ML20217Q225
| ML20217Q225 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/05/1998 |
| From: | Curry D AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUM2-PPNR-1203, NUDOCS 9803120073 | |
| Download: ML20217Q225 (20) | |
Text
1 1
PARSONS Daniel L. Curry, Vce President, Nuclear Serv ces Parsons Energy & Chemicals Group Inc.
2675 Morgantown Road
- Reading, Pennsylvania 19607 * (E10) 855-2366 e Fax:(61D) 855-2602 f
March 5,1998 Docket No. 50-336 Parsons NUM2-PPNR-1203-L U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Millstone Nuclear Pour Station Unit No. 2 e
Independent Corrective Action Verification Pream (ICAVP)
I Gentlemen:
1 This latter transmits summaries of telephone conferences between Parsons Power Group Inc., the U. S.
Nuclear Regulatory Commission, NNECo and NEAC on February 10, February 12, February 18, February 19 and February 24,1998.
Please call me at (610) 855-2366 if you have any questions.
Sir.cerely, Daniel L. Curry Parsons ICAVP Project Director DLC:djv Attachments 1.
Telephone Conference Notes from February 10,1998 2.
Telephone Conference Notes from February 12,1998 3.
Telephone Conference Notes from February 18,1998 4.
Telephone Conference Notes from February 19,1998 5.
Telephone Conference Notes from February 24,1998 t
"(LU,i cc:
E. Imbro (2) - USNRC J. Fougere - NNECo H. Eichenholz - USNRC Rep. Terry Concannon -NEAC R. ".,audenat - NNECo Project Files j
9803120073 900305 l
PDR ADOCK 05000336 l ll llllllllll P
PDR PPNR1203. doc i
j
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ADMINISTRATIVE CONFERENCE NOTES February 10,1998 DATE:
2/10/98 PUR' POSE:
Administrative tekohone conference with NNECo, NRC, NEAC and Parsons to discuss; 1.
Response to DR-0078 2.
RWST Setpoint 3.
Verification of High Energy Line Break 4.
Guide to Specifying M&TE 5.
Unit 2 Feed to Unit 1 - Effect on Unit 2 Voltages 6.
ECCS surveillance procedures 7.
Follow-up information from (2/3/98) DR-313 discussion 8.
VETIP Review LIST OF ATTENDEES:
i NNECo NRC NEAC Persons f
Joe Fougere Ralph Architzel Wayne Dobson Fred Mattioli Don Marks Roy Terry Ray Thomas James Diluca -
Rich Glaviano Ke.: Fox Richard Boyd Rick Honner Larry Jacksor.
Laird Bruster Daniel Wooddell Rich Ewing Bill Jones Ken Moore Clark Tracy Steve Wainic, Andy O'Connor Morris Sanders Kaluin Anglin 1.
Topic: Response to DR-0078 (Clark Tracy)
Background:
The discussion of the second concern (Pg. 3 of 5 of Response ID: M2-IRF-00935) states that this was "previously discovered by NU and icivires corrective action."
Action requests, AR980001-5 and AR980001-6, are referenced as the mechanism for tracking.
These AR's reference the Vectra Appendix R Audit for Millstone 2 that was issued on August 12,1996 and Design Engineering Memo MP2-DE-96-750 issued on December 13,1996.
i Questions:
What formal corrective action document was issued?
e i
Response: A formal corrective action document was not issued. They stated that in thefuture, they would issue a formal action document when deficiencies were noted in ES4R'S and contractor reviews.
2.
Topic: RWST Setpoint (Ray Thomas)
Background:
The RWST Level Setpoint is set in the Surveillance Procedure (SP 2403E; ]DV_S_T Level Calibration) at 41.8 Inches from the top of the discharge pipe and meets the requirements specified in the UFSAR, the Sctpraint Calculation and in the Technical Specification.
PAGE 1
AUMINISTRATIVE CONFERENCE NOTES Febru ry 10,1998 Questions:
What is the basis for the RWST Level Setpoint being set specifically at 41.8 inches from the top e-of the discharge pipe per the Surveillance Procedures and what documentation supports this actual setting? (In efTect, is there a 50.59 Evaluation, Modification, or some other design document that actually approved the Surveillance Procedure's setpoint?)
.Respsuse: The basisf the Rif STLevel Setpoint being set specifically at 41.8 inchesfrom the top ofthe discharge pipe per the Surveillance Procedures is unknown according to Afillstone. Note, that the Technical Specifications reflect a setpoint of48 inchesfrom the bottom ofthe tank which is equivalent to 42 inchesfrom the top ofthe discharge pipe. This isn 't 41.8 inches, although it is very close. Afillstone stated that they had no records to document the setpoint specifically at 41.8 inches other than the Surveillance Procedure itself i
3.
Topic: Verification of High Energy Line Break (Gary Jackson)
Background:
ERC 25203-ER-97-0406, Revision 0, "MP2 Verification of High Energy Line Break (HELB) Design Adequacy Inside Containment" was performed to establish a reasonable confidence level in the onginal design relating to the protection provided from High Energy Line Break (HELB) inside Containment. The approach to verify the design adequacy was to walkdown and evaluate a sample of High Energy Lines inside containment. The sample consisted of the following:
10" Pressure Relief Piping from the Pressurizer Relief Valves to the Pressurizer Relief Tank 12" Shutdown Cooling Line from the SG No. 2 Hot Leg to Penetration #10 34" Main Steam Line from SG 1 & 2 to Penetn.tions 19 & 20 18" Fe:dwater Line form Penetrations 15 & 16 to SG 1&2 2" Charging Line - This line was limited to the verification of a pipe whip restraint due to an existing known documentation discrepancy with a restraint.
