ML20217Q182
| ML20217Q182 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/10/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9803120035 | |
| Download: ML20217Q182 (83) | |
Text
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' Sar gerNA Luncly"c Don K. Schopfer Senior Vice President 312-269-6078 March 10,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 p[-r Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document ControlDesk Washington, D.C. 20555
' I have enclosed the following four (4) discrepancy reports (DRs) identified during our review activities for the ICAVP, These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.
- DR No. DR-MP3-1072 DR No. DR-MP3-1076 1
DR No. DR-MP3-1078 DR No. DR-MP3-1080 I have also eccioned the following two (2) DR that has been determined invalid. No action is required from Northeast Utilities for this DR. The basis for its invalid determination is included on the document DR No. DR-MP3-1062 DR No. DR-MP3-1079 I have also enclosed the following twenty-one (21) DRs for which the NU resolutions have been I
reviewed and accepted by S&L.
DR No. DR-MP3-0137 DR No. DR-MP3-0699 DR No. DR-MP3-0159.
DR No. DR-MP3-0732
"@ d DR No. DR-MP3-0167 DR No. DR-MP3-0742 s
DR No. DR-MP3-0339 DR No. DR-MP3-0747 DR No. DR-MP3-0551 DR No. DR-MP3-0762 i-DR No. DR-MP3-05%
DR No. DR-MP3-0764
. DR No. DR-MP3-0651 DR No. DR-MP3-0805 DR No. DR-MP3-0698 DR No. DR-MP3-0814 9903120035 990310 PDR ADOCK 05000423
- Chicago, IL 60603-5780 USA + 312-269-2000 P
.i United States Nuclear Regulatory Commission March 10,1998 Document Control Desk Project No. 9583-100 Page 2 DR No. DR-MP3-0815 DR No. DR-MP3-0818 DRNo DR-MP3-0816 DR No. DR-MP3-0819 DR No. DR-MP3-0981 I have also enclosed the four (4) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.
DR No. DR-MP3-0139 DR No. DR MP3-0267 DR No. DR-MP3-0468 DR No. DR-MP3-0553 Please direct any questions to me at (312) 269-6078.
Yours very tmly,
%.K-}i D. K. Schopfer i
Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/1) NU m%evyiourr9ter0310-odoc
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4 Northeast Utstles ICAVP DR NS. DR41P34137 mastone unit 3 Discrepancy Report moviewGroup: AccWent AMigelien DR RESOLUTION ACCEPTED noview Element: Operssng Pnmedwo O vee Deserupeney Type: usensing peoumont g,
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I"'I 4 Date faxed to NU:
Dale Puldlehed: 11/13/97 placeepancy: FSAR Accident Analysis Assumptions inconsistent With Operating Procedures EOP 35E-0 and EOP 35ES-1.1 osseriplien: The accident analysis for a postulated loss of feedwater accident assumes the following operator action is necessary (Reference FSAR $15.2.8.2, item 3): Stop high head safety injection pumps if water level in the pressurizer is r3 covering, and the inted steam generators are at the safety valve set point, and the water level in the inted steam generators is in the narmw range span (NRS). NOTE: forthe purposes of the accident analysis, assumption of the steam generators operating at the safety valve setpoint is conservative as this maximizes the steam generator pressure and temperature and minimizes the heat removal from the primary system. In practice, the steam generators will be operated at the atmospheric relief (dump) valve setpoint or telow.
The ICAVP review of the EOPs determined that the high head safety injection pump is stopped if the water level in the pressurizer is recovering and a heat sink is confirmed. (NOTE:
At Steps 16b and 27 within EOP 35E-0, the operator determines
)
AFW flow is >530 gpm OR a NRS >6% in ONE steam generator as the means of establishing the existence of the heat sink.)
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The FSAR and the EOPs should be consistent relative to whether water level is required to be in NRS in ONE or in ALL intact steam generators. Further, equivalency of a) AFW flow
>530 ppm and b) NRS >6% for the required number of intact steam generators requires justification.
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3/4/g8 nEsOLUTION Desposition:
NU has concluded that the issue reported in DHicrepancy Report, DR-MP3-0137, does not represent a discrepent condition.
ICAVP Discrepency Report DR-MP3-0137 has stated a discrepincy exists between FSAR Chapter 15 and the Emergency Operating Procedures (EOPs) relative to the number Pnreed3/1oes10:29:11 AM Page 1 or 4
1 Northeast Utsties ICAVP DR No DR MP3 0137 Mastorm unit 3 Discrepancy Report of steam generators above 6% level that are required to satisfy sufficient host sink. The EOPs are specific in that only one q
steam generator is required. FSAR 15.2.8 states that operator action to reduce ECCS flow would be taken when the water level i
in the steam generators is in the narmw range span. The DR implies that this indicates more than one steam generator is required to provide a heat sink. The existing FSAR wording arises from the fact that following a design basis feedwater line break event, as described in FSAR Section 15.2.8, all intact 6
steam generators would show water level in the narrow range after the auxiliary feedwater is initiated. However, the EOPs, and specifically EOP 35 E-1, Loss of Reactor or Secondary Coolant, provide guidance to the operator for beyond design basis accidents in addition to those analyzed in the FSAR. The minimum requirement for secondary heat sink, which is water level in the narrow range in one steam generator, is used to determine if feed and bleed cooling is needed This would be needed for a total loss of main and AFW for which level could not be recovered in any steam generator.
j The discussion of operator actions in FSAR 15.2.8 is therefore potentially misleading. As an enhancement, in order to improve the clarity of this section, a restatement has been documented in Condition Report (CR) M3-97-4412 initiated on 12/5/97. The CRs corrective action plan is being tracked to completion by action request (AR) 97029719. The corrective action will revise FSAR Ch.15.2 per marked up page 15.2-19 from FSAR Change l
Request 97-MP3-583. The FSAR section will be revised to state f
that a secondary heat sink exists in lieu of identifying tise specific setpoint criteria. This restatement will still be consistent with the EOPs. The resulting FSAR change request will be Plant Operations Review Committee approved befcre restart. No field modifications are required.
The DR requested additional information regarding the equivalency of Auxiliary Foodwater flow >530 gpm or a narrow range level signal >6% in an intact steam generator. These prerequisites for manual operator actions appear in procedures EOP 35E-0 and EOP 35ES-1.1. Procedures EOP 35E-0, Rev.
18 and EOP-35ES-1.1, Rev.14 (latest revisions) state the setpoint for a narrow range level signal as >8% in an intact steam generator.
In the EOPs, the existence of a adequate secondary heat sink is verified using factors including total auxiliary feedwater flow to the steam generators (SGs) or narTow range (NR) level in at least one SG The EOPs are based on the Westinghouse standard and are supported by the Chapter 15 accident analysis for the minimum auxiliary feedwater flow requirement Per Millstone 3 drawing 1106J72, the lower Narrow Range steam generator level tap is above the tubes. The level corresponding to 8% NR includes instrumentation uncertainties. Therefore, this level irdcates that the tubes are covered and the steam generatoris inted.
Prtreed 3/1o5810'29:14 AM Page 2 or 4
i Northerst Utilities ICAVP DR No. DR-MP3 0137 ministone unit 3 Discrepancy Report An moequate secondary heat sink indication can also be verified by using the total feedwater flow indication. The value of 530 gpm total feed flow delivery, used in EOP 35E-0, Reactor Trip or Safety injedion, corresponds to the maximum feed flow which would assure adequate secondary heat removal capability, but would preclude an overcooling condition This value includes instrumentation uncertainties and would be used for situations in which steam generator level has been depleted below the NR tap, as is predicted in the Chapter 15 analysis to occur in the early stages of a transient. EOP 35E-1.1, Si Termination, directs the operator to control feed flow to maintain steam generator level in the normw range, if it has been verified that steam generator level is above lower NR tap, or maintain the total feed flow greater than 530 gpm until steam generator NR level can be verified. Therefore, while the two plant conditions are independent of each other, the steam generator NR level indication is the primary vr:riable for verifying if secondary heat q
sink has been established following an accident.
Using steam generator level or feedwater flow for verification of the secondary side status is a common industry practice. In a past MP3 NRC Lispection Report No. 50-423/90-12, dated 8/14/90, it is deemed acceptable that the redundant NR steam generator level indication provide backup to auxiliary feed flow indication when determining the existence of the secondary side heat sink.
e it should be emphasized that steam generator level or total auxiliary feedwater flow, when used by it emselves, cannot give assurance to the opermor that adequate decay heat removal capability is provided post accident, unless it is used in conjunction with RCS subcooling margin, RCS pressure and pressurizer level indications. This is reflected in the EOPs.
J NU does not consider ICAVP Discrepancy Report DR-MP3-0137 a discrepancy. Therefore the signifcance level 4 does not apply.
==
Conclusion:==
1 NU has concluded that Descrepancy Report, DR-MP3-0137, does not represent a discrepent condition.
ICAVP Descrepancy Report DR-MP3-0137 has stated a discrepancy exists between FSAR Chapter 15 and the EOPs relative to the number of Steam generators above 6% level that are required to satisfy sufreient heat sink. The EOPs are specifc that only one steam generator is required. FSAR 15.2.8 states that operator action to reduce ECCS flow would be taken when the water level in the steam generators is in the narrow range spen. This could imply that more than one steam generator is required to provide heat sink. However, the EOPs, and speceficeNy EOP 35 E-1 Loss of Reactor or Secondary Cooiset, provioe guidance to the operator for beyond design i
basis accidents in addition to those analymt in the FSAR. EOP 35 E-1, Rev.18, states the setpoint for a narrow range level sinnel as >6% in an intact steam oenerator.
Printed 3/1o9610:2e:15 AM Page 3 of 4
)
1 NonheOst Utinties ICAVP DR No. DR.4tP3-0137 Minstorm unit 3 Discrepancy Repoft NU does not consider the current FSAR text discrepant.
However, to improve clarity, a restatement has been documented by Condition Report (CR) M3-97-4412, initiated on l
12/5/97. The CRs corrective action plan is being tracked to completion by action request (AR) 9W29719. The corrective action will revise FSAR Ch.15.2 per masked up pa0e 15.2-19 from FSAR Change Request 97-MP3-583. The FSAR section wlit be revised to state that a secondary heat sink exists in lieu of identifying setpoint criteria. This restatement will be consistent with the EOPs. The resulting FSAR change request will be Plant Operations Review Committee (PORC) approved before restart.
No field modifications are required. NU does not consider ICAVP Discrepancy Report DR-MP3-0137 a discrepancy.
Therefore the significance level 4 does not apply.
Using steam generator level or feedwater flow for verification of the secondary side status is a common industry practice. :In a past MP3 NRC Inspection Report No. 50423/90-12 dated 8/14/90, it is deemed acceptable that the redundant NR steam generator level indication provide backup to auxiliary feed flow I
indication when determining the existence of the secondary side heat sink.
Attachments.
CR M3-97 4412 (Form RP4-1 pages 16 of 7) initiated 12/5/97 NRC Inspection Report No. 50-423/90-12 dated 8/14/90 FSAR Chan0e Request 97-MP3-583 (pages 1,2 and mark-up of FSAR page 15.2-19) initiated 10/14/97
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sL caenmente: The response provided by NU adequately addresses the issues I
cited in the DR.
However, ICAVP believes that this was a discreper.t condition which is in the process of conection by CR M3-97-4412.
2 Printed 3/10981029:16 AM PeGe 4 or 4
1 Northeast Utilities ICAVP DR No, DR-MP3 4159 maistone Unit 3 Discrepancy Report ReviewGroup: AcciderdMagelkm DR RESOLUTION ACCEPTED Revlow Element: Syelem Design Diedpline:
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i Date Puldiohed. 9/29/97 D6screpency: Discrepancies between FSAR commitments and Fuel Drop Monitor setpoint.
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FSAR Section 15.7.4, Fuel Handling Accident, states that there are radiation monitors inside containment that will respond to a fuel handling accident inside containment (FHAIC) and isolate the containment purge ventilation system, preventing any release of radioactivity to the environment. The setpoint basis and calculation methodology is not consistent with this commitment as discussed below.
This discrepancy was identified by the ICAVP during the review of the following documents related to the fuel drop monitors, 3RMS*41&42:
A) Unit 3 Millstone FSAR-Section 15.7.4 B) Millstone Unit 3 Radiation Monitor Manual dated 4/11/g7 C) Unit 3 Millstone Calculation Alarm Setpoint Calculation-RE41,42 D) EPIP 4400, Rev. 4 Event Assessment, Classification and Reportability.
The Fuel Handling Accident (FHA) is a design basis accident that is required to be evaluated in the FSAR for ;1tential off-site consequences. It involves the non-mechanistic asumption that a fuel assembly is dropped during movement, rupturing all of the fuel pins in the assembly and causlag the release of radioactive I
gases into the fuel building or containment.
A review of the documents above identified the following issues f
relative to the setpoint basis for the fuel drop monitors:
- 1) The FSAR states that "Upon sensing high radioactivity, the radiation monitors send a signal to the containment isolation valves for valve closure... In the event of the fuel assembly being dropped in the refueling cavity, the containment purge isolation valves close before any radioactivity can reach the isolation valves." However, the calculation contained in Reference C calculates a setpoint t ml on effluent releases.
Also, the stated purpoce of the roc
- monitors in Reference B, page 90, is 'to minimize off-site micases following a fuel handling accedent." It further states that 'The alarm setpoint of 0.92 R/hr is based on isolating the purge at a release rate which would result in 10CFR20 concentration limits of Xe-133 at the cPgheumdant
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I Northeast Utilities ICAVP DR No. DR-MP3-0159 Minstone Unit 3 Discrepacy Report documents are in conflict.
- 2) The setpoint calculation, Refemnce C, is based on a
- Charlie-two release limit for vent 0.03 uCl/cc". A Charlie-two event classification is defined in the Emergency Plan implementing Procedures (EPIP) as a Site Area Emergency, which is more severe than the Fuel Handling Accident (Charlie-one or Alert),
which is more severe than 10CFR20 release Ilmits (Delta-two or Unusual Event).
i i
The ICAVP review of the setpoint calculation (Reference C) also identifies the following issues with the calculation methodology:
a)As stated in item 2), the Monitor calculated setpoint is based on a concentration in the effluent. This caNiation estimates a uniform concentration in containment which produces the effluent concentration and uses this to oetermine the monitor response. The postulated FHAIC, however, is expected to produce a bubble of gas above the refueling pool which travels to the purge duct. The response of the monitor will depend on the location of the accident and the pathway of the bubble to the purge. Therefore, the uniform concentration assumed in the calculation is not consistent with the accident.
b) All of the actin released is assumed to be Xe-133, which has a low decay energy. Although most of the nobio gas activity
)
in the assembly will probably be Xe-133, the monitor response may be dominated by more energetic nuclides.
c) The uniform cloud inside containment is corrected for finite
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size using the finite cloud correction factor formula from a paper on control room habitability by Murphy-Campe. This formula was developed for the energetic, post-LOCA nuclide mix and use s
of this formula may not be consistent with Xe-133 alone.
d) The monitor response to the cloud of activity in containment is assumed to be equivalent to a dose conversion factor from Regulatory Guide 1.10g for whole body dose at a depth of 5 cm.
It is expected that the monitor response would be closer to the dose rate in air, e) The Charlie-two effluent concentration in the current EPIP is 0.1 uCi/cc rather than the value of 0.03 used in the setpoint calculation.
CONCLUSION:
j The issues identified in this discrepancy report (DR) pertain to the docurrrentation of the Monitor setpoint re.ber than the design of the system. Therefore, this discrepancy report is assigned a significcace Level 3. If resolution of this DR requires that the i
monitor setpoint be lowered or that the FHAIC is not bounded by i
the FHA in the fuel btdiding, the significance level wt!! be reassessed.
Review Vaud hvaud Needed DMe I
Pdnted 3/1o961o.29:50 AM Pap 2 of 6
Northeist Utilitie3 ICAVP DR No. DR-MP3 4159 Ministone unit 3 Discrepancy Report initiator: schwartz, Barry B
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Date:
3/7/96 RESOLUTION Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0159, does not represent a discrepant condition. The alarm setpoint calculation for 3RMS41 and 42, was not based on the fuel handling accident, it was based on effluent criteria which is more limiting than the dose rates resulting during a DBA fuel handling accident.
Note that the Technical Specification setpoint requirement is 1R/hr. This is the required setpoint established in the license to ensure the DBA fuel handling assumptions are met. This value was not based on any specific calculation. Rather it was chosen as the first round number (i.e. first decade of 10) above the expected dose rates on the refueling floor of the containment.
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The dose rate at area radiation monitors in relative proximity and line of sight to the fuel cavity or pool is expected to be many R/hr for a DBA fuel handling accident. Hence, typical Technical Specification setpoints of 0.1 or 1 R/hr would ensure alarm and auto actuation following the DBA fuel handling accident.
In 1986, a bases for each radiation monitor setpoint was developed. Since it is beneficial for RMS 41 and 42 to isolate the containment purge for any event that resulted in high effluent releases, and not just the fuel handling accident, a setpoint based on effluent criteria was calculated. The calculated value was 0.92 R/hr, per the assumptions in the previously transmitted calculation (M3-IRF-00252, attachment 2(a)). The only reason i
this calculation mentioned the fuel handling accident was that the basis for selecting Xe133 as the controlling nuclide, as the most likely cause for high airbome activity was some kind of fuel failure. The calculation was not intended to calculate the expected dose rate from a DBA fuel handlin0 event as the basis for the setpoint. Such dose rates were expected to be higher j
than the calculated value of 0.92 R/hr. To confirm this, after this DR was inceived, the expected dose rate at the RMS 41/42 monitor locations for a DBA fuel handling accident was calculated. The Microshield shielding code was used and assumed the source was contained in a sphere of a diameter of e feet, immediately on top of the refuel pool water. The s
calculated dose rate at the detector location,44 feet away, is 16 R/hr. Based on this assessment, NU has confirmed that 0.92 and 1 R/hr are c:onservative setpoints in regard to isolating the DBA fuel handlin0 accident.
The following are in response to the individual issues in the above Back0round Section of this DR:
Prtnted 3/104610:30 00 AM Page 3 or 6
Northeast Utilities ICAVP DR No. DR-MP3-0159 ministorm Unit 3 Discrepancy Report issue 1)- Recognizing that the specified setpoints will ensure isolation for a fuel handling accident based on the above discussion, the statements in the FSAR and Radiation Monitor Manual are valid.
Issue 2)- The EAL's are based on realistically expected consequences, not DBA accidents. A fuel handling accident is not expeded to result in a significant release (only a few rods might be expeded to fall). Hence, its initial classification is only at the Alert level. If the fuel handling accident actua'ly resulted in unisolated releases at the concentrations calculated for the Site Area classification, it would be upgraded to a Site Area based on release rates. The 10CFR20 release limits are at a much lower value and would not be detectable with an R/hr area radiation monitor. NU relies on the sensitive stack monitor to wem of releases at that level and prompt operator action.
Issue 2a) - NU concurs. Had the setpoint been based on a FHA, NU would have used a bubble. As noted above, the calculated 16 R/hr for a fuel handling accident was based on a bubble (10 foot diameter sphere) above the reactor cavity and is well above the setpoint based on a homogeneous mixture.
Issue 2b)- The recently run Microshield calculation, assumes a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decayed mix. It shows that 94% of the mix is Xe133 and 90% of the dose contribution for the geometry noted above is from the Xe133 80 key gammas. Hence the assumption of all Xe133 is reasonable.
