MP3-0341 Northe:st Utilities Millstone Unit 3 Discrepancy Report Review Group: Sretem DR RESOLUTION ACCEPTED Review Element: S stem Dee&On Diecipline: ft octurel Design O Ya D6ecrepency Type: ( 44culat6an gg

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systemnaceos: WA NRC SigntAconce level: 4 Date faxed to NU:

Date Publ6ehed: 1/17/96 D6ecrepancy: Reference Calculation # 12179-NP(B)-174-ZC & 12179-NP(B)-

174 XC Discrepancy

Description:

Calculation Nos.12179-NP(B)-174 XC & 12179-NP(B)-174-ZC are referenced in the pipe support calculations listed below for qualification of the pipe straps. These calculations are voided (Referenco NU Response I.D. No. M3-IRF-00174 ( ltem NO.15 & 17 )). Therefore, pipe strap qualification cannot be verified. The associated pipe support calculations include:

1, NP(F)-ZO19R-019-H007, Rev.5

2. NP(F)-ZO19R 717-H003, Rev.5 3, NP(F)-ZO19R-018-H001, Rev.5
4. NP(F) ZO19R-786-H001, Rev.1
5. NP(F)-ZO19R-015-H003, Rev.8 Review Valid inval6d Needed Date initiator: Patel, A. O O O 12/23/97 VT Lead: Nort, Anthony A O O O 2/23/97 O 1ri2/96 VT Mgr: Schopfw, Don K O O NtC Chmn: Singh, Anand K O O O 5'13'S8 Det.:

INVALID:

Date: 3/23/98  !

RESOLUTION: NU has concluded that Discrepancy Report, DR-0341, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B18901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability concems and meets ,

the Unit 3 deferral criteria. CR M3-98-0967 has been written to i develop and track resolution of this item per RP-4.

Previously identined by NU7 O Yes (#) No Non Discrepent Condition?O Yes Tel No Resolution Pending?O Yes M No ResolutionUnresolved?O Yes

  • No Review Acceptable Not Acceptable Needed Date VT Leed: Nort, Anthony A VT Mor: Schopfer, Don K Ntc Chmn: Singh, Anand K O O Date: 3/23/98 SL Comments: Deferralis acceptable since strap allowables are provided in Calculation No. NP(F)-398-ZC , Rev.0 which has superceded Calculation No. NP(B)-174 ZC.

9 ??^d m_aasviewaf strap.altamahlae Mg Onte datlan Na_

Printed 3/2496 2:23 37 PM Page 1 of 2

1 ICAVP DR NS. DR-MP3-0341 Northeast Utilities Millstone Unit 3 Discrepancy Report NP(F) 398-ZC, we have concluded that althou9h the pipe support calculations reference a voided document, the straps are adequate based on the comparison of the applied loads to the available capacities provided in Calculation No. NP(F).398-ZC.

Therefore, the capacity of straps is not an issue.

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1 Northe:st Utilities ICAVP DR No. DR-MP3-0453 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p

Discipline: Mehanical Dwign Discrepancy Type: Calculeuon Om SystemProcess: Oss gg NRC Significance level: 4 Date faxed to NU:

Date Published: 12m97 Discrepancy. Calculation SP 3QSS-4

Description:

Calculation SP 3QSS-4, Rev. O concludes that the minimum QSS flow setpoint should be 3850 gpm per pump. The purpose of the minimum flow alarm is to alert operators responding to a postulated accident of the failure of QSS to provide containment spray. The low flow alarm is actuated if OSS flow is less than 3850 gpm 10 seconds after receipt of the CDA signal, or 15 seconds if there is a loss of offsite power concurrent with a CDA.

There are two discrepancies in the SP-3QSS-4 deterrrination of the low QSS flow setpoint:

1

1. The 3850 gpm value for the setpoint is based solely on an undocumented engineering Judgment.
2. During a design basis accident, the opening time of QSS spray isolation valves SQSS*MOV34A/B would limit flow to less than 3850 gpm during the first 15 seconds of an event and a low flow alarm would be generated even if the QSS system were fully operationalin accordance with its design basis (see evaluation below).

Logic Diagram LSK-27-12A, Rev.13 shows that that Flow Transmitters 3QSS-FT32A and B will produce a low flow alarm 10 seconds after receipt of a CDA signal, (which is delayed an additional 5 seconds after EDG start in the event of a LOP /LOCA)if flow from one of the QSS pumps is less than the 3850 gpm setpoint.

Fill time calculation US(B)-225, Rev. 6 indicates that there is a 5-second delay for sta, ting the QSS pump on the EDG load sequencer during a LOP /LOCA. According to US(B)-225, the QSS pumps will reach full speed in 1 sec (when powered from the DGs during a LOP /LOCA) and will fill the piping downstream of 3QSS*MOV34A/B in no more than 50.2 sec for one pump operation and no less than 25.3 sec for two pump operation.

Logic Diagram LSK-27-12B, Rev.13 shows that MOV34A opens on receipt of a CDA signal and its start is not delayed by the EDG load sequencer, so it will begin opening as soon as the EDG connects to the 1E bus. MPR Report 1824, Part 7, Rev. O states that the nominal opening time of butterfly valve MOV34A/B is 30 seconds. NM-027-ALL, Rev. 2 states that the surveillance limit for MOV34A/B time to open is 40 seconds.

Thus the worst case for the low QSS pump flow alarm is a LOCA without a LOP,10% degraded OSS pumps, and an MOV34A/B p g it:10 Open Of 40 0000~!0. In !N 00000d0, the MO'! w"g!b 5

Northerst Utilities ICAVP DR N3. DR MP3-0453 Millstone Unit 3 Discrepancy Report be 1/4 open when the annunciator time delay permits a low flow alarm signal to be generated. US(B)-225 states that the flow from one degraded QSS pump with the MOV34 valve wide open is 5580 gpm. MPR Repurt 1824, Part 7 uses this as the basis for the conclusion that at 1/4 open (22.5 degrees) the QSS pump flow would be approximately 2525 gpm.

Thus, after a postulated accident which automatically starts the QSS pumps, a QSS low flow alarm would be received by control room operators, even if the QSS pumps are functioning in accordance with their design basis. The time delay as well as the {

low flow alarm setpoint need to be re-evaluated to deterime how they can be !mproved to support operator response to a postulated accident.

Review Valid invalid Needed Date initiator: Wakeland J. F. O O O si/22/97 VT Lead: Neri, Anthony A y Q O 11/22/97 VT Mgr: Schopfer, Don K O O O $2it/97 1 1RC Chmn: Singh, Anand K O O O 2ra/97 Date:

INVALID:

Date: 3/14/98 RESOLUTION DISPOSITION:

NU has concluded that Discrepancy Report, M3-DRT-0453, has identified a condition not previously discovered by NU which requires correction. NU has determined that the QSS Low Flow Alarm setpoint and time delay issues identified in this DR will be re-evaluated to determine the correct settings required to support the QSS System Operation.

DR-MP3-0453 and the initial CR No. M3-98-075 investigation indicated that Calculation SP-3QSS-4, Rev. O, "3QSS-FS32A/B, 3QSS*P3A/B Discharge Low Flow Alarm," did not identify the engineering basis (Justification for selected value of design flow) for the Quench spray flow low alarm setpoint of 3850 GPM.

However, further review has determined the basis for the flow setpoint included in calculation SP-3QSS-4 is included in Reference 1 of the calculation (" System Description Number 3309, Quench Spray System," Appendix A-4-1, Quench Spray Pumps, SQSS*P3A/B design flow (quals 4000 gpm and minimum flow equals 1500 gpm). The selected setpoint at that time (4/23/84) represents a conservative engineering judgment (150 gpm < design flow) for supporting a non-safety related operator annunciation function. This is the typical level of engineering documentation provided at that time. In addition, Calculation SP-3QSS-4 states that the 10 second time delay prevents the alarm from actuating when the pump is stopped, and for the first 10 seconds while the pump is coming up to speed, it does not account for the EDG load sequencing time during a LOP /LOCA or QSS spray header isolation valve (30SS*MOV34A/B) opening time. It should be noted that the Printed 3/24/96 2:24:18 PM Page 2 of 5 J

Northecst Utilities ICAVP DR No. DR-MP3-0453 Millstone unit 3 Discrepancy Report QSS system does not incorporate a min-flow line, thus flow is not established until the QSS spray header isolation valves begin to stroke open.

Calculation US(B)-225, Rev. 6, CCN-1,

  • Quench Spray Header Fill Time," (max. fill time assuming one degraded pump operation) concluded that at time equal to 11.1 seconds the corresponding pump isolation valve 3QSS*MOV34A/B will be at 25 degrees open with QSS flow at approximately 3350 GPM.

Thus, the Low Flow alarm will be activated since the 10 second time delay will have expired. This may initially lead the operators to question the operability of QSS flow.

A review of the QSS Low Flow Alarm Setpoint Licensing / Design Basis and Operational Impact has determined the following:

1.) Licensing / Design Basis: The MP3 FSAR does not address in detail the QSS Low Flow Alarm Setpoint or delay time, but only indicates that Low Flow annunciation is provided.

2) OperationalImpact: Per Alarm Response Procedure OP3353.MB2A, Rev.1, chg. 3, following the activation of the

" QUENCH SPRAY FLOW LO" Annunciator Alarm (window 4-5) on a CDA signal, operators are required to verify total flow rate on both QSS trains greater than 4,000 GPM and to verify valves in the QSS flow path are positioned properiy. The Low Flow setpoint does not initiate any automatic actions. Flow can quickly be verified using F1-32A/B on MB2. The annunciator may provide a premature annunciation of OSS Flow Low condition, however, once flow is established above the alarm setpoint, the annunciator alarm can be cleared by the operators.

CR No. M3-98-0757 was initiated to investigate the QSS Low Flow Annunciator Alarm setpoint discrepancies. AR No.

98003082 will track the corrective action associated with the evaluating and revising the QSS Low Flow Alarm Setpoint and time delay. This DR does not impact any startup issues because the flow alarm function does not affect system operability or functionality of any safety related components.

NU believes the Significance Level for this DR should be I downgraded to Level 4 because the Quench Spray System is capeble of providing a flow equal-to-or greater than the Licenting/ Design Basis flow assumed in the containment accidert analysis per" Design Bases Summary For The Quench Spray System," 3DBS-NSS-002, Rev. O, whenever the system is activated and the provided low flow annunciation is not a safety-  ;

related or risk-significant function. Additionally, adequate '

instrumentation is provided to determine QSS flow during normal or emergency operations. The implementation of any corrective action associated with this DR and CR M3-98-0757 is considered a post startup issue because the flow alarm function is not required for any accident analysis function and the operators have multiple indications of QSS alignment and flowrates.

Reference attached: CR No. M3-98-0757.

Printed 3/2498 2:24:20PM Page 3 of 5

l ICAVP DR No. DR-MP3-0453 Northe:st Utilitie]

Millstone Unit 3 Discrepancy Report CONCLUSION:

NU has concluded that Discrepancy Report, M3-DRT-0453, has identified a condition not previously discovered by NU which requires correction. NU has determined that the QSS Low Flow alarm setpoint and time delay issues identified in this DR will be re-evaluated to determine the correct settings required to' support the QSS System Operation.

CR No. M3-98-0757 was initiated to investigate the QSS Low Flow Annunciator Alarm setpoint discrepancies. AR No.

98003082 will track the corrective action associated with l evaluating and revising the QSS Low Flow Alarm Setpoints and l time delay. This DR does not impact any startup issues because the flow alarm function does not affect system operability or functionality of any safety related components. j i

NU believes the Significance Level for this DR should be j downgraded to Level 4. The Quench Spray System satisfies its Licensing and Design Bases Criteria per 3DBS-NSS-002, Rev. O, Section 8.2, " Design Bases Summary For The Quench Spray System," providing a flow equal-to-or greater than the flow assumed in the containment accident analysis whenever the system is activated. The low flow annunciation addressed is not a safety-related or risk-significant function. Additionally, adequate instrumentation is provided to determine QSS flow during normal or emergency operations. The implementation of any corrective action associated with this DR and CR M3 l 0757 is considered a post startup issue because the flow alarm function is not required for any accident analysis function and the operators have multiple indications of QSS alignment and flowrates.

Previously klontined by NU7 O Yes (#) No Non Discrepent condition?O Yes (#) No Resolution Pending?O Y @ No R iution unre.oiv.d?O Yes @ No Review initiator: Wakeland, J. F.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date: 3/14/98 sL Comments: SarDent & Lundy concurs that the NRC Significance Level of DR-MP3-0453 should be changed from Level 3 to Level 4 and that corrective actions for this issue may be deferred until after Unit 3 restart. Alarm Response Procedure OP3353.MB2A directs operators to veryify QSS pump flow using FI-32A/B on MB2.

Therefore operators will not use the spunious low QSS flow alarm to take inappropriate actions during an off-normal event.

Operators have multiple safety-related indications for QSS alignment and flowrates which are adequate to support their response to a postulated accident.

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ICAVP DR No. DR-MP3-0463 Northert Utilities Millstone unit 3 Discrepancy Report SarDent & Lundy concurs with the corrective action plan of CR M3-98-0757 for resolving DR-MP3-0453. NU's response in M3-lRF-01168 indicates that the planned evaluation of SP-3QSS-4 might require a modification.

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ICAVP DR No. DR-MP34464 Northecst Utilitie0 Millstone Unit 3 Discrepancy Report 1 Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design g Discipline: Mechanical Design Discrepancy Type: Cm Om

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

Date Published: 12/8/97 Discrepency: Calculation P(R)-1186

Description:

The purpose of Calculation P(R)-1186, Rev.1/CCN 2 is to determine the design pressures and temperatures for RSS piping.

Five discrepancies were identified in Calculation P(R)-1186:

1. The elevation of the RSS pump suction,-29'-8", is incorrectly used as the elevation of the RSS pump discharge, which is -23'-

3". This error adds 6' 5" of head (2.7 psi) to these pressures for all modes of operation. For the reasons identified in discrepancy 2, below, this error is not significant.

2. A nominal water density of 62.34 lbm/ft3 is used to compute system pressures, rather than the actual densities of 62.426 lbm/ft3 at 40F,60.07 lbm/ft3 at 201.5F. This results in errors of

+9.6 to -0.4 psi. When combined with the error in the RSS pump discharge elevation (identified in discrepancy 1, above) the total error is from +2 to +11 psi. It is the engineering judgment of the reviewer that overestimating operating pressure by 12 psi is conservative and results in negligible errors in computing stresses in standard wall piping. Therefore the errors in density and pump discharge elevation identified in discrepancies 1 and 2 do not affect the affect the validity of the piping stress data package.

3. CCN 2 to P(R)-1186 acknowledges that the RSS pump at shutoff is capable of producing 300 psig pressures in RSS process piping between the pumps and the spectacle flanges (3-RSS-010-3,5,8,9,10,11,13,14,15,18,19 & 20, 3-RSS-008-54 & 55, and 3-RSS-004-122 & 124). It then states that the design pressure is 275 psig from the pumps to the containment isolation valves and 225 psig from the isolation valves to the spectacle flanges, and it states that these design pressures are acceptable according to an evaluation in E&DCRs T-P-07894 and 07939. The evaluations in E&DCRs T-P-07894 and 07939 address component design pressures and piping minimum wall, but do not address the validity of the piping design pressures for the system line list. The design pressures for RSS piping from the pumps to the spectacie flanges in P(R)-1186 and in the line list are inconsistent with statements in P(R)-1186 that these lines are subject to pump shutoff head (See voided DR-MP3-0501).
4. Valves RSS MOV'8837A&B and 8838A&B, which connect the RSS supply to the HHSI pump suction (via the RHS system),

are closed during ECCS Injection Mode. In this mode, according to P(R)-1192, Rev. O the RHS pump can operate at its shutoff head and pressurize Lines 3RSS-008-040,041,047 and 053 to Printed 3/24/98 2:25:19 PM 'I 1 of 4

ICAVP DR No. DR-MP3-0454 Northent Utilities Millstone unit 3 Discrepancy Report pressure for these lines as 600 psig. Calculation P(R)-1186 states that the design pressure of all RSS lines downstream of the RSS HX and upstream of MOVs 20A, B, C, and D is only 275 psig. P(R)-1186 should be changed to include the determination of the 600 psig design pressure in Lines 3RSS-008-040,041, 047 and 053, or to reference an RHS system calculation which does this (See voided DR-MP3-0501).

5. During shutdown cooling mode operation of RHS, according to P(R)-1192, Lines 3RSS-008-040,041,047 and 053 may reach temperatures of 350F. Rev.1 of Calculation P(R)-1186 states that the design temperature for all RSS lines downstream of the RSS HX is 260F. P(R)-1186 should be changed to include the determination of the 350F design temperature in Lines 3RSS-006-040,041,047 and 053, or to reference an RHS system calculation which does this.

Review Valid invalid Needed Date initiator: Wakelend, J. F. B 0 0 51r2trs7 VT Leed: Neri, Anthony A B O O i r22/97 VT Mgr: schopfer, Don K B O O $2/t/97 IRC Chmn: singh, Anand K B O O 2/4/97 Date:

INVALID:

Date: 3/23/98 RESOLUTION: DISPOSITION:

NU has concluded that DR-MP3-0454 has identified conditions not Aviously discovered by NU which required correction. DR-MP3-0454 raises 5 issues,4 of which are discrepant (issues 1,3, 4, & 5), Condition Report (CR) M3-98-0588 was written to provide the necessary corrective action to resolve these issues.

The corrective action requires that the errors identified in calculation P(R) 1186 be corrected. As none of the identified discrepancies alter the conclusion of the calculation, action will be performed Post M3 Startup.

NU has concluded that Discrepancy Report DR-MP3-0454 has identified an issue that does not respresent a discrepant condition. Issue 2 identified by DR-MP3-0454 results in increased conservatism in the calculation and is acceptable in present form. Significance level criteria does not apply as issue 2 is not a discrepant condition.

CONCLUSIONS:

NU has concluded that Discrepancy Report DR-MP3-0454 has identified conditions not previously discovered by NU which required correction. DR MP3-0454 raises 5 issues,4 of which are discrepant (issues 1,3,4, & 5), Condition Report (CR) M3 0588 was written to provide the necessary corrective action to resolve these issues. The corrective action requires that the errors identified in calculation P(R)-1186 be corrected. As none Printed 3'24/9e 2:25:22 PM Page 2 of 4

l ICAVP DR No. DR-MP3-0464 Northecst Utilities Millstone Unit 3 Discrepancy Report of the identified discrepancies alter the conclusion of the calculation, the MP3 LB / DB is not affected, therefore NU considers this issue to be a significance level 4 discrepancy.

This corrective action will be performed Post M3 Startup.

NU has concluded that Discrepancy Report DR-MP3-0454 has identified an issue that does not respresent a discrepant condition. Issue 2 identified by DR-MP3-0454 results in increased conservatism in the calculation and is acceptable in present form. Significance level criteria does not apply as issue 2 is not a discrepant condition.

Previously klenoned try NU7 (,) Yes r#) No Non Discrepent Condition?(.) Yes (S) No~

ResolutionPending7O Yes @ No Resolution Unresolved 7O Yes @ No Review initiator: Wakeland. J. F.

VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K F4C Chmn: singh, Anand K O O O Date: 3/23/98 SL Comments: Item 1, the error in pump discharge nozzle evelation, introduces a conservative error in design pressure of 2.7 psi. Therefore Sargent & Lundy concludes that it is a Level 4 discrepancy.

Sargent & Lundy agrees that the corrective action plan of CR 98-0588 (AR 98002724-02) will resolve DR-MP3-0454, items 1 (DR-MP3-0454 item 1 is the same as DR-MP3-0988 item 1). Sargent

& Lundy also agrees that item 1 may be deferred until after Unit 3 restart.

Item 2, the use of incorrect water density introduces a +9.6 to -0.4 psi error in the design pressure. An error of-0.4 psl is an insiginficant non-conservative error, therefore Sargent & Lundy concludes that it is a Level 4 discrepancy. Sargent & Lundy's ICAVP review of P(R)-1186, Rev. 2 concluded that items 2 is incorporated into the design pressure calculation. In the ICAVP review of SDP-RSS-01361M3, Rev. 5, Sargent & Lundy determined that DR-MP3-0454, item 2 was not incorporated into the new stress data package or the piping stress analysis.

Because it is an insignificant Level 4 error, correction of the design input to the piping stress analysis may be deferred until after Unit 3 restart.

Item 3, the change in design pressure to account for the possibilty of RSS pump shutoff head, introduces a non-conservative error of 25 psi. Sargent & Lundy's ICAVP review concluded that this error has been corrected in P(R)-1186, Rev. 2, the RSS system design pressure calculation. Therefore Sargent & Lundy concludes that corrective action for item 3 is complete. (see item 1 of DR-MP3-0999, written because Rev. 2 to P(R)-1186 was not used to provide the corrected input to the stress data package, SDP-RSS-01361M3, Rev. 5.)

Item 4, failure of P(R)-1186 to address the design pressure for lines 3RSS-008-040,041,047 and 053, affects piping stress Printed 3/24/96 2:25:24 PM Page 3 of 4 l

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ICAVP DR No. DR-MP3 4454 Northeast Utilities Millstone Unit 3 Discrepancy Report analysis and MOV design conditions. The piping line list indicates that these RSS/HHSI crosstie lines have a design pressure of 600 ,

psig. Thus the piping was designed for the 583 psig pressure ]

which could be generated by the RHR pumps at their shutoff head. The only design issue connected with this 600 psig design pressure which may be a problem is the maximum differential pressure during the opening and closing of valves MOV*8837A&B l I

and MOV*8838A&B. This is a Level 3 issue. The issue is addressed by DR-MP3-0781 (NU has leitiated CR-98-0439 in response to DR-MP3-0781). Therefore, item 4 of DR-MP3-0454 is considered to be closed to DR-MP3-0781.

Item 5. failure of P(R)-1186 to address the design temperature for lines 3RSS-008-040,041,047 and 053, affects piping stress analysis. Sargent & Lundy's ICAVP review of SDP-RSS-01361M3, Rev. 5 did not identify any problems with the operating temperatures for the ECCS injection mode and recirculation mode. The only high temperature conditions that exist are for RHR shutdown cooling mode. Temperature stresses are not a major issue for the RSS/HHSI crossover lines. This issue does not raise concems of excessive piping stress levels and should be considered to be a Level 4 issue. Sargent & Lundy agrees that the corrective action plan of CR 98-0588 (AR 98002724-02) will resolve DR-MP3-0454 item 5 and that resolution may be deferred until after Unit 3 restart.

Each of the 5 items of DR-MP3-0454 is either a Level 4 l discrepancy, which may be resolved after Unit 3 restart, or is covered by Discrepancy Reports DR-MP3-0999 and MP3-DR-0781. Therefore Sargent & Lundy is downgrading the NRC ,

Significance Level of this DR to Level 4 and accepting NU's disposition.

1 Printed 374/98 2:25 26 PM page 4 or 4

ICAVP DR No. DR-MP3-0467 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Peterstial Operatety lasue Discipline: Mechanical Design Discrepancy Type: Calculation Om 1 fe) No SysterrvProcess: SWP NRC Significance level: NA Date faxed to NU:

Date Published: 10/23/97 D6 crepency: Calculation W3-517 366-RE, Rev 0 has a conflict of status.

Descript6on: Calculation W3-5171105-RE, Rev 1, CCN#1 states that it supersedes calculation W3-517-366-RE, Rev 0. However, calculation W3-517 366-RE, Rev 0 is not stamped

" SUPERSEDED" and is still shown as active in the Millstone Document Database.

Review Valid invand Needed Date init6ator: Deonne. B. J. O O O 'oo/S7 VT Lead: Nort, Anthony A g O O 10/11/97 VT Mgr: Schopfer, Don K O O O 'o/15'87 1RC Chmn: Singh. Anand K O O O 10/iarD7 Date:

WVALID:

Date: 3/23/98 RESOLUTION Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0457, does not represent a discrepant condition.

Calculation W3-5171105-RE, Rev 1, CCN#1 was received by Nuclear Document Control (NDC) to be processed on 4/21/97.

Calculations are reviewed by NDC personnel per the requirements of Nuclear Document Services Work Practice NDSWP 3.15Q. Section 6.3.2 of 3.150 requires that both superseding and superseded calculations be provided to NDC at the same time. It further requires that NDC personnel retum calculations to the preparer when all related superseding / superseded calculations are not provided together for processing. Calculation W3-5171105-RE, Rev 1, CCN#1 was retumed as required to it's owner for correction. Calculation W3-517-366-RE was then revised to delineate that it has been superseded by W3-517-1105-RE, Rev 1 and both calculations were re-submitted to NDC for processing on 6/5/97.

A review of the Millstone calculation tracking database shows the status of calculation W3-517-366-RE as superseded on 6/14/97. j Significance Level criteria do not apply here as this is not a discrepant condition.

Conc lusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0457, does not represent a discrepant condition.

Printed 3/24/96 2.26.06 PM Page 1 of 2

ICAVP DR No. DR-MP3-0467 Northeast Utilities Millstone unit 3 Discrepancy Report Calculation W3-5171105-RE, Rev 1, CCN#1 was rejected by NDC and retumed to the owner to be corrected per the requirements of section 6.3.2 of Nuclear Document Services Work Practice NDSWP 3.15Q. The owner then revised calculation W3-517-366-RE to depict that it has been superseded by W3-5171105-RE, Rev 1 and both calculations were re-submitted to NDC for processing on 6/5/97, A review of the Millstone calculation tracking database shows the status of calculation W3-517-366-RE as superseded on 6/14/97.

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

Prev 6ously identified by NU? O Yes (S) No Non Diecrepent Condition?it) Yes Q No RuoM6onPendng?O Ya @ No Raakaan unr.oiv.d?O Ya @ No Review initiator: Denne, B. J.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Dete: 3/23/98 SL Comments: We do agree that this calculation has since been superseded and that the process is in place to handle superseding / superseded documents.

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Northeast Utilities ICAVP DR No. DR-MP3-0493 j Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operstdisty locue Discipione: Mecherscal Doo6g" Discrepancy Type: Calculation Om (5) No System / Process: Rss

NRC Significence level: 4 Date faxed to NU:

Date Published: 11/13/97 D6ecrepency: Calculation SDP-RSS-01361M3 Descript6on: The purpose of SDP-RSS-01361M3, Rev. 4 is to provide a line-by-line listing of RSS operating pressures and temperatures for each mode of system operation in a format which can be used as input to the piping stress analysis. The operating pressures and temperatures are determined in Calculation US(B)-1187, Rev.1/CCN 1.