Questions:
For the above listed lines, what was the basis for this sample?
Response: Conflicts between calculations and drawings Large si:es and energy Line was analped with breaks andno targets were ident:Jied. ReviewedflELB inside to reconfirm as-builting of existing piping configuration and restraint. system to insure separation, etc. CR identifiespiping load combinations require addition ofjet impingement loads. No load combinations were included in the analyses whici address impingement loadt Next refueling outage will capture remaining open items.
Why weren't the Safety injection Lines, Steam Generator Blowdown lines, or other portions of the RCS, (such as the Pressurizer Surge Line), included in the sample? (Reference Table 6.1-1 of the FSAR)
Response: See response below.
MP2 HELB Program Upgrade PA 90-039 Project Description, HELBASIS-1302M2, Revision 1 -
Appendix A, identifies a significant number of components in the HELB Safe Shutdown Equipment List that are located in containment. Why wasn't the Safe Shutdown Equipment List used as a basis for the sample population in lieu of a line by line sample?
Response: Waa not trying to capture everything in this walkdown. This is not to be considered the finalproduct. The emphasis was on the CR andline to line interaction.
PAGE 2
ADMINISTRATIVE CONFERENCE NOTES Febru:ry 10,1998 Were any of the components that are contained in the HELB SSEL included as a part of the e
walkdown of original sample?
Respense: Did not walkdown the HELB SSEL Line to line interaction was the main purpose ofthe walkdown to address thejet impingement concerns as identifiedin the CR. 87-11 criteria was not applied. Walkdown showed the ystems basically meet the criteria ofReg. Guide 1.46. Not committed to this Reg. Guide; however, was evaluated to R.G.1.46 in the SER, but not licensed to it.
4.
Topic: Guide to Specifying METE (Dan Wooddell)
Background:
Please explain the application of Figure 1, Guide to Specifying M&TE, that is provided in Procedure WC-8, Control and Calibration of Measuring and Test Equipment.
Questions:
What information is ' ng provided by this figure?
e How is this mformation used to establish setpoints?
e What is meant by the phrase " design limit"?
e iIow is the design limit for the measured item determined?)
e Response: WC-8 is at revision 2, therefore the above questions are moot because they apply to an earlier revision. Parsons willsend an RAIfor revision 2 of WC-8.
5.
Topic: Unit 2 Feed to Unit 1 - Effect on Unit 2 Voltages (William Jones)
Background:
Unit 2 4160V bus 24E provides the ability to supply Unit 2 from Unit 1, and vice versa. The supply can be from the diesel generators or through Normal / Reserve Station Senice Transformers. Calculation PA79-126-1027-E2 includes Unit 1 SBO loads in the Unit 2 Emergency Diesel Generator loading calculation. U'IR 1529 identifies lack of Alternate AC Loading and Voltage Drop calculations while feeding Unit 2 from Unit 1.
l Question:
Is there a calculation that shows the effect on Unit 2 busses while supplying Unit I loads through Unit 2 Reserve / Normal Station Service Transformers?
Response: No calcidation is available. There is a related UlR, but it is not specific to this case. NNECo will write a CR ifno bounding condition isfound 6.
Topic: ECCS sun eillance procedures (Wayne Choromanski)
Background:
ECCS pumps, which are acquired to operate to mitigate accidents as outlined in Chapter 14 of the Millstone FSAR, undergo performance testing (4.0.5-P) to verify that they meet minimum flow conditions. It was found that SP 21118 tested the capacity of the "A" 4
charging pump. This procedure has been marked as " Canceled" in world view.
PAGE 3
)
ADMINISTRATIVE CONFERENCE NOTES F1hav:ry 10,1998 Question:
What surveillance procedures test the flow capacity of each of the charging pumps (P18A/B/C)?
Response: Operations Procedure: 26011.
7.
Topic: Follow-up information from (2/3/98) DR-313 discussion (Rich Glaviano)
Background:
A conference was held at MP-2 on Feb 3 to discuss Preliminary DR-313. The modeled RC core finw distribution versus the actual core flow distribution was discussed.
Parsons will provide updated information regarding the n.odeled core flow distribution used in the anah sis.
Question:
N/A Response: Deferred to 2/12/98.
t Topic: VETIP Review (Wayne Dobson) [ Note: This topic was not on the original agenda]
Background:
The Unit 2 KSREL has been revised and approved. Approximately 35-40 vendor manuals will need to updated for Unit 2, the exact number has not been established. Five manuals have been reviewed and updated. When a manual has been updated it is put in nuclear records and an AR is written to track procedure validation performed by various procedure owners. Unit 3 vendor manual review is planned to be completed by 2/15/98. By the end of February, NNECo will have a list of all Unit 2 manuals that will need to be updated and a schedule for their review and procedure validation. This information is needed before the NRC can make decisions on coordinating the reviews to M done by the ICAVP and the NRC staff.
