ML20247B925

Forwards Drs Identified During Review Activities for Independent C/A Verification Program.Twenty-two Drs for Which Nu Resolutions Have Been Reviewed & Accepted by S&L & Two Drs for Which Nu Resolution Has Not Been Accepted

ML20247B925
Person / Time
Site:	Millstone
Issue date:	05/06/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9805110148
Download: ML20247B925 (90)

Text

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W Don K. Schopfer Senior Wce President 312 269-6078 May 6,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed the following discrepancy reports (DRs) identified during our review

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

I have enclosed the following twenty-two (22) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0013 DR No. DR-MP3-0702 ,

DR No. DR-MP3-0122 DR No. DR-MP3-0813 ,

DR No. DR-MP3-0136 DR No. DR-MP3-0910 DR No. DR-MP3-0144 DR No. DR-MP3-0957 DR No. DR-MP3-0202 DR No. DR-MP3-0987 DR No. DR-MP3-0477 DR No. DR-MP3-0997 DR No. DR-MP3-0482 DR No. DR-MP3-0998 DR No. DR-MP3-0509 DR No. DR-MP3-1005 /

DR No. DR-MP3-0584 DR No. DR-MP3-1016 / .

DR No. DR-MP3-0655 DR No. DR-MP3-0687 DR No. DR-MP3-1026 DR No. DR-MP3-1093 j[

9805110148 900506 i PDR ADOCK 05000423 '

P PDR l

55 East Monroe Street + Chicago, IL 60603-5780 USA + 312-269-2000 i j

=, s United States Nuclear Regulatory Commission May 6,1998

) Document Control Desk Project No. 9583-100 Page 2 I have also enclosed the two (2) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.

DR No. DR-MP3-1011 DR No. DR-MP3-1088 Please direct any questions to me at (312) 269-6078.

Yours very truly,

),-f( 9 -

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

E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/1) NU m:Wevphrn98'uv0506-a &c l

l l

I

ICAVP DR N3. DR-MP3-0013 N:rthert Utilities Millstone unit 3 Discrepancy Report Review Group: Accident Mr.igaton DR RESOLUTION ACCEPTED Review Element: System Deuign p Discipline: I & C Design Discrepancy Type: Design Control Procedure Om SystenVProcess: N/A NRC Significance level: NA Date Faxed to NU:

Date Published: 8/22/97 Discrepancy: Impact of Re-Analysis of Transients and Accidents Descripuon: We have reviewed the following MP-3 documents:

A) NGP 3.12 Safety Evaluations, Rev. 9, April 7,1995; D) NGP 4.03 Changes and Revisions to Final Safety Analysis Reports,Rev.7,Nov. 4,1996.

C) Updated page markups for FSAR, Chapter 15, ACCIDENT ANALYSIS,as reviewed and submitted by Westinghouse under letter # NEU-96-623, dated November 25,1996.

The Chapter 15 Accident Analysis markups by Westinghouse, referenced above, include accidents which have been reanalyzed and/or accidents with additional information.

Although the limits and consequences may remain within the previously analyzed boundaries the methods, processes, or systems used to mitigate the consequences of an accident may j require changes based on the analysis and additional information {

submitted to NU by Westinghouse. l For example, Figure 15.0-9 that is used to represent the results ,

of the accident " EXCESSIVE LOAD INCREASE" which was analyzed in section 15.1.3 and marked up in the Westinghouse letter, added a " Low Pressurizer Pressure" and " Manual" to trip the Reactor Trip System to mitigate the transient. Also, a Note 3 was added which states the following: " Note that safety valve setpoints are not reached in the analysis of the Section 15.1.3 event."

l NGP 3.12 provides guidance for safety evaluations including l those resulting from transient and accident analysis. This is i discussed in some detail in Attachment 8.A to this procedure. j There are no identifiable steps or guidance in this procedure to evaluate the potential impact on training material, simulator scenarios, other calculations, etc.

