Text

Forwards Fourteen Discrepancy Repts (Drs) Identified During Review Activities for Independent Corrective Action Verification Program.Drs Distributed IAW Communications Protocol,PI-MP3-01
	ML20217P327
Person / Time
Site:	Millstone
Issue date:	05/01/1998
From:	Schopfer D; SARGENT & LUNDY, INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	9583-100, NUDOCS 9805060234
	Download: ML20217P327 (53)
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Sar gentl& Lundy"c fks

'jv Don K. Schopfer Senior Vice President 312-269-6078 May 1,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company ]1 Millstone Nuclear Power Station, Unit No. 3 j Independent Corrective Action Verification Program j

United States Nuclear Regulatory Commission i Attention: Document Cont 31 Desk _ l Washington, D.C. 20555 Enclosed are discrepancy reports (DRs) identified during our review activities for the ICAVP. 1 These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01. j I

I have enclosed the following forteen (14) DRs for which the NU resolutions have been reviewed and accepted by S&L.

k DR No. DR-MP3-0015 DR No. DR-MP3-0810 l

DR No. DR-MP3-0225 DR No. DR-MP3-0827 j DR No. DR-MP3-0394 DR No. DR-MP3-0829 j DR No. DR-MP3-0464 DR No. DR-MP3-0831 DR No. DR-MP3-0589 DR No. DR-MP3-0915 t .

DR No. DR-MP3-0658 DR No. DR-MP3-0918

. DR No. DR-MP3-0659 DR No. DR-MP3-0992 7 i

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. .a 9805060234 980501 PDR ADOCK 05000423-p PDR 55 East Monroe Street

Chicago, IL 60603 5780 USA

312 269 2000 I

United States Nuclear Regulatory Commission May 1,1998 -i Document Control Desk Project No. 9583-100 Page 2 l

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

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Yours very truly, i

f i 1.

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

E. Imbro (1/1) Deper ' ector,ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council L J; Fougere (1/1) NU ,

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, Ncrthe:st Utilities ICAVP DR N . DR-MP3-0015 MiiistOne Unit 3 Discrepancy Report Review Group: Accident Mitigation DR RESOLUTION ACCEPTED RevW EW. Sysh W Potential Operability issue Discipline: Other Discrepancy Type: Calculation O va system / Process: N/A gg NRC significance level: 4 Date faxed to NU:

Date Published: 8/22/97 Discrepancy: Compliance with GDC 19

Description:

A review of the following documentation has concluded that a discrepancy exists with regard to documented compliance with the Millstone 3 Operating License, FSAR and GDC 19 as they relate to the estimated dose received by the operators following postulated design basis accidents. The documents reviewed are:

4

1) MP3 FSAR Tables 6.4-1 and 9.4-2

2) MP3 FSAR, Chapter 15.6, Less-of-Coolant Accident (LOCA)

3) MP3 Ventilation Systerns DBD

4) MP3 Tech. Spac. 3/4.7.7 - Control Room Emergency Ventilation System

5) MP3 Control Room Dose Calculations [UR(B)-365-1; UR(B)-

366-1; UR(B)-367-1; and 88-019-97RA, Rev. 0]

6) UIR 343 The MP3 Technical Specification indicates that the design and tested flow rate for the control room emergency filter system is 1120 cfm +/- 20%. Based on this specification, the flow could range from 896 to 1344 cfm. This value is different from that reported in the FSAR and the DBD. The referenced dose calculations are the calculations of record to show compliance with control room habitability requirements at Millstone 3. The calculations use a value of 1000 cfm for the flow rate of this safety system. This value differs from the reported Technical Specification value. Since the flow rate through these filters directly affects the estimated post-LOCA dose to the operators, a concem exists regarding NU compliance with the Millstone 3 FSAR estimates for post-LOCA operator doses and General Design Criteria (GDC) 19. Use of a filter flow rate other than that which is put out by the control room emergency filter unit may be non-conservative.

GDC 19 requires that the operators be provided with a control room from which actions can be taken to operate the nuclear power plant safely under normal conditions and to maintain it in a safe condition under accident conditions, including a loss-of-coolant accident (LOCA). It is this latter capability that is under question in this discrepancy report.

NU has identified an unresolved issue report (UIR 343) that a discrepant condition exists with regard to the reported flow Valuce b. the ?!!cic c 3 TcGhnica SpeGifiGationS-On C,r, ,

PN N M PM

1 hJarthert Utilities ICAVP DR N2. DR-MP3-0015 Millstone Unit 3 Discrepancy Report the control room emergency filter system. The UIR concludes j that actions in ACR 8843 and A/R 9600766 will process the 1 FSAR change required to resolve the condition and states that no additional action is required. While these actions note the FSAR discrepancy, there is no objective evidence that NU has appropriately addressed the issue in the design calculations.

Review Valid invalid Needed Date initiator: Bennett, L A. 8 0 0 8'5/97 VT Lead: Rahoja, Raj D G O O 8/5'S7 VT Mgr: Schopfer, Don K B O O 8'5/97 IRC Chmn: Singh, Anand K B O O 8/8/97 l

Date:

INVALID:

Date: 4/30/98 RESOLUTION: Disposition:

NU Disposition Dated 11/21/97 NU has concluded that Discrepancy Report DR-MP3-0015 has identified a condition previously discovered by NU which requires correction. S&L's statement that UIR 343 does not adequately address the design calculation is correct, however, UIR 1005 was written to clarify this apparent discrepancy. The problem was documented on UIR 1005, and is due for completion on 10/16/97.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0015 has identified a condition previously discovered by NU which requires correction. The problem was recorded on UIR 1005, which is currently under evaluation. This issue is start up related and scheduled for completion on 10/16/97. NU concurs that this item is Significance Level 3.

NU Disposition Dated 3/31/98 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0015 has identified a condition not previously discovered by NU which has been corrected.

At the time NU responded to ACR 8843, UIR 1005 and DR-MP3-0015, NU was trying to justify acceptance of the original licensing basis for the MP3 Control Room Habitability calculations. The original licensing basis for MP3, and many other nuclear power plants, was to use the design nominal flow for the control room habitability system in the radiological calculations. The response addressed the point that the sensitivity of the dose to flow was small compared tre the uncertainties and conservatism of other assumptioes This Printed 5/1/981:26:49 PM Page 2 of 5

ICAVP DR N2. DR-MP3-0015 i

, ferthea:t Utilitl2s Millstone Unit 3 Discrepancy Report discussion was an attempt to justify why the use of nominal flows was an acceptable industry practice.

Since that time, the NRC has evaluated this issue during their Tier 2 inspection of MP3. They clearly stated that the dose analysis must use the bounding (maximizes the dose) flow assumptidn for all flows allowed by Technical Specifications. NU wrote CR-M3-97-2959 in response. Based on this determination by the NRC, NU has recalculated the control room dose using the bounding flow allowed by Technical Specifications. The calculation M3 ROOM 94/01064-R3, Rev.1 has been completed and is attached. All other LOCA to Control Room calculations have been superseded.

Please note that the bounding flow is the minimum flow allowed by Technical Specifications 3/4.7.7,1120 cfm -20% , which is 896 cfm. The maximum outside air intake flow is 230 cfm. This is ensured byTechnical Specification 4.7.7.e.2, which requires the plant to adjust the system dampers to ensure less than 230 cfm. Hence,230 cfm is used in the calculations as the outside air inflow rate. Given this maximum outside air flow, the max! mum dose would be achieved by minimizing the recirculation or l cleanup flow. Hence 896-230= 666 cfm was used as the recirculation flow in the revised calculation. Higher flow raies would result in increased cleanup and lower dose. Even at the maximum possible flow of 1344 cfm, the filter efficiency would be expected to be greater than the 95% assumed in the calculations, and any slight decrease in actual efficiency would I be more than compensated for by the increased turnover rate.

See the attached CR-M3-97-2959 for the reportability determination related to this Discrepancy Report.

NU concludes that the revision of the calculation using the l bounding flow allowed by Technical Specifications will satisfactorily resolve this DR.

The dose rate limits of GDC 19 are not compromised and MP3 is i in compliance with its licensing basis. NU considers this issue Significance Level 4.

Conclusion:

NU has concluded that Discrepancy Report DR MP3-0015 has identified a condition not previously discovered by NU which has been corrected. This issue was evaluated as a result of the NRC Tier 2 inspection. NU wrote CR-M3-97-2959 in response. l Simultaneously, Calculation M3 ROOM 94/01064-R3, Rev.1, was prepared and issued. This CR and calculation address the issues identified in this Discrepancy Report.

GDC 19 dose rate limits are not exceeded. NU is in compliance with its licensing basis. This issue is considered Significance Level 4.

Previously identified by NU? O Yes (8) No Non Discrepent condition?Q Yes (e) No Page 3 of 5 Printed 5/1/98126:51 PM

i ICAVP DR N . DR-MP3-0015

. N rthe t Utilitie3 Millstone Unit 3 Discrepancy Report Resolution Pending70 Yes (*) No ResolutionUnresolved70 Yes ($ No Review inittetor: Johnson, W. J.

VT Lead: Rahoja, Rai D VT Mgr: schopfer, Don K l lRC Chmn: Sin 0h. Anand K Date: 4/30/98 sL Comments: S&L COMMENTS (11/21/97)

The ICAVP Team has reviewed NU's response to this DR and the proposed resolution in the associated UIR 1005. NU has still not provided sufficient information for the ICAVP to conclude that the proposed actions will appropriately resolve the issue identified in the DR. The basis for this determination is discussed below.

ICAVP reviewed the following documents:

1) ACR# 8843

2) UIR 1005 I

3) MP3 Control Room Dose Calculations [UR(B)-365-1; UR(B)-

366-1; UR(8)-367-1; and 88-019-97RA, Rev. 0]

4) SP 3614F.1

5) SP 3614F.2 The discussion and recommended disposition in both ACR# 8843 and UIR 1005 indicates that NU has focused the engineering review and concem at the component level of the filtration portion for the control room emergency ventilation system (CREVS).

The discussion indicates that NU has determined that the Tech.

Spec. flow rate of 1120 cfm +/- 20% could result in a velocity across the charcoal adsorber bed in excess of that specified for the component. Although not explicitly stated in the UIR, the discussion infers that there is a potential for degradation of the CREVS filter efficiency. While the ICAVP team agrees that this is important, the NU reviews to date did not conclude this to be an LER reportable condition because there is no requirement to assure that the unfiltered air intake is <= 250 cfm as assumed in the Reference 3 calculations.

The dose calculations of record (Reference 3) use 250 cfm as the i filtered air make-up flow rate. The Tech. Spec. and the References 4 and 5 surveillance procedures do not specify that the condition of the control room emergency filter unit be such that the filtered air make-up is <= 250 cfm. Using this i information, a cursory review of the design calculations concludes that, if the recirculated air flow is approximately 750 cfm as cited in the Reference 3 calculations, the filtered air make-up could be i

as high as 594 cim. Since this represents an increase in the source term being introduced into the control room of 130% over and above that estimated in the calculations, there is a potential Page 4 of 5 Printed 5/1/9e 1:26:52 PM

ICAVP DR No. DR-MP3-0015

. N:rthenct Utiliti:s Millstone Unit 3 Discrepancy Report to increase the estimated thyroid dose received by the operators by a factor of 2.0 or greater. The ICAVP concludes that NU has sufficient information to recognize that the currently estimated 26 Rem thyroid dose to the operators could exceed the GDC 19 lirnit of 30 Rem and the plant is outside the design basis. l NU performed an LER reportability determination in the ;

Reference 1 ACR. This determination cites the conservatisms in )

the design calculations as a basis to determine that no reportable condition exists. The ICAVP team does not agree with this i l

determination because it does not specifically cite or quantify the conservatisms being credited. In addition, it is our judgment that these conservatisms are required by regulatory guidance and the MP3 design basis. Therefore, NU has a condition which is ;

outside of the MP3 design basis and is reportable under 10 CFR )

I 50.73.

l The ICAVP Team concludes that NU is currently taking a I

component view of the problem versus the functional design impla,ations. We expect that NU would have already determined that revisions to the calculations are required, rather than the statement provided in UIR 1005 that calculations will be updated 1 "if determined necessary". We request that NU reconsider this !

Issue. ;

S&L COMMENTS (3/31/98)

S&L concurs that the use of maximum Technical Specification l intake flow and minimum recirc'ilation flow produces a conservrative control room dose. ICAVP finds the revised calculations acceptable.