Question:
N/A Response: NNECo will fax to Parsons and the NRC information on the schedule for the FSAR Chapter 14 re-analysis efTons.
PAGE 4
ASMINISTRATIVE CONFERENCE NOTES Febrwry 12,1998 DATE:
2/12/98 PURPOSE:
Administrative telephone conference with NNECo, NRC, NEAC and Parso'is to discuss:
Evaluation of Piping Analysis Loads on the Safety Injection Nozzles DR-313 discussion (continued form 2/10/98)
Fast Transfer from NSST to RSST supply with Service Water and
=
RBCCW pumps connected to 4160V busses LIST OF ATTENDEES:
NNECo NRC NEAC Panons Joe Fougere Steve Repicids Wayne Dobson Fred Mattioli Ralph Architzel Don Marks Steve Wainio Walt Jensen William James Paul Hesler Gene Imbro Paul Schmitzer Dan Van Dyne Rich Glaviano Rich Ewing Larry Collier Dave Bajumpaa
- 1. Topic: Evaluation of Piping Analysis Loads on the Safety injection Nozzles to Reactor Coolant Loops. (Paul Schmitzer)
Background:
Teledyne Analyses E-1475-2,3,4, and 5 tabulate the piping nozzle loads at the Safety injection nozzles to the reactor coolant loops but do not provide a comparison of these loads 1
against the loads used in the Ref. I nozzle qualifications. Because the loads from the piping analyses are different from these evaluated for the Si nozzle qualification, a detailed loading comparison is necessary. No latr* xumentation or references for the Si nozzle qualifications have been provided.
Associated references:
Thermal Stress and Fatigue Analysis of the Safety Injection Nozzle, Calculation No. PS-202-P, Rev. O, Dated 3/802, Combustion Engineering, Inc.
Engineering Specification for Primary Coosaid Pipe and Fittings, Specification No.18767-
{
o 31-5, Rev.1, Dated 10/18/68 (not available, see RAI-0577 and IRF-01006)
Project Specification for Reactor Coolant Pipe and Fittings, Specification No. 18767-31-5, Rev.13, Dated 10/5n2 TMR Technical Report No. E-1475-2, Rev. C, Dated 5/2404 TMR Technical Report No. E-1475-3, Rev. F, Dated 1/17D5 TMR Technical Report No. E-1475-4, Rev. D, Dated 1/23/75 TMR Technical Report No. E-1475-5, Rev. F, Dated 1/2355 e
Question:
a) What document evaluates the latest loads from the TMR piping analyses to show that the Si nozzle qualifications are still acceptable?
Respense: The 11PSIpiping no=le loads have not been reconciled with the existing SI-RCL noule quahfications. There is an ongoing effort to reconcile interfaces with the Reactor Coolant 5:vstem and as a result there are approximately 50 UIRs assoMated with NSSS.. Since some of these UIRs are "open-ended" in ncture, the S1 nonle connection.t may not be included. No reference to a specific UIR on this item could be provided.
1 PAGE 1 i
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ADMINISTRATIVE CONFERENCE NOTES F;hrutry 12,1998 2.
Topic: DR-313 discussion (continued form 2/10/98). (Rich Glaviano)
Background:
A conference was held at MP-2 on Feb 3 to discuss Preliminary DR-313. The j
modeled RC core flow distribution versus the actual core flow distribution was discussed.
Parsons will provide updated information regarding the modeled core flow distribution used he the analysis.
- Question:
a) N/A Response: Parsons provided an update on the modeling of the Decrease in Reactor Coolant System Flow Events.
The analysis model assumes uniform flow (minimum reduction assumedfor the hot channel)for the 4 quadrants of the core 3.
Topic: Fast Transfer from NSST to RSST supply with Senice Water and RBCCW pumps connected to 4160V busses (William Jones)
Bathground: On turbine trip,4160V emergency busses fast transfer from NSST supply to RSST supply. Senice Water & RBCCW pumps remain connected to their busses during the evolution. Bechtel spec. 7604-E10, used to procure subject motors, states that motors must be capable of withstanding stresses associated with interrupted circuit TEN CYCLE emergency throw-over, in paragraph 7.7. None of the General Electric purchase order correspondence supplied to Parsons on RAI-0778 acknowledges this requirement. An actual Fast Transfer test, performed in 1995, showed that the transfer completed in 3.67 cycles during this test.
Question:
Is there documentat on from GE that recognizes the fast transfer requirement?
i a)
Response: There is no documentation. But since there was no exception taken, no problems are anticipated.
b) Was GE consulted regarding fast tran
,ithstand capability of the motors with a 3.67 d-cycle to 6 cycle (from Calc. PA93-045-12~3E2) transfer time?
Response: Defer. Ito 2/17/98.
PAGE 2
l ADMINISTRATIVE CONFERENCE NOTES Fehntry 18,1998 DATE:
2/18/98 PURPOSE:
Administrative telephone conference with NNECo, NRC, NEAC and Parscar to discuss:
HVAC Calculation Initiative (EWR 96-105) and Passport Calculation Database AOP 2579J rev. 3 as regards 2-SI-659 and 2 SI-660 e
LIST OF ATTENDEES:
NNECo NRC NEAC Parsons Fred Mattioli Steve Reynolds Wayne Dobson Mike Smaga Don Marks Martin Vezina William Clemenson Jim Nicholson Andrew O'Connor Rich Ewing Daniel Wooddell Debbie Hctsey RogerIIall Steve Stadnick Nayam Shah Bo Pokora clark Tracy Jerry Reynolds 1.