Two discrepancies were identified in Calculation SDP-RSS-01361M3:

1. Valves RSS MOV*8837A/B and 8838A/B, which connect the RSS supply to the HHSI pump suction (via the RHS system), are closed for Operating Condition 1, ECCS injection Mode. In this mode, according to P(R)-1192, Rev. O the RHS pump can operate at its shutoff head and pressurize Lines 3RSS-008-040, 041,047 and 053 to 583 psig. Stress Data Package SDP-RSS-01361M3 claims that the pressure in these lines for Operating Condition 1 is only 235 psig.
2. The following errors were made in transposing data from Calculation P(R)-1187 to Stress Data Package SDP-RSS-01361M3:

3RSS-012-003: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-012-008: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-012-013: Op Coled 4 press should be 37 psig, not 0 psig 3RSS-012-018: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-012-035: Op Cond 4 press should be 105 psig, not 37 psig 3RSS-010-038: Op Cond 3 temp should be 40F, not ambient 3RSS-008-041: Op Cond 3 press should be O psig, not 156 psig 3RSS-006-041: Op Cond 3 temp should be 40F, not ambient 3RSS-001-080: Op Cond 3 press should be 156 psig, not 0 psig 3RSS-150-087: Op Cond 3 press should be 56 psig, not 0 psig 3RSS-750-090: Op Cond 3 press should be 56 psig, not 0 psig 3RSS-750-095: Op Cond 2 press should be 210 psig, not 0 psig 3RSS 750-095: Op Cond 2 temp should be 116F, not ambient 3RSS-750-096: Op Cond 2 press should be 210 psig, not 0 psig 3RSS-750-096: Op Cond 2 temp should be 116F, not ambient 3RSS-750-102: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-750-102: Op Cond 4 temp should be 40F, not ambient 3RSS-001-103: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-001-103: Op Cond 4 temp should be 40F, not ambient 3RSS-750-106: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-750-106: Op Cond 4 temp should be 40F, not ambient 3RSS-001-107: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-001 107: Op Cond 4 temp should be 40F, not ambient 3RSS 750-110: Op Cond 4 press should be 37 psig, not 0 psig p pg 3RSS 750140-Opcend4 'Omp 20dd be 40F, not Omyeg , 3

ICAVP DR No. DR-MP3-0493 Northeost Utilities Millstone Unit 3 Discrepancy Report l 1

3RSS-001-111: Op Cond 4 press should be 37 psig, not 0 psig l 3RSS-001 111: Op Cond 4 temp should be 40F, not ambient 3RSS-001 119: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-001-119: Op Cond 4 temp should be 40F, not ambient 3RSS-001 120: Op Cond 4 press should be 37 psig, not 0 psig .

3RSS-001 120: Op Cond 4 temp should be 40F, not ambient  !

3RSS-004-122: Op Cond 3 press should be 156 psig, not 195 l psig 3RSS-004-122: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-004-123: Op Cond 3 press should be 156 psig, not 195 psig 3RSS-004-123: Op Cond 4 press should be 37 psig, not 0 psig 3RSS-004-124: Op Cond 3 press should be O psig, not 195 psig 3RSS-004-124: Op Cond 3 temp should be ambient, not 40F -

3RSS-004-125: Op Cond 3 press should be O psig, not 195 psig  !

3RSS-004-125: Op Cond 3 temp should be ambient, not 40F These transposition errors require further evaluation to determine how they affect piping stress calculations X-7919, X-7920, X-7923, X 7925, 688 XD,694 XD,695 XD,739 XD,900 XD, and 961 XD.

Review Val 6d invalid Needed Date l Initiator: Wakelend, J. F. '

O O O o/30'S7 VT Lead: Neri, Anthony A B O O io/3197 VT Mgr: schopfer, Don K O O O 15/SS7 11/7/97 IRC Chmn: Sin 0h, Anand K Q Q Q Date:

INVAUD:

Date: 3/17/98 RESOLUTION DISPOSITION:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0517 has identified a condition not previously discovered by NU which requires correction. The corrective action plan for CR M3-98-0504 will track the correction of the errors.

CR-M3-98-0504 (attached) was written to correct and track the deficiencies identified in this DR. Corrective actions will be to review and revise calculation SDP-RSS-01361M3 with the operating conditions as reported in calculations 12179 P(R)-1187 and 12179-P(R)-1192.

All reported inconsistencies have been reviewed against the piping stress calculations which are affected by changes in the stress data package,. The piping stress calculations define each operating condition conservatively. Thus, the inconsistencies do not affect RSS piping stress calculation results or RSS code compliance. All primary stress calculations use design pressure, which bounds all operating mode pressures for this system. The analyzed thermal cases bound the correct operating mode temperatures.

Printed 3/24/96 2:26.47 PM Pa0e 2 of 3

Northeast Utilities ICAVP DR No. DR-MP3-0493 Millstone Unit 3 Discrepancy Report This DR should be down graded to a significance level 4 since there is no impact on the licensing and design basis for the system.

CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0517 has identified a condition not previously discovered by NU which requires correction.

Since the inconsistencies identified in DR MP3-0493 do not affect the licensing or design basis of the RSS system or piping stress calculations associated with SDP-RSS-01381M3, this should be a significance level 4.

Previously identined by Nu? (,) vos (4) No Non Discrepent Condetion?O v.. (*) u.

Resolution Pend 6ng70 v (v)No R oivison unt oiv.d70 v (#)No Review Inittetor: Wakeland, J. F.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Dete: 3/17/98 st Comment.: Sargent & Lundy agrees with the corrective action plan of CR M3-98-0504 for resolving DR-MP3-0493. Sargent & Lundy agrees that the NRC Significance Level of DR-MP3-0493 should be changed from Level 3 to Level 4. Increases in line operating pressure do not affect calculated piping stress levels and the changes in line operating temperatures are within existing temperature ranges which have already been analyzed.

Printed Y24/96 2 26 40 PM Page 3 of 3

1 Northeast Utilitie3 ICAVP DR NA DR-MP3-0618 Millstone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED j Review Element: System Design p Discipline: Mechanical Design D6screpancy Type: Calculation g

System / Process: SWP NRC Significance level: 4 Date Faxed to NU:

Date Published: 1/25/98 Discrepancy: Calculations for Reactor Plant CCW Heat Exchanger contained various similar errors.

Descripuon: Calculation 94-ENG-1036-M3 rev. O through CCN 02 determines the Required SW Flow During a LOP Event with a 78'F SW Temperature. Calculation 91-BOP-783ES rev. 2 determines the Required SW Flow Rate to Support a 70.24 Mbtu/hr Safety Grade Cooldown Heat Duty. Calculation 91-BOP-789ES rev. 2 through CCN 02 determines the Required SW Flow During Safety injection. These calculations contain the following similar j errors:

Equations were not correctly transposed from the reference as follows: Equation 10 noted on page 15 should be noted from page 394 of reference A not page 417 with llD > 10 not 60, and equation 13 is from page 345 not page 356 of reference A. l l

Numerous minor mathematical errors were found throughout the I calculation. i.e. Page 20 - Tsl for train A and B should be )

121.4*F and 120.7'F respectively, based on values listed in calculation, instead of 121.5'F and 120.5'F. Page 24 - The values calculated for the prandtl number and film coefficient were not consistent with values calculated based on inputs noted in equations. The overall effect of these mathematical errors can not be determined since the incorrect values are used throughout this calculation.

Data was transposed incorrectly from inputs / equation to equation in various places throughout the calculation. i.e. The mass flow rate (Mt) is listed on page 21 in the results table as 2.34x10E6 (Ibm /hr) and is determined /used in equation on page 29 as 2.00x10E6 (Ibm /hr). Page 38 - Thi = 121.5 *F should be 120.5

'F for train B, per page 20. This also applies to Tsi. Page 39 -

The heat duty determined to be 43.5x10E6 on page 13, should have been used instead of 43.54x10E6. Then the heat duty is written and used as 43.64x10E6 on pages 40 and 41.

Several typographical error were noted. The nomenclature used for the tube radius (page 7) contains incorrect units. The units should be ft not ft'.

Errors specific to calculation 94-ENG-1036-M3 are as follows:

Table 2 notes Tso = 95.1*F where design input D states the outlet temperature is 95'F. This is above the maximum allowable value stated in the design input without justification.

CCN 02 removes the reference for 75'F which was incorrectly noted and insert 78'F but does not include a reference or inctifientinn inr auntnntinn thic hant ownhnnnar at 7A'F The

' ~ ~

Printed 3/2490 2:27;18 PM Page 1 of 2

l ICAVP DR N9. DR-MP3-0518 Northeast Utilities Millstone Unit 3 Discrepancy Report Tech. Spec. references an UHS temperature of 77'F but does not address 78'F as is used in this calculation.

Errors specific to calculation 91-BOP-783-ES are as follows:

Page 3 notes reference V as the stress calculation, however this reference is a flow balancing calculation, which is noted ,

consistent with the text of this calculation. j Review l Valid invalid Needed Date initiator: Dionne, B. J. 8 O O 1'15/S8 VT Lead: Neri, Anthony A B O O 1' S/S8 VT Mgr: schopfer, Don K G O O 1'1S/S8 O 1i21/98 1RC Chrm: Singh, Anand K O O Date:

INVALID:

Date: 3/20/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0518, has identified a condition not previously discovered by NU which ,

requires correction. This discrepancy meets the criteria specified {

in NRC letter 816901 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 M3-98-0809 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0518, 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 M3-98-0809 has been written to develop and track resolution of this item per RP-4.

Previously identifled by NU? O Yee @ No Non Discrepent Condition?O Yes (#) No ResolutionPending?O vee @ No Reeosuisonunresoeved?O vee @ No Review initiator: Dionne, B. J.

VT Lead: Neri Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date: 3/20/98 sL comments: Based on further review of the calculation, it is agreed that this discrepancy will not have an operability or reportability concems and can therefore be accepted for deferral.

Printed y24S6 2:27:21 PM Page 2 of 2

ICAVP DR N3. DR-MP3 0523 Northeast Utilities Millstone unit 3 Discrepancy Report .

Review aroup: system DR RESOLLmON ACCEPTED neview Element: system Design ,

Diecipane: Ia c De@n O vee Discrepency Type: Calcuishon

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

Date Published: 11/15/97 Discrepency: Instrument error value discrepancy for the empty (low-low-low) level setpoint Ducription? I&C calculation 3451801-1232, Rev 00, titled "RWST Level Interiock Channel Calibration" calculates instrument channel uncertainty and setpoints for low-low and empty level instrumentation. Switches 3QSS*LS56A/B/C/D are provided on the RWST tank to provide empty level signals. Upon detection of empty level signal QSS pumps are tripped and the condition is annunciated in the control room.

Per FSAR figure 6.3-5 these switchas have an associated instrument error of i 12 inches for the empty level setpoint of 40 inches. Calculation HYD-H39 Rev.1 titled " Design of Vortex supressor for QSS Tank QSS*TK1" determined the empty level process setpoint should be 28 inches.

Calculation 3451803-1232E3 is using 28 inches as nominal st *phet value. Per page 2 of this calculation the instrument suor - identified as total loop uncertainty (TLU) - is +12.7 inwc and -13.8 inwc. Please note that the calculation is done for seven decimal accuracy. The write-up here is using one decimal for convenience.

The error of -13.8 inwc does not agree with the FSAR figure 6.3-

5. Additionally,the setpoint calculated in 3451B03-1232E3 does not support the level requirements of calculation HYD-H39.

Review Valid inve ;d Needed Date initiator: Hindie, R. O O O S'S7 VT Lead: Neri, Anthony A g O O 11/8/97 O 15' o'S7 VT Mgr: schopfer, Don K G O BRC Chmn: singh, Anand K B C D '5'25/87 Date:

INVALlO:

Date: 3/23/98 RESOLUTION: NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0523, do not represent a discrepant condition.

NU is currently in the process of revising the RWST/QSS level setpoints to support new ECCS Runout Flows and instrument uncertainties through the implementation of Design Change Request (DCR) 97106. Applicable Calculations, FSAR and Procedures will be included to support this design change. The I

& C calculations and FSAR figure referenced in the DR are included within the scope of this design modification.

Printed 3/2498 2:27.50 PM Page 1 of 4

4 Northeast Utilities ICAVP DR No. DR-MP3 0523  ;

Millstone Unit 3 Discrepancy Report Calculations referenced in the DR (e.g. 3451B03-1232E3, HYD-

39) represents interim conditions during the development of DCR No. M3-97106, while the FSAR figure 6.3-6 referenced represents the existing RWST low-low-low (empty) level setpoint.

ACR No. M3-96-0499, Dated 8/6/96, identified that the basis criteria for the RHR Pump shut off for RWST Level was not clear. DCR No. M3-97106 was initiated as a result of ACR No.

M3-96-0499. The DCR will change RWST/QSS level setpoints, FSAR, Calculatinns and Procedures to support new ECCS Runout Flows and instrument uncertainties.

The ACR Corrective Action Plan includes preparing a change to j US(B)-295 "RWST Draw-Down Rates and Switch Over Levels" to re-evaluate the setpoints using the latest instrument setpoint tolerances and revising FSAR Figure 6.3-6 accordingly. The i calculations referenced in this DR do not represent the current 3OSS*LS56A/B/C/D RWST Level setpoint field condition.

l&C Calculation 3451801-1232, Rev. 00[ sic. 3451B03-01232 E3, Rev. 0] titled "RWST Level Interlock Channel Calibration" calculates instrument channel uncettainty and setpoints for low-low and empty level instrumentation. Switches 3QSS*LS56A/B/C/D are provided on the RWST tank to provide empty level signals. Upon detedion of empty level signal QSS pumps are tripped and the condition is annunciated in the control {

room. j 1

The process setpoint limit is specified as 28 inches above the tank bottom in calculation SP-3Q5S-9, Rev. 4, "3QSS*LS56A-D Refueling Water Storage Tank Empty Setpoint" which uses calculation 12179-HYD-H39, Rev.1 " Design of Vortex Suppressor for the QSS Tank QSS*TK1" as a design input.

The l&C channel calibration / scaling calculation 3451B03-01232 )

E3, Rev. O, then established an instrument trip setting including )

I totalloop uncertainty (TLU) on page 4 of Appendix A. This result is in agreement with the 28 inch process limit from the vortex calculation plus instrument uncertainty.

Additional input to the RWST level requirements is provided by calculation US(B)-295 "RWST Draw-Down Rates and Switch Over Levels". This calculation is being revised due to changes in the containment analysis and it will incorporate a change to the RWST empty level setpoint to accommodate the increased instrument uncertainty (+12.7 in.,-13.8 in.) provided by WCAP 14353, " Westinghouse Setpoint Methodology for Indication, Control and Protedion System for Millstone Nuclear Power Station -Unit 3,24 Month Fuel Cycle Evaluation".

Therefore, while setpoint changes with different uncertainties, are being issued to support DCR No. M3-97106 the FSAR figure is awaiting the US(B)-295 calculation revision which is the primary input to the FSAR figure 6.3-5 [ sic 6.3-6] discrepancy cited in the DR. The existing FSAR figure 6.3-6 shows an empty setpoint of 40 inches. The 40 inches includes the existino 28 in. i i

Printed 3f2#98 2.27:53 PM Page 2 of 4

R Northe:st Utilities ICAVP DR N2. DR-MP3-0623 Millstone Unit 3 Discrepancy Report empty process setpoint limit plus the current 12 in. instrument uncertainty. This setpoint value will be revised for clarity in the FSAR via the DCR. Superseded Calculation No. 3-ENG-111

" Calibration Data for Procedure SP 3451B03, RWST Level interlock Calibration" supports the existing FSAR figure 6.3-6 empty setpoint value.

DCR No M3-97106 is presently under development. AR No.

96028013-02 & 04 will track the RWST empty level setpoint re-evaluation and FSAR figure update. Design change modification DCR No. M3-97106 installation and testing is scheduled to be complete prior to Startup.

NU has recently updated the Design Control Manual, Rev. 6, procedure to add an " Installation Verified" box on new Calculation and CCN Title Pages. This box will eliminate confusion about if the results of a calculation has been implemented in the field. CR M3-97-3350, identified calculation control issues. AR 97024519 08 will provide corrective actions to identify calculations of record prior to DCM, Rev. 6. Also, AR 97024595 will involve implementing a calculation improvement plan to identify critical calculations and review requirements.

References attached: 1.) CR M3-96-0499 2.) D C R M3-97106, page 1 3.) 3-ENG-111 Rev.1 & 2 4.) C R M3-97-3350 Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0523, do not represent a discrepant condition.

NU is currently in the process of revising the RWST/QSS level setpoints, FSAR, Calculations and Procedures to support new' ECCS Runout Flows and instrument uncertainties through the imolementation of Design Change Request (DCR) 97106. The I

& C calculations sind FSAR figure referenced in the DR are l included within the scope of the design modification. I The FSAR figure referenced in the DR supports the RWST empty level setpoint existing condition while the calculatiens referenced in this DR represent interim revisions issued during I the developement of DCR No. M3-97106. j l

ACR No. M3-96-0499, Dated 8/6/96, identified that the basis i criteria for the RHR Pump shut off for RWST Level was not I clear. DCR No. M3-97106 was initiated as a result of ACR No. l M3-96-0499. The DCR changes RWST/QSS level setpoints, l FSAR, Ct.lculations and Procedures to support new ECCS Runout Flows.

The l & C Calculation referenced in this DR is being further revised to support DCR No. M3-97106. Revision of the PrHed 3/24/96 2:27:54 PM Page 3 of 4

ICAVP DR No. DR-MP3-0623 Northeast Utilities Millstone Unit 3 Discrepancy Report SQSS*t.SS6A/B/C/D process setpoint limit of 28 inches plus increased instrument uncertainty presented in other documents (i.e. CCNs, Procedures, FSAR) is still in development.

Design change modification DCR No. M3-97106 installation and testing is scheduled to be complete prior to Startup. AR No.

96028013 is tracking the RWST empty level and FSAR figure update.

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

Previously klontined by NU? O Yee r#) No Non Diecrepent Condition?O Yee (S) No ResolutionPending?O vee 5) No ResolutionUnresolved?O vee r*) No Review initiator: Hindia, R.

VT Leed: Nerl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Sirgh, Anand K Date: 3/23/98 SL Commente: This DR deals with RWST empty level setpoint discrepancy due to misapplication of uncertainty to the analytical setpoint . CCN 1 in response to this DR has been provided. This CCN incorporated the concems identified by this DR, Note: DR-MP3-1085 was written against subsequent revision of this calculation.

Printed 3r24/96 2:27.55 PM p.g. 4 og 4

ICAVP DR No. DR MP3 4526 Northeast Utilities Ministone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED

s@ W Potential Operaldhty lasue Discipline: Modend Design O vos Discrepancy Type: Calculation

@' No SystemProcess: Rss NRC Significance level: 4 Date faxed to NU:

Date Published: 11/13/97 Discrepency: Calculation US(B)-354

Description:

The purpose of Calculation US(B)-354, Rev. O is to calculate the quench spray system (QSS) piping temperature transients following a set of potentially limiting design basis LOCA scenarios. The calculated piping temperature transients are then to be used in the pipe stress analysis and support load calculations.

Two discrepancies were identified in Calculation US(B)-354.

1. The quench spray flow rates tabulated on page 16 of US(B)-

354 are based on Reference 1 of Calculation US(B)-354 (Calculation US(B)-225 Rev. 5). However, the time dependent spray flow rates have been revised with Revision 6 of Calculation US(B)-225.

2. The containment pressure for scenario P02 at time 25.0 seconds (page 14 of US(B)-354) is incorrectly listed as 35.97 psia. The correct pressure from Reference 9 (Calculation US(B)-

352, Rev. page 24)is 38.02 psia. The value of 35.97 psia is listed in the input echo for scenario P02 (Appendix 1, pages 55 and 56 of US(B)-354). However, the difference of 2.05 psiis not expected to significantly affect the results.

The impact of the revised spray flow rates based on Revision 6 of Calculation US(B)-225 should be evaluated.

Review Valid invalid Needed Date initiator: Walteiend, J. F. O O O S o'30'S7 VT Lead: Neri, Anthony A O O O 10'31/S7 VT Her: schopfer, Don K O O O 11dvS7 IRC Chmn: singh, Anand K O O O $ $'7/87 Date:

INVALID:

Date: 3/17/98 RESOLUTION. DISPOSITION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0526, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR.

M3-98-0180 (attached) will revise calculation US(B)-354 using the corrected input values post startup. The new calculation will change the maximum QSS fill time from 51.2 to 50.2 seconds.

Printed 3/24/98 2:26:22 PM Page 1 of 2

Northe:st Utilities ICAVP DR No. DR-MP3-0526 Millstone Unit 3 Discrepancy Report For scenario PO2 at time 25.0 seconds it will change the containment condition value from 35.97 psia to 38.02 psia.The impact of the changes to calculation US(B)-354 do not adversely affect the piping temperature transients contained within the calculation. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0526, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan (attached) for Condition Report (CR) M3-98-0180 will revise calculation US(B)-354 post startup. The corrections to the calculations are small and will have no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identined by NU7 O Yes (S) No Non Discrepent Condition?O Yes (8) No ResolutionPending?O v @ No R oiutionunr oiv.drO Y (*) No Review initiator: Waksimd, J. F.

VT Lead: Nerl, Anthony A VT Mgr: schopfw, Don K IRC Chmn: singh, Anand K Date: 3/17/98 sL Comments: Sargent & Lundy concurs that the corrective action plan of CR M3-98-0180 will resolve DR-MP3-0526.

Sargent & Lundy concurs that the NRC Significance Level of DR-MP3-0526 should be changed from Level 3 to Level 4. The correction of the QSS fill rate (DR-MP3-0526 item 1) will result in a small change in flow. This will have minor effect on waterhammerloads and water hammerloads are only one of the inputs which contribute to the calculated piping stress levels. The correction of the containment peak pressure (DR-MP3-0526 item

2) is a very small change in a parameter which has an insignificant effect on the calculated piping stress levels.

Prinled Y24/98 2:26:26 PM Page 2 of 2 l

l

)

Northe:st Utilities ICAVP DR N;. DR-MP3-0647 Millstone Unit 3 Discrepancy Report Review Group: Configurabon DR RESOLUTION ACCEPTED Review Element: System instellation Diecipline: Electrical Design Discrepency Type: Drawing Ow SystemfProcess: Rss g

NRC Significence level: 4 Date faxed to NU:

Date Published: 11/2/97 Discrepency: Tray Support Configuration

Description:

1. Field inspection of support R208A-098 found a horizontal section of PS-201 style strut attached to the side vertical I member towards a work platform which is not shown on the I detail drawing EE-34HC Rev. 5. Note: the strut is not attached to work platform. No open documents discuss its addition.
2. Field inspection of support R204-105 found a ve-tical section  !

of PS 200 style strut attached below the bottom member.

Nothing is attached to this added piece. The detail drawing EE- i 34HC Rev. 5 does not show this member. No open documents I discuss its addition.

3. Field ir.gouction of support R150-055 found that the bottom tray shelf member is installed at a 45 degree angle for proper fit- l up to tray. This is not noted on the detail drawing EE-34HA Rev. '

6 and is not covered by any listed open document.

4. Drawing EE-34T Rev.11, indicates that all tray covers for instrument trays shall be flat. This is consistent with the tray detail draw!ng EE-34MJ Rev.3 and tray cover identification drawing EE-34TQ Rev. 2 which indicates top and bottom covers. The Cable and Raceway Program (TSO2) indicates that at least one of the covers for tray riser 3TX104P is vented. Field observation of the tray identified a vented cover on the bottom and flat on the top.

Review Velid invalid Needed Date initiator: server, Y. L G O O 10'18/97 VT Leed: Nwi, Anthony A B O O sot 27/97 VT Mgr: schopfer, Don K O O O ior2as7 IRC Chmn: singh, Anand K 9 O O o'30'97 Date:

INVALID:

Date: 3/17/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0547, 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.

Previously identined by NU7 O Yes @ No Non r"=- --f Condition 70 Yes @ No Printed 3/24/96 2:26:57 PM Pope 1 of 2

l Northext Utilities ICAVP DR N . DR-MP3-0547 l Millstone Unit 3 Discrepancy Report Resoluth Pending?O Yes (9) No Resolution unresolved?O Yes (e) W Revs Y M Needed Me Initiator: Kleic, N VT Leed: Neil, Anthony A B O O *1 m VT Mgr: Schopfer, Don K G O O -  !

- 1 1RC Chmn: Singh, Anand K O O Date:

j

- SL Comments:

I I

l l

l l

Printed 372498 2:292) PM Page 2 of 2

Northe:st Utilities ICAVP DR N3, DR-MP3-0654 Millstone Unit 3 Discrepancy Report Review Group: Conrguration DR RESOLUTION ACCEPTED Review Element: System Instenation D6scipline: EW Design D6ecrepancy Type: Instaustion implementation O vee systemerocess: RSs fs) No NRC Significance level: 4 Date Faxed to NU:

Date Puolished: 11/9/97 Discrepancy: Installation not in agreement with design documents

Description:

1. The third support from tray 3TX763N on conduit 3CX763NB is missing its clamp and therefore the conduit is not supported within the requirements for a maximum span of 8' on non-safety related conduits.
2. Conduits 3CC769NB2 and 3CX755NG are attached to Support G218-016 which is shown on Dwg. EE-34JG Rev. 4.

Neither this drawing nor any open change documents address these additions.

3. Conduit 3CK970PB is routed on the southwest leg of tray Support G400B-026. The support detail drawing for this support, EE-34JK Rev. 3, nor any of the open change documents listed for this drawing address this addition.
4. Conduit 3CX9700G 1" spans 3'-8" to a support that should be an item FE as shown on drawing BE-52CD Rev. 5. Support is missing critical components and is non-functional as found.

Resultant span to next support exceeds criteria in BE-52CA Rev.

4 in that 4'-6" maximum allowed support spacing is not maintained.

5. Conduit 3CC763PC8 (1%")is attached support ES-2678. The support spacing found in field exceeds the maximum listed on drawing BE-52CA Rev. 4, Table CA. Field span is 6'-6" (estimated) while maximum allowed spacing is 5'-6".
6. Conduit 3CK9700B3 (1%") is attached support ES-2528. The support spacing found in field exceeds the maximum listed on drawing BE-52CA Rev. 4, Table CA. Field span is 6*-9" versus allowable of 5'-6".
7. Conduit 3CK7500C, attached to Support ES-344, has support spacing in excess of the maximum allowed by Table CA on drawing BE-52CA Rev 4 for 1 1/2" aluminum. Field measured 6' 3" while maximum allowed is 5'-6".
8. An electric outlet and an emergency lighting unit are installed on the vertical leg of tray Support S106-052 (Ref. drawing EE- .

