ML20217H531
| ML20217H531 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/28/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9804300001 | |
| Download: ML20217H531 (15) | |
Text
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Don K. Schopfer Senior Vice President 312-269-6078 April 28,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Enclosed are discrepancy reports (DRs) identified during our ieview activities for the ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.
I have enclosed the following five (5) DRs for which the NU resolutions have been reviewed and j
accepted by S&L.
l DR No. DR-MP3-0007 DR No. DR-MP3-0941 DR No. DR-MP3-0130 DR No. DR-MP3-1078 DR No. DR-MP3-0679 Please direct any questions to me at (312) 269-6078.
Yours very truly, 4
/
9804300001 980429 D. K. Sc iopfer k
g PDR ADOCK 0500 3
Senior Vice Presidst and
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ICAVP Manager DKS:spr ggg7 0
Ericlosures D
l Copies:
E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU mNeavp'corrStar04284 doc 55 East Monroe Street
- Chicago, IL 60603-5780 USA
- 31M69 2000
i N6rthert Utilities ICAVP DR N3. DR-MP3-0007 Millstone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Other Discrepancy Type: Design control Procedure g
SystenVProcess: N/A NRC Significance level: 4 Date faxed to NU:
Date PutWshed: 7/10/97 Discrepancy: Use of Unverified Information Ducription: We have reviewed Millstone Station Procedure DC 2, Rev.1, Change 3 (effective 3/3/97), titled " Developing and Revising Millstone Procedures and Forms". Based on this review, we have noted the following discrepancy.
When, while revising a procedure, reference information is not available, paragraph 1.2.8.b and Attachment 2 of DC 2 require the Procedure Writer to place an empty basis box in the appropriate location (of the procedure) with the following content:
" Reference information not currently available." During the procedurs verification and validation process, the Independent Reviewes, with the Department Head's concurrence, determines whether the document can be approved without verifying reference information.
Thus, a procedure can be revised with unavailable reference information. There is no review by the PORC/SORC or a subcommittee to evaluate the risk of implementing the procedure with this missing information, and no requirement is imposed to try to recreate the reference material later, This is a discrepancy because unverified information could be used as the basis for a procedure.
Review 6
Valid invalid Needed Date initiator: Sheppard, R. P.
O O
O 7/7/87 VT Lead: Ryan, Thomas J B
O O
7/7/97 VT Mgr: Schopfer, Don K O
O O
7/7/97 IRC Chmn: singh, Anand K O
O O
7/7/97 Date:
INVAUD:
Date: 4/24/98 RESOLUTION: Disposition:
The purpose of the procedure basis document is to facilitate the process of revising and reviewing procedures. The basis document provides specific information regarding the source of technical material as well as other information such as the reason a modification has been made. Since this information does not appear in the user's version of the procedure it will not influence the expected outcome of a procedure. The references which support the technical content of a document must be listed in the document's References Section. The technical content is also assured by requiring that personnel who prepare, revise, and review procedures are proper 1y qualified to do so. This Printed 4/25D011:30:44 AM Page 1 of 3
Northert Utilitie3 ICAVP DR N:. DR-MP3 0007 Millstone Unit 3 Discrepancy Report requirement is not changed by the unavailability of basis information.The Verification piocess, performed as an integral part of every change and revision made to a procedure, requires the Independent Reviewer to concur that any missing Basis information has no impact on the technical accuracy of the I
procedure's content and the Department Head to further agree that the document can be approved for use as-is. Attachment 1, letter B18296 to the NRC, " Clarification of Pmvlous Information on Procedure Basis information," provides additional supporting information.
==
Conclusion:==
{
DC 2 requires that the references which support the technical content of a document be listed in the document's References I
Section. The procedure basis sections serve as an informational tool to aid when reviewing, changing or revising a procedure and t
do not contain information which would be used during
)
performance of the procedure. This conclusion is supported by the attached docketed correspondence (Attachment 1, letter B16296 to the NRC, " Clarification of Previous information on Procedure Basis Information."). Therefore,we do not consider this item to be a discrepancy. No further action is required.