Issue 2c)- NU concurs. For a low energy gamma nuclide like Xe133, the finite cloud correction factor should be closer to 1 (higher) than for a more energetic mix. Therefore, use of the correction fador as was done would result in a lower setpoint and hence le M the conservative direction. Additionally, for the Microshield run for the FHA, that calculation does not use such a correction factor in calculating the 16 R/hr.
Issue 2d) NU concurs. This was done for conservatism. The use of the lower whole body dose factor ins'ead of the air dose factor results in a lower setpoint requirement.
Issue 2e) NU concurs. However when the Ch.orile 2 criteria was increased, the RE41 and 42 setpoints could not increase by the same amount since it would exceed the 1 R/hr Technical Specification requirement. Current plans are to change the setpoint basis from the 0.92 R/hr calculated basis, to approximately 2 to 3 times the normal reading. This would resu!!
in a setpoint of approximately 0.3 R/hr. This would provide increased sensitivity and would be even further below the Technical Specification value and the expected dose rate from a DBA fuel handling accdent. This change however has been delayed to an after startup improvement.
PrWed 37109810:30:02 AM PM 4 or 6'
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Northe:st Utilities ICAVP DR No. DR-MP3-0159 ministone unit 3 Discrepancy Report in summary, the setpoints of the radiation monitors are not based on the fuel handling accident but on conditions which are more limiting than for the fuel handling accident alone. While some assumptions in the fuel handling accident releases could be changed, the results would not indk: ate any change is needed either for the Technical Specifications or for the radiation monitor setpoints to be lowered.
Significance Level criteria do not apply here as this is not a discrepant condition.
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3/7/98 SL Comments:
S & L Comments ICAVP has reviewed the NU response to this DR and has the following comments:
- 1. NU response to issue 1. Although NU has concluded in the response to this OR that the setpoint of this radiation monitor is adequate, they have not demonstrated the responce time of the radiation monitor at this setpoint which S & L questioned in DR-MP3-0263. Therefom, closure of this issue is associated with the NU response to DR-MP3-0263.
- 2. We agree with your response to issue 2 that EAL classification depends on the stack monitor reading and that any EAL associated with an unisolated FHAIC release to the
)
environment would be classified with the stack monitor. We agree that the use of a sphere 10 feet in diameter for the FHAIC dose rate at the radiation monitors is a reasonable approach used h the calculation. We also agree with your responses 2a,2c, and 2d. The current setpoint of 0.92 R/hr and the future setpoint 3
of approximately 0.3R/hr are conservative in comparison with NU's recently calculated vakse of 16 R/br.
- 3. We agree with your response to issue 2b.
- 4. We agree with your response to issue 2e.
Note that a discrepant condition currently exists because the present setpoint is based on the former Charlie 2 concentration and can not be revised using the current Charlie 2 classification due to the Technical Specifk:ation limit on the setpoint of 1 R/hr.
Prwed 3/10&.. J0:03 AM Page 5 or 6 J
Northeast Utilities ICAVP DR No. DR-MP3-0169 mmstone unit 3 Discrepancy Report NU has stated this is scheduled to be corrected after startup. The text in the calculation for 0.92 R/hr should be amended to remove the Charlie 2 verbiage, since the Charlie 2 effluent concentration in the calculation (.03 uCi /cc) is different than the Charlie 2 concentration in the current EPIPs (0.1 uCi/cc).
Conclusion We agree that that the new setpoint of approximately 0.3 R/hr can be instituted after startup, since, this is a containment purge isolation setpoint for a FHAIC, l
4 I
PrNed 3/10961030:05 AM PA0e flor 3
Ibrtheast utsties ICAVP DR No. DR MP34187 Elastmw Unit 3 Discrepancy Report
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nais e, wop.m ame.enn#effrosne OnnesownoNaccamo Review Eissnent. OpwohnJ Proomkre Diecipane: Opussons O vee Discrepac1/ Type: Test irgiornentation
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f84c SigntAcencelevel:4 Dale faxed to Nu:
Dale Pubthshed: 1/22/We oleerspeacy: IST Valve Timing Testing Mrs To Not Be in Accoittance With Standard lindustry Practice.
Descetpeten: The following are excerpts taking from various refereocra which provide guidance for Inservice Testing of Power-Operated Valves at Nuclear Power Plants. This information should have been used in the development of the procedures for Inservice Valve Testing.
- 1) Sedion 4.2.2 of NUREG-1482,"Gu'elelines for Inservice Testing at Nuclear Power Plants", states that 'the traditions!
method of stroke timing power-operated valves was to use stopwatches to measure the stroke time from iniLation of the signal at the handswitch to the change in position-indicating lights (switch to light). The traditional method includes signal processing time from the switch to the valve actuator.
- 2) NRC Generic Letter 89-04, Supplemord 1: " Guidance on Developing Acceptable inservice Testing Programs", Attachment 1, " Potential Generic Deficiencies Related to IST Programs.end Procedures", states: "The Code intent with respect to measuting the full-stroke times of power operated valves is to verify operability and to detod valve degradation.*
- 3) ASME Section XI, Article IWV-3000 Test Requirements, IWV-3413 Power Operated Valve states: " Full-stroke time is that time interval from initiation of the actuating signal to the end of the aduating cycle."
- 4) Part 10, inservice Testing of Valves in Light-Water Reador Power Plants, OMa-1988, also defines ' full-stroke time', the same as ASME Mdion XI.
- 5) FSAR Sedion 6.2.2.4.2 states, " Proper functioning of interlocks, time delays, stJrms, instrumJnts, and valves during both the spray mode and switchover to recirculation mode will be vertf:o:t during a simulated system actuation test. Valve speed and positioning will be verified in the control room and by local visual observation."
Operations Procedure SP 3609.9, Quench Spray Valve Operatnlity, and OPS Form 3000.9-1, QSS Valve Biennial Position Indication Verification, were reviewed to determine how the requirements stipulated in the references noted in items 1) thru 5) above were being met.
SP 3609.9 pmvides instructions to verify quench spray sydam valve operability to most the requirements of T/S 4.0.5 the ~ m mand==e: far in==..sh tar =efinn and Teeth Page 1 of 4 Pnnled3/100s1030:51 AM
Nodheast Utilities ICAVP DR No. DR-MP3-0167 Millstone unit 3 Discrepancy Report of.ASME Code Class 1,2, and 3, components), T/S 4.6.3.3 (Surveillance Requirements, Containment Isolation Valves), and ASME Boller and Pressure Vessel Code,Section XI (and its app 3 cable Addenda).
The methodology uses the plant computer or Control Room Operator with a Stop watch to measure the length of tims between the open and close limit switch signals. This time is then used as the opening or closing time for the valve. Limit switch readings do not meet the intent of items 1 to 5 above, for the following reasons:
- 1. Limit switches on valves are usually set 5 to 15% before the end of valve travel in both the open and close direction.
- 2. The general nature of a limit switch is that it is an inaccurate device and not necessarily repeatable.
OPS Form 3609.9-1 does require an operator to observe the stroking of the valve locally, but his functicn is to only verify that the valve physically strokes. The acceptance criteria is that:
" Local position indication matches Control Room indication for the open and closed position". There is no measurement of the valve's physical stroke timefor this activity, Valve stroke time is determined in the same manner as for SP 360g.9.
Further review was conducted to determine if a " compensation factor" was developed and applied for the actual stroke times from receipt of signal to completed valve movement; none could be found. The fact that actual storke time from receipt of signal j
to end of valve movement is not being accurately measured as j
required by the applicable code or regulatory requirements, i
outlined above is a discrepancy.
{
11 appears that the extent of the concem is broader than for just the QSS valves, as evidenced by:
- 1) The purpose of Operations Procedure SP 36128.6, Containment isolation Valve Operability After Maintenance, is
'To provide a cross reference of containment isolation valves and surveillance procedures'. This procedure does not provide for the measurement of the valves' physical stroke times.
- 2) Other valve stroke time procedures were also looked at and they used the Control Room Board valve indicator lights, which also use the valve limit switches for their input, for the valve timing.
Therefore this Discrepancy has the potential for effecting all MOVs and AOVs in the plant that must meet the IST requirements as described above.
Review vand invased Needed Date Inightor: Ungeren, R.
O O
O imse VT Lead: Base Ken 8
O O
imos VT Mgr: schopfer, Don K Q
Q Q
i/12/96 Printed 3/10/9610M5s AM Page 2 of 4
Northeast Utilities ICAVP DR No. DR-MP3-0187 Millstone unit 3 Discrepancy Report stC Chnuu singh, Anand K O
O O
5'1888 ones:
enraup:
Dele: 2/27/98 NEsot.trnoN. Disposition:
NU has concluded that Discrepancy Report DR-MP3-0167 does not represord a descrepent condMion, implementation of reculatory requirements with respect to valve stroke time testing is contained in the IST Umgram Manual and associated Program
. Instructions. These instmotions are consistent with the requirement documents referenced in this Discrepancy Report.
The IST Program is related to other Engineering Programs and Site Organizations as described in Sections 3.2 and 3.3 of the Manual, interface with Appendix J Testing, the Motor Operated Valve (MOV) program, and the Maintenance Rule, ensures that any degradation identified dudng valve stroke testing, leak rate testing or MOV testing will be addressed as required by NRC Generic Letter 89-04, Supplement 1 (Ref. 2 in Discrepancy Report).ASME/ ANSI Part 10 (oms.1988 Addenda to the 1987 Ed;ilon)(Ref.'4 in Discrepency Report)is addressed in Section 4.1.3 of the Program Manual. Part (d) of this sect 6on provides rules for establishing Limiting Stroke Time. Beyond this limiting time, valve stroke testing must also meet a narrow acceptance criteria.- As shown la procedure IST PI-12, " Valve Testing and Data Evaluation,* valve stroke times are required to be within tolerance times based on reference values as well as meeting the limiting stroke time. Measurement of valve stroke times is consistent with the requirements of NUREG-1482 and ASME Section XI, IWV-3413 (Ref. 3 in Discrepancy Report). This is shown by the definition of Full Stroke Test pmvided in the Pt grarn Manual, which states:" Stroke Time shall be measured from intiatica of actuation signal to receipt of end-of-stroke indication. This is the same as " switch to light" stated in NUREG-1482 (Ref.1 in Discrepancy Report).
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0167 does not represent a discrepent condition. Regulatory requirements for valve stroke time testing is described in the IST Program Manual and associated Program Instructions, and is implemented in test procedures. Local visual observation, required by FSAR 6.2.2.4.2, is performed at least once every two years, as stated in subject procedure SP 3609.9 and other valve stroke test procedures. Required actions during local otceivation are defined by CondNioned Based Maintenance as verification that cordrol room indication is consistent with actual valve poonion. Significance level criteria do not apply as this is not a discrepent condition.
Previously heentsmed by Nu? U Yes @ No NonDiscrepentCone6on?O Yes @ No nammoneenenetO v.
@ N.
- unr= *.d7 0 Y a @ No
- n. view insister: spear, R.
Printed 3/1oes 10.30:57 AM -
Page 3 or 4
9 Northeast Utilities ICAVP DR No. DR MP34167 Millstone Unit 3 Discrepancy Report 8
O O
2/27/9e VT t.eed: sees, Ken O
O O
m VT Mgr: SctWor, Don K O
O m
ac chmn: S@, Anand K De-2/27/96 st comments: S&L concurs with NU's response to DR-MP3-0187. However, it should be noted the NU IST Program Manual and associated Program Instructions, identified in the DR response, have effective dates after the Wave 1 cut-off date of May 27,1997.
The two documents that were identified in the response as the basis for the IST Vaive Testing Program and estabilsh that the DR does not represent a discrepant condition are IST Program Manual Rev, O and IST PI-12 Rev. O, Valve Testing and Data Evaluation.
i PeWed 2109610.3050 AM i
\\
i
l Northe:st Utilities ICAVP DR No. DR-MP3-0339 idilistone Unit 3 Discrepancy Report Review ornup: syneem Da REsoumoN ACCEPTED Revhw Elemenc Syelem Design Diecipune:I a c Desig" O vee C.
_i Type: NW g
8,___._.
- OsS
. W algniacance imi: 4 Date faxed to Nu:
Date Putdished 11/24/97 r.
i: Calculation SP 303S-1 Discrepancy Description.
Background:
Per text of Calculation SP-3QSS-1, Rev 1 on page 3, the RWST temperature is maintained between 46 and 48 degF and the High lemperature Alarm is set to 49 degF increasing. Per Section 1,1 of Operating Proceduse OP3353.MB2A, Rev 0, the alarm shall be set to greater than 49 degF. The Master Setpoint index identifies the alarm setpoint as 49 degF increasing. The PMMS Data Sheet, which references the subject calculation, identifies the alarm setpoint as 49 degF.
Discrepancy:
Per calculation results on page 4, the liigh Temperature Alarm setpoint is specified to be 48 degF increasing which is inconsistent with the above-rate.tenced design basis documents.
The Refueling Water Recirculation Fumps start and stop automatically at 40 and 46 degF, r6spectively, if the high temperature alarm is set to 48 degF, it may alarm indicating a temperature control loop problem. Setting the high temperature alarm to 49 degF will prevent an alarm from falsely indicating equipment problems and will allow the operator ample time to inv6.ttigate the problem before the RWST temperature reaches the Tech Spec high temperature limit of 50 degF.
]
veed invene Needed note inittstor: Pinelse. H.
O O
O
$ $'ic'87 VT Leed: Nort. Anthony A B
O O
55/11/87 VT Ingr: schopfer, Don K Q
Q 11/167 Nec Chmn singh. Anand K G
O O
$1'1SS7 Date:
INVAUD:
Date:
3/6/98 REscumON. Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0339, has identified a condition not previously discovered by NU which requires corredion. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0138 has been written to develop and track resolution of this item per RP-4.
Printed 3/10981031:32 AM Page 1 or 2
i i
Northeast Utilities ICAVP DR No. DR-MP3 0339 Millstone Unit 3 Discrepancy Report
==
Conclusion:==
1 NU has concluded that D!screpancy Report, DR-MP3-0339, 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 opesability or reportability 4
concerns atxt meets the Unit 3 deferral criteria. CR M3-98-0138 1
has been written to develop and track resolution of this item per RP-4.
Previously identined ty NUr O Y=
(G) No NonDiscrepentCondition?U Yes (G) No l
n iwi nPonens70 va @ No p + unroe m ed7 0 v a @ No n
A' R.
Not t--, '
Needed Date VT Leed: Nerl, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Dele:
3/6/98 sL Comments:
1 Printed 3/10/ile 10:31:36 AM Pagw 2 or 2
Northeast Utnities ICAVP DR No. DR-MP3 0661 unistone Unit 3 Discrepancy Report ReviewGroup. ConAgurellon DR RESOLUTION ACCEPTED Noview Element. System Design Discipane: Elecirical Design Om r
. -; Type: Drawing gg SystemProcess: RsS NRc signiacance level: 4 Date faxed to NU:
Date Published.11AWD7 Descrapency: Crawings not in agreement Description.1. Conduit Support Log (CSL) 12179-FSK-SB-130, Rev. 3, indicates that conduits 3CL373NA and ND are 5 inch diameter rl0id aluminum. The Cable and Raceway Program (TSO2)
Indicates that these conduits are 4 inch diame'.er rigid aluminum.
- 2. The Cable and Raceway Program (TSO2) indicates conduits 3CX402YA1 and 3CX402YC1 am aluminum. These conduRs were verified in the field to be aluminum. The listed Conduit Suppost Logs indicate the conduits are steel. This material type differencs could impact the allowable span betwen support and the actual weights on the sepports identified on the CSLs. The affected CSLs are 2179-FSK-SB-175, -182, -171, -17?. -173, -
174, -176, -177, -179, -180, and -181.
Review vend inveNd Neested Date insistor: Sener, T. L 8
O O
ot2 ver VT Land: Nort, Anthony A B
O O
1a/2as7 VT tegr: Schopfer, Don K O
O O
10/3*87 atC Chmn: Singh, Anand K B
O O
11/4/S7 Date:
INVAUD:
Date:
3/6/98 REa0 Limon NU has concluded that Nem # 1 and # 2 of Discrepancy Report DR-MP3-00551 has identified conditions not previously discovered by NU which requiro correction. item 1 describes a discrepancy between the Conduit Support Log (CSL) 25212-34011 Sh SB0130 and the TSO2 Database for the size of conduits 3CL373NA and 3CL373ND. The CSL depicts these conduits with a diameter of 5 inches, while the TSO2 Database shows them to be a diameter of 4 inches. A field walkdown was completed which revealed both conduits to be 4 inch diameter.
DON DM3-00-1225-96 was approved in April of 1997, where pages 41,42,43 of 72 (CSL's 25212-34011 Shs. SB0130A, Pev.
NEW DRAWING; 1300, Rev. NEW DRAWING; & 130C, Rev.
NEW DRAWING which supersede 25212-34011 Sh. SB0130, Rev. 3.) document these conduits as 4 inch diameter. Conduit Plan 12179-EE-42B, Rev,9 and Conduit Support One une Draw!ngs 25212-34479 Shs 0026,0027,0028 show the subject conduits as 5 inch diameter. These drawings will be revised. item 2 indicates conduits 3CX402YA1 and 3CX402YC1 are aluminum which was confirmed by a walkdown. The followin0 Conduit Support Logs (CSL's) indicate these two conduits are Steel which Pnntes 3/10f9610.3216 AM PeGe 1 or 2
Northecst Utilitie0 ICAVP
- DR No. DR-MP3-0661 milistone unit 3 Discrepancy Report may impad the allowable span and actual weights. The affected supports are: 25212-34011 Shs SB0171 to SB0182 (new drawing numbers). For the Maximum span of Aluminum or Steel conduit, refer to BE-52AN, Note 3, which states
- Maximum span between supports is 8'-0", with the excepuon of concrete attachments as shovm on detail BE-52CD through BE-52DZ'. The span between Supports SB0171 to SB0182 has been confirmed to be 8'-0" or less and all the referenced supports utilize detail BE-52LK, which is covered by Note 3 for an 8'-0* maximurn span. The actual loads shown on the applicable CSL's are for 4* Steel Conduit.
The as-built configuration and the Cable and Raceway Program are in agreement; the installations are acceptable and do not represerd discrepant conditions. The CSL Support Drawings 25212-34011 Shs SB0171 to SB0182 will be revised to reflect the as built condition as aluminum and to revise the actual loads. Condition Report (CR) M3-96-0579 was written to provide the necessary corrective actions to revise the documentation.
The approved Corrective Action Plan (CAP) (attached) will have:(1) Electrical Design department to initiate a DCN to correct drawing EE-42B to show the correct size for conduits 3CL373NA and 3CL373ND, as well as 3CL373NB, to be 4' diameter.(2) Civil / Mech. Design Department to initiate an Administrative DCN to revise Conduit Support One Line DrawinOs 25212 34479 Sh 26,27 & 28 to reflect the correct size for Conduits 3CL373NA and 3CL373ND, as well as 3CL373NB, to be 4' diameter. Also, revise CSL's SB-171 through SB-182 to reflect the as-installed conduits 3CX402YA1 and 3CX402YC1 as Aluminum, as well as revise drawings SB-171 through SB-182 accordingly to indicate the correct Aluminum conduit weights for the Actual Loads.The stem is scheduled for completion post startup. As this is an administrative chan0e to revise all conduit and support drawings to reflect as-built conditions. NU considers this item to be Significance Level 4.