NGP 4.03 provides guidance to screen and implement changes to Final Safety Analysis Report that summarizes the numerous calculations, analyses, evaluations, design information and plant descriptions.

There are no identifiable steps or guidance in this procedure to

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I evaluate the potentialimpact of analysis results on training material, simulator scenarios, other calculations,etc.

Both of these procedures may be supported by lower tier procedures. If that is the case, identify the procedures that Pnnted 5/6/98 3:29:39 FM Page 1 of 6

ICAVP DR NO. DR-MP3-0013 N:rtheast Utilitiea Millstone Unit 3 Discrepancy Report procedures. The impact of Westinghouse reanalysis for each reload cycle requires an assesment.

Review Valid invalid Needed Date initiator: Balodis, V. E. O O O 8'5'97 VT Lead: Raheja, Raj D 0 0 0 8'5'97 VT Mgt: Schopfer, Don K O O 8'5'97 O

IRC Chmn: singh, Anand K O O O 8' 1/97 Date:

INVAllD:

Date: $/4/98 RESOLUTION: Disposition:0 ( ORIGINAL or First)

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0013, does not represent a discrepant condition. There are four reasons for changing the FSAR:

1. Changes that affect the design basis of the plant: DCRs, DCNs, EWRs, etc. are governed by the Design Control Manual (DCM) and, therefore, appropriate reviews, including training impact review, are required per DCM form DCM 3-2C.

Fuel reloads are considered design changes so a DCR is prepared and processed per the DCM. This is done even if the specific design of the fuel assemblies is not being changed. The DCR identifies those transients reanalyzed for the particular reload and includes the Westinghouse documentation  !

I transmitting the analysis results. As specified in the DCR, review by other departments, including training, is required. j

2. Changes that affect the licensing basis: DC 10, incorporation and Implementation of License Amendments, and NGP 4.02, Proposed Tech Spec Change Request and Requests for Enforcement Discretion, govem changes to the Tech Specs and provide guidance for implementing those changes, including FSAR change requests. DC 10 has specific instructions for a training review.

3. Changes that affect operator action: DC1, Administration of Procedures and Forms, has guidance for including training impact on all procedure changes.

4. FSAR changes that are not generated as a result of design change, license amendment or procedure change would not automatically be routed to departments, such as training. There are not specific procedure requirements for the training f department to evaluate " stand alone* FSAR changes and FSAR j changes associated with a Notification of Suspected Error as  !

defined in NGP 4.03. The example cited in the DR with respect to Figure 15.0-9 falls into this category. This example represents changes to the FSAR to clarify the existing text, correct inaccuracies and add additional information for completeness.

l These changes are not being made to reflect new analysis.

Thus, it would not affect the previous assessments made under the DCRs for previous reloads. This applies not only to Chapter Printed S/6/98 3:29:39 PM Page 2 of 6

Northsast Utilitiss ICAVP DR No. DR-MP3-0013 Millstone Unit 3 Discrepancy Report 15 but to any chapter of the FSAR that could be used as source material for training. To capture these types of changes, step 6.3.2 of NGP 4.03 states that a CR should be initiated. Thus, reliance is placed upon the CR investigator to identify the need for training department review.

Based on the above, it is clear that those substantive changes (plant modifications, reload analyses etc) that could be the reason for revising the FSAR are covered by existing processes.

While preparing this response, however, NU recognized that changes falling into the fourth category, albeit of a subtle and non-intent nature, do have a chance of being underestimated in terms of their impact on the Nuclear Training Department. For this reason, CR M3 97-3141 was initiated to evaluate the need for process improvements regarding the review of non-intent FSAR changes for training impact.

NU views the proposed resolution to be one of enhancement to existing processes and, as such, believes that the described condition does not constitute a discrepancy.