2nd Response:
Disposition: The original DR prepared by S&L stated "This is a l
discrepancy because unverified information could be used as the I
basis for a procedure." The NU response explained that the review and verification process is considered adequate to preclude the use of unverified information which would impact i
the expected technical outcome of the procedure. However, NU has determined that the provisions of DC 2, Paragraph 1.2.8.b.
are unnecessary. Change 4 has been issued to delete this paragraph and the related section in Attachment 2.A review of Unit 3 Condition Reports found no instance where the use of I
"unverif6d" information in the basis document caused a techr; cal deficiency in the implementing document. Thus, there is no discrepant condition.
==
Conclusion:==
NU continues to believe that the issue reported in Discrepancy Report DR-MP3-0007 does not represent a discrepant condition.
Based on the review of Unit 3 Condition Reports, NU concludes that the provisions of DC 2 for technical review and verification are adequate to prevent inappropriate use of unverified information. However, since DC 2 paragraph 1.2.8.b is considered to be unnecessary, this provision has been deleted as part of Change 4 to DC 2.
Previously idenufied by NU? O Yes
(#1 No Non Discrepant Condition?O Yes (S) No Resolution Pending?O Yes
'7G) No Resolution Unresolved?O Ye.
@ No Review initiator: sneppard, R. P.
VT Lead: Ryan. Thomas J Printed 4/28/9811:30:48 AM Page 2 of 3
1 Nlrthert Utilitie3 ICAVP DR No. DR-MP3-0007 Millstone unit 3 Discrepancy Report
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VT Mgr: schopfer, Don K j
g IRc Chmn: Singh. Anand K Date:
4/24/98 st. comments: Review of First Response:
NU's responr,e is acceptable for the Basis Document discussed in paragraph 1.2.8.a and Attachment 2 of DC 2.
Paragraph 1.2.8.b of DC 2 deals with both Basis Documents and references in the procedure. NU's response does not resolve the discrepancy noted for paragraph 1.2.8.b of DC 2 as it relates to references listed in the procedure which cannot be found.
)
We believe Procedure DC 2 should be revised to state that revisions to a procedura with missing references may only be approved when the missing information has no effect on the contents of the revision. In addition, the extent of the condition for past procedures developed following DC 2, paragraph 1.2.8.b should be addressed.
Review of Second Response:
We accept the NU resolution, but disagree that this is not a discrepancy since we believe that Procedure DC-2 was unclear.
Any further discussion of the discrepancy status should be referred to the NRC. NU's finding that past Condition Reports do not reveal any procedural technical deficiencies due to unverified
)
reference information, the findings from Sargent & Lundy's review of past procedure changes which support this conclusion, and the corrective actions which have been taken in response to DR No.
DR-MP3-0624 conceming the control of vendor tecnnical information resolve this issue for past procedure changes.
Further Review:
Based on a 4/22/98 telecon, NU agreed that the problem with i
Procedure DC-2 was a discrepancy. Since there were no i
problems with other procedures found which were caused by the wording in DC-2 nor was there a clear violation of the licensing basis, the Significance Level was reduced to Level 4.
1 Printed 4/28/9811:30:50 AM Page 3 of 3
DR N2. DR-MP3-013[
Nirthert Utilities ICAVP Millstone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Rev6ew Element: Corrective Action Process p
Discipline: Mechanical Design g
Discrepancy Type: Conective Action Om SystanVProcess: sWP NRC Significance level: NA Date faxed to NU:
Date Published: 9/22/97 Discrepancy: Inadequate Cor7ective 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 effectiveness of the corrective action." in neither case has the l
action to correct the causal factors been addressed, i.e.,
j inadequate Safety Evaluations. The same applies on page 4 of for of Form RP 4 7, block 7 which requires a statement identifying, "...how the corrective actions will effectively prevent or reduce the possibility of the same or a similar event or adverse condition from happening again..." This section in ACR M3-96-0041 has nothing entered, while the entry for ACR M3 0920 is inadequate in that it does not describe how the corrective action will prevent recurrence.
Review Valid invalid Needed Date initiator: Wrone. S. P.