34MA Rev 5). Two members are installed near the ceiling I between Supports S109E-056 and S109D-065 with nothing attached to them. Neither the detail drawing nor any open change documents discuss these items. l J

9. A section of PS-201 was added to the north vertical leg of O'

Printed 3/2N9e 2:29:27 PM k 1 of 6

DR N;. DR-MP3-0664 Northe:st Utilities ICAVP milistone unk 3 Discrepancy Report This attachment is not shown on the detail drawing EE-34JH Rev. 3. No open change documents listed for this drawing address these additions.

10. Drawing EE-34JG Rev. 4 shows tray Support G213-032. A member not shown on the drawing has been added above the tray as a conduit support. No open change control documents address this addition.
11. Three sections of E-24 strut were added above the cable trays on cable tray support G2038-022 and are used for routing lighting conduit and a door alarm conduit for Door 386. A lighting fixture was installed below the center two trays. This is not shown on drawing EE-34JG Rev.4 and no open change control documents referenced for this drawing address these additions.

Rev6ew Valid invalid Needed Date initiator: server, T. L.

O O O 10/28/97 VT Lead: Nort, Anthony A B O O or2as7 VT Mgr: Schopfer, Don K O O O 1o/3as7 IRC cienn: singh. Anand K B O O l'S7 Date:

INVAllO:

Date: 3/19/98 RESOLUTION. NU has concluded that the issue reported in items 1,4, 5,6,7, and part of 11 of Discrepancy Report, DR-MP3-0554, have identified conditions not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0372 (attached) will correct the documentation or generate the field changes as follows: ltem 1 describes a support on conduit 3CX763NB as missing its clamp. The support is indicated as the third support from tray 3TX763N and states the 8'-0" span for a Non-safety Related conduit is exceeded.A search of the conduit One-Lines and field walkdown indicates the support is ES-2652 and the clamp is missing as stated. The conduit is Non-QA and the distance between the two adjacent supports, ES-170 and ES-171 is approximately 8'-0" which may be slightly overspaned. The Load Allowed for these support details is 600 lbs. and 625 lbs. respectively, with the maximum Actual Loads for the two supports at 8' x 6.54 lbs./ft = 52.32 lbs.

There is adequate capacity which indicates there is no QA 11/1 interaction concem. Issue work orders per the corrective action plan to install the missing clamp per detail BE 52BL to bring the support into conformance. The structuralintegrity of the support as well as the conduit remains acceptable.As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.ltem 4 describes conduit 3CX9700G missing the clamp portion of an item FE as detailed on BE-52CD which results in a span to the next support in excess of the allowed 4'-6* per BE-52CA.A field walkdown and a search of the conduit One-Lines confirms the missing One-Hole C-Clip is for support ES-3295. The actual Printed 3/2498 2:29.31 PM Page 2 of 6 i

]

NortheCst Utilitiea ICAVP DR No. DR-MP3-0664 ultistone Unit 3 Discrepancy Report span between the two adjacent supports, ES-3294 and ES-3296 is approximately 7' 3". The allowed load for ES-3296 is 600 lbs.

and based on a review of Calc.12179-BE-52CD, Rev.1. The capacity of a 1* C-Clip for Aluminum on support ES-3294 is XM(SSE) = 78 lbs. YM(SSE) = 160 lbs. and ZM(SSE) = 30 lbs.

These values were based on accelerations of ig in three directions and the spans given on BE 52CA. To determine the actual load in the three direction on support ES-3294 use the existing span of 7'-3* with the Resonant Peak Acceleration values given in Calc.12179-SEO-SE-52.122 for El.19.5'in the ESF Bldg. A work order per the corrective action plan will be issued to install the missing clip per detail BE-52CD to bring the support into conformance. The Accelerations values at this elevation are less than 1.0 in all directions and due to these reduced values, even with the increased span, support ES-3294 has adequate capacity and remains acceptable. Support ES-3296 also is structurally adequate with the overspan condition as reported. As such there is no effect on the license or design basis, therefore NU has enncluded this to be a Significance Level 4 issue. item 5 describes conduit 3CC763PC8 (1 1/2" AL) attached to support ES 2676 as exceeding the allowed span of 5'-

6* as listed on drawing BE-52CA. The estimated span from field observation is 6*-6*.A search of the applicable drawings in GRITS reveals this is not a previously identified condition and actual span does exceed the allowed span. A review of Calculation 12179-SEO-SE 52.98, Rev.1 indicates for a 1 1/2" Aluminum conduit in the ESF Building (Cut-off frequency of 20 CPS as indicated on drawing BE-52EA) with a span of 6'-6' remains in the rigid range. The maximum span per this calculation for 1 1/2" Aluminum is 7'-8". A DCN will be initiated to document the as-installed condition and the DCN will be posted against ES-2676 in the Cable and Raceway Program to indicate the actual span is acceptable. Therefore, the structural integrity of the support as well as the conduit remains acceptable.As such there is no effect nn the license or design basis, accordingly NU has concluded this to be a Significance  ;

Level 4 issue. item 6 describes conduit 3CK9700B3 (1 1/2" AL)  !

attached to support ES-2528 as exceeding the allowed span of 5'-

6* as listed on drawing BE 52CA. The span from field observation is 6'-9".A search of the applicable drawings in GRITS reveals this is not a previously identified condition and actual span does exceed the allowed span. A review of Calculation 12179-SEO-SE-52.98, Rev.1 indicates for a 1 1/2" Aluminum conduit in the ESF Building (Cut-off frequency of l

20 CPS as indicated on drawing BE-52EA) with a span of 6*-9" '

remains in the rigid range. The maximum span per this calculation for 1 1/2" Aluminum is 7'-8*. A DCN will be initiated to document the as installed condition and the DCN posted against ES-2528 in the Cable and Raceway Program to indicate the actual span is acceptable. Therefore, the structural integrity of the support as well as the conduit remains acceptable.As such there is no effect on the license or design basis, accordingly NU has concluded this to be a Significance Level 4 issue. item 7 describes conduit 3CK7500C (1-1/2" AL) attached to cupport ES-344 as exceeding the allowed span of 5'-6' as listed on drawing PrWed 3/2*B8 2:29:32 PM BE-52CA. The sown from field observation is 6'-3*.A search of Page 3 or 6

Northerst Utnitie3 ICAVP DR No. DR4P3-0664 ministone unit 3 Discrepancy Report the applicable drawings in GRITS reveals this is not a previously I identified condition and actual span does exceed the allowed span. A review of Calculation 12179-SEO-SE-52.98, Rev.1 Indicates for a 1 1/2" Aluminum conduit in the ESF Building (Cut-off frequency of 20 CPS as indicated on drawing BE-52EA) with a span of 6'-3' remains in the rigid ran0e. The maximum span per this calculation for 1 1/2" Aluminum is 7'-8". A DCN will be initiated to document the as-installed condition and the DCN posted aGainst ES-344 in the Cable and Raceway Program to indicate the adual span is acceptable. Therefore, the structural integrity of the support as well as the conduit remains acceptable.As such there is no effect on the license or design basis, accordin0ly NU has concluded this to be a Significance Level 4 issue. item 11, the first part, states that three sections of E-24 strut were added above the cable trays on support G2038-022 and are used for routing lighting conduN and a dnor alarm conduit for Door 386.A field walkdown confirms that three sections of power strut are installed between the vertical members of EN-G2038-022 with (4) 1" lighting conduits and (1) 1* security conduit. A search of the Cable and Raceway Program and GRITS a0ainst the applicable documents reveals no supporting documentation for these attachments and this condition was not previously identified. A DCN will be initiated to document the as-installed condition and the DCN posted against the Cable and Raceway Program to indicate conduit attached to EN-G2038 022 also posted a0sinst drawing EE-34JG. The avera0e weight for this tray support is 18.35 lbs. with a maximum everage weight allowed of 38 lbs. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.NU has concluded that the issue repurted in items 2, 3, 8, 9,10 and the second part of item 11 of Discrepancy Repor1, DR-MP3 0554, does not represent a descrepent condition. item 2 describes conduits 3CC769NB2 and 3CX755NG as being attached to Cable Tray Support G218-016 on EE -34JG, Rev. 4 without documentation. A search of the Cable and Raceway Program indicates these two conduits as having work in progress. A further search against the tray support EN-G218-016 indicates CND are attached and that the qualification document is DCN DM3-00-1228-96 (attached) and its supplements. A review of this DCN shows the conduit attached to the Tray Support and qualified by SAVT 96-015. Therefore, since the attachments are fully qualified and documented this is not a discrepancy and no further action is required. item 3 describes conduit 3CK970PB as bein0 attached to the southwest leg of tray support G400B-026 with no open change documents listed.A search of the Cable and Raceway Program indicates that tray support EM-G4006-026 does have conduits attached. A GRITS search aGainst drawing EE-34EM reveals E&DCR F-E-41790 (attached), which gives details and approval for attachin0 conduit 3CK970PB on CSL ES-3199 to tray support EM-G400B-026. Therefore, this is not a discrepancy and no further action is required. item 8, the first part, describes an electric outlet and an emergency lighting unit attached to the vertical leg of tray support S106-052 shown on EE-34MA with no supporting documentation.A field walkdown Printed 3G4418 2:29:33 PM ir**es there are no electric outlets or emeser.cv liohtina units Page 4 or 6

Northext Utilities ICAVP DR No. DR-MP3-0554 j g Millstone Unit 3 Discrepancy Report attached to tray support DQ-S106-052. However, the described condition does exist at suppod DQ-S109E-56 which is also shown on drawing EE-34MA. It is assumed that this item is referring to support DQ-S109E-56 for the location of the electric outlet and an emergency lighting unit. With this assumption, a search of the Lighting Plan for the Service Bldg. El 4'-6* reveals that drawing EE-68A, Rev. 7 shows the configuration observed in the field with the electric outlet and emergency lighting unit attached to the side of a cable tray in the location of DQ-S109E-

56. Therefore, this condition has been documented and is not a discrepent condition. item 8, the second part, describes two l members installed near the ceiling between tray supports 8109E-056 and S109D-065 with nothing attached to them with no documentation supporting the condition.A GRITS Search against drawings EE-34DQ and EE 34MA reveals an E&DCR F-E-8999 )

(attached) that adds two section of strut between these two tray supports as axial bracing with no intent of attaching anything to them. This E&DCR is also reflected on drawing EE-34MA which shows the location of these two struts. Therefore there is no discrepancy and no further action is required.ltem 9 states that a lighting fixture and lighting box are attached to the north vertical i member of tray support G306-039 via a length of PS-201 and  !

are not shown on support detail drawing EE-34JH. This lighting fixture is installed to a length of PS-201 which is attached perpendicular to the bottom horizontal of tray supports G306-39

& G305-38. The outlet box for this fixture is attached to the inside vertical member of tray support G306-39. This arrangement and attachment is in accordance with the Lighting 1 Plan and Fixture Support Detail Drawings EE-67G & 67J.

Therefore this item is not valid and requires no further  !

action. item 10 describes a member used for a conduit support as ,

being attached above tray support G213-032 on drawing EE-34JG with no open change documents listed.A search of the Cable and Raceway Program indicates that tray support EN-G213-032 is detailed on EE-34EN. A GRITS search against drawing EE-34EN and EE-34JG reveals E&DCR F-E-15026 l

(attached), which gives details and approval for attaching a member above tray support G213 for a future lighting conduit.

Therefore, this is not a discrepancy and no further action is required. item 11, the second part, identifies a lighting fixture l

attached to tray support G2038-022 which is not shown on '

support detail drawing EE-34JG. This lighting fixture is installed parallel with tray support G2038-022 and to the bottom horizontals centered under 2 trays, via 2-PS201 strut clamps.

This arrangement and attachment is in accordance with the Lighting Plan and Fixture Support Detail Drawings EE-67F &

67J. Therefore this item is not valid and requires no further action. Significance Level criteria do not apply here as this is not a discrepant condition.

Previously identified by Nu? O Yes @ No Non Discrepent Condition?O Ye. @ No Resolution Pending?O ve. @ No Ree iuiion unr ev.d?O v.. @ No initiator: tonic, N *

  • VT Lead: Nort, Anthony A Printed 3/24/98 2:29:34 PM Page 5 or 6

NsrtheTt Utilitieo ICAVP DR No. DR MP3-0654 Millstone Unit 3 Discrepancy Report w a -- -i, - ., n VT Mgr: Schopfer, Don K O O O S=

IRC Chmn: Skyh. Anand K O O -

Date:

D O O SL Comments:

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l Printed T2498 2:29:36 PM Page 6 of 6

Northe:st Utilitie3 ICAVP DR No. DR-MP3-0671 Millstone Unit 3 Discrepancy Report Review Group: system i DR RESOLUTION ACCEPTED Review Element: system Design Discipline: Mechanical Design Diecropency Type: Calculaten OYee 1 SystemProcess: Rss g j NRC Significance level: 4 Date faxed to NU:

Date Published: 11/15/97 Discrepancy: Calculation US(B)-1187

Description:

The purpose of calculation US(B)-1187, Rev.1 is to determine RSS operating pressures and temperatures for RSS stress data package SDP-RSS-01361M3, Rev. 4 which are to be used in the piping stress analysis.

{

Four discrepancies were identified in US(B)-1187:

1. The elevation of the RSS pump discharge is incorrectly used.

Pump discharge pressure is conservatively calculated as {

occurring at the pump impeller elevation of-47'-4" which is intemal to the pump. This resulting discharDe pressure is used to RSS HX outlet, and RSS spray header pressures as if it occurred i at the minimum elevation of the pump discharge line,-23'-3".

This error overestimates head by 24'-1" (9.8 to 10.4 psi) for all modes of operation.

2. A nominal water density of 62.34 lbm/ft3 is used to compute k system pressures, rather than the actual densities of 62.426 lbm/ft3 at 40F,61.74 lbm/ft3 at 118F, and 58.60 lbm/ft3 at 257F.

This results in overestimates of pressure of up to 11.6 and underestimates of pressure of as much as 0.3 psi.

3. The reference given for RSS pump impeller elevation of -47'-

4" is Calc. US(B)-326. Calc. US(B)-326, Rev.1 does not, however, reference a pump drawing. It references Calc. NM(B)- )

i 418-BD, which is superseded by Calc. NM(B)-323-BD. Thus, a proper reference for this elevation was not given. The elevation {

that was used is reasonable because Dwg. EP-79N-8 shows that the bottom of the pump is at elevation -49'-0".

4. To compute RSS pressures during ECCS injection phase containment spray, a sump level of elevation of-25'-2" is used.

The reference for this level, Calc. US(B)-273, actually gives a level of 23.1 ft.

The cumulative significance of the discrepancies discussed above is to overestimate system pressures by up to 26 psi. It is the engineering judgment of the reviewer that overestimating operating pressure is conservative and that reducing the estimated pressure by 26 psi would have a negligible effect on computed stresses in standard wall piping.

Review Valid invalid Needed Date initiator: Wakelend. J. F.

O O O 'or31'S7 VT Leed: Nerl, Anthony A O O O 'or31'S7 Printed 3/2O62:30.17 PM Ph D l

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Northe:st Utilitie3 ICAVP DR No. DR-MP3-0671 Millstone Unit 3 Discrepancy Report WT Mgr: schopfer, Den K RC Chmn: Singh, Anand K Q ] Q 11/6@7 Q Q Q 11/11/97 Date:

RvALo:

Date: 3/17/98 RESOLUTION: DISPOSITION:

NU has concluded that Discrepancy Report, DR-MP3-0571, 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 l

concems and meets the Unit 3 deferral criteria. CR M3-98-0138 1 has been written to develop and track resolution of this item per RP-4.

CONCLUSION:

NU has concluded that Discrepancy Report, DR-MP3-0571, 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 M3-98-0138 has been written to develop and track resolution of this item per RP-4.

Prev 60usly identitled by NU? O Yes (#1 No Non Discrepent Condition?() vos (ej No Resolution Pend 6ng?O v @ No R iution unr ev.drO vos @ No Review initiator: Wakeland. J. F.

VT Lead: Nut, Anthony A VT Mgr: Schopfer, Don K RC Chmn: Singh. Anand K Date: 3/17/98 SL Comments:

Sargent & Lundy concurs that correction of the discrepancies identified in DR-MP3-0571 may be deferred until after Unit 3 restart.

Prinled V24962:30:21 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-068 milistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p

w 2. m Design O yeo Discrepancy Type: ceiculetkm (,y g, SystwWProcess: Rss NRC Significance level: 4 Date faxed to NU:

Date PutWiehed: 12/8/97 Discrepancy. Calculation US(B)-326

Description:

The purpose of Calculation US(B)-326, Rev.1 is to demonstrate I that there would be an adequate supply of sump water to the RSS pumps for a postulated design basis large break or small break LOCA. The sump water supply determination includes evaluation of insulation debris buildup on the sump fine mesh screens, containment spray holdup and time delay, and RSS pump required NPSH.

Ten discrepancies were identified in Calculation US(B)-326:

1. The specialized LOCTIC run used in calculation US(B)-326 models a PSDER break with initial conditions and blowdown based on Reference 45 (Calculation US(B)-273, Rev. 3) (pages 33 of US(B)-326). However Revision 5 of US(B)- 273 provides new LOCA analyses.
2. Figure 9 on page 26 of calculation US(B)-326 incorrectly labels the width of screens F2 (17.68") and FS (36"). The correct width of F2 is 26 7/8". The correct width of F5 is 28" (Drawing ES-53AM). However, the calculation is based on the correct width for F2. The areas of screens F4 and F5 are based on a width of 28", page 30, (the F5 width). The calculation for the screen area requires refinement for more accuracy. See also comments 3 and 8.
3. The length of the angle steel around the perimeter of screen F6 is incorrectly calculated as 9.52' on page 30. The total length should include another horizontal section of length 1.25' for a total length of 10.77'. The increase in angle length would reduce the F6 screen area. The calculation for the screen area requires refinement for more accuracy.
4. Based on Reference 4 (Calculation US(B)-249, Rev. 3, CCN
1) (note: calculation US(B)-326 is based on revision 2 of US(B)-

249), the water fill rate above elevation (-) 24' 6" and up to elevation (-)11' 3"is 8138 gal /in and not 7650.97 gal /in (page 51 of US(B)-326). Additionally, the IOC dated 3/21/86 concludes that previously misinterpreted LOCTIC output (there is actually less water on the floor) is acceptable since the fill rate above (-)

24' 6" is more closer to 7200 gal /in. However, there is no calculation to support the smaller and less conservative fill rate of 7200 gal /in.

5. The total volume of 1663.5 gallons (page 55) for the RSS pumps, suction pipes and suction inlets includes a suction pipe p vim 0 Of St.S ;;0!!One b=0d On R0f0ren00 2 (C22t!0h e 4

Northert Utilities ICAVP DR No. DR-MP3-0583 Millstone Unit 3 Discrepancy Report 232, Rev. 2). A previous comment with regards to calculation ES-232 stated that suction pipe volume is considerably larger than 84.8 gallons. Additionally, the RSS volume tabulated on page 56 i of US(B)-326 is based on Reference 1 (Calculation ES-231, Rev.1). The current revision of ES-231 is 2. The results tabulated on page 25 of ES-231, Rev. 2 for the RSS volumes are larger than those used in US(B)-326. The empty RSS volume of 15793 Gallons (page 56) would be affected as would 4 the fill times shown on pa0e 57 as a result of this discrepancy. l

6. The value for TDWSPY' at 724 seconds (453,000 !b) in Table 8 on page 57 is transposed in equation 3 to 435,000 lb. The l smaller number is conservative since it results in less water on j the floor and a less net submerged screen area at 724 seconds. i
7. The trough elevation on page 88 should be based on a horizontal distance to point A (The distance between the reactor i cavity wall and the point in containment sump trough where insulation debris is assumed to land) of 13.08' and not 33.88' (the distance of 33.88' was selected because it is below the center of a steam generator). This discrepancy results in an elevation difference at point A of approximately 0.08'. This difference would have a sli0ht affect on the approach velocity, however the j difference is not expected to affect the results. l
8. The net fine screen area calculated on page 100 at time equal to 2000 seconds is 256.4 ft2 at a water elevation of (-)

20.4' ((-)24.5 + 4.1) (page 99). However, from page 25 the top of the fine screens is at elevation (-) 20.21' and the net wetted area at 100% submergence is 244.2 ft2 (page 69). The total net screen area calculation based on the water elevation above (-)

24.5' (pa0e 100) over estimates the net fine screen wetted area.

Additionally, the calculation on page 31 for the total net screen area for any submergence level above elevation (-) 24.5' also over estimates the net screen area. This is not conservative since a larger area results in a smaller approach velocity and a smaller debris thickness. The smaller approach velocity and debris thickness, due to the larger than actual screen area, result in more available NPSH, as calculated in US(B)-326, than is actually available.

9. The assumption is made on page 50 that all four RSS pumps start at 660 seconds is based on the premise that two pumps ,

l start at 660 seconds and two pumps start at 670 seconds.

According to LSK 24-9.4A, Rev.9, the DG load sequencers delay A and B pump actuation 650 seconds after receipt of a CDA signal and, C and D pump actuation 660 seconds after receipt of I a CDA signal. According to TS Surveillance Requirment 4.6.2.2.c, the allowable setpoint drift for the RSS pump time delay is +/-20 seconds. Detailed analysis of sump volume, net submerged screen area, and available NPSH for the RSS pumps is not performed at time equal 630 seconds.

10. The cover page of calculation US(B)-326 indicates that US(B)-326 supplements calculation US(B)-316. However, I calculation US(B)-316 addresses complete fine screen i PrWed 3/2498 2:39:32 PM Page 2 of 4

Northe:st Utilities ICAVP DR No. DR-MP3-0683 Misistone Unit 3 Discrepancy Report submer0ence (which is not limiting) and secondary side system breaks. It is not clear how calculation US(B)-326 supplements calculation US(B)-316.

Calculation US(B)-326 should be evaluated for the impact of discrepancies.

Review Valid invand Needed Date initiator: Wakelena, J. F. O O O 31/i2/97 VT Leed: Nort, Anthony A B O O sii als7 VT Mgr: Schopfer, Don K O O O i2is/97 1RC Chmn: Singh, Anand K O O O 52/4/97 Date:

INVALID:

Date: 3/17/98 RESOLUTION: DISPOSITION:

NU has concluded that DR-MP3-0583 identifies a condition previously discovered by NU which has been corrected. As a result of the calculation review process, errors were discovered j in calculation US(B)-326. ACR M3-96-0620 was generated to document these errors and to track the corrective action. The corrective action agreed upon in ACR M3-96-0620 was to review I all calculations necessary to ensure RSS pump NPSH. This review culminated in calculation US(B)-326 Rev 1 being superceded by calculation US(B)-362 which incorporates current design information and operating practices. 4 CONCLUSION:

NU has concluded that Discrepancy Report DR-MP3-0583 identifies a condition previously discovered by NU which has been addressed. As a result of the calculation review process, errors were discovered in calculation US(B)-326. ACR M3 0620 was Generated to document these errors and to track the corrective action. The corrective action agreed upon in ACR M3-96-0620 was to review all calculations necJssary to ensure RSS l pump NPSH. This review culminated in calculation US(B)-326 Rev 1 being superceded by calculation US(B)-362 which incorporates current design information and operating practices.

Previously identified by NU7 O Yes @ No Non Discrepent condition 70 Yes (G) No ResolutionPending70 v @ No R iuiion uar.conv.d70 v.. col No Review inittelor: Wakeland, J. F.

VT Leed: Nerl. Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/17/98 sL Comments: Sargent & Lundy does not agree that all of the issues identifico in DR-MP3-0583 were previously discovered by NU in ACR M3 0620. initiated 8-25-96. ACR M3-96-0620 identifies DR-MP3-Printed 3/24/96 2.39:34 PM Page 3 of 4

NortheCCt Utilkies ICAVP DR N9. DR MP3-0583 Millstone Unit 3 Discrepancy Report 0583 items 4,8 and 9, but does not identify items 1,2. 5,6, 7, or 10.

Sargent & Lundy has determined that the NRC Significance Level of items 1, 2, 5,6, 7 and 10 is Level 4, so the significance level of I

this DR was chan0ed accordingly.

Sargent & Lundy concludes that NU resolved all 10 discrepant conditions identified in DR-MP3-0583 with the issuance of US(B)-

362.Rev.O.

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Printed 3/24/98 2:39:36 PM p i

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Northe:st Utilities ICAVP DR No. DR-MP3-0613 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design g r" E Disci Pilne: Mechancel Desden wy Type: Component Date Om

@ No SystemProcess: Oss NRC We levd 4 Date faxed to NU:  ;

Date Putdished 11/20/97 D6screpency: Inconsistency between FSAR Sec 6.1.1.1 Tbl 6.1 1, & l component desi0n w/ respect to yelid strength

Description:

FSAR Section 6.1.1.1 states that cold-worked stainless steels exhibiting a yleid strength in excess of 90,000 psi shall not be used. The following are inconsistencies with this requirement:

A. All stainless steel material in the quench spray system has a yleid strength less than 90,000 psi, except as follows:

1. SA-564 TP 630 Cond H-1150 used for the shaft on

. valves 3QSS*MOV34A,B, SQSSV2,6, and 3QSS*V945,946.

2. SA 564 TP 630 Cond H-1075 used for the shaft on valves 3QSS*AOV27,28. ,

I

3. SA 193 GR B7 used for the bolts on the RWST have a yleid strength less than 90,000 psi only if bolts the are 4 to 7 inches in diameter. The sizes of the RWST bolts are not shown on the RWST drawings. Therefore, the yleid strength for this materialis indeterminant. Note that FSAR Table 6.1-1 specifies tank botting to be SA-193 G R B 7.
4. SA-193 GR B7 and GR B16 used for bolts on valves j 3QSS*AOV27/28 have a yield strength less than '

90,000 psi only if the bolts are 4 to 7 inches in diameter.

Drawing 2472.110-185-349 shows that the bolts on these valves are SST 18-8. Conflicting data is  ;

provided on the valve botting material.

5. A-276 TP 316 Cond B used for the stem on valves 3Q SS*V50-58, 940, 941, 948-951, 968-975, 933-936, 957-959, 964-967, 986, 987, 42,43.
6. A-276 TP 316 Cond B used for the pump shaft on pumps 3QSS*P3A,B.