Page 5 of 5 Printed 5/1/981:26.53 PM

ICAVP DR No. DR-MP3-0225 N::rthe:st utilit::s Millstone Unit 3 Discrepancy Report l Review Group: Conrgurabon DR RESOLUTION ACCEPTED Review Element: systern Installation Discipline: I & C Design Discrepancy Type: Instalianon trnplementation g System / Process: SWP NRC significance level: 4 Date faxed to NU:

Date Published: 12/14/97 Discrepancy: Labeling not in accordance with requirements Descripuon: The following labeling inadequacies with respect to design ,

documents and requirements of Procedure OA-9, Rev. 2,

" System and Component Labeling " were noted during system walkdowns.

Kaman vendor drawing 2474.030-624-193 Rev. F designates the following identitles for components included in panels i 3RMS*RAK1 A and 3RMS*RAK1B:

Recorder (REC 7) to be identified as 3SWP*RR60A Recorder (REC 7 & 8) to be identified 3SWP*RR60B Contrary to these requirements, these recorders are currently labeled as RIC 7A and RIC 78 & 88.

Review Valid invalid Needed Date initiator: server, T. L 8 O O 11/26/97 VT Lead: Nort, Anthony A B O O 11/29/97 O 12/st97 VT Mgr: schopfer, Don K O O IRC Chmn: singh, Anand K B O O 12/8/97 l Date: )

INVALID:

Date: 4/30/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that Discrepancy Report, DR MP3-0225, has identified a condition not previously discovered by NU which requires cort:ction. 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 M3-98-0137 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0225, 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-Pnnted 5/1/981:28:47 PM Page 1 of 3

l i

ICAVP DR No. DR-MP3-0225

. N::rthear.t Utilitiea !

Mil: stone Unit 3 Discrepancy Report l l

20 criteria and found to have no operability or reportability l concems and meets the Unit 3 deferral criteria. CR M3-98-0137 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE: {

i Disposition: l NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0225 does not represent a discrepant condition.

U3 PI 20 section 1.3.2 e defines the type of labeling discrepincies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues ;

which will be completed prior to startup. The intent of attachment 11 is to corre't issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

NU concludes that the assignmen' of priority 4 is correct and in accordance with U3 Pt 20 section 1.3.2 e.

The recorders are labeled sufficiently to prevent operational confusion. The radiation monitor display is labeled with the 3SWP*RlY60A designation and the manufactures RIC-7A designation. The recorder repeats the RIC7A designation.

Significance level criteria does not apply to the new issue as this I

is not a discrepant condition.

The corrective actions in CR M3-98-0137 will correct these issues post startup.NU considers the overall classification of the DR to be significance level 4.

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0225 does not represent a discrepant condition.

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

Previously identified by NU? O Yes (*) No Non Discrepant Condition?U ves (*) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve= @ No Review initiator: Warner,1.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 4m IRC Chmn: singh, Anand K G O O

n=ta- Alin/oA

~ ~~

Page 2 of 3 Printed 5/1/961:28:51 PM

ICAVP DR No. DR-MP3 0225

. N:rthea:t Utilities Millstone Unit 3 Discrepancy Report

=> r- ,J;;,';;

SL Comments: INITIAL COMMENT -

Plant screening criteria states:

Plant labeling discrepancies which have a diroct impact on plant configuration, operation or personel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels) may be deferred.

This labeling discrepancy does not appear to meet the Unit 3 deferral criteria.

COMMENT ON SECOND RESPONSE:

We accept NU's response.

^

Frinted 5/1/961:28.s2 PM Page 3 of 3

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. N::rtherct Utilities ICAVP DR No. DR-MP3-0394 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: Mechanical Design Discrepancy Type: Calculation Om g

System / Process: SWP NRC Significance level: NA Date faxed to NU:

Date Published: 11/13/97 Discrepancy: Calculation 90-069-1130-M3 rev. O design informction not

)

verified.

Description:

The Westinghouse calculation notified NU in the body of the

}

calculation that design inputs needed to be verified, however there is no stateinent that indicates that NU verified this design information. This is in reference to refrigerant temperature of the HVK chillers (page 35, section 4.11.1, paragraph 1).

Westinghouse Thermal Equipment Calculation Report, TE-EC-027 was used for design inputs into revision 0, but this calculation was not issued per M3-lRF-00417, Calculation P EC-225, rev. O " NEU Safety Injection Pump Seawater Minimum Flow Evaluation" and calculation P-EC-230, rev. O "CH/SI Pump Cooling Water Evaluation for Millstone 3 (NEU)" were used for design inputs into revision 0, but were not found in Nuclear Documentation Services (NDS) per M3-IRF-00524.

Review Valid Invalid Needed Date initiator: Dionne, B. J. 8 O O So'S/S7 VT Lead: Neri, Anthony A B O O 10' o'87 VT Mgr: Schopfer, Don K B O O o' " 7 IRC Chmn: Singh, Anand K B D O 1i'7/S7 Date:

INVALID:

Date: 4/30/98 ;

RESOLUTION: FIRST RESPONSE: l Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0394, does not represent a discrepant condition. CCN1 (pg 35) to calculation 90-069-1130 M3 deleted the analysis for j the HVK chiller condenser from the calculation including the i reference to TE-EC-027. Calculations P-EC-225 and P-EC-230 l are not in Nuclear Documentation Services since they are Westinghouse proprietary calculations referenced in calculation 90-069-1130 M3 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-MP3-0394, does not represent a discrepant condition. CCN1 to calculation 90-069-1130 M3 deleted the analysis for the HVK Printed 5/1/961:31:32 PM Page 1 of 3 1

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ICAVP DR N2. DR-MP3-0394

. N rthe:st Utilitie3 Millstone Unit 3 Discrepancy Report I

chiller condenser from tne calculation including the reference to TE-EC-027. Calculations P-EC-225 and P-EC-230 are not in Nuclear Documentation Services since they are Westinghouse proprietary calculations referenced in calculation 90-069-1130 M3. Significance level criteria do not apply here as this is not a discrepant.

SECOND RESPONSE:

_________=

Disposition: j NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0394, does not represent a discrepant condition. The requested Westinghouse calculations P-EC-225 and P-EC-230 are attached. NU emphasizes that the attached calculations are considered Westinghouse proprietary and should be handled as agreed to under the NU / S&L ICAVP proprietary agreement.

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-MP3-0394, does not represent a discrepant condition. The requested Westinghouse calculatioris P-EC-225 and P EC-230 are attached. NU emphasizes that the attached calculations are considered Westinghouse proprietary and should be handled as agreed to under the NU / S&L ICAVP proprietary agreement.

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

Previously identified by NU? O Yes @ No Non Discrepant Condition?(# Yes O No Resolution Pending?O Ye. @ No Re.oiution unre.oiv.d?O Ye. @ No Review inittetnt: Dionne, B. J.

VT Lead: Nerl, Anthony A =

VT Mgr: schopfer, Don K O O IRC Chmn: singh, Anend K Date: 4/30/98 sL Comments: FIRST RESPONSE:

=___._____.=.

Item one of this discrepancy was not addressed in this resolution.

This point becomes irrelevant since the calculation that supersedes the information in question, is now superseded by a new calculation (97-123) as outlined in the resolution to DR MP3-0397.

l Item 2, the calculations that were referenced and are noted as Westinghouse proprietary calculatlons should be provided so that l we may complete our review of the calculation.

l l SECOND RESPONSE:

Page 2 of 3 Printed 5/1/981:31:36 PM

1 1

DR Ns. DR-MP3-0394

, Northea:t Utilitima ICAVP Millstone Unit 3 Discrepancy Report l u ____________________:.

No additional comments.

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Page 3 of 3 Printed 5/1/981:31:37 PM

ICAVP DR N:. DR-MP3-0464 l

. N:rthert Utilities Millstone Unit 3 Discrepancy Report DR RESOLUTION ACCEPTED j Review Group: system

" Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation Om g~

System / Process: OsS NRC Significance level: 4 Date faxed to NU:

Date Published: 11/15/97 Discrepancy: Spray Area Calculation ES-229 Ducription: Calculation ES-229 (Rev.1; CCN 1) determines the spray area for each QSS and RSS spray header at standard containment pressure and at an elevated containment pressure. ,

1

1. Page 12 of the calculation introduces a friction factor. The friction factor is the effectiveness of the spray due to steam, air and other particulates in containment. This factor comes from SWEC Safeguards Generic Calculation PE-125. This calculation was requested by RFI MP3-278. Response M3-lRF-00222 indicated that Calculation PE-125 could not be found in the NU System. The conclusions of the calculation appear to be consistent with the purpose, methodology and inputs. However, a final conclusion cannot be drawn since Calculation PE-125 is not available.

l

2. The calculation modeled the spray pattem for all nozzle configurations as circular. The SPRACO charts show that the spray pattem is circular for nozzles pointed straight down. For nozzle configurations pointed 45',60' and 75* up from horizontal, the spray pattem is elliptical with the width greater than the length of the spray. The length is in the spray direction.

The width is perpendicular to the spray direction. For all other nozzle configurations, the spray pattem elliptical with the length l greater than the width of the spray. l The calculation of the spray area for nozzles pointed 22.5* up, horizontally,22.5' down,45' down and 67.5* down is unaffected by the elliptical spray pattem. The calculation uses the length of spray for the circle diameter. The nozzle configurations as located on each header provide overlapping sprays. Therefore, this is not a concem.

However, the calculated spray area for nozzles pointed 45' up is overestimated. The calculation uses the average of the length ar ; width of spray for the circle diameter. This overestimates the ? ray diameter which affects the coverage area.

Review Valid invalid Needed Date initiator: Langel, D. O O O 11'3/S7 11'3S7 VT Lead: Neri, Anthony A B O O 11'S/87 VT Mgt: schopfer, Don K O O O 11'1 'S7 IRC Chmn: singh, Anand K G O O Date:

INVALID:

Page 1 of 4 Printed 5/1/981:32:27 PM

1 DR No. DR-MP3-0464

- N:rthert Utiliti;s ICAVP Millstone, Unit 3- Discrepancy Report Date: 4/30/98

.l RESOLUTION: Disposition:

Disciepancy Report, DR-MP3-0464, has ident separate issues. NU has concluded that the second issue (the overestimate of spray pattem coverage for QSS nonles pointed at 45' up) reported in Discrepancy Report, DR-MP3-0464, has identified a discrepant condition not previously discovered by NU which requires cosction. Using an average diameter to represent the actual elliptical pattem for the nonles spraying 45' up inward will result in a spray pattem which extends further from the header than that supported by the laboratory data. Spray coverage will not be affected if ellipses are drawn in strict accordance with the actual nonle manufacturer data since these pattems overlap pattems from the adjacent QSS header.

Nonles which are aimed at an angle 45' up are present on QSS header 3-QSS-010-30-2(Z-) at Elevation 153 ft (see drawings ,

12179-EP-79C & D). These nonles spray inward, toward the I center of the containment. The spray pattems created by these nonles overlap the spray patiems created by the nonles aimed i outward at an angle 45' down on QSS header 3-QSS-006 l 2(Z-) at Elevation 168 ft, which is concentric and inside the header at Elevation 153 ft. These headers are separated radially by 23.5 feet. Coverage would be complete even if the smaller elliptical dimensions had been used for both the 45' up and the 45' down nonles. This has been determined based on the radial separation between the headers and on the nonle spray pattems from attachment 1 of calculation 12179-ES-229.

CR M3 98-0421 has been issued to develop the corrective actions associated with this DR. The corrective action, which will resolve this discrepancy, is to issue a CCN to the calculation using a conservative spray diameter for the 45' up spray nonles. This is scheduled to be completed after restart.

NU considers this to be a significance level 4 discrepancy: this is a minor error that does not significantly affect the results of the calculation.

NU has concluded that the first issue (the unavailability of calculation PE 125 to verify a friction factor in calculation ES-229) reported in Discrepancy Report,~ DR-MP3-0464, does not represent a discrepant condition. PE 125 is a Stone & Webster proprietary calculation provided to support several calculations, potentially for different utilities; therefore, this calculation would not be included in the NU Records System. The calculation is available for viewing in Stone & Webster's Boston office.

Conclusion:

Discrepancy Report, DR MP3-0464, has identified two separate conditions. NU has concluded that the second issue, regarding the spray coverage for a 45' up OSS nonie, has identified a discrepant conditico not previously identified. CR M#-98-0421 has been issued to develop the corrective actions associated

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r N::rth; cst Utilitle3 ICAVP DR No. Dd1P3-0464 f Millstone Unit 3 Discrepancy Report is scheduled to be implemented after restart.

NU has concluded that the first issue (the unavailability of !

calculation PE-125 to verify a friciion factor in calculation ES- j t

229) reported in Discrepancy Report, DR-MP3-0464, does not represent a discrepant condition. The calculation is proprietary and is available for view in Stone & Webster's Boston office.