B 0
0 S/S/97 VT Lead: Ryan. Thomas J G
O O
o/12/97 VT Mgr: schopfer, Don K G
O O
S/15/S7 IRC Chmn: singh, Anand K 8
0 0
S/17/S7 Date:
INVALID:
Date: 4/23/98 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report, OR-MP3-0130, does not repreeent 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 IDENTIF-Y 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 i
1, the required causal factor determination process was to identify corrective achons required for this adverse condition and Printed 4f28/9e 11:29 47 AM Page 1 of 4
i Nirtheast Utilities ICAVP DR N s. DR-MP3-0130 Millstone Unit 3 Discrepancy Report i
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.
j 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.
NU's second Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0130, has identified a condition previously discovered by NU which required correction. Based on review of the documentation associated with DR-MP3-0865, NU concurs with Sargent &
Lundy's assessment that this discrepancy report reflect the same conclusions made in Discrepancy Report DR-MP3-0865. DR-MP3-0865 made reference to the same ACRs contained in this discrepancy report indicating that the actions to prevent reoccurrence failed to address the weaknesses found in the safety evaluation screening process. NU has acknowledged this weakness on a site wide level and has begun to institute an intensive training effort in the process of safety evaluation screening and the preparation of safety evaluations to the Millstone staff.
The discrepancy, regarding ACRs that were dispositioned with l
incomplete corrective action, has been previously identified via ACR M3-96-0925 which was written on 10-07-96. This ACR was written to address the inadequacies in the corrective action piogram identified by the NRC in NRC Inspection Report 96-201; l
these include inadequately detecting and correcting problems, inadequately monitoring the completion of required actions and the failure to assess the effectiveness of corrective actions taken to prevent reoccurrence. The NU Report entitled " Common l
Cause Assessment of Apparent Violations at Millstone Nuclear Station', dated 12/16/96, determined the root causes associated with these inadequacies and recommended corrective actions.
The corrective actions associated with this ACR included the issuance of Revision 4 to RP-4, which was implemented on 2 97 and the establishment of a Corrective Action Manager with a supporting staff. This department is responsible for firmly establishing accountability and ownership for identifying, reporting and evaluating problems including tracking and implementation of corrective actions. Adverse Condition Reports (ACRs) are submitted and receive review of a multi-dbcipline team to ensure that ownership and the appropriate level of significance is attached to identified problems.
Significant ACRs receive multi-discipline management review for appropriate evaluation and corrective action plans. Procedures have been revised to ensure the ACRs remain cpn until the Pmted 4/28/9811:29.5o AM Page 2 of 4 a
Nirthext Utilitiea ICAVP DR N2. DR-MP3-0130 Millstone Unit 3 Discrepancy Report corrective actions are complete.
The discrepancy, regarding inadequate safety evaluations and safety evaluation screenings that could result in a failure to perform required safety evaluations, has been previously identified via ACR M3-96-0924 which was written on 10-07-96.
This ACR was written to address the significant weaknesses in the performance of safety evaluations identified by the NRC in NRC Inspection Report 96-201. The NU Report entitled
" Common Cause Assessment of Apparent Violations at Millstone Nuclear Station', dated 12/16/96, determined the common root causes associated with these weaknesses and recommended corrective actions. The corrective actions associated with this ACR resulted in the issuance of Revision 10 to NGP 3.12, which became effective on 3-1-97. Additionally, the corrective actions ensured training was provided, to this revised procedure, for all j
personnel who perform safety evaluations, and for the oversight J
and review organizations This revision to NGP 3.12 centralized j
the screening requirements and provided improved guidance on screenings and the preparation of s&fety evaluations; prior to this revision, safety evaluation screenings were controlled by Individual implementing procedures. The Millstone Unit 3 Corrective Action Program Trend Report for 2nd Quarter 1997, dated 8-29-97, identified that the actions taken to resolve it,e significant weaknesses in the performance of safety evaluations identified by the NRC had not been totally effective resulting in several implementation and programmatic errors occurring in the 2nd quarter. The trend report notes that these findings have been included in the root cause analysis for CR M3-97-1955 and the adverse trend is being addressed by the corrective actions associated with this CR. The corrective actions associated with each of the CRs identified above have resulted in many additional changes to the safety evaluation screening process and associated training including the following to improve the quality of safety evaluations and safety evaluation screens:
0 Millstone management has developed a set of expectations for preparing and documenting safety evaluation screens and safety evaluations. These expectations have been provided to approvers of these documents at a series of intervention sessions that took place between July and November 1997.