M.. "iIdoneaed try NU7 O Yes (S) No Non Discrepent Condition 70 Yes (S) No Romah% Pending70 Yes @ No w~ unreceived70 Yes @ No Review Acceptable Not areafa.haa Needed Date initiator: Kleie, N 8
O O
88
VT Lead: Nori, Anthonjr A e
O O
3mie VT Mgr: schopfer, Don K e
O O
3"'8 IRC Clunn: Singh, Anand K O
O O
Date:
aL Comments:
l i
l i
I l
Pnnled 3f109610:32:19 AM Page 2 or 2 l
met UWWes
-lCAVP DR No. DR-MP3-0696 umstone unit 3 Discrepancy Report Review ereup: syneem on REscumoN ACCEPTED Review esement: system Design Discipune: Electrieel Design Om Discrepency Type: %W g
systenWProcese: DGX NRC signtAconce M 4 Date faxed to Nu:
Date Published. 11/15/97 E.
- i. Bus Differential Relay Samne (Calculation 420CA)
Descrepelen: One of the protective devices used for the Safety Related 4.16 kV awitchgear is a set of General Electric Type PVD high impedance bus differential relays at each of the two switchgears.
Calculation 420CA determines the setting of the PVD relays.
The calculation was based on a maximum fault current of 41,000 amperes, which is the breaker rating at the maximum rated voltage of the switchgear (4760 volts). However, the circuN breaker rating at the normal operating voltage is higher, and symmetrical fault currents larger than 41,000 amperes are reported in Calculation NL-051. The existihg setting of the voltage elemord (100 voks) leaves no margin from the calculated minimum setting for 41,000 amperes fault current (100.4 volts). The minimum setting is determined by the need to prevent falso tripping during faults outside the protective zone of the relay. The calculation methodology assumes the complete saturation of a current transformer, which is conservative. Also, three phase bolted faults near the switchgear terminals are rare.
However, the setting of the PVD differential relay voltage elements should be raised to accomodate a through fault current equal to the maximum interrupting rating of the circuN breakers (49,000 amperes).
Review vond invaud Nomled Date intilstor: Bloelho, G.Wlasm Q
Q Q
11/4G7 v7 Laod: Neri, Anthony A O
O O
15'd'87 VT tagr: schopfer, Den K G
O O
1'107 unc chen: singh, Anand K G
O O
55'15/S7 Dese:
udvAUD:
Date:
3/4/98 RESoumON. NU has concluded that Discrepancy Report, DR-MP3-0596, has iderdified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per US PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97-4190 has been written to develop and track resolution of this item per
.I RP-4.
Conch.sion:
NU has concluded that Discrepancy Report, DR-MP3-0596, has
]
Printed 3/ toes to 33:31 AM Page 1 or 2 i
Northeast Utilities ICAVP DR No. DR MP3-0696 ministone unit 3 Discrepancy Report 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 cilteria CR M3-97-4190 l
has been written to develop and track resolution of this item per RP-4.
Previously identtRed by NU? O Yes @ No NonDiscrepentCondluon?Q Yes @ No nosoionenP.nanntO v.e @ No nosoimion unr.coeved70 vs. @ No
- n. view Y
~
initiator: Womer,1.
VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K Inc Chmn: Singh, Anand K Date:
SL Conenents:
1 1
l l
Printed 3/104610.33.34 AM Page 2 of 2
Northeast Utilities ICAVP DR Ns. DR-MP3-0661 Millstone unit 3 Discrepancy Report Review Group: Configuration DR REsOUJTION ACCEPTED Review Element: System instellation DiecipNne: Piping Design O vee i Type: m implementeon
@ No s, :
.cox NRC signMcence W:4 Date faxed to Nu:
l
]
Discrepency: Walkdown Discrepancy of DGX
==
Description:==
The following discrepancy items were found during the walkdown of the piping and mechanical equipment of the Emergency Diesel Generators (DGX):
- 1. Pipe support CP-360512-H0002 shown on drawing BZ-60R-79 Rev 1 is suppose to be supported between two wide flange beams that are 5ft-31n apart. The field walkdown found the support to be cantilevered out 2ft-8in from one beam only.
- 2. Pipe support CP-360267-H002 shown on drawing BZ-60R-102 Revi has vertical tube steel supported from a wide flange beam but not centered on the flange as shown on the drawing.
Review Veild invalid Needed Date Initiator: Reed, J. W.
O O
O f '/8/87 VT Leed: Nort. Anthony A B
O O
iiiaro7 VT Mgr: schopfer, Don K G
O O
1/ o'87 IRC Chmn: sin 0h, Anand K B
D O
i /ti/S7 Date:
INVAUD:
Date: 2/24/98 REs0LUTioN: Disposition:
NU has concluded that Discrepancy Report DR-MP3-0651 item 1 has identified a condition not previously discovered by NU which requires correction. Condition Report ( CR ) M3-97-4472 was written to provide the necessary corrective actions to resolve this
)
issue. The corrective action (AR 97029771) is to requalify the existing supposi configuration in calculation 12179-NP(F)-Z60R-512-H002 and issue a DCN to update drawing BZ-060R-79 to reflect the as-installed condition. The corrective action is not required for restart. No field modifications will be required.
)
Item i states that Pipe Support CP-360512-H002 is not installed i
with its tube steel supported between two wide flange beams 5'3" apart as shown on drawing BZ 60R-79, Rev.1, but cantilevered out 2'-8' from only one of the beams.
A search of GRITS reveals the present drawing configuration was derived from E&DCR F-J-33010 which requested the 1
attachment of another support CP-360511-H003, to the cantilevered member of CP-360512-H002. This was allowed, but with the modification of extending the cantilevered tube steel member of H002 to obtain an additional attachment point on the adjacent wide flange beam. The latest Calculation 12179-NP(F)-
Z60R-512-H002, Rev. 3 suppo.ts the configuration shown on E&DCR F-J-33010 and its incorporation on BZ-60R-79, Rev.1.
Printed 3/10/9610 35.33 AM PeGe 1 or 3 1
Northeast Utcities ICAVP DR No. DR41P3 0481 Millstone unit 3 -
Discrepancy Report i
A field walkdown of support CP-360512-H002 and its ganged support CP 360511-H003 in the Fuel Oil Storage Tank vault of 3EGF*TK18 reveals that, as stated in this DR, the extension of the tube steel vms not installed and no additionM documentation could be located to support the as-installad contiguration.
Descrepancy Report DR-MP3-0651 item 1 is considered by NU to be significance level 4 based on the review of the as-installed support and structural steel. The evaluation determined that the as-installed condition is adequate for the existing design loads The as-installed configuration does not affect Nuclear Safety and Licensing Design Basis.
NU I:as co.v:luded that Discrepancy Report DR-MP3-0651 item 2 does not represent a discrepant condition.
j ltem 2 indicates that the vertical tube steel member for Pipe Support CP-360267-H002 is not centered on the attachment wide flange beam as shown on drawing BZ-60R-102, Rev.1. A search of the GRITS database indicates the installed -
configuration was originally issued per E&CCR F-J-35092 and a field walkdom determined that the of the vertical member (item 2)!s located 2 5/8" from the centedine of the beam (or 7/8" from the west edge of the flange) with a stiffener plate installed on the same side of the beam as the eccentricity.
A review of Pipe Support Calculation 12179-NP(F)-Z060R-267-H002, Rev.1 indicates that prior to the request for modification due to existing field conditions, the original suppott detail was to be installed per a standard BZ-300A Smallbore Pipe Support Standards Series detail. The revised design per E&DCR F-J-j 35092 was reviewed and approved by the Structural Department l
and a stiffener plate was added which indicates the eccentricity l
was recognized and accounted for. Even ilmugh this support was converted from a Standard to a Special due to field conditions, it still followed the strudural steel attachment gu'delines given in the BZ-300A Series in general, the
)
guidelines of this senes require structural attachments to be no i
closer than 1/2" from the edge of a beam flange (for example, refer to BZ-300A 52, Sh. 4 of 8) and gives the maximum eccentricity allowed without adding stiffeners. Since this attachment is 7/8" from the edge of the flange it is therefore within the guidelines of the BZ-300A Smallbore Pipe Support Standards Series which covers this type of pipe support.
Therefore, the drawmg does not have to be updated and no further adion is required.
Conclusion.
NU has concluded that Descrepency Report DR-MP3-0651 item 1 has identified a condMion not prevhsly discovered by NU which requires corredion. The corredive sdions to requalify the existing support configuration in calculation 12179-NP(F)-Z80R-512-H002 arxl issue a DCN to update drawing BZ-060R-79 to reflect the as installed condition will be implemented and tracked under the auspices of Condition Report MS-g7-4472.
Discrepancy Report DR MP3-0651 item 1 is considered by NU to i
be significance level 4 based on the review of the as-installed support and strudural steel. The evaluation determined that the as-installed condition is :-'= t for the existino desian loads.
PHnted 3/100s 10:35:35 AM Page 2 or 3
Northeast Utilities ICAVP DR No. DR MP34661 Millstone Unit 3 Discrepancy Report The as-installed configuration does not affect Nuclear Safety and Licensing Design Basis.
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0651 item 2 does not represent a discrepsnt condition.
The pipe support was modifie.1 per EADCR F-J-35092 to add a stiffner due to conditons at its location during construction. The stiffner was added to the drawing. The attachment ( vertical tube steel) offset position is within the guidelines of the BZ-300A Smallboro Pipe Support Standards Series which covers this type of pipe support and therefore the drawing does not have to be j
updated. The corrective action is not required for restart. No field modifications will be required.
i.
Previounty khmtened by NU7 U Yee (G) No Non Discrepent ComNtkm?U Yes (9) No me.oimionremne?O m @ No n oiunonunr e*ed70 va @ No n.wi RW W Not F- / "- Needed Date VT Laod: Nerl, Anmeny A VT Mgr: Schopfer, Don K InC Chmn: S$, Anand K Date:
si.Conenents-Printed 3/1oS610.35:38 AM Page 3 of 3
Northeast Utilities ICAVP DR No. DR-MP3-0698 Millstone Unit 3 Discrepancy Report Review Group: System DR REsot.UTION ACCEPTED OY=
Electricot D"*"
E--
, - :p Type: Component Date gg systemmocess: DGX NRC signiacesce level: 4 Det.:. FAKod to NU:
Date Putdiohed.1/1046 F+, mi. Vsndor Drawings and NU Database Discrepancies involving Motors Ducription.
A. Vendor Drawings, Plant Design Data System (PDDS), and Production Maintenance Management System (PMMS)
- 1. The checklists do not provide a requirement that the motors' equipment numbers agree among the design documents, Mwever, conflicting equipment numbers could result in selecting the wrong data for a motor. The service descriptions ol the fonowing pumps disagrees between the Specification 2447.300-241 (Rev. 2), vendor drawings, PDDS, and PMMS, and the one line diagram as shown below (vendor drawings are all prefixed with 2447.300-241):
Descript!on Vendor One Line Spec. PMMS PDDS Pre-lube Pump X
Prelube & Filter Pump
-009 Lube Oil Filter Pump
-169,-004 EE-1EH X
X Prelube Oil and Filter Pump X
X Lube Oil Circulating Pump X
Preiube & L.O. Filter Pp
-107 Description Vendor One Line Spec. PMMS PDDS Jacket Keep Warm Pump X
Water Jacket Circulating Pu X
X Standby Jacket Cool Pu -169,-004 EE-1EH X
Jacket Water Pump X
X Jacket Water Sys. Pu.
-006 Note: The revision used for the above documents are Rev. 4 for EE-1EH, Rev. G for -009, Rev. C for-169, Rev. F for-004, and Rev. A for-107.
The documents need to be revised to reflect consistent equipment descriptions.
- 2. The equipment numbers of the following pumps disagrees between the vendor drawings, PDDS, and PMMS, and the one fina dinnrnm ne chmun hairw ruandnr drawinne nra all reafivnd
' Pege 1 of 4 Printed 3/104610:3606 AM
4 Northeast bidities
- OAVP DR No. DR-MP34498 milistone Unit 3 Discrepang Report with 2647.300-241)
Rocker Arm Prelube Pu Vendor One Line PMMS PDDS 1
3 EGO *P2A/B
-009 3 EGO *P1A/B
-169,-004 EE-1EH X
X Standby Jacket Calant Pu Vendor One Line PMMS PDDS 3EGS*P2A/B
-169,-004 EE-1EH X
X 3EGS-P1A/B
-006 Lube Oil Filter Pump Vendor One Line PMMS PDDS 3 EGO *P1A/B
-009 3 EGO *P4A/B
-169,-004 EE-1EH X
X 3 EGO *M1A/B (motor)
X X
3 EGO *M4A/B (motor)
X Note: The revision used for the above documents are Rev. 4 for EE-1EH, Rev. G for -009, Rev. C for-169, Rev. F for-004, and Rev. J for-006.
The documents need to be revised to reflect consistent 4
equipment numbering.
- 3. The Addendum 3 motor data sheet for 3EGF*P1 A, 3EGF*P18,3EGF*P1C, and 3EGF*P1D has data which is not the same as the data on the Addendum 2 motor data sheet in Specification 2441.200-043 (Rev. 0). Plant Design Data System (PDDS) and Production Maintenance Management System (PMMS) reflect the efficiency (0.808), speed (3500 rpm), full load (3.8) and locked rotor (25) current data in Addendum 2, but PDDS reflects the power factor (0.915) of Addendum 3. Vendor Drawing 2441.200-043-001F reflects the Addendum 3 d:ta (Frame 210HP,3440 RPM), and Vendor Drawing 2441.200-043-0038 reflects the Addendum 2 data (Frame 180HP,3550 RPM, fullload current of 3.8 amps, locked rotor current of 25 amps). A review of GRITS shows both drawings as active and with no outstanding change documents which would affect the motor i
data shown on the drawin0s. It cannot be ascertained if the test data in Calculation M3-SP-EE-011 (Rev.1) is from the Addendum 2 motor or the Addendum 3 motor because the test data is significantly lower (2.5 to 2.9 amps full load current and 36.8 to 42.3 amps locked rotor current for 3EGF*P1 A, and 2.7 to 3.6 amps full load current and 36.2 to 43.2 amps locked rotor current for 3EGF*P1B). PDDS and PMMS should t>e revised to i
reflect the data of the installed motor, and the test data shown in Caldation M3-SP-EE-011 should be reconciled with the i
vendor's data shown in Specification 2447.200-043.
- 4. The speed is shown on Vendor Drawing 2441.500-241-107A i
as 1150 rpm for SEGO*P4A and 3 EGO *P48. This does not aaree with the speed shown in Sixx,ification 2441.300-241 (Rev.
PrWed 3/1of961o.36:00 AM Page 2 of 4
I Northeast Utilities ICAVP DR No. DR-MP3-0698 Minstone Unit 3 Discrepancy Report 2), Plant Design Data System (PDOS), and Production Mairdenance Management System (PMMS) which is 1160 rpm.
B. Production Maintenance Management System (PMMS)
- 1. For the following pump motors, Production Maintenance j
Management System (PMMS) has three ampacity categories j
and values for two ampacity attributes:
i 3EGF*M2A/B: AFL = 18; ALR = 0; Amps = 2 3EGS*M1 A/B: AFL = 1.4; ALR = 9.2; Amps = 0.75 3 EGO *M1 A/B: AFL = 10.3; ALR = 63.5; Amps = 7.5 Comparing the values in PMMS with other documents, "AFL" and "ALR" represent full load and locked rotor current, respectively. It appears that " Amps" represents the horsepower, in addition, horsepower is shown as zero for 3EGS*M1 A, 3EGS*M18,3 EGO *M1A, and 3 EGO *M18.. " Amps" and 1
" horsepower" should be revised to refied the actual motor I
attributes and values. Note that the PMMS sheets for the corresponding pumps appears to have the appropriate data entries for these attributes.
- 2. Production Maintenance Management System (PMMS) shows the following multiple motor equipment numbers and equipment descriptions for the same driven equipment: Prelube Oil and Filter Pump (3 EGO *P4A and 3 EGO *P48), Lube Oil Filter Pump Motor (3 EGO *M1 A and 3 EGO *M18), and Prelube Oil and Filter Pump Motor (3 EGO *M4A and 3 EGO *M4B). PMMS should be revised to reflect the appropriate equipment number and description.
- 3. The service factor for 3 EGO *P1 A and 3 EGO *P1B is shown as 1.0 in Specification 2447.300-241 (Rev. 2) Page 2-15 and as j
1.15 on vendor Drawing 2447.300-241-111 A. The appropriate document should be revised to reflect the actual service factor of the motor.
Review Valid invalid Needed Date initiator: KendeR,D.J.
O O
O
' ' SS7 VT Lead: Neri, Anthony A O
O O
52iists7 VT Mgr: schoph, Don K S
O O
2/2297 IRC Chmn: Sm0h. Anand K B
O O
$2/31/s7 1
oste:
mvAvo:
pote:
2/9/98 RESOLUTION-Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0698, has Printed 3/10/9810:36.10 AM Page 3 of 4 i
Northe:st Utilities ICAVP DR No. DR-MP3-0898 Millstone Unit 3 Discrepancy Report i
identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B18901 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 M3-98-0493 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0698, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has beer; screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criterie. CR M3-98-0493 has been written to develop and track resolution of this item per RP-4.
Previously identleed by NUF f.) Yes @ No Non Discropont condalon?U Yes @ No ResolutionPending?O Yee @ No P- %uareeoived70 vee @ No Review N-,"'__
Not #=5-- ' '
Needed Date
^
y VT Leed: Nort, Anthony A VT Mgr: schopfer, Don K IRC Chmn: S@ Anand K Date:
sL Comments:
Prhted 3/10/9610:36:12 AM PeGe 4 of 4
Northeast Utilities ICAVP DR No. DR-MP34699 milistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipane: Elodrical Deegn gy Ow N, - up Type: Component Date gg Systemproc_es: DGX NRC Signiacance level: 4 Date faxed to Nu:
Dale Putisched.1/10G8 NV-y: Calculation Design input Discrepancies involving Motors Descr8ption: 1. Calculation SP-M3-EE-011 (Rev.1) provides test values for the emergency d!essi generator motors. It is expected that there would be some variation between the tested data and the vendor supplied data, for even in Calculation SP-M3-EE-011 the values recorded in the three phases are different. However, for 3 EGO *P4A and 3 EGO *P4B, the full load current values i
shown in Calculation SP-M3-EE-011 (5.8 to 6.6 amps 9 3 EGO *P4A and 6.4 to 6.8 amps for 3 EGO *P4B) are 4 aficantly lower than the values provided in Specification 2441.300-241 Rev. 2 (10.3 amps). For 3 EGO *P1 A and 3 EGO *P1B, the values for full load current (1.2 amps) and locked rotor current (4.46 to 5.02 amps for Code Letter J) in Specification 2441.300-241 also vary from Calculation SP M3-EE-011 (the full load current = 1.0 amps and the locked rotor current = 5.9 to 7.1 amps for i
3 EGO *P1 A, and the full load current = 1.2 amps and the locked rotor current = 5.4 to 7.8 amps for 3 EGO *P18). The difference between the tested values and the vendor's data provided in the specification could affect the starter's breaker and thermal overioad settlags (these cannot be verified because the setting sheets are not available for review).
- 2. For 3EGF*P2A and 3EGF*P28, the full load current value of 18 amps shown in Specification 2441.300-241 (Rev. 2), Plant Design Data System (PDDS), and Production Maintenance Management System (PMMS) does not match the tested data shown in Calculations SP-M3-EE-011 Rev.1 (9.6 amps for 3EGF*P2A and 9.5 amps for 3EGF*P28), BAT 1-96-1241E3 Rev.