Conclusion:

0 NU has concluded that the issue reported in Discrepancy Report.

DR-MP3-0013, does not represent a discrepant condition. Since core reloads are performed as Design Changes under the Design Control Manual (DCM), the controls in the DCM provide assurance that all re-analysis performed as part of a reload will receive review for impact on plant procedures and training (including simulator scenarios).

Investigation of this DR was expanded to include a review of the process for FSAR changes that are not associated with design changes. NGP 4.03 has guidance for processing each different type of FSAR change (design change, licensing change, change to operator action, etc.) Changes that are significant and affect the design or licensing basis or that affect operator action have programs and processes in place to ensure the appropriate reviews are completed. It was discovered however, that some non-intent changes could be misjudged in terms of their impact on Nuclear Training. CR M3-97 3141 was written to evaluate the need for process improvements regarding the review of non-intent FSAR changes for training impact.

NU views the proposed resolution to be one of enhancement to existing processes and, as such, believes that the described condition does not constitute a discrepancy.

DISPOSITION: (Final)

NU has concluded that the issue reported in DR-MP3-0013, does not represent a discrepant condition. This condition has been addressed previously in responses to DR-MP3-0696 (M3-IRF-01724), DR-MP3-0865 (M3-IRF-01450), and DR-MP3-0626 (M3-IRF-01456) which indicated the FSAR Change Request and Safety Evaluation processes would be revised. However, DR-MP3-0013 resolution rejection is predicated upon 'the process that identi'ies changes to the Accident Analysis of Record and the resultina Oction items -includina methorisJquipment.

Printed 5/6/98 3 29 39 PM Page 3 of 6

N:rthea:t Utilities ICAVP DR N2. DR-MP3-0013 Millstone Unit 3 Discrepancy Report training, FSAR update, etc. - remains in question *, The FSAR CR and Safety Evaluation processes have recently been revised which addresses all of the conditions identified. Procedure RAC 3, Changes and Revisions to Final Safety Analysis (supersedes NGP 4.03), effective 12/18/97, requires a Safety Evaluation Screening for both Upfront changes (with parent documentation) andUpdating changes be performed in accordance with RAC 12, Safety Evaluation Screens and Safety Evaluations, which superseded NGP 3.12 on 3/1/98. Section C.2 of the Safety Evaluation Screen Form requires intent changes to be evaluated per the Design Manual Design Engineering Screening Evaluation (Form 3-2C). This form requires an assessment of pntential impact on training, Simulator Certification Program, mandated programs, equipment design, setpoints, etc. For those areas determined to be potentially impacted, a review by the group responsible for the program is required. Reload analyses are documented as DCR's and are processed in accordance with the requirements of the Design Change Manual. For cases where the reload analyses include changes to the assumptions, credited operator actions, or results of an accident, these changes are evaluated only against the current analysis of record since no single source document of each accident analysis was ever established. The Design Control Manual (DCM) Design Engineering Screening Evaluation will assure reviews are performed which address training, simulator certification, and Emergency Operating Procedures. While changes in credited operator actions are addressed through the DCR process, there is no single separate document that summarizes all of the credited operator actions. Reliance is placed upon the evaluations performed for initial startup and the DCR process for subsequent changes. However, a program is now in place to develop baseline documentation for each accident analysis such that changes can be easily evaluated. While there is no specific NRC requirement for developing and maintaining such documentation, the evaluations from CR M3-97-3141 identified that such a document would improve control of credited operator actions. Thus AR's 97013531 and970114758 will develop a comprehensive list of credited operator actions and formalize the documentation of training necessary to ensure these actions are performed. The process for developing and maintaining a MP3 Safety Functional Requirements Manual has now been started.

The current plan is to include this list of credited operator actions in the MP3 Safety Functional Requirements Manual since control of the updating of this document is already addressed in the DCM. The SFRM will be issued after the startup of MP3.

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

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Previously identified by NU? O Yes Si No Non Discrepant Condition? S) Yes O No Resolution Pending?O Yes ei No Resolution Unresolved?O Yes <*! No Review initiator: Balodis, V. E.

