ML20217Q242

Forwards 4 Drs Identified During Our Review of Activities for Independent CA Verification Program.Nineteen Drs for Which Nu Resolutions Have Been Reviewed & Accepted & Four Nu Resolutions That Have Been Reviewed & Not Accepted

ML20217Q242
Person / Time
Site:	Millstone
Issue date:	04/06/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9804100353
Download: ML20217Q242 (91)

Text

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Don K. Schopfer Senior Vice President 312-269-6078 April 61998 t Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed four (4) discrepancy reports (DR)s identified during our review activities for the i

ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.

DR No. DR-MP3-1092 DR No. DR-h@3-1094 l DR No. DR-MP3-1093 DR No. DR-MP3-1095 l

I have also enclosed the following nineteen (19) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0002 DR No. DR-MP3-0682 /

L DR No. DR-MP3-0068 DR No. DR-MP3-0836 f DR No. DR-MP3-0370 DR No. DR-MP3-0860 DR No. DR-MP3-0389 DR No. DR-MP3-0862 DR No. DR-MP3-0451 DR No. DR-MP3-0880 DR No. DR-MP3-0479 DR No. DR-MP3-0953 O[

DR No. DR-MP3-0494 DR No. DR-MP3-0967 DR No. DR-MP3-0623 DR No. DR-MP3-1000 DR No. DR-MP3-0671 DR No. DR-MP3-1029 DR No. DR-MP3-1048 i

P f l j

I 55 East Monroe Street

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

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United States Nuclear Regulatory Commission April 6,1998 Document Control Desk Project No. 9583-100 l Page 2 l

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-MP3-0029 DR No DR-MP3-0823 DR No. DR-MP3-0287 DR No DR-MP3-0971 Please direct any questions to me at (312) 269-6078.

Yours very truly,

%.7 A. O % -

D. K. hopfer 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 l m%avpben98WO406-a. doc i

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• DR No. DR-MP3-1092

• N:rthea:t Utilities ICAVP Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR VALID Review Element: Corrective Action Process p ,

Discipline: Operatons Om i Discrepancy Type: Corrective Acton implementaten g'  ;

I system / Process: N/A NRC significance level: 4 Date faxed to NU:

Date Published: 4/9/98 Dmcrepancy: Closure of CR M3-97-030 Descripuon: Related corrective action assignment AR 97002930-04 has been statused as complete in assignment tracking. The action involves inspection of expansion joints identified in ERC 25212-

- ER-97-0125 Rev.1, as referenced in Memo MP3-DE 1556 dated . __.___ _.__

November 24,1997. Memo MP3-DE-97-1556 states that the expansion joints listed in the ERC (referenced above) shall be covered by PEO rounds, namely SP3670.2-11. -12 and SP 3670.3-6 -10,-11, and -13.

Contrary to the above, our review indicates that the aforementioned surveillances do not cover inspection of expansion joints on PEO rounds, neither generally nor specifically. Some of the PEO round surveillance forms do address general inspection of a particular area however, with regard to expansion joints, such a checkoff on the OPS Form by itself would not be considered adequate since the goveming procedure (SP) does not contain guidance to the Operator covering expansion joints as part of the ' general" inspection made when PEO rounds are performed.

Review Valid invalid Needed Date O 3'3SS8 initiator: Navarro, Mark O O O 43S8 VT Lead: Ryan, Thomas J B O VT Mgr: schopfer, Don K g Q Q 4G98 IRC Chmn: singh, Anand K O O O dS8 I

Date:

INVALID:

Date:

RESOLUTION:

Previously identified by NU? O ves @ No Non Discrepant Condition?O ves @ No Resolunon Pending?O ves @ No Resoiution unresoived?O ves @ No Review Acceptable Not Acceptable Needed Date VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date:

sL Comments:

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Prhted 4/6,98 2.31:01 PM Page 1 of 1 l

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ICAVP DR ND. DR-MP3-1093

- N:rthest Utilities Millstone unit 3 Discrepancy Report Review Group: Programmatic DR VALID Review Element: Corrective Acton Process Discipline: Operations Om Discrepancy Type: Corrective Acton implementation g SysterrvProcess: N/A NRC Significance level: 4 Date faxed to NU:

Date Published: 49/98 Discrepancy: Closure of CR M3-97-0713

Description:

The issue described in this CR is with respect to adequacy of surveillances in verifying the operability of electrical busses pursuant to technical specifications 4.8.3.1 and 4.8.3.2. l Included in the closure package was related corrective action -

assignment AR 97005722-02 which was closed on the basis that procedures 3670.1-2 Rev. 9 and 3672.1-2 Rev.12 were issued to include checking indicated voltages.

1. Technical specification surveillance requirements 4.8.3.1 and 4.8.3.2 cover the vital 4160V,480V and 120V A.C. busses and the 125V D.C. busses. The procedure revisions indicated above were reviewed and it was noted that checking of indicated voltages is included with a note in both procedures (note 4 in OPS Form 3670.1-2, note 5 in OPS Form 3672.1-2) for the 480V busses only. The other vital AC busses and the vital 125V DC busses were not included nor was any justification or other i

explanation provided for such exclusion.

! 2. In addition, in the memo from J. Plourde to WhiteWE and .

I

! HallerJ dated 5/13/97 (copy contained in the closure package for l this CR), item (1) reads as follows: 'The term indicated bus ,

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voltages used in TS and Sury. procedure should be interpreted as bus nominal voltage, i.e.120V system (120V),480V system  :

l l (480V),4160V system (4160V). etc." The value for ' nominal' voltage documented in the above memo is not consistent with the notes added in the revised procedures for the 480V busses.

The notes indicate that " nominal" voltage requirements are provided to verify indicated voltage..." and the criteria provided on both OPS forms for the 480V busses is greater than or equal 450V. Since the value for nominal voltage discussed in the memo referenced above has not been disputed in the CR closure package documentation and since the nominal voltage value used in the procedure revisions differs, please provide the basis for the value used in the procedure revisions.

Note that reference M3-EV-970399, Rev. 0 (listed in section 7.14 of SP 3670.1 Rev. 9 Chg 2) was not contained in the closure package and was requested but could not be located. The reference evaluation number may not be correct.

Review Valid invalid Needed Date O 3/3ase initiator: Navarro, Mark 8 O

3/98 VT Lead: Ryan, Thomas J B O O VT Mgr: schopfer, Don K @ Q Q 4/3/98 IRC Chmn: strch, Anand K B O O 'S8 Page 1 of 2 Pnnted 4698 2:30:49 PM

ICAVP DR No. DR-MP3-1093 N rthout Utiliti:s Millstone Unit 3 Discrepancy Report Date:

INVALID:

Date:

RESOLUTION:

Previously identifled by NU7 O Yes (9) No Non Discrepent Condition?O Yes (e) No Resolution Pending70 Ye. @ No Re.oiution unre.oived70 Ye. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K -

IRC Chmn: Singh, Anand K Date:

SL Correnents:

Page 2 of 2 Pnnted 4698 2:30:50 PM

ICAVP DR N2. DR-MP3-1094

• N:rther.t Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR VALID Potential Operability issue Discipline: Mechancal Design Discrepancy Type: calculaton g System / Process: NEW NRc Significance level: 3 Date faxed to NU:

Date Published: N9/98 Discrepancy: Modeling of Air Conditioning Units in Calculation T-01528-S3

Description:

During review of calculation T-01528-S3, Rev,0

• Evaluation of ECCS Passive Failure in RSS Pump Cubicle" discrepancies regarding the modeling of the sensible and latent cooling capacity of the air conditioning units were identified.

1) Assumption 4.7 on page 9 assumes that the air conditioning units (3HVQ* ACUS 2A/B) operate at design conditions during the entire transient. At rated conditions the direct-expansion refrigerant cooling coil has a total capacity of 386,000 Btu /hr and a sensible capacity of 355,000 Blu/hr at entering air conditions of 104*Fdb/70.4*Fwb (at 18% RH). The sensible and latent cooling capacity of the coilis a function of the entering dry-bulb temperature and the moisture content of the air. As the moisture content of the entering air increases the sensible heat ratio (sensible capacity /lotal capacity) for the coil decreases. When this is accounted for in the GOTHIC model the resulting RSS Pump Cubicle temperature is expected to increase.

2) The results of the GOTHIC model show that the room temperatures are approx 120*F and 100 %RH. At this condition the capacity of the cooling coils is significantly higher than rated conditions. Calculation should address the ability of the air  !

conditioning units (3HVQ* ACUS 2A/B) to operate with this j loading. l Review Valid invalid Needed Date initiator: stout, M. D. B 0 0 * '98 I

VT Lead: Neri, Anthony A B O O +3/98

• 3'S8 l VT Mgr: schopfer, Don K B O O

• • S8 IRC Chmn: Singh, Anand K O O O Date:

l INVALID:

Date:

RESOLUTION:

Previously identified by NU? O Yes (9) No Non Discrepant condition?O Yes @S) No Resolution Pending?O Yes @ No ResolutionUnresolved?O Yes @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date:

Pnnted S6/98 2:30;33 PM Page 1 of 2

ICAVP DR No. DR-MP3-1094

. N rth art Utilitisa Millstone Unit 3 Discrepancy Report SL Comments:

l Page 2 of 2 Printed 4Y48 2:30:34 PM

ICAVP DR ND. DR-MP3-1096

. ' N:rthert Utilities Miiistone Unit 3 Discrepancy Report Review Group: systern DR VALID i Potential Operability issue Discipline: Mechanical Design Om Discrepancy Type: Calculation System / Process: NEW gg l

NRC Significance level: 3 Date faxed to NU:

Date Published: N9/98 Discrepancy: Weak Link Inputs to Motor Operated Valve Target Thrust / Torque i Calculations

Description:

There are six MOV target / thrust calculations which use the second weakest link rather than the weakest link for the determination of torque switch settings:

1. Calculation 89-094-0899ES, Rev. 6 (target thrust calculation for 3RSS*MV8837A&B/8838A&B) uses 21,733 lbs as the open valve thrust limit and as the open valve non-as-left thrust limit.

Calculation 94103-C-24, Rev. 4/CCN 1 (weak link calculation for 3RSS*MV8837A&B/8838A&B) is referenced for this input.

These input values are for the maximum thrust for the valve stem T-head. However, the T-head is identified as the second weakest link. Calculation 94103-C-24 Rev. 4/CCN 1 identifies the weakest link as the backseat. For the backseat, the open valve thrust limit and the open valve non-as-left thrust limit are 11,795 lbs. l l

2. Calculation 89-094-0997ES, Rev. 3 (target thrust calculation for 3RSS*MOV38A&B) uses 14,002 lbs as the open valvo thrust limit and 14,659 lbs as the open valve non-as-left thrust limit.

Calculation 94103-C-22, Rev. 3 (weak link calculation for 3RSS*MOV38A&B) is referenced for this input. These input values are for the maximum thrust for the valve stem T-head.

However, the T-head is identified as the second weakest link.

Calculation 94103-C-22, Rev. 3 identifies the weakest link as the backseat. For the backseat, the open valve thrust limit and the open valve non-as-left thrust limit are 12,977 lbs. i 1

3. Calculation 89-094-1027ES, Rev. 2/CCN 3 (target thrust calculation for 3OSS*MOV34A&B) uses 996 ft-lbs as the open valve torque limit and 1245 ft-lbs as the open valve non-as-left ,

torque limit. Calculation 94103-C-40, Rev. 3 (weak link calculation for 3OSS*MOV34A&B) is referenced for this input. i These input values are for the maximum torque for the valve shaft key. However, the valve shaft key is identified as the second weakest link. Calculation 94103-C-22, Rev. 3 identifies the weakest link as the valve disk pins. For the valve disk pins, the open valve torque limit is 396 ft-lbs and the open valve non-as-left torque limit is 804 ft-lbs.

4. Calculation 89-094-1029ES, Rev. 2 (target thrust calculation for 3SWP*MOV50A&B) uses 6458 ft-lbs es the open valve non-as-left torque limit. Calculation 94103-C 28, Rev. 2 (weak link calculation for 3SWP*MOV50A&B) is referenced for this input.

The open valve non-as-left torque limit of this calculation is 6599 ft lbs. This trascription error is in the conservative direction.

Printed N6/90 2:30.19 PM Page 1 of 2

ICAVP DR N9. DR-MP3-1095 N rthert Utilities l

Millstone Unit 3 Discrepancy Report

5. Calculation 89-094-1069M3, Rev. 3 (target thrust calculation for 3SWP*MOV102A, B, C & D) uses 7508 ft-lbs as the open valve torque limit and 14,033 ft-lbs as the open valve non-as-left torque limit. Calculation 94103-C-42, Rev. 3 (weak link calculation for 3SWP*MOV102A, B, C & D) is referenced for this input. These input values are for the maximum torque for the valve shaft. However, the valve shaft is identified as the second weakest link. Calculation 94103-C-42, Rev. 3 identifies the weakest link as the valve shaft key. For the valve shaft key, the open valve torque limit is 4623 ft-Ibs and the open valve non-as-left torque limit is 6214 ft-lbs.

6. Calculation 89-094-1076M3, Rev. 2/CCN 1 (target thrust calculation for 3SWP*MOV71 A&B) uses 1967 ft-lbs as the open valve torque limit. Calculation 94103-C-30, Rev,2 (weak link calculation for 3SWP*MOV71 A&B) is referenced for this input.

These input values are for the maximum toque for the disk.

However, the valve disk is identified as the second weakest link.

Calculation 94103-C-30, Rev. 2 identifies the weakest link as the valve disk pins. For the valve disk pins, the open valve torque limit is 1871 ft-lbs.

Review Valid inval6d Needed Date initiator: Wakeland, J. F. O O O 4/2/96 VT Lead: Neri, Anthony A O O O 4'3'S8 VT Mgr: Schopfer, Don K O O O 4'3/S8 .

d'4'S8 IRC Chnus: Singh, Anand K O O O Date:

INVALID:

Date:

RESOLUTION:

Previously identified by NU? O Yes @ No Non Discrepant Condition?O Yes (G) No Resolution Pending?O ve. @ No Re.oiution unre.oived?O ve. @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chrnn: Singh, Anand K Date:

, SL Cornments:

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Pnnted 4/6/98 2:30:19 PM Page 2 of 2

1 ICAVP DR N3. DR-MP3-0002

. Northext Utilities Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED

" # Potential Operability lasue Discipline: Mechanical Desig" Om Discrepancy Type: Design control Procedure g System / Process: N/A NRc Significance level: NA Date faxed to NU:

Date Published: 7/B/97 Discrepancy: Use of Later Versions of ASME Section XI

Description:

We have reviewed Station Administrative Procedure WC-3, Revision 0, titled "ASME Section XI Repair and Replacement Program" with Changes 1,2 and 3 effective February 3,1997 and Nuclear Group Procedure NGP 7.05, Revision 4, titled

• ASME Section XI Program for Repair, Replacement, and Modification Activities" effective September 21,1994. Based on these reviews we have noted the following discrepancies.

1. These procedures are ambiguous conceming the need to obtain prior NRC unit specific approval before using a later edition of ASME Section XI for a repair, replacement or modification. The edition and addenda of ASME Section XI required for repair, replacement and modification at each unit is defined in its Inservice inspection (ISI) Program. The ISI Program we have for Unit 3 (has 5/12/96 stamp) shows the 1983 Edition of Section XI with the Summer of 1983 Addenda, except that Class 2 welds are examined per the Summer of 1985 Addenda.

Section 1.1 of procedure WC-3 and paragraph 6.1.1 of procedure NGP 7.05 state that subsequent editions and addenda (of Section XI) may be used provided they are accepted by the I enforcement and regulatory authorities.

10 CFR 50.55a(g)(4)(iv) is referenced in Unit 3's ISI Program.

This regulation allows the use of subsequent editions and addenda of Section XI incorporated in 10 CFR 50.55a(b), subject to Commission approval on a unit specific basis. Thus, it is not sufficient that the later edition use be accepted on the basis of l

10 CFR 50.55a(b) alone, (Side Note: Draft Regulatory Guide DG-1050 issued February, 1997 (draft Revision 12 to Regulatory Guide 1.147) endorses Case N-389-1 without exceptions. Therefore, when this revision is issued and when a commitment to this Case is incorporated into Unit 3's ISI Program,the necessity to obtain prior NRC approval of the use of later editions of Section XI for repair, replacements and modifications will be precluded.)

2. The note on Attachment 5 to WC-3 references Regulatory Guide 1.83. This should be Regulatory Guide 1.85. This is a typographical error only.

3. The training requirements for Revision 0 to Procedure WC-3 and changes thereto are inconsistent. Changes 1 and 3 to Revision 0 of the procedure, which are minor changes, state U3d0rtr0ir G:"FO. !!O O!On CQU!rOf" 0 !On010y ,

Pr E8 PM 4

ICAVP DR N3. DR-MP3-0002

. N:rtheist Utilitie3 Millstone Unit 3 Discrepancy Report the initial issue of the procedure, states: *No familiarization required".

Review Valid invalid Needed Date initiator: sheppard, R. P. 8 O O S/13'S7 VT Lead: Ryan, Thomas J G O O S/13'S7 VT Mgr: Gehopfer, Don K S O O S/30/97 1 IRC Chmn: singh, Anand K G O O 7/3/97 Date:

INVALID:

Date: 4/2/98 RESOLUTION: Disposition:

CR M3-97 2079 was written to request corrections to WC-3.

Although this station procedure applies to all three Millstone units, each unit has a specific ISI program goveming repair and replacement of ASME Section XI components.

i Each of these ISI programs has a clear statement that use of later editions or addenda of ASME Section XI requires NRC approval. Item 1 of the subject DR was previously identified. In December of 1995 all three Millstone units requested NRC approval to use Code Case N-389-1, which would resolve this problem for all our plants, (ref. letter no. B15120 and B15659).

To date, we have neither received approval, nor has the NRC issued a revision to Reg. Guide 1.147. In the meantime, even though there is no possibility of any Millstone unit using unauthorized editions of the code, CR M3-97-2079 will require that WC 3 be revised to state NRC approval is required to use any subsequent editions and addenda of Section XI or portions thereof for Repair / Replacement actiivities that are beyond our specific plant ISI Program Section XI Code commitments.

Item 2 is an obvious typographical error that will be corrected.

Item 3 requires no action. WC-3, Rev. O was converted to the new format from ACP-QA-2.18 with no changes in instruction or responsibility, therefore no training was required. For subsequent changes or revisions, the procedure writer may, at his discretion, guided by DC 1, Attachment 5, determine that the subject of the change does or does not require familiarization.

Conclusion:

Each Millstone unit's ISI Program govems repair / replacement activities and each program clearly states that use of subsequent editions or addenda of Section XI requires NRC approval.

However, until NRC approves our use of Code Case N-389-1 or issues a revision to Reg. Guide 1.147. WC-3 will be changed to address use of Section XI outside of each specific ISI program. i The error identified in item 2 will be corrected, item 3 requires no action, since determination of training requirements may differ from one revision to another depending upon the nature of Printed 4/6/96 2:05:19 PM Page 2 of 4 l

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ICAVP DR Ns. DR-MP3-0002

. ' N2rthert Utilities Millstone Unit 3 Discrepancy Report the change. These items are administrative and are not startup '

related. CR M3-97-2079 will track these changes to completion.

2nd Response:

Disposition:

NU has concluded that DR-MP3-0002 does not represent a discrepant condition. DR-MP3-0002 raises 2 issues, ( 2a and 2b

) which are dispositioned as follows:

Item 2a: The control of ASME Section XI work at MP3 has always been performed by the ISI Coordinator who is charged with ensuring that the authorized ASME Section XI Edition and Addenda as defined in the Inservice Inspection Program are being used and that subsequent Editions and Addenda are utilized only if accepted by the enforcement and regulatory authorities. Prior to the issuance of WC-3, ASME Section XI work was controlled under the auspices of NGP 7.05 and NEO 7.05 which provided assurances that the authorized Edition and Addenda were being used ( See attached copies of NGP 7.05 Rev 4 and NEO 7.05 Revisions 3,2,1,0). There is no extent of conditions concem with this issue.

Item 2b: The statement that this issue was previously identified is incorrect. Code Case N-389-1 did not recognize that WC-3 was in error because no error existed. As previously configured, WC-3 provided sufficent assurances that the authorized ASME Section XI Edition and Addenda were being used since it mandated that all ASME Section XI work be reviewed by the ISI Coordinator who is responsible for ensuring that subsequent l Editions and Addenda are utilized only if accepted by the enforcement and regulatory authorities. Significance level criteria does not apply as these issues are not discrepant conditions.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0002 does not represent a discrepant condition. As detailed in the disposition, ASME Section XI work at MP3 is currently and has been historically properly controlled to ensure that the authorized Edition and Addenda of ASME Section XI are used and that that subsequent Editions and /.ddenda are utilized only if accepted by the enforcement and regulatory authorities. There is no extent of conditions concem with this issue. Additionally, the statement regarding prediscovery in the initial response to this discrepancy report was in error. Prediscovery is not an issue since Code Case N-389-1 did not recognize that WC-3 was in error because no error existed. Significance level criteria does not apply as these issues are not discrepant conditions.

Attachments:

1. NGP 7.05 Rev 42. NEO 7.05 Rev 33. NEO 7.05 Rev 24. NEO 7.05 Rev 15. N'dO 7.05 Rev 0 Pnnted 4/6/96 205:19 PM Page 3 of 4

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ICAVP DR N2. DR-MP3-0002

. N:rthea:t Utilities Millstone Unit 3 DjSCrepancy Repor!

l Previously identified by NU? U ves @ No Non Discrepm. 'ondstion?(8) vos O No Resolution Pending?O vos @ No Resolution Unresolved?O yes @ No Review i Initiator: Sheppard, R. P.

VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K l

lRC Chmn: Singh. Anand K Date: 4/2/98 sL comments: Review of ist Response:

1. The responses to parts 2 and 3 of the discrepancy are acceptable.

2. We accept your decision to revise procedure WC-3 to resolve {

the discrepancy in the future. However, the proposed resolution is incomplete for the following reasons:

a. The corrective actions do not address the extent of condition as it relates to past use of other editions of Section XI.

Specifically, what mechanism would have prevented the use of unapproved code editions in the past? ,

f

b. The statement " Item 1 of the DR was previously identified" is not supported by facts. it does not appear that the request for NRC approval for Code Case N-389-1 recognized that procedure WC-3 was in error.

Review of 2nd Response:

S&L agrees that this is not a d!screpant condition. S&L's review of ASME Section XI Repair and Replacement packages, modifications and procedure changes did not reveal any inappropriate use of later editions of Section XI. Therefore, the issue is reduced to a procedure question. Since the Unit 3 ISI Coordinator is involved in all of these changes, WC-3 did not I l

need to be as detailed as the case where the Coordinator would not be involved. WC-3 has been improved. Therefore, S&L agrees with NU's disposition.

t Printed 4@98 2:05:19 PM Page 4 of 4

1 ICAVP DR No. DR-MP3-0068 N':rthea:t Utiliti::s Millstone unit 3 Discrepancy Report j Review Group: Confguration DR RESOLUTION ACCEPTED Review Element: system installation p Discipline: Electncat Desig" Om Discrepancy Type: Installation implementation g System / Process: sWP NRC Significance level: NA Date faxed to NU:

Date Published: tor 30/97 Discrepancy: Cable Tray Cover not installed in Accordance with Drawing  !

Description:

Drawing EE-34TB Rev.1 (H-5) indicates the cover on tray riser 3TL7530 shall extend from elevation 29'-3" to 35'-8". The installed cover starts at elevation 22' extending upward to the end of the tray. The additional cover may affect the ampacity of the included power cables.

Review Valid invalid Needed Date initiator: sarver, T. L. O O O o'17/S7 VT Lead: Neri, Anthony A 8 0 0 20'17/S7 VT Mgr: schopfer, Don K O O O 1o/20/97 IRC Chmn: singh, Anand K O O O o/27/97 Date:

INVALID:

Date: 4/2/98 RESOLUTION: INITIAL RESPONSE:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0068, does not represent a discrepant condition.

Drawing EE-34TB depicts the tray cover to be installed on the top of the tray from EL 29'-3" to EL 35'-8" for separation purposes. Note 1 of EE-34TB references the general notes and legend on EE-34TA; on which Note 3 states:" Tray covers are detailed to minimum lengths and shall be installed to meet or exceed the specified lengths". Tray 3TL7530 is designed and installed with a ventilated cover vertically on the G.7 line wall in the ESF Bldg, from EL 18'-0" to EL 38'-0" in accordance with drawings EE-34AN & EE-34AU. When cable trays are continuously covered for traore then 6 feet with solid, unventilated covers, the cable ampacity rating should be de-rated as required by the NEC, (National Electrical Code) Section 318. NEC section 318-11(a), exception No.1 states: 'Where Cable trays are continuously covered for more than 6 feet (1.83m) with solid unventilated covers, not over 95 percent of the allowable ampacities of Tables 310-16 and 310-18 shall be permitted for multiconductor cables." From this reference it can be concluded that it is not necessary to derate the cables installed in cable trays with ventilated covers.

Significance Level criteria do not apply as this DR does not represent a discrepant condition.

Conclusion:

/ Page 1 of 3 Printed 4/6/90 2:05:40 PM

ICAVP DR N2. DR-MP3-0068 N:rthert Utilities Millstone Unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report, DR MP3-0068, does not represent a discrepant condition. Tray covers are detailed to minimum lengths and shall be installed to meet or exceed the specified lengths. Tray 3TL7530 is designed l

and installed with ventilated cover for separation purposes in accordance with drawings EE-34AN & EE-34AU and will not affect the ampacity of the included power cables. NEC (National Electrical Code) section 318-11(a), exception No.1 states:

"Where Cable trays are continuously covered for more than 6 l feet (1.83m) with solid unventilated covers, not over 95 percent of the allowable ampacities of Tables 310-16 and 310-18 shall be permitted for multiconductor cables." From this reference it can be concluded that it is not necessary to derate the cables installed in cable trays with ventilated covers. Significance Level criteria do not apply as this DR does not represent a alscrepant condition.

SECOND RESPONSE:

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0068, does not represent a discrepant condition.

Specification SP-EE-076 Rev. 5, Section 11.1.5 provides the engiaeering basis for installation of ventilated tray covers on "L" type cable trays. Section 11.1.5 specifies that ventilated cable tray covers are installed to maintain electrical separation and it references the 12179-CE 54 series drawinDs to provide installatian details. 1 The 12119 CE-54 (or 25212-35030) series drawings provide 1 generic tray cover installation instructions. General Note: # 1 of l drawing CE-54A states "All tray covers and barriers shall be installed to maintain the separation requirements of reference 1 ,

I (Spec 2400.000-350 Specification for Electrical Installation) and this drawing series?

Drawings CE 54D & E of the 54 series, provido tray cover installation details and special case instr.liation details. Note 3 of drawing D states: " Tray covers shall sr,an the cable tray length in its entirety. Where tray covers are di'nensioned, they shall be installed to the lengths indicated, at a minimum?

Section O-L of Drawing EE-34TB indicates the dimensioned length (minimum length of tray that has to be covered) in order to maintain adequate electrical separation. The tray cover spans the cable tray length (approx. 20') in its entirety which is in accordance with Note 3 on drawing 54D.

Significance Level criteria do not apply as this DR does not represent a discrepant condition.

I l

Conclusion:

l Page 2 or 3 Printed 4/6/98 2.osAo PM

Northsast Utilitics ICAVP Millstone Unit 3 DR No. DR-MP3-0068 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0068, does not represent a discrepant condition. The dimensions specified on drawing EE-34TB are the minimum cable tray cover dimensions to meet electrical separation requirements. Covering the entire tray length is acceptable and is specified on drawing CE-54D in Note 3.

Significance Level criteria do not apply as this DR does not represent a discrepant condition.

Prev 6ously identmed by NU? O Yes @ No Non Discrepant Condition?@ Yes Q No Resolution Pending?O Ye. @ No Re.osution unre.onved?O Ye. @ No Review initiator: Wamer, l. * * * * *

• VTLead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date: 4/2/98 SL Comments:

I Pnnted 4tV98 2:05:41 PM Page 3 of 3

r ICAVP DR N2. DR-MP3-0068 N:rthert Utilities Millstone Unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0068, does not represent a discrepant condition. The dimensions specified on drawing EE-34TB are the minimum cable tray cover dimensions to meet electrical separation requirements. Covering the entire tray length is acceptable and is specified on drawing CE 54D in Note 3.

Significance Level criteria do not apply as this DR does not represent a discrepant condition.

Previously ident6hed by NU? O Ye. (9) No Non Di.crepant cond6 tion?t#) Ye. O No Resolution Pending?O ve. @>No Re.oiuiion unre.oived?O ve. 9 No l

Review initiator: Warner,1.

VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 4/2/98 sL comments:

j I

l l

l l

1 i

l l

l f

Page 3 of 3 Pnnted 4/6/98 2:05 41 PM

f I

. N::rthert Utilities ICAVP DR N . DR-MP3-0370 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED j l

F'otential Operability issue l Discipline: Piping Design l Discrepancy Type: Calculation Om l System / Process: RsS g

NRC Significance level: NA Date faxed to NU:

Date Published: 10/23/97 l D6screpancy: Safety factors used for potentially non conforming welds may be unconservative 4

Description:

lit the process of reviewing the following documents, I (i) Calculation No. 79-236-397GP, Rev. 01, Fracture Mechanics Evaluation of Embedded Containment Sump Line (ii) SDP-RSS-01361M3,Rev. 04, 5/29/97 Stress Data Package, RSS and the additional references (iii) Newman and Raju, " Stress-Intensity Factors for intemal Surface Cracks in Cylindrical Pressure Vessels", Transactions of ASME, Vol.102, November 1980.

(iv) G.C.Sih, " Handbook of Stress Intensity Factors", institute of Fracture and Solid Mechanics, Lehigh University,1973.

we note the following:

Background:

1) Calculation 79-236-397GP,(i), is based on the formulations provided by Newman, reference (iii), for the Applied Stress intensity, Kl. On page 4 it is noted that: "This solution is valid to at least 90% through wall [ defects] . ."

The initial condition assumed for the evaluation is a 95% through wall defect which would have passed the initial hydro pressure test.

2)Furthermore, assumption 2) on page 12 acknowledges that "At j 95% they [the solution] may no longer be very accurate" and

"... substantial errors in the calculation of fatigue growth would not change the conclusions." i 3)The final acceptance of this condition is not based on demonstration that the end of design life condition satisfies the original design basis (ASME 111) but rather that the computed safety factors are comparable to those implied by the ASME Code. The computed safety factor is 3.0 whereas the stated ,

safety factor implied by ASME Section XI is 3.2.  !

Discussion:

Based on a review of reference (iii), we believe the limits of the Newman formulation are 80%, a defect with an alt ratio (crack depth to wall thickness) of 0.8.

l Ponted 4/6/98 2:06:03 PM Page 1 of 7

' i' ICAVP DR N2. DR-MP3-0370 N:rthest Utilities Millstone Unit 3 Discrepancy Report Therefore, the alt ratio (0.95) exceeds the limitation of the K1 stress intensity f actor formula. It is our opinion that it may not be conservative to use the formula for this higher alt ratio. This conclusion is based on a calculation using the Ki formula provided by Sih's Handbook (reference iv) for an edge crack on a finite width plate subject to tension loading.

Comparing the results of these two formulations yields the following; The ratio of Newman's Kl values for alt =0.95 and a/t=0.8 is 1.845 The ratio of Sih's Kl values for alt =0.95 and alt =0.8 is 9.035 i Therefore, the potential for a lower value of Kl will under predict the value of crack growth per load cycle, da/dN by the difference in K1 to the power 3.25.

It is also noted that the calculation identifies the design conditions for the affected piping as 235 degrees F, whereas the SDP (reference 11) identifies the maximum operating and design ,

temperatures as 257 degrees F and 260 degrees F, j respectively. This will have a nominal influence on the values j for Flow Stress (collapse) and KIC used.

Discrepancy:

The formulation used to calculate crack growth rates may be I

unconservative for the postulated alt ratio of 0.95 when compared to other methods. A higher growth rate would result in a lower safety factor than predicted and less than the stated safety factorimplied by ASME Section XI.

Review )

Valid invalki Needed Date i 10/2/97 Initiator: Olson, P.R. O O VT Lead: Neri, Anthony A B O O 10/10'S7 VT Mgr: schopfer, Don K O O O 10' 'S7 IRC Chmn: sin 0h, Anand K B O O 10/18'S7 Date:

INVALID: l Date: 4/1/98 RESOLUTION: M3-IRF-01374 Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0370, does not represent a discrepant condition.

NU concurs that the depth of the postulated flaw evaluated in the above referenced calculation was greater than the range of applicability of the equations used. This issue was acknowledged and discussed in the calculation.

Pnnted 4/6/98 2:06:04 PM Page 2 of 7

ICAVP DR N3. DR-MP3-0370

. Northert Utilities Millstone Unit 3 Discrepancy Report To address the specific issues identified in this DR, the following discussion is provided:

1) At the time that the calculation was performed, were there standards / equations (i.e. ASME or equivalent) available to evaluate deep (i.e. 95% through wall) part through wall flaws?

No. Based on a literature survey performed at that time, it was concluded that no equations were readily available to evaluate a 95% through wall flaw which was considered to be the bounding flaw size that could have survived the hydrostatic pressure test.

2) Are the equations used expected to yield reasonable and/or conservative results?

Yes. Equations for part-through wall flaws are not expected to result in grossly inaccurate results for deeper (i.e. > 80% through wall) flaws and are also expected to be conservative. The basis for this conclusion is that the Kl equations used to calculate the stress intensity are based on linear elastic fracture mechanics (LEFM) concepts which neglect any effects of crack tip yleiding typical of deep cracks (i.e. small remaining ligament).

Consideration of ligament yielding results in a lower K1 value since some of the potential crack propagating energy is converted to plastic strain. Furthermore, the Newman equations used in the calculation are the most conservative of the equations considered by ASME XI and included as part of the flaw acceptance standards as described in Attachment 3 of the calculation. These equations are also considered to be more accurate than those published by G. C. Sih in 1973 since Newman's equations included further technology advances and additional piping test data not available in 1973. Also, NU does not concur that an edge crack on a finite width plate provides a i better representation of the actual stress field around the crack l tip than the Newman equations used in the subject calculation. l l

3) Does the accuracy of the calculation impact the conclusion? )

l No. As the calculation acknowledges, there is the potential for inaccuracies in the calculated values. However, the purpose of the calculation was not to assess the structural integrity of a known flaw but rather to assess the potential crack growth of a postulated flaw. The calculation concluded that the 0.3562" postulated flaw would be expected to grow to approximately 0.35629' by the end of life of the plant. If one were to assume that the growth in crack depth was unconservative by a factor of 10, this would have an impact of approximately 0.2% on the final crack size. A factor of 100 would have an impact of approximately 2% on the final crack size. Since the purpose of a flaw tolerance evaluation is to assess the potential behavior of a flaw rather than to demonstrate strict regulatory compliance with any one specific requirement, inaccuracies of this magnitude (i.e. 2%) are considered to be within the overall accuracy of the evaluation. NU believes that the conclusion reached in the calculation that the postulated flaw is not expected to exhibit sianificant flaw orowth durina the life of the plant. remains valid Pnnted 4W98 2:06:04 PM Page 3 of 7 t____________

ICAVP DR N2. DR-MP3-0370

. Narthea:t Utilitie3 Millstone Unit 3 Discrepancy Report and appropriate. It should further be noted that the affected portion of the piping system has since been encased in concrete which provides additional structural support for the imposed loads. ,

Compliance with ASME 111.

Since ASME 111 does not allcw cracks to be left in service, any component / pipe which contains cracks ::an not be demonstrated to be in compliance with ASME Ill. The calculation acknowledged the fact that any location which contained a flaw similar to that evaluated in the calculation, would be outside of the limits of the ASME Code and therefore require regulatory approval.

Compliance with ASME XI margins of safety.

Page 9 of 14 of the calculation provides a comparison of the estimated normal and faulted margins of safety (i.e. 3.0 and 2.6  ;

respectively) compared to the ASME Code required margins of l safety (i.e. 3.2 and 1.4 respectively). The DR questions whether l the appropriate margins of safety are satisfied. i As discussed above, the purpose of the calculation was to demonstrate that future crack growth will not have a significant impact on the structural integrity of the piping. The margins of l safety provided on page 9 of the calculation are based primarily l

on the successful completion of a system hydrostatic pressure test at 155 psi as compared to the design pressure of 60 psi.

Even though the calculation states that the implied ASME margins of safety are 3.2 and 1.4,later Editions of the ASME I Code (i.e. lWB-3640) clarify the minimum required margins of I safety to be 2.77 and 1.39 respectively for circumferential flaws and 3.0 and 1.5 for axial flaws in stainless steel piping. Both of these values are equal to or less than the calculated marDins of 3.0 and 2.6 respectively.

Accuracy of the system design temperature The DR indicates that the calculation lists the system design temperature as 235' F while reference li) of the DR lists the design temperature as 260* F and that this discrepancy will have a nominal influence on the values for flow stress and KIC.

Although NU agrees that the actual design temperature is different from that provided by Stone & Webster in attachment 4 of reference I), this temperature was not used in the calculation and therefore has no impact on the results of the calculation.

The flow / collapse stress used in the calculation was obtained from the results of the testing provided in EPRI report NP-2472 (reference 2 of the calculation). Furthermore, the ASME XI, Flaw Evaluation Subcommittee has published the basis for the stainless steel evaluation procedures of IWB-3640 (Attachment 1 to this response). Page 2-5 discusses the concept of flow stress and defines it as 3Sm since this provides a reasonable estimate of the onset of plastic collapse in stainless steel pipina. Since the Printed 4@96 2:06:04 PM Page 4 of 7

ICAVP DR NO. DR-MP3-0370 N:stheast Utilities 1

Millstone Unit 3 Discrepancy Report i value of Sm for SA-312. TP304 material does not depend on temperature for temperatures less than 300* F (see ASME 111, i

l Appendix 1, Winter 1985 Addenda) a change in system design

' temperature from 235' F to 260* F will not impact the flow stress.

Furthermore, a slightly higher system design temperature has a beneficial impact on the fracture toughness (KIC) of the stainless steel because fracture toughness increases with increased temperature.

Based on the above discussion, NU has concluded that the results of the flaw tolerance eval;.'ation performed in the above calculation remain appropriate for its intended use. Significance Level Criteria does not apply because this is not a discrepant condition.

Attachment:

EPRI NP-4690-SR, " Evaluation of Flaws in Austenitic Steel Piping", Dated July 1986.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0370, does not represent a discrepant condition. The purpose of the subject calculation was to assess the potential for fatigue crack growth in embedded sections of the Recirculation Spray System piping through the end of the plant life using a flaw folerance approach.

NU concurs that the limiting flaw depth to thickness ratio was greater than the range of applicability of the equations used in the calculation. However, this issue was recognized and evaluated in the calculation with the conclusion that the expected accuracy of the results was consistent with the accuracy of a flaw tolerance evaluation. Significance Level Criteria does not apply as this is not a discrepant condition.

Second NU Response M3-IRF-01986 Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0370, does not represent a discrepant condition. S&L states that this issue can be brought to closure with verification that the required regulatory exemption for the Code weld condition was filed and granted. This issue was discussed with the NRC in a series of correspondence culminating with resolution documented in the NUREG - 1031 Safety Evaluation Report Supplement 4, Section 6.6.3.1, pages 6 7 and 6-8 ( See Attached ) which state "The staff determined that since Class 2 components in plants with construction permit applications docketed before May 14,1984, are not required by 10 CFR 50.55a to meet the requirements of Section ll1 of the ASME Code for Class 2 components, an i

exemption is not needed."

l Significance Level Criteria does not apply as this is not a discrepant condition.

I Attachments:1. NUREG-1031 Safety Evaluation Report Supplement 4 (Pages 6-7 and 6-8)

Page 5 of 7 Printed 4/6/98 706:04 PM

1 l

ICAVP DR No. DR-MP3-0370 q

. N:rtherst Utilities Millstone Unit 3 Discrepancy Report

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0370, does )

not represent a discrepant condition. S&L states that this issue can be brought to closure with verification that the required regulatory exemption for the Code weld condition was filed and granted. This issue was discussed with the NRC in a series of correspondence culminating with resolution documented in the NUREG - 1031 Safety Evaluation Report Supplement 4, Section 6.6.3.1, pages 6-7 and 6-8 ( See Attached ) which state "The staff determined that since Class 2 components in plants with construction permit applications docketed before May 14,1984, are not required by 10 CFR 50.55a to meet the requirements of Section 111 of the ASME Code for Class 2 components, an exemption is not needed."

Significance Level Criteria does not apply as this is not a discrepant condition.

Previously identified try NU? O Yes (9) No Non Discrepent Condition?@) Yes O No Resolution PendingtO ve. @ No Re.oiution unre.oiv.d?O ve. (*) No Review initiator: Olson, P.R.

VT Leed: Neri, Anthony A VT Mgr: Schopfu, Don K IRC Chmn: singh, Anand K Date: 4/1/98 SL comments: initial Comments Based on M3-IRF-01374 The conditions leading to the preparation of the subject calculation were that the embedded RSS sump line pipe welds had questionable documentation. Volumetric examinations to establish the actual weld condition was not possible.

Lacking any clear evidence to establish the condition of the welds, it would be prudent to assume that a weld defect may exist and that the defect would not meet ASME Section 111 Code limitations. Given that situation, an exemption request with regulatory approval would be required. This was recognized in conclusion 5 of the calculation and acknowledged in the response provided by NU.

S&L believes the final closure of the issue be based on verification that the req.ilred regulatory exemption was filed and granted. This aspect of the condition is not related to the resolution of any specific technical comment on the calculation itself, but related to the inherent assumption regarding the condition of the weld.

The NU response does not identify the documentation which supports the stated need for regulatory approval. Therefore, we request that NU identify the documentation that was provided to address the Code exemption for the weld condition.

Observations on the IRF disposition of technicalissues Pnnted 4W96 2:06:04 PM Page 6 of 7

. Northe ct Utilities ICAVP DR N2. DR-MP3-0370 Millstone Unit 3 Discrepancy Report The following observations are provided on NU's response to the technical issues raised in the DR. We do not believe these observations require further response from NU based on the following two considerations applicable to the issue at question; The subject piping experiences limited loading conditions (primarily pressure). In the absence of other loading or mechanisms which contribute to flaw growth, the expected propagation of an initial flaw would be small for a wide range of potential flaw sizes (an ratios) for which good predictive methods are available.

The postulation of an initial flaw with an an ratio of 0.95 is judged to be conservative given that included flaws encountered during acontrolled welding process would be expected to be much smaller.

Specific Observations on NU Responses it is noted that the 0.95 ah ratio for the postulated flaw size does not define a real upper bound limit at which a leak might be expected under the 155 psig hydro pressure. Using the method provided in the reference report, EPRI NP-4690-SR, an axial flaw with sa aA ratio of 0.99 and crack length of 2*t can be shown to have suvived the applided hydro test pressure. Therefore the initial con 6 tion for a " worst case" postulated flaw could have been even greater than used in the calculation.