1 (9.6 amps for 3EGF*P2A), and BAT 2-E1243E3 Rev.1 (9.5 amps for 3EGF*P28). The documents should be revised to reflect the actual full load current. In addition, Calculation SP-M3-EE-011 shows a locked rotor current of 54 amps for 3EGF*P2A which does not agree with the value of 58 amps used in Calculation BAT 1-96-1241E3. This discrepancy should be reconciled, however, the data used in performing battery sizing calculations (58 amps in Calculation BAT 1-96-1241E3) is the higher value and therefore is conservative.
- 3. Calculation SP-M3-EE-011 (Rev.1) shows 3 EGO *P1 A and SEGO*F'.3 as non safety-related (i.e., a dash * "is shown instead of an asterisk * * "). This calculation should be revised to reflect the safety related desi0 nation.
- 4. Cal mlation SP-M3-EE-342 (Rev.1) states as an assumption
'hhor3
'N' E' Pftnted 3/104610:3751 AM
W Northeast Utilities ICAVP DR No. DR MP3 0499 i
Millstone Unit 3 Discrepancy Report values are not available from the project documentation" 1
(Appendix B, Page B2), brake horsepower (BHP) is equal to the nameplate horsepower, efficiency is 0.92, and the power factor is 0.88 for 460V motors. However, for the 460V motors 3EGF*P1 A,3EGF*P18,3EGF*P1C, and 3EGF*P1D, the project documentation is available for this data but was not used in the calculation. The data for these motors is 1.6 BHP normal / 2.2 BHP maximum, a power factor of 0.915. and an efficiency of 0.78 (reference Specification 2441.200-043, Add. 3 Rev. 0).
Since the actual brake horsepower is less than that assumed in the calculation, the results of Calculation SP-M3-EE-342 are conservative. However, since the actual data is known, either it should be used or the statement fro ri SP-M3-EE 342 should be revised.
Review i
Vend invend Needed Date j
initiator: KondeN,D.J.
8 O
O 2r3s7 VT Leed: Neri, Anthony A G
O O
'2/ 7S7 VT Mgr: Schopfer, Don K G
O O
$2r23s7 lRC Chmn: singh, Anand K G
O O
$2r3iig7 osee:
INVAUO:
Dese: 2/17/98 RESOLUTION Disposillon:
NU has concluded that Discrepancy Report, DR-MP3-0699, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0699, has identified a condition not previously discovered by NU which requires corredion. This discrepancy meets the criteria specified in NRC letter 816901 and.17010 It has been screened per U3 PI-20 criteria and fcund to have no operability or reportability concerns and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.
Previove#y identina: by NU7 (.) Yee @ No Non Discrepent Conditiont(.) Yes @ No Renoiummrensas70 va @ No P%Unremhed70 va @ No Review initiator: Kondet, D. J.
VT Leed: Nerl, Anthony A VT Mgr: Schopfer, Don K G
O m
IRC Chmn: singh, Anend K O
O O
Date:
SL Comments:
Prtneed 3/1Q9810:37:55 AM Pope 2 of 3
Northe:st Utilities ICAVP DR No. DR-MP3 0C99 Miiistone Unit 3 Discrepancy Report i
l Printed 3/10/9810:37.56 AM Page 3 of 3
Northeast Utilities ICAVP DR N3. DR-MP3-0732 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Desi0n p
Diecipene: Em Des @n Discrepancy Type: Componer1t Date O vos gg SystemProcese: HVX NRC Signinconce level: 4 Date faked to NU:
Date Published 1/3s6 Discrepancy: Cable and Motor Output Sizing Concems involving HVAC Motors Description
- 1. Calculation 067E (CCN 4, Rev. 0) establir.,hes maximum cable lengths for 460V motors. The cable size for the feed to 3HVR*ACU1 B (Cable # 3HVRBPL001, Mark # NHR-25) is not listed in Calculation 067E, as this s!ze of cable (#8 AWG) is too small for a 50 HP motor and would lead to an unacceptable voltage drop. Since this cable size is not evaluated, the voltage at the damper motor cannot be confimled (the results are indeterminate).
- 2. Specification 2474.030-624 (Rev.1) does not provide brake horsepower load requirements for 3HVR*RE10A, 3HVR*RE108, 3HVR*RE19A, or 3HVR*RE198, therefore, a mathematical evaluation cannot be performed on the data to detemiine if the licensing requirement (that the motor be sized to develop sufficient horsepower to drive the mechanical load under runout or maximum expected flow and pressure whichever is Greater, and without encroaching on the service factor) is met. (A review of vendordrawings was made, but this data could not be found.)
J
- 3. In Specifications 2472.900 594 (Add,1, Rev.1) and 2170.430-4 140 (Add.1, Rev. 2), dampers are not sized in terms of brake horsepower but are sized to develop torque sufficient to drive the dampers. Specification 2472.900-594 Page A1-13 requires that the torque developed by the motors be at least 1.5 times the l
torque required by the dampers. However, in Specification 2472.900-594 Pages A2-104 and A2-105 and Vendor Drawing 2472.900-594-1578, the motors for Dampers 3HVP* MOD 26A cod 3HVP* MOD 268 develop 1523 inch-pounds which is only 1.26 times t'1e torque required by the dampers (1206 inch-pounds). No calculation could be found which justifies this deviation from Specification 2472.900-594.
Review Valid invalid Needed Date i
Initiator: KendeR.D.J.
B 0
0 12/ tis 7 VT Leed: Neri. Anthony A G
O O
12SS7 VT Mgr: Schopfer, Don K O
O O
i2/ii/or NtC Chmn: singh, Anand K Q
O 12/2497 j
Dele:
{
INVALID:
Date:
3/5/96 RESOLUTION Dispositlon:
Printed 3/109610:36:26 ABA Page 1 of 3
4 Northeast Utilities ICAVP DR No. DR-MP3-0732 Ministone Unit 3 Discrepancy Report NU has concluded that item 3 of Discrepancy Report, DR-MP3-0732, has identified a condition not previously discovered by NU which require correction. The safety function of the damper is
(
satisfied by the actuator spring (retuming the damper to a closed position), not the actuator motor. The actuator motor performs a non-safety function of opening the damper, and is adequately sized to operate the damper.
1 The approved corrective action plan for CR-M3-98-0277 will reconcile the discrepancy between Soecification 2472.900-594 and the Technical Data Sheets for dampers 3HVP*28A & B.
Since this discrepancy is minor iri nature, and does not affect the Design or Licensing Bases, it is SPJn fance Level 4 issue.
NU has concluded that item 1 of Discrepancy Report, DR-MP3-0732, has identified a condition which was previously discovered by NU, and has been corrected by DCN #DM3-00-1817-97.
f The power cable for 3HVR*ACU1B was misdesignated in the Cable Raceway Control Program Database. Instead of belrg a 4/C #8, Mark #25 as indicated in the raceway program; it is a Tri.
2/0, Al., Mart # 35 which has been verified by a field walkdown.
This discrepancy was identified by Unit 3 Engineering Staff on 10/30/97 and DCN # DM3-00-1817-97 was issued to correct the issue. Unit 3's discovery of thisiissue was independent of the S&L discovery process, as this DR was received on 12/31/97.
Since the nature of this discrepancy is administrative and has no Imped on the Design or Ucensing Basis, NU concluded that a Significance Level 4 assignment is appropriate.
NU has concluded that item #2 of Discrepancy Report, DR-MP3-0732, does not represent a discrepanct conditlon.
1 The four radiation monitoring units were purchased as packaged units to include the pump system. The manufacturer provides a l
1.5 HP mohr and pump as a standard unit. The maximum j
design flow fre these units is 5,000 cc/ min which the motor is l
sized for. System flow is adjustable from 0 to 5,000 cc/ min by use of manual needle valve. In the case of the KMG-HRH monitor, the nominal sample flow rate is adjusted to 670 cc/ min (or 2.637 E-02 cubic feet per minute). This represents about 12% system capacity. The default flow setpoint is usually specified at about one-tenth this value, or about 2.0 E-03 cubic feet minute. Periodic surveillainces verify calibration of these units. The HP of the pump motor is adequately sized for maximum system flow and pump runout.
Significance level criteria does not apply to item #2, as this is not a disempant condition.
==
Conclusion:==
NU has concluded that item 3 of Discrepancy Report, DR-MP3-0732, has identified a condition not previously discovered by NU which require correction. The approved corrective action plan I
for CR M3-98-0277 will reconcile and correct Specification 594 Prned 3nOr9e 10.3829 AM Page 2 of 3
4 Northeast Utilities ICAVP DR No. DR MP3-0732 milistone unit 3 Discrepancy Report and the Damper Data Sheets. Since this discrepancy is minor in nature, and does not affect the Design or Licensing Bases, it is Signifance Level 4 lasue.
NU has concluded that item 1 of Discrepancy Report, DR-MP3-0732, has identified a condition which was previously discovered by NU, and has been corrected by DCN #DM3-00-1817-97. This item is considered an administrative error, therefore NU considers it to be a Significance Level 4 issue.
NU has concluded that item #2 of Discrepancy Report DR-MP3-0732 does not represent a discrepant condition. The motor for the radiation monitoring unit has been sized for maximum system performance. The motor operates at 10% of its rated capacity, as such it did not require a detailed calculation.
Previously ha. Wined tpy NU7 O Yee (#J No Non Discrepent Constion?O Yes (9) No n.*none..angtO va @ No p%unroemedtO Yee @ No n.wi.,
M f"-
Not Acceptaine Needed Date VT Lead: Neri, Anthony A vr Mgr: schopfer, Don K IRC Chmn: sk@. Anand K Date:
3/5/98 sL comments: Item 1 - Upon review of the field verification and the design changes NU has made as noted in their response, this item is satisfactorily resolved and the discrepancy has been reassigned to a Level 4 discrepancy because it is a documentation and not a hardware concem. NU discovered this discrepancy in October 1997, which was after the 6/1/9/97 cutoff date and therefore it is still a discrepancy.
Item 2 - Sargent & Lundy concurs with NU's response that this is not a discrepant condition, based upon the additional technical data NU supplied in their response.
Item 3 - Sargent & Lundy concurs that the actuator is designed w!!h sufficient marDin to provide reasonable assurance that the damper will operate as required, and that this will be confirmed with the vendor as noted in CR M3-98-0277. Sargent & Lundy does not agree with NU's statement that the operation of the i
motor to open Dampers 3HVP* MOD 26A/B is a non-safety function, because in the winter these dampers are modulated to maintain adequate room temperature.
I I
Printed 3/10/9610:38.30 AM Page 3 or 3 l
l I
1 i
Northeast Utilities ICAVP DR No. DR-MP3-0742 L
mitistone Unit 3 Discrepancy Report Moview Group: System DR REsoumON ACCEPTED i
Review ElemerA: system Design Olecipane: Elodncel Des:"
O vos F-
, ci Type: Cahdman g
systemProcese: DGX NRC W W 4 Date faxed to NU:
Date Putdiohed.1/Ss8 t'
. ai; Fast Sus Transfer BlocAing Time Delay Relay (Calculation 426CA)
Pm ;.-- Calculation 426CA determines the setting of miscellaneous undervoMage and time delay relays associated with the fast and residual voltage bus transfer schemes. One relay,62R, blocks a fast bus transfer if it is delayed for some reason.
The calculation of the setting of time delay relay 62R includes a 1 cycle allowance for the delay due to an interposed auxiliary relay. However, an examination of schensatic diagrams 12179-1 ESK-7J, Revision 20 and 12179-ESK-5BD, Revision 24 indicates that there is no auxiliary relay that should be included in the setting calculation. After relay 62R times out, the fast transfer is blocked. The omission of the auxiliary relay shortens the time delay for relay 62R to operate and increases the chance that a fast txis transfer would be blocked.
Review vetid inveNd Needed Date infilator: Bloethe, G.Widiom O
O O
$2rs/97 YTLead: Nerl. Arthony^
O O
O t2ses7 viugr: schapter, Don x 0
0 0
12iitis7 mC chmn: singh, Anand K O
O O
12/24ro7 Date:
INVAUD:
Date:
3/6/98 REsoumoN Dis, y;,ition:
NU has concluded that Discrepancy Report. DR-MP3-0742, has identified a condition not previously discovered by NU which requires correction.
Calculation 426CA of Specification SP-EE-269 is in error because it includes a 1 cycle allowance due to an interposed auxiliary relay to the determination of the time setting fur relay 62R.
Breaker Adivity Time - Calculation 426CA, calculated the maximum allowable time for successful breaker transfer
" transfer v indow" from normal to reserve power as 11.10 cycles.
From this determination, the calculation of the blocidng relay (62R) setting was determined so as to successfully block the l
breaker transfer process if the transfer wasn't going to be completed within 11.10 cycles. The determination of the 11.10 cycles for the breaker " transfer window" included a timinD margin of 15% (1.45 cycles). Without consideration of the margin factor Printed 3/109810:39:Ou AM Page 1 of 2
Northeast Utilities IC^Vp DR No. DR-MP3-0742 Millstone Unit 3 D'screpancy Report in the calculated required breaker activity time, total breaker adivity time for successful operation is 9.65 cycles (11.10-1.45
)
cycles).
Blocking Relay Time - In the calculation of the blocking relay time settino, a determination of all relay and contact activity
[ timing of the early 'b" contads, isolation contacts, and the determination of the setting of the blockir.g relay (62R)] had to 3
be made. The timing of another relay (1 cycle.) was inadvertently included in this calculation. The subtotal of relay and contact
]
timing (without timing relay 62R) was determined to be 3.65 cycles.
Detemination of Relay 62R Setting - To successfully block the
]
breaker activity if a problem occurs, t% to meet the breaker 11.10 cycle criteria, relay 62R was set at 7.5 cycles (11.01
)
cycles - 3.65 cycles = 7.45 or 7.5 cycles).
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0742 has identified a condition not previously discovered by NU which requires correction.The approved Corrective Action Plan for CR-MS-96-0319 will correct calculation 426CA post startup.Since the conclusion of the calculation is unaffected by the discrepancy, i
this condition is considered to be a Significant Level 4 issue.
Previousy idenoned by NU7 O Yes (G) No Non'- ;M conditirn?Q Yes (G) No n iunone.ndine70 v
@ No nosolutionuntesolved?O v
@ No
- n. view
^
inmesor: w.m.r. i.
VT Lead: Nort. Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh. Anand K Date:
SL Comments:
Printed 3/10S810.39N AM Pape 2 of 2
\\
Northeast Utilities ICAVP DH No. DR-MP3-0747 Millstorm Unit 3 Discrepancy Report Review Group Opendons & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Diecipene: opwauons O vas W. - :, Type: Correcthe Action g
s,L.. = Hvx i
NRC Signiacance level: NA Dale faxed to NU:
Dale Putmahed 1/1048 Discnsancy: Ineffective resolution of common mode failure.
Descriphon Licensee Event Report (LER) 91-018-01 states that: "...as a result of a loss of a nor, vital power supply, a common mode failure occurred which rendered both trains of the Supplemental Leak Collection and Release System (SLCRS) inoperable. The postulated cause is steam enteiing the common SLCRS discharge duct, melung the fusible links for the Train 'A' and Train 'B' fire dampers (3HVR*DMPF44 and 3HVR*DMPF29 respectively), and causing the fire dampets to close. The root cause is design deficiency. The waste gas system and SLCRS were not proper 1y designed to handle a loss of non-vital power.
As corrective action, the fusible links were replaced and the SLCRS re;umed to service. The design of the SLCRS and waste gas system were reviewed ar.d procedural changes made to prevent a common mode failure of the SLCRS due to a loss of non-vital power."
The analysis of event states that: *...should a loss of offsite power occur feitowed by a safety injection signal, there is a possibility that the GLCRS could become inoperable due to a common mode fa' dure "
In response to this event an additional corrective action revised plant operating procedures to direct the control r.om operators to close the Main Steam isolation Valves in the event of a loss of non-vital power. This procedure change to compensate for a design deficle')cy is contrcry to the industry practice of reducing operator work arounds.
S&L does not consider this to be appropriate long-term corrective action and to be a discrepancy.
Review vand invaud Needed Date initiator: Piernowicz, R.
O O
12/4S7 VT Leed: Bees, Ve O
O O
12/4S7 VT Mgr: schopfer, Don K 8
O O
52ritrar inc chmn: Shgh, Anand K D
C O
i2 ratio 7 Dese:
INVALID:
Date:
3/9/98 RESOLUTION. Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR.MP3-0747, does not represent a discrepant condition. LER 91 018-01 states,"As a long term corrective actions, the design of the SLCRS system and connections to the waste gas system Printed 3/104610 39:33 AM Page 1 of 3
Northeast Jtilities ICAVP DR No. DR-MP3-07[
Millstone unit 3 mpancy Report l'
M The fusible links in dampers 2
9 44 have been changed by PDCR MP3 t apoints of 285 degrees Fahrenheit to prevent
. 5xoming inoperable on a loss of non-vital Arredive action solved the specific concem of a
!silure of SLCRS due to a loss of offsite power
, M J c'
'y a safety injection signal.
Several ade.snal corrective actions have been taken as described in another LER, LER 91014-01, which are not required to ensure SLCRS operability. "...in addition, plant operating procedures have been revised to direct the control room operators to close the Main Steam isolation Valves (MSIVs)in the event of a loss of non-vital power. Taking this action will not only limit energy input to the condenser, but also isolate the auxiliary steam supply to the Steam Jet Air Ejector (SJAE).*
The corrective actions associated with this event included a review of the SLCRS and waste gas system design.
To ensure future operability of the SLCRS system, the design rey!ew concluded that the existing 165 degrees F fusible links be replaced with links that would fail at duct temperatures above 285 degrees F. The setpoint is well above a maximum expected 245 degrees F temperature corresponding to saturated steam at a pressure of 12 psig.12 psig is the set pressure for the auxiliary steam supply relief valves (3 ARC-RV23A(B)) to the SJAE which was the source of energy la the event described in LER 91-018-01. Plant Design Change Request (PDCR), MP3 152, provides the evaluation for 3HVR*DMPF29 and 3HVR*DMPF44 Fire Dampe Fusible Link Replacement.
Significance Level Criteria do not apply here as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Repoli, DR-MP3-0747, does not represent a discreprat condition. The subsequent design review and modification to the fire dampers, 3HVR*DMPF29 and 3HVR*DMPF44, will prevent a common mode failure of the SLCRS due to a loss of non-vital power through the installation of fusible links having setpoints in excess of the highest expected dud temperature resulting from this type of event.
Corrective actions taken as described in LER 91-014-01 are not required to ensure SLCRS operability. Plant operating procedures have been revised to direct the control room operators to close tha Main Steam isolation Valves (MSIVs) in the event of a loss of non-vital power. Taking this action will not only limit energy input to the condenser, but also isolate the auxiliary steam supply to the SJAE.
The desian chance and operator actions are both acceptable I
Printed 3/10/9810.39.30 AM Page 2 of 3
i Northeast Utilities ICAVP DR No. DR-MP3-0747 Millstone Unit 3 Discrepancy Report corrective actions for this event although the re-rated fusible links was the action to ensure SLCRS operability. Therefore NU 1
does not consider this to be a discrepant condition.
Significance Level Criteria do not apply as this is not a d!screpent conga.q.