OThe goveming procedure, NGP 3.12, Revision 10, will be replaced by a new Millstone procedure (RAC 12) with an effective date of March 1,1998. The new procedure has additional guidance for preparing safety evaluation screens and safety evaluations which address the types of problems identified in many poor 1y written safety evaluations and safety evaluation screens. RAC 12 requires that preparers, reviewers arid approvers of safety evaluation screens and safety evaluations meet consistent training and qualification requirements.
0 Additional training is being developed and will be added to these requirements when the lesson plans have been developed and approved (expecte J May 1998).
PrWed 4/28/9611:29.50 AM Page 3 of 4
Nhrthert Utilitica ICAVP DR N2. DR-MP3-0130 Millstone Unit 3 Discrepancy Report These additional improvementt, to the wifety evaluation program are expacted to significantly impruve the quality of the safety evaluation screens and safety evaluatichs at Millstone.
NU's second
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0130, has identified a condition previously discovered by NU which required correction. NU's position on this condition has changed, from nondiscrepant to a prediscovered condition which required correction, based on re-evaluating the documentation of discrepancy report DR-MP3-0865. The original response to DR-MP3-0130 reported under M3-lRF-00469, appeared to have only considered the data as isolated cases and did not identify the trend of similar events. A formal root cause analysis for CR M3-97-1955 and the adverse trend is being addressed by the corrective actions associated with this CR. The corrective 1
actions associated with each of the CRs identified within CR M3-
)
97-1955 above have resulted in many additional changes to the safety evaluation screening process and associated training to improve the quality of safety evaluations and safety evaluation screens. Changes will include extensive training to plant staff, increased management expectations and standards. M3-lRF-00469 failed to identify the efforts to retrain the plant staff prior
)
to responding to discrepancy report DR-MP3-0130.
Previously identified by NU? ($ Yes O No Non Discrepent condition?O Yes (e) No Resolution Pending?O ve.
@ No ResoMion Unresolved?O ve. @n Review initiator: Neverro, Mark VT Lead: Ryan, Thomas J VT Mgt: schopfer, Don K IRC chmn: singh, Anand K Date:
4/23/98 sL comments: S&L comments to NU's first response:
S&L agrees with the response as it pertains to the specific requirements which were applicable at the time for assigned level D significance ACRs. However, the issue identified in this DR is the same issue noted in DR-MP3-0865. 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.
S&L comments to NU's second response:
NU's response is acceptable Printed 4/28/9811:29:52 AM Page 4 of 4
Nhrtheast Utilities ICAVP DR N2. DR-MP3-0679 Millstone Unit 3 Discrepancy Report
{
l Review Group: Operations & Maintenance and Testhy DR RESOLUTION ACCEPTED Review Element: Operating Procedure Potential OperabiHty issue Discipline: Operatons
@) y,
Discrepancy Type: 0 & M & T Procedure O No System / Process: DGX NRC Significance level: NA Date faxed to NU:
Date Published: 12/14/97 Discrepancy: Surveillance procedure designates a load range that is 186 kW less than the TS requirement
==
Description:==
Technical Specification 4.8.1.1.2.b states:
"At least once per 184 days, verify that the diesel generatot starts and attains generator voltage and frequency of 4160 i420 and 60 *0.8 Hz within 11 seconds after the start signal. The l
generator shall be synchronized to the associated emergency l
bus, loaded to greater than or equal to 4986 kW in accordance l
with the manufacturer's recommendations, and operate with a l
load greater than or equal to 4986 kW for at least 60 minutes.
l l
The " Technical Specification Surveillance / Testing for
=
Requirement Cross-Reference to actual Plant Procedure for all l
Tech. Specs." database identifies SP 3646A.1, " Emergency Diesel Generator A Operability Test" as the controlling procedure l
that satisfies the requirements of TS 4.8.1.1.2.b. SP3646A.1 identifies OP Form 3646A.1-1, " Emergency Diesel Generator A Operability Tests" as the data sheet for establishing the T/S acceptance criteria and documenting the test results.