Topic: HVAC Calculation Initiative (EWR %105) and Passpon Calculation Da3ase. (William Clemenson)
Background:
A resiew of tle Calculation database contained in Passport indicates that nmnerous HVAC calculations have been recently revised. We are trying to match this database with our in-house list of HVAC calculations that are applicable to systems 2314B,2314G and 23 ISE.
The following is a listing of calculations u hich we have not been able to locate in Passport.
Question: Please prmide tie three letter Passport system designator wlere these calculations are located (e.g., EBF) or provide a status of these calculations (i.e., Active, Superseded, Void) and their latest revision.
- System 2314G, Enclosure Building Filtraticn System:
Calcs IK2-7, IK21-9, IK21-11, IK21-13 Response: These calculations are in the process of being superseded by a new calculation 98 EBF-02377M2. Willbe issuedin apprawnately three uveks. These calculations uilt be enteredintopanymt in the EBFsystem. Though these calculations are being revised, they are still consideredthe calculation ofrecord
= System 231 AB, Containment / Enclosure Building Purge:
Cales IKl2-1 Appendix A. IK12-2, IK12-3, IK21-10, IK42-05 Response: All of these calculations except 1K42-05 uill be revised in Phase III, thus these current calculations are to be considered the calculation ofrecordfor Tier i review. Calculation 1K12-M uilt be revisedshcwsly. IMywt system designator has not been established.
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ADMINISTRATIVE CONFERENCE NOTES Febncry 18,1998 l
- System 2315E, Emergency Diesel Generator Room Ventilation:
dalc 91-056-359M2 Response: This calculation is currently listed in passport, but the system designator could not be established. Willprovidelater.
2.
Topic: AOP 25793 rev. 3 as regards 2-SI-659 and 2-SI-660. (Andrew O'Connor)
I
Background:
AOP 25793 rev. 3 dated 10-1-96 and the Appendix R Compliance Report Pages 3.3-11 and R-6-6 both indicate that certain events may in-fact call for manual closing of AOV's 2-SI-659 and 2-SI-660 through the use of handwheels. A walk down of valves 2-SI-659 and 2-SI-660 i
revealed that they are not provided with handwheels as indicated in the above documents.
)
Question:
j a) What Alternative method will be used to assure these valves can be manually closed as directed?
j Response: The plant has recogni:ed that the procedure is incorrect, because the valves (2-51-659 and 660) do not have handwheels. The procedure is being written to use the LPSIpump valves instead. The Appendix R Compliance review document will also have to be revised, and that will be part ofMode 4, (prior to start up but no other date.)
3.
Topic: Procedure MP 27191 (Daniel Wooddell) i
Background:
Procedure MP 2719J, Section 4.3, Provides instructions to replace the EDG Motor Driven Jacket Coolant Pump Scal. Step 4.3.8 of this procedure contains an instruction to inspect the
{
pump wear rings for excessive wear, The procedure step also states "If wear is apparent, consult Maint. Eng. for direction."
Question:
a) What inspection method is used to check for wear rings excessive wear?
b) In what document is the inspection method detailed?
c) What document provides minimum and maximum wear ring clearance information?
Response: NUperforms a visual check ofthe Dierel Generator Motor Driven Jacket Coolant Pump wear ringc There is nu doamentation detailing an inspection method orproviding wear ring i
clearance informaticn. NU relies on the k towledge and skill ofthe craftsman to determine excessive wear ring clearances. Also, failure to keep the diesel coolant system warm wouldprovide indication ofexcessive wear ring clearances. Pump discharge pressure is not routinely checked.
4.
Topic: Fast Transfer from NSST to RSST supply with Service Water and RBCCW pumps connected to 4160V busses (William Jones)lcontinued from 2/12/98]
Background:
On turbine trip,4160V emergency busses fast transfer from NSST supply to RSST supply. Service Water & RBCCW pumps remain connected to their busses during the PAGE 2
ADMINISTRATIVE CONFERENCE NOTES Febm ry 18,1998 evolution. Bechtel spec. 7604-E10, used to procure subject motors, states that motors must be capable of withstanding stresses associated with interrupted circuit TEN CYCLE emergency throw-over, in paragraph 7.7. None of the General Electric purchase order correspondence supplied to Parsons on RAl-0778 acknowledges this requirement. An actual Fast Transfer test, performed in 1995, showed that the transfer completed in 3.67 cycles during this test.
Questions:
a) Was GE consulted regarding fast transfer withstand capability of the motors with a 3.67 cycle to 6 cycle (from Calc. PA93-045-1273E2) transfer time?
Response: No-GE hadperformed u rimilar analysisfor AfPl. AfP2 performed their own analysis for AiP2 predicated on the similarity ofthe motors between Units 1 and 2. Parsons can have this
. information by requesting it in a RAl.
(
I I
i PAGE ?
ADMINISTRATIVE CSNFERENCE NOTES February 19,1998 DATE:
2/19/98 PURPOSE:
Administrative telephone conference with NNECo, NRC, NEAC and Parsons to discuss:
CAR unit operation
- PDCR 2-186-79 Vendor Equipment Technical Information Program e
Calculation 78-772-16RA Rev.1. and radiological off-site doses
=
Peaking factor form Calculation 78-772-16RA Rev.1.