VT Lead: Raheja. Raj D VT Mgr: schopfer, Don K Pnnted 5/6/98 329.40 PM Page 4 of 6

l N:rtherst Utilities ICAVP DR ND. DR-MP3-0013 l

Millstone Unit 3 Discrepancy Report

.,m.

NtC Chmn: Srgh. Anand K g g g use l oste: 11/18/97 l

sL Comments: ICAVP finds the disposition not acceptable.

ICAVP agrees with the four reasons or categories that NU provides in the response for changing the FSAR. However, we I believe that the example cited by us should have been identified I and processed under category (1) as stated in your disposition.

Therefore, the process that identifies changes to the Accident Analysis of Record and the resulting action items - including ,

methods, equipment, training, FSAR updates, etc.- remains in j question.

ICAVP reviewed these additional NU documents to support our conclusions:

i) Design Control Manual, NUC DCM, Rev. 5,5/7/97; li) Millstone Unit 3: Chapter 15 FSAR Design Basis Review, TAG-NU-96-06, September 13,1996 by YANKEE ATOMIC -

BOLTON; lii) UIR No.: 1041, Resolution of Yankee Report Comments on I Ch 15 review, (AR 97004565).

The ICAVP does not dispute the fact that Fuel Reloads are considered design changes so a DCR is prepared and processed per the Design Control Manual (Ref i). DCM, Rev.5, section 2.4 "10CFR50.59 SAFETY EVALUATION", TASK 3 instructs "If required (i.e. for DCR), COMPLETE 10CFR50.59 Safety Evaluation in accordance with NGP3.12.

NGP 3.12, Rev.10, March 1/97, SAFETY EVALUATIONS, section 6, INSTRUCTIONS, includes the seven questions under section 6.4.7 to determine if the change remains within the previously analyzed safety boundaries or if it is an Unreviewed Safety Question (USQ). If it remains within the previously analyzed boundaries and is not an USO the Preparer may make a qualitative Safety determination per section 6.4.8.1. The clarification in NGP 3.12 Attachment 8.A, Section A.5 SAFETY DETERMINATION GUIDANCE states "The qualitative determination may make use of the arguments used to determine that the Change is not a USQ to show that the Change would not increase public risk".

The original Licensing Basis Accident Analysis and the Technical Specifications define the boundary that separates what is acceptable, from the standpoint of public risk, and what is not. In this context, risk is intended as the combination of the probability of occurrence and the Consequences of accidents that could affect public health and safety. In the case of accident analysis, an accident is defined as a sequence of events beginning with an initiator, followed by the possible failures of operators and/or equipment to terminate the event, and resulting in Consequences (e.g., doses) to the public.

Theavnluntinn nf thn chnnnes in nctumnfinns and the recutic nf Pnnted 5/6S8 3:29:40 PM Page 5 of 6

N:Irth:ast Utilitl2s ICAVP DR No. DR-MP3-0013 Millstone Unit 3 Discrepancy Report analysis used to mitigate the consequences of an accident derived in response to the Unreviewed Safety Questions from the original Licensing Basis Accident Analysis or subsequent fuel reload analysis should consider the four elements of risk as discussed in Section A.5 SAFETY DETERMINATION GUIDANCE. As NU stated in their response, procedure NGP 4.02 govems changes to the Tech Specs and provides guidance for implementing these changes. A similar procedure can not be traced for the records and actions associated with Accident Analysis.

Since NU did not identify any other procedure, NGP 3.12 is the vehicle that must provide instructions to maintain a record and incorporate the original and updated Licensing Basis Accident Analysis assumptions and results.

The Chapter 15 FSAR Design Basis Review Report (Ref li) provides a one time summary of the status of the Accident Analysis of Record that, we believe, should have been discovered and evaluated under a MP-3 process. It does not address the maintenance and updates of these records. The UIR 1041 (Ref lii) addresses the incorporation of some changes in the FSAR. It does not discuss the incorporation or instructions for plant work processes.