The calculation addressed a potential flaw with an an ratio of 0.95 This case is outside of the limits of available predictive equations specifically developed for crack growth evaluations. In the absence of other published data, the Shi approach was suggested for this case as a point of comparison with the calculation's methods, albeit conservative or not.

Finally, the only load considered significant to potential crack growth is the pressure (hoop) stress effect. Given the DA ratio for the subject pipe, we do not believe the encasing concrete provides any significant additional structural support in the hoop direction that would arrest potential crack growth.

Final Comments Based on M3-lRF-01986 Based on the response provided by M3-IRF-01986, S&L agrees with NU's conclusion that this issue is a non discrepant condition.

Printed 4W98 2:06:04 PM Page 7 of 7 l

I DR Na. DR-MP3-0389 l N:rthea:t Utilities ICAVP Millstone Unit 3 Discrepancy Report l Review Group: System DR RESOLUTION ACCEPTED j Review Element: System Design Potential OperabiHty issue Discipline: Structural Design Discrepancy Type: Calculation Ow

@ No

~

SystenvProcess: N/A NRC Significance level: 4 Date faxed to NU:

Date Published: 1/17/98 Discrepancy: Microfiche is not available for pipe support calculations

Description:

We have requested the reference documents (Microfiche, E &

DCR, N & D etc.) for the following calculations. These i docurnents are not available per NU ICAVP Response ID Nos. l as listed below. Thus the review of the calculations can not be completed.

CALCULATION NO. NU RESPONSE I.D. NO. j NP(F)-Z60R-506-H001 1087 NP(F)-Z60R-261 H001 1087 NP(F)-Z707A-002 1087 NP(F)-Z545D-461 1120 NP(F)-Z545D-484 1120 NP(F)-Z545D-518 1120 NP(F)-Z545D-552 1120 NP(F)-Z545G-874 1120 l NP(F)-Z507A-064 1120 ,

1169 NP(F)-Z612A-119-H005 I I NP(F)-Z701A-001 1169

! NP(F)-Z615A-003-H003 1169 C36.11 1169 NP(F)-Z545J-1288 (EQ. MT.) 1169 NP(F)-Z545B-163 1154 NP(F)-Z-545D-473 1154 l C29.143 1154 l l

NP(F)-Z545B-245 1154 i NP(F)-Z545J-1304 1154 NP(F)-Z545A-086 1154 SEO-SE.34.339 1154 NP(F)-Z545J-1308(EQ. MT.) 1154 NP(F)-Z545J-1235 1154 NP(F)-Z545J-1221 1154 NP(F)-Z545J-1252 1154 NP(F)-Z545D-479 1154 NP(F)-Z545G-828 1154 SEO-SE.34.350 1171 SEO-SE.34.435 1171 NP(F)-Z545J-1286 (EQ. MT.) 1214 NP(F)-Z507A-039 1214 NP(F)-Z507A-017 1214 NP(F)-Z507A-018 1214 NP(F)-Z545J-1291 (EQ. MT.) 1214 CFSK-736DA-E194 1198 CFSK-737R-E17 1198 CFSK-736L-E4 1198 CFSK-736MA-E31 1198 c c-

~gea 2 " 4m <<no Printed 4/6/90 2:06:20 PM Page 1 of 3

. ' N:rtheart Utilities ICAVP DR No. DR-MP3-0389 Millstone Unit 3 Discrepancy Report CFSK-736KA-E16 1195 CFSK-736E-E237 1195 NP(F)-Z507A-008 1154 NP(F)-Z545J-1323 1154 NP(F)-Z612A-013-H014 558 NP(F)-Z798-062 721 NP(F)._Z19R-018-H001 1173 NP(F)-Z798-086 506 NP(F)-Z79B-003 506 ,

CFSK-732B-E156 506 l NP(F)-Z79B-064 506 CFSK-7328-E112 506 NP(F)-Z79R-008-H007 506 SEO-V1.051 506 NP(B)-1024-XC 910 NP(F)-2612A-077-H007 910 NP(B)-ZO19A 910 NP(B)-1016-XC 910 NP(F)-Z19R-716-H004 910 NP(F)-Z79C-138 332 NP(F)-Z19F-253 332 NP(F)-Z19F-007 332 NP(F)-Z19A-128 298 NP(B)-1029-XC 380 NP(F)-Z612A-046-H003 558 NP(F)-Z612A-046-H001 558 NP(F)-Z626A-015-H008 558 l

Review Vand invalid Needed Date initiator: Patel, A. 8 O O "

l VT Lead: Neri, Anthony A e O O '"

VT Mgr: schopfer, Don K 9 0 0 t'

• 1Rc Chmn: Singh, Anand K B O O ' '

• Date:  ;

INVALID:

Date: 3/31/98 l RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0389, has identified a condition not previously discovered by NU. The condition described in the DR was investigated under CR M3 0711 and has determined that no further CA is required. The missing documentation for these referenced documents will be recreated on an as needed basis. The addition of this  !

documentation will not revise the conclusion of the associated I I

calculations nor willit improve the quality of the plants fit, form or function. The body of the calculation provides the design bases, computer inputs and calculation / computer run results. It additionally provides the summary of the software level and version used in the original computer run and thus can be recreated when the additional information provided by the microfiche is needed. Because the design and licensing basis is  ;

supported by the text of the calculation, the additional microfiche j information is not required, unless modifications or specific  ;

Printed 4/6/96 2:06:21 PM Page 2 of 3

ICAVP DR N A DR-MP3-0389 N:rtherst Utilities Millstone Unit 3 Discrepancy Report operability reviews are needed. When this additional information is required, NU will supply the supporting analysis (microfiche) from the information which exists in the calculation, or create a new calculation. Because this is a normal and existing work practice, no additional corrective actions or AR assignments are necessary. It should be noted that the microfiche was located by NU for may other calculations and subsequently reviewed by S&L. Based on the S&L DRs received to date, a generic issue with these types of calculations or design interfaces has not been identified. Therefore NU has concluded this to be a Significance Level 4 issue.

Prev 6ously identmed by NU? O Yes @ No Non Discrepent Condit6on?O Yes @ No Resolution Pending?O ve. @ No Resolution Unresolvid?O yes @ No Review A ceptable Not Acceptable Needed Date N

VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 3/31/98 st comments: S & L has reviewed the support configurations and applied loads in lieu of the review of microfiche runs.

Based on the results of this review, it has been determined that no overstress conditions exists and that the output results are reasonable when assessed against the support geometry and magnitude of the applied loads.

Therefore, missing microfiche files are not a restart issue.

Also, based on the aforementioned reasoning, the significance level has been revised to level 4.

Printed 4/6/98 2:06:21 PM Page 3 of 3

r ICAVP DR Ns. DR-MP3-0451 N:sthert Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p Discipline: Mechanical Design Om Discrepancy Type: calculation g I System / Process: SWP NRC Significance level: 4 Date faxed to NU:

Date Published: 1o/23/97

Discrepancy

Calculation P(R) 1157 has been superceded but the calculation I has not been identified as superceded

Description:

Calculation P(R)1194, *ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," indicates on the l

original Rev. O cover page that it supercedes calculation l

P(R)1157,"ESF Building Flood Study: Maximum Flood Height in ESF Building due to Pipe Break." Calculation P(R)1157 (the document itself) has not beer: marked as " void" or " superceded."

Review Valid invalid Needed Date i

1 initiator: Launi, C. M. 8 O O 'o/S/S7 VT Lead: Neri, Anthony A O O O So/5 /S7 VT Mgr: Schopfer, Don K B O O 10/15/97 1RC Chmn: Singh, Anand K B O O ioria/97 Date:

INVAUD:

Date: 4/1/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0451, has 3 identified a condition not previously discovered by NU which j requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI- ,

20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0138 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0451, has .

identified a condition not previously discovered by NU which I requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010, it has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0138 has been written to develop and track resolution of this item per RP-4.

Prev 60usly identified by NU7 Q Yes @ No Non Discrepent Condation?O Yes @ No Resolution Pending70 vos @ No Resoiutioaunresolved70 vos @ No Review initiator: Launt, C. M.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Pnnted 4/6/98 2:06.47 PM Page 1 of 2 l

l

[

ICAVP DR Ns. DR-MP3-0451

. ' N:rthenzt Utiliti2a Millstone Unit 3 Discrepancy Report ou v, .. ~ ,. ~ m

.m.......

g D*: 4/1/98 at mments: This response is acceptable. This issue is being tracked and resolved via CR M3-98-0138.

i l

t i

i l

i l

l Printed 4596 2:06.47 PM Pe 2 of 2

I

, . Northert Utilitie3 ICAVP DR NA DR-MP3-0479 Millstone Unit 3 Discrepancy Report l

Review Group: System DR RESOLUTION ACCEPTED l l Potential Operability issue I j Disciplitw: Other Discrepancy Type: calculatkan System / Process: SWP g

NRC significance level: 4 Date faxed to NU: I l

Date Published: 1or26/97 Discrepancy: Math error in Calculation No.130(P), Rev. 0

Description:

Calculation No.130(P), Rev. O, " Service Water 1" Line Break."

This calculation calculated the flow rate through a 1" and 2" diameter line breaks in 1" and 2" diameter lines connected to a 26" service water line. The flow rate through a 2 inch diameter break was calculated to be 317.5 gpm. A mathematical error was made. The flow rate should be 530 gpm. This reduces the time to cover the floor of the service water pump cubicle to a depth of 1 foot from 55 minutes to 33 minutes. This calculation was not used as input to any of the other flooding calculations reviewed for the ICAVP. A review should be made to determine the use of this calculation. Depending on the outcome of this review, the Calculation No.130(P) should be either voided or revised.

Review Valid invalid Needed Date initiator: Launi. C. M. B 0 0 o/14/S7 VT Lead: Neri, Anthony A B O O $o' 5'S7 VT Mgr: Schopfer, Don K 8 0 0 1or20/97 BRC Chmn: Singh, Anand K B O O tor 2iis7 Date:

INVALID:

Date: 4/2/98 RESOLUTION: Disposition

• NU as concluded that discrepancy report, DR-MP3-0479 has identified a condition not previously discovered by NU which requires correction. Stone & Webster generated calculation 130(P) Rev 0 to determine the flow through a 1 inch line break in the Sevice Water Pump cubicle. The calc. incorrectly resulted in a flow rate of 317.5 GPM and the time to flood the cubicle to a depth of 1 foot is 55 mintes. The correct flow rate is 530 GPM and the time to flood the cubicle to a depth of 1 foot is 33 minutes. CR M3-97-3870 corrective action will be to void calculaion 130(P). This is a stand alone calculation which provides no input to the latest flood salysis and is not a design nput to any other calculations. Flooding is addressed in calculation 12179-P(R)-1072, Rev. 2,

• Service Water Cubicle l Flooding Hazards Analysis," which does not use any of the j values calculated in 130(P). The corrective actions will be completed post startup. I This condition does not affect system operability, and has no technical significance with respect to active calculations, and has been determined not to affect the conclusion of subsequent calculations. therefore, NU considers this a Significance Level 4 Printed 4T)/98 2:07:02 PM Page 1 of 2 I

ICAVP DR N::. DR-MP3-0479

- N:rther::t Utilities Milistone unit 3 Discrepancy Report issue.

Conclusion:

NU has concluded that discrepancy Report DR-MP3-0479, has identified a condition not previously discovered by NU which requires correction. The corrective action will void calculation 130(P) as described in CR MP3-97-3870. Since the condition does not affect systrn operability, no technical significance with respect to active calculations and will not affect subsequent calculations, NU considers this a Significance Level 4 issue. l Prev 6ously identined by NU? O Yes i@ No Non D'screpent Condition?O Yes (9) No ResolutionPending?O vos @ No ResolutionUnresolved?O veo @ No Review initiator: Launi. C. M.

VT Lead: Nort. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 4/2/98 SL Comments: Thie NU resolution of this discrepancy is acceptable. NU will void the calculaton since is is not used as input to any active calculation. Since the calculation was not used as input to any i existing calculation and since Calculation 130(P) will be voided, this discrepancy a Significance Level 4.

It should be noted that the disposition referencs Rev. 2 of Calculation No.12179-P(R) 1072. This is incorrect. The attached calculation to the NU response form is Rev. O, CR M3-97-3870 references Rev. O and Sargent & Lundy reviewed Rev. O.

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Northert Utilities ICAVP DR N3. DR-MP3-0494 Ministone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Otter Discrepancy Type: Calculation Om System / Process: SWP g

l NRC Significance level: 4 Date faxed to NU:

Date Pubilshed: 11/17/97 Discrepancy: Design inputs to Calc P(R) 1194 are not consistent with the latest l

controlled document I

Description:

Attachment 1 of Calculation No. P(R) 1194, Rev. 2, "ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break, " identifies the potential flooding sources for each cubicle in the ESF Bldg. For each of the flooding sources (pipelines), the highest potential pressure in the line was identified from the Stress Data Package for each system and recorded in Attachment 1. This pressure was used to determine the potential flow rate from a crack in the line. For the SWP system the Stress Data Package is in Calculation No. SDP-SWP-D1370M3, Rev.10, for the QSS in Calculation No. SDP-QSS-01358M3, Rev. 6 and for the RSS in Calculation No. SDP-RSS-01361 M3, Rev. 4. For Cubicles "C," *E," "K," "J," "L," and "P,"

the value for the pressure in Attachment 1 for some of the SWP, ,

OSS and RSS lines differs from the value in the Stress Data Package.

Cubicle "C": Lines RSS010-13-2 and RSS010-18-2 Cubicle "E": Line SWP003-59-3 Cubicle "J": Lines QSS012-24-2 and QSS008-32-4 Cubicle "K" Lines RSS010-5-2, RSS012-12-2, RSS010-18-2, RSS010-19-2 and RSS010-32-4 Cubicle "L" Lines RSS010-3-2, RSS010-5-2, RSS010-8-2, RSS010-9-2, RSS010-20-2, RSS010-33-4, RSS010-35-4, RSS008-46-2, RSS008-52-2 and RSS004-124-2 Cubicle "P" Line SWP003-59-3 This does not change the conclusions of the calculation because either the pressure is lower reducing the consequences of a flood or the break in the pipe is still bounded by other breaks with a greater flow rate.

Review Valid invalid Needed Date initiator: Launi. C. M. B 0 0 11/3'87 l

VT Laad: Neri. Anthony A O O O 2 /4'87 I VT Mgr: Schopfer, Don K O O O / o'87 IRC Chmn: Singh. Anand K B D 0 tir12/97 Date:

INVALID: 1 Prtrded 4/6/98 2:07:23 PM Page 1 of 2 l

. N:;rthemt Utilitie3 ICAVP DR N3. DR-MP3-0494 Millstone Unit 3 Discrepancy Report Date: 4/1/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0494, 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 M3-97-4140  !

has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0494, 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 M3-97-4140 has been written to develop and track resolution of this item per RP-4.

Previously identified by NU7 O Yes (8) No Non Discrepant Condition?O Yes (8) No Resolution Pending?O Yes @ No Resolution Unresolved?O Yes @ No Review Acceptable Not Acceptable Needed Date initiator: Launi, C. M.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K ,

IRC Chmn: Singh, Anand K Date: 4/1/98 SL Comnents: The NU response is acceptable. This issue is being tracked by CR M3-97-4140. The CR recommends to review and revise calculation P(R) 1194 as necessary.

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Printed 4/6/98 2:07:23 PM Page 2 of 2

ICAVP DR N2. DR-MP3-0623

. ' N:rthe :t Utilities Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p Discipline: Maintenance Discrepancy Type: Correcthe Action Ow

@~ No System / Process: N/A NRC significance level: 4 Date faxed to NU:

Date Published: 11/2497 Discrepancy: Criteria Determining which Vendor Technical Manuals Need Upgrading by Startup

Description:

Adverse Condition Report (ACR) 013783 is part of the "out-of-scope" Tier 3 review of corrective actions. The ACR deals with a procedure inadequacy which affects the maintenance of reactor trip switchgear. This ACR, together with other corrective action documents such as ACR M3-97-0295 and ACR 10562, addresses the broader problem of vendor technical manual inadequacies related to updating manuals with current vendor recommendations.

Section 1.7 of Procedure DC 16, Revision 0, is titled " Interim Recovery of Key Safety Related Vendor Technical Manuals".

Section 1.7 defines key safety related equipment as:

" Components which in the performance of their safety-related functions, change operating modes or positions". It is our understanding that most of these key manuals will be upgraded during Phase 2 (after startup).

No criteria or schedule was found, however, for determining when vendor technical manuals will be upgraded. Additionally, it was not evident which manuals will be upgraded by startup.

Review Valid invalid Needed Date initiator: sheppard, R. P. 8 O O $ $n/97 VT Lead: Ryan, Thomas J B D 0 11n/97 VT Mgr: schopfer, Don K B O O 15/10'97 IRc Chmn: singh, Anand K B O O 11/19'97 Date: 11/7/97 INVALID:

Date: 4/3/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0623, does not represent a discrepant condition. The criteria for the key safety related equipment list (KSREL) is defined in DC-16, Revision 0, Change 2, Section 1.8. The procedure requires that each Unit develop and maintain a Unit specific Key Safety Related Equipment List to include:

Consideration of primary safety significant components based upon design complexity, active safety function and the fundamental need to function upon demand.

Identification of associated safety significant components that Printed 46/98 2:08:35 PM Page 1 of 5

- N:rthea:t Utilitie3 ICAVP DR No. DR-MP3-0623 Millstone unit 3 Discrepancy Report l )

provide critical support functions to the primary components.

The Key Safety Related Equipment List (KSREL) for non-NSSS equipment at Millstone Unit 3 is comprised of 1149 components represented by 29 Vendor Technical Manuals (VTM). Technical Evaluation M3-EV-970326, Revision 0, " Key Safety Related Equipment List Components Selection at Mi!!s'one Unit 3" documents the list and its basis.

The KSREL selection addresses the safety functions of:

Make-up water to maintain S/G's as heat sink DC control power Ultimate heat sink cooling water flow Cooling water flow to vitalloads Cooling water flow to critical ECCS pumps (charging pump and SI)

Motor operator functionality for GL 89-10 MOVs Availability of emergency electrical power including engine, .

generator, bus transfers, l unloading / loading l Reactor trip Control Room habitability (air conditioning)

Containment depressurization  !

The KSREL documented in Technical Evaluation M3-EV-970326, Revision 0, represents Northeast Utilities' commitment for Millstone 3 relative to Generic Letter 90-03 " Relaxation of  ;

Staff Position in Generic Letter 83-28, item 2.2", including Supplement 1.

Attachment 2 provides the schedule for " upgrading" the VTMs associated with the Key Safety Related Components identified in Technical Evaluation M3-EV-970326, Revision O. It should be noted that AR#97020789 tracks the completion of the entire list of manuals on Attachment 2. There are only 9 manuals remaining to be completed at this time and all are well on their way to completion. The remaining KSREL VTMs will be

" upgraded" by February 15,1998. Completion of the 29 VTMs associated with the KSREL fulfills NU's commitment to GL 90-03.

As an " engineering improvement item", a long term VTM

" upgrade" effort is also scheduled (a portion of which is referred to as " Phase 2"in the DR). The scope of this effort encompasses VTMs for safety related components which, in the performance of their safety-related functions, change operating modes or positions. While " upgraded" to the same criteria, the components associated with these VTMs are not part of the KSREL.

I I A baselining effort to identify all vendor technical publications I associated with the enhancement effort is currently underway. It I is estimated that the overall VTM enhancement program for Millstone Unit 3 will require approximately 18 months to complete.

Pnnted 4698 2:08:35 PM Page 2 of 5

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. N:rthert Utilities ICAVP DR N3. DR-MP3-0623 Ministone Unit 3 Discrepancy Report The full scope of the 18 month " betterment" has not been completely defined. Scope definition is ongoing with consideration given to common vendors and equipment between multiple units, mairtenance and design activity history as well as Reliability Centered Maintenance information. Baseline of all vendor " publication" data is also ongoing to identify commonalities and for provision to PRC/ USA for continuing vendor recontracts. A/R 97028038 is tracking development of a long term schedule.

NSSS manuals are not included in the initial " upgrade" scope.

NU is in continuous contact with the vendor (e.g., vendor representatives are on site) and the majority of VTM information )

is processed via Nuclear Safety Engineering via NOOP 3.04. i Significance level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0623, does not represent a discrepant condition. The Key Safety Related Equipment List (KSREL) is documented in Technical Evaluation M3-EV-970326, Revision O. There is a schedule for upgrading the VTMs associated with the Key Safety Related Equipment identified in Technical Evaluation i M3-EV-970326, Revision 0. To date,20 of the 29 KSREL VTMs l have been upgraded and transmitted to Nuclear Document Services for distribution to Controlled Document Libraries. The remaining 9 KSREL VTMs will be upgraded by February 15, 1998.

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

l Attachments: Technical Evaluation M3-EV-970326, Millstone 3 KSREL and Associated Vendor Manuals Schedule, DC 16, Revision 0, Vendor Equipment Technical Information Program (VETIP) 2nd Response:

Disposition: NU has concluded that Discrepancy Report, DR-MP3-0623, has identified a condition not previously discovered by NU which requires correction. Revision 0 to the Key Safety l Related Equipment List (KSREL) did not include the RSS pumps. The philosophy of the KSREL was to exclude NSSS l vendor supplied equipment as communication with the NSSS vendor is typically good and maintained on a continuous basis.

The initial evaluation mistakenly considered the pumps "NSSS scope of supply" as part of the integrated ECCS System supplied l

under Specification 25212-001. Further evaluation has l

determined that the Containment Recirculation Pumps were procured under S&W design authority with Westinghouse interface. Therefore, these components are non-NSSS and have been added to the KSREL.