\'

7. SA-276 TP 304 Cond A and SA-296 CF8 used for the clapper arm, clapper arm shaft, disc nut pin, and disc nut washer on valves 30SS*V4,8 and 30SS*V976-979, and for the impeller in pumps 3QSS*P3A B. These materials are not listed in ASME Section 11, Part A, eventhough the material designations can be traced back to ASTM specifications A-276, A-743, A-743M, A-744, nrvi A.741u Printed 3f24/98 2 40:22 PM Pege 1 of 4

Northe:st Utilities ICAVP DR N3. DR-MP3-0613 Millstone Unit 3 Discrepancy Report Material references are:

Drawings:

2472.110-185-349 Revision C 2282.050-153-0-39 Revision B 2362.200-164-040 Revision A 2282.150-154-021 Revision G 2282.150-154-043 Revision G 2214.602-040-013 Revision C 2362.200-164-018 Revision B 2214.601-023-001 Revision R 2282.050-153-036 Revision A Specifications:

24??.110-185 Revision 1 SP-ME-784 Revision 2 2362.200-164 Revision 1 B. All stainless steel material used in the containment recirculaiton spray system has a yleid strength less than 90,000 psi, except as follows:

1. SA-564 TP 630 Cond H-1150 used for the shaft on valves 3RSS*MOV20A,B,C,D and 3RSS*MOV23A,B,C,D.
2. SA-564 TP 630, no Condition specified, used for the bonnet nuts and studs on valves 3RSS*MOV38A,B.  ;
3. A-705 Grade 630, no Condition specified, used for the stem on valves SRSS*MOV38A B.

3RSS*MOV8837A,B, and 3RSS*MOV8838A,B.

4. A-276 TP 316 Cond B used for the stem on valves 3RSS*V32-33, 58-59, 62-63, 66-67, 913, 916, 920-931, 946-953, 988-995,958-959, 961-962, 64-65,68-69, 912, 970-971, 973, 977-978, 984, 967-968,980-981,911, and 3RSS-V25,941-944, 935-938,918-919,960,934,939, 963-966, 969, 976,979,983.
5. A-276 TP 316 Cond B used for the packing gland and packing gland bolts on valves 3RSS*V32-33, 58-59,62-63,66-67,913,916,920-931, 946-953, 988-995, 958-959, 961 962.
6. SA-276 TP 304 Cond A, SA-276 TP 316 Cond B, l and SA-296 CF8 used for the clapper arm, clapper '

arm shaft, disc nut pin and disc nut washer on valves 3RSS*V3,6,9,12. These materials are not listed in ASME Section li, Part A, eventhough the material designations can be traced back to ASTM specifications A-276, A 743, A-743M, A 744, and A-744M.

7. SA-569 used for the shroud on the RSS expansion loints.

Printed 3f24/98 2M24 PM Page 2 of 4

I Northeast Utilities ICAVP DR No. DR-MP3-0613 Millstone Unit 3 Discrepancy Report 3RSS*EJ1 A,B,C,D and 3RSS*EJ2A,B,C,D. This material is not listed in ASME Section ll, Part A.

Material references are: .

Drawings:

2332.910-669-026 Rovision H 2282.150-154-019 Revision G 2332.910-669-027 Revision J 2282.150-154-021 Revision G 2282.050-676-103 Revision i 2282.150-154-022 Revision K 2282.050-676-110 Revision E 2282.150-154-026 Revision G 2282.050-153-036 Revision A 2282.150-154-042 Revision G 2282.050-153-039 Revision B 2282.150-154-043 Revision G 2282.050-153-042 Revision A 2282.150-154-044 Revision G 2282.150-154-018 Revision G 2282.150-154-046 Revision G

Specifications:

SP-ME-764 Revision 2 Review Vaud invand Needed Date initletor: Feengold, D. J. 6 O O 5 '50'87 VT Lead: Nerl, Anthony A B O O $ '15/S7 VT Mgr: schopfer, Don K B O O 557/S7 1RC Chmn: singh, Anand K B O O 17/S7 Date:

INVALID:

Date: 3/19/98 RESOLUTION: Dispositon:

NU has concluded that Dircrepancy Report DR-MP3-0613 has identified a condition not previously discovered by NU which requires correction. Condition Report (CR) M3-97-4568 (See Attached) was written to provide the necessary corrective action to resolve this issue. The corrective action to correct this issue is to issue a FSARCR to clarify the appropriate applicability or exclusion of the materiallimitations within the ECCS. This corrective action is an enhancement to the FSAR to clarify plant configuration and is an administrative task for FSAR clarification only. Based upon the preceding discussion, the LB / DB of MP3 is not impa ted by this discrepancy therefore NU considers this issue to be a level 4 discrepancy.

This corrective action will be performed Post MP3 Startup.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0613 has identified a condition not previously discovered by NU which requires correction. The corrective action necessary to resolve Printed 324/98 2 40:26 PM Page 3 of 4 1

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Northe st Utilities ICAVP DR No. DR-MP3-0613 Ministone unit 3 Discrepancy Report the issues detailed in DR-MP3 0613 will be implemented and tracked under the auspices cf condition report M3-97-4568 (See Attached). The corrective action outlined in Condition Report M3-97-4568 necessary to correct this issue is to issue a FSARCR to clarify the appropriate applicability or exclusion of the material limitations within the ECCS. This corrective action is an enhancement to the FSAR to clarify plant configuration and is sn administrative task for FSAR clarification only. Based upon the preceding discussion, the LB / DB of MP3 is not impa ted by this discrepancy therefore NU considers this issue to be a level 4 discrepancy.

This corrective action will be performed Post MP3 Startup.

Previously identified by NU? U Yes @ No Non Diecrepant Condition?O Yes @ No Resolution Pending?O Yes @ No Resoiuiionunresoeved?O Yes @ No Review initietor: Feingold, D. J.

VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Date:

SL Commente:

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Printed Y24/96 2:40.26PM Page 4 of 4

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I Northe:st Utilities ICAVP DR No. DR-MP3-0666 Mmstone unit 3 Discrepancy Report 1 i

Review Group: System DR RFSOLUTioN ACCEPTED Je:;:: = :e" . g,-- 4 D6screpency Type: Calculat6an (9) No

~

SystemProcese: HVX )

NRC S:;;f we level: NA Date faxed to NU: )

Date Publ6ehed: 12/8S7 D6screpancy: Calculation P(B) 741 CCP Area Temperature Gradient on Loss of Ventilation Ducription: Calculation P(B)-741 Rev. 0 ' Auxiliary Building Ventilation - CCP Area Temperature Gradient on Loss of Ventilation' determines =

the tempemture Gradient within the component cooling area following the loss of ventilation due to a design basis fire in the mechanical equipment room. During review of the calculation the following discrepancy was identified:

The heat loads used in the calculation for the component cooling water heat exchanger, component cooling water pump, and motor control center are assumed values and are lower than the heat loads for normal operation in calculation 3-92-103-191M3, Rev.1. As a result the calculation under estimates the time it takes the room to heatup to 185'F. FSAR Appendix 38 shows the maximum accident room temperature as 185'F Review Valid invalid Needed Date initielor: Stout, M. D. O O O ist2as7 VT Leed: Nerl, Anthony A B O O r20m7 VT Mor: Schopfer. Don K G O O 2/i/97 IRC Chmn: Singh, Anand K O O O 12/4s7 Date:

INVAUD: j Date: 3/18/96 RESOLUTION First Response:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0666 does not represent a discrepant condition.

l Calculations P(B)-741 and 3-92-103191M3 represent diverse plant conditions and the equipment and system total heat loads ,

used in these calculations are not comparable.

Calculation P(B)-741 determines the heat up in the component cooling water pump and heat exchanger (CCP) area due to loss of ventilation in the summer with only one train of CCP, but of no other system or equipment, in operation. This condition is postulated following a fire at elevation 66'-8" or a fire on the south side of the fire sprinkler curtain that separates the charging pumps (CHS) area from tha CCP area. These scenarios are described in Appendix R Compliance Report.

Calculation 3-92-103-191M3 was generated in 1992 as part of PDCR 3-92-103 which covers various plant conditions during Printed 3/24S8 2.41:00 PM Page 1 of 4

I Northe:st Utilities ICAVP DR No. DR-MP3-0666 Millstone unit 3 Discrepancy Report winter and spring (but not in the summer), such as normal 3 i

operation, Loss of Power, SIS etc. with and without single failure but with both trains of the CCP and CHS systems in operation.

The hect loads used its calculation P(B)-741 are not assumed values; they had been extracted directly from calculation P(B)-29 j as indicated; only the CCP pump motor heat rejection rate had been modified using up to date CCP pump motor Bhp and efficiency data which were not available at the time P(B)-29 was prepared. P(B)-29 was superseded and is now replaced by P(B)-

900. The qualifier " assumed" refers to the fact that at the time of P(B)-741 preparation, there was no valid documentary source for the assumption of only one CCP train operation to cope with an Appendix R fire. Calculation P(B)-741 was one of the earliest activities associated with the Appendix R task effort which ended up with the formal Appendix R Compliance Report.

In conclusion, the input data used in calculation P(B)-741 are in line with the calculation of record P(B)-900 and its assumptions are in conformance with Appendix R Compliance Report.

Significance Level Criteria do not apply since this is not a discrepant condition.

Attachments: None Second Response: .

__ _ j NU has concluded that the issue reported in Discrepancy Report DR-MP3-0666 does not represent a discrepant condition.

1. The current Rev. of Calc. No. 12179-900P(B), is 01 (copy i attached), This Rev, depicts total Electrical Load from f Equipment and Lights to be 95,660 BTU /HR.
2. The total Electric Load from Equipment and Lights of 95,660 BTU /HR, shown in Calc. 3-92-103-191M3, Rev. 01 is extracted from Electrical Calculation No. 92-LOE-189E3 for Normal Conditions as 29,227 Watts. This Load is used as an input to l Calc. No.12179-900P(B), Rev. No. 01, page 6. l
3. The objective of Calculation P(B) 741 is to determine the temperature gradient within the Component Cooling Area at the end of 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br />, following loss of ventilation due to damage of j both ventilation trains from a single design basis fire in the mechanical room. This calculation concluded that the qualifying maximum temperature of 185 F (even with lower loads than the j ones depicted in Calculations 3-92-103-191M3 & 12179- l 900P(B)), will be exceeded in less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> & in tum }

prompted the need to provide temporary emergency ventilation system to cope with the elevated temperatures in these areas.

This was accomplished by issuing Calculation P(B)-1130, E &

DCR # TP-07786 and OP 3314J. Therefore Calculation P(B)- l 741 should be treated as a historical calculation and it does not j need to be updated to agree with the parameters of other associated calculations (see attached copy of CCN-01 for Rev. l Printed 3/24/96 2:41:04 PM Page 2 of 4

l t

Northe:st Utilities ICAVP DR No. DR-MP3-0666 Millstone Unit 3 Discrepancy Report 00 of Calculation P(B)-741) .

NOTE: No data from Calculation P(B)-741 was used as an input in other calculations. Calculation P(B)-1130, referenced above, is also the subject of DR-MP3-667. This calculation has an error that was reported in CR-M3-98-1231, (M3-IRF-01922).

Discrepancy Level Criteria do not apply since this is not a discrepant condition.

Attachments:

CCN-01 for Calculation P(B)-741, Rev. O Calculation 900P(B), Rev.1 Previously idenuned by NU? O Yes (e) No Non Discrepent Condluon?@) Yes O No f Resolution Pending70 Yes @ No Resoiunon unr.ooiv.d70 Yes @ No Rev6ew inittetor: stout, M. D.

VT Leed: Nort, Anthony A VT Mgr: Schopfw, Don K IRC Chmn: Singh, Anend K g

O Date: 3/18/98 sL cornments: Comments on First Response; Agree with NU's response that it is reasonable to assume one component cooling water pump is operating during normal plant conditions. l l

However, NU's response does not adequately address the differences in the electrical equipment, cable, and lighting heat l gains used in calculations P(B)-741, P(B)-900, and 3-92103- l 191M3. l The electrical equipment load in calculation P(B)-741 is a motor control center at 13,640 Blu/hr.

The electrical equipment loads in calculation P(B)-900 are motor control centers at 13,200 Blu/hr, miscellaneous electrical equipment at 8,450 Btu /hr, cable loads at 4,200 Blu/hr, and lighting at 25,600 Blu/hr for a total of 51,450 Blu/hr.

l The electrical equipment loads shown on page 15 of calculation 3- l 92-103-191M3 for normal operation is 95,660 Blu/hr and was '

based on calculation 92-LOE-189E3.

NU's response should address the differences in tne electrical loads used in the three calculations for normal conditions and why the loads from calculation 3-92-103-191M3 are not used in calculation P(B)-741. Also, how would a faster heatup rate effect the conclusions of other calculations / evaluations that used the results of P(B)-741 as input?.

Comments on Second Response:

Printed V2496 2A1:oS PM Pa0e 3 of 4

ICAVP DR No. DR-MP3-0666 Northert Utilities Millstone Unit 3 Discrepancy Report A0ree with NU's response that the conclusion of calculation P(B)-

741 was not affected by using lower heat loads. Since the results of the calculation resulted in the use of temporary fans to cope with elevated temperatures (ref. OP 3314J) this is considered to be a non41screpant condition.

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PrWed 3/2496 2.41:07 PM Page 4 of 4 I i

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Northeast Utilities ICAVP DR No. DR-MP3-0710 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLLmON ACCEPTED Potential Operability issue Diecipline: Mechanical Design E ' -- .- - ;y Type: Calculation SystemProcess: Rss g

NRC Significance levet: NA Date faxed to NU:

Date Published: 1/22/98 Discrepancy. Basis for RSS Pump Performance Requirement for Cold Leg / Hot Leg Recirculation Modes of ECCS

Description:

FSAR Figure 6.3-1, " Safety injection / Residual Heat Removal System Process Flow Diagram", indicates that the RSS pumps must meet the following two performance requirements:

1. One RSS pump alinged to one train of HHSI during ECCS Mode B, Cold Leg Recirculation, must deliver at least 1310 gpm at 206 psig to the suction of the SlH and CHS pumps (REQ-MP3-RSS-0867).
2. One RSS pump alinged to one train of HHSl during ECCS Mode C, Hot Leg Recirculation, must deliver at least 2341 gpm at 160 psig to the SlH pump suction and 170 psig to the CHS pump suction (REQ-MP3-RSS-0873).

No analytical basis was found for the RSS pump performance requirement for the cold leg / hot leg recirculation modes of ECCS.

Westinghouse Letter NEU-562 (3-21-73) transmitted ECCS piping resistance criteria. Westinghouse Letter NEU-16g3 (11 75) transmitted the results of a preliminary ECCS hydraulic analysis. Calculation P(R)-982, Rev. O confirms that the ECCS piping system design conforms to the criteria of Westinghouse Letter NEU-562. Calculation US(B)-245, Rev. 0 (and CCNs 1,2 and 3) develops the design basis model for the ECCS hydraulic netwod (the ECCS system from the RWST and sump to the RCS cold legs). Calculation US(B)-311, Rev. O employed the US(B)-245 hydraulic model with the 10% degradation of ECCS pump head allowed by the IST program. It calculated the design basis Min. ESF ECCS flows for injection mode (including RSS spray flow). US(B)-311 also calculated the design basis Min.

ESF ECCS flows for cold leg recirculation mode.

For the cold leg recirculation mode analyzed in US(B)-311, Rev.

O, RSS pumps supply water to the HHSI pumps and directly to the RCS through the LHSl cold leg injection lines (via the 3SIL*MV8809A/B valves). This mode of operation is no longer part of the ECCS system design. According to FSAR Table 6.3-7, RHR pump cold leg injection valves 3SIL*MV8809A/B are closed prior to manual ECCS suction switchover (REQ-MP3-RSS-0225 and RSS-0265). Thus, there no longer is any LHSI function for the RSS pumps. CCN 1 to US(B)-311 recongnizes this fact and deletes the hydraulic analysis of ECCS cold leg recirculation mode (Design Basis Summary Document 3DBS-NSS-003 still contains data from the deleted portion of US(B)-

M1 can fW LADtn7A7)' hin nihar hudrnntie nnnlucic

' ' hne hamn Printed 3/2496 2.47A0 PM Page 1 of 4

Northeast Utilities ICAVP DR No. DR-MP3-0710 Millstone Unit 3 Discrepancy Repoft found which addresses ECCS Mode B, cold leg recirculation.

No calculation has been located which demonstrates that the RSS pumps can deliver the design basis flow of 1310 gpm to each train of HHSI during the cold leg recirculation mode of ECCS. No calculation has been located which demonstrates that the RSS pumps can deliver the design basis flow of 2341 gpm to each train of HHSI during the hot leg recirculation mode of ECCS.

No pre-operational test was fcund which proves the RSS pump meets its performance requirement for the cold leg / hot leg recirculation modes of ECCS. The preoperational test, T 3306-P, verified that the combined HHSI/LHSI flow requirement could be provided by the RSS pumps during ECCS cold leg recirculation mode. According to UNS-5767 the RSS pumps in the as-tested configuration delivered a combined LHSI/HHSI flow of 5250 gpm. UNS-5767 determined that this flow was great enough to raise a concem about RSS HX tube vibration.

No test has been located which demonstrates that one RSS pump can provide the required 1310 gpm to each train of HHSl for the cold leg recirculation mode of ECCS. No test has been located which demonstrates that one RSS pump can provide the required 2341 gpm to each train of HHSI for the hot leg >

recirculation mode of ECCS.

It is probably true that the flow required to support the combined operation of the HHS! and LHSI flow paths is less than the flow required to support operation of the HHSI alone. However, no such evaluation has been located. This discrepancy should be resolved before DCR 97045 is closed-out.

Documentation of the NPSHa available to the HHSI pumps from the sump /RSS path is addressed in DR-MP3-0712.

Review Valid InveEd Needed Date inettator: wakeiend J. F. O O O $2/is/97 VT Leed: Nat. Anthony A B O O 52ii7/97 VT Mgr: Schopfer, Don K 8 0 O 12/23/97 RC Chmn: Singh, Anand K O O O 5'17/88 Date:

mvAuo:

Date: 3/13/98 RESOLUTION DISPOSITION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0710, does not represent a discrepant condition. The referenced FSAR Notes to Figure 6.3-1 states in the Modes of Operation section that, "ECCS process flow diagrams are provided for illustrative purposes only and are not intended to represent flow rates used in various accident analyses, such flow Printed 3/24/98 2:47;44 PM Page 2 of 4 1

Northeast Utilitico ICAVP DR No. DR-MP3-0710 Millstone Unit 3 Discrepancy Report rates are pmvided in Chapter 15, where appropriate. The process flow diagrams are developed to provide representative l system performance data. This data consists of process flow l data (i.e., pressure, temperature, and flow) and valve alignments for three principal modes of ECCS operation." These listed pressures and temperatures from Figure 6.3-1, are for injection, hotleg and cold leg recirculation modes with the reactor coolant system depressurized, in equilibrium, with the containment pressure at 0 psig. i The values show in Figure 6.3-1 for the RSS pump performance j requirements for the cold leg / hot leg recirculation modes were  !

transmitted to NU by Westinghouse Letter NEU-86-510. Since these flow rates are being changed as a result of the modifications to the RSS System, we did not request Westin0 house to provide the now historical supporting calculation. The new flow rates determined as a result of the modifications to the RSS System were transmitted to NU by Westin0 house Letter NEU-97 327E along with supporting calculation number SAE/FSE-C-NEU-0143. The FSAR Figure 6.3-1 will be updated as part of the design change process, via DCR M3-96077.

The combined operation of the HHSI and LHSl flow paths as demonstrated Dy preoperational test T-3306-P envelopes the operation of the HHSI alone. To document this conservative ,

evaluation would have been des!reable however not required. 1 New performance testing procedures for the RSS pumps have been developed. A preliminary copy of IST 3-97-014, RSS Pump Performance Test," is attached for your review and information.

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

CONCLUSION:

NU has concluded that it'.e issue reported in Discrepancy Report, DR-MP3-0710, does not represent a discrepant condition. The now historical values shown in Figure 6.3-1 for the RSS pump performance requirements for the cold le0/ hot leg recirculation modes of ECCS was provided by Westinghouse Electric Corporation Letter NEU-86-510. The new flow rates determined as a result of the modifications to the RSS System were transmitted to NU by Westinghouse Letter NEU-97-327E along with supporting calculation number SAE/FSE-C-NEU-0143. The combined operation of the HHSI and LHS! flow pruns as demonstrated by preoperational test T-3306-P envelopes the operation of the HHSI alone. New performance testing procedures for the RSS pumps have been developed. A preliminar/ copy of IST 3-97-014, "RSS Pump Performance Test,"is attached.

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

Printed Y24S8 2.474 PM Page 3 of 4

!CAVP DR No. DR-MP3-0710 Northecst Utilities Ministone unM 3 Discrepancy Report l Previously klontlaed by NU7 O Yee (#) No Non Discrepent condition?ft) Yes O No Resolut6onPending?O vos (#3 No pe% Unresolved?O vos @ No Review initiator: Wakeland, J. F.

VT Lead: Nerl, Anthony A VT Mgr: Echopfer, Don K 1RC , ; 'm: Singh, Anand K Date: 3/13/98 st.commente: Sargent & Lundy agrees that DR-MP3-0710 does not identify a descrepant condition: l

1. The analytical basis for RSS system performance data for the cold leg / hot leg recirculation modes of ECCS, identified in FSAR Figure 6.31, was provided by Westinghouse Letter NEU-86-510.

This performance data has been updated for the new configuration created by modifications DCR M3-97045 and DCR MS-96077 in Westinghouse Calculation SAE/FSE-C-NEU-0143 I

(transmitted by Westinghouse Letter NEU-97-327E) and in Stone

& Webster Calculation US(B)-361.

2. The preoperational testing basis for RSS system performance l for the cold leg / hot leg recirculation mode of ECCS for the HHSI-only recirculation path is bounded by the results of Preoperation Test T-3306-P for the combined HHSI/LHSI recirculation paths.

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Printed Y2498 2.47.47 PM Page 4 of 4

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Northeast Utilitie3 ICAVP DR No. DR-MP3-0785 Millstone unM 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System De@n Pdential Opermy h DieciPune: Structors De*"

Diecrepeney Type: Design Control Procedure O v.

g SystemProcess: N/A NRC SigniAcance level: 4 Date faxed to NU-Date Putsehed 1/10/98 Diecrepancy: Design Procedure Discrepancy Ducription: We have reviewed the Millstone Unit 3 - NETM 41(Rev.1, dated May3.1985)

  • Procedure for the Qualification and Cataloguing of the Embedded Plates with Headed Anchors *,

Based upon this review we have noted the following discrepancy:

On page # 7 of the above procedure the constant used in the expression for the tension capacity of the stud is incorrectly shown as follows:

Pue = 0.255 As fy.. .....(ibs).

The corrected constant in the expression should read as:

Pue = 0.225 As fy........(ibs). This is also corroborated in a solved example as shown on page #1 of 8.

Review Valid inveNd Needed Date inmistor: Kleic, N O O O 2/i2/97 VT Lead: Nwl, Anthony A B O O s2/isto7 VT Mgr: Schopfer, Don K O O O 2/23<s7 inc Chmn: Singh, Anand K O O O $2/31/97 Date:

INVAUD:

Date: 3/21/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-0785, 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 concerns and meets the Unit 3 deferral criteria. CR M3-98-0969 has been written to develop and track resolution of this item per RP-4.

Previously identined by NU7 Q vos (9) No Non Discrepent Condition?O vos (#') No Radutk= Penene?O va C*)No R=okmon Unr.wv.d70 va @ No Revie.

Acceptable Not Arrapaahla Needed Date

~

VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Printed 3/24/96 2.57A0 PM Page 1 or 2

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Northert Utilities ICAVP DR No. DR MP3-0785 Millstone Unit 3 Discrepancy Report

-_.. -...~-~"

D D D Date:

SL Comments:

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l Ptwed Y2496 2.57A3 PM Page 2 of 2

Northecst Utilities ICAVP DR No. DR-MP3-0792 milistone Unit 3 Discrepancy Report Review oroup: Syelem DR RESOLUTION ACCEPTED Review Element: system Dengn p

Diecipene: stmenad Desig" Discrepancy Type: Cm O vos

@ No SystemProcess: HVX NRC Signiecencelevel 4 Date faxed to NU:

Date Putdished: 1/17/98 D6ecrepancy: Non-Standard Duct Support Calculation Discrepancy D=cription We have reviewed the Duct Support Calculation no. NP(F)-

Z545D-560,Rev.3.

Based upon this review.we have noted the following discrepancies:

1. On page no.8,the computer model does not correspond to the STRUDL input at joints no. 6,7 and 8.

Also, the 6" eccentricity that accounts for the depth of the member S6x12.5 has not been accounted for in the computer I

model.

2. On page no.15,the ratio fa/Fa = 0.44>0.15. 1 Therefore, Equation 1.6 - 1a or 1.6 - ib (instead of  ;

Equation 1.6 -2 ) shall be used to evaluate stresses in member L 31/2 x 21/2 x 1/4 as required by the AISC,8th edition,page 5-26.

Also, the allowable stresses used to evaluate L 31/2 x 21/2 x 1/4 1 have not been adjusted (reduced) to account for the effect of bending about principal axes.

Review Valid invalid Needed Date initietor: Kleic, N 8 0 0 2/12/97 VT Lead: Neri, Anthony A g Q ] 12/16/97 VT Mor: Schopfer, Don K 8 O O 12r23/97 IRC Chmn: Singh, Anand K B D D 1/13/S8 1

Dete:

INVALID:

Date: 3/17/98 RESOLUTION NU has concluded that Discrepancy Report, DR-MP3-0792, has i identified a condition not previously discovered by NU which l requires correction. This discrepancy meets the criteria specified l in NRC letter B16901 and 17010. It has been screened per U3 PI- l 20 criteria and found to have no operability or reportability i concems and meets the Unit 3 deferral criteria. CR M3-98-0967 has been written to develop and track resolution of this item per RP-4.

Previously identined by NU? O Yes @ No Non Discrepent Condition?O Yes @ No PM%Pending?O va @ No ReestionUnrn&ed?O va @ No Review I F-- ;' ' ' - Not AccardaMa Needed Date VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K Printed 3/24/96 2:58:10 PM Page 1 of 2 l

N:rthenct Utilities ICAVP DR Ns. DR-MP3-0792 Millstone Unit 3 Discrepancy Report IRC Civnn: Singh, Anand K O O *1 m O O O Date:

SL Comments.

1 Printed 3/2W 2:58:14 PM Py2d2

i DR No. DR-MP3-0856 i Northe:st Utilities ICAVP Millstone Unit 3 Discrepancy Report 1 Review Group: System DR RESOLLmoN ACCEPTED Potential tditty issue E4 ;-- y Type: Design Control Procedure e No SystemProcess: SWP NRC SZ"we level: NA Date faxed to NU:

Date Putdished: 1/22/98 Dicropency: PDCR 3-94-094 Design Control Discrepancies

Description:

PDCR 3-94-094, which involved changeout of pump intemals and coating of intemal surfaces with Arcor for 3 SWP *Plc and '

D, plus deactivation of lube water to the bearings of 3SWP*PIB, C, and D, was reviewed and the following discrepancies noted.