Previounty idenamed by Er7 U Yes. @ No NonDiscrepentConda6on?(#) Yes O No j
ner.nana70 m
@=
neeanonunreemed70 m @m no*.
Ine;esor: spear, R.
8 O
O
=
vrLese: sees, Ken VT Mgr: schopfer, Don K NtC Chmn: s6ngh, Anand K Dese:
3/9/98
{
st comments: S&L concurs with NU's response to DR MP3-0747.
Not included in the response was the rational for continuing to direct the control room operators to close the Main Steam isolation Valves (MSIVs) in the event of a loss of non-vital power, j
285 degree Fahrenheit fusible links in the fire dampers will prevent the dampers from isolating in the event of loss of non-vital power and steam entering the Supplemental Leak Collection and Release Sythm (SLCRS) common discharge duct, thus j
pos& bly negating the need to close the MSIVs as identified in the -
initial ca.Tectiva action.
No rational could be determined for manually closing the MSIVs and initiating a plant transient duo solely to the loss of non vital power with the 285 degree fusible links installed. S&L recommmds that NU reassess the closure of the MSIVs now that the fusible links of higher temperature ratings are installed.
)
I Pnnted 3/1o961039:37 AM Page 3 of 3
Northeast Utilities ICAVP DR No. DR-MP3-0762 Misistone Unit 3 Discrepancy Report Kwlow Group: System DR RESOLUTION ACCEPTED Review Element: Modecanon m rmW: m W O vee F
, - :y Type: TeeUmpnwnertenon g
Syster WProcess: HVX NRc "'J" =Esilevel:3 Date faxed to NO Date Putdished 12/20s7
'. ci; PDCR MP3 92-024 Fan 3HVRTN128 Vibration Test Deriptnan: During review of PDCR MP3-92-024 that installed a larger diameter wheel in supplementary leak collection and release
]
system (SLCRS) fan 3HVRTN128 a discrepancy regarding i
vibration test results was identified.
l Reg. Guide 1.52, Rev. 2, Position C.3.1 states that the system fan, its roount!ng, and the ductwork connections should be designed, constructed anti tested in accordance with the provisions of Sections 5.7 and 5.8 of ANSI N509-1976. ANSI N509-1976 Section 5.7.3 states that the maximum pem11ssible vibration velocities shall be 0.1 inisec radially and 0.2 inisec axially. FSAR Table 1.6-1, Reg. Ouide 1.52, Rev. 2 does not take exception to this requirement i
The fan vibration test results dated 6/19/92 included with AWO M3-92-14052 exceed ANSI N509-1976 reqquirements. The radial vibration was.205 inisec horizontel and.122 in/sec vertical at the outboard motor bearing,.215 in/sec horizontal and 0.052 in/sec at the inboard motor bearing. The axial vibration was.265 in/sec at the motor outboard bearing.
Review Vaud invalid W
Date Instietor: stout. M. D.
O O
O 52/as7 VT t. sed: Neri, Anthony A O
O O
52ss7 VT Mgr: Schopfer, Don K O
O O
2/ itis 7 (RC Chmn: singh, Anand K Q
Q 12/16/97 Date:
INVAL10:
Dele:
3/4/96 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR MP3-0762, has identified c condition not previously discovered by NU which requires correction. CR M3-93-0304 (Attached) has been written to develop the corrective actions associated with this DR.
It was determined that the SLCRS exhaust fans modified via PDCR M3-92-024 were balanced to the criteria of Engineering Procedure EN-31128, which was in effect at the time. EN-31128 is currently in "Do Not Use" status, pending bi-annual review.
Equipment balancing is currently covered by CBM-104. Both referenced prtx:edures have less restrictive criteria than ANSI N509, which was committed to in FSAR Section 6.3.2.1 through reference to Reg Guide 1.52. An engineering evaluation will be conducted to determine the acceptability of Millstone fan Pnnted 3/1096 toA7:25 AM Pege 1 of 2
T Northecst Utilities ICAVP DR No. DR MP34762 Millstone Unit 3 Discrepancy Repoft vibration criteria. The evaluation shalljustify Millstone's standards for fan performance acceptance versus ANSI N509 standards. An exception to ANSI N509 must be added to the FSAR, based on the results of the en0ineering evaluation.(FSAR commitment). An FSARCR shall be created to initiate / track the update.
The vibration analysis procedures shall be updated to reference the FSAR Table 1.8.1 requirements, it should be noted that during the early licensing of MP3 an exception to the vibration balancing recuirements of the RG 1.52 was initiated. However the in!'Ja! exception was not implemented. (refer to Letter B11165, dated 5/9/84, W. G.
Council to B. J. Youngblood, Open item # PSRB-13, Question 0640.5)
Corrective actions 1 & 2, associated with this CR, evaluating the current Millstone fan vibration criteria and Generating an FSARCR to take exception to the criteria of the FSAR, will be completed prior to unit restart. Corrective action 3, updating the vibration analysis procedures to reference the FSAR Table 1.8.1 requirements will be deferred until after unit restart
Attachment:
CR M3-98-0304 Letter 811185, dated 5/9/84, W. G. Council to B. J. Youngblood, Open item # PSRB-13, Question Q640.5)
MM/ Identined by NU7 O Yes (#) No NonDiscrepentCondition?O Yes (G) No n.-a% rensastO v.
@ No p % uareemed70 Ya @ No n.wi Initiator: Stout, M. D.
VT Leed: Neri. Anthony A O
=
VT Mgr: Schopfer, Don K.
InC Chmn: Sineh, Anand K Date:
SLConiments:
i.
T.W 3/104610:47:26 AM Page 2 of 2
Northeast Utilities ICAVP DR No. DR-MP34764 ministone Unit 3 Discrepancy Report Review Group: Operations & Meirtenance ord Testing DR RESOL.UTION ACCEPTED Review Element. OpenWng Procedure O vee oleerepancy Type: Test implementation gg SystemProcess: OsS NRC Sigplacencelevel:4 Date faxed to NU:
Date Pubilohed 1/1o/96 m ; cy: l&C's Measurement & Test Equipment Used for Surveillance Testing not Property Documented.
Deecription. OPS Form 3609.9-2, Quarterly QSS Valve Stroke Test, OPS Form 3609.9-3 & -4, Quarterly QSS Valve Stroke Surveillance-Train A & B have a *N/A" typed on their respective page 1's under the headin0s of ' Test Equipment Type', 'QA Number, and
' Cal Due Date' As these are Tech Spec Surveillances, the information for the test equipment used for these tests would seem to be a requirement for accuracy, traceability, trending, etc.
It should be noted that a cursory review of other OPS Forms shows that *N/A" may have been typed in the above mentioned fields on more than the cited Forrns. Therefore, it should be noted that this item of this Discrepancy could affect more than timing with stopwatches, and more than just Operations Surveillances.
Review Valid invalid Needed Date initiator: Ungeren, R.
O O
O
$2/1o/97 VT Leed: sees. Ken Q
Q Q
12/10/97 VT Mgr: Sctmpfer, Don K O
O O
12/23/97 IRc chmn: Singh, Anand K O
O O
52/3i/97 Date:
INVAUD:
Date:
3/2/98 RESOLUTION. Disposition:
NU has concluded that Discrepancy Report DR-MP3-0764 has identified a condition not previously discovered by NU which has been corrected. NU had previously discovered the specific condition described in DR-MP3-0764, however, during the investigation of the generic concem cited in the DR, one additional OPS Form, out of a review of more than 240, was found to have an inappropriate N/A included in the MT&E fields;
' Test Equipment Type', 'QA Number, and ' Cal Due Date'.
OPS Form 3609.9-2, Revision 7, Change 1. OPS Form 3609.9-3, Revision 3, Change 1, and OPS Form 3609.9-4, Revision 3, are utilized to record the results of stroke testin0 prescribed by surveillance procedure SP 3609.9. Procedure SP 3609.9, Revision 6, requires the stroke times for valves included on OPS Form 3609.9-2 to be measured utilizing a stopwatch and the stroke times for valves included on OPS Forms 3609.9-3 and 3609.9-4 to be measured utilizing plant nrocess computer points; valve stroke is timed from when the cic 'd limit switch computer point changes state until the open limit rwitch computer point Printed 3/10/98 to 49.33 AM Page 1 of 4
Northeast utnities ICAVP DR No. DR MP3 0764 l
Millstone unit 3 Discrepancy Report changes state. The current revision of OPS Form 3609.9-2 requires the recording of the QA Number and Cal Due Date for 3
the Stopwatch used when testing these valves; the form no lon9er has an 'N/A' included in the MT&E fields. OPS Form 3609.9-3 and OPS Form 3609.9-4 both utilize the plant process computer to measure valve stroke times. Therefore, the N/As included in the MT&E fields on these fomis are appropriate.
OPS Form 3609.9-2 was revised to remove the N/A from the MT&E fields via Revision 7 on 10-197. The need to remove the N/A was discovered during a review of surveillance procedures performed as part of the corrective actions (
Reference:
AR i
97022371-02) associated with CR M3-97-2999. This CR was written on 9-9-97, during the closeout of UIR 2513, to address I
several additional occurrances of an identical nature regarding operator failure to record MT&E information on OPS Form I
3626.3-12.
l A review of historical copios of OPS Form 3609.9-2 found the N/A had been added to the MT&E fields via Revision 5. A review of all completed surve'llances performed and recorded on OPS Form 3609.9-2 since Revision 5 became effective on 10 i 95 until the N/A was removed from these fields effective 10-20-97 via Revision 7 found the stopwatch calibration information was recorded on the OPS Form approximately 55%
of the time although the field was N/A'd. The remaining 45% of the completed surveillances do not provide any calibration information for the test equipment utilized to determine the valve stroke time. CR M3-96-0562 was written on 2-2-96 to address this condition and to develop corrective action. The investigation of this CR found the most recent completed surveillance properly j
recorded the MT&E information on the OPS Form. Additionally, I
it determined the completed survelitances with the missing calibration data were performed when the unit was in Mode 5; the valves that are stroke tested via OPS Form 3609.9 2 are not required to be operable in this plant mode. The approved corrective action plan for CR M3-98-0562 included a corrective action to review other surveillance forms associated with T/S 4.0.5 that have a N'A for MT&E to determine if tile N/A is appropriate. This assignment has been completed. A review of over 240 surveillance foncs associated with T/S 4.0.5 found one additional OPS Foan that incc%ctly has an N/A included in the M&TE fields. A corrective action to revise CPS Form 36108.3-5 to remove the N/As from the MT&E Fields has also been completed.
During the preparation of a response to this discrepancy report, it was discovered that the method utilized to determine the valve stroke time froin the plant process computer for valves included l
on OPS Form 3S09.9-3, and OPS Form 3609.9-4 is not consistent with the method described in the IST Program.
Surveillance Procedure SP 3609.9 measures valve stroke timo from when the closed limit switch changes state until the open limit switch chanoes state while the IST orocram states the Pdnted 3/10/9610:49;36 AM Page 2 of 4
i Normeast uuimes ICAVP DR No. DR MP3 4764 ministone unE 3 Discrepancy Report stroke time shall be measured from initiation of the actuation signal to the receipt of the end-of-stroke-indication. CR M3 0986 was written on 2-19-98 to investigate further and develop corrective adion.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0764 has identified a condition not previously discovered by NU which has been cor7ected.
NU has concluded that Discrepancy Report DR-MP3-0764 has identified a condition not previously discovered by NU which required correction. NU had previously discovered the specific condition described in DR-MP3-0764, however, during the i
investi0ation of the 9eneric coiscem cited in the DR, one i
additional OPS Form, out of a review of more than 240, was found to have an inappopriate N/A included in the MT&E fields;
' Test Equipment Type *, 'QA Number, and ' Cal Due Date'.
OPS Form 3609.9-2 was revised on 10-0197, prior to the issuance of this DR, to remove the N/A from the MT&E fields that had been added via Revision 5. The need to remove the N/A was discovered during a review of surveillance procedures performed as part of the corrective actions (
Reference:
AR 97022371-02) associated with CR M3-97 2999. This CR was written on 9-9-97, durin0 the closeout of UlR 2513, to address several additional occurrances of an identical nature re0arding operator failure to record MT&E information on OPS Form 3626.3-12. OPS Form 3609.9-3 and OPS Form 3609.9-4 both utilize the plant process computer to measure valve stroke times. Therefore, the N/As included on these forms is appropriate.
I A review of completed surveillances performed and recorded on OPS Form 3609.9-2 since Revision 5 became effective on 10 95 until the N/A was removed from these fields on 10-20-97 via Revision 7 found the stopwatch calibration information was recorded on the OPS Form approximately 55% of the timo althou0h the field was N/A'd. The remaining 45% of tiie completed surveillances did not provide any calibration information for the test equipment utilized to determine the valve stroke time. CR M3-96-0562 was written on 2-2-98 to address this condition and to develop corrective action. The approved corrective action plan included an assignment to review other surveillance forms associated with T/S 4.0.5 that have an 'N/A' for MT&E, in conjunction with their associated procedures, to determine if the N/A is appropriate. This assignment has been completed. A review of over 240 surveillance forms associated with T/S 4.0.5 found one additional OPS Form that incorrectly has an N/A included in the MATE fields. An assignme,nt to revise OPS Form 3610B.3-5 to remove the N/As from the MT&E Fields has also been mmpleted.
Previously Idenufted by Nu? O Yes
(#' No
~NonCWCondehon?U Yes (S) No n suuonPenens70 va @w n dui e dv.470 va @ No Review Pnnted 3/1oS810A9:37 AM Page 3 of 4
. ~
Norttwast Utilitin ICAVP DR No. DRMP34764 Millstone Unit 3 Discrepancy Report
- * * * * * - ^ ^
m M*
- m. som. t.
O swee VTLead: sees, nan vi m r: se w oonx D
=
e E
~
IRC Chmn: Singh, Anand K Dele:
SL Comments:
l Printed 3/10S810:49.39 AM p.g 4 og 4
Northeast Utilities ICAVP DR No. DR-MP3-0808 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element. Modification Design Discipane: Mew Dwign O v.
W, ny Type: C*W g
SystenWProcese: sWP NRC W M NA Date faxed to NU:
Date Published.1/1098 i
W
- i. Reduction in Material Strength of Impeller for 3SWP*P3A/B Dacrip#en. PDCR No. MP3-91-088 changes the material of the impeller for the Control Building A/C Booster Pumps 3SWP*P3A and B from ASTM B148-958 aluminum bronze to ASTM A744 Grade M-35 Monel. The strength of the replacement material is less than j
that of the original. The tensile strength of ASTM B148-958 aluminum bronze is 85 ksi and the tensile strength of ASTM A744 Grade M-35 Monel is 80 ksi. Yield strength is also reduced. No justification for the reduction in strength has been 4
provided in the modification package.
Review Valid invalid Needed Date initietor: Johnson, Joy G
O O
12/1sS7 VT Lead: Nei, Anthony A B
O O
12/1s/97 VT Mgr: schopfer, Don K Q
O O
i2/23/s7 1RC Chmn: Singh, Anand K O
O O
2rai/97 l
Dese:
INVAUD:
Date:
3/9/96 RESOLUTION NU has concluded that DR-MP3-0805 does not represent a discrepent condition. PDCR 91-88 was written to replace the Aluminum Bronze impellers with monel, due to s1 nificant wear 0
on the impellers. The PDCR package also contains a Certificate of Conformance from Goulds Pump, Inc. (See Attached), the original pump supplier, certifying that the replacement impellers
" are equivalent and/or interchangeable with original parts as supplied on the original pump order". Included in the Certificate cf Conformance is a certificate of analysis that indicates that the tensile strength of the new impeller is identical (85 ksi) to the i
original impellers tensile strength. An intemal NU memo from the Chemistry and Materials Department (MCE-CM-93-087 see attachod) provides justification for this material replacement by i
addressing the concems of wear, experience at Millstone Unit 2 and recommendations from technical publications. This certification from the pump manufacturer is sufficient justification for the differing material strengths.
Significance level criteria does not apply as this is not a discrepant condition.
L/-~ ";idenuhed by nut O vos @ No Non N, " Cond4Hontit) vos O No R *noneemana70 va @ No R=*mmun, d70 vos @ No Review
- -- ;'" Not " -: ;"
- Needed Date O
O O
3SS8 Printed 3/104610:50:06 All' ~ '""'"'"'"' "
Page 1 of 2
Northeast Utilitieu ICAVP DR N;. DR-MP3-0806 M1lIstone Unit 3 Discrepancy Report
. -,,. ~ ' ' '
O O
O "8
VT Mgr: M Don K O
=
MC Chmn: Singh, Anand K O
Date:
SL Comments:
l i
I 1
1 Printed 3/10S610.50:10 AM Page 2 of 2
Northeast utsties ICAVP DR No. DR MP34414 umstone unit 3
. Discrepancy Report moview Group: Syelem Dn nEsoLUT1oM ACCEPTED newtow Element: Modacellon Design D6eospane: Mechaniel Dwig" O va Diocespency Type:NW
@ No systendprocess: sWP NnC signiscenceloved: NA Date faxed to NU:
Date Putdlehed 1/2296 Deserspency: Manufacturers Report required by ASME Section lil, Paragraph ND-3649 is not identified in PDCR.
Descripelon: PDCR 3-92-042,3-92-043 and 3-92-006 are for the replacement of expansion joint assemblies 3SWP*EJ1B,3SWP*EJ1C and 3SWP*EJ1D in the discharge piping from the service water ptmps. The existing expansion joints, as shown on Drawing No.
25212-29348-20, had bellows manufactured of Monel 400 (ASTM S8127) material. The replacement expansion joints, as shown on Drawing No. 25212-29348-36, have bellows manufactured of Inconel 625 (ASTM SB-443) material.
i The P&lD, Drawing No.12179-EM-133A 26, shows that these expansion joints are installed in 30" diameter ASME Class 3 piping. Drawing No. 25212-29348-36 for the replacement expansion joints indicates that they are designed and fabricated to ASME Code,Section I!l, Class 3,1974 Edition, Winter 1974 Addenda. The design requirements for Class 3 bellows expansion joints are found in Paragraph ND-3649 of the Code.
Subsubparagraph ND-3649.4(h) requires that the Manufacturer submit a report which demonstrates compliance with ND-3649.
The Seismic Qualification Review for the referenced PDCRs does not reference or identify a Manufacturers report and it does
)
not provide any other basis forthe qualification of the bellows.
Review Vaud invoud Needed Date initissor: Johnson, Jay G
O O
12/ine7 VT Leed: Nerl, Anthony A O
O O
12/ine7 VT Mer: Schopfer, Don K O
O O
12/23 7 inc chen: Singh, Anand K O
O O
1/17/9e Dese:
INVAUD:
Dese:
3/9/96 nEsOLUTloN' NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0814, does not represent a discrepant condition.
Drawing No. 25212-29348-36 Indicates that the applicable Stone
& Webster specification is 2332.910-348. A review of this specification in GRITS shows that DCN DM3-S-0751-95 is a related change control document. This DCN contains both the vendor's C of C declaring compliance with ND-3649 and the desi0n calculation (which demonstrates compliance with ND-3649) for componer#s related to Drawin0 No. 25212-29348-36 (Flexonics Inc. Drawing D-53530, Rev.1).