Pmted 4/6/98 2:08:35 PM Page 3 of 5 l

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ICAVP DR N3. DR-MP3-0623 l

, N:rthenct Utilities Millstone unit 3 Discrepancy Report Revision 1 to the KSREL has been issued and the associated Vendor Technical Manual (25212-044-001) has been " upgraded" ,

l to the requirements of Station Procedure DC-16.

NU considers this discrepancy as Significance level 4 as it does

. not effect the Licensing or Design basis of the RSS pumps.  !

Conclusion:

NU has concluded that Discrepancy Report, DR.

MP3-0623, has identified a condition not previously discovered by NU which requires correction. Revision 0 to the Key Safety Related Equipment List (KSREL) did not include the RSS pumps. The philosophy of the KSREL was to exclude NSSS ,

vendor supplied equipment as communication with the NSSS  !

vendor is typically good and maintained on a continuous basis. l

~

The initial evaluation mistakenly considered the pumps "NSSS scope of supply" as part of the integrated ECCS System supplied under Specification 25212-001. Further evaluation has determined that the Containment Recirculation Pumps were procured under S&W design authority with Westinghouse interface. Therefore, these components are non-NSSS and have been added to the KSREL.

Revision 1 to the KSREL has been issued and the associated Vendor Technical Manual (25212-044-001) has been " upgraded" ,

i to the requirements of Station Procedure DC-16.

NU considers this discrepancy as Significance level 4 as it does not effect the Licensing or Design basis of the RSS pumps.

Attachments - Key Safety Related Equipment List Components Selection at Millstone Unit 3 (Technical Evaluation M3-EV-970326, Revision 1), CR M3-98-1206 Previously identified by Nu? O Yes (#) No Non Discrepant Condition?Q Yes (@ No Resolution Pending?O Yes @ No Resolution Unresolved?O Yes @ No Review initiator: sheppard, R. P.

VT Lead: Ryan. Thomas J VT Mgr: Schopfer, Don K 1RC Chmn: singh, Anand K Date: 4/3/98 sL comments: S&L Comments on 1st Response:

1. The establishment of criteria for determining when vendor technical manuals will be updated and the schedule presented for this upgrading are acceptable.

2. The application of the above criteria is not consistent. The KSREL should include appropriate components in the RSS system which were not supplied as part of the NSSS, e.g., the RSS pumps.

S&L Comments on 2nd Response:

Pnnted 4/6/98 2:08:35 PM Page 4 of 5 I

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' - N:rthea:t Utilitie3 ICAVP DR N . DR-MP3-0623 Millstone Unit 3 Discrepancy Report S&L agrees that this discrepancy should be lowered to a Significance Level 4. The discrepancy was originally classified as Significance Level 3 since it was not clear that criteria or a schedule existed for upgrading vendor technical manuals. The valid discrepancy was that the Key Safety Related Equipment List did not include the RSS pumps and so the pump vendor was not contacted as frequently as necessary and the pump vendor technical manual was not scheduled to be upgraded before startup. Neither affected the licensing or design basis of the pumps. Therefore, lowering the significance levelis appropriate.

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ICAVP DR N2. DR-MP3-0671

. Northent Utilities Millstone Unit 3 Discrepancy Report i I

( Review Group: system DR RESOLUTION ACCEPTED i Review Element: System Design

( Discipline: Electrical Design Discrepancy Type: Calculation SystenVProcess: N/A NRC significance level: 4 Date faxed to NU:

Date Published: 12/8S7 f

Discrepancy: Cable resistance values were not colTectly transposed i (Calculation 230E)  ;

Description:

This calculation determines if adequate voltage is available across the relays and starter coil of the Charging Pump &

Component Cooling Water Pump Area Supply Fan j (3HVR*FN14A).

One of the cable resistance values was incorrectly transposed from Rev.0 to CCN-2 of the calculation. The resistance of Cable No. 3HVRAOC004 is listed as 0.85 ohms in Rev. O of the calculation but was transposed as 0.085 ohms in CCN-2, 1

l Also, the cable lengths used in the calculation are all shorter than the cable lengths listed in the NUSCO Cable and Raceway System. The source of these shorter lengths are from an interoffice correspondence included as Attachment D to Rev. O l

i of the calculation. An explaination of the basis for these shorter l

lengths should be included in the calculation.

There is only about 2 volts of margin in the calculation results (CCN-2 indicates that 85.2 volts are needed for the starter coil to pickup and 87.3 volts are available). Our review indicates that after correcting for the proper cable resistance on cable 3HVRAOC004 the available voltage at the statter coil will be below the pickup value even when using the shorter cable ,

l lengths. The MCC degraded voltage of 428 Volts, per calculation NL-042 Rev. 2. CCN #5, is the available voltage considered.

Review Val 6d invalid Needed Date initiator: Crockett, Ed. O O 15' 3S7 O

VT Lead: Neri, Anthony A B O O / 8/S7 VT Mgr: schopfer, Don K G O O 12/1/97 IRC Chmn: Singh, Anand K O O O $2/4/97 Date: l INVALID:

l Date: 3/31/98 RESOLUTION: INITIAL RESPONSE Resolution: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0671, has identified a condition not previously discovered by NU which requires correction. The cable resistance of cable 3HVRAOC004 ,

was indeed incorrectly transferred from revision 0 to CCNs 1 and l

Printed 4/6S8 2:14:12 PM Page 1 of is l l

ICAVP DR No. DR-MP3-0671 N:rthert Utilities Millstone Unit 3 Discrepancy Report 2 in calculation 230E. The cable length used in the calculation j was based on actual field measurements versus the values used q in the Cable and Raceway Program which are based on the j lengths shown on the cable pull tickets. The values shown on the cable pull tickets are the cable lengths of the cable as cut off the cable reel during pulling. These values are conservative but they do not account for excess cable at either end of the run which may be cut off at the time of termination. It is common practice, for circuits which may have voltage dmp concems, to use actual cable lengths in order to get a more accurate voltage drop value.

The actuallength of 3HVRAC004 has been field verified to be slightly less than 294 feet as used in the calculation and documented on the interoffice memo attached to calculation 230E. The request on the memo is for actual cable lengths for five cables and these actual lengths were provided in the memo response. This is the basis for using these values in the calculation and no further clarification is required. l The fact that there are some 480 volt and 120 voit devices which may not have adequate voltage under Degraded Voltage conditions has been previously identified and documented in ,

LER 97-010, CR M3-97-0119 and CR M3-97-0522. LER No. 97-  !

010 was issued as a result of CR No. M3-97-0119. This CR was written as result of the 10CFR50.54(f) assessment audit identifying that the 480V and 120V system calculations improperly evaluated circuit voltages for minimum input MCC voltages.

The corrective action plan for CR No. M3-97-0119 provided for a number of modifications (see DCR No. M3-97030, attached) to improve the minimum voltages available at the 480V and 120V levels. Calculation 230E was revised by CCN No. 3, as a result of this DR, to correct the cable impedance error and further refine the key cable and wiring impedances and recognize an increase in the minimum MCC voltage from 428V to 436V because of design modifications (DCR No. M3-97030) as a result of CR M3-97-0119 and LER 97-010. The CCN show that adequate voltage is available to the contactor coil. The CCN demonstrates 86.1V available to the coil that requires 85.2V as a minimum.

The calculation assessment program did not find the input error in calculation 230E, as this would have only been found under a line-by-line verification. Because various measures such as changing tap settings on the 480 voit load center transformers have been completed and because of the existence of conservatism and margin in the calculation, the discrepancy related to the calculational error in calculation 230E is a significance level 4 discrepancy as the fan is capable of meeting its design basis function, and the error is one of transposition that did not result in an unacceptable condition.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0671, has identified a condition not previously discovered by NU which Printed 4/6/98 2:14:13 PM Page 2 of 15

N:rthert Utilities ICAVP DR No. DR-MP3-0671 Millstone Unit 3 Discrepancy Report requires correction. The cable resistance of cable 3HVRAOC004 was indeed incorrectly transferred from revision 0 to CCNs 1 and 2 in calculation 230E. The cable length used in the calculation was based on actual field measurements versus the values used in the Cable and Raceway Program which are based on the lengths shown on the cable pull tickets. The actual length of 3HVRAC004 has been field verified to be less than 294 feet as

! used in the calculation and documented on the interoffice memo attached to calculation 230E. The request on the memo is for actual cable lengths for five cables and these actual lengths were provided in the memo response. This is the basis for using these values in the calculation and no further clarification is required.

The fact that there are some 480 volt and 120 volt devices which

( may not have adequate voltage under Degraded Voltage conditions has been previously identified and documented in i

LER 97-010, CR M3-97-0119 and CR M3-97-0522. t.ER No. 97-

! 010 was issued as a result of CR No. M3-97-0119. The corrective action plan for CR No. M3-97-0119 provided for a i

number of modifications to improve the minimum voltages available at the 480V and 120V levels. Calculation 230E was revised by CCN No. 3, as a result of this DR, to correct the cable impedance error and further refine the key cable and wiring impedances and recognize an increase in the minimum MCC voltage from 428V to 436V because of design modifications (DCR No. M3-97030) as a result of CR M3-97-0119 and LER 97-010. The CCN was able to demonstrate adequate voltage is available to the contactor coil. The CCN demonstrates 86.1V available to the coil that requires 85.2V as a minimum. Based on fan 3HVR*FN14A being capable of performing its design basis function, and the error being one of transposition that did not result in an unacceptable condition, this discrepancy should be a significance level 4.

SECOND RESPONSE Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0671, has identified a condition not previously discovered by NU which requires correction. The cable resistance of cable 3HVRAOC004 I was incorrectly transferred from revision 0 to CCNs 1 and 2 in calculation 230E. As reported in our initial response to this DR, a i

refinement of the calculation together with load center transformer tap changes have the cumulative effect of nullifying the consequence of the number transposition error. Correct operation of the starter contactoris assured at a voltage level corresponding to the lowest level which can exist and a degraded voltage condition is not declared with power remaining to be supplied by the offsite system.

This second submittal provides information required to address those issues identified in Sargent and Lundy's revised DR which placed the DR in Follow Up" status. NU has concluded that the Printed 4/6/98 2:14:13 PM Page 3 of 15 l

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ICAVP DR N2. DR-MP3-0671 i . N:rthert Utilities l

Millstone Unit 3 Discrepancy Report ,

I identified calculation number transposition error has no impact )'

on the conclusion. There is no impact on the design and/or license basis of the unit. This DR should be designated as a l Significance Level 4 item.

Background:

The following information is provided to assist in the resolution of this issue:  !

The degraded voltage (DV) issue and its potentla! Impact on nuclear safety related systems and equipment was first recognized in 1976 at Millstone Unit 2. While the term

" degraded" could be used to describe under as well as overvoltage conditions, it is commonly accepted as referring to the undervoltage condition. Prior to 1976, voltage on the safety related medium voltage buses (4kV at Millstone) was sensed and used as input to a breaker control scheme that was intended to respond to a power system degradation leading to a Loss of Offsite Power (LOP) condition. Nominally, nuclear units used voltage sensing relays with settings of from 50 to 80 percent of rated voltage together with a time delay having a setting of from one-half to two seconds to signal the LOP condition. This was based on the expectation that a voltage falling within that range and lasting for that duration would be an indication of a pending complete loss of voltage. If both the voltage level and duration conditions were met, positive automatic actions ensued to trip the nuclear unit free of the offsite power system, thus enabling the onsite power supplies to energize the safety related buses to i power safe shutdown and/or accident mitigation equipment. ]

)

In response to the 1976 event and based on design changes j developed at Millstone Station, NRC generic requirements were i published calling for a second set of relays and interfacing logic )

(now installed at all domestic units) having the capability to:

detect a sustained voltage degradation beyond which correct operation of safety related equipment could not be assured, tolerate short periods of voltage degradation due to starts of large motors or short term offsite power system transient events, and, trip the unit free of offsite power so that the onsite supplies can restore power of adequate voltage and frequency characteristics to the unit's emergency buses.

Further, analyses were required to demonstrate that for certain system and/or generating unit losses, a simultaneous trip of the analyzed nuclear unit would result in that unit remaining connected to the offsite power system. A recently issued information Notice (IN-98-07) details several events wherein this capability may have been compromised, aad wams of some of the potentially negative effects of electric industry deregulation on the reliability of offsite power.

Because MP 3 was designed and constructed over a period that

, enabled its oriainal desian to make provisions for the dearaded Printed 4/6/98 2:14:13 PM Page 4 of is

ICAVP DR No. DR-MP3-0671 Nrrthertt Utilities Millstone Unit 3 Discrepancy Report 4

voltage issue, the unit is advantaged relative to older units, in that low impedance transformers and generally larger than required cables were installed in the unit. Both of these features reduce voltage drop and make the unit more tolerant of a wider band of offsite power voltage swings than the adjacent units at Millstone Point. The offsite system voltage control band is, however, dictated by the most limiting unit at Millstone.

The process of selecting settings for the voltage relays and l timers used in the Degraded Voltage Schemes is one that, at the I outset, recognizes the need for engineering judgment. The l objective is to provide a balance which accepts reasonable short I duration equipment exposure to potentially " life reducing" overvoltage levels while providing the best opportunity for the

! unit to remain connected to the offsite power supply. Some considerations involved include the reqdrements to:

> identify through complex analyses, the most limiting voltage i condition, below which correct operation of safety related equipment cannot be assured, establish through interaction with those parties having responsibility for the control of transmission system voltage, a

" normal" voltage band or range, that is compatible with both the l nuclear unit and the " grid". Cleariy, the "best" compromise must I be struck, as each of the parties has to accept a limitation in  !

l flexibility in order to satisfy the other party, coordinate with transmission systems analysis experts, the nuclear unit's required response to those postulated system loss scenarios (contingencies) that are both transmission system coordination council and NRC mandated, based on the preceding determinations, establish the optimal l

selection of nuclear unit transformer taps, a set of degraded voltage setpoints including time delays, and the extent to which, under light load condition, equipment within the nuclear unit could be exposed to overvoltage, establish an overvoltage alarm setpoint which ensures that a sustained overvoltage condition will not go unnoticed, and, establish a set of operator actions and interactions with transmission system operators, to enable a correction of the overvoltage condition, thus minimizing the potential " life shortening" effects that may accompany sustained periods of operation under that condition.

l l

Incumbent in all of the above is the knowledge that:

the " acute" condition of unacceptable voltage degradation absolutely cannot be allowed to persist for periods longer than l could possibly result in damage to critical equipment (a matter of several seconds). Examples of the " acute" condition damage are a fuse blowing or inoperability such as the inability of the 3HVR*FN14A control circuit to pickup the contactor to ensure the safety function is accomplished, the " chronic" condition of overvoltage, while undesirable, is not measurably damaging to critical equipment in the short term and can be dealt with through manual actions, but must not go unnoticed. Examples of chronic overvoltaae effects would be a Printed 4/698 2:14:13 PM Page 5 of 15 l

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. N sthe%t Utilitie3 ICAVP DR N3. DR-MP3-0671 l

Millstone Unit 3 Discrepancy Report 4 loss of life in the electrical windings of a transformer or motor, the nuclear unit, during times of transmission system distress, should not add to that distress by automatically tripping due to a sensed condition (degraded voltage) that occurs as a result of that system's distress, and, in the event of the nuclear unit trip for reasons other than degraded voltage, the loss of the unit shall not create a transmission system condition (degraded voltage) that precludes the tripped unit from shutting down with the benefit of offsite power.

Thus, the balance that is struck is one that credits the unit's

! ability to tolerate periods of overvoltage, and the unit's inability

! to tolerate degraded voltage outside of established limiting values, and selects operating ranges and sensor setpoints which provide the unit its best opportunity to remain connected, and, in most cases, contributing to the transmission. In the event of a nuclear unit trip, in most instances, accident mitigation and safe shutdown equipment should remain powered from the offsite {

system and only place dependence on the onsite power supplies when absolutely necessary for the reasons discussed above.

Responses to Revised issues:

The following is a description of each of the (3) issues identified in Sargent and Lundy's revised DR and NU's responses to these:

Issue 1:

Changing the taps on the unit substation transformers in order to ra!se the minimum voltage also raises the lightly loaded voltage i on the same buses. Calculation NL-038, Rev 2, CCN # 7 was l prepared to assess increasing the voltage on the 480V load l centers during degraded grid conditions. Sargent and Lundy has identified a concem with NU's position that the only impact of degraded voltage is assumed to be accelerated aging and heating to the downstream components and that timely reduction of voltage is adequate to address this issue. Without a greater knowledge of the downstream components, Sargent and Lundy is unable to determine whether there are devices that would suffer " acute" versus " chronic" degradation.

NU Response: A brief description of the actions taken by NU to resolve the degraded voltage issue by changing transformer tap settings follows:

Millstone Unit 3 is equipped with two (2) trains of safety related electrical systems or buses. This discussion will be limited to one train, but is also directly applicable to the other.

The transformer tap change was driven by a need to raise the minimum voltage level at the Motor Control Center (MCC)-

related 480 volt buses and attached devices. Of the four (4)

Load Control Centers (LCCs) on each safety train, only two (2)

, feed MCCs. It is these two (2) LCCs whose transformer tap Printed 4/6/98 2:14:13 PM Page 6 of 15

. N:rthert Utiliti:s ICAVP DR Ns. DR-MP3-0671 Millstone Unit 3 Discrepancy Report ,

J settings were changed. Additionally, the SCV transformers had their taps changed to offset the higher voltages incurred by the 480V load center tap changes - the DCR impact only increased voltage on the Class 1E 480V system. At Millstone Station, a maximum switchyard voltage of 363 kv has been established l

requiring that, overvoltage calculations be run at this voltage level with the buses lightly loaded, essentially simulating a unit shutdown condition representing our worst case condition. Via calculation, it was determined that under light load conditions, and, with 363 kv in the switchyerd, a voltage level could be )

present on the 480 volt LCC buses of concem that exceeds MP j 3's most limiting the 4.16 kv to 480 volt LCC transformer. The manufacturer sets a limit of 105% of low side rated voltage when the transformer is at full load and 110% of low side rated voltage when at no load. These two (2) points correspond to voltage l levels of 504 and 528 volts, respectively. The high switchyard voltage / low unit load voltage run revealed that, in the worst case, I a voltage as high as 514 volts could be experienced on one of j the LCCs. l l

Since the low side winding voltage of these transformers is j exceeded for the fully loaded case (514 vice 504 volts), it was concluded that overvoltage alarms were required to be located at the LCC level, to ensure that Operations is aware of an overvoltage condition such that corrective actions could be taken. The selection and location of the overvoltage alarm at the LCC levei protects the 480V and 120V systems, the weak link is the transformer 105% rating (504V). Therefore this alarm provides an umbrella of protection for all the other devices / components.

These Operator actions were identified in our initial response and in your follow-up DR and, will therefore, not be repeated here.

The setpoint for these overvoltage alarms is derived in Calculation NL-042, and corresponds to a pick-up level of 506.5 volts and a drop-out level of 504 volts. The 506.5 volt pickup is j justified based on the knowledge that the limiting transformer is far from fully loaded; thus, a voltage selection near the low end of its 504 to 528 voit full load /no load capability was conservatively selected.

Attachments B through N to Calculation NL-038 provide detailed analyses of voltage levels at various equipment, including the maximum voltage that could be experienced given the 363 kv switchyard voltage / lightly loaded condition. While at no point in the unit does voltage reach the LCC transformer low side maximum of 514 volts, there are many cases wherein the established maximum acceptable voltsge is exceeded, but to a lesser degree than at the LCC transformer low side, in the worst case, if operator actions are ineffective, a voltage level of 1.6% above the manufacturer's rated maximum continuous voltage level could persist at some components.

This is clear 1y not an " acute" level of overvoltage wherein one would expect affects other than accelerated aging to occur.

Further, vitalinstrumentation is isolated from these conditions by Pnnted 4/6/96 2.14.13 PM Page 7 of 1s

r

. ' N:Irthert Utilitiea ICAVP DR N1 DR-MP3-0671 Millstone Unit 3 Discrepancy Report J the interven!ng uninternaptable power supplies (UPSs) and their l

dynamic voltage control systems. In cases where some instruments are powered by non UPS sources, regulating transformers are utilized, also providing voltage regulation to acceptable levels. Not included in the NL-038 calculation are i

the components attached to the non-regulated SCV transformer buses. Calculation (NL-038) stops at the SCV buses and Calculation 97-ENG-1512E3 takes over to evaluate the connected components which, while Q designated, are only Q by virtue of their connection to the safety related buses. Examples are motor heaters, Motor Operated Dampers with a fail-safe /no j power required function etc.

The Table in Attachment 1 presents the results of an assessment of electrical components installed during the 1990s, completed to determine if this more modem equipment is less capable relative to tolerance to an overvoltage condition than equipment of a .

vintage corresponding to MP 3's original design and equipment j procurement period. In no case, was a more limiting component identified. This review was completed in response to a question raised in the March 11,1997, telephone conference with Sargent  !

and Lundy on this DR.

Also in response to an item raised during the March 11 telephone call, NU reviewed for inclusion with this second response, the issue of 480 vac breaker interrupting capability while at elevated voltage levels. In the case of the MCC Molded Case Breakers, the capability of the devices was considered at the slightly elevated voltage and it was concluded that, for the light load /high voltage case, running load contribution to a three phase bolted fault at the worst location is significantly reduced. This, when combined with the breakers interrupting margin (22,000 amps rated vs.17,300 amps maximum available) is more than sufficient to conclude that these breakers will not be challenged beyond their design capability upon demand for removal of this faulted condition at a voltage level corresponding to 363 kv in the Millstone 345 kv Switchyard.