1. The mod package originally fumished by NU in response to RFI # 159 was incomplete, consisting only of Form A [one page]

Form B [ thirteen pages] and a one page attachment addressing

" Retest Requirements Discussion." During a trip to Millstone to

]

j complete reviews of mod packages, including 3-94-004, it was

]

found that PDCR 3-94-094 had been checked out of the controlled library. In response to S&L's subsequent request for -

the complete mod package, NU indicated that "it could not be I located in Nuclear Records and therefore was not available"- ]

[see IRF 01193 in response to RFI MP3-793). Despite the limited content of the package, the review was completed and additional discrepancies noted as follows.  ;

2. Section 5 of Form B," Detailed Evaluations / Reviews," ,

indicated that detailed reviews had been completed and attached to the PDCR for Fire protection, Seismic Qualification, Electrical /l&C, Control Panel, and Mechanical Systems, however none of these five items were included in the package.

3. Section 7 of Form B," Safety Evaluations," indicated that a Safety Evaluation had been completed and attached, however none was included with the package.
4. No work orders or procedures for controlling the work were j referenced in the PDCR for implementation, however an uncontrolled report fumished by NU allowed retrieval of 15 AWOs that were issued and closed out implementing the change. These AWOs contained adequate references to procedures for proper control of the work activities.
5. The changeout of pump intemals requires that each pump be physically removed from the pump house and taken to the shop where it is disassembled and reassembled. This involves removal and replacement of concrete hatches in the roof of the pump house which results in breaching of a vital area barrier.

This was not addressed in the PDCR.

6. Section 15 of Form B, " Requirements Prior to Operation,"  !

Indicated that Redlining of Operations Critical Drawings, Update ,

of Process Computer Alarm (s), and New, Revised or Changed Procedures were required prior to retuming to operation after

% gg 'n=~;^r '!:n Of the PDCP.,50;;;/07 'h0 0 " 00 n0 !^d!='f04tg 3 j

Northeast Utilities ICAVP DR No. DR-MP3 4866 Millstone Unit 3 Discrepancy Report these items had been completed, and no identification of the affected drawings, alarms, or procedures was included to allow confirmation.

7. Section 17 of Form B "ltems Required to be Completed Prior to PDCR Closeout," indicated that PMMS Data Sheets,  ;

Technical / Maintenance / Operations Manuals, Spare Parts Lists, (

DCNS, and New, Revised, or Changed Procedures were )

required. Several DCN numbers were included and verified as part of the revie* e. The other requirements did not include any specific references which could be verified. In addition, under item 17F, CCN Number 11 to Nusco Calc. NL-025 was referenced as required prior to closeout; however this calculation could not be located as it is not listed in the NU Calculation j Database. j Review Valid invalid Needed Date initiator: Tonwinkel, J. L 6 O O 2/22/93 VT t.ead: Nei, Anthony A B O O i2t20/97 VT Mgr: Schopfer, Don K O O O 2t22s7 IRC Chmn: Singh, Anand K O O O 7/S8 1 Date:

WVAUD: l Date: 3/j7/98 NEsoLUTioN: Disposition:

NU has concluded that the issue reported in Discrepancy Report.

DR-MP3-0856, does not represent a discrepant condition.

The PDCR has not yet been closed out and was checked out of the library by the Engineer responsible for the design.

The PDCR contains the items identified in the discrepancy report as listed below:

Item 2: Fire protection, Seismic Qualification, Electrical /l&C, Control Panel and Mechanical Systems reviews, item 3: Safety Evaluation, item 4: Woric orders are listed in Form I, item 5: Removal of concrete hatches are addressed in the Security Evaluation, 3

Item 6: Documentation and drawings required prior to operation are detailed in Section 15, Form H and Form I, item 7: Calculation NL-025 is retrievable from the controlled Hbrary and listed on Passport.

l 1

Because the PDCR close out is still in progress, an "Information Copy" of the open PDCR is included with this ICAVP Response Form.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR MP3-0856, does not represent a discrepant condition.

Printed 3/24@6 2.58:47 PM Page 2 of 3

)

Northe:st Utilities ICAVP DR No. DR-MP34856 Millstone Unit 3 Discrepancy Report The PDCR has not yet been closed out and was checked out of the library by the Engineer responsible for the design. An "Information Copy" of the open PDCR containing the items listed {

in the discrepancy report is included with this ICAVP Response Form.

Previousey identified by NU7 O Yes (@ No Non D6ecrepent Condition?(O') Yes O No Resolution Pending70 Y= @ No R unonunr ev.d70 Yu @ No Rev6ew initiator: TerwMkel, J. L.

VT Lead: Nort, Anthony A O O Me VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K O mm Date: 3/j7/93

]

st Comments: The items fumished by NU along with the above Disposition satisfactorily resolve the issues raised in the DR. Further, these items were in place prior to the 5/27/97 cutoff date for ICAVP review of SWP. Therefore this item is adequately closed, and the discrepant condition has been eliminated i

1 i

Printed 3"24/98 2M40 PM Page 3 of 3

DR N;. DR-MP3-0931 Northe:st Utilities ICAVP Milistone Unit 3 Discrepancy Report Review Group: Configurahon DR RESOLUTION ACCEPTED Potential Operstditty issue Discipline: Electrical Design Discrepancy Type: Installation implementation Om (G) No SystenVProcese: DGX NRC Significance level: 4 Date Faxed to NU:

Date Putdished: 1/25/98 Discrepancy: Conduit Supports not in accordance with design documents

Description:

Standard Seismic Conduit Support criteria are included in the 12179-BE-52 Series drawings. These drawings include allowable spans (i.e., the distance to the next support) for conduits. Contrary to the requirements of these standards, the following anomalies were observed during system walkdowns.

1. Conduit 3CX9260C has a span of 8 ft. to adjacent supports from that shown on Conduit Support Log 121790-FSK-DG042, Rev. 4. This is greater than the allowed span for any conduit in any location.
2. Conduits 3CX9500Q (identified as OC on CSL) and 3CX9500N4 are attached to support CB-1541 as shown on Conduit Support Log 12179-FSK-1541. The span to adjacent supports for these conduits exceed the allowable as specific on drawing BE-52AN, Rev. 5.
3. Conduit 3CX449NX3 is listed on Conduit Support log 12179-FSK-DG-129, Rev. 4A, as attached to the support. This conduit is not attached and as a result its span of greater than 7 feet 4 inches exceeds the allowable.
4. Conduit Support Log 12179-FSK-CB-555, Rev. 8, in Section 1 shows all conduits attached to the top of the horizontal members. This is not accurate; all condalits attached to the B member are below as is 2 of the 4 on the D member.
5. 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 span"). With respect to these requirements, the following field conditions were noted: Conduit 3CX9260G5 has a rigid back span of 4 feet 10 inches; Conduit 3CX9260A has a rigid back span of 4 feet-5 inches.

6. Conduit support log 12179-FSK-DG490, Rev. 4 shows two conduits for the support in section 1. only one conduit is listed as attached and field observations revealed only one conduit attached.

Review Valid invalid Needed Date initiator: Server, T. L 0 0 0 1'15/98 VT Lead: Nerl. Anthony A O

@ Q 1/16/98 VT Mgr: schopfer, Don K O O O '1S'S8 Printed 3/24/98 2:59:20 PM Page 1 of 4 m

Northeast Utilities ICAVP DR No. DR-MP3 0931 utsestone unit 3 Discrepancy Report unc chmn: singh, Anand K O O O si22ise este:

INVAUD:

Date: 3/21/98 RESOLUTION. Disposition:NU has concluded that Discrepancy Report, DR-MP3-0931, has identified three concems, (items 2, 3 and 6) that represent discrepent conditions not previously discovered by NU which require correction. CR M3-98-0712 has been written to develop the corrective actions associated with these items. NU l has concluded that 3 items, (items 1,4 and 5) do not represent i discrepent conditions.

The Description for this DR states that Standard Support Detail  ;

Drawings (12179-BE 52 Series Drawings) provide the criteria and general installation notes for conduit supports. The DR lists 6 flems observed as conduits which seem to exceed the allowable span criteria, or other BE-52 criteria.

NU concludes that discrepancy report DR-MP-0931 has identified items 2,3, & 6 of DR-MP3-0931 as three conditions not previously discovered that require correction. CR M3 0712 has been written to develop the corrective actions associated with these items.

The Corrective Action items will be completed after restart.

Field modification will be required to add conduit clamps to conduit 3CX449NX3 on supports DG-128 and DG-129, and add ID labels to conduits 3CX95000 and 3CX449NX3. In all cases, as noted below, the existing supports are considered adequate as is in meeting their licensing and design basis, and the remaining items are administrative in nature, NU considers this DR to be a Significance Level 4 Resolution to item 2:

This item states conduits 3CX9500Q (identified as OC on the CSL) and 3CX9500N4 are attached to support CB-1541 as shown on CSL 12179-FSK-CB-1541. The span to adjacent supports for these conduits exceeds the allowable as specified on drawing BE 52AN, Rev. 5.

From the information provided in item 2, it was not specified, and, without waliting down the entire conduit, can not be determined where the overspan is located. An extensive review of the conduit and conduit support drawings, including change paper issued aGainst those drawings, indicated that the conduit support loads are below the max allowable and are acceptable, and did not produce any instances where the span exceeded the 8'-0* allowed by BE-52AN. Initial field observations indicate that i the supports are installed at the locations ori0inally specified by the design drawings, as noted above, and if the span criteria is exceeded, it is very minor in nature and considered acceptable.

A walkdown of conduit 3CX9500C will be performed to determine any puesible overspen condition, and document the results and update drawings, if necessary.

(Note, there is a discrepancy on the callout of conduits 3CX9500Q and 3CX9500N4. Support CSL CB-1541 lists l 3CX9500C and 3CX9500N 3CX9500C is field verified to be i_ _ _ ._._ v_ _ _vown_ ._e e_ n_ _ m_ . , h__ o_e_ v_ ._,.h._ , ,4m n _ ._, e n_ _

1 I

l Northeast Utilities ICAVP DR No. DR-MP3-0931 Millstone Unit 3 Discrepancy Report 1107 and CB-1108, the conduit is correctly labeled as 3CX95000. Also, conduit 3CX9500N4, as stated in this item, does not exist in TSO2 and is assumed to be 3CX9500N, which, as noted above, is listed on CSL CB-1541).

An Administrative DCN will be issued to update One-Line j drawing for 3CX9500C to reflect "To: 3JB*4300* in the Heading .

and on the Plan View and document any possible minor  ;

overspan conditions found during final field walkdown.Also, Trouble Report No.16M3154933 has been issued to remove the incorrect label '3CX9500Q' and correctly label the conduit 3CX9500C near CSL CB-1541.

Resolution to item 3:

This item states conduit 3CX449NX3 is listed on CSL 12179-FSK-DG-129, Rev 4a, as attached to the support. This conduit is not attached and as a result its' span of greater than 7'-4" exceeds the allowable.

For item 3, a field walkdown indicates that conduit 3CX449NX3 4 is not attached to supports DG-129 or DG-128, resulting in a span of 7'-4', exceeding the allowable span for seismic conduits. j lt is, however, attached to two unscheduled supports, one on either side of supports DG-129 and DG-128. This is a non-QA conduit, and has a max allowable span of 8'-0*. In addition, it was evaluated and accepted as meeting the 2 over 1 criteria as installed on its' existing supports. However, to be in compliance with drawings DG-129 and DG 128, clamps will be added to conduit 3CX449NX3 as shown on the two supports.

In addition, there is no label on conduit 3CX449NX3 where it enters box 3 COP-AMP 852.

Trouble Report No.16M3155436 has been issued to add a label to the middle conduit coming from Box 3 COP-AMP 852 to indicate it is *3CX449NX3* and to add missing Conduit Clamps to conduit 3CX449NX3 on supports CSL DG-129 and DG-128, as shown on drawings 12179-FSK-DG-129 and DG-128.

Resolution to item 6:

This item states the Conduit Support Log (CSL) shown on FSK.

DG-490, Rev 4, shows two conduits in Section 1-1. Only one conduit is listed as attached and field observations revealed only one conduit attached.

Item 6, is a drawing clarification. In the Revision Block for Rev.

3, it is noted that a conduit has been removed, and there is a circled area on the drawing indicating a conduit had been removed. Section 1-1 should have been updated to show this conduit as being removed. The Cable and Raceway Program also correctly indicates only one conduit is attached to this support. Drawing DG-490 will be corrected to show only one conduit in Section 1-1.

l l

NU has concluded that the issues reported in items 1,4, & 5 in I discrepancy Report DR-MP3-0931 do not represent discrepant l conditions.

l l

Resolution to item 1- '

This item states conduit 3CX9260C shown on FSK-DG-042. i Printed 3/2496 2:59:25 PM Pa0e 3 of 4

Northe:st Utilities ICAVP DR No. DR-MP3-0931 Millstone Unit 3 Discrepancy Report .

Rev. 4, has a span 8'-0", exceeding the allowable span for any conduit in any area.

For item 1, DG-042 is supported by a Steel Attachment per Detail BE 52FY. Per General Note 3 on BE-52AN, the maximum allowable span between supports is 8'-0", except for support details shown on BE-52CD thru BE-52DZ. Since this detail is BE-52FY, the 8'-0* criteria is applicable.

Resolution to item 4: l This item states all conduits shown on FSK-CB-555, Rev. 8 indicate they are attached to the top of the horizontal members.

This is not accurate, all conduits attached to B member are below as are 2 of the 4 on D member.

For item 4, a review of the documents listed on drawing 12179-FSK-CB-555 reveals N & D 10287 accurately depicts the conduit locations on the horizontal members and are as stated in this DR.

Resolution to item 5: l This item references Note 65 on BE-52AS as a basis for rigid back span of supports utilizing Flex type conduit in mid-run.

Conduit 3CX9260G5 has a rigid back span of 4'-10" and conduit 3CX9260A has a rigid back span of 4'-5*.

For item 5, the wrong General Note is used as a basis for the span of supports when flex conduit is used in mid-run. The only time Note 65 is applicable is when 3/4" ANACONDA Flex conduit is substituted for 3/4* BOA Flex. In this case the two conduits listed are 2' Aluminum and are subject to the criteria given in General Note 39 on BE-52AQ, which do not give restrictions on the next support other than it has to be within the general span criteria for the support type (i.e. Direct Concrete Attachment or others).

Previously identiaed by NU? O vos (#) No Non Discrepent Condition?O vos (*) No Resolution Pending?O ve. @ No Re.osution unre.oev.d?O yes @ No Review inMiator: Kleic. N VT Lead: Neri, Anthony A O 2*

VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 3/10/98 st Comments:

Printed 3/2496 2:59:26 PM Page 4 of 4

ICAVP DR N3. DR-MP3-0961 Northerst Utilities Millstone Unit 3 Discrepancy Report i

Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mehenical Dwign O vee Discrepancy Type: CN

(#)No System / Process: NEW ,

NRC Significance level: 4 Date faxed to NU:

Date Published: 2/7/96 D6screpancy: Calculation CRS-MOV-1382M3 Ducription: Calculation CRS-MOV-1382M3 [Rev. 0; CCN 1] documents the conditions, pressure, temperature, flow, etc., for the RSS System MOVs. These conditions are used in the torque and thrust calculations.

DCR 97045 installed an orifice at the RSS pump discharge to reduce the system flow rate. The hydraulic analysis for RSS System operation was performed by Calculation US(B)-361.

CCN 1 of Calculation CRS-MOV 1382M3 incorporated the revised flow rates and references for RSS Valves MOV20 MOV23 and MOV 38.

The flow rates and references for Valves MOV8837 and MOV8838 were not revised by the CCN. Calculation US(B)-361 determines higher ECCS flow rates through these valves (Non-Conservative). The current basis for the valve flow rates is Calculation US(B)-245, Section 5. Section 5 was deleted by CCN 3 of Calculation US(B)-245.

Review Valid invalid Needed Date initiator: Langel.D. O O O 2/2/9e VT Lead: Nort. Anthony A B O O 2/2/98 VT Mgr: Schoper, Don K O O O 2/2/98 O 2/3/98 IRC Chmn: Singh. Anand K O O Date:

INVALID:

Date: 3/20/98 RESOLUTION Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0961, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0725 (attached) will revise calculation CRS-MOV-1382M3 to incorporate the correct higher value of flow.

The effect of the flow increase is to increase the stem pressure, I which is in the non-conservative direction. In order to determine valve operability, a computer computation (EPRI PPM) was performed for MOV8837 and MOV883810 evaluate the effect on tho valve of the higher value of flow. The value used was the I highest value for flow contained in the draft copy of US(B)-361.

This value,1553 gpm, is 6% greater than the value previously used,1465 gpm. The results of this computation show an increase of one pound in the closing stem pressure. The stem Printed 3f24/96 3.00:12 PM Page 1 of 2

Northecst Utilities ICAVP DR No. DR-MP3-0961 Millstone Unit 3 Discrepancy Report pressure is currently shown as 13,074 pounds. The increased flow rate will be incorporated in the next CCN to Calculation CRS-MOV-13282M3. Other changes have occurred since the orl0inal valve calculation was performed. The effect of each change is computed, and if the result has a conservative effect, the overall calculation is not re-performed. These changes include a change in gear ratio and a change in stem design.

Presently these changes are calculated to result in a reduction in stem pressure of over 400 pounds. When combined with the effect of the increased flow, the net effect will be a reduction in the closing stem pressure, which is in the conservative direction.

In the opening direction, the increased flow does not affect the maximum stem pressure. Thus no adverse condition exists in either the opening or closing mode of valve operation. The cause of the error, the failure to update the value of flow, was an incomplete cross reference between calculations. Both calculations, US(B)-361 and CRS-MOV 1382M3, will be revised to correct their discrepant condition. Their revision is not needed to support system operability because the new value of valve I stem pressure will be less than the previously analyzed value of j pressure. As such there is no effect on the license or design i basis, therefore NU has concluded this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0961, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0725 (attached) will revise calculation CRS-MOV-1382M3 (and the cross reference with US(B)-361). The correct value for maximum flow through the valve will be used. The effect on the valve due to the flow increase is non-conservative, but is more than offset by other i changes that have occurred since the reference calculation was performed. These changes include a change to the gear ratio.

The end result is a reduction in the force exerted on the valve l stem. As such there is no effect on the license or design ba:Is, therefore NU has concluded this to be a Significance Level 4 issue. 4 Prevlously identined by NU7 O vos (9) No Non D6ecrepent Condition?O vos (#') No Resolution Pending?O vos @ No P*iaq Unresolved 70 vos @ No l Review inillotor: Langel, D.

VT Leed: Neri, Anthony A VT Mgr: schopfer, Don K O m RC Chmn: singh, Anand K Date: 3/19/98 st Comments: The flow change is insignificant to the calculations. The action plan for the CR is acceptable.

Printed 3GN98 3:00:15 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0988 f

Millstone Unit 3 Discrepancy Report Review Group: Syelem DR RESOLUTION ACCEPTED Review Element: system Design PotentialOperatWity issue Discipline: Mechanical Design Discrepancy Type: Calculanon O v.e No SystenVProcess: NEW

  1. Date faxed to NU:

Date Published: 1/29/98 Diecrepancy: Revision of Calculation US(B)-1186 for DCR MP3-97045 D*ecription: The purpose of calculation US(B)-1186, Rev. 2 is to determine the RSS design pressure and temperature.

Four discrepancies were identified in US(B)-1186, Rev. 2:

1. The RSS pump suction nozzle elevation of (-)29'-8" is incorrectly used to compute the design pressure for RSS suction piping. The correct elevation to use is the lowest point in the suction piping, centerline elevation (-)32'-3". This error reduces the maximum suction pressure by 2'-7" (1.1 psi). The design pressure for the RSS suction piping should be 49.9 psig. The lowest part of the RSS system exposed to RWST submerDence pressure are RSS pump de-watering lines 3-RSS-150-43,51,84 and 87. Drawing EP-79N, Rev. 8 indicates that the minimum elevation for these lines is (-)49'-5" - which implies that the maximum pressure which could occur on the suction side of the RSS pumps is 57.3 psig (as computed on p. 8).
2. Calculation US(B)-362, Rev. O is incorrectly referenced for l the maximum post accident sump level, elevation (-)11'-3", The  !

correct reference is calculation US(B)-249, Rev. 3/CCN 1 - I I

which determines that if all of the water inventory of the RCS and the RWST were released onto the containment floor, it l would reach elevation (-)11'-3".

3. Calculation US(B)-362, Rev. O is referenced for a maximum i post-accident sump water temperature of 193F (pp. 6, 9,11 &

13). However, this is the maximum sump water temperature only for one scenario: 4" LOCA in Cubicie D with failure of 1 QSS pump (Table 11d of US(B)-362). Calculation US(B)-362 identifies two PSDER scenarios for which the maximum sump water temperature is greater than 211F (Tables 11a and lib of US(B)-

362). Furthermore Table 5 of US(B)-352, Rev. 0/CCN1 Indicates that the peak sump water temperature for the worst-case LOCA is 258F.

4. No basis is provided for the maximum temperature of 260F and the maximum pmssure of 227 psig identified in the calculation summary, p. 6.

Review Valid invalid Needed Date initiator: Wakelend. J. F. O O O 1r22/98 VT Lead: Nerl. Anthony A G O O 1/2i/98 VT Mgr: schopfer, Don K S O O 1/22/96 IRC Chmn: singh. Anand K O O i23se O

Printed 3/24/96 3:00.44 PM Page 1 of 2

NortheIt Utilities ICAVP DR No. DR-MP3-0988 Millstone Unit 3 Discrepancy Report Date:

INVALID:

Dele: 3/17/98 RESOLUTION: DISPOSITION:

NU has concluded that Discrepancy Report, DR MP3-0988, has identified a condition not previously discovered by NU which requires correction. A CCN will be initiated to correct the discrepancies in calculation P(R)-1186 after startup in accordance with the corrective action plan for CR M3-98-0588.

Specifically, the first discrepancy identifies a lower piping elevation which should be used to determine the maximum suction piping pressure. However, even accounting for the lower piping loop, the piping design pressure remains 60 psig. The second discrepancy notes that an incorrect reference is provided for the post accident sump level, but the correct sump level elevation was used in the calculation. The third discrepancy identified additional post accident scenarios which increased the maximum sump water temperature to 258 F. This temperature is bounded by the design temperature of 260F. The last discrepancy noted that no basis were provided for the maximum pressure and temperature identified in the calculation summary.

These references will be provided. The four discrepancies have i no impact on the conclusions of the calculation. The Significance Level is concluded to be Level 4.

CONCLUSION:

NU has concluded that Discrepancy Report, DR-MP3-0988, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-96-0588 will correct the calculation after startup. The Significance Level is concluded to be Level 4 since there is no impact on the calculation conclusions.

Previously identHied by Nu? O vos (#) No Non D6ecrepent Condition?O vee (#) No Resolution Pending70 vos (3) No neeosutionunresoeved70 vos @ No Review initletor: Waketend, J. F.

VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K IRc chmn: Singh, Anand K Date: 3/17/98 st commente: Sargent & Lundy agrees that the NRC Significance Level of DR-MP3-0988 should be downgraded to Level 4. DR-MP3-0988 identifies discrepancies in documentation which do not impact the design basis requirements of the RSS system. l Sargent & Lundy concurs that the corrective action plan of CR 98-0588 (AR 98002724-02) will resolve DR-MP3-0988 items 1 through 4 and Sargent & Lundy concurs that the corrective action may be deferred until after Unit 3 restart.

Printed 3r2W96 3.00A6 PM Page 2 or 2

l Northeast Utilities ICAVP DR No. DR-MP3-1014 Millstone Unit 3 Discrepancy Report  ;

Review Group: system DR RESOUITION ACCEPTED Review Element: Syelem Design ,

Diecipline: I & C Design Discrepancy Type: ceiculouan g

SystemProcess: NEW O No NRC Significance level: 4 Date faxed to NU' Date Putnished: 2/1/98 l

Diecrepancy: Incorrect methodology and use of inputs for calculation SP-3RSS-3, Rev.1 Description. The stated purpose of Revision 1 of calculation SP-3RSS-3 is to determine the new low pressure alarm setpoints for pressure switches 3RSS-PS43A/B/C/D based upon the implementation of design modification DCR M3-97045 which reduces the flow rate l through the RSS pumps by installing a flow reducing orifice plate l In the discharge line of each pump. SP-3RSS-3 Rev.1 incorrectly calculates the probable errors (uncertainties) associated with the pressure sensing instrument loop configuration; therefore, the Total System Normal Channel  ;

Uncertainty is incorrect. l The stated premise that the calculation " demonstrates that the overall loop inaccuracies will not exceed 15% of the discharDe pressure"is based upon a non-conservative assumption about the amount of air that may become trapped in each pressure transmitter sense line when the respective RSS pumps are started. A calculation that considers the minimum and maximum possible air entrapment demonstrates that for a ,

desired process setpoint of 79.6 psig (dec), the pressure "seen" by the transmitter will lie between 65.6 psig (vertical portion of sense line full of water) and 79.6 psig (vertical portion of sense j line void of water). And, including the probable channel instrumentation errors, the actual process pressure will lie between 59.1 and 86.1 psig when the low pressure alarm is actuated. A pump discharge pressure of 59.1 psig is 37% below the design pump discharge pressure which is greater than the 15% design value. An aNemative means to reduce this error may be necessary to achieve the design intent.

Review Valid invenid Needed Date initiator: Reed. William. G 0 2/2/98 VTL.eed: Nwl. Anthony A 8 0 0 2/2/98 VT Mgr: schoper, Don K G O O 2/2/98 IRC Chmn: Singh, Anand K G O O 2/3/98 Date:

INVAUD:

Date: 3/23/98 resol.UTION Disposition:

NU has concluded that Discrepancy Report, DR-MP3-1014, has identified a condition not previously discovered by NU which requires correction. The issue raised by this DR is that calculation SP-3RSS-3 incorrectly calculates the probable errors Printed 3/24/98 3:01:18 PM Page 1 of 6

Northeast Utilities ICAVP DR No. DR MP3-1014 Millstone Unit 3 Discrepancy Report

. associated with the amount of air that may become trapped in each pressure transmitter sense line when the respective RSS pumps are started, thereby exceeding the 15 % overall loop inaccuracy as stated in the purpose of this calculation.