Total dose from Calculation 78-772-16RA Rev.1.
IIVAC Calculation Initiative (EWR 96-105) and Passport Calculation Database e
List OF ATTENDEES:
NNECo NRC NEAC Panons Joe Fougere Ralph Architzel Wayne Dobson Fred Mattioli Don Marks Jim Petrosky David Lengel Ray Crandall Claude Didier Debbie Hersey Candace Segar Jim Nicholson Wayne Choromanski Rich Ewirie William Clemenson 1.
Topic: CAR unit operation. (David Lengel)
Backgroun3: The analysis associated with the FHA inside containment assumes uniform mixing within containment. Two systems are required to provide unifonn mixing of the containment. TI. "ontainment Auxiliary Circulation System fans normally provide mixing of the upper portion of containment while the CAR units provide mixing in the lower portion of j
containment. Both systems are required to provide uniform mixing throughout containment.
OP-2313 A is not mode specific and does not address the number of fans operating for any set of conditions. OP 2205, Plant Shutdown, OP 2207, Plant Cooldown, OP 2209A, Refueling Operations, SP 2619A, Control Room Shift Checks, and SP 2614A, Periodic Checks in Mode 5 and 6 or When Defueled, along with the associated forms, were reviewed and did not address operation of the CAR units.
Questions:
a) Are the CAR units operating in Modes 5 and 67 b) If so, how many are operating?
c) Please identify / provide the procedure or program which specifies /comrols the operation of the CAR units in Modes 5 and 6.
Response: 2 CAR units are normally run during Modes 5 and 6, even during refueling operations. CAR units are operated as needed to maintain habitability in the containment.
They are also used to maintain pressure control. However, there is no procedural requirement to operate any CAR units in Modes 5 or 6.
PAGE 1
ADMINISTRATIVE CONFERENCE NOTES February 19,1998 2.
Topic: PDCR 2-186-79. (Candace Segar)
Background:
PDCR 2-186-79 installs cable needed to provide automatic start capabilities for the AFW system. This mod does not include cable terminations.
\\
Questions:
)
a) Please identify the mod package which terminates these cables.
Response: The relevant modpackage is PDCR 2-182-79 3.
Topic: Vendor Equipment Technical Information Program. (Claude Didier)
Background:
NEO 2.32 section 4.2 defines Engineering Program (EP)- A documented approach for addressing an engineering problem or issue that requires ongoing programmatic responses to fulfill a specific or recurring Nuclear Group need or commitment.
Questions:
a) As the VETIP program appears to fulfill the elements of this definition, is the VETIP program i
an engineering program.?
l b) If not why is it excluded from being an engineering program and 'vhat is it?
Response: The VETIPprogram is currently under evaluation andis a candidatefor being an Ergineering Program. CR-197-3649 and CR -397-4118 have been initiated regarding the VETIP program.
c) Are desktop instructions currently being used in reviewing, assembling, and updating Vendor Manuals?
Respense: DC-16 is the governing procedure. There was somefurther discussion on what defined the scope, the objectives, the implementation of the VETIP program. DC-16 was a station procedure which as defined in procedure DC-1 provides "Instructionsfor controlling theflow ofinformation. material, or responsibilityfor administrative tasks. " DC-16 does not address questions like, "What is a VIM: what is it'sformat?; What are its contents?;
Does it contain an applicability list?; Does it contain an index?" Jim Petrosky cxplained that the vendor manuals were reviewed, assembled, and updated using best practices by one group station-wide and all the manuals went through a review by the Vendor Coordinator to assure consistency of output. He offered that Unit 3 manuals were available if Parsons would care to look at them, and that these might help to answer some of the questions.
Parson responded that this appeared to be a good idea and would look at arrangements to go to the plant and do that.
PAGE 2
q ADMINISTRATIVE CONFERENCE NOTES February 19,1998 i
4.
Topic: Calculation 78-772-16RA Rev.1. and radiological off-site doses. (Wayne Choromanski)
Background:
During the review of Chapter 14, Fuel Handling Accident in the Spent Fuel Pool, calculation 78-772-16RA Rev. I entitled MP II Stretch Power Application Fuel Handling Accident in Spent Fuel Pool was resiewed. On page 3 of the calculation, to adjust for multiple (14 ) fuel rod failures in an assembly to rupture must be multiplied by the fraction of rods that fail over the total l
rods in the assembly. The total number of rods in an assembly used within the calculation is 172.
Questions:
a) Per FSAR section 3.3.1.3.3.1, the assembly consists of a 14 X 14 array, consisting of 176 rods in a cage structure of 5 guide tubes. Each of guide tubes displace 4 fuel rods leaving the total of 176 to be used in calculation 78-772-16RA Rev.1. Is the number for the radiological off-site doses still valid (conservative)?
Response: The number offuel rods in an assembly is 176. Calculation 78-772-16RA Rev. I used the incorrect number in the calculation of 172.
The fuel assembly is a 14 X 14 array. A side calculation that wasfound, 96 RAD-1378-R2 Rev.1 is not the calculation ofrecord, but will be used post start-up for leakage allowances in the fuel pool area. The current calculation, 78-772-16RA Rev. I is conservative with the lowerfuel rod number usedin the calculation.