Both SP3646A.1 and OP Form 3646A.1 1 acceptance criteria for load is 4,800 to 5000 kW. and therefore designates a load range I
that is 186 kW less than the Technical Specification requirement.
4 Review Valid invalid Needed Date initiator: Tamlyn, Tom O
O O
11/1 *97 1
VT Lead: Bass, Ken G
O O
11/17/97 VT Mgr: schopfer, Don K B
O O
12/1/97 1RC Chmn: singh, Anand K O
O O
12/5/97 Date:
INVALID:
Date: 4/23/98 RESOLUTION: Disposition:
i l
NU has concluded that Discrepancy Report, DR-MP3-0679, 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 beer screened per U3 PI-20 criteria and found to have no operability oi reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0169 has been written to develop and track resolutio1 of this item per RP-4.
Conclusion-Pnnted 4/28/9811:31:25 AM M41 of ?
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1
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Nhrthert Utilities ICAVP DR N3. DR-MP3-0679 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report, DR-MP3-0679, 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 M3-98-0169 has been written to develop and track resolution of this item per RP-4.
Revised response received on 4/22/98 Disposition:
NU has concluded that the overall issue reported in Discrepancy Report, DR-MP3-0679 does not represent a discrepant condition.
Further investigation has determined that the TS 4.8.1.1.2.b was revised to 4800 to 5000 Kw on May 12,1995. Significance level criteria do not apply as this is not a discrepant condition.
Concliision:
NU has concluded that the overall issue reported in Discrepancy Report, DR-MP3-0679 does not represent a discrepant condition.
Further investigation has determined that the TS 4.8.1.1.2.b was revised to 4800 to 5000 Kw on May 12,1995. Significance level criteria do not apply as this is not a discrepant condition.
~ Previously identified by NU? O Yes (G) No Non Diecrepent Condition?(#) Yes O No Resolution Pending?O Ye.
@ No Resolution Unresolved?O Ye.
@ No Review Initiator: Speer, R.
VT Lead: Bass, Ken VT Mgr: Schopfer, Don K 1RC Chmn: Singh. Anend K Date:
4/23/98 sL comments: S&L does not concur with NU's determination that this discrepancy meets the Unit 3 deferral criteria. The DR Identifies a discrepancy bet'veen the FSAR and plant procedures which have a direct impact on plant safety and operation.
S&L Comments regarding revised responsed received 4/22/98:
S&L concurs that this DR does not represent a discrepant condition. This determination is based on the additional information that was provided with the revised response. NU's identification of Amendment number 137 to the Technical Specification provided the verification that the Technical Specificatioa acceptance criteria and Surveillance procedure SP 3646A.1 including the associated OPS FORMS are consistent.
It should be noted that the date of Amendment 137 to the Technical Specification is 4/15/98 and not May 12,1995 as stated in NU's response.
Printed 4r28/9811:31:29 AM Page 2 of 2
Ni:rtheast Utilities ICAVP DR N2. DR-MP3-0941 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Test Procedure Discipline: Operations Om Discrepancy Type: Correctue Action implementation g'-
l SystenVProcess: Oss I
NRC S%nificance level: 4 Date faxed to NU:
Date Published: 1/22/98 Discrepancy: Unable to confirm that commitment in LER 94-007-00 was met.
==
Description:==
SP 31024, Calculation of Reactor Trip and ESF Response Times is the only procedure that matches the description of the procedure referenced in the subject LER. SP 31024, Attachment 9, Page 81, F<eactor Trip and ESF Component Response Times, requires transferring data from other surveillances into one of three tables. The review concludes that this portion of the r
attachment cannot be completed as written.
The first end second tables reference data collected from the Quench Spray (Without LOP) surveillance OPS Form 3909.9-2.
The listed valves, QSS*MV34A & B, are apparently incorrect equipment numbers. Only valves 3OSS*AOV27 & 28 are listed on OPS Form 3909.9-2. If the correct valve numbers are QSS*MOV34A & B then the referenced forms should be OPS Form 3609.9-3 and 4.
The third table references data collected for valves 3QSS*MV34A & B from the Quench Spray (With LOP) surveillances. Again the valves referred to appear to have incorrect equipment numbers. No source document is identified for this information.