We recommend that NGP 3.12 needs changes either to a Lower Tier Procedure, or a clear requirement for the use of a risk analysis process for each Licensing Basis Accident Analysis or fuel reload analysis. This should include an associated " Form" for each accident, to perform SAFETY DETERMINATION for accident mitigating items, actions, and time constraints, if any, as discussed in NGP 3.12 Attachment 8A, Sections A.S.1 through A.S.4 to assure their incorporation in the plant work processes.

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1 Pnnted 5/6/98 3:29.40 PM Page 6 of 6 t I

North 2a::t Utiliti2s ICAVP DR No. DR-MP3-0122 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Eternent: system Design Potential operability issue Discipline: Electncal Design Discrepancy Type: Drawing Om

,g systern/ Process: N/A NRC Significance level: 4 Date faxed to NU:

Date Published: 10/18/97 Discrepancy: Schematic and wiring drawing discrepancies at motor control centers.

Description:

Various discrepancies were identified between common figures (details), as shown on the wiring diagrams, and the corresponding schematic diagrams as listed below:

1) Motor Control Center (MCC) intemal wiring diagram (EE-9JF), figure SA indicates point 5 of contact 42-0 is connected to terminal point 4. The schematic diagram ESK-6AAA (3SWP*MOV57A) indicates point 5 of contact 42-0 is connected to point 6 of device 49X. In addition, wiring diagram EE-9JF indicates point 3 of contact 42-C is connected to terminal point 2 in figure 5A. Schematic diagram ESK-6AAA indicates point 3 of contact 42-0 is connected to point 4 of device 49X. Similar situation for 3SWP*MOV578 (ESK-6AAB),3SWP*MOV57C (ESK-6AAC), 3SWP*MOV57D (ESK-6AAD), 3SWP*MOV1028 (ESK-6AAV), 3SWP*MOV102D (ESK-6AAX), 3SWP*MOV115A (ESK-6AGF), 3SWP*MOV115B (ESK-6AGG), 3RSS*MOV20A (ESK-6LD), 3RSS*MOV20B (ESK-6LE), 3RSS*MOV20C (ESK-6LF), 3RSS*MOV20D (ESK-6LG), 3RSS*MV8837A (ESK-6LM),

3RSS*MV8838A (ESK-6LN), 3RSS*MV88378 (ESK-6LP),

3RSS*MV8838B (ESK-6LQ), and 3OSS*MOV34A (ESK-6LS).

2) Schematic diagram (ESK-6AAX) for service water motor operated valve (3SWP*MOV102D) indicates terminal point 2 is in-between contact 57-58 of 52S-3SWP*P1D and contact 5-6 of 49X. Wiring diagram EE-9GB indicates terminal point 2 is wired in the circuit between contact 57 58 of 52S-3SWP*P1D and the close torque switch (TOS17).

3) Schematic diagram ESK-6AAG (3SWP*MOV54B) indicates a connection between points 4 and 12 in the " seal-in" portion of the open circuit. The corresponding MCC intemal wiring diagram (EE-9JM, figure SE) does not indicate this connection. In addition, the wiring diagram (EE-9JM, figure SE) indicates a connection between terminal points 2 and 7, the schematic (ESK-6AAG) does not indicate this connection. Similar for 3SWP*MOV54D (ESK-6AAJ), 3SWP*MOV50A (ESK-6AAK),

3SWP*MOV50B (ESK-6AAL), 3RSS*MOV38A (ESK-6AFL), and 3RSS*MOV388 (ESK-6AFM).