5.
Topic: Peaking factor form Calculation 78-772-16RA Rev.1. (Wayne Choromanski)
Background:
The peaking factor of 1.80 was used within the body of calculation 78-772-16RA Rev. I entitled MP 11 Stretch Power Application Fuel Handling Accident in Spent Fuel Pool. This number is referenced in FSAR table 14.7.4-2 which references Technical Specification 3/4.2.3 This specification indicates that the peaking factor is part of the recent CORE OPERATING LIMITS REPORT (Fr). Review of Cycle 13 Startup Test Report indicater that the Peaking Factor (FrT) is less then or equal to 1.69. This value is found on page 8 of Attachment #1 entitled Millstone Nuclear Power Station, Unit No. 2 Startup Test Report for Cycle 13. This was part of NRC Docket No. 50-336, B15414. This value is also shown on figure 2.6-1 on the Millstone Unit #2 Cycle 13 Core Operating Limits Report, dated Jan.1995, Rev. O.
Questions; a) What is the correct peaking factor to be used? Is this the same number used in calculation 78-772-16RA Rev.17 If not the same number, does this impact that calculation?
Response: 7he 1.8 is a projected maximum expectedpeakingfactor. Current cycle is 1.69 Fr. The 1.8 is used so that the calculation does not have to b= revised every time a peakingfactor is changed fromfuelcycle tofuelcycle.
6.
Topic: Total dose from Calculation 78-772-16RA Rev.1. (Wayne Choromanski)
Background:
Calculation 78-772-16RA Rev. I multiplies the dose obtained on page 3 by 14 to come up with total dose at the site boundary for the number of fuel rods. This number is also referenced on page 14.7-4 of the FSAR and referenced in tables 14.7-1 in the FSAR.
PAGE 3
4.
i ADMINISTRATIVE CONFERENCE NOTES February 19,1998 Questions:
a) What calculation is used to determine that only 14 fuel rods will be damaged on a fuel assembly drop?
i Response: The 14 rod failure is determined by engineering judgment. There is no basis for selecting the 11 rodfailurefor the most probablefuelfailure during a drop event. The referenced section in the F54R (14.7.4.2) which states kinetic energy values were probably frcno construction times. This paragraph in the FK4R wil! be removed at some later date.
1 I
1 7.
Topic: HVAC Calculation Initiative (EWR 96-105) and Passport Calculation Database (William Clemenson )
i
Background:
Per discussion with NNECo on 2/18/98 information was prosided on the status of various HVAC cales but information on the Passport swtem designator was not prosided.
Question:
i
- 1. Please provide the three letter Passport system designator (e.g., EBF, DGV) for the following calculations. If they are not currently located in Passport, please specify as such.
1 a) System 2314G, Enclosure Building Filtration System: Cales IK21-7, IK21-9, IK21 11, IK21-13 b) System 2314B, Containment / Enclosure Building Purge: Calcs IK12-1 App.A, IK12-2, IK12-3, IK21-lo, IK42-05 c) System 2315E, Emergency Dicsci Generator Room Ventilation: Calc 91-056-359M2 Response: To date there are 3260 kip 2 calculations of which 2419 have been input into Passport.
Calculations identijled in the first two bullets have not been inputted into Passport at this date.
i When they are inputted they will be placed in system EBE The calc identyled in the third bullet will be input into the DGl' system.
PAGE 4
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ADMINISTRATIVE CONFERENCE NOTES Febru:ry 24,1998 DATE:
2/24/98 PURPOSE:
- Administrative telephone conference with NNECo, NRC, NEAC and Parsons to discuss:
- 1. Maintenance Rule
- 2. Processing of Action Requests
- 3. Process Interface Between UIRs and CRs
- 4. Tagging of EEQ Equipns '
- 5. PDCR-2.166-78
- 6. Prvcedure MP 2721D 7.
Procedure CBM 107
- 8. Procedure CBM 102 9.
Engineering Procedure Containing Valve Thrust Values
- 10. Tier-2 Information Needs [previously referred to as Chapter 14 Accident Analyses]
- 11. EN 21137 LIST OF ATTENDEES:
NNECo NRC NEAC Panons Fred Mattioli Steve Reynolds Don Marks Rich Ewing Dom Ramos Karen Tillett Dan Wooddell Steve Stadnick Larry Collier Mike Ahern Jim Collins Dave Bajumpa Roger Milkr John Festa Rich Glaviano Greg Tardif Claude Didier Russ Sturgis Joe Nochera 1.
Topic: Maintenance Rule. (Larry Collier)
Background:
ESAR PGRM-97-050, PI-21 dated 6/26/97 checklist item A stated that " Licensing should develop and document a Unit 2 commitment position for implementing the Maintenance Rule in accordance with Regulatory Guide 1.160 Revision 2". The Maintenance Rule Program is important in (l'at it is integral part of determining whether certam CR's should be initiated to resolve a UIR.
Questions:
a) Has a Maintenance Rule program or procedure been written and approved describing and fulfilling all the elements specified in 10CFR50.657 b) Please provide the document name and number.
j Response: Deferred to 2/26/98 2.
Topic: Processing of Action Requests (ARs) (Larry Collier)
Background:
The lifecycle: initiation, routing, and closcout of ARs is confusing and often leads resimers in circular documentation chases.