To compensate for the elevation difference between transmitters and the discharge pipe, the transmitter zero adjustment is suppressed by 14 psig. This accounts for the head correction when the sensing lines are filled with water and void of air. The l concem arises from the fact that the RSS system is a normally I dry system that causes the pressure transmitter's impulse lines to drain and when the system starts air in the sensing lines is then trapped and compressed replacing the expected water column. This results in a sufficient shift of the setpoint due to the reduction in the required head correction for these transmitters thereby, causing the pressure switches to actuate at a lower system pressure. The subject calculation considered this effect as a bias term that was added to the random errors to determine the upper and lower limits of the instrument accuracy range to ensure that the overall loop inaccuracles do not exceed 15%.

During the review of the subject calculation it was determined  !

that the calculation contained several discrepancies. CR M3  !

0710 was initiated to document these discrepancies associated )

with the method used to determine the amount of trapped air in 4 the sensing lines and the application of the bias term. The following provides an attemative method of determining the effects of the trapped air on the setpoint uncertainty calculation. l l

This altemative method determined that the overall loop Inaccuracy was 11.95 % which is less than 15% therefore, the objective of calculation 12179-SP-3RSS-3, Rev.1 has been meet.

Tubing OD = 1/2 From Drawing No.12179-EK-526016 i 1/2 - lCN - 9 instrument tubing has a wall thickness of 0.065*

From MS12179-424E Tubing ID = 0.5 - 2

  • 0.065 = 0.370 inches d2 = (0.5 - 2
  • 0.065)^2 = 0.1369 inches ^2 Pi / 4 = 0.7854 Volume from Tee to 3RSS-PT45D (Values Obtained from )

Drawing No.12179-EK-526016)

Feet Inches Elev Chan0e(a) adjacent (b) Total Length l

  • " 1 4 0.625 16.000 16.012 6.5 6.500 6.500 1 3.25 15.250 15.250
  • " x = (a^2 + b^2)^0.5 used to determine the hypotenuse length (graptucincluded on hardcopy)

Elevation change from Tee to 3RSS-PT45D = 22.3750 inches Tube Length from Tee to 3RSS-PT45D = 37.762 inches VT-PT45D = (Pi / 4)

  • d^2
  • h = 0.7854
  • 0.1369 inches ^2
  • 37.762 inches = 4.060 inches ^3 Printed 3f2496 3.o1:19 PM Page 2 of 6

I Northert Utilitica ICAVP DR No. DR-MP3-1014 Millstone Unit 3 Discrepancy Report Volume from Tee to 3RSS-PT25D (Values Obtained from Drawing No.12179-EK-526016)

Feet Inches Elev Change adjacent Total Length 7.4375 7.438 7.438 1 3.25 15.250 15.250 Elevation change from Tee to 3RSS-PT25D = 22.688 inches Tube Length from Tee to 3RSS-PT25D = 22.688 inches VT-PT25D = (Pl / 4)

  • d^2
  • h = 0.7854
  • 0.1369 inches ^2
  • 22.688 inches = 2.439 inches ^3 Volume from Tee to 3RSS-PT25D and 3RSS-PT45D VAbove-Tee = VT-PT45D + VT-PT25D = 4.060 inches ^3 + l' 2.439 inches ^3 = 6.499 inches ^3 Total Tubing Volume:

Process tap to Common Tee:

Feet Inches Elev Change (s) adjacent (b) Total Length 2 7.25 0.000 31.250 1 8.50 20.500 20.500 3.00 3.000 3.000

"* 2 7.75 2.000 31.750 31.813 1 12.000 12.000 3 2.875 38.875 38.875 3 10.25 46.250 46.250 4 1.875 49.875 49.875 4 48.000 48.000 4 0.25 48.250 48.250 6.75 6.750 6.750

      • 4 9.50 11.875 57.500 58.713 1 4.00 16.000 16.000 3 8.975 44.975 44.975 5.8125 5.813 5.813 4.125 4.000 4.125 5.746 l 6.00 6.000 6.000 l 1

Length from Process Tap to Tee = 364.163 inches From Connecting Tee to 3RSS-PT45D Feet Inches Elev Change (a) adjacent (b) Total Length 1 4.0 0.625 16.000 16.012 I 6.5 6.500 6.500 1 3.25 15.250 15.250 From Connecting Tee to 3RSS*PT25D Feet inches Elev Change (a) adjacent (b) Total Length 7.4375 7.438 7.438 1 3.25 15.250 15.250

  • Not included in the Elev. Chanoe since it is paralleled with Printed 3'2N96 3.0120 PM Page 3 of 6

Northeast Utilities ICAVP DR No. DR MP3-1014 Millstone unit 3 Discrepancy Report 3RSS*PT25D

      • x = (a^2 + b^2)^0.5 used to determine the hypotenuse length (graphic included on hardcopy)

Total Elevation Change:

ht = 386.85 Note: There is a 3/4 inch difference between using the elevation on the EK drawing vs the elevation changes when the rise of instrument tubing is added up.

Vsensing Line = (Pi / 4)

  • da2
  • Total Length

= 0.7854

  • 0.1369 inches ^2
  • 534.259 inches =

57.444 inches ^3 P1

  • Vsensing Line = P2
  • V2 P1 = 14.7 PSI Assume tubing is dry and at 1 ATM pressure when the system is drained.

Vsensing Line = 57.444 inches ^3 Total volume of the sensing line when dry P2 = 79.6 PSI The desired Process Alarm Setpoint V2 = Unknown The sensing line volume at the desired setpoint V2 = (P1

  • Vsensing Line) / P2 = (14.7 PSI
  • 57.444 inches ^3) / I 79.6 PSI = 10.608 inches ^3 Common tubing (from process tap to Tee) Volume: )

Vc = V2 - VAbove-Tee = 10.608 inches"3 - 6.499 inches ^3 =  ;

4.109 inches ^3 Height of air column in the common sensing line:

h = Vc / ((Pi / 4)

  • d^2) = 4.109 inches ^3 / (0.7854
  • 0.1369 inches ^2 ) = 38.219 inches The air column extends 38.219 inches below the Tee at the desired setpoint Water column at desired setpoint with a column of air: I We = hProcess-Tap-to-Tee - hair-column = 364.163 inches -

38.219 inches = 325.944 inches Head correction when both 3RSS-PT45D and 3RSS*PT25D have been vented:

Headvented = ht / 27.7 inches /PSIG = 386.85 inches / 27.7 inches /PSIG = 13.966 PSIG '

Headvented = 14 PSIG (approx.)  :

Note: Calibration of the transmitter zero shifts to compensate for the head correction by 14 PSIG therefore, this value will be used to determine the error.

Head correction when 3RSS-PT45D and 3RSS*PT25D has not Printed 3/24S6 3:01:21 PM Pop 4 of 6

1 I

Northeast Utilities ICAVP DR No. DR-MP3-1014 Millstone Unit 3 Discrepancy Report l

been vented:

Headnot-vented = ht / 27.7 inches /PSIG = 325.944 inches / 27.7 inches /PSIG = 11.767 PSIG Error due to Water Column:

Error = Wo4esired - Wc-acutal = 386.850 inches - 325.944 inches = 60.906 inches Error = Headvented - Headnot vented = 14 PSIG - 11.767 PSIG

= 2.233 PSIG in terms of PSI Error = 2.233 PSI / 300 PSI = 0.7443 % in terms of % span Totalloop erroris given by:

Note: Assumption that the uncertainties that are not associated with the trapped air in sensing lines are correct.

[ (( 0.477)^2 + (( 0.3)^2 + (( 0.49)^2 + ((2.3)^2 + ((0.087)^2 +

((0.194)2 ]^0.5 Term is obtained from Calculation 12179-SP- 4 3RSS-3 Rev.1. I Positive uncertainties = +[(( 0.477)^2 + (( 0.3)^2 + (( 0.49)^2 + '

((2.3)^2 + ((0.087)^2 + ((0.194)2 ]^0.5 + (0.7443 % )

= + 3.172 %

= + 9.52 PSIG Negative uncertainties = -[ (( 0.477)^2 + (( 0.3)^2 + (( 0.49)^2 +

((2.3)^2 + ((0.087)^2 + ((0.194)2 ]^0.5

= - 2.428 %

= - 7.28 PSIG Desired Process Alarm Setpoint = 79.6 PSIG Upper Limit of Instrument Accuracy Range = 79.6 PSIG + 9.515 PSIG = 89.12 PSIG Lower Limit of Instrument Accuracy Range = 79.6 PSIG - 7.28 PSIG = 72.32 PSIG Maximum % Loop Error = (9.515 PSIG / 79.6 PSIG)

  • 100 =

11.95 %

The overall loop inaccuracies determine to be 11.95 % which is I less then 15% therefore, the conclusion of calculation 12179-SP- l 3RSS-3 Rev i has been meet. The approved correction action I plan for CR M3-98 710 will revise calculation SP-3RSS-3 post  !

startup. Based on the conclusion of calculation SP-3RSS-3 l remaining valid, NU considers this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-1014, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-96-0710 will correct the methodology used for determining the amount of trapped air in the sensing lines and the application of the bias term. The stated premise and conclusion for calculation 12179-SP-3RSS-3. Rev.1 remains unchanoed and Prtreed 3/2&96 3 01:22 PM Page 5 of 6

Northe:st Utilities ICAVP DR No. DR-MP3-1014 Mmstone unM 3 Discrepancy Report the overallloop inaccuracies do not exceed 15% of the l discharge pressure for the desired setpoint, NU has concluded that Discrepancy Report, DR-MP3-1014, is not a Significance Level 3 Discrepancy and should be downgraded to Significance Level 4.

Previously ident6 fled by NU? U vos (8) No NonDescrepentCondit6on?C) vos (S) No Resolution Pending?O vos @ no p-=% unresoeved?O v @ u.

, , , , , , _ . -- not w - us.d.o Deie VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K O O O Date: 3/23/98 st Comments: S&L finds NU's resolution acceptable. In light of the analysis provided by NU in their response, this DR should be downgraded to a Significance Level 4.

1 Printed lV2W96 3.0123 PM Page 6 of 6

Northeact Utilitieo ICAVP DR No. DR-MP3-1025 millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: ConedNo Action Process p

Diecipline: Mechanical Design Discrepancy Type: CorrectNo Action implementation Om SystemProcese: SWP gg NRC S:;;nt- .w level: NA Date faxed to NU:

Date Putdished: 2/7/98 Diecrepancy: Improper Closure of UlR 1049 to OIR 71, item 2

Description:

UIR 1049 identified a work around that had been in place for nearly 5 years which included Bypass Jumper MP3-92-005 being installed to compensate for the inoperability of the SW PCVs at the four HVQ A/C units. The jumper was installed via Special Test IST 3-92-003, in 1994, one of the bypass valves had to be replaced, and a new test IST 3-94-021 was performed to rethrotle the bypass valves from their earlier settings. This plant configuration is not reflected in the FSAR.

The UIR recommended either permanent hardware fixes to solve the problem or revision to the FSAR to reflect the plant configuration.

UIR 1049 is indicated in the closure package, Closure Request Report 97003666-01, to have been closed against OIR 71, item 2.

However, included in the closure package are the meeting notes from the 3/31/97 EP Meeting which indicate that closure of UlR i 1049 to OIR 71 was tabled due to minimal informaticn provided and pending clarification that the issues raised by UIR 1049 were indeed encompassed by OIR 71. Therefore the item has not been closed based on the package submitted.

Review Vand invand Needed Date initiator: Tenwir*el, J. L 8 O O 2/2/98 VT Lead: Nort, Anthony A B O O 2/2/98 VT Mgr: schopfer, Don K G O O 2r2Se IRC Chmn: singh, Anand K B O O 2ra/98 Date:

INVALID:

Date: 3/17/98 RESOLUTION. Dispostilon:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1025, does not represent a discrepant condition.

FSARCR 97-MP3-62 was issued to correct the wording originally changed by FSARCR 96-MP3-25 conceming the automatic operation of the MCC and Rod Control Area booster pumps.

DCN DM3-00-0790-97 replaces the actuators for the SW PCVs l

at the four HVQ A/C units, thus eliminating the need for Bypass ,

Jumper MP3-92-005. The new actuators used in the DCN

{

retumed the SW PCVs to their original design confguration.  ;

Bypass Jumper MP3-92-005 was restored November / December  !

Printed 3/24/96 3:19.39 PM Page 1 or 2 i

Northe:st Utilities ICAVP DR No. DR-MP3-1026 Ministone Unit 3 Discrepancy Report 1997.

It is correct that the EP meeting minutes included in the package for UlR 1049 Assignment 97003866-01 indicated that the package was tabled on 3/31/97. These minutes were associated ,

with an earlier version of the package that the Panel considered '

deficient. Subsequent to some clarification EP did approve the package on 4/8/97 and the Unit Project Mana0er approved the 1

packa0e on 9/12/97.

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

l

Conclusion:

NU has concluded that the issue reported in I Discrepancy Report DR-MP3-1025, does not represent a discrepant condition. FSARCR 97-MP3-62 was issued to correct the wording originally changed by FSARCR 96-MP3-25 conceming the automatic operation of the MCC and Rod Control Area booster pumps. DCN DM3-00-0790-97 replaces the actuators for the SW PCVs at the four HVQ A/C units, thus eliminating the need for Bypass Jumper MP3-92-005. The new ,

actuators used in the DCN retumed the SW PCVs to their  !

ori0 i nal design configuration. Bypass Jumper MP3-92-005 was l restored November / December 1997. ,

1 It is correct that the EP meeting minutes included in the package for UIR 1049 Assignment 97003686-01 Indicated that the package was tabled on 3/31/97. These minutes were associated with an earlier version of the package that the Panel considered deficient. Subsequent to some clarification EP did approve the package on 4/8/97 and the Unit Project Manager approved the package on 9/12/97.

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

Attachments - Closure Request Report UIR 1049, Bypass  ;

Jumper 3-92-005, DCN DM3-00(01)-0790-97, FSARCR 97-MP3- '

62 Previously kienesed by NU? O Yes @ No Non Diecrapent Condition?@ Yes O No n iunonPendine70 Ya @ No P%unroeowr0 Ya @ No inmator: Tenwinkel J. L VT Lead: Nerl Anthony A VT Mgr: schopfer. Don K O O O 3/ m sic chmn: singh. Anand K j

Date: 3/17/98 st commente Based on the documentation provided by NU along with the above Disposition, S&L agrees that this no longer represents a discrepent condition.

l l

Prirted 3/2@96 3:19A2 PM Pa0e 2 of 2

Northe:st Utilitie3 ICAVP DR Nr. DR-MP3-1068 Millstone Unit a Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System installetion p

Diecipline: Electrical Design D6screpancy Type: Instellation Irnplementation Om System / Process: N/A g

NRC Significence level: 4 Date faxed to NU: I Date Putsshed: 2/23/9e D6screpancy: Miscellaneous Differences in Installed Configuration / Drawings /

Standards.

D*ecripuon: The following miscellaneous drawing discrepancies, differences in installed configuration, and deviations from standards were I noted as part of the system reviews /walkdowns.

Item 1 The Electrical Installation Specification E-350, Procedure OA-9, and the Cable and Raceway Control Program (TSO2) require that cables be tagged in the field. Contrary to this requirement the following cables were found not to have identifications tags at the indicated locations or as shown on the reference drawings.

1. Cable 3EGPAOC405, Reference drawing EE-3ATA Rev.1
2. Cable 3EGEBPX400, Reference drawing EE-3ATZ Rev. 4
3. Cable 3SWPSPX235, Reference drawing EE-3NU Rev.
4. Cable 3SWPBPX400, Reference drawing EE-3ABK Rev. 3
5. Cable for wires landed at terminal block 4T10 points 1 and 2, Reference drawing EE-3JD Rev. 4 Item 2 The following differences in the observed installed wiring and that shown on the connection diagram EE-3ATZ Rev. 4, at Panel 3CES*MCB-MB8, were noted during walkdowns:
1. Terminal Block HCG Point 21 has no conductors landed whereas the referenced drawing indicates two white wires should be terminated.
2. Terminal Block HCG Point 23 has a single white wire terminated whereas the drawing indicates a black wire should be terminated at this point.
3. Terminal Block HCG Point 24 has only one shield wire terminated whereas the drawing indicates that two shields should I be terminated at this point. I I

ltem 3 The following terminations were contrary to that shown on the reference drawings.

1. Cable 3RSSAOC501 is shown with its black conductor terminated -this w:re is not terminated. (Reference Drawing EE-3JT, Rev. 3)

Printed 3r24/9e 3:04:17 PM Page 1 of 5 l

I i

l i

Northeast Utilities ICAVP DR No. DR-MP3-1068 Millstone Unit 3 Discrepancy Report  !

2. Cable o SSAOC502 is shown with its white conductor terminated -this wire is not terminated. (Reference Drawing EE-3JT, Rev. 3)  !
3. Based on the color coding of the conductors, the wires at Terminal Block 820, Points 9 and 12 of Panel 3RPS*PNLSAFA1, are reversed. (Reference Drawing EE-3JQ, Rev. 6) ltem 4 i l

The Cable and Raceway Control Program (TSO2) indicates that cable 3HVRAOX251 is spare per DCN DM3-00-0256-96. This cable was observed in Panel 3CES*lPNLl22 as spare per DCN DM3-00-1569-97. GRITS shows DCN DM3-00-0256-96 as outstanding for the connection diagram for this location (EE-3NX, Rev. 4).

Item 5 The Single Line Diagrams fall to show the local / remote switch for i the SWP, QSS, RSS pumps supplied from the safety related l 4160V bused (34C and 34D). The single line also fails to show l the Lead / Lag switch for pump 3SWP*P18. (Reference Single Line Diagrams EE-1M, Rev. 30 and EE-1N, Rev. 9)

Item 6 l

Conduits 3FX767N04, NOS, N06 entering the bottom of Panel 3CES*PNLBE2P were observed not to be sealed contrary to the requirements of Electrical Installation Specification E-350, Rev.  !

9. (Reference drawing EE-7G) I l

item 7 l l

Drawing EE-7BX, Rev. 6 shows two cables as "F" terminating at l TB4. The uppu one of these cables is actually cable E."

Item 8 The *MCC Layout & Bill of Material" drawings for all of the MCCs have been voided. (Example drawing 2425.600-244-029 for MCC 3EHS*MCC1 A4) These drawings contain several pieces of information regarding the size, type and setting of control circuit components as well as MCC bus ratings and engravings. All of the setting / size information was to be relocated to Specification (ME)-EE-321. Review of this specification revealed a significant lack of information that was included on the now volded drawings. It was further indicated that the nameplate engravings were to be per the single line diagrams; comparison of the installed placards with the text for the loads on the single line found little (verbatim) agreement No other source for the information has been identified.

Review V846d invalid Needed Date initiator: saner, T. L 0 0 0 2nsras Printed 3/2N96 3:0420 PM Page 2 of 5

Northe:st Utilities ICAVP DR No. DR-MP3-1068 Millstone Unit 3 Discrepancy Report VT Leed: Nwl, Anthony A B O O 2/i7/98 VT Mor: Schopfw. Don K O O O 2/18/98 BRC Chmn: Singh, Anand K 2/iwse O O O Dete:

INVAUD:

Dete: 3/20/98 RESOLUTION: Disposition:

NU has concluded that three items (1,2, & 7) reported in Discrepancy Report DR-MP-3-1058 has identified conditions not previously discovered by NU which require correction.

Item # 1:

Cable 3SWPBX235 and 3EGPAOC405 located in panels 3CES*MCB-MB8 and 3CES*lLNLl19, respectively, were not ta90ed. TR#23M3131739 was written to instruct field forces (FIN team) to tag these cables. CR #1022, CA #1 will correct this discrepancy post startup. A field walkdown indicated cables 3EGEBPX400 & 3SWPBPX400 were tagged, item # 2:

The conductors and shield wire discrepancies between what is shown on drawing EE-3ATZ and actual field wiring were caused by cable 3BYS2PX402 being erroneously added to drawing EE-3ATZ during the incorporation of E&DCR T-E 00603. This cable does not exist in the field, on terminal tickets, or in TS02, and should bc removed from drawing EE-3ATZ. Removal of this cable and its conductors from drawing EE-3ATZ will eliminate the wiring discrepancies on points 21,23, and 24, of terminal strip HCG as described in item 2. DCN DM3-00-0181 98 was issued to correct this drawing discrepancy.

Item # 7:

Drawing EE-7BX Rev. 6 shows two cables designated as "F" terminated at TB4. The upper cable should be designated as cable "E". DCN DM3-00-018198 was issued to correct this drawing discrepancy.

These three items (1,2, & 7) represent discrepancies which are minor in 'iature and do not effect the LB or DB therefore, NU considers these items to be Significance Level 4 issues.

NU has concluded that item 8 (part 1) reported in Discrepancy Report # 1058 has identified a condition previously discovered by NU which requires correction.

Item # 8:

Part 1: (Information contained in SP-EE-0321 verses what was contained in "MCC Layout & Bill of Material") Information that Printed 3/24'98 3:o4:22 PM Page 3 of 5

)

Northe st Utilities ICAVP DR No. DR-MP31068 Mmstone unit 3 Discrepancy Report j was previously contained in the voided "MCC Layout & Bill of Material has been transferred to other design documents, other than SP-EE-0321. A majority of the information has been j transferred to One-Line Diagrams, MCC Wiring Diagrams, MCC 1 Starter and Relay Compartment Intemal Wiring Diagrams, and the associated Elementary Diagrams for MCCS Specification SP-EE-0321 will document information relating to the MCC ,

Thermal Overload and Magnetic Breaker Setting. Presently, I Engineering is compiling this information for inclusion into Appendix J of SP-EE-0321. This action was initiated by a periodic self-assessment 3DE-SA-97-03 which generated CR M3-97-3095.

I Item # 8 (part 1) represents a discrepancy which is minor in nature and does not effect the LB or DB therefore, NU considers this item to be Significance Level 4 issue.

NU has concluded that items 3,4,5,6, & 8 (part 2), reported in )

Discrepancy Report # 1058, do not represent discrepant conditions.

Item # 3:

l DCN #DM3-00-079197 changed the wiring on terminal block )

820 points 9 & 12. The work was completed in the field but has I not been incorporated into drawing EE-3JQ yet. This DCN was  !

due to project work, not the result of a wiring error, item # 4:

The TS02 program indicates DCN #DM3-S-0256-96 as the DCN which indicates cable 3HVRAOX251 is a spare cable, not DCN

  1. DM3-00-0256-96. DCN # DM3-00-0256-96 does not exist in GRITS. DCN DM3-00-1569-97 is not associated with either panel  !

3CES*1PL122 or cable 3HVRAOX251. It is the DCN for " Check Valve Specification for Pump Casing Vent Line On 3RSS*P l B, I ,

C, & I D". '

Item # 5:

Remote and Local operator control switches are shown on the Electrical One-Lines for the pumps indicated. One-Line diagrams do not indicate lead / lag control switches. Control switches other than operator " start" are shown on the component's respective ESK drawing. The Electrical One-Line does provide a component's respective ESK ltem # 6:

A review of the fire stops and seal requirements for the ESF Building at the 37' elevation, at column /line 45.3/G7 (reference drawing 25212-24279 sheets ES070A, B, & C) indicates that no seals are required for these raceways.

Item # 8: Part 2:

Printed 3/2498 3.04:23 PM Page 4 of 5

Northeast Utilities ICAVP DR No. DR MP3-1068 Mmstone Unit 3 Discrepancy Report (Name plate engraving on MCCs verses identifications shown on the One Line Diagrams) Equipment ID references found on the one Lines matched vert >atim with the nameplates on the MCCS. Due to space constraints, the nameplates on the MCC sections often cannot contain all the information referenced on the One Line Diagrams. References to drawings such as ESKs or vendor drawings usually are not included on the nameplates in the field.

Significance level criteria does not apply as these five items [3, 4,5,6,8 (part 2)] are not discrepant conditions.

Conclusion:

NU has concluded that three items (1,2, & 7) reported in Discrepancy Report DR-MP 3-1058 has identified conditions not previously discovered by NU which require correction. The approved corrective actions for CR M3-98-1022 will correct items 1,2, & 7. These discrepancies are minor in nature (cable tagging, drawing corrections) and do not effect LB/DB, therefore NU considers them to be Significance Level 4 issues. NU has concluded that item 8 (part 1) reported in Discrepancy Report DR-MP3-1058 has identified a condition previously discovered by NU which requires correction. Information that used to be contained in the now voided "MCC Layout & Bill of Material" I drawings is being transferred to other engineering documents to include Specification SP-EE-0321. Item # 8 (part 1) represents a discrepancy which is minor in nature and does not effect the LB or DB therefore, NU considers this item to be Significance Level 4 issue. NU has concluded that items 3,4, 5,6, & 8 (part 2),

reported in Discrepancy Report # 1058, do not represent discrepant conditions. These issues were either changes that will be made due to project work or the process of updating technical documents that are already in progress. Significance level criteria does not apply as these five items are not discrepant conditions.

Previooaly klontened by Nu? U Yee @ No Non Discrepent Condition?O Yes @ No Resolution Ponding7O Yee @) No Reedution unresoev.d70 Yee @ No Review Acrard aMa Not AM" _ Needed Date VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anend K Date:

SL Comments:

Printed 3/24/96 3:04 24 PM Page 5 of 5

1 Northeast Utilities ICAVP DR No. DR-MP3-0130 ministone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION REJECTED Review Element: CorrectNo Actkm Process Diecipune: Mechanical Design g y ,,

Diecrepancy Type: CorrectNe Action ayotemProcese: SWP Om NRC E,f" -K.e levet:4 Date faxed to NU:

Date Putdished 9/22/97 D6ecrepency: Inadequate Corrective Action - Action to prevent Recurrence

Description:

Two Condition Reports (ACR M3-96-0041, Level D and M3 0920, Level 2) identified the probable causes of the conditions as inadequate 10CFR50.59 Safety Evaluations. Although the technical issues were adequately resolved, in neither of these cases was the action to prevent recurrence (inadequate safety evaluations) appropriately addressed. Form RP-4-7, page 3 of 4, Causal Factor Corrective Action Plan states, " Detail those actions that have been taken, are on-going or will be taken (near-term and long-term) that will be taken to verify the continued i effectiveness of the corrective action." in neither case has the action to correct the causal factors been addressed, i.e.,

inadequate Safety Evaluations. The ssme applies on page 4 of for of Form RP 67, block 7 which requires a statement identifying, "....how the corrective actions will effectively prevent i or reduce the possibility of the same or a similar event or  !

adverse condition from happening again..." This section in ACR l M3-96-0041 has nothing entered, while the entry for ACR M3 0920 is inadequate in that it does not describe how the corrective l action will prevent recurrence.  !