4) Schematic diagram ESK-6AAW (3SWP*MOV102C) indicates the use of a transfer switch (43-3SWP*MOV102C) in the control circuit. The schematic and wiring diagram (2424.100-245 sht 689) do not match in various cases. As an example, the schematic indicates point 26 of the switch is connected to terminal point TBC-8, only. The wiring diagram indicates and ndditinnn[Lonanctinn in nnint 97 nf the enma cwitch Rimilar Pnnted 5698 3:30:02 PM Page 1 of 6

N::rthea:t Utilities ICAVP DR N3. DR-MP3-0122 Millstone Unit 3 Discrepancy Report situation for 3SWP*MOV102A (ESK-6AAU & 2424.100-245 sht.

689).

5) The wiring diagrams for 3SWP*MOV102A (EE-9JM, figure SD

& EE 9FX) indicates fuse FU1 point 2 (3SWP*MOV102A) is connected in the close circuit, between the torque switch (TOS17) and TBB-47. The schematic diagram (ESK-6AAU) indicates the fuse FU1 point 2 is connected to TBB-48.

Review Valid invalid Needed Date

'nttiator: Morton. R. O O O 9/26/97 VT Lead: Nert, Anthony A O O O 10' '97 VT Mgr: schopfer. Don K O O O 1o' 3'S7 IRc Chrnn: singh, Anand K O O O 10/14'S7 Date:

INVALID:

Date: 5/1/98 RESOLUTION: FIRST RESPONSE:

Disposition.:

NU has concluded that issues # 1,2 and 3 in Discrepancy Report. DR-MP3-0122, have identified conditions not previousiy discovered by NU which requires correction. -

Issue # 1) discusses a conflict between Figure SA on EE-9JF and a number of RSS, QSS & SWP motor operated valve ESKs for I the intemal wiring of the 42-0 & 42-C seal-in contacts to TB1.  !

The present configuration in this figure shows the 42-0 contact

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wired to TB1-4 & SA and the 42-C contact wired to TB1-2 & 3A.

After a review of each elementary with their corresponding internal and extemal MCC wiring drawings, it has been determined that Figure SA on EE-9JF is in error for the referenced schematics. This figure and it's associated table should be revised for the referenced schematics to show the 42-O contact wired to TB15 & SA in lieu of TB1-4 & SA and the 42 -

C contact wired to TB13 & 3A in lieu of TB1-2 & 3 A. This is drawing change only, and will bring all the documents into agreement with this revision.

l Issue # 2) A review was performed of ESK-6AAX, EE-9GB & i Figure SA on EE-9JF for the location of terminal point 2 in the closed circuit of 3SWP*MOV102D. Both intemal and external wiring drawings depict the location of terminal point TB1-2 to be between the valve's limit / torque switch and the 57-58 contact of 52S-3SWP*P1 D.

This agrees with the SWEC termination tickets for conductor

! SC2 in cable's 3SWPDPC045 and 3SWPDPC046 as well.

l Therefore, ESK-6AAX needs to be revised to show terminal point 2 in the same location as it's corresponding intemal and external wiring drawings. This is a drawing change only, no field work required.

Printed s/6/98 3-30:03 PM Page 2 of 6

N::rth:ast Utilities ICAVP DR No. DR-MP3-0122 Millstone Unit 3 Discrepancy Report issue # 3) The referenced SWP & RSS motor operated valve schematics were verified against Figure SE on EE-9JM to validate the discrepancy. The Figure depicts an unneeded jumper between TB1-2 & 7 and elimination of a required jumper between TB1-4 & 12, by means of a deviation symbol (i.e. a darkened triangle). The darkened triangle means that an intemal wire needs to be added to the Figuro and is correlated with the applicable starter by the addition of this symbol to the deviation column of the corresponding table. Since the darkened triangle is not in deviation column for the referenced schematics, the impression given is that the needed jumper appears not to be installed and unneeded jumper appears to be installed in these starters. However, it has been determined that this symbol is misplaced in the Figure and should be moved to be to the left of the jumper between TB12 & 7. This will eliminate the unneeded jumper between TB1-2 & 7 and insert the required jumper between TB1-4 .i 12. This change has already been documented by DCN DM3-09-079197 which was approved on 7/25/97. Since this is after the 27 of May, credit could not be taken for pre-discovery. There is no additional change needed by this issue.