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ADMINISTRATIVE CONFERENCE NOTES F;bru!ry 24,1998 Questions:
a) Is there a procedure or administrative document that describes the authority of Action Requests relative to safety related and/or quality related components and the Action Request's initiation, function, cancellation process, completion and close-out.?
Response: res.
b) Please provide the procedure or document number that describes those items listed above?
Response: SI-100.1 Rev 0,
" Action Item Tracking" Non-Ouality Assurance Handbook. Dated January 1, 1998.
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I 3.
Topic: Process Interface Between UIRs and CRs. (Wayne Dobson / Jim Collins)
We would like a better understanding of how NNECo intends UIRs and CRs to work together to control corrective actions. From our reading of RP-4, we would have expected many of the items identified in UIRs to have resulted in a CR, but no CR was written. We 3
would like to discuss this topic. The following attempts to describe the basis for our
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confusion and the type of questions we have.
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Background:
q We understand that Millstone Nuclear Power Station Administrative Proe: dure PI 14,
" Configuration Management Plan Project Process Administration Instructicr" addresses whea a CR is prepared in conjunction with a Unresolved Item Report, (UIR). This procedure contains two notes identifying that CRs will be generated to address issues of a repetitive or p_r_oarammatic nature. In addition, step 1.3.2 of PI 14 specifies that if an item is potentially reportable or impacts operabilit_y, initiate a CR. From this we conclude that a CR is written when a UIR (or several UIRs) identifies items which are repetitive or programmatic in nature; or when items are potentially reportable or impact operability.
Questions:
a) Are these the only criteria for when a CR is written, or is the direction given in RP-4 also applicable to the items identified in UIRs? This question arises because one of the notes in PI 14 says, "Where specific questions arise as to the need for a CR,. refer to RP-4 for additional guidance." Is all of the RP-4 guidance on when to write a CR applicable to CMP, or does PI 14 somehow limit when RP-4 is used?
Background (cont.):
Section 1.1 of RP 4 states that the Corrective Action Program for resohing conditions adverse to quality and significant conditions adverse to quality is essential in complying with 10CFR50 Appendix B Criterion XVI. The section identifies the types of conditions.
These are: 1) external event, 2) design deficiencies, 3) human performance, 4) component failure,5) program or procedure inadequacy, and 6) ineffective management oversight.
The section then states that "A Condition Report, or "CR", is initiated for adverse, discrepant, or other conditions needing improvement." It appears that the criteria for when a CR is to be written is broader in RP-4 than in PI 14.
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ADMINISTRATIVE CONFERENCE NOTES Fekwry 24,1993 The following UIR examples have contributed to our confusion. In UIRs 3100 and 3265 the conditions were determined not to require a CR and had not identified potential safety 7
significant conditions. These UIRs identified many instances where valve positions on operations critical drawing were incorrect. In another instance, UIR 3355 documented that the NRC inspector noted that valve lineup check sheets were inconsistent with procedure and with the Control Room OPS Critical drawing. The UIR stated that system makeup valve 2-PMW-167 is closed by the procedure, but is shown open on the drawing in the updated final safety analysis report and the most recent P&lD. CR # M2-97-1881 was initiated to document this discrepancy. This condition appears to be similar to those identified in UIRs 3100 and 3265, yet no CR was initiated for these two UIRs.
Questions:
b) How does NNECo inteipret PI 14 and RP-4 regarding when a CR should be written?
Response: Deferred to 2/26/98 1
4.
Topic: Tagging of EEQ Equipment. (Jim Collins)
Background:
NCR 291-0188 was initiated against an activity performed for work on valve motor 2-CS-16.1 AM, Containment Sump Outlet Header "A" Isolation Motor Operator. Work l
order M2-91-05305 was initiated to perform electrical inspections for.Raychem splice installations. The NCR states that the valve had a EEQ tag and was not to be disturbed. The NCR stated the gasket and seating surfaces of the box cover exhibited mst and that the EEQ integrity was violated. Also, it was identified that the flexible conduit entering the box was damaged and had been repaired with electrical tape.
The disposition stated that the purpose of the EQ green tag was to alert personnel that the component was within the EEQ program and that procedures were to be reviewed and to be aware of any special EQ requirements pertaining to maintenance of the component. The~
disposition also stated that specific EQ requirements have been incorporated into maintenance-procedures to ensure EQ requirements are not violated.
During the ICAVP Tier 3 review of this NCR, no procedure could be found controlling the issuance or purpore of the EQ green tag referenced in the NCR disposition.
Questions:
a) What procedure controls the issuance, installation, purpose, and meaning of the EQ green tag?
Response: NNECo respondedin the 2-24-98 teleconference thatprocedure NEO 2.21 controlled the tagging ofEQ equipment with the green tag at the time the NCR was initiated. The response stated that the identification of EQ equipment is now controlled within the EQ program, green tags are no longer used and are Eeing removedfrom equipment as maintenance is performed. However, a review ofthe procedurefound no reference to the use ofgreen tagsfor equipment identification. The reason for the question was thefact that the NCR disposition inferred that the presence of the green tag alertedpersonnel that procedures be reviewedfor any special requirements that may apply.