Review l Vahd invalid Needed Date l Initletor: Wrone, S. P. O O O S'S/S7 VT Lead: Ryan, Thomme J B O O st 2/97 VT Mgr: Schopfer, Don K O O O S' S'87 IRC Chmn: Singh, Anand K B O O S'17/S7 Date:

INVALID:

Date: 3/j7/98 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0130, does not represent a discrepant condition. The two ACRs referenced in the DR were written on 6/5/96 and 10/7/96. At that time revision 2 of RP4 was effective. Step 1.6.6 of RP4 rev. 2 states: 'lF corrective actions to prevent recurrence are not required (level D significance) DOCUMENT on Form RP4-7, (only pages 3 and 4 required) and IDENTIFY corrective actions.*Both ACRs were classified as level D (verified on AITTS that M3-96-0920 is level D not level 2). Level D ACRs are treated as isolated incidents where no programmatic failure is found to exist. The two incidents were not indicative of a programmatic failure. Also, as indicated on RP4-6 rev. 2, block 1, the required causal factor determination process was to identify corrective actions required for this adverse condition and Prtreed 3/24/98 3:05:s3 PM Page 1 of 2

1 Northe:st Utilitie3 ICAVP DR No. DR-MP3-0130 Millstone Unit 3 Discrepancy Report document on RP4-7, pages 3 and 4. (No causal factor determination required.) Significance level criteria do not apply as this is not a discrepant condition.

Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0130, does not represent a discrepant condition. The two level D ACRs were written and resolved while rev. 2 of RP4 was effective. Step 1.6.6 does not require action to prevent recurrence to be completed for level D ACRs because they are not considered programmatic failures. Significance level criteria {

do not apply as this is not a discrepant condition. 1 Previously ident6 fled try NU7 O vos (9) No Non D6ecrepent Condit6on?O Yes @) No Resolution Pending?O v @ No Resoeunion unre.oiv.d70 v @ No Review F,^~- Not E=^ Needed Date VT Lead: Ryan, Thomme J VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K O

oste: 3/17/98 st Comments: S&L agrees with the respense as it pertains to the specific requirements which were applicable at the time for assigned level D sl0nificance ACRs. However, the issue identified in this DR is the same issue noted in DR-MD3-0865. NU's response to DR-MP3-0865 acknowledged the issue as discrepant and previously identified via ACRs M3-96-0924 and 925. A similar disposition for DR-MP3-0130 should be made.

l l

Printed 3r24/96 3:05:56 PM Page 2 of 2 l

Northe:st Utilities ICAVP DR No. DR-MP3-0572 millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: System Design Discipline: Mechanical Design Discrepency Type: Calculation Om SystemProcess: Rss g

NRC SignHIcence level: 4 Date faxed to NU:

Date Published 11/20S7 Discrepency: 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 rato of 228 gpm from the CHS and SFC systems.  !

No reference for this fill rate is provided. The 60-minute overflow I 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 for the elevation of the high level alarm setpoint, the l 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: Wake)end, J. F. B 0 0 /S7 VT Lead: Neri, Anthony A Q Q Q 11/11/97 VT Mgr: schoprer, Don K O O O /17/S7 IRC Chmn: Singh, Anand K O O O 15/17/S7 Date:

INVALID:

Date: 3/14/98 RESOLUTION: 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 derived from Calculation 3-ENG-167 Rev.1. Utilizing the input data to 3-ENG-167, it can be shown that, assuming 80 gpm 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 calculatioris necessary to confirm the Printed 3/24/96 3:06:59 PM Page 1 of 3

Northecst Utilitieo ICAVP DR NS. DR-MP3-0572 Mmstone unit 3 Discrepancy Report 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 gpm ( See Pages 9 an 11 of OP 3304 C Attached ). Utilizing this makeup rate and the volume associated with height differential between tank overflow and RWST HI Level Alarm it is possible  ;

to calculate the time differential (delta T) between alarm  !

annunciation and tank overflow. l delta T = V / MUR = 13,498.1 gal / 80 gpm = 168.7 minutes =

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 addrescas 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.

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

CONCLUSION:

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 derived from Calculation 3-ENG-167 Rev.1. Utilizing the input data to 3-ENG-167, it can be shown that, assuming 80 gpm makeuD to the RWST as prescribed in OP 3304C. the 3QSS-PrWed 3/2498 3:07:02 PM Page 2 of 3

3 i

Northeast Utilities ICAVP DR No. DR-MP3-0672 {

Millstone Unit 3 Discrepancy Report l 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.

Additionally, 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 4 alarm 3OSS-LIS60 assessment.

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

Prewously identiaed by NU? O vos fe) No Non Discropont Condition?O vos (G_) No Resolution Pending?O vos (i)No ResolutionUnresolved?O vos @ No Review inittstor: Wakelend, J. F. l VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Sin 0h, Anend K Date: 3/14/98 l SL Commente: Sargent & Lundy concludes that DR-MP3-0572 is a discrepant condition. There is no documented basis for the response to FSAR Question Q410.5. This response is part of the Millstone Unit 3 licensing basis. Therefore a documented basis is required.

Because NU's evaluation in M3-IRF-01444 concludes that the Millstone Unit 3 would meet the FSAR Q410.5 requirement, DR-MP3-0572 is an NRC Significance Level 4 discrepancy and revising calculation 357P, or issuing a calculation change notice to 357P may be deferred until after Unit 3 restart.

l Printed 3/24/96 3:07.03 PM Page 3 of 3

.___-._________-________________j

Northeast Utilme3 ICAVP DR Nr. DR-MP3-0608 millstone Unit 3 Discrepancy Report Review Group: P,uy...i ic DR RESOLUTION REJECTED Review Element: corrective Action Process p D6scipline: Operation.

Om Discrepancy Type: Corrective Action g SystemProcess: N/A NRC W level: 4 Date faxed to NU:

Date Putdished 11/22/97 D6ecrepancy: Lack of Generic Implicatior;s Assessment D*ecription MP3 LER 97-020-00 provides a description of a condition where the desi9n placement of flow throttle valves for cooling water to the containment air coolers was set such that insufficient cooling would be provided to the containment during a loss offsite power condition. The issue is primarily related to inadequate cooling for an operator to perform credited fire event related mitigation actions in the containment. The action requests generated by NU to address this lisue appear to be limited to remediation of this particular issue. The NU corrective action for this condition did not include an assessment of the generic implications on other post-fire credited actions with regard to conditions that could interfere with completion of the required actions.

Altemately, a review could be made to determination if the existing basis documentation for these actions adequately accounts for such conditions. Specifically, such a review or basis should consider design and operation subtleties that might be overlooked relative to environmental impacts or other obstructions to complete the actions.

Review Valid invalid Needed Date initletor: Bennett, L. A. O O O 1' '97 VT Lead: Ryan, Thomas J B O 1/ 2/97 VT Mgr: Schopfer, Don K O O O 52/97 IRC Chmn: Singh, Anand K O O O 15'18/97 Date:

INVALID:

Date: 3/17/96 RESOLUTION. Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0608, does not represent a discrepant condition. The corrective action for CR M3-97-0392 did require an evaluation of environmental conditions for operator action feasability for containment entry. It was considered adequate to only look at the containment because this condition was believed to be an isolated issue, and that loss of ventilation wnuld have no significant impact on operator action for other fire events. An additional CR M3-97 0634 identified problems with the ability to perform a safe shutdown if all charging pump: were lost. As part of that CR's corrective action, AR 97005496-04 required a review of Altemate shutdown capability credited actions to ensure compilance with performance goals. Compliance with the perfa .Tiance goals ensures a safe shutdown. ERC 25212-ER-97-0007, Manual Action Feasability" docurnents this review.

Printed 3f24/96 3.07:47 PM Page 1 of 3

ICAVP DR No. DR-MP3-0608 Northecst Utilities Millstone Unit 3 Discrepancy Report This report summarizes the results of a number of activities that relate to feasability of manual operator actions taken as :; result of a fire. The development of EOPs for all fire arece ensured that operator access to various areas of the pleist was possible for the manual actions, (i.e. that actions did not require entry to the area (or zone) on fire until after the fire has been extinguished.) The ERC also evaluate the use of emergency lighting and communications that support operator actions during a fire event. In this regard, these reviews captured design and operational subtleties and other obstructions that may have impacted the operator action. However, it must be noted that specific evaluations on loss of ventilation on operator action was not included in these reviews.

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-MP3-0608, does not represent a discrepant condition. The corrective action for CR M3-97-0392 did require an evaluation of environmental conditions for operator action feasability for containment entry. It was considered adequate to only look at the containment because this condition was believed to be an isolated issue, and that loss of ventilation would have no significant impact on operator action for other fire events. ERC 25212-ER 97-0007, Manual Action Feasability" documents this review. This report summarizes the results of a number of activities that relate to feasability of manual operator actions taken as a result of a fire. The development of EOPs for all fire areas ensured that operator access to various areas of the plant was possible for the manual actions, (i.e. that actions did not require entry to the area (or zone) on fire until after the fire has been extinguished.) The ERC also evaluate the use of emergency lighting and communications that support operator ,

actions durin0 a fire event. In this regard, these reviews I captured design and operational subtleties or other obstructions that may have impacted the operator action.

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

Previously identifled by NU? O vos (e) No NonDiscrepentCondition?O vos (#) No Resolution Ponding?O ve. @ No ResoluuonUnresolved?O vos @ No Review Acceptable Not Areap8aMa Needed Date initietor: Neveno, Me*

O O O x2ase VT Leed: Ryan, Thomas J y$7g vi Mgr: Schopfer, Don K IRC Chmn: singh, Anand K O 8 0 m Se O O O Date: 3/17/98 sL comments: In discussing the Altemate Shutdown capability Review which was documented in ERC 25212-ER-97-0007. The Disposition section of the DR reponse states 'However, it must be noted that Printed 3/24/96 3:07:51 PM Page 2 of 3

Northe:st Utilities ICAVP DR N1 DR-MP3-0608 Millstone unit 3 Discrepancy Report 1 specific evaluations on loss of ventilation on operator action was not included in these reviews". This statement appears contrary to Attachment 2 (page 2-1, item 6.0 b) of 25212-ER-98-0007 which states: "The proposed manual actions were also reviewed to ensure habitability issues were addressed" and also appears contrary to Attachment 2 (page 2-2, section 6.1.2 under EOP procedural verification) of 25212-ER-96-0007 which states: "The field verification of these procedures included the following )

criteria-Environmental conditions in the area where task is to be accomplished will allow its performance".

If loss of ventilation to any specific area which must be entered to perform manual actions occum due to the LOP coincident with a fire, the resultant ambient conditions need to be considered to ensure feasibility of the manual action.

l 1

Printed F2496 3:07:53 PM Page 3 of 3

Northe:st Utilities ICAVP DR No. DR-MP3-0688 j Millstone Unit 3 Discrepancy Report j Review Group: System DR RESOLUTION REJECTED Review Element: system Design Diecipline: Mechenecol Design Discrepency Type: Calculebon Om i SystemrProcess: DGX g )

NRC We M 3 Date faxed to NU:

Date Putdished: 12f2cS7 D6ecrepency. Discrepancies in Calculation 3-92-102-263-M3/Rev. O, CCN 1 l

Description:

Review of the calculation " Emergency Diesel Starting Air System Design Pressure and Temperature", calc. no. 3-92102-263-M3, Rev 0, Calculation Change Notice no.1 resulted in the following discrepancies:

1. This calculation is classified "Non-QA" on the Calculation Change Notice No.1, page 1, box 7, and "non QA" and seismic qualification basis "N/A" on page 1 of the calculation. However, among components included in the scope of the calculation are Air Receiver Tank 3Er?A*TK1 A,1B,2A,28 (classified QA Cat.1 component) and safety related piping (lines with line sequential numbers 1,3,5,11,13,15).
2. The model used to calculate air temperature at the air compressor discharge (page 9 of the calculation) yleids  ;

temperatures below those provided by the Emergency Diesel Generator supplier via the Colt Industries letter " Contract 206072 Millstone 3 Quincy Air Compressor", dated April 5,1983, and attached to calculation P(T)-1042, Rev. (blank) as Attachment

2. The Colt Industries letter states that if the compressor tums 900 rpm, the air discharge temperature at 450 psi will be approximately 585 degrees F, and at 425 psi approximately 575 degrees F. (This information was used in calculation P(T)-1042 to define operating temperatures at limiting compressor discharge pressures.) The model used in this calculation yields air temperature of 570 degrees F at 450 psig and 584.5 degrees F at 500 psig. In comparison to the vendor provided data, the temperature calculated in this calculation appears non conservative.
3. The calculation states that the aftercooler design pressure is 500 psig per "Aftercooler Heat Exch.inger Spec. Sheet",

Appendix E, Specification 12179-2520.300-730, Add.1, dated 3/21/85. The Aftercooler Heat Exchanger Spec Sheet could not be found in the referenced purchase specification. However, the purchase specification. Attachment 2 does specify the air cooled l aftercooler process side design pressure at 450 psig.

4. Calculation states that "The whole EGA system is using pipe Class 301, Spec SP-ME-572.. Class 301 piping is suitable for 1 555 psig up to 600 degrees F temperature.

Conclusion:

Piping is I OK for 500 psig." The P&lD's EM-1168-25 and EM-116D-5 I show a class change within the dryer package between the aftercooler (CL 602), condensate separator (CL 151), prefilters (CL 602), and the dryer (CL 151). Per Spec. SP-ME-572 piping  !

Class 151 is good for 275 psig at 100 degrees F, and 150 psig at I p , pg 5^^ 5 0: F, :::!! b:b 150 : 'ed:S MdentsedOp:M M3

1 1

l DR No. DR-MP3-0688 j Northe:st Utilities ICAVP Millstone Unit 3 Discrepancy Report pressure and the design pressure.

Review Valid Invalid Needed Date initiator: obersnei.Bojen. O O O 5/2i/97 VT Lead: Nort, Anthony A B O O i r24/97 VT Mgr: Schopfer, Don K B O O $2 isis 7 ;

WtC Chmn: sin 0h, Anand K B O O 2/is/97 oei.:

INVAllO:

Date: 3/j7/98 RESOLUTION: Disposition:

NU has concluded that issues 1 and 4 reported in Discrepancy ,

Report, DR-MP3-0688, have identified conditions not previously )

discovered by NU which require correction. An issue by issue discussion follows:

The approved corrective action plan in CR M3-98-0140 will be completed post startup to revise calculation 3-92-102-263-M3 to identify it as QA CAT 1. It will also revise the designation of EGA-pipe class from 151 to 301 on P&lD EM1168 and EM116D to reflect the material provided by the vendor. There is no impact on the licensing or design basis since the calculation was independently reviewed as regtfred for CAT 1 calculations and the installed material is identical (A106Gr B. Sch 80) for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4.

J NU has concluded that issues 2 and 3 of Discrepancy Report, DR-MP3-0688, do not represent discrepant conditions. The Colt Industry letter provides " approximate" temperatures for various discharge pressures and compressor speed. The method for calculating compressor discharge temperatures uses several conservative assumptions and room temperatures specific to Millstone and is deemed acceptable. The after coolers were replaced by DCN DN3-S-1269-93 with models rated for 500 psig. There is no requirement to revise a superseded purchasing specification. Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that issues 1 and 4 reported in Discrepancy ,

Report, DR-MP3-0688 have identified conditions not previously '

discovered by NU which require correction. Issues 1 and 4 will l be corrected by the approved corrective action plan in CR M3 j 0140 to revise the calculation and the P&lD. These actions will l be completed post startup. There is no impact on the licensing or {

design basis since the calculation was independently reviewed l as required for CAT 1 calculations and the installed material is identical for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4. NU has concluded that issues 2 and 3 of Discrepancy Report, DR-MP3-0688, do not represent discrepant conditions. issue 2 is considered non discrepant since it uses an acceptable method of calculating Printed 3/24/96 3:08:22 PM Page 2 of 3 i

l

l Northeast Utilities ICAVP DR No. DR-MP3 4688 milistorm unit 3 Discrepancy Report compressor discharge temperatures while the vendor provided approximate information. Issue 3 requires no correction since the aftercoolers have been replaced by models rated for 500 psig by DM3-S 1269-93. Significance Level criteria do not apply for issues 2 and 3 since these are not discrepent conditions.

t/ ?;idoneRed by NU7 U Yes @ No Non Discrepent Consation?O Yes @ No PM% Pensung70 vos @ No ""h Unresolved?O vos @ No moviour m %g ^~aren Not a~ar h a Nooded Date VT Lead: Neri, Anthony A i VT Mer: schopfer, Don K Ntc Chmn: Singh. Anand K Date: 3/17/98 st Commente. S&L agrees with the disposition for the first discrepancy.

S&L will require additional information to determine adequacy of the NU disposition for the second discrepancy regarding the determination of air compressor air discharge temperature. While S&L agrees that the model of isentropic compression is conservative for this calculation and accepts the interstage pressure model, the assumption that the intercooler temperature approach to athbient temperature will not exceed 50 degrees F J needs to be substantiated with design information, and so documented in the calculation. Please identify such approach temperature supporting information.

4 S&L agrees with the disposition for the third discrepancy. As shown on the revised data sheet for air cooled aftercooler (page 60 of DCN DM3-S-1269-93) the desi0n pressure for the aftercooler process side was revised to 500 psig. This is a non-discrepent condition.

Regarding the fourth discrepancy S&L a0rees that the condensate separator and dryer pipe material and wall thickness (per dwg.

2520.300-730-004C, Sh.100 of DCN DM3-S-1269-93) meet the pipe Class 301 requirements. S&L agrees with the NU disposition for this discrepancy, that is that the P&lD should be appropriately corrected.

Printed 3/2496 3:08:24 PM Page 3 or 3

Northecst Utilities ICAVP DR No. DR-MP3 0688 Millstone Unit 3 Discrepancy Report Review oroup: system DR RESOt.UTION REJECTED Review Element: system Design Diecipline: Mechenical Design Discrepency Type: Calculation O vos System / Process: DGX (e. ) No NRC Significence level: 3 Date faxed to NU:

Date Putsehed: 12/20/97 D6screpency: Discrepancies in Calculation 3-92-102-263-M3/Rev. O, CCN 1 Deecription* Review of the calculation " Emergency Diesel Starting Air System Design Pressure and Temperature", calc. no. 3-92102-263-M3, Rev 0, Calculation Change Notice no.1 resulted in the following discrepancies:

1. This calculation is classified "Non-QA" on the Calculation Change Notice No.1, page 1, box 7, and "non QA" and seismic qualification basis "N/A" on page 1 of the calculation. However, among components included in the scope of the calculation are Air Receiver Tank 3EGA*TK1A,18,2A,28 (classified QA Cat.1 component) and safety related piping (lines with line sequential numbers 1,3,5,11,13,15).
2. The model used to calculate air temperature at the air compressor discharge (page 9 of the calculation) yields temperatures below those provided by the Emergency Diesel Generator supplier via the Colt Industries letter " Contract 206072 Millstone 3 Quincy Air Compressor", dated April 5,1983, and l attached to calculation P(T)-1042, Rev. (blank) as Attachment
2. The Colt Industries letter states that if the compressor tums 900 rpm, the air discharge temperature at 450 psi will be approximately 585 degrees F, and at 425 psi approximately 575 degrees F. (This information was used in calculation P(T)-1042 to define operating temperatures at limiting compressor discharge pressures.) The model used in this calculation yields air temperature of 570 degrees F at 450 psig and 584.5 degrees F at 500 psig. In comparison to the vendor provided data, the temperature calculated in this calculation appears non conservative.
3. The calculation states that the aftercooler design pressure is 500 psig per "Aflercooler Heat Exchanger Spec. Sheet",

Appendix E, Specification 12179-2520.300-730, Add.1, dated 3/21/85. The Aftercooler Heat Exchanger Spec Sheet could not be found in the referenced purchase specification. However, the purchase specification, Attachment 2 does specify the air cooled aftercooler process side design pressure at 450 psig.

4. Calculation states that "The whole EGA system is using pipe Class 301, Spec SP-ME 572... Class 301 piping is suitable for 555 psig up to 600 degrees F temperature.

Conclusion:

Piping is OK for 500 psig." The P&lD's EM 116B-25 and EM-116D-5 show a class change within the dryer package between the aftercooler (CL 602), condensate separator (CL 151), prefiliers (CL 602), and the dryer (CL 151). Per Spec. SP-ME-572 piping  ;

Class 151 is good for 275 psig at 100 degrees F, and 150 psig at p

"i;;::= F, ::::' M!r !M 9:":'rt!= Mr'Td ep~g g I

ICAVP DR No. DR-MP3-0688 Northe:st Utilitles mmstone Unit 3 Discrepancy Report pressure and the design pressure.

Review Vaud invand Needed Date inisator: ot e nei.soien. O O O si2is7 VT Lead: Nat. Anthony A B O O $'i24m7 VT Mgr: schopfer, Don K O O O $2iis7 IRC Chmn: Singh, Anand K O O O 2/iss7 Date:

INVALID:

Date: 3/17/98 RESOLUTION: Disposition:

NU has concluded that issues 1 and 4 reported in Discrepancy Report, DR-MP3-0688, have identified conditions not previously discovered by NU which require correction. An issue by issue discussion follows:

The approved corrective action plan in CR M3-98-0140 will be completed post startup to revise calculation 3-92-102-263-M3 to identify it as QA CAT 1. It will also revise the designation of EGA pipe class from 151 to 301 on P&lD EM1168 and EM116D to reflect the material provided by the vendor. There is no impact on the licensing or design basis since the calculation was independently reviewed as required for CAT 1 calculations and the installed material is identical (A106Gr B. Sch 80) for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4.

NU has concluded that issues 2 and 3 of Discrepancy Report, DR-MP3-0688, do not represent discrepant conditions. The Colt industry letter provides " approximate" temperatures for various discharge pressures and compressor speed. The method for calculating compressor discharge temperatures uses several conservative assumptions and room temperatures specific to Millstone and is deemed acceptable. The after coolers were replaced by DCN DN3-S-1269-93 with models rated for 500 psig. There is no requirement to revise a superseded purchasing specification. Significance Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

)

NU has concluded that issues 1 and 4 reported in Discrepancy Report, DR-MP3-0688 have identified conditions not previously discovered by NU which require correction. Issues 1 and 4 will be corrected by the approved corrective action plan in CR M3 0140 to revise the calculation and the P&lD. These actions will be completed post startup. There is no impact on the licensing or design basis since the calculation was independently reviewed as required for CAT 1 calculations and the installed material is identical for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4. NU has concluded that issues 2 and 3 of Discrepancy Report, DR-MP3-0688, do not represent discrepant conditions. Issue 2 is considered non discrepant since it uses an acceptable method of calculating Printed 3r24s0 3.08:47 PM Page 2 of 3

ICAVP DR No. DR-MP34688 Northeast Utilitiec Milistone unit 3 Discrepancy Report compressor discharge temperatures while the vendor provided approximate information. Issue 3 requires no correction since the aftercoolers have been replaced by models rated for 500 psig by DM3-S-1269-93. Significance Level criteria do not apply for issues 2 and 3 since these are not discrepant conditions.

Previously identifled by NU7 U Yes (8) No Non Discrepent Condition?U Y.s (#) No R. solution Pending70 Y @ No n iuisonunr ev.d70 Y @ No n.vi Inittstor: Obersnel.Bojan.

VT L.ed: Nort, Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Det.: 3/17/98 st Comments: S&L agrees with the disposition for the first discrepancy.

S&L will require additional information to determine adequacy of the NU disposition for the second discrepancy regarding the determination of air compressor air discharge temperature. While S&L agrees that the model of isentropic compression is conservative for this calculation and accepts the interstage pressure model, the assumption that the intercooler temperature approach to ambient temperature will not exceed 50 degrees F l needs to be substantiated with design information, and so documented in the calculation. Please identify such approach temperature supporting information.

S&L agrees with the disposition for the third discrepancy. As shown on the revised data sheet for air cooled aftercooler (page 60 of DCN DM3-S-1269-93) the design pressure for the aftercooler process side was revised to 500 psig. This is a non-discrepant condition.

Regarding the fourth discrepancy S&L agrees that the condensate separator and dryer pipe material and wall thickness (per dwg.

2520.300-730-004C, Sh.100 of DCN DM3-S-1269-93) meet the pipe Class 301 requirements. S&L agrees with the NU disposition for this discrepancy, that is that the P&lD should be appropriately corrected.

Printed 3'2N96 3:08:49 PM Pa0 3 of 3

ICAVP DR No. DR-MP3-0696 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: System Design O vos l Descrepancy Type: ceiculation gg  !

SystemProcese: QSS l NRC Significence level: 4 Date faxed to NU:

Date Putd6.hed: 52r25/97 D6.crepancy: RWST Insulation

Description:

FSAR Sec. 6.2.2.2 requires the maximum RWST heat up or cooldown rate be less than 0.25F/ day. Calculation P(R)-931, Rev. O assumes that the RWSTs are covered with 6 inches of thermal insulation in order to conclude that the maximum heat up and cooldown rates are 0.13F/ day.

There are no design documents which demonstrate that the RWSTs are covered with 6 inches of insulation.

Review )

Veild invalid Needed Date Ininetor: Wolmiend,J.F. O O O 11/22/97 VT Leed: Nort, Anthony A B O O sir 22/97 O $2/i/97 VT Mgr: Schopfer, Don K O O

$2/9s7 IRC Chmn: Singh, Anand K O O O Date:

INVALID:

note: 3/14/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0695, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 Pl.

20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.

CONCLUSION:

NU has concluded that Discrepancy Report, DR-MP3-0695, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.

Previously identified by NU7 O Yes @ No NonDiscrepentCondition?O Yes (9') No Resolution Pend 6ng?O ve. @ No Resolution Unresolved?O ve. @ No Review A -: - "'- Not Accata.ada Needed Date VT Leed: Nort. Anthony A VT Mgr: Schopfer, Don K Pnnled 3/24/98 3'00.36 PM Page 1 of 2

ICAVP DR Ns. DR-MP3-0695 Northe0Ct Utilities Millstone Unit 3 Discrepancy Report

.. . _ .. ~ "'

O B O =

RC Chmn: Singh. Anand K Date: 3/14/98 st. comments: Sargent & Lundy acknowledges that DR-MP3-0695 is a documentation issue only; however, this design documentation issue my not be defered until after Unit 3 restart.

The FSAR Section 6.2.2.2 requirement for a maximum RWST heat up/cooldown rate of 0.25F/ day is a licensing requirement.

I This licensing requirement is met by Calculation P(R)-931 which assumes that the RWST is covered with 6 -inch thick insulation.