It is unclear, once the data has been collected for these valves, how the data is used to perform calculations or what requirement the calculations support.
The commitment also states that SP 31024 will be revised prior to its next use. SP 31024, Revision 10 through Change 3 were reviewed using OSCAR. None of the changes reference a revision to page 81. RFI 170, item 14 requested "SP 31024, Latest Results". The data provided is dated mid 1995 but was not included with these documents. Therefore it cannot be resolved by this review if this commitment has been satisfied.
Review Valid invalid Needed Date initiator: Tamlyn. Tom O
O O
12/3i/97 VT Lead: Bass, Ken O
O O
1/6'S8 VT Mgr: schopfer, Don K O
O O
/ 2/98 IRC Chmn: Singh, Anand K O
O O
1'17'S8 Date:
INVALID:
J Date: 4/23/g8 RESOLUTION Disposition:
Pnnted 4/28/9611:3i:59 AM Page 1 of 3
I Nhrtheart Utilities ICAVP DR N3. DR-MP3-0941 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-0941 describes a discrepant condition pre-discovered by NU for which corrective action is complete. Errors in procedure SP 31024 identified in the discrepancy report were found during procedure reviews and corrected with the issuance of SP 31024, Revision J
- 3. Actions required by LER 94-007-00 have been completed such that acceptance criteria in QSS system valve stroke test procedures and SP 31024 now ensure implementation of the limits stated in the Technical Requirements Manual (TRM).
The tables contained in Attachment 9, page 81 of SP 31024, Rev. 2 have become Attachment 2 and 3, Tables 13 and 14 in SP 31024, Rev. 3. The following has been corrected in Revision 3:
(1) The equipment numbers have been corrected to 3QSS*MOV34A/B, which is consistent with the system flow diagram.
(2) Revision 2 incorrectly referenced OPS FORMS 3609.9-1 and 2 to obtain valve response times. Revision 3, Table 13 correctly directs the user to the chart recorder printout attached to OPS l
FORM 3646A.8-3 as the source.
The discrepancy report stated that it is unclear how the data is used. The data is collected in accordance with the instructions of Section 4.1 of SP 31024, Rev. 3, and is then transferred to as directed by Step 4.4.9 Data for the QSS valves is evaluated in Attachment 1, pages 25 and 28. Note that the acceptance criteria is consistent with the TRM.
Closure of LER 94-007-00 is stated in Commitment Record 18440, which identifies SP3609.9, TRM Table 3.6.3-1 and TRM Table 3.6.3. Revision 3 of SP 31024 is consistent with the requirements stated in the TRM.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0941 describes a discrepant condition pre-discovered by NU for which corrective action is complete. Errors in procedure SP 31024 identified in the discrepancy report were found during reviews of the surveillance procedures and corrected with the issuance of SP 31024, Revision 3. Actions required by LER 94-007-00 have been completed such that acceptance criteria in QSS system valve stroke test procedures and SP 31024 now ensure implementation of the limits stated in the Technical Requirements Manual. Instructions in SP 31024 direct the collection, compilation and evaluation of data.
Previously identifled by NU7 O yes (s) No Non D6screpent Condition?O ves @) No Resolution Pending70 v
@ No R iunon unr oiv.d70 vs.
@ No Review Acceptable Not Ac+-Y - Needed Date VT Lead: Bass, Ken VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Printed 4/28/9811:32.o2 AM Page 2 of 3
1 i
Nhrtheast Utilities ICAVP DR No. DR-MP3-0941 l
Millstone unit 3 Discrepancy Report i
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O Date:
4/23/98
{
st. comments: NU Indicated in their response that this is a discrepant condition l
pre-discovered by NU for which corrective action is complete.
The corrective action included making changes to procedure SP 31024, Calculation of Reactor Trip and ESF Response Times.
This procedure change has a PORC Meeting date and Effective 4
t t
date of 2/9/98 which is after the system cut off date of 5/27/97.
Therefore, the Discrepancy Record is marked as not previously identified by NU and as a discrepaM condition.