Disposition to S&L comments:

NU has concluded that the issues reported in item 1 of Discrepancy Report, DR-MP3-0464, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0421 (attached) I has been revised to prepare a CCN for calculation ES-229 to change the spray area coverage for nozzles pointed 45 degrees up and revise the drag coefficient used in the calculation to that ;

of an atmospheric ccatainment (0.48)in lieu of a sub- l atmospheric conta' ament (0.54) or provide more detailed justification for using 0.54. These changes will have no significant impact on the conclusion of calculation ES-229-1. 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 issues reported in item 1 of Discrepancy Report, DR MP3-0484, have identified conditions not previously discovered t:y NU which require correction. The approved corrective action plan for CR M3-98-0421 (attached) l has been revised to prepare a CCN for calculation ES-229-1 to change the spray arca r. overage for nozzles pointed 45 degrees up and to address the norNonservative drag coefficient used in the calculation. These changes will have no significant impact on the conclusion of calculation ES-229-1. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously idenufied by NU? () Yes (#) No Non Discrepent Condition?(,) Yes (e) No Resolution Pending?O ve. @ No Resolution Unresolved?O yes @ No Review ACCeP t able Not Acceptable Needed Date initiator: Langel, D. =

VT Lead: Neri, Anthony A O O O O =

VT Mgr: schopter, Don K O O m IRC Chmn: singh, Anand K O O O Date: 4/30/98 SL Comrnents: 1. The input for the friction factor was substantiated from Calculation PE 125 by a telephone call with Mr. Frank Ella of Stone & Webster. Mr. Elia indicated that the friction factor is really a drag coefficient and is applied to the distance from the nozzle. Mr.Ella also indicated that there are two curves for the drag coefficient; one for atmospheric containments and one for sub-atmospheric containments. The coefficient for sub-Page 3 of 4 Printed 5/1/961:32:33 PM

i l

DR No. DR-MP3-0464 I

. N:rth:=t Utilitlen ICAVP i Millstone Unit 3 Discrepancy Report l atmospheric containments is 0.54 at 275 *F as reported in the calculation. The coefficient for atmospheric containments is 0.48 at 275 *F. Millstone Unit 3 was a sub atmospheric containment; however, this has been changed and the containment is maintained around atmosphede pressures. Therefore, the calculation should use 0.48 for the drag coefficient. This results in a smaller spray diameter which is not conservative.

2. It is agreed that this error is minor. Updating the calculation may be deferred.

Final Resolution:

The corrective action proposed is acceptable. The items identified in this discrepancy do not affect the conclusions of the calculation and may be deferred, i

l l

i i

l i

l l

l Page 4 of 4 Printed s/1/961:3234 PM

ICAVP DR N3. DR-MP3-0589 l

. N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: Systern DR RESOLUT)GN ACCEPTED Potential Operability issue Discipline: Mechanical Design g Discrepancy Type: Cornponent Data System / Process: HVX Om NRC significance level: 4 Date faxed to NU:

Date Published: 11 2/97 Discrepancy: SLCRS and ABVS Filter Unit Adsortent Qualification

Description:

During review of the Supplementary Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/3B and the Auxiliary Building Ventilation System (ABVS) exhaust filter units 3HVR*FLT1 A/1B a discrepancy regarding the charcoal adsorbent face velocity for qualification testing was identified.

Per FSAR Table 1.8-1, Millstone complies with RG 1.52 Rev. 2

' Design, Testing, and Maintenance Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants' regulatory position C.3.1 with the following exception:

The dwell time for the minimum 2 inches of the carbon adsorber unit is 0.21 sec. All filters use a 4-Inch thick charcoal bed which exceeds the minimum 2 inches recommended by R.G.1.52, Rev. 2. The additional 2 inches will result in a dwell time of 0.43 sec.as a minimum. Carbon is purchased to Table 5-1 of ANSI N509-1980. Testing of the charcoalis based on a maximum face velocity of 46 fpm and a 2-inch thick bed.

Charcoal test results for purchase orders 904806 and 910825 state that the tests were conducted with a face velocity of 12.2 m/ min (40.2 ft/ min) instead of the 46 ft/ min face velocity stated in FSAR Table 1.8-1.

UIR 1073 addresses differences in the testing requirements between ANSI N509-1976 and ANSI N509-1980. It does not address the higher face velocities required for testing.

Review Valid invalid Needed Date Initiator: Stout, M. D- 0 0 0 10/28/97 VT Lead: Neri, Anthony A 8 0 0 10/28/97 VT Mgr: Schopfer, Don K 8 O O 10/30/S7 10/31/S7 IRC Chmn: Singh, Anand K O O O Dat.:

INVALID:

Date: 4/30/98 RESOLUTION: First Response NU has concluded that Discrepancy Report, DR-MP3-0589, has identified a condition previously discovared by NU v/hich required correction. The closure request for UIR 10 73 addremos the issue of the velocity criteria used for the testing oiihe subject charcoal. AITTS did not include all of the information contained Printed 5/1/981:33:18 PM Page 1 of 4

ICAVP DR No. DR-MP3-0589

. Nrrtheist Utilities Millstone Unit 3 Discrepancy Report in the Closure Request. This information has since been included in AITTS AR 96033919-01 for reference.

As stated in the closure request, although the current stocks of charcoal were initially tested at a face velocity of 40 FPM, i routine surveillance testing, performed at a maximum face J velocity of 46 FPM for all applications, has indicated the i

acceptability of the existing charcoal. Because the testing is completed on a representative sample, all charcoal from that procurement lot, including charcoal stored in the warehouse, is validated.

Future procurement of charcoal will require Engineering review prior to ordering due to a HOLD against the stock code number (see attached printout from MaterialInformation Management System, MIMS). This review will be done to the requirements of Specification 2170.430-065. ;

i NU concurs with the significance level of this previously discovered DR.

Attachments:

UIR 1073 Closure Request M3-EV 970224 3614A.2-1 Auxiliary Building Filter Train A Charcoal Sample, completed 12/5/95 3614F.21, Control Room Filter Charcoal Analysis - Train A, completed 3/7/96 3613D.1-5, Containment Filter Charcoal Analysis Train A, completed 8/12/96 3814C.21, Fuel building Filter Charcoal Analysis - Train A, completed 1/8/97 i MIMS data printout;" Master Materials Catalog" for stock code i 0324180, Charcoal Second Response (M3 lRF-1802) l NU has concluded that Discrepancy Report DR MP3-0589 has 4 identified a condition not previously discovered by NU which requires correction.

The closure of UIR 1073 did not fully address this issue. Per R.

G.1.52, Rev. 2, C.6. b: "The efficiency of the activated carbon j adsorber section should be determined by laboratory testing of !

representative samples of the activated carbon exposed simultaneously to the same service conditions as the adsorber section. . .. Laboratory tests of representative samples should be conducted, as indicated in Tablo 2 of this guide, with the test ;

gas flow in the same direction as the flow during service conditions. Similar laboratory tests should be performed on an adsorbent sample before loading into the adsorbers to establish an initial point for comparison of future test results." This means that in order to track the degradation of charcoal as it ages, laboratory analysis of charcoal samples must be performed j under conditions identical to those tne process bed is going to i see. and that the surveillance test results must be compared to t Page 2 of 4 Prtrded 5/1/981:33:22 PM

ICAVP DR No. DR-MP3-0589

. N2rthe:st Utilities Millstone Unit 3 Discrepancy Report those performed on the charcoal before (or at the time of) loading. It is understood that new, unused charcoal must meet the physical property specifications of Table 5.1 in ANSI N509-1976. This requirement assures procurement of the highest quality charcoal so that the charcoal arriving on site can be installed with the expectation that field requirements for efficiency will be met. Subsequently, the procurement test results become of little meaning since periodic testing of installed samples via a qualified laboratory provide ongoing ovidence that the installed charcoal degradation is within acceptable limits of R.G.1.52, Table 2.NU has written CR M3-981710 to address the differences between the laboratory test performed per the requirements of ANSI N509, Table 1, on the unused charcoal before installation in filter units 3HVR*FLT1 A/B and the surveillance tesi requirements, specifically the variance between the laboratory conditions of 95% RH at 40 FPM for new, unused charcoal vs the ficid conditions of 70% RH at 46 FPM.

Engineering Evaluation M3-EV-970224 will be revised to consider these variances and to provide justification that the charcoal, purchased and tested to ANSI N509, is acceptable and has consistently met the Tech. Spec, requirements, evidence of which is that the charcoal contained in units 3HVR*FLT1 A/B has been laboratory tested and consistently conforms to R.G 1.52, position C.6.a and position C.6.b. Note that specification 2170.430-065 does state that the ABVS filter units have a face velocity of 46 FPM and the MP3 FSAR was 3 revised per FSAR CR 97-MP3-531 to commit to procurement of l new charcoal with laboratory testing at the higher velocity. UlR 1073 will be revised per AR 98006599-02. Corrective action will be completed before Mcda 2.

The charcoal in service in 3HVR*FLT1 A/B has been surveillance tested at 46 FPM. Laboratory tests of the samples taken establish that there has been no degradation of the charcoal which continues to conform to the MP3 licensing and design bases. NU therefore considers this issue Significance Level 4.

l Attachments:

CR M3-98-1710 with approved corrective action Previously identmed by NU? U Yes (9) No Non Discrepant Condition?O Yes (#) No Resolution Pending?O Yes S No ResoludonUnresolved?O Yes

No Review f initiator: Stout, M. D.

VT Lead: Nerl. Anthony A =

VT Mgr: schopfer, Don K O O IRC Chmn: Singh, Anand K Date: 4/30/98 I st corrrnents: Comments on First Response Disagree with NU's response that the charcoal velocity discrepancy was fully addressed by the closure request for UIR 1073.

1 Page 3 of 4 Printed S/1/961:33:23 PM

l ICAVP DR No. DR-MP3-0589

. N::rtheast Utiliti:o Millstone Unit 3 Discrepancy Report The Auxiliary Building Filter Train A Charcoal Sample Test (OPS Form 3614A.21) coinpleted 12/5/95 used a test condition of 70%

Rela'ive Humidity. ANSI N509-1980 Table 51 ' Performance Requirements and Physical Properties of (Unused) Activated Carbon' requires a test condition of 95% Relative Humidity. This difference was not evaluated in Engineering Evaluation M3-EV-970224, Rev. O provided with NU's response.

Comments on Second Response This is considered to be a level 4 documentation discrepancy regarding Engineering Evaluation MS-EV-970224.

Page 4 of 4 Printed 5/1S81:33:24 PM

ICAVP DR No. DR-MP3-0658

. N:rthea:t Utilities Millstone Unit 3 Discrepancy Report l l

Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical

O vee Discrepancy Type: Component Date g System / Process: HVX NRC Significance level: 4 Date Faxed to NU:

Date Published. 11/2497 Discrepancy: ABVS Filter Unit Electric Heater Capacity Descripuon: During review of the Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/1B a discrepancy regarding the capacity of the electric heating coil in the filter units was identified.

Regulatory Guide 1.52, Rev. 2, position C.3.b requires the heaters to be designed, constructed, and tested in accordance l with the requirements of Section 5.5 of ANSI N509-1976. ANSI N509-1976 Section 5.5.1 states that the heater shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air-steam mixture (RH=100%) to approximately 70% in the housing space between the moisture separator and prefilter stage, at system design flowrates. FSAR Table 1.8-2 and FSAR Table 6.5-1 state that the filter units are in compliance with Regulatory Guide 1.52, Rev. 2, position C.3.b.

The results of calculations 97 ENG-01453M3, Rev. O ami B235-9915 Rev. B indicate that for degradM voltage and the .

specified 170*F,100%RH enter lng ear conditions the electric heater capacity results in a relative aumidity of 75.2%. The 75.2% RH value does not meet the RG 1.52 requirements.

Review Valid invalid Needed Date 1 '11/87 initiator: Stout, M. D- 8 O O VT Lead: Nort, Anthony A 8 O O 11 '97 VT Mgt: schopfer, Don K B O O 1'17/97 IRC Chmn: Singh. Anand K B O O 1 /20/97 Date:

INVAUD:

Date: 4/30/98 RESOLUTION: First Response NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0658, does not represent a discrepant condition.

ACR M3-97-0161 was written on 6/1/96 to document discrepancies between the minimum design voltage for Class 1E heaters and the low voltage capability of the heaters to perform their design basis function.

A design basis review of the degraded voltage calculation (NL-042) was performed and documented on ACR M3-97-0119, which was determined to be reportable. During the review of that ACR, it was noted that the acceptance criteria used for Page 1 of 4 Printed 5/1/9e 1:34:19 PM

N:rthe:st Utilities ICAVP DR No. DR-MP3-0658 l Millstone Unit 3 Discrepancy Report motors (90% of rated voltage,460 volts) was a'so applied to i resistive devices (heaters, rated 480 volts). This results in a 25% reduction in heater output. No justification for this assumption was given in calculation NL-042. Upon further review it did not appear that this reduced operating margin was accounted for in the heater sizing calculation either, This finding was reinforced by a previous review for reportability (Ref 92-25) whereby, neither the electrical nor mechanical calculation accounted for operating margin at reduced voltage (voltage just above the degraded voltage setpoint) during a DBA condition.