Condition Repo t (CR) M3-97-3711 was written to provide the necessary corrective actions to resolve these issues. Approved Corrective Action Plan (CAP) (attached) and DCN DM3-00-1765-97 were issued to correct the design drawing discrepancies. No work is required in the field.

NU also has concluded that issues # 4 and 5 in Discrepancy i Report, DR-MP3-0122, do not represent discrepant conditions.

Issue # 4) Both schematics ESK-6AAU rev.13 and 6AAW rev.15 were reviewed against wiring drawings 2424.100-245-689 rev.E, 690 rev.E,691 rev.F & EE-3BA rev.4 for the wiring at points 25-26-27 on the transfer switches for both motor operated valves and a discrepant condition could not be found on any of these drawings. There are no changes required by this issue.

Issue # 5) This issue implies there is a discrepant condition between Figure SD on EE-9JM rev.5,9FX rev.12,3BA rev.4 &

ESK-6AAU rev.13 for the wiring from fuse FU-F2A through TB1- l 2 in the MCC to TBB-48 in the FTSP. However , a discrepancy could not be found during this verification process. It appears Figure SD on EE-9JM was misinterpreted, because using the i deviation symbol (i. e. darkened circle) all the documents are in i agreement. There are no changes required by this issue.

l

Conclusion:

NU has concluded that issues # 1,2 and 3 in Discrepancy Report, DR--MP3-0122, have identified conditions not previously discovered by NU which requires correction. Condition Report (CR) M3-97-3711 was written to provide the necessary corrective actions to resolve these issues. Appro. ved Corrective Action Plan Pnnted 5/6/98 3.30.03 PM Page 3 of 6

Northsa:t Utiliti:s ICAVP DR No. DR-MP3-0122 Millstone Unit 3 Discrepancy Report (CAP) (attached) and DCN DM3-00-1765-97 were issued to correct the design drawing discrepancies. No work is required in the field.

NU also has concluded that issues # 4 and 5 in Discrepancy Report, DR-MP3-0122, do not represent discrepant conditions.

NU has reviewed the referenced drawings and concluded that they are consistent and correct.

SECOND RESPONSE:

Disposition:

NU has concluded that new issues 1 and 4 reported in Discrepancy Report, DR MP3-0122, have identified conditions not previously discovered by NU which require correction.

Item 1: The standard detail Figure SA on EE-9JF has been reviewed to confirm that the changes associated with DCN DM3-00-1765-97 did not impact any other circuits. However, during this review a drafting error was found, DCN DM3-00-1765-97 inadvertently deleted "open square symbol" from the standard detail for 3CVS*MOV25 circuit. NU considers this to be a minor drafting error that does not affect the design or licensing basis. A CR Change Form (attached) has been issued to revise CR M3-97 3711 to provide a positive statement that there is no impact on the other circuits, listed in the corresponding table, as a result of this DCN.

Item 3: The standard detail Figure SE on EE-9JM has been reviewed to confirm that the changes associated with DCN DM3-00-791-97 does not impact any other circuits. A CR Change Form has been issued to revise CR M3-97-3711 to provide a positive statement that there is no impact on the other circuits, listed in the corresponding table, as a result of this DCN.

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

Item 4: S&L indicated that on wiring diagram (25212-39245 sh.

691) the wire on TBC-19 should be wired out to device AM point 35 not 39 as shown on the wiring diagram. Rev'iew of this wiring diagram indicates that a wiring discrepancy exists in that the wire from TBC-19 is terminated on device AM point 35. NU considers this to be a minor drafting error that does not affect the design or licensing basis.