Similarly,if the unit and system operators are unsuccessful in their attempts to intercept a rise in voltage to a level corresponding to 363 kv in the switchyard, the 480 vac LCC breakers will be exposed to a voltage level of some 6 volts (514 volts vs. 508 volts) above their rating. For the light load /high voltage case, the reduction in running load contribution (about 3,000 amps) when combined with interrupting margin already existing (25,000 amps rated vs. 20,000 amps maximum available) at the ANSI-specified 508 volt level, more than compensates for the reduced interrupting capability of the breakers at the elevated voltage levels. We estimate a 30 %

l below rated capability maximum MP 3 fault level at a 1% over rated voltage level on the bus and breakers. This analysis is currently discussed in general terms in Calculations NL-038 an NL 051; however, it is difficult to follow these documents to this conclusion due to the large number of Calculation Change Notices (CCNs) posted against these.

Pnnted 4/6/98 2:14:13 PM Page 8 of 15

- N:rthert Utilities ICAVP DR N2. DR-MP3-0671 Millstone unit 3 Discrepancy Report NU has initiated AR# 97021088-10 to ensure that, post unit restart, a new revision to these calculations is completed to attempt to better clarify the rationale supporting acceptability of the described condition, and to incorporate the many outstanding DCNs. -

This is a positive action from the standpoints of clarification and bringing together in one document, all of the changes made to the calculation over the term since its last revision. This action is consistent with the recently revised Design Control Manual which requires key calculations (such as these) to be revised after no more than five (5) CCNs have been issued. These two (2) calculations currently have well in excess of five (5) CNN's outstanding, making their use unnecessarily confusing.

Based on the above, NU concludes that the protective features installed to ensure the operator is knowledgeable of potentially degrading overvoltage and the procedures to correct this condition via manual actions are in full conformance with industry and regulatory criteria. The potentially degrading affects of minor levels of overvoltage are " chronic"in nature and the equipment will therefore not be measurable impacted. On this basis, we submit that item 1 of the revised DR does not represent a discrepant condition.

Issue 2:

The second Sargent and Lundy item of the revised DR concems the impact of the voltage rating of the General Electric CR120B control relay in calculating the impedance and its application in determining starter terminal voltage.

NU Response: A voltage rating of 115 vac was considered in calculating the impedance for the CR 1208 relay in the attached Calculation 230E Rev.0 CCN-4. A follow up telephone call to GE has revealed that both the newer 115 vac and older 120 vac coils are physically the same with no difference in the tums ratios. The use of the 115v value will remain as a conservative approach in the calculation. A higher inrush current is used through a lower calculated inrush impedance using a 115V value for the CR1208 relay. On this % sis, we submit that this is not a discrepant condition.

, Issue 3:

The third item from the revised DR expresses a concem about using the rated no load voltage (128 vac) in calculating the control power transformer impedance as opposed to the nominal voltage rating (120 vac). The impact of both items 2 and 3 decreases the available voltage at the starter to 70.9% of rated voltage vs. 71% minimum required for the starter.

NU Response: Change notice 4 to the calculation incorporates the use of the higher voltage in determining the CPT impedance. Other factors incorporated into the calculation include resistance from the control circuit fuse and contact Pnnted 4/6/98 2:14:13 PM Page 9 of 15

f

. " N::rthe st Utilities ICAVP DR N2. DR-MP3-0671 Millstone Unit 3 Discrepancy Report resistance. Incorporating these changes along with a remodeling of the impedance for the Agastat relays using specific manufacturer's data has resulted in a starter terminal voltage of 86.88 volts compared with a published minimum pickup voltage of 85.2 volts. The original modeling of the Agastat relays was i more conservative using an inrush impedance that reflected a higher current draw than calculated using specific manufacturer's data (0.90 amps vs. 0.6 amps). The use of the higher no load voltage minimally impacts the voltage to the starter and other conservatism within the calculation more than offsets any I negative impact on the calculated starter terminal voltage. On this basis, we submit that this is not a discrepant condition.

l There is other conservatism that is not credited within the calculation such as:

l No diversity for MCC loading is assumed and therefore a higher l MCC voltage would be available.

One of the Agastat relays (62) provides a permissive for the starter,62A and 42X relays and can be credited for holding i

current / impedance rather than inrush.

l Field testing conducted on a NEMA size 3 starter has indicated a solid pickup at approximately 66% of nominal voltage.

l l

Conclusion:

i

! l l NU has concluded that Discrepancy Report, DR-MP3-0671, has I l identified a condition not previously discovered by NU which l requires correction. The cable resistance of cable 3HVRAOC004 was incorrectly transferred from revision 0 to CCNs 1 and 2 in calculation 230E. This transposition error is a Significance level 4 condition since the Licensing and Design Basis for the control circuits are not effected. CCN 3 to calculation 230E has corrected the transposition error.

l l The specific additional issues identified in the Sargent and Lundy response to NU's first submittal are all non discrepant conditions  ;

as detailed in the Disposition section of this IRF. Actions taken  !

to reach this conclusion for each of these three (3) items follow:

1. There is no specific identification of components and l evaluation of the failure modes during a potential overvoltage '

l condition.

l A narrative was provided describing the background of the degraded voltage /overvoltage issue and the manner in which Millstone 3 has arrived at an optimal set of transformer tap and sensing relay settings, A review of components purchased and installed in the 1990s time frame was completed and presented in this response, and a determination made that none of these are more limiting than that equipment originally specified and purchased for the unit, and, A discussion regarding the LCC and MCC breaker fault interruptina capability at voltage levels sliahtly in excess of their Pnnted 4/6/96 2:14:13 PM Page 10 of 15

ICAVP DR N2. DR-MP3-0671

. Northea:t Utilities Millstone unit 3 Discrepancy Report rating was completed and presented in this response.

Additionally, NU committed to add clarifying statements on this topic in the next change to the calculation of record. AR#

97021088-10 has been initiated to ensure that this work will be completed as part of a post-restart activity which will incorporate all outstanding DCNs into the calculation.

1. Voltage rating on the CR120B relay 115 vs.120 volts.

The results of discussions with the relay manufacturer's technical organization are provided in this response.

2. No-load voltage of the control transformers is 128 volts instead of 120 volts.

CCN 4 to the calculation included this consideration with no resulting impact on the overall conclusion of the calculation.

We note that this DR and the ensuing related discussions have all contributed positively to the quality level of the affected calculations and have resulted in a rnore firm basis for NU's determination of acceptability of Millstone 3's electrical distribution system.

Attachment 1 - Electrical Components installed During The 90's item IDfrype Description Approximate Comments Date of installation 1 CR1208 General electric 1995 to current 103.5 to 132 vac replacement (115v -10%

control relay and 120v+ 10% )

2 ITE Slemans Siemans 480 voit 1996 Voltage class of 600 vac HED4 Molded Case with interrupting rating l Circuit Breaker of 42K amps in a nominal 480 vac application.

Maximum MCC SSC is t

less than 18K amps.

3 E7000 Agastat timing relay 1995 to current 85% to 110% of Printed 4/6/96 2:14:13 PM Page 11 of 15

ICAVP DR N3. DR-MP3-0671

. N:rthert Utilities Millstone Unit 3 Discrepancy Report 120 vac rating l

4 Chromalox 480 volt electric 1992 to 1994 480/120 vac heater LUH-B heaters with

/ motor rating with +/-

l 43-32-00 120 voit blower motors

! 10% voltage capability on rating.

l l 5 Limitorque Motor Operated Valve 1995 to current l 460 vac rating with SMB Motors (used as +

l

10% voltage capability l Motors part of GL 89-10 per NEMA Standard Operator upgrades)

(intermittent duty motors l

l with low voltage start l

capability as specified for application) l 6 NH-91-95 ITT Corporation 1996 to 1997 120 vac motors with a l Motor Operated 132 l vac (+10% certified Damper Motors upper rating) l 7 27N/59N Solid State Under 1997 l Rated for sense level and overvoltage relays to 150v and 160 v,

! respectively. Control voltage is DC.

l 8 120 vac ASCO Used in Misc. 1986 to current Rated for upper limit of +

Solenoid Applications 10%,

but not for indefinite Valves mainly as periods (recognizes AOV pilot valves loss of life)

Pmted N6/98 2:14:13 PM Page 12 of 15

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, N:rthert Utilitie3 ICAVP DR N3. DR-MP3-0671 Millstone Unit 3 Discrepancy Report Previously identified by NU? O Yes (#) No Non Discrepant Condstion?O Yes @ No Resolution Pending?O ve. @ No ResolvhonUnresolved?O ves @ No Review initiator: Womer, l.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 3/31/98 ,

sL comments: INITIAL COMMENTS SL Comments: We have confirmed that degraded voltage 5 condition issues were identified and documented in LER 97-010 (dated 2-28-97), CR M3-97-0119 (dated 1-3-97) and CR M3 0522 (dated 4-16-97).

We have reviewed the calculations and acknowledge the principal actions taken by NU which were to correct the transposed cable ,

impedance in the calculation, reduce the lengths of some of the l cables based on field measurements, and raise the minimum I voltage of the motor control center to 436 Volts. CCN 10 to Calculation NL-038 confirms that the voltage at the motor control center is 436V under degraded voltage conditions. (See Duke Engineering & Services Calculation VN4500-F02-001, Revision 5, page B2.)

However, based on the information provided we have incomplete data to concur with the conclusion that the issue defined in the D/R is acceptably analyzed. The issues that are open are:

1. Changing the taps on the unit substation transformers in order to raise the minimum voltage also raises the lightly loaded voltage on the same buses. Calculation NL-038, Rev. 2, CCN #7 i was prepared to assess increasing the voltage on the 480V load centers during degraded grid conditions.

INPUT FROM DESIGN DATA:

Per Page 9 of DCR# M3-97-030,"During elevated grid conditions and/or the plant is in refuel outage, with fewer critical loads energized, the voltage could exceed the 105% maximum. This could cause accelerated aging / heating to the transformer and downstream components..." j l Per Page 13 of DCR# M3-97-030," Calculation NL-038, Rev. 2,  !

CCN #7, concluded that with the tap change modifications being done by this DCR, there is a chance of overvoltage on the 480V load centers when switchyard voltage is at or near the maximum expected voltage range. ABB 59N overvoltage relays will be  !

cdded by this DCR to provide control room annunciator to signal the need to take compensatory action to prevent possible equipment damage from the overvoltage."

Operating Procedure 3353.MB8B indicates that if in MODE 5. 6, Pnnted 4/6/98 2:14:14 PM Page 13 of 15

) .

ICAVP DR ND. DR-MP3-0671

! , N:rthert Utilities Millstone Unit 3 Discrepancy Report or 0, if Vital load center voltage is high one of the following actions is to be performed:

Cross tie affected load center Add additional load to the affected load center l Request CONVEX to lower grid voltage CONCERNS:

The unstated assumption in the DCR is that the only failure mode associated with overvoltage is accelerated aging / heating to downstream components and that timely reduction of voltage !s i adequate to address the issue. This assumption has two  !

weaknesses,1) the downstream components are not identified,2) there may be other failure modes associated with overvoltage, e.g., solid state components may actually fail.

Without an identification of the downstream components and an evaluation of the failure modes during overvoltage we could not confirm that raising the tap settings is acceptable.

i

2. The rated voltage of the typical General Electric CR120B control relay uted for 42X is 115 volts not 120 volts as shown in the calculation cited for the impedance of this relay. The result of the lower coil voltage is a reduction in the relay impedance and l l

an increase in the current drawn by the relay. While it is true that j a 120 volt,60 Hz /110 volt,50 Hz coil was available, the most  !

commonly used coil, the one rated 115 volt,60 Hz, is the one that was probably used. l

3. The rated no load voltage of the control transfonner is 128 volts with a 3% tolerance. However, the calculation assumed a base voltage of 120 volts, which is inconsistent with the transformer tums ratio. Using the proper base voltage increases the impedance of the control transformer to 2.097 + J 0.802 ohms compared to the value used in the calculation of 1.958 + j 0.749 ohms.

l l The use of these values (i.e., a control transformer base voltage l of 128 V and a GE relay coil voltage rating of 115 V) in the l calculation results in an inrush voltage of 65.1 volts or 70.9% of 120 volts across the contactor,42, and the Essociated auxiliary relay,42X. A minimum of 71% of 120 volts is required to pick up the contactor reliably. It should be noted that some minor impedances such as the resistance across closed contacts and that of the control circuit fuses were not included or considered l within the calculation. The inclusion of these would lower the circuit voltages slightly.

Our review of the calculation indicates that the voltage required at the contactor will be fractionally below the minimum voltage required by the calculation. Without specific contactor test data to verify that the equipment will operate at the calculated voltage (71% of the coil rating is the minimum voltage allowed and 70.9%

is calculated to be available) we cannot confirm that the minimum setpoint of 436V is adeouate.

Printed 4598 2:14:14 PM Page 14 of 15

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. N:rthenet Utiliti3s ICAVP DR No. DR-MP3-0671 Millstone Unit 3 Discrepancy Report SECOND RESPONSE COMMENTS: NONE f

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Printed 4%8 2;14;j4 pg Page 15 of 15

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. N:rthent Utilities ICAVP DR No. DR-MP3-0682 Millstone Unit 3 Discrepancy Report l Review Group; system DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design Potential %apy issue f j Discrepancy Type: Calculation Om i

@ No i

System / Process: N/A NRC Signifcance level: 4 Date faxed to NU:

Date Published: 12/20/97 Discrepancy: Calculation US(B)-349 l

Description:

The purpose of Calculation US(B)-349, Rev. O is to I conservatively quantify the containment mixing rate between the {

sprayed and unsprayed regions as a function of time during the '

l time when the quench spray operates following a LOCA. The mixing rate will be used in accident dose calculations.

l Three discrepancies were identified in Calculation US(B)-349,

1. The is no valid basis for the sprayed volume within the I containment of 902,000 ft3. This volume is taken from Reference 2 (Calculation US(B)-280, Rev.0). However, CCN 1 for US(B)-280 voids Calculation US(B)-280. Additionally, Reference 3 (Calculation US(B)-341, Rev.1) page 11 (not page

20) uses the value of 902,000 ft3 to determine a total sprayed volume of 1,166,200 ft3 (page 15 of US(B)-349). Therefore, cannot verify the spray volume of 1,166,200 ft3, due to the quench spray, used in calculation US(B)-349.

2. The maximum flow rates identified on page 19 for quench sprays (6400 gpm) and LHSI (9700.2 gpm) are not consistent l

with Calculation US(B)-295, Rev. 5, CCN 1. Calculation US(B)-

295 identifies the runout flow rate for two QSS pumps as 6500 gpm, and the runout flow rate for 2 RHR pumps as 10,200 gpm (CCN 1, page 5). The higher flows would be more conservative than the flow rates used in the calculation since the earliest time l

for quench spray to stop would be less than the time calculated on page 20 of US(B)-349.

l l

3. The time of 2330.6 seconds (39 minutes) (page 20) for the j l earliest time the LHSI could stop drawing from the RWST is not l consistent with US(B)-295, Rev. 5, CCN 1. The minimum time l l to drain the RWST is 33 minutes (US(B)-295). This time

! difference affects the time calculated on page 20 of US(B)-349 for when quench spray would stop. Quench spray would stop earlier than calculated in US(B)-349.

A revision to Calculation US(B)-349 to evaluate the above discrepancies should be performed.

Review Valid invalid Needed Date initiator: Wakeland. J. F. 8 0 0 12/8/97 VT Lead: Nort, Anthony A B O O 2/9/97 VT Mgr: Schopfer. Don K B O O 2/11/97 IRC Chmn: singh, Anand K S O O 2/16/97 Date:

Printed 4/6/98 2:15:28 PM Page 1 of 3

DR N;. DR-MP3-0682

, Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report INV ALIU; Date: 3/31/98 )

RESOLUTION: DISPOSITION: 1 NU has concluded that the issues reported in Discrepancy Report DR MP3-0682 are conditions not previously discovered by NU which require correction. The approved corTective action plan for CR M3-98-0769 (attached) will correct Calculation US(B)-

349 with respect to each of the three discrepancies identified.

The revised results will then be carried forward into the calculations and documents which use results from US(B)-349.  ;

CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action plan will l be completed by May 31,1998, and will ensure that the errors in US(B)-349 are cleariy identified and addressed. The corrective action plan for CR M3-98-0769 is tied to CR M3-98-0619 by AR 98002805.

As part of the ICAVP program, trending CR M3-98-1132 has been written to ensure that any process-related issues related to these calculations are clearly identified and are being dealt with. i l

This assessmcot is scheduled to be completed prior to Startup.

Each of the discrepancies identified in DR-MP3-0682 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR-MP3-0682 significantly affect the results of the RSS related calculations, or the conclusion that the RSS system meets its design basis, in addition, each of these discrepancies has been reviewed by NU design engineers, who have further determined that none of the discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis. Therefore NU has conicuded this to be a Significance Lesel 4 issue.

CONCLUSION:

NU has concluded that the issues reported in Discrepancy Report DR-MP3-0682 are conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0769 (attached) will correct Calculation US(B)-

349 with respect to each of the three discrepancies identified, in addition, an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure I that these issues are clearly identified and addressed. Each of the discrepancies identified in DR-MP3-0682 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS System meets its design basis. As such there is no effect on the license or desyn basis. Therefore NU has conicuded this to be a Significance Level 4 issue.

Previously identified by NU7 O Yes @ No Non Discrepant Condition?Q Yes (9) No Printed 4'6/98 2:15:28 PM Page 2 of 3 i I

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ICAVP DR Ns. DR-MP3-0682

. ' Northent Utilities Millstone unit 3 Discrepancy Report ResolutionPending70 Yes (9) No ResolutionUnresolved70 Yes (#_) No l Review Innlator: Wakeland, J. F.

O **

VT Lead: Neri. Anthony A VT Mgr: schopfer. Don K IRC Chmn: singh, Anand K Date: 3/31/98 sL Correnents: Sargent & Lundy concurs that CR M3-98-0769 will correct the discrepancies in Calculation US(B)-349, Rev . O, reported in DR-MP3-0682.

The significance of the errors in US(B)-349, Rev. O identified in DR-MPS-0682 have been evaluated. The :iciusion of this evaluation is documented in Stone & Webster Letter SRE-MP3-9805, dated 3-6-98. Based on this and on the engineering Judgment of the ICVAP reviewer, Sargent & Lundy concurs that the cumulative effect of the errors identified in DR MP3-0682 is minor and the NRC Significance Level should be changed to level 4.

In addition to the specific corrections to US(B)-349, Rev. O of CR M3-98-0769, NU is addressing the generic implications of these types of errors in CR M3-96-0619 and is addressing the potential for any programmatic defficiencies in CR M3-98-1132.

l Pr6nted 4/6/98 2:15:29 PM Page 3 of 3 l

i i 1

1 DR N2, DR-MP3-0836

, N:rthert Utilities ICAVP Millstone Unit 3 Discrepancy Report ]

which ventilation system is discharging into the plenum. This I ensures the design flow rates for each system are maintained within acceptable limits. The modulating function is not an essential function as defined in 10 CFR 50 part 36 and therefore is not required to meet Reg. Guide 1.105 or ANSI /ISA-S67.04-1988 requirements. Calculation SP-3HVR-51 provides the basis and methodology used in determining the controller setpoint. The acceptable system design flow rates are given as ( 10 % which encompasses the instrument uncertainties and therefore, inclusion of instrument uncertainties in the setpoint is not applicable.

The function of temperature controller 3HVP* TIC 29A (B) is to increase the availability and reliability of the Diesel Generator system, but from the safety system viewpoint, it does not perform an essential function as defined in 10 CFR 50 part 36 and therefore is not required to meet Reg. Guide 1.105 or ANSI /ISA-S67.04-1988 requirements. Temperature controller 3HVP* TIC 29A (B) modulate the Diesel Generator enclosure inlet, recirculation, and outlet dampers to maintain the enclosure temperature below 120 degrees F. A nominal setpoint value of 75 oF was selected based on engineering judgment as the starting point to start modulating the ventilation dampers. The selected value helps to maintain the enclosure at a lower overall temperature while providing a more desirable environment for equipment, systems and personnel.

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

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0836, does not represent a discrepant condition. NU has concluded that Reg. Guide 1.105 requirements are not applicable to these devices and therefore are not required to have instrument uncertainties included in their setpoints.

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

Previously identified by NU? O Yes @ No Non Discrepant Condition?T) Yes Q No Resoluuon Pending?O ve. @ No Re.oiution unr. iv.d70 ve. @ No Review initiator: Rced, William.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh. Anand K Date: 3/30/98 SL Comments: The 17,500 cfm +/-10% addresses the minimum flow for the 3HVR*FN6A/B fans, therefore, S&L agrees that the item documented by DR-MP3-0847 is not a discrepant condition. l l

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Pnnted 4/6/98 2:26:s7 PM Page 2 of 2 l

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ICAVP DR N2. DR-MP3-0860 l ,

Northert Utilitie3 l

Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design l

Pential OperabHMy lasue Discipline: Piping Design O ve.

Discrepancy Type: Calculaton

@ No System / Process: DGX l NRC Significance level: 4 Date faxed to NU:

Date Published: 1/17/98 Discrepancy: Pipe stress Calculations have unconfirmed assumptions

Description:

During the review of DGS System piping calculations, (i) 12179-NP(F)-X6007- Rev. O, CCN-2.

(ii) 12179-NP(F)-X6006-Rev. O CCN-1 we noted the following discrepancies:

1. Calculations (i) & (ii) require confirmation for assumptions 2(a), (b), (c), & 3,

2. Qualification calculations for Flexhoses 3EGS*1 A,1B,2A &

2B are not identified.