At that point the ACR-M3-97-0161 was generated for the suspect equipment and a formal reportabilty review commenced.

ACR M3-07-0161, Item 4, discussed Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/18. CVI inc., provided the MP3 filter assemblies. CVI Calculation (DWG B2553-9915, change B dated 4-21-92), determined the relative humidity at design flow and degraded voTdge (414V) to be 75.2% RH for the Auxiliary Building Ventilation System (ABVS) ,

filter units 3HVR*FLT1 A/18. This calculation determined that l Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/1B does in fact meet the RH criteria of ANSI N509 at design flow and degraded voltage. The Conclusion was based on the following criteria.

ERDA-76-21, Nuclear Air Cleaning Handbook, for Design, Construction and Testing of High-Efficiency Air Cleaning System for Nuclear Application is referred to as a supplement to ANSI-N509. ERDA-76-21 recommends conservative efficiency values for design of 2 inch impregnated activated carbon beds (ref, section 3.4.2 and table 3.11).

For example, from table 3.4.2, at 85% or less RH, the design for charcoal is 95% efficient at 70' and 98% efficient at 270' These temperatues are consistant with the expected condition when the heaters are required. The ERDA values are conservative and have been validated with the charcoal testing vendor (NCS) where NCS's assessment stated that charcoal could exceed 80% relative humidity without impacting charcoal adsorption measurably. The MP3 Radiological calculations credit charcoal filters at 95% efficiency. Although, the purchase specification states each electric heater shall reduce the relative humidity to less than 70%, it also states that the heaters are to meet design requirements of ANSI N509, which states that "the heaters shall be sized on the basis of heat transfer calculations showing its capability of reducing the maximum expected relative humidity of the entering air-stream mixture to approximately 70% in the housing space". The purchase specification was providing margin when it specified less than 70% while meeting the specified requirements of ANSI N509.

This is the widely recognized and acceptable requirement.

Therefore, the filtration unit heaters meet the purchase specification requirements of ANSI-N509. Based on Northeast Utilities Memo No. PSM3-92-066 the effect on the charcoal sample penetration test with higher relative humidities of 75.2%

in the Auxiliary Buildina Filtration System (#HVR*FLT1 A & 1B) _

Printed 5/1/981:34:22 PM Page 2 of 4

ICAVP DR No. DR-MP3-0658

, N:rthenst Utilities Millstone Unit 3 Discrepancy Report will be unmeasurable. The memo further stated that (NNECO) could exceed relative humidity without impacting the charcoal absorption to a measurable level.

1 Additionally, concems were sufficiently substantiated to question !

the validity of the degraded Grid Voltage Calculations (CR M3-97-0119 & LER 97-010). Reviews performed on MP3 heater applications found that the heaters were able to perform their ,

design functio with the exception of the Hydrogen recombiner I heaters. The wrrective action plan for CR M3-97-0119 required (

a comprehensive review of all the class 1E components to ensure operability at the voltage levels at the DGV setpoint analyticallimit. (see LER 97-011-00). Calci.lation NL-038 documents the voltage profile and load flow aad NL-042 determines the DGV setpoint. Calculation 97-ENG-01453M3 evaluates the heater minimum voltage capacity. This Calculation,97-ENG-01453M3, has concluded that minimum available voltage is 414VAC for heaters at all locations except those at the Auxiliary Building Area. The Auxiliary Building Area Heaters Relative Humidity will be approximately 5% higher than 70% requirement, at a temperature of 170'. This environmental condition should only last 30 minutes and then return to normal. l Supplemental calculations, following the CVI calculation method !

show that at 120*F the heaters are capable of achieving 70% RH l at degraded voltage (Ref. Calc. NL-038 Rev. 2, CCN 7, included I in Package). conditions. The actual degraded voltage is greater than 414/422VAC as determined from Calculation NL-038 (VN4500-F02-001). l l

Based on discussion above the plant was not and is not outside its design basis and this subject is not reportable.

Therfore, NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0658, does not represent a discrepant condition.

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

Attachments:

1. ACR M3-97-0161

2. Ref 92-25 & PS M3-92-066

3. NL-038, Rev 2, CCN7

4. 97 ENG-01453M3 Second Response (M3-IRF-02145)

NU has concluded that Discrepancy Report DR-MP3-0658 has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for Condition Report (CR) M3-98-1871 will provide the necessary corrective actions to resolve this issue. The approved corrective action for the CR is to implement an FSAR Change Request, post startup, to change Table 1.8-1 and Table 6.5-1 to clarify the degraded voltage condition for the 70% RH criteria.

I Printed 5/1/981:34:23 PM Page 3 of 4

1 hrtheast Utilities ICAVP DR No. DR-MP3-0658 Millstone Unit 3 Discrepancy Report The Charccal testing vendor, NCS was requested to evaluate values for charcoal bed efficiency stated in ERDA-76-21. This assessment determined that the charcoal could exceed 80% RH without impacting Charcoal adsorption measurably. Therefore there is no impact on laboratory testing of charcoal adsorbent.

Since the present configuration meets the requirements of Technical Specification 3.7.9 and it has been shown by evaluation that the design basis can be met with the RH resulting from a degraded voltage condition, this is considered a level 4 deficiency; the FSAR change is for clarification only.

Attachments:

CR M3-98-1871 with approved corrective action plan Telecon J.Pearson, NCS to R. Mcdonald, MP3 Engineering Previously identified by NU? O Yes (G) No Non Discrepant Condition?O Yes @ No Resolution Pending?O ves @ No Resolution Unresolved?O ve. @ No Review initiator: Stout, M. D.

VT Lead: Nerl. Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Date: 4/30/98 sL Comments: Comments on First Response Disa0ree with NU's response that this is not a discrepant condition.

This is a discrepant condition because FSAR Table 1.8-1 and Table 6.5-1 do not take exception to nor provide claritication to RG 1.52, Rev. 2, paragraph C.3.b requirements regarding capibility of the electric heating coil to maintain relative humidity of air entering the adsorber below 70%.

NU's response should also address impact on laboratory testing of charcoal adsorbent which is conducted with a 70% relative humidity entering condition.

Comments on Second Response This is considered to be aTevel 4 FSAR clarification discrepancy.

f Printed 5/1/98134:25 PM Page 4 of 4

ICAVP DR No. DR MP3 0659

. N:stheast Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED !

Reh EW: spem W Potential Operability lasue Discipline: Mechanical Design Discrepancy Type: Component Data Ow l

No System / Process: HVX NRc sigreificance level: 4 Date faxed to NU: j Date Published: 11/24/97 D6screpancy: SLCRS Filter Unit Electric Heating Coil Capacity

Description:

During review of the the Supplementary Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/3B a discrepancy regarding the capacity of the electric heating coil in the filter units was identified.

Regulacry Guide 1.52 Rev. 2, position C.3.b requires the heaters to be designed, constructed, and tested in accordance with the requirements of Section 5.5 of ANSI N509-1976. ANSI N509-1976 Section 5.5.1 states the'. the heater shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air steam mixture (RH=100%) to approximately 70% in the housing space between the moisture ,

separator and prefilter stage, at system design flowrates. FSAR Table 1.8-2 and FSAR Table 6.5-1 state that the filter units are in compliance with Regulatory Guide 1.52, Rev. 2, position C.3.b.

Calculations 97 ENG-01453M3, Rev. O and 8235-9915, Rev. B show that at an air flow rate of 8500 scfm and entering air conditions of 120'F & 100% RH the required heater capacity is J 36 kW. The capacity of the heater at degraded voltage conditions is 37.2 kW. At the current maximum SLCRS air flow rate of 9,800 cfm shown on P&lD EM-148E-12, the required heater capacity increases above the available capacity of the ]

heaters. This will result in a relative humidity greater than 70%. j Review invalid Needed Date l Valid Initiator: stout, M. D. 8 O O 11'1 /S7 !

VT Lead: Nerl, Anthony A B O O 11'11/S7 l

1 /17/S7 VT Mgr: schopfer, Don K G O O IRC Chmn: singh, Anand K O O O 31/20/97 ]

T Date: {

INVALID:

Date: 4/30/98 RESOLUTION: First Response NU has concluded that the issue reported in Discrepancy Repor1, DR-MP3-0659, has identified a condition previously discovered j by NU which does not represent a discrepant condition. l ACR MS 97-0161 was written on 6/1/96 to document discrepancies between the minimum design voltage for Class 1E iieaters and the low voltage capability of the heaters to perform their design basis function, i

Page 1 of 5 Printed 5/1/981:35:12 PM

ICAVP DR N . DR MP3-0659

. N rthe:ct Utilities Millstone Unit 3 Discrepancy Report A design basis review of the degraded voltage calculation (NL-042) was performed and documented on ACR M3-97-0119, which was determined to be reportable. During the review of that ACR, it was noted that the acceptance criteria used for motors (90% of rated voltage,460 volts) was also applied to resistive devices (heaters, rated 480 volts). This results in a 25% reduction in heater output. No justification for this assumption was given in calculation NL-042. Upon further review it did not appear that this reduced operating margin was accounted for in the heater sizing calculation either. This finding was reinforced by a previous review for reportability (Ref 92 25) whereby, neither the electrical nor mechanical calculation accounted for operating margin at reduced voltage (voltago just above the degraded voltage setpoint) during a DBA condition.

At that point the ACR-M3-97-0161 was generated for the suspect equipment and a formal reportabilty review commenced.

ACR M3-97-0161, Item 4, discussed Supplemental Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/38. CVI Inc., provided the MP3 filter assemblies.

CVI Calculation (DWG B2553-9915, change B dated 4 21-92),

determined the relative humidity at design flow and degraded voltage (414V) to be 73.4% RH for discussed Supplemental Leak Collection and Release System (SLCRS) filter units ;

1 3HVR*FLT3A/3B. This calculation determined that discussed Supplemental Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/3B does in fact meet the RH criteria of j ANSI N509 at design flow and degraded voltage. The l Conclusion was based on the following criteria. l ERDA 76-21, Nuclear Air Cleaning Handbook, for Design, Construction and Testing of High-Efficiency Air Cleaning System for Nucleat Application is referred to as a supplement to ANSI-N509. ERDA-76-21 recommends conservative efficiency values for design of 2 inch impregnated activated carbon beds (ref.

section 3.4.2 and table 3.11).

For example, from table 3.4.2, at 85% or less RH, the design for charcoal is 95% efficient at 70* and 98% efficient at 270*.

These temperatues are consistant with the expected condition j when the heaters are required. The ERDA values are l

[

conservative and have been validated with the charcoal testing vendor (NCS) where NCS's assessment stated that charcoal could exceed 80% relative humidity without impacting charcoal adsorption measurably. The MP3 Radiological calculations credit charcoal filters at 95% efficiency. Although, the purchase specification states each electric heater shall reduce the relative humidity to less than 70%, it also states that the heaters are to meet design requirements of ANSI N509, which states that "the heaters shall be sized on the basis of heat transfer calculations showing its capability of reducing the maximum expected relative humidity of the entering air-stream mixture to approximately 70% in the housing space *, The purchase j

specification was providing margin when it specified less than 70% while meeting the specified requirements of ANSI N509. l This is the widely recoanized and acceptable reautrement.

Page 2 of 5 Printed 5/1/961:35:15 PM

ICAVP DR No. DR-MP3-0669

N:rthe:st Utilities Millstone Unit 3 Discrepancy Report Therefore, the filtration unit heaters meet the purchase specification requirements of ANSI-N509. Based on Northeast Utilities Memo No. PSM3-92-066 the effect on the charcoal sample penetration test with higher relative humidities of 73.4%

in the discussed Supplemental Leak Collection and Release Systern (SLCRS) filter units 3HVRTLT3A/B will be j -

unmeasurable. The memo further stated that (NNECO) could exceed relative humidity without impacting the charcoal absorption to a measurable level.

Additionally, concems were sufficiently substantiated to question l the validity of the degraded Grid Voltage Calculations (CR M3- l 97-0119 & LER 97-010). Reviews performed on MP3 heater i applications found that the heaters were able to perform their ]

design functions with the exception of the Hydrogen recombiner j heaters. The corrective action plan for CR M3-97-0119 required j a comprehensive review of all the class 1E components to i ensure operability at the voltage levels at the DGV setpoint f) analyticallimit. (see LER 97-011-00). Calculation NL-038 documents the voltage profile and load flow and NL-042 determines the DGV setpoint. Calculation 97-ENG-01453M3 evaluates the heater minimum voltage capacity. This I Calcult. tion,97 ENG-01453M3, has concluded that minimum f available voltage is 414VAC for heaters at all locations except l; those at the Auxiliary Building Area. The Auxiliary Building Area Heaters Relative Humidity will be approximately 5% higher than !