- " L
_, hioMilled by NU7 Q vee @ No Non Discrepent Condelion?@ vee O No nos.hmeneenang?O v=
@ No neschmonunr=wwd70 va @ No Prarded 3/10/9810:50:37 AM Page 1 of 2
1 l
\\
Northecst Utilities ICAVP DR No. DR-MP34814 milistone unit 3 Discrepancy Report n.wi w ar h Ned F-,*
Needed Date a
O O
[
VT Leed: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
SL Comments:
l l
Printed 3/109610:50:41 AM Page 2 of 2 I
l
r Northecst UtilMies ICAVP DR No. DR-MP3-0815 usiistone unM 3 Discrepancy Report Review Group. connguration DR REs0LUTION ACCEPTED Review Element: system Design Diecipane: ElodrtcelDesign PotenthiWebMNy heue O veo Diecrepency Type: Drawing
@ No s-C _ A = HVX NRC Signinconcelevel: 4 Dese faxed to NU:
Date Published 1/10/98 F+z. ny. Drawing Discrepancies between CSLs and TSO2
==
Description:==
The following discrepancies were discovered during the review of Conduit Support Logs (CSL) and the Cable & Raceway Control Program (TSO2) for the HVX System. All drawings have been verified as current, valid design drawings with no open change documents per the Generation Records information Tracking System (GRITS):
- 1. CSL 12179-FSK-AB-2396 Revision 2A lists conduit 3CC2070M as an associated conduit, however, TSO2 does not indicate that conduit 3CC2070M attaches to support AB-2396.
- 2. TSO2 indicates that conduit 3CC2070H - attaches to support AB-2396, however, CSL 12179-FSK-AB-2396 does not show that conduit as an associated conduit.
- 3. CSL 12179-FSK-AB-3606 Revision 2E lists conduit 3CC233NU as an associated conduit, however, TSO2 does not Indicate that conduit 3CC233NU attaches to support AB-3606.
- 4. TSO2 indicates that conduit 3CC233NA attaches to support AR-3606, however, CSL 12179-FSK-AB-3606 does not show this conduit as an associated condult.
- 5. CSL 12179-FSK-AB-4266 Revision 3A lists E&DCR F-J 39025 as a qualification document for the support and its conduits, however, TSO2 does not indicate that the E&DCR is a qualification document for the support.
- 6. CSL 12179-FSK-MA-0014 Revision 48 lists conduit 3CC105PF as an associated conduit, however, TSO2 does not have a listing for th!s condult. TSO2 does indicate in the support information screen that the drawing shows conduit 3CC105PF but it is not listed in TSO2.
- 7. CSLs 12179-FSK AB-6268 Revision 1 and 12179-FSK-AB-6269 Revision 1 list conduit 3CC933PV as an associated l
conduit, however, TSO2 does not indicate that conduit 3CC933PV attaches to supports AB-6268 or AB-6269.
l l
- 8. TSO2 'ndicates that conduit 3CC133PA1 attaches to supports AB-6268 and AB-6269, however, CSLs 12179-FSK-AB-6268 and 12179-FSK-AB-6269 do no'show this conduit as an associated condult.
I
- 9. CSL 12179-FSK-AB-5716 Revision 2C lists conduit 3CX104PF5 as an associated conduit, however, TSO2 does not
="'2t0 tP' ' "^ ? ICXIC? ' 2"*
- IO '"^^^?"^E M w 2 p
um l
Northeast Utilities ICAVP M No. DR-MP34816 mmstone unit 3 Discrepancy Report noview vand invand Needed Dr'.e inmesor: senw, T. L 8
O O
12/17/S7 J
VT Lead: Nort, Anthony A
]
O 12/18/97 VT Mor: schopter, Don K O
O O
12/23/97 NtC Chmn: singh, Anand K O
O O
2/31/87 Date:
INVALID:
Date:
3/5/98 REfWLUTION: NU has concluded that Discrepancy Report, DR-MP3-0553, has j
identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter D16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meats Ibe Unit 3 deferral criteria. CR M3-98-1063 has been written to develop and track resolution of this item per RP-4.
Previeve#y identined by NU7 O Yee @) No Non Diecropont Condition?U Yes (#) No nosowonPonens70 va @ No naowonunroemed70 va @ No Review inittels: Kleic, N
~ '
VT Lead: Nori, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date:
SL Comments:
Printed 3/1o9610:51:10 AM Page 2 of 2
Nortneast Utilities ICAVP DR No. DR-MP3 0816 mmstone Unit 3 Discrepancy Report Review Group: Conngurshon DR RESOLUTION ACCEPTED Review Element: system insteNetion ru-te : I a C Desi'"
m O vee N. xy Type:InsteNetionIrnpismentation SystemProcese: Oss g
NRC W W 4 Date faxed to NU:
Date Putdished 1/10/96 W. - :i. Instrument installation Implementation
==
Description:==
During system walkdowns the following installation discrepancies were discovered These discrepancies have the potential of affecting the accuracy and performance of the associated equipment.
- 1. Electrical Instal'ation Specification E350 Rev 9, paragraph 1.10.2.1.e states that all electrical conduit connections shall be tight. Contrary to this requirement the conduit fitting at instrument 3LMS*PT935 is loose such that it can be tumed by hand.
- 2. Tubing Installation Specification SP-EE-212 Rev 1, page 2-6, paragraph 3 states "Any tubing located so that it may be stepped on by personnel shall be protected by a barrier strong enough to support at least 440lbs." Contrary to this requirement the tubing to instruments 3RSSTE38A and 3RSSTE38B is located in a high traffic area without any protection. Also, scaffolding is currently installed such that it touches the tubing which causes more traffic in the area of the tubing.
- 3. 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: l&C Technical Bulletin
- 102, Tubing Installation Specification SP-EE-212, and Piping Installation Specification SP-ME 570. Contrary to the above requirement instruments 3QSS-PT30A and SQSS-PT31 A have Teflon tape applied to their threaded connections.
- 4. Electrical Installation Specification E350 Rev 9, paragraph 1.10.2.1.b states "All equipment shall be cleaned inside and outside, with no tools, rubbish or scrap materials left on or within any part of it." Contrary to this requirement 3CES*iPNL1P and 3CES*1PNL10 contained excessive foreign metal debris inside the cabinets. One of the instruments inside 3CES*1PNL1P had a stripped piece of wire touching th3 formed edge of the insPument next to an energizco terminal.
Review Vend invand Needed Date insistor: sen r. T. L 9
O O
2<t 7/97 VT Lead: Nort, Anthony A O
O O
$2rias7 vr m r: sc% Don x 0
0 0
2/23s7 e
IRC Chmn: singh. Anand K O
O O
12tais7 Date:
INVALID:
Printed 3/105610.58:58 AM Page 1 of 3
Novewast Utsties ICAVP M No. M49W8 uttistorm Unit 3 Discrepancy Report asse:
34W98 nasocmoN: Disposition:
NU has concluded that item 2 in Discrepancy report, DR-MP3-0818, has identified a condition not nreviously discovered by NU which requires correction.
l The tubing was found to be in a location that could be stepped on. Further, there was no protection for the tubing as required.
Therefore, this is a discrepent condition. Condition report (CR)
M3-98-0498 was written to provide the necessary correction actions to resolve this issue. The Approved Correction Action Plan for CR MS-98-0498 (attached) will implement a modification to protect tie tubing associated with 3RSSTE38A and 3RSS*FE388, and any susceptible instrument tubing located between the Containment Cooling pump discharge and the Containment Coolers in accordance with Tubing installation Specification SP-EE-212. The corrections will be completed post stastup.
NU has concluded that item 4 in Discrepancy Report, DR-M3 0818, has identified a condition previously discovered by NU which requires correction. CR M3-97-2851, dated 8/29/97, identified safety to non-safety wiring separation issues in panels 2CES*lPNLCB1P and 3CES*lPNLl10 that were corrected immediately upon discovery. A walkdown of the panels found them to be in order and cleaned. There is no field work needed as a result of this item.
NU has condlued that items 1 and 3 in Discrepancy report, DR-M3-98-0816, do not represent discrepent conditions.
Item 1) The conduit fitting at instrument was observed by two separate parties. Both parties found the connections at instrument 3LMS*PT935 to be tight. No work orders or other methods were found to document the ti0htening of the connection item 3) SQSS-PT30A and SQSS-PT31A were observed by two separate parties. Grafoil tape is installed on instrument fittings.
Not work order or other method has been found to document the replacement
==
Conclusion:==
NU has concluded that item 2 in Discrepancy report, DR-MP3-0818, has identified a condition not previously discovered by NU which requires correction.
Condition report (CR) M3-98-0498 was written to provide the necessary correction actions to resolve this issue. The Approved Correction Action Plan for CR M3-98-0498 (attached) will implement a modification to protect the tubing associated with 3RSSTE38A and 3RSSTE388, and any susceptible instrument tubing located between the Containment Cooling pump a:
- u. _..a m r c ~.a
- u..,,,,~ a. ~.,. m
Northeast Utilities ICAW DR No. DR-MP3-0816 j
minstone unit 3 Discrepancy Report Tubing installation Specification SP-EE-212. The corrections will be completed post startup.
NU has corcluded that item 4 in Discrepancy Report, DR-M3 0818, has identified a condition prwsiously discovered by NU which requires correction. CR M3-97-2851, dated 8/29/97, identified safety to non-safety wiring separation issues in panels 2CES*1PNLCB1P and 3CES*lPNLl10 that were corrected immediately upon discovery. A walkdown of the panels found j
them to be in order and cleaned. There is no field work needed as a result of this item.
Previously identHied by NU7 U Yes (G) No Non Discrepent Comption?U Yes (G) No P-*% Pending?O ve.
8 No P-aian une.conv.dto v
@ No Review
^ - -, ' ' _ Not *-,
Needed Date VT Land: Neri, Anthony A j
VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K Dele:
sL Comments:
Printed 3/10/9810:50:03 AM Pope 3 of 3
No.thecst Utsties ICAVP DR No. DR-MP3-0818 Millstone Unit 3 Discrepancy Report Review Group: Syelem DR RESOLUTION ACCEPTED Review Element: system Design Diecipane: ElectricalDesign Ow Discrepincy Type: Calculation gg Systemerecess: DGX NRC Signiacence level: 4 Date Faxed to NU:
Date Putdiohed.1/1G96 F. :i: Panel Loading Discrepancies involving Calculation NL-030 Description; Calculation NL-030 (Rev.1, CCN #4)
- 1. Assumption 2 states that the calculation uses the results of Calculation NL-038 for determining the minimum voltage of the motor control centers feeding the panels, however Calculation NL 042 is now the calculation of record for minimum bus voltage and should be used for minimum bus voltages.
- 2. Assumption 2 states that the minimum motor control center volta 0e was used in determining the ampacity of the transformer primary cables, but 208 volts was used for three phase panels and 240 volts for single phase panels to determine the rating of the transformer secondary cables (and was also used in determining the individual panel loads). In order to be consistent, and since the data is readily available, the minimum panel volta 0es provided in Calculation 182E (Rev.1, CCN #1) should be used for determing the transformer secondary cables and the ampacity of the panel loads (e.g.,185 volts instead of 208 volts for the transformer secondary cables of Penel 3SCA-PNL5N, and 214 volts instead of 240 volts for the transformer secondary cables of Panels 3SCA-PNL8N and SCA-PNL9N, with a resultant voltage at the panel load devices of 106.7 volts for Panel 3SCA-PNL5N and 107.0 volts for Panels 3SCA-PNL8N and SCA-PNL9N). The use of 208 volts and 240 volts presently used by Calculation NL-030 is not conservative.
- 3. On CCN #1 Page 3, the totalload of 40 VA is computed for only 8 pressure differential switches but this circuit has 10 pressure differential switches (a total load of 50 VA).
- 4. In Appendix C, the Service Voltage for Cable 3SCABNLO35
!s shown as 480VAC for the transformer secondary. The actual Service Voltage is 208VAC.
- 5. In Appendix C, the Service Voltage for Cable 3SCABNLO31 is shown as 208VAC for the transfonner secondary. The actual Service Voltage is 240VAC.
- 6. In Appendix A, Circuits 11 and 15 of Panel 3SCA-PNL9N and Circuits 6,8,12, and 14 of Panel 3SCA-PNL5N use a diversity factor of 0.8 in computing the individual circuit load, but then a 0.8 diversity factor is applied to the total load on Panels 3SCA-PNL9N and 3SCA-PNL5N. Assumption 1 only states that a diversity factor is applied to the total panel load. It seems that the diversity factor was applied once too often for these loads and should not have been applied to the individual circuit load.
Printed 3/1041610:50:36 AM Page 1 of 2 i
Northeast Utilities ICAVP DR No. DR MP3 4818 milistone unit a Discrepancy Report
- 7. In Appendix A, the unit heaters of Panel 3SCA-PNL5N assume a power factor of 0.6, resulting in a circuit load of 414 VA. Unit heaters of the same rating (some even from the same specification) are shown in Circuits 11 and 12 of Panel 3SCA-PNL8N and Circuit 9 of Panel 3SCA-PNL9N but are shown w'th a load of 246 VA. These should all have the same load (i.e.,414 VA).
Review vend invand heeded Dete inattator: Kenden, D. J.
O O
O 2/iss7 VT Leed: Nort, Anthony A O
O O
12ftiw7 VT Mgr: Schopfer, Don K G
O O
2r23s7 sec chmn: singh, Anand K B
O O
$2tatie7 Dese:
IrfVALID:
Dese:
2/9/98 REsOLLrnoN Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0818, 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 M3-98-0515 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0818, has identified a condition not previously discovered by NU which requires conectiori. 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 critruria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.
Prwiously identised by NU7 O Yes (S) No Non Discrepent Condition 70 Yes @) No nes kmonPenene70 Y=
@ No nee nman unr=*ed70 Y=
@ No neview Irltletor: Kondel, D. J.
vT Lead: Nort, Anthony A B
O O
=
vr Mer: schoper, Don K IRC Chmn: Singh, Anand K Dele:
SL Comments:
Printed 3/109610:50:40 AM Page 2 of 2 i
I Northeast Utilities ICAVP DR No. DR MP3-0819 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUT1oN ACCEPTED Review Element: System Design Discipline: Electrical Design Om h
- y Type: NW g
s,_._. =: Dox
)
NRC SignMcence level: 4 Date faxed to NU:
Date Publiehod.1/1048 j
Discrepancy: Discrepancies involving Calculation 160E Description Calculation 160E (Rev. -)
- 1. On Pa0es 6 and 7, the snowable heat generated by the triplex 350 MCM cable should read 21,594 watts and not 25,194 watts.
- 2. On Page 6, the maximum design load for Motor Control Center 3EHS*MCC181 is identified as 380.75 amps. This exceeds the maximum allowable value of 211 amps shown in j
Calculation 129E (CCN #3, Rev. 0) Table 3 on Pa0e 8.
- 3. References are made to calculations which have been superseded (e.0.,93E,116E,146E). References should be made to calculations which are still active and valid (i.?
updated).
Review valid Invend Needed Date Inllistor: Kendell, D. J.
6 O
O 2iiaS7 VT Leed: Nat, Ardhony A O
O O
12/18/97 VT Mgr: Schopfer, Don K B
O O
12/23s 7 NtC Chmn: Singh, Anend K G
O O
12r31/or Date:
INVALID:
Dele:
3/5/98 RESOLUTION: Disposition:
NU has concluded that item 3 of Discrepancy Report, DR-MP3-0358, has identified a condition not previously discovered by NU which requires correction.
Condition Report (CR) M3-98-0182 was written to provide the i
necessary corrective actions to resolve the calculation i
discrepancies. The appmved Co:Tective Action Plan (CAP) for M3-96-0182 is attached.
I item (3) Calculation 160E, uses superseded calculations. The calculation was completed at the time the inputs were active and i
today are historical. An Engineering Report M3-ERP-97-0002 l
" Assessment of Critical Calculation MP3 Electrical Distribution System" in support of the MP310CFR50.54(f) effort was completed March 21,1997. Condition Report (CR) M3-97-1217 was written to track the recommendations of the Engineering Report M3-ERP-97-0002. Item 3 of the approved Corrective Action Plan (CAP) setup a tracking number in the Action l'.em Printed 3/10S811:00:33 AM Page 1 of 3
4 Northecst Utilities ICAVP DR No. DR-MP3 4819 Millstone Unit 3 Discrepancy Report Tracking and Trending System (AITTS) as A/R 97009922-03 for consolidating and voiding calculations. The item is scheduled for completion post startup. NU considers this item to be si0nificance level 4.
NU has concluded that items 1 and 2 of Discrepancy Report, DR-MP3-0819, do not represent discrepant conditions.
Item (1) The allowable heat (watts) generated for triplexed 350MCM Aluminum cable was calculated but the value was incorrectly written down as 25194 vs 21594. The error was noted in an interoffice memo dated 3/5/85 posted in the calculation file which is attached, item (2) The load amps associeted the Motor Control Center (MCC) feeder cable which user the triplexed 350MCM Aluminum cable was originally calculated to be 381 amps using calculation 93E as inpd. Calculation 93E was e.aperseded by calculation 129E which reevaluated the ampacity to be 154kVA (185A @
480V). The MCC loading is evaluated in calculation NL-025 which uses 129E as ir put, the cable loading is within this limit.
==
Conclusion:==
NU has concluded that item 3 of Discrepancy Report, DR-MP3-0358, has identified a condition not previously discovered by NU which requires correction.
Calculation 160E is historical and is being consolidated with other calculations as result of the Engineering Report
" Assessment of Critical Calculation MP3 Electrical Distribution System"in support of the MP310CFR50.54(f). NU considers this item to be significance level 4. The item is scheduled for completion post startup.
NU has concluded that items 1 and 2 of Discrepancy Report, DR-MP3-0819, do not represent discrepant conditions.
The item 1 errors identified by S&L have been found and corrected. Item 2 MCC cable loading is within the limits and is evaluated in calculation NL-025 that uses 129E as input.
Previousey idenoned by NU7 O Yes (#) No NonD6ecrepentCondition?O Yes (#) No no.euonreamas70 Ya @ No p%unreemed70 Yes @ No novi Inittstor: KendeR,D.J.
VT Lead: Neri. Anthony A VT Mgr: Schepfer, Don K NtC Chmn: Singh, Anand K Dele:
3/5/98 sL comments: item 1 - Based on the interoffice memorandum dated 3/5/85 which NU provided with their response to this discrepancy report, and in light of the fact that NU states that they will consolidate this 1
Printed 3/10461120:36 AM Page 2 or 3
Northeast Utilities ICAVP DR No. DR-MP34819 Millstone Unit 3 Discrepancy Report calculation as a result of the Engineering Report " Assessment of Critical Calculation MP3 Electrical Distribution System", Sargent
& Lundy concurs that this is not a discrepant condition.
Item 2 - Based on the clarifications provided by NU in their response to this discrepancy report, Sargern & Lundy concurs that this is not a discrepant condition.
Item 3 - NU has concluded that this item is a discrepancy and will be tracked for resolution by CR M3-97-1217.
This discrepancy report is reclassified as a Level 4 discrepancy because item 1 is now non-discrepant.
^
Printeo,Y109211:00:38 AM Page 3 of 3 l
Northeast Utilities ICAVP DR No. DR-MP3 0981 Millstone Unit 3 Discrepancy Report Reelow Group: Accident Mitigation DR RESOLUTION ACCEPTED Review' Element: Change Proces.
Diw:ipane: I a c Desi'"
O vee R, a Type: Lloensing Document g
SystemPre.ees: N/A NRC Signiacencelavel: NA Date faxed to NU:
Date Publista :r25/9e n. ~ :i: SGTR EOP instruments Need to be Reg. Guide 1.97 Type A Description.