3 Equipment Nozzle loads were generated and transmitted to the stress reconcillation group. However no documentation is provided for the qualification and acceptance of these loads.

4. According to (i) & (ii) Stress Data Package SDP-EGO-O is to be issued

• Date--Later

• This SDP was not issued.

Review Valid invalid Needed Date initiator: Jain. R. C. O O O 12r22/97 VT Lead: Neri, Anthony A B D 0 2/20ts7 VT Mgr: Schopfer, Don K O O O 12/23/97 O 5'13'98 IRC Chmn: singh, Anand K O O Date:

INVALID:

Date: 3/30/98 RESOLUTION: Disposition: Response ID: M3-IRF-01672 NU has concluded that items 1,2 and 4 reported in Discrepancy Report DR-MP3-0660 have identified conditions not previously discovered by NU which require correction.

The disposition of the four individual items identified by S&L follows.

NU agrees that the following three items represent discrepant conditions not pre-discovered by NU.

1. Calculations (i) & (ii) require confirmation for assumptions 2(a), (b), (c), & 3.

The calculations do not document closure of the confirmations Printed 4/6/98 2:27:16 PM Page 1 of 4

ICAVP DR N2. DR-MP3 0860

. N:rthert Utilities Millstone Unit 3 Discrepancy Report lequired. NU agrees this item is discrepant and concludes that the stress calculations should be updated to show their closure.

The items listed as requiring confirmation were:

- Piping drawings (assumption -2a)

- Stress Data Package ( 2b)

- Valve and Equipment drawings ( 2c)

- Weight of flex hose per foot (-3)

The E&DCR T-P-07233 referenced in this calculation was cortsolidated into E&DCR T-P-07956 (attached), which required incorporation of tha design into piping drawings EP-60 series. A new drawing, EP-60D (NU number 25212-23021 sht.1, attached) was created to show the lube oil piping.

The design conditions of 200F and 150 psig were considered in the calculation. Thermal flexibility analysis was performed for an operating temperature of 140 F in accordance with the original E&DCR. The stress data package issue is addressed below in ,

item #4.

The equipment drawings are available and are included with the attachments. The 4 valve drawings are contained in E&DCR T-P-07956 and are still valid. There is no significant change to the information used for analysis in the calculations.

The weight per foot of the flex hose being less than the weight per foot of 4 pipe is confirmed by the information contained in Metal Bellows Corporation report CR1277 (attached). On page 5 of the report the total weight including contents is given as 23.537 lbs and the total length is given on page 4 as 22.375 inches. Thus the weight per foot is 23.537 lbs / 22.375 inches x 12 inches per foot = 12.6 lbs/ foot, which is less than the 16.3 1 lbs/ foot used in the stress calculation The above resolution of the confirmations required will be documented in a change notice to the subject stress calculations post startup.

2. Qualification calculations for fiex hoses 3EGS*1 A,1B,2A &

28 are not identified.

The flex hoses were specified to have a large enough acceptable range of movements to accommodate the expected displacements. See tne data sheet included with Addendum #2 to Specification 2472.800-729 (attached). The data sheet specifies a maximurn range of movement of for the flex hose of 0.5 inches, much greater than the movements of less than 0.2 inch calculated in the stress calculations. NU concludes the stress calculations should be updated to show a comparison of calculated displacements versus the specified displacement capabi!ities. A separate calculation to accomplish this is not required.

The vendor qualification calculation for the flex hoses is contained in their report CR1277 dated 10/3/1985 (attached). It includes Qualification for the 0.5 specified movements.

PrWed 46/98 2:27:17 PM Page 2 of 4

~

ICAVP DR N3. DR-MP3-0860

- N:rthert Utilities Miiistone Unit 3 Discrepancy Report

4. Stress Data Package SDP-EGO-O referenced with " DateLater-

" but never issued.

Per procedure NETM-30 Attachment A page A1-6 (attached), no SDP was required int the Emergency Diesel Lube Oil system (EGO). The design conditions were to be supplied by the diesel vendor, and were provided in the E&DCR T-P-07233 referenced in this calculation. However, the E&DCR was superseded by E&DCR T-P-07956, and the latter document did not include the statement " Operating Conditions 100 psig 120-140 F for diesel operating that appeared on page 6 of the first E&DCR. There is thus a need to document the lube oil piping operating conditions to be used for the piping analysis. The diesel operating manual gives a typical operating range of 125-140 F, consistent with the temperature used in the stress calculation.

The approved action plan for CR M3-98-0706 includes preparation of an engineering evaluation or calculation to confirm and document the lube oil operating conditions downstream of the lube oil cooler.

The approved action plan for CR M3-98-0706 will issue a calcuhtion change notice post startup to address the above issues of proper documentation of operating pressure and temperature of piping, and removal of the confirmations required from the stress calculations.

NU has concluded that item #3 reported in Discrepancy Report DRMP3-0860 does not represent a discrepant condition.

3. No documentation is provided for the qualification and acceptance of these loads.

Nozzle loads from calculations 12179-NP(F)-X6007- Rev. O, CCN-2 and 12179-NP(F)-X6008-Rev. O, CCN-1 are addressed in calculation 12179-NM(B)-786-CZC Rev.1 dated 5/14/1985 (attached). Explicit accounting of the nozzle loads is shown on pages 7 and 8 of the calculation. Significance Level does not apply to this item.

In summary, NU concludes there are three discrepant items not pre-discovered by NU which require correction. The approved corrective action plan for CR M3-98 0706 requires documentation of the piping operating conditions and update of the stress calculations to resolve the confirmations required post startup.

Items 1,2 and 4 above are deficiencies in documentation only.

The piping and equipment has been adequately analyzed and shown to meet design basis requirements on pipe stress and equipment loading. Therefore the Significant Level should be 4, I since there is no impact on the design or licensing basis, l

Conclusion:

NU has concluded that items #1,2 and 4 reported in Discrepancy Report DR-MP3-0860 have identified conditions not Printed 46/98 227:17 PM Page 3 of 4

ICAVP DR N2. DR-MP3-0860

. ' N:rthe-t Utilities Millstone unit 3 Discrepancy Report I

previously discovered by NU which require correction. The approved correction action plan for CR M3-98-0706 requires action to address these items, including post startup documentation of the piping operating conditions and update of the stress calculations to address flex hose movements and resolve the confirmations required. The Significance Level should be 4, since there is no impact on the licensing or design basis.

NU has concluded that item #3 of the Discrepancy Report does not represent a discrepant condition because a calculation was prepared to address equipment nozzle loads.

Attachments:

CR M3-98-0706 E&DCR T-P-07956 dated 11/17/85 NU drawing 25212-23021 Sht.1 Vendor drawings 2447. 300-241 Shts.114A and 115A 12179-FM(B)-786-CZC Rev.1 Specification 2472.800-729 Rev. O Addendum 3 dated 10/11/85 Metal Bellows Corporation report CR1277 dated 10/3/1985 NETM 30 Attachment A page A1-6 Previously identified by NU? O Ye. (#') No Non Discrepant Condition?O Yes (G) No Resolution Pending?O ve. @ No Resolution unresolved?O ve. @ No Review initiator: Jain, R. C.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date:

SL Comments: I l

l 1

Printed 4/6/98 2:27:17 PM Page 4 of 4

f ICAVP DR N2. DR-MP3-0862

., N::rthert Utilities Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p Dist;lpline: Electrical Design Om Discrepancy Type: Calculation g SystemProcess: HVX NRC Significance level: 4 Date faxed to NU:

Date Published: 1/10/98 Discrepancy: Damper load left out of the SBO diesel generator loading calculation

Description:

Calculation No. PA-90-050-0308E3, Rev. 2, " Station Blackout Diesel Generator Loading" calculates the steady state required and contingency loading for the SBO diesel generator. The calculation did not include Damper 3HVR* MOD 50A as a required load. This is the ventilation supply damper to the charging pump A cubicle. During the winter, the damper upstream of damper

• MOD 50A is closed and remains closed during pump operation and therefore, damper

• MOD 50A is not required to operate.

However, during the summer months the upstream valve is opened and damper

• MOD 50A must be open to supply ventilation to the cubicle during pump operation. This is a small load and should not change the conclusion of the calculation, Review Valid invalid Needed Date initiator: Launt, C. M. B O O 2ris/97 VT Lead: Nerl. Anthony A O O O 12/20/97 VT Mgr: schopfer, Don K O O O 2/23s7 IRC Chmn: singh, Anand K G O O 12/35/97 Date:

INVALID:

Date: 4/1/98 resol UTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0862, 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-MP3-0862, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concems and meets the Unit 3 deferral criteria. CR M3-98-0515 has been written to develop and track resolution of this item per RP-4.

Previously identified by NU7 U Yes (9) No Non Discrepant Condition?Q Yes (9) No f Resolution Pending70 vos @ No Resoiuiion unreeoived70 ves @ No Pnnted 4696 2:27:31 PM Page 1 of 2

I ICAVP DR No. DR-MP34862 N:rtheart Utilities Millstone Unit 3 Discrepancy Report Review c*Ma AcceMa Date initiator: Launi, C. M.

B D 0 m VT Lead: Nori, Anthony A VT Mgr: Schopfer. Don K b

O O e IRC Chmn: Singh, Anand K O O O Date: 4/1/98 SL Comments: The NU response is acceptable. CR M3-98-0515 has been written to track and resolve this issue. This CR transfers this issue to the general calculation CR M3-98-0138.

l Page 2 of 2 Printed 4ti/90 2:27:32 PM

ICAVP DR ND. DR-MP3 0880

- brthe:st Utilities MinistDne Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p l

Discipline: Mechanical Design l

Discrepancy Type: Calculation g System / Process: DGX NRC significance level: 4 Date faxed to NU:

Date Published: 1/17/98 Discrepancy: Incorrect area property of fuel oil day tank used in the calculation.

Description:

The seismic qualification review for fuel oil day tank, 3EGF*TK2A/B, calculation #12179-NM(S)-lA 187, was performed and following discrepancy was identified.

Page #11 of calculation shows multiplication error in area. ,

The correct area should be 27.31 sq.in, instead of 145.7 sq.in. l used in the analysis. This error is non-conservative since it underestimated stresses.

Review Vahd invalid Needed Date Initiator: Patel. Ramesh 9 O O 12/24/97 VT Lead: Neri, Anthony A B O O 2r31/97 VT Mgr: schopfer, Don K B O O 1'12/98 IRC Chmn: singh, Anand K B D 0 1'13'98 Date:

INVALID:

Date: 3/30/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0880, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3 98-0401 (attached) will revise calculation NM(S)-IA-187 so that the correct values of stress are computed post startup. The correct area for the tank section is 28.16 in2 based on the following input received from design engineering:

Per page 6-20 of the AISC Manual, Ninth Edition, for a hollow circle A=0.785398 (d2 - d2) l where d=48 inches (outer diameter) d=47.625 inches (inner diameter)

A=0.785398(482 - 47.6252) = 28.16 in2 This area value was used for STRUDL members numbers 1 to

! 10,44, and 45 and constitutes the tank cylinder based on page 9 of the calculation. Based on the STRUDL analysis, the area value would be used in the determination of axial, shear or combined axial plus bending stresses.

Based on a review of the STRUDL computer run Job No. 6324, dated 9-22-85, page 1 to 20, the following maximum forces were found:

Printed 4/6/96 2:27:53 PM Page 1 of 2 l

l ICAVP DR N2. DR-MP3-0680

, N rthen:t Utiliti:s Millstone Unit 3 Discrepancy Report l

Load case Axial Shear Y Shear Z l 1 1550.5 2 1575.3 6&7 4761.0 Based on these forces, the maximum axial stress is:

Axial Stress = 1575.3 pounds / 28,16 in2 = 55.94 psi The maximum shear stress is: J Shear Stress = 4761.0 pounds / 28.16 in2 = 169.07 psi Based on a review of the Member Maximum Stresses listed on page 28 of the calculation, the stresses are small e,onsidering the change in area value for axial, shear or combined axial plus bending stress. As such there is no effect on the conclusion of the calculation, license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identirMMI by NU7 U Yes @ No Non Discrepant Conddion?U Yes @ No Resolution Pending?O Yes @ No Resolution Unresolved?O Ye. @ No Review initiator: Johnson, Jay VT Lead: Neri. Anthony A VT Mgr: Schopfer, Don K 1RC Chrnn: singh. Anand K Date: 3/30/98 sL Comments: The resolution provided by NU ls acceptable. Implicit in this resolution is the engineering judgement that the difference in axial stiffness of Members 1 through 10 in the STRUDL computer model will not have a significant impact on the magnitude and distribution of member forces and displacements. This engineering judgement should be documented in the revised l calculation.  !

l Prtnted 4W98 2:27:54 PM Page 2 of 2 E_____________

ICAVP DR ND. DR-MP3-0953

. ' N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: structural Design Om Discrepancy Type: Calculation g System / Process: N/A NRC Significance level: 4 Date faxed to NU:

Date Published: 1/25/98 Discrepancy: Reference Documents are not available from NU

Description:

We have requested the microfiche for STRUDL & BASEPLATE runs to complete the review of the following calculations.

These documents are not available per NU ICAVP Response 1.D. Nos as listed below. Therefore the review of the calculations ,

cannot be completed. l l

! CALCULATION NO. RFINO, IRF NO. l l

i CFSK-736MA.E29 MP3-786 M3-IRF-1308 NP(B) 1041 XC MP3-786 M3-IRF-1308 l

l NP(B)-Z545E-697 MP3-786 M3-IRF 1308 NP(B)-Z545B-214 MP3-786 M3-IRF-1308 NP(B)-Z545B-228 MP3-786 M3-lRF-1308 NP(B)-Z5450-365 MP3-786 M3-IRF-1308 NP(B)-Z545G-822 MP3-786 M3-IRF-1308 NP(F)-Z612A-119-H004 MP3-786 M3-IRF-1308 NP(F)-Z615A-003-H033 MP3-808 M3-IRF-1281 NP(F)-Z507A-084 (EQ. MT.) MP3-734 M3-IRF-1169 NP(B)-Z545G-841 MP3-716 M3-lEF-1120 i NP(B)-Z545J 1218 MP3-735 M3-lRF-1154 NP(B)-545H-972 MP3 735 M3-IRF-1154 l SEO-SE34.418 MP3--743 M3-IRF-1171 NP(B)-545J-1245 MP3-735 M3-IRF-1154 Review I Valid invalid Needed Date l

Initiator: Patel, /.. 9 O O 5/15'98 VT Lead: Neri, Anthony A B O O sits /se VT Mgr: schopfer, Don K 8 O O 1'1S/S8

! IRC Chmn: singh, Anand K 8 O O ir22/98 Date:

INVALID:  ;

i l

Date: 3/31/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0953, has identified a condition not previously discovered by NU. The' condition described in the DR was investigated under CR M3 0711 and has determined that no further CA is required. The missing documentation for these referenced documents will be recreated on an as needed basis. The addition of this documentation will not revise the conclusion of the associated calculations nor will it improve the quality of the plants fit, form or function. The body of the calculation provides the design bases, computer inputs and calculation / computer run results. It additionally provides the summary of the software level and version used in the original computer run and thus can be Printed 4/6/90 2:28:15 PM Page 1 of 2

ICAVP DR N3. DR-MP3-0953

. N:rthea:t Utilities Millstone Unit 3 Discrepancy Report recreated when the additional information provided by the microfiche is needed. Because the design and licensing basis is supported by the text of the calculation, the additional microfiche information is not required, unless modifications or specific operability reviews are needed. When this additionalinformation is required, NU will supply the supporting analysis (microfiche) from the information which exists in the calculation, or create a new calculation. Because this is a normal and existing work practice, no additional corrective actions or AR assignments are necessary. It should be noted that the microfiche was located by NU for may other calculations and subsequently reviewed by S&L. Based on the S&L DRs received to date, a generic issue with these types of calculations or design interfaces has not been identified. Therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by NU? O %'s @ No Non Discrepant Condition?O yes @ No Resolution Pending?O ve. <*) No Re oiution unre.oiv.d?O ve. @ No Review Acceptable Not Acceptable NeedeJ Date VT Lead: Nort, Anthony A VT Mgt: schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/31/98 st comments: S & L has reviewed the support configurations and applied loads in lieu of the review of microfiche runs.

Based on the results of this review, it has been determined it'at no overstress conditions exists and that the output results a e reasonable when assessed against the support geometry and magnitude of the applied loads.

Therefore, missing microfiche files are not a restart issue.

Also, based on the aforementioned reasoning, the significance level has been revised to level 4.

I Pnnted 4/6/98 2:28:15 PM Page 2 of 2

N:rthea:t Utilities ICAVP DR No. DR-MP3-0967 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: structural Design Discrepancy Type: Calculation Om SysterrvProcess: N/A g

NRC Significance level: 4 Date faxed to NU:

Date Published: 1/25/98 Discrepancy: Reference document Discrepancy Descriptkm: We have requested the following reference documents to complete the review of calculations.

These documents are not available per NU verbal response as listed below.Therefore the review of calculations can not be completed.

l NP(F)-Z545G-841 STRUDL# R2582006,9/20/84 {

NP(F)-Z545G-841 STRUDL# R25820078,10/9/84 j NP(F)-Z545G-841 STRUDL# R2582003,11/16/84 I NP(F)-Z545G-841 STRUDL# R2582002,9/21/84 NP(F).Z545G-841 STRUDL# R6357013,1/20/82 NP(F)-Z545G-841 STRUDL# R2582005,10/6/84 l

NP(F)-Z612A-126-H008 STRUDL# R2582082,1/11/85 NP(F)-Z629A-020-H010 STRUDL# 2582010,7/26/84 )

I NP(F)-Z545G-868 STRUDL# 6357010 l NP(F)-Z545G-868 BASE PLATE # ARHGRNO l BE-52VR CALCULATION NO. CG-8 Review Valid invalid Needed Date Initiator: Patel, A. G O O " i VT Lead: Nerl, Anthony A B O O '"

VT Mgr: schopfer, Don K B O O '"

1RC Chmn: singh, Anand K B O O 1" Date:

INVALID:

Date: 3/31/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0967, has identified a condition not previously discovered by NU. The l condition described in the DR was investigated under CR M3 '

0711 and has determined that no further CA is required. The missing documentation for these referenced documents will be recreated on an as needed basis. The addition of this documentation will not revise the conclusion of the associated calculations nor willit improve the quality of the plants fit, form or function. The body of the calculation provides the design bases, computer inputs and calculation / computer run results. It additionally provides the summary of the software level and version used in the original computer run and thus can be recreated when the additional information provided by the microfiche is needed. Because the design and licensing basis is Pnnted 4/6/98 2:28:35 PM Page 1 of 2

[

- N:rthra t Utiliti;s ICAVP DR No. DR-MP3-0967 Millstone Unit 3 Discrepancy Report supported by the text of the calculation, the additional microfiche information is not required, unless modifications or specific operability reviews are needed. When this additionalinformation is required, NU will supply the supporting analysis (microfiche)

I from the information which exists in the calculation, or create a new calculation. Because this is a normal and existing work l practice, no additional corrective actions or AR assignments are necessary, it should be noted that the microfiche was located by NU for may other calculations and subsequently reviewed by S&L. Based on the S&L DRs received to date, a generic issue with these types of calculations or design interfaces has not been identified. Therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by Nu? O Yes @ No Non Discrepant Condition?O Yes (8) No Resolution Pending?O Ye. @ wo Re.oiution unre.oived?O ve. @ No Review initlator: Klaic, N C. 8 *Pta k M Date VT Lead: Nort. Anthony A O **

O e l Vf Mgr: schopfer, D(n K IRC Chmn: Singh, Anarx' K Date: 3/31/98 l

sL Comments: S & L has reviewed the support configurations and applied loads in lieu of the review of microfiche runs.

Based on the results of this review, it has been determined that no overstress conditions exists and that the output results are reasonable when assessed against the support geometry and magnitude of the applied loads.

Therefore, missing microfiche files are not a restart issue.

l Also, based on the aforementioned reasoning, the significance i level has been revised to level 4.

l l

l Pnnted 4698 2:28:35 PM Page 2 of 2

i ICAVP DR N3. DR-MP3-1000 N:rtheart Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: Mechanical Design Q ye, Discrepancy Type: Calculation (G)No SystenVProcess: NEW NRC Significance level: 4 Date faxed to NU:

Date Published: 2/1/98 Discrepancy: Revision of Calculation US(B)-253 for DCR M3-97045

Description:

The purpose of Calculation US(B)-253, Rev. 5 is to identify the sources of allinput data for the LOCA containment pressurization model and to compile the LOCTIC input data deck l for this model.

Seven discrepancies were identified in US(B)-253:

l i 1. According to Attachment B of US(B)-270, Rev. 5, the time l required for the RSS pump to accelerate to full speed is 0.8 l seconds, given no voltage degradation - a condition previously assumed to correspond to RSS pump autostart for a postulated l

LOCA without a LOP. Rev. 5 to US(B) 253, increased this time l to 2.0 seconds (pp.13 and 13a) without indicating a new l reference for this new start time. Rev. 6 to US(B)-270 no longer l provides data on pump acceleration time.

2. According to Attachment B of US(B)-270, Rev. 5, the time l required for the RSS pump to accelerate to full speed is 3.2 l seconds, given 30% voltage degradation - a condition previously assumed to correspond to RSS pump autostart for a i postulated LOCA concurr ' Uth a LOP. Rev. 5 to US(B)-253, decreased this time to 2.0 :.a onds (pp.13 and 13a) without indicating a new referenc. !o this new start time. Rev. 6 to US(B)-270 no longer provides data on pump acceleration time.