70% requirement, at a temperature of 170', This environmental l condition should only last 30 minutes and then return to normal. f Supplemental calculations, following the CVI calculation method show that at 120*F the heaters are capable of achieving 70% RH at degraded voltage (Ref. Calc. NL-038 Rev. 2, CCN 7, included in Package). conditions. The actual degraded voltage is greater than 414/422VAC as determined from Calculation NL-038 (VN4500-F02-001).

Based on discussion above the plant was not and is not outside its design basis and this subject is not reportable. Therefore, NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0659, does not represent a discrepant condition.

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

Attachments:

1. ACR M3-97 0161

2. Ref 92-25 & PS M3-92-066

3. NL-038, Rev. 2, CCN 7

4. 97 ENG-01453M3 Second Response (M3-IRF-02146) j NU has concluded that Discrepancy Report, DR-MP3-0659, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-1834 will correct errors in calculations 97 ENG-01453M3 and B235-9915 post startup. Calculation 97-ENG-01453M3 will be revised usino the correct maximum airflow and calculation Page 3 of 5 Printed 5/1/961:35:1e PM i

i

ICAVP DR No. DR-MP3-0689

. N rthert Utilities Millstone Unit 3 Discrepancy Report B235-9915 will be revised using an appropriate ambient and entering temperatures.

DR-MP3-0659 also shows that the ANSI N509 criteria to reduce RH to approximately 70% may not be met under conditions of degraded voltage. CR M3-981871 was written to provide the necessary corrective actions to resolve this issue. The approved corrective action for this CR wil; implement an FSAR Change Request to revise Table 1.8-1 and Table 6.5-1, post startup, to clarify the degraded voltage condition for the 70% RH criteria.

The Charcoal testing vendor, NCS was requested to evaluate values for charcoal bed efficiency stated in ERDA-76-21. This assessment determined that the charcoal could exceed 80% RH without impacting Charcoal adsorption measurably. Therefore there is no impact on laboratory testing of charcoal adsorbent.

Since the present configuration meets the requirements of j Technical Specification 3.6,6.1 and the design basis can be met l with the RH resulting from a degraded voltage condition, this is {

considered a level 4 deficiency; the FSAR change is for clarification only.

Attachments:

CR M3-98-1834 with approved corrective action plan CR M3-98-1871 with approved corrective action plan Telecon J. Pearson, NCS to R. Mcdonald, MP3 Engineering Previously identifled by NU? O Yes @ No Non Discrepent Condition?Q Yes (#) No l Resolution Pending?O Yes G No Resolution unresolved?O Yes

No Review initiator: stout, M. D.

VT Lead: Nort. Anthony A VY Mgr: schopfer, Don K l lRC Chmn: singh. Anand K =

~

Date: 4/30/98 SL Comments: Comment on First Response NU's response did not address the discrepancy in calculation 97-ENG-01453M3, Rev. O which used an airflow rate of 8,500 cfm instead of 9,800 cfm.

From calculation B235-9915, Rev. B at a 120'F 100% RH entering air conditions and 9,300 cfm, the heater KW required is 41.53 KW + housing losses. Note that the housing heat gain determined in B235-9915 was based on a 300'F ambient temperature and is not applicable for the 120'F entering condition. Calculation needs to be revised to determine the correct housing heat loss that needs to be added to the required heater capacity. At 414 volts the heater output is 37.2 KW for 3A/3B. At the switchyard voltage (not defined in calc) the heater output is 40.4KW for 3A and 39.7KW for 38. Therefore the heater capacity is not sufficient to limit the relative humidity to 70% RH.

Printed 5/1/961:35:18 PM Page 4 of 5

1 ICAVP DR N2. DR-MP3-0669

- N:rthert Utilitie3 Discrepancy Report Millstone Unit 3 FSAR Table 1.8-1 and Table 6.5-1 do not take exception to nor provide clarification to RG 1.52, Rev. 2, paragraph C 3.b requirements regarding capibility of the electric heating coil to maintain relative humidity of air entering the adsorber below 70%.

NU's response should also address impact on laboratory testing of charcoal adsorbent which is conducted with a 70% relative humidity entering condition.

Comment on Second Response Based on the corrective actions for CR M3-98-1834 to correct airflow and housing heat loss in calculations B235-9915 and 97-ENG-01453M3 and the corrective action for CR M3-98-1871 to revise the FSAR to provide a clarification to Reg. Guide 1.52, Rev. 2 requirements this is considered to be a level 4 discrepancy.

Printed 5/1/961:35:19 PM Page 5 of 5

)

ICAVP DR No DR-MP3-0810

, N:rtheast Utilities ;

, MiliStone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED 1 Potential Operability issue Discipline: Electrical Design Om Discrepancy Type: Calculation g System / Process: DGX ,

NRC Significance level: 4 Date faxed to NU: I Date Published: 1/10/98 l l

D6screpancy: Could not locate calculation which verifies adequacy of control I circuit voltage at 4kV breakers l

Description:

j Design Basis Summary Document 3 ELE-001, Rev.1, paragraph 12.2.3 states:

The control voltage for the 4160 V breaker shall be nominally 125 V DC ungrounded. The closing coil shall operate over a range of 90 to 140 volts. The tripping coil shall operate over a

, range of 70 volts and 140 volts.

1 Since the breakers may be required to operate at any time and )

at any range of acceptable battery voltage the ICAVP review I attempted to verify that adequate voltage was always available !

at the closing and tripping coils, especially during minimum DC bus voltage.

We could not locate any calculations which evaluated control cable voltage drop, therefore we could not confirm that the breakers are always operable.

Review Valid invalid Needed Date initiator: Warner, l. B 0 2/17/97 VT Lead: Neri, Anthony A G O- 0 12/57/97 VT Mgr: schopfer, Don K B O O 12/23/97 IRC Chmn: singh, Anand K 8 0 0 2/31/97 Date:

INVALID:

Date: 4/30/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that the issue reported Discrepancy Report, DR-MP3-0810, does not represent a discrepant condition.

Calculation BAT 196-1241E3 and BAT 2-06-1243E3 (125VDC Calculations) provide the available voltage at electrical devices during specific operating scenarios and compare these values to minimum required operating voltages. In both calculations (one for each 1E train), Attachment B, Node ID #8 provides the voltage at the breaker trip /close coils foi N evaluated scenario For each device in a table format, the operating scenario, the voltage at the device (protective relays, trip /close relays, etc.), and the required voltage is identified.

Printed 5/1/981:35:58 PM Page 1 of 9

ICAVP DR N2. DR-MP34810

- N:rtheast Utilities Mmstone Unit 3 Discrepancy Report

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

Conclusion:

NU has concluded that the issue reported Discrepancy Report, DR MP3-0810, does not represent a discrepant condition.

Calculation BAT 1-96-1241E3 and BAT 2 96-1243E3 verify that adequate tripping and closing voltage is available at the closing and tripping coils, especially during minimum DC bus voltage.

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

SECOND RESPONSE:

Disposition:

NU has concluded that the ' Follow-Up" items to Discrepancy Report DR-M3-0810 do not represent discrepant conditions.

Response to these items only provides clarification of the issues.

Item 1.

The fast transfer circuit for the 34C bus was reviewed. NU concurs with the S&L computation that there is approx. 6 ohms of circuit resistance in the breaker control circuit (Path C). T':e r close coil is rated 6 amps @ 125VDC. The minimum voltage required to close the circuit is 90V. The current drawn by the close coil will be 4.34 A (6* available coil voltage /125). We can take credit for conductor resistance at a lower temperature (40 deg. C) since the conductors to the closing coil are not energized until the closing coil operates and will assimilate hmbient temperature. This equates to an approx. 25V control circuit voltage drop requiring the battery voltage to be greater than 115V to assure the fast transfer circuit will function propedy.

Item 2.

The voltage profile contained in the DC calculations indicates over 115V is available @ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months into the battery discharge for the conservative loading profile used for the LOP scenario (the tabulated panel loading is connected load with few exceptions),

s At a minimum, the loss of a battery charger would be alarmed on Low DC volts @ 129V The plant TS dictate a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LCO, therefore, the swing charger will be placed into service promptly, long before a voltage of 115V is reached, it can be concluded that NU does not rely on the chargers to support DC voltage for the operation of the fast transfer circuit.

A calculation change will be processed (for additional information purposes only) to address this specific scenario. The corrective action plan for CR M3-98-0668 was revised to track this activity as a post-start up item.

Page 2 of 9 Printed 5/1/961:36:02 PM

ICAVP DR N2. DR-MP3-0810

. N::rthe:st Utilities Millstone Unit 3 Discrepancy Report Significance level criteria does not apply to the above follow-up items as well as items in the initial DR (IRF 1426), as they do not represent discrepant conditions.

Request for Additional Information - April 14th:

In the April 14,1998 meeting with Sargent and Lundy on this subject, a question was raised as to the remainder of DC controlled breaker control circuits. The reviewer noted that the high speed transfer case outlined in the DR was simply an example and that NNECO needed to address circuits in general.

In response to that new understanding, we note that all circuits whose breakers must operate for all analyzed scenarios including design basis and beyond the design basis events (such as SBO), have been analyzed to ensure that sufficient DC system voltage is present at the time of need, to power the required breaker operations-related devices. The remaining breakers would be of no usefulness without the reestablishment of ac power, at which time the battery charger is back in service restoring DC system voltage. We do not'e, however, that the circuits analyzed are representative of most circuits in terms of conductor length, and would likely envelope these. The high speed transfer circuit falls into this category as a worst case example due to unusual circuit conductor lengths (due to interiocks and permissives) since ac power is available at the time of transfer; however, a very detailed analysis of the circuit as presented in this response reveals it to be capable of successful operation without the need for the battery charger, This is, however, not required for the reasons stated above.

CONCLUSIONS:

NU has concluded that the " Follow-Up" items to Discrepancy Report DR-M3-0806 do not represent discrepant conditions. NU does not rely on the chargers to support DC voltage for the operation of the fast transfer circuit. Based on using conductor resistance at ambient temperature and battery voltage greater than 115V assures that the fast transfer circuit will function proper 1y.

l Significance level criteria does not apply to the above follow-up items as well as items in the initial DR (IRF 1426), as they do not represent discrepant conditions.

l THIRD RESPONSE:

1 Disposition:

NU has concluded that the new issue of updating the DC control voltage drop calculation for all Class 1E,4kV and 480V circuits does not represent a discrepant condition.

The corrective action plan for CR M3-98-0668 has been changed I to add the followina items as aareed upon in a S&L conference Printed 5/1461: 36:03 PM Page 3 of 9

i 1

ICAVP DR No. DR-MP3-0810 l

- N::rtheast Utilities

, Millstone Unit 3 Discrepancy Report l call on 4/23/98. NU will provide additional analysis / evaluation to l address DC control circuits used for Class 1E 4kV and 480V {

circuit breakers which are not required to operated during design l basis scenario. This is a calculation enhancement. The present !

calculations demonstrate operation of the required circuit {

breakers under the design basis scenario. The original startup !

calculation done by Stone & Webster, generically addressed all circuit breakers by evaluating the worst case control circuit i configuration.

l NU considers the updating of these calculation as an j enhancement and not a discrepant condition. Significance level l criteria does not apply to this DR since none of the identified items represent discrepant conditions.

Conclusion:

)

NU has concluded that the new issue of updating the DC control I voltage drop calculation for all Class 1E,4kV and 480V circuits !

does not represent a discrepant condition. l NU has agreed in the phone conversation on 4/23/98, to update the two original (start-up) de control voltage drop calculations for circuit breakers not included in existing operating design basis scenarios.

NU considers the updating of these calculations as an enhancement and not a discrepant condition.

Significance level criteria does not apply to this DR since none of the identified items represent discrepant conditions.

Previou.ly identmed by NU? O ve. (@ No Non Di.crepent condiuon?O ve. (#) No Re.oluuon Pending?O v.. @ no n..oiution unr..oiv.d?O ve. @ no Review initiator: Warner, l.

VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date: 4/30/98 SL Comments: COMMENTS ON INITIAL RESPONSE:

Sargent & Lundy agrees that, for those circuits required to operate under the scenarios described in Calculation BAT-SYST-1240E3, NU has modeled and analyzed each of those circuits and that NU has concluded these circuits are able to perform their safety-related function..