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l Printe 478G011:32:04 AM Page 3 of 3
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Nhrthe:st Utilities ICAVP DR N. DR-MP3-1078 I
Millstone Unit 3 Discrepancy Report Review Group: Programrnatic DR RESOLUTION ACCEPTED l
Review Element: Corrective Action Process j
Discipline: Other g
Discrepancy Type: corrective Action Imp 6ementatien System / Process: DGX NRC significance level: 4 Date faxed to NU:
Date Published: 3/12/98 Discrepancy: Insufficient Data Provided for Corrective Action Closure
]
^
Implementation on ACR # M3-96-0703 i
==
Description:==
The ACR # M3-96-0703 block, " Describe the adverse condition" states the following:
" Miscellaneous Emergency Diesel Generator components are identified as non-QA in PMMS. Although these components do not actuate to support diesel start or continued operation, they are required to be QA Cat -1 to be consistent with plant design basis failure analysis (diesel stop logic, electrical separation, lube oil pressure boundary etc...). (3EGS*TS28A/B, 3 EGO *TS34A/B, 3EGS* PS27A1/B1, 3EGS* PS27A2/B2, 3EGS*LS34A/B,3EGS*TC31 A/B,3 EGO *PS24A/B, MADALP13, MADBLP13, 3EGD*V994A&B995B, MDDALP03, MDDBLP03, MA4C1503)"
The Operability Determination, OD No. MP3-209-96, Block F states that "The installed components meet the design requirements forinstalled service. Details dispositions on a component by.,mponent basis are provided in NCR M3 067." This statement applies to the above listed components.
NCR M3-95-067 covers the upgrade of the following components to QA Cat-1: 3EGS*TS28A/B, 3 EGO *TS34A/B, 3EGS*
PS27A1/B1, 3EGS* PS27A2/B2, 3EGS*LS34A/B,
3EGS"TC31 A/B, 3 EGO *PS24A/B.
NCR M3-95-067 does not cover the upgrade of the following components to QA Cat-1: MADALP13, MADBLP13, 3EGD*V994A&B995B, MDDALP03, MDDBLP03, MA4C1503.
Note: NCR M3-95-067 is missing 1 of the 12 pages.
Review Valid invalid Needed Date Initiator: Caruso, A.
O O
O 3/2/98 i
VT Lead: Ryan, Thomas J B
O O
3/4S8 VT Mgr: schopfer, Don K O
O O
3/8/98 i
IRC Chmn: singh, Anand K O
O O
3/9/98 1
Date:
j INVALID:
Date: 4/25/98 RESOLUTION: Disposition:
I NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1078, does not represent a discrepant condition.
I Components MADALP13,3EGD*V994A & 9958, MDDALP03, j
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Nhrtheast Utilities ICAVP DR Ns. DR-MP3-1078 Millstone Unit a Discrepancy Report MDDBLP03, & MA4C1503 are addressed on page 11 of NCR M3-95-067 (complete copy attached). MADBLP is not described in NCR M3-97-067 but is considered as QA CAT 1 as referenced in MEPL 1117-513 (copy attached). Additionally, MEPL 1117 addresses the other components in question and copies of the applicable pages are attached for review.
Significance Level Criteria does not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1078, does not represent a discrepant condition. The upgrade to QA CAT 1 for the components in question is contained on page 11 of NCR M3-95-067 (attached) and in MEPL 1117 (applicable pages attached).
Significance Level Criteria does not apply as this is not a discrepant condition.
Attachments:
- 1) ACR M3-96-0703
- 2) NCR M3-95-067 (complete copy - pages 1 - 12)
- 3) MEPL 1117 (applicable pages for components in question)
Previously identifled by NU? O Yes @ No Non Discrepent condition?@ Yes O No
]
Resolution Pending?O v..
@ No R iution unr.soiv.d?O v..
@ No Review i
Initiator: Caruso, A.
VT Lead: Ryan, Thomas J g
VT Mgr: schopfer, Don K O
O em l
IRC Chmn: singh, Anand K O
O O
Date:
4/25/98 st comments: NU's response is acceptable, j
Based on the attached documents, it was noted that the following l
components have been upgraded to QA Cat-1: MADALP13, l
MADBLP13, 3EGD*V994A&V995B, MDDALP03, MDDBLP03, l
MA4C1503.
Consequently, the issue reported in DR-MP3-1078 does not represent a discreptant condition.
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