I 3. According to p. 66 of US(B)-225, Rev. 6, the time required for the QSS pump to accelerate to full speed is 2.0 seconds, given 30% voltage degradation - a condition previously assumed to i correspond to QSS pump autostart for a postulated LOCA concurrent with a LOP. Rev. 5 to US(B)-253, decreased this time to 1.0 seconds (pp.13 and 13a) without indicating a new reference for this new start time.

! 4. According to LSK-24-9.4Q, Rev. 9, the 650 or 660-second

. RSS pump autostart timer would not start after a postulated I LOCA/ LOP until the EDG breaker closes - a sequence in which  !

the EDG starts, comes up to speed, and synchronizes. It is  ;

conservatively assumed that the EDG breaker would close 14.0  ;

seconds after the postulated LOCA/ LOP commences. Rev. S to j US(B)-253 adds only 1.6 seconds rather than 14.0 seconds to  ;

the RSS effective time to account for when the autostart timer ]

starts its 650 or 660 second count down (pp.13 and 13a).

5. None of the operating conditions for the RSS heat exchanger identified in US(B)-253, Rev. 5 (pp.13b,13d, and 13g)  ;

corresponds with any of the 15 operating conditions listed in the

Oc3 ccctiOn Of US(S) 342, RcV. 2 (p. 20). NO HTR! g,0 ,

P 289 PM

N:rthert Utilities ICAVP DR No. DR-MP3-1000 Millstone Unit 3 Discrepancy Report runs except those in US(B)-342, Rev. 2 are identified as references in US(B)-253, Rev. 5. Therefore, even though the RSS heat exchanger UA values identified in US(B)-253 appear to be consistent with the HTRI model of US(B)-342, no basis for these UA values is provided.

6. According to US(B)-361, Rev. 0 (Case 9), the ECCS cold leg recirculation flow for a LOCA/ LOP with Min. ESF and degraded RSS pumps is 1171 gpm, not 1160 gpm, the value listed for this flow in US(B)-253, Rev 5(p.13a).

7. According to US(B)-361, Rev. 0 (Case 5), the ECCS cold leg recirculation flow for a LOCA/ LOP with Max. ESF and non-degraded RSS pumps is 1553 gpm, not 1614 Opm, the value listed for this flow in US(B)-253, Rev. 5 (p.13c).

The net effect of the above comments on spray effective time is l as follows:

LOCA/ LOP (PSDER, Min. ESF, degraded pumps, p.13) i RSS Effective Time: 838.4 sec = 14.0 + 20.0 + 660.0 + 0.8 +

143.6 sec ZSTART: 68.6 sec (co Tect as is)ZDELAY: 768.2 sec = 838.4 - l 70.2 sec j l

LOCA with offsite power (PSDER, Min. ESF, degraded pumps, p.13)

QSS Effective Time: 53.8 sec = 1.6 + 2.0 + 50.2 see RSS Effective Time: 828.4 sec = 1.6 + 20.0 + 660.0 + 3.2 +

143.6 sec ZSTART: 52.2 sec = 53.8 - 1.6 sec ZDELAY: 774.6 sec = 828.4 - 53.8 sec LOCA/ LOP (PSDER, Max. ESF, non-degraded pumps, p.13a)

RSS Effective Time: 789.6 sec = 14.0 + 20.0 + 660.0 + 0.8 +

94.8 sec ZSTART: 68.6 sec (correct as is) l ZDELAY: 719.4 sec = 789.6 - 70.2 sec l LOCA with offsite power (PSDER, Max. ESF, non-degraded pumps, p.13a)

QSS Effective Time: 53.8 sec = 1.6 + 2.0 + 50.2 sec RSS Effective Time: 779.6 sec = 1.6 + 20.0 + 660.0 + 3.2 + 94.8 i sec ]

ZSTART: 52.2 sec = 53.8 - 1.6 sec ZDELAY: 725.8 sec = 779.6 - 53.8 sec it is the engineering judgement of this reviewer that the lack of input documentation will not affect the RSS heat exchanger UA input data.

The ECCS cold leg recirculation flows used in the LOCA containment pressurization model are non-conservative inputs.

The higher values which should have been used would result in a very small increase in the mass release rate - and, in the ludaement of the reviewer, an inslanificant increase in predicted Printed 4/6/98 228.s4 PM Page 2 of 4

N:rthe:st Utilities ICAVP DR NO. DR-MP3-1000 Millstone Unit 3 Discrepancy Report containment pressure and temperature, i Review Valid invalk! Needed Date initiator: Wakeland, J. F. B 0 0 5/28/98 l

VT Lead: Neri, Anthony A B O O 2/2/98 VT Mgr: schopfer, Don K B O O 2/2/98 IRc Chmn: s6ngh, Anand K B D 0 2/3/98 Date:

INVALID:

1 Date: 3/31/98 RESOLUTION: DISPOSITION:

NU has concluded that the issues reported in Discrepancy l Report, DR-MP3-1000, are conditions not previously discovered by NU which require correction. The approved corrective action i plan for CR M3-98-0843 (attached) will correct Calculation US(B)-

t 253 with respect to each of the seven discrepancies identified..

The revised results will then be canied forward into the calculations and documents which use results from US(B)-253 as an input.

l CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepencies identified by the ICAVP program. This corrective action will be completed by May 31,1998, and will ensure that the errors in US(B)-253 are clearly identified and addressed. The corrective j action plan for CR M3-98-0843 is tied to CR M3-98-0619 by AR 98002805.

As part of the ICAVP program, trending CR M3-98-1132 has been written to ensure that any process-related issues related to these calculations are clearly identified and are being dealt with.

This assessment is scheduled to be completed prior to Startup.

Each of the discrepancies in DR-MP3-1000 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR-MP3-1000 significantly affect the results of the RSS related calculations, or the conclusion that the RSS system meets its design basis. In addition, each of these riiscrepancies has been reviewed by NU design engineers, who have further determined l that none of the discrepancies impacts the operability of the RSS

! system. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

I CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1000, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0843 (attached) will correct Printed 4W98 2:28:s4 PM Page 3 of 4

ICAVP DR NO. DR-MP3-0836 N::rthext Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED .

Review Element: system Design p Discipline: I & C Design O ve.

Discrepancy Type: Calculaton gg System / Process: HVX NRC Significance level: NA Date faxed to NU:

Date Published: 1/1oGB Discrepancy: Calculation methodology vs. RG 1.105 commitment: NSP-097- ,

i HVR & SP-3HVP-5 Descripuon: The calculations described below document the vendor's process l

setpoint values but do not analyze the impact of instrument inaccuracy, calibration uncertainty, and instrument drift upon their respective Category 1 instruments. No bases for selecting instrument setpoint values is documented. >

1. Calculation NSP-097-HVR documents the setpoint for pressure controllers 3HVR*PIC104A and B that modulate inlet vanes 3HVR* MOD 140A and B respectively which are located on the suction side of fans 3HVR*FN6A and B respectively which is ,

part of the auxiliary building ventilation filtration system. )

2. Calculation SP-3HVP-5 documents the setpoint for ,

temperature indicating controllers 3HVP* TIC 29A and B that modulate vanes 3HVP* MOD 20A,20C,23A, and 26A, and 3HVP* MOD 208,20D,238, and 26B respectively which are part of the emergency diesel generator enclosures' ventilation system.

Review Valid invalid Needed Date initiator: Reed, William. O O O 12/19S7 VT Lead: Nert, Anthony A Q Q Q 12/19/97 VT Mgr: schopfer, Don K B O O 12/2as7 IRC Chmn: singh, Anand K B O O $2/31/97 Date:

INVALID:

Date: 4/1/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0836, does not represent a discrepant condition. The auxiliary building ventilation inlet plenum for fans 3HVR-FNBA and B receives exhaust from several different ventilation systems with varying flows (17,500 CFM,22,000 CFM,28,000 CFM, and 50,000 CFM, etc.). The set point for the pressure controller was established by the system requiring the least amount of pressure at the plenum to obtain its design flow rate.

This resulted in flow rates which were in excess of the design flow rates for the balance of the ventilation systems connected to the plenum. These ventilation systems were then flow balanced to obtain their design flow rates with a plenum pressure of 1.5 inches. The function of the pressure controller 3HVR*PIC104A (B) to maintain the intet plenum at a constant pressure by modulating the inlet vanes 3HVR* MOD 140A and B regardless of Page 1 of 2 Pnnted 4/6SB 2:26:57 PM

N:rthe:st UtilitiIs ICAVP DR ND. DR-MP31000 Millstone Unit 3 Discrepancy Report Calculation US(B)-253 with respect to each of the seven discrepancies identified. In addition, an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure that these issues are clearly identified and addressed. .

Each of the discrepancies identified in DR-MP3-1000 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS system meets its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously klentified by Nu? O Yes (#) No Non D6screpent Condition?Q Yes (8) No Resolution Pending?O Yo. @ No Re.oiuiion unre.oiv.d?O Yo. Ce) No Review CC*

• cceMa Needed Date inluator: Wakeland J. F.

B D D **

VT Lead: Nerl. Anthony A S O O =

VT Mgr: Schopfer, Don K O O e IRC Chmn: Singh, Anand K O O O D*: 3/31/98 sL comments: Sargent & Lundy concurs that CR M3-98-0843 will correct the discrepancies in Calculation US(B)-253, Rev . 5, reported in DR-MP3-1000. (11 should be noted that Sargent & Lundy now concludes that item #5 of DR-MP3-1000 should nnt have been considered a discrepancy. US(B)-342, Rev. 2 provides a performance curve for the RSS HX from which the values of UA are determined.) l I

The significance of the errors in US(B)-253, Rev. 5 identified in DR-MP3-1000 have been evaluated. The conclusion of this l evaluation is documented in Stone & Webster Letter SRE-MP3- j 9805, dated 3-6-98. Based on this and on the engineering judgment of the ICVAP reviewer, Sargent & Lundy concurs that the cumulative effect of the errors 1(ientified in DR-MP3-1000 is minor and the NRC Significance Level should be changed to level l 4.

In addition to the specific corrections to US(B)-253, Rev. 5 of CR M3-98-0843, NU is addressing the generic implications of these types of errors in CR M3-98-0619 and is addressing the potential for any programmatic defficiencies in CR M3-98-1132.

Pnnted 4/6/98 2:28:s5 PM Page 4 of 4

DR NO. DR-MP3-1029 N:rthert Utiliti;s ICAVP Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design j Discipline: PAechanical Design Discrepancy Type: Calculation System / Process: NEW NRC Significance level: 4 Date faxed to fvU:

Date Published: 2/7/98 Discrepancy: Revision of Calculation US(B)-349 for DCR M3-97045

Description:

The purpose of Calcuation US(B)-349, Rev.1 is to quantifiy to mixing rate between the sprayed and unsprayed regions of the containment following a postulated design basis LOCA.

Calculation US(B)-349 provides input to dose calculations.

One discrepancy was identified in US(B)-349:

The calculation assumes that containment atmosphere temperature will be less than 225F when RSS becomes effective (Assumption 2); however, Table 2 (p. 20) indicates that a postulated PSDER with an MCC failure would result in a containment atmosphere temperature of 240.1F at 780 seconds, the RSS effective time for that event.

Review Valid invalid Needed Date initiator: Wakeland, J. F. B O O 5'31/98 l

VT Lead: Neri, Anthony A 8 O O 2/2/98 VT Mgr: Schopfer, Don K B O O 2/2/98 IRC Chmn: singh, Anand K 9 O O 2/3/98 Date:

INVALID:

Date: 3/31/98 RESOLUTION: DISPOSITION:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1029, are conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0844 (attached) will correct Calculation US(B)-

349 with respect to the discrepancy identified. The revised results will then be carried forward into the calculations and documents which use results from US(B)-349 as an input.

CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and OSS related calculation discrepencies identified by the ICAVP program. This corrective action will be completed by May 31,1998, and will ensure that the errors in US(B)-349 are clearly identified and addressed. The corrective action plan for CR M3-98-0844 is tied to CR M3-98-0619 by AR 98002805.

As part of the ICAVP program, trending CR M3-98-1132 has been written to ensure that any process-related issues related to these calculations are clearly identified and are being dealt with.

This assessment is scheduled to be completed prior to Startup.

Page 1 of 2 Printed 46/98 229:09 PM

(

, N:rthert Utilities ICAVP DR N3. DR-MP31029 Millstone Unit 3 Discrepancy Report l

l The discrepancy in DR MP3-1029 has been reviewed by the I

vendor (the Unit 3 architect engineer), who has determined that the discrepancy enumerated in DR-MP3-1029 does not significantly affect the results of the RSS related calculations, or

)

l the conclusion that the RSS system meets its design basis. In 1 addition, the discrepancy has been reviewed by NU design engineers, who have further determined that the discrepancy l does not impact the operability of the RSS system. As such l

there is no effect on the license or design basis, therefore NU j l has concluded this to be a Significance Level 4 issue. '

CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1029, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0844 (attached) will correct Calculation US(B)-349 with respect to the discrepancy identified.

In addition, an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure that these issues are clearly identified and addressed.

The discrepancy identified in DR-MP3-1029 has been reviewed by the vendor and by NU, and it does not affect the conclusion i that the RSS system meets its design basis. As such there is no

! effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by NU7 O Yes (8) No Non Discrepant Condition?U Yes @) No Re.olution Pending70 Yes @ No Re aution uore.av.d70 Ye. @ No l Review initiator: Wakeland, J. F.

VT Lead: Nort, Anthony A l VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 3/31/98 sLComment : Sargent & Lundy concurs that CR M3-98-0844 will correct the discrepancy in Calculation US(B)-349, Rev .1, reported in DR-MP3-1029.

The significance of the error in US(B)-349 Rev.1 identified in DR-MP3-1029 has been evaluated. The conclusion of this evaluation is documented in Stone & Webster Letter SRE-MP3-9805, dated 3-6-98. Based on this and on the engineering judgment of the ICVAP reviewer, Sargent & Lundy concurs that the error identified in DR-MP3-1029 is minor and the NRC Significance Level should be changed to level 4.

In addition to the specific corrections to US(B)-349, Rev.1 of CR M3-98-0844, NU is addressing the generic implications of these types of errors in CR M3-98-0619 and is addressing the potential for any programmatic defficiencies in CR M3-98-1132.

Printed 4/6/98 2:29:10 PM Page 2 of 2

~

ICAVP DR N). DR-MP3-1048

. N:rtheart Utilities Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability iss ue Discipline: Mechanical Design Om Discrepancy Type: calculation g" SystenVProcess: NEW NRC Significance level: 4 Date faxed to NU:

Date Published: 2/12/98 Discrepancy: Inputs to Revision of US(B)-270 for DCR M3-97045 Ducription: The purpose Calculation US(B)-270, Rev. 6 is to determine the RSS fill time for input to the containment pressurization calculations, US(B)-253, Rev. 5, US(B)-273. Rev. 6, and US(B)-

266, Rev. 3. Calculation ES-231, Rev. 2/CCN 1 computes the volume of the R$S system for input to RSS fill time calculation US(B)-270.

Two discrepancies were identified in the input data for US(B)-

270, Rev. 6:

)

1. Only three of the RSS system volumes identified on pp.10-13 were found to have a documented basis (in ES-231, Rev. 2/CCN 1):

a. RSS heat exchanger shell side volume (pp.10-13)

b. RSS header # 1 volume for minimum ESF (pp.11,13)

c. RSS header # 2 volume for minimum ESF (pp.11,13)

The other volumes may be calculated from input of ES-231, but it was not shown how this was done.

2. Based on the difference between wet and dry shipping weights identified on the RSS heat exchanger data sheet, Calculation ES-231, Rev. 2/CCN 1 computed the shell-side volume of each heat exchanger to be 1404 gal. Heat exchanger shipping weights are an inappropriate measure of the fill volume of the RSS ,

system. Shell-side dimensions taken from Drawings l 2214.803-020-002G and 2214.803-020-003E should j I

be used. These dimensions yleid a shell-side volume of 1100 gal for each heat exchanger. Reducing the RSS heat exchanger volume from 1404 to 1100 gal reduces the RSS fill time by 6 to 7 seconds.

Review Valid invalid Needed Date O O 2/ss8 initiator: Wakeland, J. F. O VT Lead: Neri, Anthony A G O O 2/5/98 l VT Mgr: schopfer, Don K O O O 2/6/98 l IRC ' hmn: singh, Anand K 9 0 0 2/7/98 Dr,te:

INVALID:

Date: 3/31/98 RESOLUTION: DISPOSITION:

NU has concluded that Discrepancy Report DR-MP3-1048 has Pnnted 4/6/98 22925 PM Page 1 of 3

N:rthenct Utilities ICAVP DR ND. DR-MP3-1048

Millstone Unit 3 Discrepancy Report  ;

! l l identified conditions not previously discovered by NU which l require correction. The approved corrective action plan for CR M3-98 0824 (attached) will correct Calculation US(B)-270 with respect to each of the two discrepancies identified. The revised results will then be carried forward into the calculations and documents which use results from US(B)-270 as an input. i l

CR M3-98-0619 contains the corrective action plan to complete  ;

the review of all RSS and QSS related calciation discrepancies.  !

This corrective action plan will be completed by May 31,1998, l and will ensure that the errors in US(B)-270 are clearly identified and addressed. The corrective action plan for CR M3-98-0824 is tied to CR M3-98-0619 by AR 98002805.

As part of the ICAVP program, trending CR M3-98-1132 has j been written to ensure that any process-related issues related to I these calculations are clearly identified and are being dealt with.

This assessment is scheduled to be completed prior to Startup.

Each of the discrepancies identified in DR-MP3-1048 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR-MP3-1048 significantly affect the results of the RSS related calculations, or the conclusion that the RSS system meets its

, design basis. In addition, each of these discrepancies has been reviewed by NU design engineers, who have further determined that none of the discrepancies impacts the operability of the RSS l l system. As such there is no effect on the license or design basis. Therefore NU has conicuded this to be a Significance Level 4 issue.

I CONCLUSION:

l l NU has concluded that Discrepancy Report DR-MP3-1048 has identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0824 (attached) will correct Calculation US(B)-270 with

respect to each of the two discrepancies identified. In addition,  !

l an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure that these issues are clearly identified and addressed. Each of the discrept :ies identified in DR-MP3-1048 has been reviewed by the vendor and by NU, and none of them affect the conclusion j that the RSS System meets its design basis. As such there is no l effect on the license or design basis. Therefore NU has conicuded this to be a Significance Level 4 issue.

l l Prniously identified by Nu? U ve. (9) No Non Discrepent Condition?O ves (9) No Rssolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Wakeland, J. F.

VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Pnnted 4/6/96 2:29:26 PM Page 2 of 3 l

l

• N:rthea:t Utilities ICAVP DR No. DR-MP3-1048 Millstone Unit 3 Discrepancy Report mm v. .. .. eo vo. ~ - ,s g g g Date: 3/31/98 sL comments: Sargent & Lundy concurs that CR M3-98-0824 will correct the discrepancies in Calculation US(B)-270, Rev . 6, reported in DR-MP3-1048.

The significance of the errors in US(B)-270, Rev. 6 identified in DR-MP3-1048 have been evaluated. The conclusion of this evaluation is documented in Stone & Webster Letter SRE-MP3-9805, dated 3-6-98. Based on this and on the engineering judgment of the ICVAP reviewer, Sargent & Lundy concurs that the cumulative effect of the errors identified in DR MP3-1048 is minor and the NRC Significance Level should be changed to level 4.

In addition to the specific corrections to US(B)-270, Rev. 6 of CR M3-98-0824, NU is addressing the generic implications of these types of errors in CR M3-98-0619 and is addressing the potential for any programmatic defficiencies in CR M3-98-1132.

I Pnnted W90 2:29:25 PM Page 3 of 3

1 l DR N3. DR-MP3-0029 Northerct Utilities ICAVP

Millstone Unit 3 Discrepancy Report l Review Group

system DR RESOLUTON REJECTED Review Element: System Design Potential Operabilitylasue l Discipline: Mechanical Design (g] Yes Discrepency Type: calculation Q No System / Process: SWP NRC significancelevel: 3 Date faxed to NU:

Date Published: 9/11/97 Discrepancy: Service Water Pumphouse Ventilation Calculation Discrepancy Descriptiom The following calculations were reviewed to verify that the correct haat load from the service water pump motors were used in determining the service water pump room ventilation requirements:

Calculation P-198 Rev. O, dated July 10,1973, Ventilation -

Circulating & Service Water Pump House Calculation P(B)-901 Rev. O, dated 12/14/83,3HVY'FN2A/2B l

l Cycling Frequency Calculation P(B)-920 Rev. O, dated 12/14/83, Recommended l

Period of Operation of the Service Water Pumphouse Ventilation Recirculation Mode Calculation P(B)-925 Rev. O, dated 12/14/83, Sentice Water Pumphouse Ventilation Requirements The review identified the following descrepancies:

1) Calculation P-198 used 800 hp for calculating the heat loss from one service water pump motor. Plant Design Data System (PDDS) data for service water pump 3SWP*P1 A and 3SWP*P1B states that the motor rating is 600 hp with a brake i

HP requirement of 555 hp.Two pumps operate post-LOCA per FSAR section 9.2.1.2 while the calculation only considered one '

operating. This would result in higher than calculated heat loss to the pump room from the service water pump motors.

Calculation P(B)-901 indicates that P(B)-906 supersedes calculation P-198. However, calculation P-198 is still shown as an active calculation in the calculation database and P(B)-906 has been superseded by P(B)-925.

2) Calculation P(B)-901 considered only one pump operating with a bhp of 561. Two pumps operate post LOCA per FSAR section 9.2.1.2 which would result in higher than calculated heat loss to the pump room from the service water pump motors.