References:
EOP 35 E-3, " Steam Generator Tube Rupture", Rev.13 Effective 10/3/95 MP3 Reg. Guide 1.97, Rev. 2 Basis Document MP3 FSAR Chapter 7.5 The ICAVP has reviewed the reference EOP as part of the ver.fication of plant characteristics important to ensure that safety analysis assumptions are appropriately implemented and maintained in accordance with the MP3 FSAR Chapter 15 accident analysis. As part of this verification the ICAVP reviewed the instrumentation necessary to ensure that the cooldown necessary to reduce the RCS pressure and minimize i
the release is initiated and appropriate for the actions as described in *he EOPs. It is noted that the entry criteria for the E-
)
3 EOP is based on the operatoft review of the radiological l
conditions using the steam line radiation, condenser air ejector radiation or steam generator blowdown r.11ation monitors.
Given the importance of this diagnosis to the initiation of the cooldown actions necessary to mitigate a steam generator tube rupture in accordance with the applicable safety analysis for the plant, the ICAVP would have expected these monitors to be Reg.
Guide 1.97 Type A variables. A review of the MP3 Reg. Guide 1.97 compliance analysis and FSAR indicates that they are desi0nated for monitoring only as Type E variables. This issue is of importance due the original comDilance with Reg. Guide 1.97 and the recent emphasis of diagnosis and response to steam generator tube rupture events to prevent overfill.
NU should address which, if any, of the identified Reg. Guide 1.97 Type A, Category 1 instruments has been designed to monitor this condition.
Review Yelid invalid Needed Date initiator: Bennett, L A.
8 O
O tr2iise VT taed: Reheja. Rei D 8
O O
tr2iise VT Mgr: Schoper, Don K B
O O
ir22/se iRc cwnr singn. Anand K B
D O
r22/se Date:
I INVALID:
Date:
3/6/98
,tESOLUTION Disposition:
Printed 3/109811:01:17 AM Page 1 of 3
9 Northecst utmtie.
ICAVP DR No. DR-MP3-0981 milistone unit 3 Discrepancy Report i
NU has concluded that the issue reported in Discrepancy Report, l
DR-MP3-0981, does not represent a discrepant condition.
Regulatory Guide 1.97 Revision 2 Mnes Type A variables as:
" Type A, those that provide primary information needed to permit j
the control room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety function for design basis accident events." E-0 procedures that lead into E-3 do not require the operator to take any manually controlled action with information from the trend history and alarm status of radiation monitors (Main steam hne, Condenser air ejector and SG blowdown). There are no manual actions credited in the pl&nts accident analysis or in the EOPs for these radiation instruments. These radiation monitors provide diagnostic information for the operator and is not the only path that leads to E-3. All three of these monitors could be off line and the operator still must be able to detect a tube rupture.
Therefore, these variables do not follow the strict definition of Regulatory Guide 1.97 Type A variables.
In EOP 35 E-3 (Page 33) Pressurizer Level and Narrow Range Steem Generator Level indication is used to perform specified manual actions to minimize RCS-To-Secondary leakage. Both Presurrizer Level and Narrow Ran0e Steam Generator Level are Type A and designed to Category 1 criteria.
In addition, other instruments which are used in EOP 35 E-3 which are RG 1.97 Type A, QA Category 1 include:
Wide Range Steam generator Level Core Exit Temperature Containment Pressure Containment High Radiation Monitors RWST Level Significance Level criteria do not apply here as this is not a discrepent condition.
==
Conclusion:==
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0981, does not represent a discrepant condition.
4 Main steam line, Condenser air ejector and SG blowdown i
radiation monitor verlables do not sollow the strict definition of Regulatory Guide 1.97 Type A variab!es. The NU EOP uses Pressurizer Level and Narrow Range Steam Generator Level j
indication to perform specified manua! actions to minimize RCS-To-Secondary leakage and steam generator overfill.
Significance Level criteria do not apply here as this is not a discrepent condition.
Previously idendaed try Nu? O vos (#) No NonDiscnpentConstion?(#) Yao O No ResolutionPending?O vos @ No nosoiutk.s eenived?O vos @ No i
W Printed 3n046110120 AM Page 2or 3
NorthIst Utilities ICAVP DR No. DR MP3-0981 j
Millstone Unit 3 Discrepancy Report initietor: Johnson, W. J.
VT Leed: Reheja, Raj O VT Mgr: Schopfer, Don K RC Chmn: Singh, Anand K Date:
SL Comments:
Printed $10961121:22 AM Page 3 of 3
Northeast Utilites ICAVP DR No. DR-MP3-0139 Mi'Istorm Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REXCTED i
Review Element: System Design Diecipline: Piping Design I'*"*
C' :, niType: Calculation S,^
_ J.-==:SWP g
j i
NRC W W 3 Date faxed to NU:
Date Putdiohed. 9/19/97
. :i: Effect of fluid transient induced header movements on branch piping not considered Deecription* In the process of reviewing the following documents, (O FSAR Section 3.98.1.4.1 Loading Conditions (10 FSAR Table 3.98-11 Load Combinations for ASME Class 2 and 3 Piping (li0 Pipe Stress Analysis Criteria Document, NETM-44, Revision 2
we noted the following discrepancy;
Background:
According to (0: The structural st. - : analysis performed for Seismic Category I ASME Code Lass 1,2, and 3 piping consider the loading and load combinations specified in Table 3.98-11 (10 According to (10: The normal / upset, emerDency, and faulted plant operating conditions, NC Equation's 9, include the loads resulting from occasional loads other than seismic. Examples of these loads i be: water hammer, steam hammer etc.
The same in t ) is repeated in the pipe stress criteria ii document (iii) as Table 4-6.
Table 3.9B-11 (10 makes no distinction between inertia loads and loads resulting from anchor movements experienced by branch piping attached to a header subjected to non-seismic occasional loads such as water hammer.
Discrepancy:
Header anchor movements resulting from fluid transient loads have not been considered in the stress analysis of decoupled large bore branch piping, small bore piping, and instrument tubing.
'M jer anchor accelerations resulting from f;uld transient loads have not been considered in the stress analysis of vents and drains.
Review Valid invalid Needed Date initietc. Prokesh, A.
Q Q
9/4/97 Printed 3/109611:17:30 AM Page 1 of 3
^
Northeast Utsties ICAVP DR No. DR-MP3-0139 umstone Unit 3 Discrepancy Report VT Lead: Nort, Arthony A B
O O
- 1057 VT Mer: schopfer, Den K O
O O
ar12ro7 Ntc Chan: singh, Anand K
-E O
O S/1357 i
Date:
I anrauo:
Dese:
3/3/98 nesottmoN: Response ID: MS-lRF-01765 Disposition:
NU has concluded that Discrepancy Report DR-MP3-0139 does not represent a discrepent condition Although no specific calculation is noted in the DR, header movements resulting from fluid transient loads generally have been considered in the qualification of branch piping (including vents and drains) by combining these movements with other anchor displacements such as seismic and thermal.
The accelerations caused by fluid transients are reviewed by the stress analyst for vent and drain line qualification. Tht;;.e acceleration values are combined with seismic accelerations and should be considered as primary loads in the calculations.
Significance level does not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0139 does not represent a discrepent condition Although no specific calculation is noted in the DR, header movements resulting from fluid transient loads have been considered in the qualification of branch piping (including vents and drains) by combining these movements with other arx, hor displacements such as seismic and thermal and considering as primary loads in the calculations. Significance level does not apply as this is not a discrepent condition.
Attachments:
None Previousey idenmand by NU? U Yes @ No NonDescrepentConstion?Q Yes @ No
- p.amagtO v.
@ No nos.hmonune.emedtO v=
@ No noview We Not Wh Needed Date m
g VT Lead: Nort, Anthony A VT Mgr:, Schapter, Don K WIC Chmn: Singh, Anand K O
O O
=
Dese:
3/3/98 sL comments: Header movements resulting from fluid transient loads have cenerally not been considered in the qualification of branch Printed 3/10S811:17:34 AM Page 2 of 3
e; Northe:st Utilities ICAVP DR No. DR-MP3 0139 Millstone Unit 3 Discrepancy Report piping, particularly for vents and drains. Specific calculations where the discrepency is roted are (run pipe calculations are noted in brackets):
Vent and Drains:
NP(F)-RSS-20-V32 [NP(F)-X7923]
NP(F)-QSS-3 V56
[NP(F).X7926]
NP(F)-RSS-19-V58 [NP(F)-X7923]
NP(F)-QSS-2-V940 [NP(F)-X7926]
NP(F)-OSS-2-V951 [NP(F)-X7926]
NP(F)-QSS-2-V934 [NP(F)-X7926]
Small Bore Unes:
NP(B)-X961hD
[NP(F)-X7901,2,3,4,5,8]
NP(B)-X10033XD
[NP(F)-X53901]
l 4
Printed 3/1Q9811:17:35 AM i
~s 3 of 3
4 Northeast UtilRies ICAVP DR No. DR MP3-0267 j
Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION REJECTED Review Element: system Design O va j
r"--
, :p Type: N'W g
systemlProcese: N/A NRC signiacena imi: 3 Dole Faxed to Nu:
Date Putdished: 10f1047
. ~~y: Design Criteria Discrepancy
==
Description:==
Criteria Document no. NETM-45,Rev.1,tdiedFPipe Support Design Criterla*does not address the impact of thermal stresses on the pipe support auxiliary steel.
Thermal growth is significant in all cases where support
)
configuration includes auxiliary steel with rigid support points at 1
both ends that preclude movement and relaxation of thermal I
stresses.
Vand invalid Needed Date inenador: IGoic, N O
O O
erias7 I
VT Leed: Nort, Anthony A B
O O
er23s7 VT begr: Schapter, Don K B
O O
8/30/87 i
5tC Chmn: Singh, Anand K.
O O
O tor 2ier Dese:
MVAUD:
Date:
3/2/g8 RESOLUTION. NU has concluded that DR-MP3-0267 does not represent a discrepant condition. Thermal expansion of support members is not addressed in the design criteria and is not considered to be within the licensing / design basis for Milir/.one Unit 3. This is appropriate since pipe support frames are typically free to expand thermally such that intemal stresses and resultant connection loads are minimal. Piping supports do not typically span large distances between concrete structures which would respond more slowly to ambient temperature chanpes.
Therefore, pipe supports are generally not susceptibl3 to constrained thermal expansion which would potentially result in significant intemal thermal stresses. Significance level criteria does not apply as this is not a discrepant condition.
_ _., identHied by NU? O Yes (9) No Non Discrepent Condition?U Yes (9) No R-%PenanetO va @ No p-%unresoevedtO va @ No Review Inllister: 10eic, N VT Lead: Neri, Anthony A VT Mgr: schapter, Don K IRC Chmn: singh, Anand K Date:
3/2/98 st Conenents: S & L cannot accept the statement that pipe support frames are
" typically free to expand thermally such that intemal stresses and the resultant connection loads are minimal".
Review of the support configurations identified several cases with Printed 3/109611:18.05 AM Page 1 or 2
Northeast Utilitle3 ICAVP DR No. DR-MP3-0287 Ministene Unit 3 Discrepancy Report rigid welded connections en both ends of the auxiliary steel members. This type of the configuration does not allow for the expansion due to thermal effects and will result in accumulation of high stresses in some instances. Therefore, the design criteria should either address this issue generically or support design should include provisions for the slotted hole type bolted connection at least at one end of the auxiliary member spanning between two fixed (rigid) structures to allow for the movement and release of thermal stresses Printed 3/10/9811:16.08 AM Page 2 of 2 l
4 Norniekst utsties ICAVP DR N3. DR MP34468 Ministone Unit 3 Discrepancy Report Review Group: system DR ftEaOLUTION REJECTED Review moment: system Design Diecipane: Electriced Design.
Om D6screpnicy Type: Component Date gg systenWprocess: RsS
. NRC signiacanoelevel: 4 Date faxed to Nu:
Date puullehod.11/2/s7 Descrapency: Calculation Discrepancies involving RSS Non-Reversing Motors Descripson: 1. For motors 3RSSP1 A,3RSS*P18,3RSSP10, and 3RSS*P1D, the locked rotor current in Calculation GM 03.409CA (Rev.1) is based on KVA Code Letter "F". This code letter disagrees with the KVA Code Letter "D* shown on Page 5-14 of Specification 2214.802-044 (Rev.1), however since the calculation's value is greater than the specification's, the results of Calculation GM40-03.409CA are still valid.
- 2. For motors 3RSSP1 A,3RSS*P1B,3RSSP1C, and 3RSS*P1D, the vendor motor curve 2214.802-044-023A shows an acceleration of 3.2 seconds for 70% of rated voltage. This agrees with Specification 2214.802-044 (Rev.1). Calculation GM40-03.409CA (Rev.1) shows an acceleration of 3.2 seconds for 80% of rated volbge, therefore the acceleration is at a different voltage The documentation should be revised to reflect the voltage associated with a 3.2 second acceleration (if Su% is the appropriate minimal volta 08, then the " minimum acceptable voltage" of 70% of nameplate voltage listed in Calculation NL-038 Pa0e 13 needs to be revised). Either voltage is technically acceptable as the minimum voltage because the minimum voltage at 3RSS* P1 A,3RSSP1B,3RSS*P1C, or 3RSSP1D is 3382 volts (reference Calculation NL-038, Rev. 2, l
CCN 6, Mode 7 Run 609) which is 85% of rated voltage.
]
- 3. Calculation SP-M3-EE-342 (Rev.1) states as an assumption that, 'where B.H.P., officiency, power factor and rated voltage values are not available from the project documentation"
- (Appendix B, Page B2), brake horsepower (BHP) is equal to the nameplate tsr=g-r;;r, efficiency is 0.92, and the power factor is 0.88 for 460V motors. However, for the 460V motors 3RSS-P2A and 3RSS-P28, the project documentation is available for this data but was not used in the calculation. The data for these
' motors is 7.3 BHP normal / 9.15 BHP maximum, a power fador of 0.87, and an efficiency of 0.84 (reference Specification 2225.202-050 Add. 6 Page 2-47 and PDDS). Since the actual I
brake horsepower is less than that assumed in the calculation, the results of Calculation SP-MS-EE-342 are conservative.
I However, since the actual brake horsepower is known, either it j
should be used or the statement from SP-MS-EE 342 should be i
revised.
I Review l
i Vaud InveNd Needed Date inittster: Kandel.D.J.
G O
O 1oria/s7 VT Laod: Nort, Anthony A G
O O
10/27/s7 i
VT Mgr: schopfer, Don K O
O O
or2ees7 IRC Chen: singh, Anand K B
O O
ior30'S7 Primed 3/1ofBs 11:18.43 AM Page 1 of 2
Northeast Utilities ICAVP DR No. DR-MP3.%68 millstone Unit 3 Discrepancy Report
- _ _ =
eNAilo:
}
9ese:
3/4/98 i
nEsoLUTioN: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0468, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified 1
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 M3-97-4065 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0468, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-97-4065 has been written to develop and track resolution of this item per RP-4.
Previously identiaed by nut U vos (S) No NonD6ecrepentconstion?U vu (S) No noe uionP. nano 70 va @ No neemison un,eem.d70 y=
@ No
^
movi Fr.
Not # -/ ^
Needed Date VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Shgh, Anand K Date:
3/4/98 i
st. comments: ltem 3 of Discrepancy Report DR MP3-0468 is not addressed in either NU's response to this DR or in CR M3-97-4065 which was written to track resolution of this DR (CR M3-97-4065 only addresses items 1 and 2 of DR-MP3-4068).
Printed 3/1o/9611:18A6 AM Papa 2 of 2
4 Nohst UtilRies ICAVP DR No. DR-MP3-0553 Ministone Unit 3 Discrepancy Report Review Group: ConAguration DR RESOLUTION REJECTED Review Element: system Design rumt%e: Electrical Desi'"
Om 04
- iType: Drawing gg systewProcese: RSS NRC SigniScnncelevel: 4 Date Faxed to NU:
Date Putsisched.11/9/97 FM.
- i. Design Documents not in greement
==
Description:==
- 1. A 1-inch diameter conduit for lighting is attached to south verticalleg of tray support G109-013. This attachment is not shown on the detail drawing EE-34JF, Rev.3. No referenced open change control documents for this drawing address this item.
- 2. Configuration of cable trays routed N-S as seen in Sections 2-
't 2,20-20,21-21 and 22-22 on drawings EE-34R Rev.10, EE-34S Rev.11 and F-E-14937 cannot be resolved in field. The F-E shows eight trays; EE-34R shows seven trays. There are seven trays installed, but configuration does not match any reviewed document.
- 3. Drawing EE-34AU Rev. 6, incorrectly identifies trays. Cable Tray 3TC774P is not clearly located on this drawing. It should be located at coord! nates B-7 and shown in Section 4 but a "P-L" tray is shown instead.
- 4. Drawing EE-34AM Rev. 5 does not correctly depict cable tray locations. The "X" cable tray is incorrectly shown routing north and east past Col. Line 49.4 while the K" cable tray is incorrectly shown stopping at Col. Line 49.4. The correct cable tray plan is as shown on drawing EE-34EN.
- 5. Cable tray 3TC7570 was extended east along Col.'Line 49.4 by F-E-14714. The tray identification drawing EE-34BB Rev.11, for "O-C2" trays was not corrected to show this change when Rev. 9 was performed incorporating the F-E.
- 6. Conduit Plan drawing EE-558, Rev. 8 shows flow transmitter 3RSS*FT38A as non-safety related (drawings has FT erroneously identified as 3RSS-FT38A).
- 7. Conduits 3CC704PA3,3CC763PA2 and PB7 are 1%" flexible conduits of approximately 4 feet long running between Junction box 3JB'7515 and valve 3RSS*MV88388. The Cable and Raceway Program indicates that these conduits are rigid.
- 8. The Cable and Raceway Program (TSO2) indicates that conduit 3CC763PC7 is supported by three supports. This 5-feet long conduit was observed to have only one support.
- 9. Conduit Support Log 1217te-FSK-ES-0442, Rev. 2A shows conduit 3CK760NA in Section 1 of view looking west but does not appear in plan view. This causes the number of conduits e
the
- /:20 cf 50 00= -"--^.10 b^ d"= pt P
um d2
I Northeast Utilities ICAVP DR No. DR-MP3-0563 1
miitatone unit 3 Discrepancy Report
- 10. Conduit Support Log 12179-FSK-ES-5129, Rev. 2, lists conduit 3CC764PB1 and this conduit was observed in the field installed on this support. The Cable and Raceway Program (TSO2) does not list this conduit as supported by this support.
- 11. Conduit Support Log 12179-FSK-ES-1082, Rev.1, lists conduit 3CX970PB1 and this conduit was observed in the field installed on this support. The Cable and Raceway Program (TSO2) does not list this conduit as supported by this support.
- 12. Conduit Support Log 12179-FSK-ES-1530, Rev.1 A, lists conduit 3CK765PF5 as supported on this support. The Cable and Raceway Program (TSO2) does not list tnis conduit as supported by this support.
- 13. Conduit Support Log 12179-FSK-ES-439 Rev. 3A lists conduit 3CK758PF as supported on this support. The Cable and Raceway Program (TSO2) does not list this conduit as supported by this support. TSO2 lists conduit 3CK758NA as supported by this support, however, the CSL does not include this conduit.
Review Vehd inveNd Needed Date inauetor: senw, T. L B
O O
10/2eror VTLead: Neri, Anthony A B
D O
io/2eis7 VT Mgr: schopfer, Don K B
D D
1or3SS7 IRC Chmn: singh. Anand K Q
Q Q
11/497 Dese:
INVALID:
Dele:
3/5/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0553, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-1063 has been written to develop and track resolution of this item per RP-4.