Assurance that there is no Unreviewed Safey Question cannot be demostrated unless design documents are located for the 6-inch insulation thickness or a properly-documented walkdown is completed to verify the 6-inch insulation thickness.

l

(

i l

l Printed 3r2496 3:09:41 PM Page 2 of 2

)

Northecst Utilities ICAVP DR No. DR-MP3-0713 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION REJECTED Review Element: system Design Diecipline: Environmnental Quahfication Discrepancy Type: ceiculation Om SystemProcess: Oss gg NRC SignWicence level: 4 Date faxed to NU:

Date Putdished. 12/21/97

" + E :i: Equipment Qualification Discrepancy l Deecripoon EEQ-TRA-113.0, Rev.1, dated 1/14/1997 is the Electrical l Equipment Qualification Test Report for Class IE General Electric (GE) Quench Spray Pump Motors (Plant 1.D. No.

3QSS*P3A,B). It ! dates on Sheet 2 of 7 that the GE test report GEK-42842 titled,

  • Topical Report IEEE 323 Class IE Induction Motors, Horizontal Class B Insulated, Model Numbers SK821051C40, SK821054C26, SK828840C88*, dated December 1978 meets the requirements of DOR instead of R>G 1.89, Rev.

1 and IEEE 323-1974.

This conclusion was based on the fact that the motor qualification in the GE Topical Report was based on separate testing and operating experience which does not meet the requirements of IEEE 323-1974.

However, the Procurement Specification No. 2441.003-009, Rev. I 2, page 1 17 of states that these pump motors should be  !

environmentally qualified in accordance with IEEE 323-1974. l Also, Millstone FSAR Section 3.11B.2.2 states that the Environmental Qualification of all safety-related equipment shall meet the requirements of IEEE 323-1974, the Intent of NUREG-0588, and NRC 10CFR50.49.

Review Valid invalid Needed Date Initiator: Yassin, s.

O O O 1/24/97 VT Lead: Nort. Anthony A O O O /2 5 7 VT Mgr: schopfer, Don K B O O 12/sa7 IRC Chmn: singh, Anand K B O O 12/9/97 Date:

INVALID:

Date: 3/16/98 RESOLUTION. NU has concluded that the issue reported in Discrepancy Report, {

DR MP3-0713, does not represent a discrepant condition.

Environmentally qualified equipment must be type tested or analyzed to withstand the postulated environmental conditions expected during its service life including a design basis accident.

The task of comparing the results of a type test to installed conditions is a three part process. The first part is to validate the  ;

test report and summarize the results, second is to document general technical issues and a9in0 calculation. The last step is to document the installed configuration and justify its similarity to the test configuration. The process by which each of these steps is accomplished is documented in the EEQ Program Manual in Program Instructions 5.2,5.3, and 5.1 respectively. The Test Report Assessment (TRA) documents the process of assessing a qualification report. The process includes but is not limited to:

Printed 324/96 3:22:o4 PM Page 1 of 3

Northeast Utilitiec ICAVP DR No. DR MP3 0713 Millstone Unit 3 Discrepancy Report

  • Defining the precise configuration of the tested items
  • Listing all required environmental parameters recorded during the test
  • Identifying and resolving anomalies which could effect qualification
  • Evaluating the test methods in accordance with IEEE 323 or DOR Guidelines
  • Specifying the performance characteristics of a component and determining if they were demonstrated during the test
  • Specifying the maintenance, replacement, installation and interfacing requirements identified in the test report
  • Calculating the DBE 500 C Equivalent Life from test profile data
  • Calculating temperatures which correspond to a range of qualified lives including the temperature associated with a 40 year qualified life The TRA, like a vendor supplied test report, is a general document unrelated to a specific plant but which may be used to support the qualification of equipment at Connecticut Yankee and Millstone 1,2 and 3.

The Equipment Qualification Record (EQR) documents the comparison of the plant installed equipment to the tested equipment evaluated in the TRA process or a DOR analysis. As a minimum the EQRs contain: {

  • Evidence that all pertinent environmental parameters, including i the temperature profile, are proper 1y enveloped
  • A circuit loop drawing showing the actual installed configuration

{

i of the component being qualified and allinterfacing components {

within a harsh environmental zone

  • Similarity analysis, performance analysis, periodic maintenance, equipment installation and equipment interface requirements to maintain qualification
  • References of all source documents that provide input to the qualification process
  • Procurement information for EQ purchase requisitions
  • EQ maintenance requirements For 3QSS*P3A and SQSS*P38, EQR 113-0-1, contained in SP-M3-EE-353 (See DCN DM3-00-1833-97), qualifies GE motor model number SK828840C88 for application in a radiation harsh only environment. The EQR also provides justification that supports the qualification of these motors in their specific application to IEEE 323-1974, the intent of NUREG-0588 and NRC 10CFR50.49. The qualification of 3QSS*P3A and 3QSS*P3B are in full compliance with the FSAR statements in SAR Section 3.11B.2.2. When the TRA and EQR are reviewed I together with any calculations referenced in the applicable EQR, the entiro EEQ evaluation can be seen and the basis for qualification conclusions evaluated.

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

Previously klontified by NU7 O Yes (@ No Non Discrepent Condition?Q Yes ($ No Resolut6onPonding?O Yee (*J No Resoiuuanunresoived70 Yee (@ No Review Printed 3/2498 3:22:08 PM Page 2 of 3

ICAVP DR No. DR-MP3 0713 Northecct Utilities Millstone Unit 3 Discrepancy Report

" ' 2 2 "

^~ '

"****d "

s.

O O N VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K NtC Chmn: singh, Anand K osse: 3/13/98 st. Comments: The Class 1E General Electric (GE) Quench Spray Pump Motors I.D. No. 30SS*P3A/B and Model No. SK828840C88 are located in EQ Zone ES-02 in the ESF Building which is Harsh, Radiation ,

only area.

In the NU response, M3-IRF-01231, and SP-MS-EE 353, Appendix ll, Rev. O it is stated that these GE motors are environmentally qualified to IEEE 323-1974 requirements.

However, the NU document EEQ-TRA-113.0, Rev.1 dated 1/14/1997, Section 1.0 Page 3 of 7 states the following with regard to GE motors 3QSS*P3A/B (Model No. SK828840C88): *

" Contrary to GE's statement regarding the qualification to IEEE 323-1974 and 344-1974 on page iv of Ref. 5.1 ( GEK-42842," Topical Report IEEE 323 Class lE Induction Motors, Horizontal Class B insulated, Model Numbers SK821051C40, SK821054C26, SK828840C88"), the engineering analysis based on separate testing and operating experience, as presented in this GE Topical Report, satisfies the requirements of the DOR Guidelines and does not meet IEEE 323-74 requirements."

On the other hand, the NU EOR 113-0-1, Rev. 0 (page 1 of 5) states that " A sufficient test documentation collected in GEK-42842 adequately demonstrates the capability of the subject pump motors to meet their performance specifications under normal and accident environmental conditions, and supports the qualification of these motors in their specific application to IEEE 323-1974."

Please explain the difference between NU TRA-113.0, Rev.1 and NU EQR 113-0-1, Rev. O.

Printed 3/2493 322:10 PM P80e 3 of 3

DR No, DR-MP3 0929 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Review Group: configuration DR RESOLUTION REJECTED Potential Operability lseue Discipline: EW Design O yeo Diecrepency Type: Instellation implementation gg SystemProcese: HVX NRC SL!"Me level: 4 Date Faxed to NU:

Date Published: 1/18/90 D6screpency: Tray Supports not in accordance with design documents.

Description:

The following anomalies were identified between the as installed field conditions and the referenced design documents during system reviews and walkdowns.

1. Field condition of support A303-005 (Reference drawing EE -

34GA - Rev. 4) has a lighting fixture attachment on the bottom tray shelf near the SE verticalleg. No open document reviewed for this drawing discusses this.

2. Field condition of support A308-012 (Reference drawing EE -

34GA - Rev. 4) has an item "W" strut attached to the bottom tray shelf that is used to support lighting fixtures and cable outlets.

No open document reviewed discusses this.

3. Support A310-018 (Reference drawing EE -34GA - Rev. 4) has a tube steel brace attached to the north leg that runs to the ceiling. No open document reviewed discusses this. (The brace installed is similar to that shown on A311.)
4. Support A316-052 (Reference drawing EE -34GB - Rev 3) has an item "W" strut attached to the bottom tray shelf that spans north and south to support lighting fixturcs and components. Not discussed in documents.
5. Support A317A-056 (Reference drawing EE -34GB - Rev. 3) has conduit 3CX104PJ (1 1/2") attached via conduit support MA-884. No open document reviewed discusses this addition.
6. Support A325-035 (Reference drawing EE -34GC - Rev. 4) has item "W" strut attached which is used to support lighting fixture and an emergency light fixture. Also, there are two unused sections of 15/8" x 13/16" strut (B-line type B-52 strut) that are 4" long that attach to the NW vertical leg, one of which has rope tied to it. No open documents reviewed discuss these items.
7. Support A336-016 (Reference drawing EE -34GD - Rev. 4) has a ceiling brace attached to the south leg that is not shown on the support detail drawing. Also, there is an item "W" strut attached to the bottom tray shelf that is used to support lighting fixtures. No open documents reviewed discuss these items.
8. Support A344A-068 (Reference drawing EE -34GE - Rev.1) has an item "W" strut attached to the bottom tray shelf ,

spanning N-S, that is used to support lighting fixtures. Also, a cantilever of 3/4" conduit used to support emergency lights is p g "Wd tc 16 b^ttcm trcy 2c!! member. Mc ope': decggtg 3

ICAVP DR No. DR-MP3-0929 Northe:st Utilities Millstone unit 3 Discrepancy Report reviewed discuss these items.

9. The fittings / connections for the intemal diagonal "X" bracing that was removed by F-E-40516 were not removed in the field (Refercoce drawing EE -34GE - Rev.1).
10. Support A404-011 (Reference drawing EE -34GF - Rev. 3) has seven horizontal N-S members that span to adjacent supports that are used to route several vertical conduits. Three of these are identified as MA-80, MA 81 and MA-82. None of the open documents for this drawing discuss such a major addition and nothing is shown on the drawing.
11. Conduits 3CL925NC and 3CL925ND are attached to the fourth mernber (from the bottom). No open document discussed this addition to support A404-011 (Reference drawing EE -

34GF - Rev. 3).

12. Support A404-011 (Reference drawing EE -34GF - Rev. 3) has an item "W" strut attached to the bottom tray shelf member that is used to support lighting fixtures. No open document reviewed discusses this.
13. Support A435-046 (Reference drawing EE -34GJ - Rev.

1)has four members attached to outer side of east vertical leg that are supporting vertical conduit runs. No open documents reviewed discuss this. <

14. Support A435-046 (Reference drawing EE -34GJ - Rev.1) has two "AV" members attached to the inside of the vertical legs (one on each leg) that span north to A435-045. These members support four 2" conduits that run to panel 3RCS-PNL50 (one ID#

is 3CL170NQ). No open documents reviewed discuss this ,

addition.

15. Support A435-046 (Reference drawing EE -34GJ - Rev.1) has an item W strut attached to the bottom tray shelf mernber that supports lighting fixtures. No open document reviewed discusses this.
16. Support A440-056 (Reference drawing EE -34GJ - Rev.1) has a horizontal strut member installed above the brace member added by F-E-35951. This second member supports 2" conduit 3CK146NA. No open document discusses this.
17. Support A440-056 (Reference drawing EE -34GJ - Rev.1) has an item W strut attached to the bottom tray shelf member.

This is used to support a lighting fixture. No open document review discusses this.

18. Support A153C-013 (Reference drawing EE -34GR - Rev. 5) is used to support two 1 1/2" conduits (3CL201PA3 and 3CL201PA4).No open document reviewed discussed the addition of these conduits.
19. Support A164-038 (Reference drawina EE -34GS - Rev. 4)

Printed 3G4/96 3.11:54 PM Page 2 or 5

ICAVP DR No. DR-MP3-0929 Northecst Utilities Millstone Unit 3 Discrepancy Report has a lighting fixture attached near the N-W leg. No open document reviewed discusses this. Also, a flex hoseAubing run is attached to this support.

20. Support A174A-051 (Reference drawing EE -34GT - Rev. 6) has item BQ" strut labeled AB-8376 attached to bottom tray shelf member that is used to support a flex hosenubing run.

TSO2 lists conduit 3CX931BA (see F-E-33584) as attaching to this conduit support - not correct by field walkdown. Per F-E, conduit should be attached to vertical leg, not added horizontally. No open document reviewed addresses this.

21. F-E-33584 routes conduit 3CC932NH and lists support A174A-051 elevation 34'-6 as an attachment point. Field installation of this conduit is at elevation 35'-10" where A174A does not have any horizontal member. F-E is incorrect. Conduit spans 8'-0" which is acceptable without support at A174A-051 (Reference drawing EE -34GT - Rev. 6).
22. Support A181-061 (Reference drawing EE -34GT - Rev. 6) is used to support conduit 3CX208NY. No open document addresses this.
23. The detail drawing for support A198-016 (Reference drawing EE -34GT - Rev. 6) shows a " dummy" member installed at elevation 39'-6". No member is installed in field. No open document discusses this.
24. Support A205-031 (Reference drawing EE -34GU - Rev. 7) has three "AV" members attached to the south vertical leg that are used to route eleven conduits (e.g.,4"-3CX227NJ). No open documents reviewed discuss this addition.
25. The horizontal item "W" addressed by F-E-24126 to be )

added to support A209A-002 (Reference drawing EE -34GU -

Rev. 7) could not be found by the field walkdown.

26. Support A211-065 (Reference drawing EE GU - Rev. 7) has an attachment for a lighting fixture support on the bottom tray shelf member. No open document reviewed addresses this.

i

27. Support A216-020 (Reference drawing EE -34GU - Rev. 7) is used to attach a flex hose coaxial cable that exits and re-enters a cable tray. No open document reviewed addresses this attachment. Typical for support A221-014 (Reference drawing EE -34GV - Rev. 6).
28. TSO2 lists support A1010-006 as a support for tray 3TC1030. The installed tray is routed horizontally on members associated with sections 5-5,6-6,7-7,8-8 and 42-42 and is a vertical run on members associated with section 9-9. The riser supports are attached to members. The total number of tray attachment points is 11. TSO2 lists nine supports: A55-001, A66-002, A77-003, A88-004, A99-005, A1010-006, A1515-011 and A1616-012 associated with drawing EE-34DS and A11-010 associated with drawina EE-34MJ. A11-010 is not identified on Printed 3/2N96 3:11:55 PM Page 3 of 5

l Northeast Utilities ICAVP DR No. DR-MP3-0929 l

Millstone unit 3 Discrepancy Report drawing EE-34MJ, but section 42-42 of DS is shown on MJ.

Sections 15-15 and 16-16 are assumed to be what TSO2 identifies as A1515-011 and A1616-012, yet these sections of l EE-34DS and EE-34MK have no role in supporting tray 3TC1030. Support numbers in TSO2 cannot be directly found on referenced drawings - only found by inference. (Reference drawings EE MK - Rev. 3, EE DS - Rev. 4 EE MJ -

Rev. 3)

29. Cable tray 3TC163N does not have any supports listed in TSO2. Field walkdown located tray in position shown on drawing EE -34DS - Rev. 4 (C-5) where a member spans between sections 8-8 and 9-9 at elevation 37*-9". The tray is attached to this member and then routes down and north through a wall penetration. One support should be listed for tray.
30. Cab lo tray 3TC166N is routed horizontally at elevation 5'-0".

It does not route vertically from this level -tray is then 3TC161N. Five supports for tray 3TC166N are members at the bottom of section views 5-5,6-6,7-7,8-8 and 9 that are shown on drawing EE-34MK. No part of this route is referred to drawing EE-34MJ, and also, no part of drawing EE-34MJ shows anything identified as A12-028. (Reference drawings EE -34MJ -

Rev. 3, EE -34DS - Rev. 4)

31. Cable tray 3TX1060 is shown on section 2-2 on drawing EE-34DS and is routed horizontally on horizontal members associated with section views 11-11,12-12.13-13,14-14 and 15-15 which are shown as details on drawing EE-34ML. The tray is also routed vertically on two members shown at elevation 13'-6" and 19"-6" on drawing EE-34DS. These members are detailed in section view 43-43, which is shown on drawing EE-34MJ Rev.
3. No member is identified as A22-024 on any drawing. Tray 3TX1060 is attached at seven points in the field, which matched drawing EE-34DS Rev. 4 information.
32. An addition to cable tray 3TC2070 was made by F-E-22975 in which a hortzontal cable tray was installed and supported by four new hangers. A250, A254 and A255 types are shown in sketches in the F-E, but no location plan changes were made to show an individual number for each support. Two type A250's were installed and found by field walkdown, but no determination - of which one is A250-072 - could be made based on the documents available.

I

33. An addition to cable tray 3TK2080 was made on the 66 elevation but no open document reviewed provided any documentation for this addition. As such, no support type A252 drawing was found, nor can any support be located with the identification of A252-077 as installed on the tray section.
34. TSO2 indicates tray 3TC139P has a support numbered Support A33-040. No drawing lists a support with A33-040.
35. A 1/2" conduit is attached to the upper portion of the north vertical leo of support A310-018 (Reference drawino EE -34GA -

Printed Y24r98 3:11:56 PM Page 4 of 5

Northe:st Utilities ICAVP DR No. DR-MP3-0929 millstone unit 3 Discrepancy Report Rev. 4) and also makes an attachment to the steel structure shown in section view 10-10 on EE-34DS Rev. 4 and EE-34MK Rev. 3. The lighting conduit addition is not addressed in any open document reviewed for these drawings.

Review Valid invalid Needed Date initiator: sanw, T. L.

O O O 1/2/98 VT Lead: Nori, Anthony A O O O 1/5/98 VT Mgr: schopfer, Don K O O O is2/98 RC Chmn: Singh, Anand K O O O ' 488 Date:

INVALID:

Date: 3/16/98 RESOLUTION NU has concluded that Discrepancy Report, DR-MP3-0503, 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 M3-98-0513 has been written to develop and track resolution of this item per RP-4.

Previously identlSed by NU7 O Yes (9) No Non Discrepent Condition?O Yes (#) No Resolution Pending?O vos @ No w % unresoev.d? O v.s @ No Review Ace h Not AccPh Needed Date N

VT Lead: Neri, Anthony A VT Mgt: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/16/98 ,

sL Comments: Adequacy of the supports for the revised configurations and/or additional loads needs to be verified prior to start-up for the DR ltems numbered 5,10,11,13,14,16,18,22,24,25 and 33.

Printed 3/24/98 3:11:58 PM Page 5 of 5

Northe:st Utilities ICAVP DR No. DR-MP3-1066 Millstone Unit 3 Discrepancy Report Review Group: Pruy-,,,. &. DR RESOLUTION REJECTED Review Element: Correceve Achon Procese Diecipline Other r"-- my Type: Correcove Achon Om System /Proceae: Rss g~ g NRC $lgnificence level: 4 Date faxed to NU:

Date Putnished: 2/2398 Discrepency: Significance Level for ACR 10382

Description:

The Reportability Evaluation which was performed determined that the concem was reportable pursuant to 10CFR50.72(b)(2)(iii) and 50.72(b)(1)(ii). The evaluation concluded that a selmic event could have resulted in the loss of one of two heat exchangers in each of the two trains of RCG.

The ACR was assigned as significance level D. Given the circumstances, it is considered that the significance level assigned was not appropriate and that root cause determination should have been performed.

Review Valid invahd Needed Date initletor: Neverro, Mark 8 O O 2/17/98 VT Leed: Ryan, Thomme J O O O 2/17/98 vi Mgr: schopfer, Don K B O O 2/1e/98 IRC Chmn: singh, Anend K O O O 2/19/98 Date:

INVAUD:

Detc 3/17/g8 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1066, does not represent a discrepant condition. It is correct that ACR 10382 classified the significance of the issue as Level D which did not warrant a formal root cause investigation.

In March 1996, when the ACR was initiated, the corrective action program was govemed by procedure RP-4, rev 1, " Adverse Condition Resolution Program." Revision 1 did not provide guidance for the assignment of significance levels to issues requiring a Licensee Event Report (LER). Although a formal root cause analysis was not performed, the LER provided a statement of apparent cause and the actions taken to prevent reoccurrence. Corrective actions implemented as a result of ACR 10382 included inspections of all safety related areas of the plant to ensure no temporary equipment or rigging material posed a condition which would hinder the operation of the plants safety related system. Operations Department implemented a program to routinely walkdown the plant, evaluating temporary material. The Work Control procedure, WC-1, was revised to provide the requirement for storage and use of temporary equipment.

Additionally, the Millstone Corrective Actions Program was significantly upgraded in February,1997 following the performance of QAS Audit QAS-96-4108, dated June 19,1996, Printed 374Se 3.12:35 PM Page 1 of 3

i 4

1 Northeast Utilities ICAVP DR No. DR-MP3-1066 milistone Unit 3 Discrepancy Report and the Corrective Action Plans for ACR-13318 and CR M3 0111. The goveming procedure, RP-4, provides specific guidance to the Management Review Teams on the significance level classification of Condition Reports (CRs) . Specifically relating to the subject matter of this DR, RP-4 ensures that all CRs which are determined to describe a condition which is reportable are assigned our highest significance level of 1.

Significance level 1 issues require a formal root cause analysis.

Significance Level Criteria do not apply here as these are not discrepant conditions.

Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1066, does not represent a discrepant condition. NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1066, does not represent a discrepant condition. RP-4 Rev 1 which was in affect at the time of ACR 10382 did not provide guidance for establishing a significance level which requires a root cause analysis for reportable events. Station management has implemented program improvements independent of this DR which have corrected the root cause of this error.

Significance Level Criteria do not apply as these are not a discrepant conditions.  !

Previoudy identmed by NU7 U Yes (G) No NonDescrepentcondition?U Yes (9) No naosuisonPeneno70 Y= @ No naowonunr=wved70 va @ No

n. view

%. %p Acceptable Not AnM Needed DWe VT Leed: Ryan, Thomes J h

VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Dete: 3/17/98 sL conenents: There are two issues noted in the DR.

1. The first issue is that the ACR significance level which was assigned by the licensee was inappropriate given the circumstances. Contrary to the Licensee's response, procedural j

guidance which existed at the time (if properly followed) would not have resulted in assignment of the issue as significance level D.

RP 4, rev.1 states on page 2 that significance levels assigned in the ACR process shall be per NGP 2.40. NGP 2.40 Rev.1 identifies significance level D for issues which are not significant noting that the significance of issues determines the depth of the evaluation and action plan development. Attachment 8A, page 8A-2 of 3 of NGP 2.40 identifies factors which are considered as aggravating or mitigating the significance associated with a given issue. Among these factors is Potential Consequences. While noting improved guidance in procedures which now exist for assignment of significance level, given the potential consequences documented in the reportability evaluation which was included in the ACR 10382 package and the guidance <

' Printed Y2496 3.12:30 PM PeGe 2 of 3

Northecst Utilities ICAVP DR No. DR-MP3-1066 Millstone Unit 3 Discrepancy Report contained in the procedures noted above that existed at the time, the classification of this ACR as significance level D was not appropriate.

2. The second issue is that a root cause determination should have been performed. NGP 2.40 further states that significance level A or B require root cause analysis per NGP 3.15. Since the ACR significance level was not assigned as A or B, a root cause evaluation was not performed. However, we believe the events documented in the ACR met the entry criteria for performing an RCE. Section 6.2.2 of NGP 3.15 Rev. 2 states "upon determination that a significant event or problem has occurred, line management shall assign a lead evaluator to perform an RCE." The reportability evaluation which was documented in the ACR package concluded "that unsupported beams above 3RSS*E1A&D was a or,ndition alone, that given a seismic event could have resulted in the loss of one of two heat exchangers in each of two trains of MSS. This...was a condition that could have resulted in a loss of safety function of the RSS, and pc;entially a breach of containment since the RSS suction valves are normally open to the containment sump. The historical condition would thus, also involve a condition outside the design basis, since the single seimic event could have resulted in the plant having multiple trains incapable of performing their design basis function."

Summary:

Based on the above and given that the apparent cause discussed in the LER is not the same as a formal root cause evaluation, NU's response should specifically address the need/ benefit of performing an RCE for this historical issue. I l

Prtnied 3/2496 3;12A0 PM Page 3 of 3 j

I Northe:st Utilities ICAVP DR No. DR-MP3-1086 l Millstone Unit 3 Discrepancy Report Review Group: Programmehe DR VAllo Review Element: Corrome Achon Process p

Diecipline: Moctonical Dwign Discrepancy Type: Corrective Action implementatea O vee SystemProcese: N/A g NRC Significance level: 4 Date faxed to NU:

Date Putdiohed: 3/27/98 Diecrepancy: Closure of UlR 1144 l

Ducription: UlR 1144 was closed to CR M3-97 2789. AR 97021317-02 (related to CR M3-97-2789 and indicated as status complete in assignment tracking) was completed based on an engineering evaluation which was documented in Memo MP3-DE-971415 dated October 8,1997. This memo documents the Licensee's review to demonstrate that all associated components and component supports will safely perform their design functions at low temperatures (down to 32F) in the Auxiliary Building.

Affected components include but are not limited to the CCPs, CCP heat exchangers and their supports. Previously issued discrepancy report DR MP3-0670 identified calculation 3-92-103 M3 Rev.1, including CCNs 1 to 5 has results which indicate that minimum temperatures below 32F can be reached in the CCP room, noting that the calc shows a supply air temperature of j

about 16F to the CCP pump /HX area. Closure of UIR 1144 is not '

acceptable because:

1. Evaluation documented in Memo MP3-DE-97-1415 needs to be re-run based on lowest calculated temperatures . (Note: This may be addressed as part of NU's response to DH 670 and closure of CR M3-97-2789.)
2. The technical evaluation which supports the capability of auxiliary building SSCs to perform their design basis functions at the lower auxiliary building ternperatures should be established on design controlled document (s) to ensure configuration management.

Review Valid invalid Needed Date initiator: Neverro, Mark 8 O O 3'17/88 VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K B O O S'17/98 O O O 3'17/98 IRC Chmn: singh, Anand K O O O 3r2398 Date:

INVALID:

Date:

RESOLUTION Previously identified by NU7 O vos (9) No Non CL- 1 Condition?O vos (9) No R=ohnion e.ndine70 va @ No R=*uon unr=*ed70 va @ No Review Aerar* h Not Accep8h Needed Date VT Lead: Ryan. Thomme J O O O Printed 3/24/96 3.13.13 PM Page 1 of 2

i 1 k

Northerst Utilities ICAVP DR No. DR-MP3-1086 Millstone Unit 3 Discrepancy Report w a -- n m i, . . . . - ,,

VT Mgr: Schopfer. Don K O O O IRC Chmn: Singh, Anand K l Date:

sL Comments:

l I

l Printed 3/2496 3.13:16 PM Page 2 of 2 l

J