The point in question is that the battery sizing calculations (e.g.,

BAT 1-96-1241E3, BAT 2 96-1243E3, BAT 3-96-1245E3, BAT 4 j 1246E3) evaluate ". . the available voltage at electrical devices during specific operating scenarios..." and do not address other possible operating scenarios. For example (see detailed evaluation further down in the text), it appears that the reserve feed breaker to the ESF bus may be unable to close on an ESF bus undervoltage.

Page 4 of 9 Printed 5/1/961:36:o4 PM

ICAVP DR No. DR MP3 0810

. Nsrthe:st Utilities Millstone unit 3 Discrepancy Report Sargent & Lundy could not find evidence (e.g., a calculation) which addresses whether safety-related circuits for the following breaker circuits would have adequate voltage at the close and trip coils (90 and 70 volts, respectively) to be able to perform their safety related function under conditions undefined in the battery sizing calculations:

Bkr Load: Description (Device ID) l 32R01-2: 480V Bus 32R Supply Breaker (3EJS*ACB-AC) 32R04-2: MCC Aux Bldg (3EHS*MCC3A1) 32R05-2: MCC Rod Control Area (3EHS*MCC3A2) 32R06-2: Aux Bldg Air Filter Unit (3HVR*FLT1 A) 32S-1T-2: Bus Tie to Bus 32R (3EJS*ACB-T2A) 32 S01-2: 480V Bus 32S Supply Breaker (3EJS*ACB-AB) l 32S07-2: Fuel Bldg Filter Assembly (3HVR*FLT2A) 32T-1T 2: Bus Tie to 32S (3EJS*ACB-T1 A) 32T01-2: 480V Bus 32T Supply (3EJS*ACB-AA) 32T05-2: MCC Control Building (3EHS*MCCA12) i l

32T06-2: MCC Circ. & Serv. Wtr. Pump Hse. (3EHS*MCCA15) 32T09-2: MCC Safeguards Area (3EHS*MCC1 A4) 32Y-1T-2: Bus Tie to 32R (3EJS*ACB-T4A) 32Y01-2: 480V Bus 32Y Supply (3EJS*ACB-AD) 15G-14U-2N: EDG Neutral Breaker (3 ENS *ACB-GNA) 23SA3-34C-2: RSST Supply to 34C (3 ENS *ACB-AR) 34C012: 480V Load Center 32Y (3 ENS *ACB-AD) 34C03-2: 480V Load Center 32T (3 ENS *ACB-AA) 34C04-2: 480V Load Center 32S (3 ENS *ACB-AB) j 34C05 2: 480V Load Center 32R (3 ENS *ACB-AC) j 34C06-2: Quench Spray Pump (3QSS*P3A) 34C07 2: Residue Heat Removal Pump (3RHS*P1 A) 34C08-2: Safety injection Pump (3SlH*P1 A) 34C10-2: Reactor Plant CCW Pump (swing pump) (3CCP*P1C) 34C20-2: Containment Recirc. Pump Pic (3RSS*P1C) l 34C21-2: CVCS Charging Pump P3A (3CHS*P3A) ,

f 34C22-2: CVCS Charging Pump P3C (swing pump)

(3CHS*P3C)

To illustrate the point in question, Sargent & Lundy reviewed the control circuit for 4KV Circuit Breaker 3 ENS *ACB AR which is not required to either close or trip as shown in Calculation BAT 196-1241E3. The following are the results of this review.

Five circuit paths were reviewed from the incoming fuses at Switchgear 3 ENS *SWG-A to the close coil 52X for breaker 3 ENS *ACB-AR (Schematic Diagram 12179-ESK 5BD, Revision 24), and the associated cable number and Mark #, conductor size, conductor length, and 9000 resistance are shown below, starting at the load side of the fuse at the positive polarity:

Path A: Wire PC1 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft):

Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16, 38 feet, 0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MB5 (Cable 3ENSAOC356.

Printed 5/1/961:36:05 PM Page 5 of 9

ICAVP DR No. DR MP3-0810

. N:rtheast Utilities '

Millstone Unit 3 Discrepancy Report NHT-32, #14,298 feet,0.0034171 W/ft); Wire C01 from 3CES*MCB-MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16, 38 feet,0.0055465 W/ft); Wire C01 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet, 0.0021421 Wift); Wire C01 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire -

COO from 3RPS*PNLAS to 3 ENS *SWG-A (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171). Total resistance is 4.0237 ohms at 6 amps, or 24,14 voltage drop for Path A.

Path B: Wire PC1 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft);

Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire CO5 from 3CES*MCB-MB80 to 3RPS*RAKOTXA (Cable .

3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wiro CO9 from 3RPS*RAKOTXA to 3CES*MCB-MB80 (Cable 3ENSAOC357 NHT-26172 feet,0.0034171 W/ft); Wire CO9 from 3CES*MCB-MB80 to 3 ENS *SWG A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16, 38 feet 0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MBS (Cable 3ENSAOC356, NHT-32, #14,298 feet, 0.0034171 W/ft); Wire CO1 from 3CES*MCB MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); f Wire CO1 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire C01 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to 3 ENS *SWG-A (Cable 3ENSAOC353, NHT-26,

14,130 feet,0.0034171). Total resistance is 6.2977 ohms at 6 amps, or 37,79 voltage drop for Path B.

Path C: Wire PC1 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO6 from 3 ENS *SWG-A to 3CES*PNLBG30 (Cable 3ENSAOC354, NHT-35, #14,110 feet, 0.0034171 W/ft); Wire CO7 from 3CES*PNLBG30 to 3 ENS *SWG-A (Cable 3ENSAOC354, NHT-35, #14,110 feet,0.0034171 W/ft); Wire CO7 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO7 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102. NHQ-47. #16. 38 feet.

Printed 5/1/981:36:06 PM Page 6 of 9

i ICAVP DR No. DR-MP3-0810 j

. N:rtheast UtilitlIs Millstone Unit 3 Discrepancy Report 0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB- 1 I

MBS (Cable 3ENSAOC356, NHT 32, #14,298 feet,0.0034171 W/ft); Wire C01 from 3CES*MCB-MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft);

Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire CO1 )

I from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire C01 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26,

14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to 3 ENS *SWG-A (Cable 3ENSAOC353, NHT-26, #14,130 feet, 0.0034171). Total resistance is 5.8739 ohms at 6 amps, or 35.24 I voltage drop for Path C.

Path D: Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 l (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft);

Wire CO3 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MB5 (Cable 3ENSAOC356, 1 NHT-32, #14,298 feet,0.0034171 W/ft); Wire C01 from l 3CES*MCB-MB5 to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT- l 32, #14,298 feet,0.0034171 W/ft); Wire C01 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16, 38 feet,0.0055465 W/ft); Wire C01 from 3CES*MCB-MB80 to 3 ENS *SWG A (Cable 3ENSAOC350, NHT-60, #12,158 feet, 0.0021421 W/ft); Wire CO1 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to 3 ENS *SWG-A (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171). Total resistance is 4.0237 ohms at 6 amps, or 24.14 voltage drop for Path D. I Path E: Wire C05 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); COS from 3CES*MCB-MB80 to 3RPS*RAKOTXA (Cable 3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wire CO9 from 3RPS*RAKOTXA to 3CES*MCB-MB80 (Cable 3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wire CO9 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet, 0.0021421 W/ft); Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16, 38 feet,0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MBS (Cable 3ENSAOC356, NHT-32, #14,298 feet, 0.0034171 W/ft); Wire C01 from 3CES*MCB-MBS to 3CES*MCB- l MB8 (Cable 3EN.SAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 ,

I (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft);

Wire CO1 from 3CES*MCB-MB80 to 3 ENS *SWG A (Cable !

3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO1 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to 3 ENS *SWG-A (Cable 3ENSAOC353, NHT 26,

14,130 feet,0.0034171). Tota' asistance is 5.8739 ohms at 6 amps, or 35.24 voltage drop for Path E.

Page 7 of 9 Prtnted 5/1/961:36:07 PM

ICAVP DR Ns. DR-MP3-0810

. N:rtherst Utilities Millstone Unit 3 Discrepancy Report Similar1y, the circuit resistance from the swit:hgear fuses to the trip coil of Circuit 3 ENS *ACB-AR is 1.0984 a 4 3.1350 ft,r two paths that were reviewed, resulting in voltage drops of 6.59 and s 18.81 volts, respectively.

As noted in the review, the voltage drop for the close coil of Circuit 3 ENS *ACB-AR, ranging from 24.14 to 37.79 vo!!s, is significant. Since 90 volts is required at the close coil, a voltage of 114 to 128 volts is required (90 + 24 = 114 and 93 + 38 = 128) at Switchgear 3 ENS *SWG-A (and an even higher voltage at 3BYS*PNL1 and the battery terminals). This would suggest that NU is taking credit for the chcrger, and not the battery, supplying power to de loads during normal operation, for the battery would not be able10 sustain a voltage level of that magnitude.

However, if the charger failed, the battery would supply power to the de loads, but the battery would not be able to fumish adequate voltage to the close coil of 3 ENS *ACB-AR (the battery would, however, be able to adequately supply power to the de loads listed in the scenario described in Calculation BAT-SYST-1240E3). [ Note: There is a spare charger connected (but not energized) to Panel 3BYS*PNL1 which could supply power to the loads if the normal charger failed, howaver, the battery would still need to fumish power to the de Ic : until the spare charger was energized, if 3 ENS *ACB-AR was required to operate during this peMod, it could not fumish the necessary 90 volts at the close coil of 3 ENS *ACB-AR due to the aforementioned large voltage drop.}

In addition, if the charger, and not the battery, is supplying power to de loads during normal operation, then on a 4KV bus undervoltage, the charger is disabled (on loss of power) and a bus fast tran;fer fmm the normal supply to the reserve supply cannot be performed becausa this Breeker 3 ENS *ACB-AR cannot close (because the battery cannot provide the required 90 volts to the close coll). Sargent & Lundy requests that NU:

- Provide the calculation (s) or other documentation to verify that the de control circuits for the safety-related services listed above have been analyzed for voltage drop and adequate voltage exists at the close and trip coils. If such documentation does not exist, then:

1. Concur (or indicate NU's differences) with Sargent & Lundy's analysis of Breaker 3 ENS *ACB AR as described in this discrepancy report.

2. Verify tl,et NU re!ws ori the charger rather than the battery for supplying power under normal opertting car.ditions to the dc loads. % battery is relied upon, explain how the bettery can suMy tt'ese cads with adequate voltage to operate the close and trl G ue spare charger is relied upon, explain how the Ic . 7 m cdequately powered from the time the normal charger

'* sntil the time the spare charger is energized.

!; the charger is relied upon for supplying de loads during normal operation, either concur wit, I argent & Lundy's conclus;on that fast transfer :annot be accomplisteid, or if NU disagrees with

! Saraent & Lundy's essessment. thesi explain how fast transfer is f Prinbd 5/16sb:36.oS PM Page 8 of 9

I ICAVP DR N3. DR-MP3-0810

. N:rther2t Utilities Millstone Unit 3 Discrepancy Report accomplished.

COMMENTS ON SECOND RESPONSE:

Sargent & Lundy accepts NU's conclusion thct battery chargers are not required to support DC voltage for the operation of the fast transfer circuit.

We also agree with the NU statement:"We do note, however, that the circuits analyzed are representative of most circuits in terms i:1 conductor length, and would likely envelope these."

We do not agree that this issue is a non discrepant condition for

~ the following reason:

All of the 4kV and 480V safety related switchgear fed motors are required to operate under various conditions. Calculations BAT 1-96-1241E3 and BAT 2-96-1243E3 outline a design basis condition which defines a subset of required 4kV and 480V loads. It does not address other possible scenarios in which the excluded subset of safety related loads may be required to operate. While these excluded loads may not operate under the conditions defined in the calculations NU should be able to demonstrate, by calculation, that there is adequate voltage available to the equipment under any operating conditions. Since the voltage drop to each load is a function of the control circuit length these circuit lengths should be calculated and operability of each breaker under worst case DC voltage should demonstrated.

COMMENTS ON THIRD RESPONSE:

As discussed in the preceding paragraph we do not agree with NU's statement: "This is a calculation enhancement." Our classification of this issue as a discrepancy is based on the fact that NU presently does not have the calculations required to verify that all safety related 4kV and 480V switchgear powered loads are operable undr all conditions.