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a ADMINISTRATIVE CONFERENCE NOTES Februtry 24,1998 5,
Topic: PDCR-2-166-78. (Roger Miller)
Background:
PDCR-2-166-78 refers to " additional loads - heat tracing, space heaters etc." as the reason for increasing breaker size.
Questions:
a) What PDCR added these additional loads and what calculations were done to evaluate the affect of the added loads on the diesel generator?
Response: No PDCR wasfound that addresses the addition ofthe non-safety related heaters. Loads that were added at the 120 volt level in 1978 would not have afected the Diesel Loading calculations, bscause calculations were based upon a percentage (typically 80%) ofbreaker and'or transformer rating.
6.
Topic: Procedure MP 2721D. (Daniel Wooddell)
Background:
Procedure MP 2721D, Emergency Diesel Generator Fire Water Connection to Engine Cooling System, Paragraph 1.2, states that the Fire Water System can supply 559 gpm of water for emergency diesel generator cooling.
Questions:
a) What method was used to determine the 559 gpm flow rate?
Response: The methodfor determining the 559 gymflow rate could not be located at the time of the conference call.
1 b) is this Dowpath periodically tested? If so, what procedure is used to perform the test?
Response: To be continued on 2/26/98.
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7.
Topic: Procedure CBM 107. (Daniel Wooddell)
Background:
Procedure CBM 107, Rev. O, Integrated Preventive Maintenance Program, was resiewed with the following questions:
Questions:
a) is equipment qualification (EQ) a consideration for performing scheduled PMs? If so, why isn't EO included in the CBM 107 PM reviews?
Response: EQ is considered in CBAi 107 reviews. Millstone is working to Rev.1 ofCBAf 107.
1 The latest revision available to Parsons is Rev. O. Rev. I will be requested via RAI.
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AOMINISTRATIVE CONFERENCE NOTES Februtry 24,1998 b) Section 1.11 of CBM 107 states that the IPMP Project Lead or the IPMP Unit Coordinator approves PM program change recommendations and initiates PM changes.
Is this the appropriate level of management for responsibility of PM Program changes?
Response: Rev.1 of CBAf 107 refers the user to CBAf 105 for PAf Program changes. CBAf 105 will be requested via RAI.
8.
Topic: Procedure CBM 102. (Daniel Wooddell)
Background:
Procedure CBM 102, sectiont.3 refers to an integrated diesel Predictive Maintenance Program.
)
i Questions:
i a) What document provides details of the Diesel Engine Predictive Maintenance Program?
Response: There is no specific predictive maintenance program for diesel engines at Afilistone.
CBAf Unit 403 is the administrative control document for the unit wide predictive maintenance program. CBAf 102 and the regularly scheduled diesel PAf's data is compiled into an evaluative report ofdiesel engine maintenance. Parsons will request CBAf Unit 403 via RAI.
9.
Topic: Engim?'..e, rrocedure Containing Valve Thmst Values. (Jim Collins)
Background:
In the description of condhion of NCR 293-012, a reference is made to EN21223 Rev 0 CH2. This appears a procedure for the source of allowable valve thrust values and is assumed to be an engineering EN procedure. During the ICAVP Tier 3 review of this i
NCR, a search of the WORLDVIEW database could not find the procedure, the procedure number could not be found in OSCAR, nor was it listed in the U2 Engineering EN Procedures Table of Contents.
Questions:
a) Is this an engineering procedure? If so, where can it be found?
b) If the procedure no longer exists, what has replaced it for the source of the thrust values?
Remonse: Deferred to 2/26/98 10.
Topic: Tier-2 Information Needs (Rich Glasiano)
Background:
Attachment B to the Parsons Bi-weekly status report to NNECo lists informatior. needed to complete validation of the Critical Design Characteristics associated with the FSAR Chapter 14 Accident Analyses. Included are listings of:
Preliminary DR's related to validation of Critical Design Characteristics
=
NNECo identified items related to validation of Critical Design Characteristics PAGE5
ACMINISTRATIVE CONFERENCE NOTES Febru:ry 24,1998 Chapter 14 events being reanalyzed by NNECc e
Misc. preliminary DR's from the Tier-2 review.
Questions:
a) Parsons wishes to discuss how the above information needs relate to completion of the Tier-2 Accident Mitigation Systems Review. Recommended attendees: Fougere, Mattioli.
t Response: Parsons stated that the Bl weeklyproject status report (as Attachment B) identifies information needs to complete the Tier-2 validation. DRs UIRs and accident analyses are identified.
NNECo is requested to provide estimated completion dates and closeoutpackagesfor items identified in Attachment B. This list will be included as a conference call agenda item on a weekly basis.
I1 Topic: EN 21137 (Lariy Collier)
Background:
Relative to Pump Vibration Monitoring, EN 21137 Resision10, Attachment 2 there is a column designated No. of Monitoring Points. The No. of Monitoring Points in this column seems to disagree with the number of monitoring points designated on each of the 4
individual attachment 4's. (i.e. The number of monitoring points on attachment 2 seems to be a multiple of the number of monitoring points listed on each individual attachment 4.)
Questions:
a) Which of the two, attachment 2 or attachment 4, is correct; or have the number of monitoring points been updated without updating attachment 4.7 i
Response: Attachment 4 shows the monitoring locations and attachment 2 shows the total number ofmonitoring points, generally 3 pointsfor each location. This a paraphrased answer.
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