W.A :", identleed try NU7 O Yes (9) No Non Discrepent Condition?O Yes (G) No PM% PendingrO vee Co) No P-a-n unreseeved70 vos @ No Review initiator: Mis 6c, N VT Leed: Neri, Anthony A VT negr: schopfer, Don K IRc caenn: singh, Anand K Date:
3/5/98 sL comments: Adequacy of tray supports needs to be verified for the additional loads (ltems 1 & 8 ) and configuration changes (Item 2 ).
Prinled 3/1o9611:18:17 AM Pope 2 of 2
i Northeast Utmties ICAVP DR No. DR-MP3-1062 Mastone unit 3 Discrepancy Repoft Review Group: Operssons & Maintenance and Testing DR BlvAUD Review Elesnont MoaAcellon Design Discipene; Mechenlosl Design g"
Discrepency Type: Design control Procedure O No systenWProcese: DGX W Wlowl 3 Date faxed to Nu:
Date Published: 3/12/96 Diserepancy: Inadequacies of Safety Evaluation for Modification MP3-91-132
==
Description:==
- lRC Comments (marked up) was givem to Tony Nerl*""
Modification MP3-91-132 (MOD) was reviewed and approved by NU on 8/13/91. The PDCR package was completed and submitted to Nuclear Records on 8/14/92. The basis for the modification was that inlet screens would be fabricated and installed on the inlet tubesheets of 3EGS*E1 A and 1B heat exchangers The screens will function to strain out mussel shells and other debris which can damage the tubesheets and tubes of the heat exchangets
" Structural failure of the screens such as screen / frame weld failure" was considered in the Safety Evaluation per NEO 3.12 j
but only to the extent that it would "... result in an increase in fouling of the heat exchanger.' The safety analysis should have considered that the increase in fouling due to screen / frame weld failure could result in the complete blockage of the heat exchanger. This blockage would cause the EDG to operate in a degraded mode.
Because of the above, S&L feels that the answer to Question 3,
" Determine if the change, or a failure mode associated with the change, increases the probability of an accident to the point where it should be considered within the design basis.", on page 7.2-6 of ACP-QA-3.06, Rev 5, should be "Yes' On page 7.2 7, it is felt that the answer to impact on protective boundaries should be "Yes".
The above items appear to constitute an Unreviewed Safety Question (USQ).
The following relates to Pages 26 and 27 of ACP-QA-4.03B, Rev. 4, of the MOD Package.
- 1. Part 11 is not completely filled out as it does not identify the parent component safety function (s) j
- 2. Part lil does not require a "Yes or No" answer, but a ' narrative' j
response. Therefore, Part V is invalid.
- 3. Part IV should have a "Yes' response based on the above, therefore the screen should be Safety Related per Part V.
If NU's review of the above shows that an USQ exists, then all modifications that installed screens in heat exchangers would need to be reviewed and appropriate actions taken.
Based on Parts ll1 and V, on Pages 26 and 27 of ACP-QA-4.03B, Rev. 4, there could have been confusion in the evaluation i
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4 Northe:st Utilities ICAVP DR No. DR-MP3-1062 ministone uaM 3 Discrepancy Report or not S&L feels that ALL Modifkations that used any revision of ACP-QA-4.038 that had similar, confusing statements as Rev.
4 above, need to be reviewed. This review is needed to determine if Safety Related parts ware used and if not, should they have been.
From the available information, the ICAVP Team could not determine if the MOD deeign of the Hast Exchanger Screens would result in both EDG's being inoperable.' Thus, a NRC Significance Level of 3 is assigned. However, based on NU's response, the DR's NRC Significance Level could escalate.
Review Vend invend Needed Date initiator: spear, R.
O-0 O
asse VT Leed: Bees, Ken O
O O
mee VT Mgr: schopfer, Don K O
O O
1RC Clenn: singh, Anand K O
O O
Date:
3/5/98 INVALID: Additional review and evaluation of intemal Review Committee (IRC) comments has determined that this is not a discrepent condition.
NU has completed two Component Part Safety Classification determinations. The first was performed as part of the modification. The second evaluation (EVAL-CD 1429-015) was completed as part of the Material, Equipment and Parts Lists (MEPL) Program. Both of these evaluations detemiined that the screen assembly is "Non-QA or not QA Category 1" i.e. note-safety related. This is consistent with the modification safety evaluation.
Further review has determined that the system with the screen installed is more reliable than without the screen and that adequate surveillances and instrumentation exists to detect si0nificant foulin0 or screen blockage. It was determined that the modification safety evaluation adequately identified and addressed all potential failure scenarios Dele:
RESOLUTION.
N,- -?;iderdthed by NU7 O voo (9.1 No NonDiscrepentCondition?O vee (9) No PM%Pending?O vee @ N.
~ % untee m.d? O ves @m Review AccepteMe Not We Needed Date g,
VT Leed: Bees, Ken VT Mgr: Schopfer, Don K IRC Clenn: dingh. Anand K O
O O
Date:
sL Commente:
Printed 3/10ee 11:20:44 AM Page 2 r4 2
1 o
Northeast Utsties ICAVP DR No. DR-MP3-1079 umstone Unit 3 Discrepancy Report Reviewereup* Programmeuc DR BWAUD Review Element: correceve Acton Procese Dieulpene: MechanicalDesign Ow Descrepeney Type: cerroceve Acman implementemon g,
ayeesmmooses: HVX NRc SignlAconce M 3 Date faxed to NU:
Date Putdiohed. 3/12/98 Dioceepancy. ACR MS-96-0900 Corrective Action implementation Descelpelon: The approved corrective action for ACR MS-96-0900 established the required overhaul date for the ITT actuatom on the emergency generator enclosure ventilation system dampers. The
)
required completion date for the next actuator overhaul do not a9 tee with the dates shown in the approved corrective action for ACR M3-96-0900 as noted below:
- 1. AWO MS 97-04575 has a required completion date of 10/30/1996 for 3HVP* MOD 20A. ACR has a required date of 9/1997.
- 2. AWO MS 97-04583 has a required completion date of 08/31/2002 for 3HVP* MOD 208. ACR has a required date of 7/2000
- 3. AWO M3-97-04579 has a required completion date of 08/31/2001 for 3HVP* MOD 20C. ACR has a required date of 7/2000
- 4. AWO MS-97-04581 has a required templetion date of 07/26/2002 for 3HVP* MOD 20D. ACR has a required date of 6/2001,
- 5. AWO M3-97-04560 has a required completion date of 08/31/2001 for 3HVP* MOD 23A. ACR has a required date of 6/2000
- 6. AWO MS-97-04573 has a required completion date of 09/24/1999 for 3HVP* MOD 238. ACR has a required date of 7/1998.
- 7. AWO MS-97-04584 has a required completion dAe c' 07/31/2003 for 3HVP* MOD 26A. ACR has a r., quired date of i
6/2002.
- 8. AWO M3-97-04574 has a required completion date of 08/31/1998 for 3HVP* MOD 268. ACR has a required date of 7/1997.
Failure of the damper actuators to function could result in the minimum room design temperature being exceeded during the winter. Operator action would be tsquired to manually cycle the supply fans on and off to maintain the enclosure temperature within the minimum and maximum design temperatures.
Review i
Valid inveNd Needed Dele maun
- m Printed 3/1o961121:10 AM Page 1 or 2
I Northeast utilities ICAVP DR No. DR-MP3-1079 millstone Unit 3 Discrepancy Report hdeator: Stut,M.D.
O O
O 3sse VT Leed: Rpn, Thomas J O
O O
3*S8 VT Mgr: Schopfer, Don K O
O O
i IRC Chmn: Singh, Anand K O
O O
I Dele:
3/9/98 INVALID: This issue is outside the scope of the ICAVP. ACR M3-96-0900 I
is not a Configuration Management related item. It is an l
equipment malfunction issue related to normal plant operations I
and maintenance, and is not required to be closed prior to plant
{
restart. The schedule for damper actuator overtiauls is not a l
configuration management issue.
=
Date:
RESOLUTION n./:r'y iden# Red by Nu? O Yes (#) No Non F-
,. Condition?U Yes (#) No
(
ResolutionPending?O Y
@ No Re iuison unt.e sv.d?O Yes @ No Rosw
" - -, ' - "_ Not A- -
Needed Date
{
O O
8 J
VTLead: Ryan, Thomme J VT Liga Schopfer, Don K I
1RC Chne: Singh, Anand K Dele:
SL Comments:
Printed 3/10/9611:21:14 AM Page 2 of 2
T Northeast Utilities ICAVP DR No. DR-MP3-1072 umstone unit 3 Discrepancy Report Review oroup: system DRvAuo Review Element: Corredhe Action Pmeses Diecipline* Mechanical Design Discrepancy Type: Corrective Action implementetion e No SystenWProcess: SWP NRC Significence level: 3 Date faxed to NU-osse Puuished. 3/12/98 r. mW ACR M3-96-0653 Corrective Action inconsistent with Corrective Action Plan DescrtPtion: ACR M3-96-0653 identified the potential for the Chlorine Pit Access Enclosure to flood and submerDe both the SWP Train A and B isolation valves to CW Pump Lube Water
[3SWP*MOV115A/B] without operator knowledge, since the only indication of flooding in the area is via level switch 3SWP-LS153 which is non safety related. The ACR also indicated that the room is only infrequently accessed. The recommended action included placing the area on rounds, performing surveillance on the level switch, and/or upgrading the switch [to safety related).
The possibility was also raised of performing analyses to demonstrate that SWP could function satisfactorily without isolating the lube water to the CW Pumps.
The Corrective Action Plan indicated that " preliminary evaluations have determined that a moderate energy line break of the 30" SWP lines in the access enclosure would flood the isolation valves in less than 30 minutes" and that "if 3SWP*MOV115A/B were disabled due to flooding, sufficient service water flow to vital loads during design basis conditions would still be available."
The Corrective Action Plan called for the following activities as a result:
- 1. Formally update the service water analysis to demonstrate that sufficient service water is available to vital loads during design basis conditions with flow to the CW pumps not isolated, and
Section 7 of the Corrective Action Plan further states:
"The criteria employed by MP3 flood studies is the availability of 30 minutes of operator time, following detection by a safety related instrument, to isolate the leak before affecting safety 1
related equipment. Revising the service water flow analysis to demonstrate isolating service water flow to the circ water pumps during design basis conditions is not required will remove the active safety function of 3SWP*MOV115A/B."
All of the above are tracked under Tracking Assignmment #
96029368-02.
In llan nf the entrac[jum nedinne timerihad nhnum n CR channa Printed 3/10481121:50 AM Pape"1 of 3
l Northe:st Utilities ICAVP DR No. DR-MP3-1072 Millstone Unit 3 Discrepancy Report i
Form was initiated. Section 7 of this form, " Justification" states:
"The amount of flow that would be lost if valves 3SWP*MOV115A/B were unable to close due to flooding would be unacceptable. Calculations have shown up to an 11%
decrease in flow to SW heat exchangers would occur. Instead of accepting condition, ensure level switch 3SWP-LS153 will operate to prevent flooding condition from occuring prior to a i
design basis condition."
In tum, a CR Action Closeout Form was completed, indicating that the amount of flow loss would be unacceptable if the MOV115 valves did not isolate when required, and stated that a
" Preventive Maintenance Change Form had been initiated to ensure the level switch 3SWP-LS153 is checked for proper operation on an annual basis."
This action is not adequate from the following perspectives:
- 1. As stated in the ACR Corrective Action Plan, the MP3 flooding study methodology assumes 30 minutes of operator time, after detection by a safety related instrument, to take action to isolate the break before affecting safety related equipment. In this case there is no safety related instrument to provide the notification.
- 2. Even if the switch were upgraded to safety related, it could not provide adequate waming to the operator based on the NU
{
analysis that the room would flood in less than 30 minutes.
- 3. Since the isolation valves for both SWP divisions are located in the same room, the potential exists for degrading both divisions due to failure from a single event - the flooding of the room.
- 4. While it is not included in the scope of the ACR lt is also noted that the two air operated safety related isolation valves
[3SWP*AOV25A/B, one for each division] for isolation of the non safety related chlorination dilution water are also located in the same SW access enclosure and subject to the same flooding conditions as the MOV115A/B valves. [See also DR-MP3-0998.]
- 5. In addition to the flooding concems, as identified in items 3 and 4 above, the requirement for physical separation of the two redundant SWP divisions is not satisfied as a result of the two instances of Train A and Train B isolation valves being located in the same room - i.e. the SWP access enclosure.
Review vand invalid Needed Date initiator: Tenwinhol. J. L O
O O
3/3/se VT Lead: Nori, Anthony A
[
[
3fN98 VT Mgr: schopfer, Don K O
O O
3 5'88 IRC Chmn: Singh, Anand K O
O O
3'S/S8 Date:
INVALID:
Printed 3/10/9811:21:56 AM Page 2 of 3
O Northeast Utilitieo ICAVP DR No. DR-MP3-1072 M!Istone unit 3 Discrepancy Report Date:
RESOLUTION:
Tss/M;identined try NU7 O Yes (e) No Non Discrepent Condition?U Yes (S) No w% P.nenetO va @ N.
p-%unr d70 va @ No navi aWh Not
^==2 Needed Date VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K g
IRC Chmn: Singh, Anand K O
O Date:
SL Comments:
Printed 3/10961121:58 AM Pege 3 of 3 I
l
Northe:st Utilities ICAVP DR No. DR MP3-1076 Millstone Unit 3 Discrepancy Report Review oroup: System DR VAuD Review Element: Modification Design Di.cipene: is
"'8" O va r-. -, Type: DrawinD gg Syste WProcess: NEW NRC SignNicence level: 4 Date faxed to NU:
Date PuWiehed 3/12/96
. 'i; incorrect markup of design drawing depicted in Plant Modification DCR M3-97045.
Description. The change to LSK-27-11H Rev.10 is shown incorrectly on pages 5 and 6 of DCN DM3-00-0079-98.
Only one logic drawing (which details the Train A lo0lc configuration) is affected by the modification, therefore, paQes 7 and 8 should be removed from DCN DM3-00-0080-98.
Pa0es 5 and 8 of DCN DM3-00-0079-98 should be revised to show the modification correctly.
Review Valid InveHd Needed Date I
Initiator: Reed, William.
O O
O 3<3/98 VT Leed: Neri, Anthony A 0
0 3/'S8 x
VT Mgr: Schopfer, Don K 0
0 35S8 x
IRC chmn: Singh, Anand K O
O 3S*8 Date:
INVAUD:
Date:
RESOLUTION:
Previously identland by NU7 O vos (e) No NonDiscrepentCondition?U vos (e) No p%Penene70 va @ No R=&6on Unr=Wved?O va @ No Review Acceptable Not #- / '
Needed Date VT Leed: Nat, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K O
B Date:
SL Comnents:
Printed 3/104611:22:21 AM Page 1 of 1
Northeast Utilities ICAVP DR No. DR.MP3-1078 Ministone uta 3 Dicerepancy Report Review Group: Programmetc DR VAUD Review Element Correcthe Action Process O v.
Dhh.repency Type: Correcthe Action impeementation gg s,.
- DGx NRC signinconce level: 4 Date faxed to NU:
Date PutWshed: 3/1298 h - :i. Insufficient Data Provided for Corrective Action Closure implementation on ACR # M3-96-0703 Desertption. The ALR # M3-96-0703 block, " Describe the adverse condition" states the following:
- Miscellaneous Emergency Diesel Generator components are ident;fied as non-QA in PMMS. Although these components do not actuate to support diesel start or continued operation, they are required to be QA Cat -1 to be consistent with plant design basis failure analysis (diesel stop logic, electrical separation, lube oil pressure boundary etc...). (3EGS*TS28A/S, 3 EGO *TS34A/B, 3EGS* PS27A1/B1, SEGS
- PS27A2/B2, 3EGS*LS34A/B,3EGS*TC31A/B,3 EGO *PS24A/B, MADALP13, MADBLP13, 3EGD*V994A&B995B, MDDALP03, MDDBLP03, MA4C1503)"
The Operability Determination, OD No. MP3-209-96, Block F states that "The installed components meet the design requirements forinstalled service. Details disposi'Jons on a component by component basis are provided in NCR M3 067." This statement applies to the abovs listed components.
NCR M3-95 067 covers the upgrade of the following components to QA Cat-1: 3EGS*TS28A/B, 3 EGO *TS34A/B, 3EGS*
PS27A1/B1, 3EGS* PS27A2/B2, 3EGS*LS34A/B,
3EGS*TC31 A/B,3 EGO *PS24A/B.
NCR M3-95-067 does not cover the upgrade of the following components to QA Cat-1: MADALP13, MADBLP13, 3EGD*V994A&B995B, MDDALP03, MDDBLP03, MA4C1503.
Note: NCR M3-95-067 is missing 1 of the 12 pages.
Review Valid InveEt Needed Date initiator: Coruso, A.
O O
O 3r2res VT Laod: Ryan, Thomes J B
O O
3'4S8 VT Mgr: Sc@, Don K O
O O
3's/S8 1RC Chmn: singh, Anend K O
O O
2sese Dele:
INVAUD:
Date:
REsot.UTION M/- r"; hientHied by NU7 O Yes @ No Non "r+, M Constion?(,,) vos (8) No RooiunonPenans70 va @ wo Roomuonunroemed70 ya @ u.
Review Printed 3/10011:22A6 AM Page 1 of 2
Northe:st Utilities ICAVP DR No. DR-MP3-1078 Millstone Unit 3 Discrepancy Report
^
n=:
www-u.a.e o.n.
- m. w, O
O O
VT Lead: Ryan, Thomas J O
O O
VT Mgr: Schopfer, Don K 0
0 0
mc ce nn: s w.An.nsx 0
0 0
Det.:
SL Comments:
I I
i i
i Printed fM10/961122.50 AM Page 2 of 2
~
~
Nortlw sst Utilities ICAVP DR No. DR hS3-1080 mmstone unit 3 Discrepancy Report Review oroup: System DRVAuo Review Element. ModlAceton Design tuae W : Mechanical Design O Y=
Discrepancy Type: Drawing g
SystemfProcese: NEW NRC SagenAconce level: 4 Date faxed to NU:
Date Published 3/12/se E.
2. DCR M3-97045 does not update drwg 2214.802-044-021 for new 1
RSS pump flow rate.
==
Description:==
DCR M3-97045 lowers the RSS pump flow rate and discharge head. Changes to the vendor pump cu.'te drawing,2214.802-i 044-021, are necessary to reflect the ne.i operating point for the RSS pump flow rate and discharge heae. No document is identified which changes the vendor pump curve drawing for the new design point.
Review ValH Invalid Needed Date initiator: Feingold, D. J.
8 O
O 3/sse VT Leed: Neri, Anthony A 8
O O
3/e/se VT Mgr: Schopfer, Don K B
O O
3/s/se IRc Chmn: Singh, Anand K G
O O
3/ arse Date:
INVAUD:
Date:
RESOLUTION:
Previously Wenuned by NU7 O Yes @ No Non Discrepent Condition?C Yes @ No Re.wation Penmag70 vos @ No Reeduuon ur
'70 va @ No j
Review Ac+ = Not a va N d.d Dei.
VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K g
{
m
)
SL Comments:
)
Printed 3/10/se 11:23:32 AM Page 1 of 1 a