I Based on NU's commitment to perform the required calculations !

sad the belief that the most limiting condition hn already been I analy ed we have classified this as a Level 4 discrepancy.

l i

1 l

1 Printed SI1S61:36:09 PM Pye 9 of 9 l 1

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ICAVP DR No. DR-MP3-0827

. N:rth cct Utilities Millstone Unit 3 Discrepancy Report l Review Group: System DR RESOLUTION ACCEPTED Review Element: System Des @

Potential Operability issue l Discipline: Mechanical Design Q y,,

Discrepancy Type: Component Data

@ No SystenVProcess: DGX NRC Significance level: 4 Date Faxed to NU:

Date Published: 1/22/90 Discrepancy: EGS Pipeline Data Discrepancies l

Description:

Review of the EGS pipeline data yielded following discrepancies: ]

1. Line List for the EGS piping contains design pressure and temperature data. No calculation was found that supports these l data. Calculation for design pressure and temperature for EGS i system was requested via RFI #MP701. NU reply IRF #00993 l stated that the requested information was provided in the '

calculation P(T)-0997. Calculation P(T)-0997, Rev. O,

" Emergency Diesel Generator (EGS) Operating Conditions (for l SDP)" documents operating pressure and temperature for I various system operating modes, but does not determine design pressure and temperature.

2. Line List for EGS piping does not show design pressure for the fresh water expansion tank Class 3 overflow lines 3-EGS-750-7-3 and 3-EGS-750-8-3.

Review Valid invalid Needed Date initiator: Obersnel,Bojan. 8 O O 12/18/97 VT Lead: Neri, Anthony A G O O 12/18/S7 VT Mgt; schopfer, Don K G O O 2r23/97 IRC Chmn: singh, Anand K S O O l'S'S8 Date:

INVALID:

l Date: 4/30/98

RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0827, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criter'a and found to have no operability or reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria.

FSK 9-20/9-21 included design pressure and temperatures for this system. There are no calculations for design pressure and temperature. The design pressure and temperature are based on the max operating pressure and temperature prior to startup (either equal to or greater than). The FSK's documented these values. SDP EGS-01345M3 (5/25/97) documents the operating pressures and temperatures and is consistent with the FSK's and LDT. PDDS does not show design pressure for line numbers 3-EGS-750-7-3 and 3-EGS-750-8-3 (P=0psig).

Printed 5/1s81:37Ao Ptl Page 1 of 2

ICAVP DR N . DR-MP3 0827

- N rthea:t Utilities Millstone Unit 3 Discrepancy Report CR M3-98-2026 was closed to CR M3-98-0138. The corrective actions in CR M3-98-0138 will correct these issues post startup.

There is no affect on License or Design Basis.

Conclusion:

NU has concluded that Discrepancy Report, DR-MPL-0827, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 Pl-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.c of U3 PI 20 deferral criteria. FSK 9-20/9-21 included design pressure and temperatures for this system. SDP EGS-01345M3 (5/25/97) documents the operating pressures and temperatures and is consistent with the FSK's and LDT. PDDS does not show design pressure forline numbers 3EGS-750-7-3 and 3-EGS-750- !

8-3 (P=0psig). Bin CR M3-93-0138 will correct these errors post startup. There is no affect on License or Design Basis.

Previously identified b/ NU? O Yes (#) No NonDiscrepantCondition?O Yes (#) No ResolutionPending?O ves @ No Resolution Unresolved?O vos @ No l Review initiator: Obersnel,Bojan.

VT Lead: Nert, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: singh, Anand K oste: 4/30/98 sL Conmnts: Based on the results of the calculation SDP-EGS-01345M3, and the NU disposition for this DR, S&L concurs that the discrepancies in this DR do not impact the design or licensing basis. S&L also agrees that the corrective action is deferrable.

Therefore, the NU disposition is acceptable.

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Prirted 5/1/961:37:44 PM Page 2 of 2 i

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ICAVP DR No, DR-MP3-0829 "N:rthert Utilities Millstone Unit a '

Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue l Discipline: Mechanical Design Discrepancy Type: Component Data Om System / Process: DGX g

NRC Significance level: 4 Date faxed to NU:

Date Publistwi: 1/22/98 Discrepancy: EGA Pipeline Data Discrepancy

Description:

Review of the EGA pipoline data per the Pipeline Checklist yielded following discrepancies:

1 Line List for the EGA piping contains design pressure and temperature data. No calculation was found that supports these data. Calculation for design pressure and temperature for EGA system was requested via RFI #MP701. NU reply IRF #00993 stated that the requested information was provided in the calculations P(T)-1042 and 3-92-102-263M(3). Calculation P(T)-

1042, Rev. O, " Operating Conditions in the Emergency Diesel Generator Air Start System (EGA)" documents operating pressure and temperature for various operating modes, but does not determine design pressure and temperature. Calcuiction no. l 3-92-102-263M(3), Rev. O, CCN 1, " Emergency Diesel Starting l I

Air System Design Pressure and Temperature" reviews consequences of raising air compressor relief valve set point from 450 psig to 500 psig on the affected portion of the EGA system from the air compressor to the air receiver tank. This calculation is classified "non-QA", and the only safety related portion of the EGA system included in it, is the piping from the air dryer to the air receiver tank. It is noted that the calculation no. SDP-EGA-01342M3, Rev. 02, " Emergency Genera'or Air l (EGA) Stress Data Package" lists the EGA system design l conditions in a table on page 14 of the calculation; however, it references Line List as the source of the information.

Review Valid Invalid Needed Date initiator: Obetsnel,Bojan. B 0 0 12/22/97 VT Lead: Neri, Anthony A B O O 12/20/97 VT Mgr: schopfer, Don K O O O 12/2w7 IRC Chmn: singh, Anand K 8 0 0 1'18'S8 Date:

INVALID:

Date: 4/30/98 REsOLUTPON: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0829, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. The P&lD's correctly show the line numbers. The isometric Drawings do not indicate all line numbers.

Printed 5/1/961:38:22 PM Page 1 of 3 k

N:rtherct Utilities ICAVP DR No. DR-MP3-0829 l Millstone Unit 3 Discrepancy Report r

FSK 9-20/9-21 included design pressure and temperatures for this system. There are no calculations for design pressure and temperature. The design pressure and temperature are based on the max operating pressure and temperature prior to startup (either equal to or 9reater than). The FSK's documented these values. SDP-EGS-01345M3 (5/25/97) documents the operating 3 pressures and temperatures and is consistent with the FSM's l and LDT. {

PDDS (LDT) has the to/from line numbers reversed for EGA 90, ,

91,88,89,86. CR M3-98-2026 was written to correct these j isometric drawing errors and provide PDDS updates post startup. j l

The scope and classification of calculation 3-92-102 263M(3) l were previously addressed in Discrepancy Report, DR-MP3-0688.

CR M3-98-2026 was closed to CR M3-98-0138. The corrective actions in CR M3-98-0138 will correct these issues post startup.

There is no affect on License or Design Basis.

Conclusion:

I NU has concluded that Discrepancy Report, DR-MP3-0829, has i identified a condition not previously discovered by NU which I requires correction. This discrepancy meets the criteria specified I in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI 20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. The P&lD's correctly show the line I numbers. The Isometric Drawings do not Indicate all line numbers. PDDS (LDT) has the to/from line numbers reversed for EGA-90,91,88,89,86. CR M3-98-0138 will correct these isometric drawing errors and provide PDDS updates post startup.

There is no affect on License or Design Basis.

Previously identified by NU7 O Yes @ No NonDiscrepantIondition?O Yes T) No ResolutionPending?O res @ No Resoluuon Unrusolved?O yes @ No Review Acceptable Not Acceptable Needed Date initiator: Obersnel.Bojan.

O ##"98 VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K

] FSV98 IRC Chmn: Singh, Anand K B O O "xvSe O O O Date: 4/30/98 SL comnwnts: Based on the results cf the calculation SDP-EGA-01342M3, the disposition of DR-MP3-0688, and the NU disposition for this DR, S&L concurs that the discrepancies in this DR do not impact the design or licensing basis, and that the corrective action is deferrable. Therefore, the NU disposition is acceptable.

The NU disposition refers to calculation SDP EGS-01345M3 as the document which documents the operating pressures and temperatures. This calculation is for the EGS system. The corresponding calculation for EGA system, subject of this DR, is Pitnted 5/1/961:38:26 PM Page 2 of 3

ICAVP DR No. DR-MP3-0829

. Ncrthsa:t Utiliti33 Millstone Unit 3 Discrepancy Report SDP-EGA-01342M3, as noted in the discrepancy description.

S&L considers this an editorial error, which does not affect evaluation of the disposition.

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ICAVP DR N2. DR-MP3-0831 l . N:rthea:t Utilitie3 Millstone Unit 3 Discrepancy Report i

Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: system Installation p Discipline: I & C Design Om Discrepancy Type: Installation implementation g ,

l System / Process: sWP NRC significance level: 4 Daf:e faxed to NU:

Date Published: 1/10/98 l Discrepancy: ;nappropriate Sealing of instrument Connection 1

Description:

The following documents state that the use of Teflon Tape for sealing of instrument connections is forbidden and that grafoil ;

tape shall be used as the thread sealant: I&C Technical Bulletic l

102, Tubing Installation Specification SP-EE-212, and Piping i instalbibn Specification SP-ME-570. j i

l l Contrary to the above requirement the following instruments l were observed, during the system walkdowns, to have Teflon Tape applied to their threaded connections: 3SWP*FIS36A,

! 3SWP*PDIS163, 3SWP-Pl134A, and 3SWP-P11348.

Review Valid invalid Needed Date Initiator: sarver, T. L 8 0 0 12/is/97 VT Lead: Neri, Anthony A 8 O O 12/is/97 ,

l VT Mgr: schopfer, Don K B O O $2/23/97 l

IRC Chmn: singh. Anand K B D 0 52/ai/97 l

Date: ]

INVAllD: l

! Date: 4/30/98 RESOLUTION: First Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0831, has identified a condition not previously discovered by NU which 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 l concems and meets the Unit 3 deferral criteria. CR M3-98-0511 l has been written to develop and track resolution of this item per RP-4. ,

First

Conclusion:

NU has concludd that Discrepancy Report, DR-MP3-0831, has I identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concerns 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.

Second Disposition:

NU has concluded t. hat the new issue reported in Discrepancy Report, DR-MP3-0831 coot not represent a discrepant condition. A ficid walkdown of the instruments found no teflon tape present for 3SWP*FIS36A. Inspection was from the tap at _

Printed 5/1/961:38:54 PM Page 1 of 2

ICAVP DR NO. DR-MP3-0831

. N:rthe:st Utilities Millstone Unit 3 Discrepancy Report

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the pipe to the instrument on wall. The presence of grafoil tape was noted at the junction block. Teflon tape was found on 3SWP-PDIS163,3SWP-P1134A and 3SWP-P1134B.U3 PI 20 section 1.3.2 e defines the type of discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design bas!s.NU concludes that the assignment of priority 4 is correct and in accordance with U3 PI 20 section 1.3.2 e. Significance level criteria does not apply to the new issue as this is not a discrepant condition.CR M3-98-0511 was closed to Bin CR M3-98-0165. The corrective actions in Bin CR M3-98-0165 will correct these issues post startup.NU considers the overall classification of the DR to be significance level 4.

'Second

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0831 does not represent a discrepant condition.

3SWP*FIS36A does not have teflon tape installed. NU has concluded that the remaining issues are deferrable based on section 1.3.2.e of U3 Pt 20. The corrective actions in Bin CR M3-98-0165 will correct these issues post startup. NU considers the overall classification of the DR to be significance level 4.

Previously identified by NU? O Yes (9) No Non Discrepent Condition?U ves (#) No Resolution Pending?O ves (*D No ResolutionUnresolved?O yes @) No Review l Accagnable Not Acceptable Needed Date In h N C .

VT Lead: Neft, Anthony A j' VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K O O Date: 4/30/98 SL comments: First Comment: 1 DR-MP3-0831 identifies four components which have teilon tape used as a thread sealant. Teflon tape tape is expressly prohibited for sealing of instrument connection because it is known that l teflon tape can t;reak off arid inhibit / prevent correct operation of l the instrument, ,

One of the four components cited in the DR is 3SWP*FIS36A, )

which is used to detect service water low flow to the Control l Building Air Conditioning Water Chiller 3HVK*CHL1 A. Upon l detection of this low flow condition, this chiller is stopped. l Due to the rcquired functionality of this chiller,11 is not acceptable j to postpone rework of the installation of SSWP*FIS36A until after Martup.

Second Comment:

Acceptable second response from NU.

Printed 5/1/961:38.s7 PM Page 2 of 2

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Nrrthe=t Utiliti;s ICAVP DR N3. DR-MP3-0915 Millstone Unit 3 Discrepancy Report Review Group: Prograrnmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Potential Operability issue Discipline: Mechanical Design O yes Discrepancy Type: Corrective Action g System / Process: SWP NRC Significancelevel: NA Date faxed to NU. ;

Date Published: 1/25/98 l Disc;epancy: No Corrective Action Plan included in ACR

Description:

ACR M3-96-0721 does not conform to the requirements of the I Corrective Action procedure, i.e., no corrective action plan is j included which describes the actions being taken to correct the identified deficiency and close the ACR. Additionally on Form RP 4-4, there is a statement saying "Close Per MRT l Comments." There are no MRT comments included in the ACR.