3) Calculation P(B)-920 considered only one pump operating while two pumps operate post-LOCA per FSAR section 9.2.1.2

4) Calculation P(B) 925 used motor load values from calculation P(B)-901 which only considered one pump operating. Per FSAR Section 9.2.1.2, two pumps on the same division are required to operate post-LOCA.

The discrepancy is assigned a significance level 3 because the discrepancy may result in a higher Servive Water Pumphouse (SWP} m CmPC & C h= h d=dO= b= = mP 'h 1 of 4 PM M 200 PM

1 1

ICAVP DR No. DR-MP3-0029

- N2rtheast Utilities Millstone unit 3 Discrepancy Report required to support the SWP equipment operation.

Review l Valid invalid Needed Date initiator: stod. M. D. B 0 0 S/4/87 VT Lead: Nort. Anthony A B O O S/d/S7 VT Mgr: schopfer, Don K B O O S'8/S7 O sia/97 IRC Chmn: singh, Anand K O O Date:

INVALID:

Dete: 3/16/98 RESOLUTION: First Response:

l NU has concluded that Discrepancy Report DR-MP3-0029 has identified a condition not previously discovered by NU which l requires correction.

The calculations will be revised to correct this condition.

Condition Report (CR) M3-97-3283 was written to provide the necessary corrective actions to resolve this issue. Based upon a preliminary Engineering Evaluation which considered the l

additional heat load frorn a second pump in conjunction with the lower BHP requirement, there exists a sufficient margin in the ventilation system to support the preliminary conclusion that the system will meet its design requirements. Once the calculation have been finalized a supplemented response will be provided confirming the results. NU concurs that until further analysis is  :

completed and evaluated, this is a Significance Level 3 )

discrepancy.

Second Response:

NU has concluded that Discrepancy Report, DR-MP3-029, has identified a condition not previously discovered by NU which required correction.

NU reponse to DR-MP3-029 (M3-lRF-00418) that was previously submitted was based upon a preliminary Engineering Evalu ition. This DR was retumed from S&L as *Pending" until" completion and submittal of calculation and supplement"is presented. The corrective action specified in CR M3-97-3283 requires calculations P(B)-1118 and P(B)-901 to be completed by Sched. Ref. 06UO2.

In order to enter Mode 4, Calculation # SWP-01516M3,

" Calculation for Service Water Pump Cubicle Temperatures for Operability Determination", was done to support Technical Evaluation # M3-EV-98-0038, Rev. 9; " Service Water Pump Cubicle Temperature with Two Pump Operation".

Technical Evaluation # M3-EV-98-0038 was done to support Operability Determination # MP3-028-98.

Results presented in Calculation # SWP-01516M3 verify that the Pnnted 46/98 2:33 0o PM Page 2 of 4

DR N3. DR-MP3-0029 N:rthert Utilities ICAVP Millstone Unit 3 Discrepancy Report ventilation system has sufficient margin to account for two service water pump operation in the post LOCA configuration.

Since this discrepancy does not change the conclusion of the original ventilation calculation and the service water pumps are still capable of performing their intended safety function, NU considers this to be a Significance Level 4 issue.

Attachments:

j Calculation # SWP-01516M3, Tech. Eval. M3-EV-98-0038, OD # MP3-028-98, CR M3-97-3283 Previously klentified by NU? O Yes @ No Non Discrepant condition?O Yes @ No ResolutionPending?O Yes @ No Re.oiutionunre.oived?O yes @ No Review Acceptable Not Acceptable Needed Date i inith* s% M. D.

VT Lead: Neri, Anth:ny A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K l

Date: 3/16/98 SL Comments: Comments on First Response:

Determination of 'inal significance level is pending completion and submittal of calculation and supplemental response from NU.

Comments on Second Response:

1. Calculation SWP-01516M3, Rev. O assumes that the temperature in the service water pump cubicles is stratified and that the temperaturc at floor level is equal to the supply sir (mixed air) temperature. Calculation does not provide justification I

for this assumption.

2. Calculation SWP-01516M3, Rev. O results show that the normal maximum average (NMA) of 85'F, maximum normal excursion of 110*F (MNE), and maximum abnormal excursion 120*F (MAE) shown in FSAR Appendix 3B are exceeded by 1*F during normal operation with one pump operating. Response does not evaluate the FSAR changes required to reflect the higher room temperatures.

3. Calculation SWP-01516M3, Rev. O did not determine the maximum room temperature with two service water pumps operating with an extreme outdoor air temperature of 103'F as required by FSAR Section 9.4.0. This case appears to have been excluded based on Technical Evaluation M3-EV-98-0038 (item 4.1 on page 3) which did not address the statement in FSAR Section 9.4.0 that refers to the extreme temperatures shown in FSAR Table 2.3-1.

4. Calculation SWP-01516M3, Rev. O results with 86*F outdoor air temperature and two service water pumps operating show that Page 3 of 4 Pnnted 4/6/96 2:33:01 PM

ICAVP DR N2. DR-MP3-0029

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

the maximum room temperature varies between 103'F at the floor and 119.8'F for the recirculation air. The maximum room temperature of 119.8'F exceeds the design temperature of 104'F stated in FSAR Section 9.4.8.1.1. NU's response should address what action is planned to correct the FSAR.

5. Calculation SWP-01516M3, Rev. O results for maximum temperature of 128'F in winter alignment exceed temperatures shown in FSAR Section 9.4.8.1 and Appendix 3B. NU's response should address what action is planned to correct the FSAR.

6. Technical Evaluation M3-EV-98-0038, Rev. O does not address what impact the higher temperatures have on instrument setpoint calculations and electrical calculations. NU's response should address this.

I l

l l

I l

i Printed 4698 2:33:01 PM Page 4 of 4

1

]

ICAVP DR N2. DR-MP3 0287 Northert Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION REJECTED Review Element: system Design Discipline: I & C Design Om Discrepancy Type: Calculation g" System / Process: SWP NRC Significance level: 3 Date faxed to NU:

Date Published: 11/17/97 Descrepancy: Calculation 3-ENG-106 data discrepancy.

Description:

The purpose of calculation 3-ENG-106, Rev.1, is to calculate instrument channel uncertainty for the 3SWP*FIS36A and B flow switches, providing start permissives to the control building air conditioning condensers, signaling that there is sufficient service water flow through the condensers.

Page 6, item 7,

• Seismic Effect (SE) states that the start / trip switches are Seismic Category I and qualified for safety application per ITT Barton Seismic Analysis Report R3-580A-9.

However, the season for this qualification is to ensure physical integrity and circuit integrity only. Per P&lDs EM-133D & 151D switches 3SWP*FIS36A & B are used to provide permissive signals to the control building air conditioning chiller condensers to indicate that there is sufficient service water flow. Hence, they perform a safety function. In which case SE component should be considered, as recommended by Attachment 4 of NUSCo procedure NEAM 41 titled - Setpoint Calculations. Per section 2.3 of this attachment the effect of vibration (seismic effect) should be included in determination of the actual setpoint.

Review Val 6d invalid Needed Date initiator: Hindia, R. O O O 11/6'S7 VT Lead: Neri, Anthony A O O O $ 5 /5'97 i O 5'r7/97 VT Mgr: schopfer, Don K O O IRC Chmn: singh, Anand K g Q [ 11/13.97 Date:

INVALID:

Date: 3/21/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0287, does not represent a discrepant condition. This Discrepancy Report identified the following issue. Calculation 3-ENG-106, Rev.1,

• Setpoint Determination for 3SWP*FIS36A,B; 3SWP-FIS37A,B; and 3SWP-FIS118A,B" states the purpose of the calculation is to i l

calculate instrument channel uncertainly for safety related SSWP*FIS36A & B flow switches however Seismic Effect (SE) l i

are not included in the uncertainty determination for these components.

Per P&lDs EM-133D & 151D and the setpoint calculation the function of 3SWP*FIS36A&B is to provide a start permissive to the control building air conditioning condenser A or B i respecilvely when adequate service water flow exists.

Page 1 of 3 Pnnted 46/98 2:32A1 PM i

1 ICAVP DR N3. DR-MP3-0287 j

• N:rthe::t Utilities Millstone Unit 3 Discrepancy Report The low flow trip setpoint has varied from 300 gpm to 200 gpm (363 gpm and 288 gpm including the instrument uncertainty from prior calculations SP-3SWP-17 and 3-ENG-106 Revision 00). In 3-ENG-106, Revision 01, Attachment A1, Carrier Building System and Services evaluated the condenser water low flow setpoint and acknowledged that this low flow trip setpoint will not j l adversely affect the reliability of the chillers if the chiilers l I refrigerant compressor head pressure is monitored and does not  !

exceed the compressor head pressure specification.

Compressor head pressure is monitored by 3HVK*PS52A, B, High Condenser Pressure Cutout, which is designated as Category I and required for proper operation of the chiller per Material, Equipment, And Parts List Program (MEPL) MP3-CD-1T. Instrument setpoint calculation SP-3HVK-8 establishes th t cetpoint in accordance with Carrier recommendations. .

Fu..hermore, per MEPL evaluation MP3-CD-1071 the flow indicating switch automatic trip function is not safety-related and that the switch provides circuit continuity in the chiller circuit.

Therefore, because this instrument does not perform a safety function seismic effects need not be included in its setpoint and Calculation 3-ENG-106 Revision 01, Section 6.7, Seismic Effect, stated that the seismic uncertainty from the ITT Barton Seismic Analysis Report R3-580A-9 would not to be included in the total probable error (uncertainty) determination.

Note: The requirements of NEAM 41 identified in DR MP3-0287 are no longer used for determining instrument uncertainties /

setpoints. SP-ST-EE 286," Standard Specification for Guidelines for Calculating Instrument Uncertaintles" provides criteria for uncertainty calculations.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0287, does not represent a discrepant condition. The safety function for 3SWP*FIS36A,B has been evaluated by the Material, Equipment, And Parts List (MEPL) Program that classifies a components safety related function or augmented quality. It has been determined by MEPL MP3-CD-1071 that the automatic trip function of 3SWP*FIS36A,B is not safety related therefore, the seismic effect errors are not included in the switch actuation uncertainty calculation.

Significance Level criteria do not apply as this is not considered ,

a discrepant condition. l Prev 6ously ident6fied by NU? O Yes (#) No Non Discrepent Condition?O yes (8) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Hindia. R.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 3/18/98 st. comments: Per logic diagrams LSK-22-12C, Rev.11 & LSK 22-12E, Rev. 9 s Page 2 of 3 Pnnted 4/6/98 2:32 42 PM

DR N1 DR-MP3-0287 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report witch 3SWP*FIS36A(B) stops chiller compressor for 3HVK*CHL1 A(B) if the flow detected is below normal flow. This is in agreement with NU drawing no. 25212-29061, Sh.15, Rev. E (vendor drawing no.12179-2176-430-061 015). Per Carrier letter dated May 27,1988 " Condenser water flow affects the chillers refrigerant compressor head pressure. If head pressure is monitored and does not exceed the refrigerant head pressure specifications, for the chiller in question, the flow rate of condenser water will not adversely affect the reliability of the chiller". This letter is a part of attachment A1. This indicates the effect of the quantitative value of the SW flow is insignificant.

However, per NU drawing no. 25212 29061, Sh.15, Rev. E the switches in question are a part of start-stop circuit for the compressor. Hence, functionally the switches should be considered safety related.

Per page 7 of CCN No 6, dated 10-23-97, to calculation 90-069-1065M3, the minimum flow required for 3HVK*CHL1 A(B) is 297 GPM. Per section 13 of calculation 3-ENG-106, the low flow trip i setpoint is 288.8 GPM. This trip setpoint is based on a Total l

Probable Error (TPE) of +/- 5.92 inches WC and a calculated dP of 9.77 inches WC. j Since the tr.inimum flow requirements and the actual trip setpoint i

values are close to each other ( namely 297 GPM vs. 288.8 GPM), impact of the drift due seismic effect component should be l evaluated to verify proper operation of the chiller compressor l after a seismic event. From the calculation the drift applied around the analyticallimit of 200 GPM would allow the switches 3SWP*FIS36A and B to function over a range of 126 to 254 GPM. Therefore the instmment uncertainty component around the actual setpoint of 288.8 GPM may trip the chiller compressor l i

when the required minimum flow of 297 GPM exists. This could result in a condition where both trains of the Controi Room cooling is rendered inoperable.

In-light of the above discussion it is possible that a seismic event could introduced an error to the loop uncertainty that is not analyzed by calculation 3-ENG-106 this could be detrimental to the chiller performance.

Please note that the significance level of the DR has been upgraded to level 3 based on the results from the most recent revision of calculation 90-069-1065M3. Other setpoints calculated in the setpoint calculation 3-ENG-106 also need to be re-reviewed in this light.

Page 3 of 3 Eind N6/98 2.32.42 PM

• ICAVP DR N2. DR-MP3-0823 N:rthert Utilities Millstone Unit 3 Discrepancy Report Review Group: systern DR RESOLUTION REJECTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Drawing pg System / Process: DGX NRC Significance level: 3 Date faxed to NU:

Date Published: 1/10/98 Discrepancy: P&lD EM-117A Rev.10, Emergency Generator Fuel Oil System, Review of piping line sizes.

Descripuon: Piping size calculations were not found. This would be the type of calculation that addressed fluid velocity and pressure drop over the expected range of operation. The transfer pump calculation P(B)-0799 indirectly verifies the main pipe header to the day tanks, but the balance of the piping has not been addressed.

Of particular concem is the gravity drain line from each day tank to it's respective AC or DC fuel oil pump. Since the line flows by gravity, it must be sized for maximum flow rates and with minimal pressure loss.

Review Valid invalid Needed Date initiator: Russ. Earl. 6 O O 2>' S'S7 VT Lead: Nerl. Anthony A B D 0 12/1o/97 VT Mgr: schopfer, Don K O O O 12/23/97 IRC Chmn: singh, Anand K B O O 12/31/97 Date:

INVAUD:

Date: 3/27/98 RESOLUTION: Disposition:

NU has concluded that DR-MP3-0823 does not represent a discrepant condition. The piping from the Day tank was installed by the AE and was sized to be compatible with the suction connections to the vendor supplied, skid mounted fuel oil pumps (See Attached Dwg 2447.300-241-005). Design pressures and temperatures for the piping system are supported by calculation P(T)-1019 ( See Attached ). The diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) and surveillence procedure SP 3646A.1/2 at least every 31 days. l i

The operability testing along with the calculations confirms the adequacy of the DG fuel oil piping system. Additionally, it should be noted that the fuel oil pumps on the diesels are DC and engine driven. There is no AC powered fuel oil pump as stated in the S&L DR.

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

Conclusion:

NU has concluded that Discrepancy Report DR MP3-0823 does not represent a discrepant condition. The piping from the Day ,

tank was installed by the AE and was sized to be compatible with )

the suction connections to the vendor supplied, skid mounted Page 1 of 3 ;

Pnnted M/98 2:32:18 PM 1

. N:rthea:t Utilitie3 ICAVP DR Ns. DR-MP3-0823 Millstone Unit 3 Discrepancy Report l fuel oil pumps (See Attached Dwg 2447.300-241-005). Design pressures and temperatures for the piping system are supported by calculation P(T)-1019 ( See Attached ). The diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) and surveillence procedure SP 3646A.1/2 at least every 31 days.

l Additionally, it should be noted that the fuel oil pumps on the

! diesels are DC and engine driven. There is no AC powered fuel l oil pump as stated in the S&L DR. The operability testing along l with the calculations confirms the adequacy of the DG fuel oil piping system.

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

Previously identired by Nu? O Yes (@ No Non Discrepant Condition?U Yes (@ No Resolution Pending?O Ye. @ No Re.oiution unre.oiv.d70 Yes @ No Review initiator: Obersnel,Bojan.

VT Lead: Neri. Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh. Anand K Date: 3/27/g8 sL Cornments: The basic concem in this Discrepancy Report is that there do not appear to be calculations for the fuel oil piping system that address pipe fluid flow velocity and pressure drop and a review of the pipe size information as shown on the P&lD's appears to show some inconsistencies in system design.

The comment is made that the piping from the day tank was sized to be compatible with the suction connections on the vendor supplied skid mounted fuel oil pumps. Reference is made to an attached drawing, Dwg 2447.300-241-005, which was reviewed and shows that the skid mounted connections are 1 1/2 inches in size. The gravity pipeline to these connections is sized at 1 inch, requiring a pipe reducer to make the connection. The diesel vendor drawing does not require 1 inch piping, however, the day tank vendors drawing does show a 1 inch connection for this gravity fuel oil pipe.

To put this in perspective, the fuel oil transfer system begins at the 35,340 gal stora0e tank in which the 40 gpm transfer pumps  ;

are mounted. These pumps have a 3 inch discharge connection which is reduced to 1 1/2 inches and then piped to the day tank.

From the day tank, the 1 inch gravity line feeds into the 1 1/2 inch piping connections the DG skid which in tum feed into the engine-driven and DC driven fuel oil pumps through 1 1/2 inch vendor supplied skid-mounted piping. The gravity feed 1 inch pipe is not under the same pressure as the other piping systems. It is possible that the engine-driven and DC driven fuel oil pumps are overcoming the flow resistance in the gravity pipeline instead of having the fluid delivered to their inlet connections at essentially atmospheric pressure. The 1 inch gravity line is the smallest pipe between the storage tank and the fuel oil pumps.

To compare with other pipe sizes, the vendor drawing also shows Printed 4W98 2:32;19 PM Page 2 of 3 1

~

ICAVP DR N3. DR-MP3-0823

. N:rthert Utiliti'sa Millstone Unit 3 Discrepancy Report that the fuel oil pressure retum header connection is 1 1/2 inch, which is also fitted with a 1 inch pipe and routed back into the day tank. Also, the gravity drain line from the day tank drip pan into plant drainage is sized at 3 inch.

Regarding the NU reference to calculation P(T)-1019, the system design pressures and temperatures are not an issue in this DR.

l This is addressed in DR-MP3-0840.

The operability of the diesels during the relatively short test periods may not be a sufficient assurance that the pump suction is appropriately designed and may mask potential consequences

! of an inadequate available Net Positive Suction Head on the pump itself over a long post accident period of diesel operation.

A piping size / pump NPSH calculation would alleviate such i concems.

Regarding the NU reference to the fact that there is no AC powered fuel oil pump, we agree and regret the error in describing the pumps.

l l

Pnnted 4W98 2:32:19 PM Page 3 of 3

DR No. DR-MP3-0971 N:rthea:t Utilities ICAVP Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION REJECTED Review Element: system Design Potential Operability issue Discipline: Mechanical Design O Yes Discrepancy Type: Calculation (G) No System / Process: NEW NRC significance level: 3 Date faxed to NU:

Date Published: 2/7/98 Discrepancy: Calculation SWS-MOV-1380M3

Description:

Calculation SWS-MOV-1380M3 [Rev. 0] documents conditions (pressure, temperature, flow, etc.) for the Service Water Systern (SWP) Motor Operated Valves (MOV). These conditions are used in the torque and thrust calculation.

Section 3.2.8 is a table of the flows through the SWP MOVs and the reference for the flow. Calculation P(T)-1092 (Reference 3.1.51) is the reference for a number of the flows. Calculation P(T)-1092 is superseded by Calculation 90-069-1116 (Reference 3.1.18). The flows determined in Calculation 90-069-1116 are considerably higher (non-conservative) in most cases than in Calculation SWS-MOV-1380M3.

Review Valid invalid Needed Date 2/2/98 initiator: Langel. D. 8 O O VT Lead: Nert, Anthony A 8 0 0 2/2/98 VT Mgr: schopfer. Don K O O O 2/2/98 2/3/o8 IRC Chmn: Singh. Anand K O O O Date:

INVALID:

Date: 3/27/98 RESOLUTION: Disposition:

NU has concluded that the issued reported in Discrepancy Report, DR-MP3-0971, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan in CRM3-98-0795 will be complete post startup and requires revising calculation SWS-MOV-1380M3 to delete the reference to superseded calculation P(T)-1092.

There is no impact on the design and licensing basis since CCN 2 to calculation SWS-MOV-1380M3 reconciled the flow rates used in the MOV calculations with those in the latest Proto Power calculations. When generating the CCN, the preparer did not remove the outdated calculation references (i.e., P(T)-

1092). CCN 2 to calculation SWS-MOV-1380M3 is provided with this DR. NU has concluded that this discrepancy is a Significant Level 4.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0971 has identified a condition not previously discovered by NU which requires correction. The approved l

corrective action plan in CR M3-98-0795 will be complete post Printed 4698 2:31:53 PM Page 1 of 2

ICAVP DR N3. DR-MP3-0971

• ' N:rthent Utilitie3 Millstone Unit 3 Discrepancy Report startup and requires revising calculation SWS-MOV-1380M3 to ,

t delete the reference to calculation P(T) 1092, There is no impact on the design and licensing basis since CCN 2 to calculation SWS-MOV-1380M3 reconciled the flow rates used in the MOV calculations with those in the latest Proto Power calculations. When generating the CCN, the preparer did not remove the outdated calculation references (i.e., P(T)-

l 1092). CCN 2 of calculation SWS-MOV-1380M3 is provided with this DR. NU has concluded that this discrepancy is a Significant Level 4.

Prev 6ously identified by NU7 U Yes (S) No Non Discrepent condition?O Yes (G) No Resolution Pending70 ve. @ No Re.osution unre.oiv.d70 ve. @ No Review in6tiator: Langel,D.

O O O **

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 3/27/98 sL comments: The CCN to Calculation SWS-MOV-1380M3 corrects the conditions referencing Calculation P(T)-935. The CCN does not correct the conditions referencing Calculation P(T) 1092.

I I

I l

Page 2 of 2 Pnnted 4698 2.31:53 PM