Review Valid invalid Needed Date l initiator: Wrona, S. P. 8 O O 1/21/98 l VT Lead: Ryan, Thomas J B O O 1/21/98 l

VT Mgr: Schopfer, Don K B O O ii22/98 l lRC Chmn: Singh, Anand K B O O 1/22/98 Date:

INVALIO:

Date: 4/30/98 RESOLUTICN: Disposition NU has concluded that Discrepancy Report, DR-MP3-0915, 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 M3-98-0652 has been written to develop and track resolution of this item per RP-4.

Conclusion NU has concluded that Discrepancy Report, DR-MP3-0915, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0652 has been written to develop and track resolution of this item per RP-4.

NU's second disposition NU has concluded that the overallissue reported in Discrepancy Report, DR-MP3-0915 does not represent a discrepant condition.

ACR M3-96-0721 was completed per C;orrective Action Procedure, RP-4, Revision 2. This issue is a duplicate of DR-MP3-0867. The disposition from DR MP3-0867 is;ACR M3 Printed 5/1/981:30:35 PM Page 1 or 2

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ICAVP DR N3. DR-MP3-0915 N:rthraat Utilities Millstone Unit 3 Discrepancy Report 0721 was closed after initial review (RP4-4, page 1) and sent to j the Events Analysis Group for processing. Per step 1.5.8 of RP- l 4, Rev 2, RP4-5, " Transmittal Sheet *, block 5 was completed l and the ACR was entered into the AITTS system. Step 1.5.8.c :

directs the reviewer to step 1.7.30 (send " Post-Closure" ACR information to appropriate individuals and groups), thus !

bypassing the requirement of implementing a corrective action plan. The current revision of RP-4, Revision 5, allows a CR to !

be closed to another CR, Trouble Report, or AWO (any of which wik be notated within the CR and within the MRT meeting notes). Additionally, the statement, "close per MRT comments",

are the MRT comments. At the time of closure, the only MRT comments incorporated within the ACR's was to close or provide resolution statements. RP4-1 page 2 Rev. 7 now has a specific l location to denote MRT closure during preliminary review.The disposition for the new issue is;The technical issue was resolved as stated in the CR

Cicsed to AWO M3-96-14784 will/has repaired " thus indicating that the issue was addressed. The AWO was closed on 9/7/96. Significance level criteria do not ;

apply as this is not a discrepant condition. !

NU's second Conclusion 1 1

NU has concluded that the overallissue reported in Discrepancy Report, DR-MP3-0915 does not represent a discrepant condition.

ACR M3-96-0721 was completed per Corrective Action Procedure, RP-4, Revision 2. A review of the Corrective Action procedure, RP-4 Rev. 2, reveals that the ACR was closed I accordingly. Significance level criteria do not apply as this is not a discrepant condition.

Previous;y identifled by NU7 (,_) ves (4.) No Non Discrepant condition?(*) Yes C) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Navarro, Mark 1 VT Leed: Ryan, Thomes J VT Mgr: schopfer. Don K 1RC Chmn: singh, Anand K Date: 4/30/98 sL comrnents: S&L comments to NU's first response The CR which was generated does not contain a corrective action plan. Altematively, the DR Review Screen by the expert panel and UPM does not contain any statement that the initial technical issue which was documentsd in ACR M3 96-0721 hasindeed been resolved which wou!d support the Review Screen conclusion that the issue is only " Administrative".

Since we have no indication that the technical issue was ever addressed, the response is not acceptable.

S&L comments to NU's second response NU's response is acceptable.

Printed Sm96139:39 PM Page 2 of 2

.* "N:rthert Utilities ICAVP DR N2. DR-MP3-0918 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechar}ical Design Discrepancy Type: Drawing Syrtem/ Process: DGX g

NRC Signihcance level: 4 Date faxed to NU:

Date Published: 1/25/98 Discrepancy: Discrepancies on EGA System Isometrics

Description:

Reviewing system isometrics for piping as-built data the following discrepancies were noted:

1. Line no. 3-EGA-500-64-3, as shown on the P&lD EM-1168-25 and as described in the Line List, is on the isometric CP-360258, Sh.1 of 4, Issue 6 erroneously shown as line no. 3-EGA 500 3. It is noted that the line number 3-EGA-500-61-3 is also used for a line in the starting air train 2B, shown on the P&lD EM-116D-5, and on the isometric drawing CP-360257, Sh.1 of 3, Issue 4.

2. Piping represented on the P&lD EM-116B-25 by the line I numbers 3-EGA-500-90-3 and 3-EGA-500-913 is not so identified on the isometric draw'm CP-360258, Sh.1 of 4, Issue

6. The Line List shows no entrs .sr a reference isometric drawing for these lines.

3. Piping represented on the P&lD EM-116B-25 by the line numbers 3-EGA-500-88-3 and 3-EGA-500-89-3 is not so identified on the isometric drawing CP-360259, Sh.1 of 4, Issue

5. The Line List shows no entry for a reference isometric drawing for these lines.

4. Piping represented on the P&lD EM-116D-5 by the line numbers 3-EGA-500-88-3 and 3-EGA 500-87-3 is not so identified on the isometric drawing CP-360-260, Sh.1 of 4, Issue

5. (The drawing is identified by the drawing number CP-360-260 on sheets 1 and 2, and by the drawing nuraber CP 360260 on sheets 3 and 4.) The Line List shows no entry for a reterence isometric drawing for these lines.

Review Valid invalid Needed Date initiator: Obersnel.Bojan. 8 O O 2/27/97 VT Lead: Neri, Anthony A B O O '5/S8 VT Mgr: schopfer, Don K B O O 1/1S/S8 IRc Chmn: singh, Anand K 8 0 0 i/21/98 Date:

INVALID:

Date: 4/30/98 RESOLUTION: Disposition

NU has concluded that Discrepancy Report, DR-MP3-0918, has identified a condition not previously discovered by NU which requires correction. This discopancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per Printed 5/1/961:40.05 PM Page i of 3

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N:rthea:t Utilities ICAVP DR Ns. DR-MP3-0918 Millstone Unit 3 Discrepancy Report -

attachment 11 of U3 PI-20 criteria and found to have no operabllity or reportability concems and meets section 1.3.2.e of

)

U3 PI 20 deferral criteria. Condition Report M3 2096 will be closed out to Bin CR M3-98-0164. The issues identified in DR-MP3-0918 we addressed as follows: l

1. Isometric drawing CP 360258, sheet 1 and 4 will be revised to show the correct p pe number. q

2. Line number 3-EGA-500-90-3 and 3-EGA-500-91-3 will be identified on isometric CP360258. Line number 3-EGA-500-88-3 s and 3-EGA-500-89-3 will be identified on isometric CP360259.

Line number 3-EGA-500-86-3 and 3-EGA-500-87-3 will be identified on isometric CP360260. The line list for these line numbers will be revised to reference the isometric drawing. The dash in the drawing number CP 360-260, sheet 1 and 2 will be deleted to agree with the drawing number CP360260, sheet 3 and 4.

l Bin CR M3-98-0164 corrective actions will correct the isometric - I drawings post startup.

Conclusion:

l NU has concluded that Discrepancy Report, DR-MP3-0918, 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 attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. Condition Report M3-98-2096 will be closed out to Bin CR M3-98-0164.

The issues identified in DR-MP3-0842 are addressed as follows:

The isometric drawings will be revised to show and identify the correct pipe numbers. The line list for these line numbers will be revised tc reference the isometric drawings. The dash in the drawing number CP 360-260, sheet 1 and 2 will be deleted to agree with the drawing number CP360260, sheet 3 and 4.

Bin CR M3-98-0164 corrective actions will correct these 5

drawings post startup.

Previously identified by NU? O Yes (G) No Non Discrepent Condition?O Yes (G) No Resolution Pending?O Y.. @ No Re.oiution unre.oived?O Ye. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Nerl, Anthony A VT Mge: schopfer. Don K IRC Chmn: singh, Anand K O O oste: 4/30/98 sL cunments: NU disposition is acceptable. S&L agrees that the described corrective action (Condition Report for this DR, CR M3-98-2090 was not included with the response) is deferrable.

Printed 5/1/961 Ao:09 PM Page 2 of 3

- ICAVP DR No. DR-MP3-0918

, N:rthe:st Utiliti:s Millstone Unit 3 DiSCreparicy Report it is noted that the discrepancies reported in this DR were also addressed in DR-MP3-0650. That DR was dispositioned 02/19/98 via CR M3-98-0164, and the disposition accepted by S&L on 02/21/98.

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DR No. DR-MP3-0992 I N::rthe=t Utilitin ICAVP Millstone Unit 3 Discrepancy Report I

Keview Group: System DR RESOLUTION ACCEPTED l

Review Element: Modification Design p .

Discipline: Mechanical Design j Discrepancy Type: Installation Implementation g Systern/ Process: NEW 1 NRC Significance level: 4 Date faxed to NU:

Date Published: 2/12/98 Discrepancy: CCNs DM3-00-596-97, DM3-01-596-97, & DM3-02-596-97 used in DCR M3-97042

Description:

DCNs DM3-00-596-97, DM3-01-596-97, and DM3-02-596-97 change specification SP-ME-574 to add new gate valves, 3RSS*V895 & RSS*V897, for the new RSS pumps 1C and 1D test lines in modifcation DCR M3-97042.

Check valves 3RSS*V896,898,900,903,906,909 are also added to specification SP-ME-574 by these DCNs but are not used for moditation DCR M3-97042. Gate valves 3RSS*V900, 903,906, and check valvo 3RSS*V909 are added to the new i RSS pump vent lines in DCR M3-97045 via DCNs DM3-00-1680- )

97, DM3-00-1569-97 and DM3-01 1569-97. There is an overlap {

between valve tag number, type and application /use for valves j 3RSS*V896, 898, 900, E03, 906, 909. l i

Furthermore, DCNs DM3-00-596-97, DM3-01596-97, and DM3- )

02-596-97 reference DCR M3 97012 instead of DCR M3-97042. l This is corrected in DCN DM3-03-596-97 for gate valves 3RSS*895 and 3RSS*897. However, the disposition of valves 3RSS*V896,898,900,903,906,909, (not used in DCR M3-97042), is not addressed in DCN DM3-03-596-97. New valves 3RSS*V896,898,900,903,906,909 are not directly addressed or indirectly referenced in the safety evaluations or analyses for j DCR M3-97042. I Review Valid invalid Needed Date O 2/3/98 initiator: Feingo6d. D. J. O O VT Lead: Neri, Anthony A B D 0 2/5/98 VT Mgr: Schopfer, Don K B D 0 2/s/98 IRC Chmn: singh, Anand K B O O 2/7/98 Date: 1/24/98 INVALID: The condition desccribed herein is considered an administrative error and not a technical error. This condition will be tracked in the review checklist and if found to be a recurring condition, it will be discussed in the final report.

Date: 4/30/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0992, has identified a condition not previously discovered by NU which requires action. .~his discrepancy ,

meets the criteria specified in NRC letter d16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concerns and meets Pnnted f!1/901:40.43 PM Page 1 of 2

ICAVP DR No. DR-MP3-0992

, N5rthe':st Utilitie3 Millstone Unit 3 Discrepancy Report section 1.3.2.e of U3 PI-20 deferral 'iteria.

The correct valve identifications are depicted on the system s

P&lD and all other design documentation. The only portion that requires clarification is the duplicate identifications referred to in Specification SP-ME 574. This will be corrected by a " grits" paper change DCN to the Specification, and this will ensure the spare valves in the warehouse do not retain these duplicate ide"ffications. CR M3-98-2090 has been closed to Bin CR M3-98-b163. The corrective actions in Bin CR M3-98-0163 will correct this issue post startup.

There is no affect on License or Design Basis.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0992, has identified a condition not previously discovered by NU which requires action. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concerns and meets section 1.3.2.e of U3 PI-20 deferral criteria.

The system P&lD and design documentation shows the correct valve identifications. A change to SP-ME-574 will eliminate the duplication within the specification and ensure the spare valves do not retain these duplicate identificaitons. CR M3-98-2090 has been closed to Gin CR M3-98-0163 which will correct this error.

There is no effect on License or Design Basis.

Previously identifled by NU? O Yes (9) No Non D;acrepant Condition?Q Yes @ No Resolutxm Pending?O Ye.

No Resolution Unresolved?O Yes @ No Review Acceptable Not Acceptable Needed Date inmator: Feingold, D. J.

VT Lead: Nort, Anttmy A VT Mgr: schopfer, Don K IRC Chrnn: singh, Anand K Date:

SL Comments:

Pnnta 15/1"O 1 e47 Pu Page 2 of 2

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