Condition Report (CR) M3-98-2085 dated April 21,1998, was written to document and provide the neces-sary corrective actions to resolve the minor drawing errors identified in items one and four. The approved Corrective Action Plan for M3 2085 has corrected these minor drafting errors by issuing DCN DM3-01-1765-97 to revise the standard detail Figure SA on EE-9JF and DCN DM3-00-371-98 to revise 25212-39245 sh. 691 wirina diagram. These draftino errors do not effect the desian or Pnnted 5/6/98 3:30:03 PM Page 4 of 6

N rtheast Utilities ICAVP DR No. DR-MP3-0122 Millstone Unit 3 Discrepancy Report licensing basis for MP3.

Conclusion:

I NU has concluded that new issues 1 and 4 reported in Discrepancy Report, DR-MP3-0122, have identified conditions not previously discovered by NU which require correction, Condition Report M3-98-2085 has been written with its corrective actions implemented that corrects these minor drafting errors by issuance of DCNs DM3-01 1765-97 that revised the standard detail Figure SA on EE-9JF and DM3-00-371-98 that revise i 25212-39245 sh. 691 wiring diagram.

Previously identified by NU? O Yes

• No Non Discrepant Condition?O Yes t f.4

• Resolution Pending?O ves ' * ' No Resolution Unresolved?O yes re' No j Review f Initiator: Morton, R.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh. Anand K Date: 5/1/98 I SL Comments: FIRST RESPONSE:

In general, S&L agrees with NU's response with the following comments:

Item 1) NU indicated that for these MOV circuits, the standard detail (Figure SA on EE-9JF) will be revised to coincide with the schematics (reference CR M3-97-3711 & DCN DM3-00-1765-97). S&L agreec, since it appears that this change does not impact other circuits. NU should confirm and provide a positive statement that there is no impact to the other circuits, listed in the corresponding table, as a result of this change.

Item 2) S&L agrees.

Item 3) NU indicated that for these MOV circuits, revision to the standard detail (Figure SE on EE-9JM) has been documented by DCN DM3-00-0791-97 and no additional changes are needed.

S&L agrees, since it appears that this change does not impact other circuits. NU should confirm and provide a positive statement that there is no impact to the other circuits, listed in the corresponding table, as a result of this change.

item 4) Based on the drawings provided by NU, with this

! response, S&L agrees with the following exception: Terminal block TBC point 19 on drawing 25212-39245 sht. 691 Rev. F indicates the wire address as 2AM.39, it should be 2AM.35.

Note, the original set of Aperture cards supplied to S&L for the Fire Transfer Switch Panel (FTSP) were filed under the vendor drawing number, such as 12179-2424.100-245-689 Rev. 2, these are the original" Reliance Custom Control Drawings". The drawing provided by NU for this response is 25212-39245 sht. 689 Printed 5/6/98 3:30:03 PM Page 5 of 6

North 20ct Utiliti:s ICAVP DR No. DR-MP3-0122 Millstone Unit 3 Discrepancy Report Rev. E, dated 5/9/94 (S&W Dwg 12179-2424.100-245-689) and indicates it is " Redrawn" from the original vendor drawing.

Item 5) S&L agrees.

SECOND RESPONSE:

S&L agrees with NU's second reponse.

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Printed 5/tV98 3:30:04 PM Page 6 of 6

N:rthe:st Utilities ICAVP DR N3. OR-MP3 0136 Millstone Unit 3 Discrepancy Report Review Group: Accident Mitigation DR RESOLUTION ACCEPTED n

Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation Om 4' - '

System / Process: N/A NRc Significance level: 4 Date faxed to NU:

Date Published: 9/11/97 Discrepancy: Feedwater Calculation 12179-735P(T) Discrepancy

Description:

While reivewing the calcualtion 12179-735P(T): " Failure of Feedwater Regulating Valve at Zero Power Level", Revision 0, dated 03DEC81, a math error was discovered on page 10 of the calculation. The Steam Generator Inlet Pressure is calculated to be 1313 psia. The computed value is 1213 psig when the math i error is corrected. As this value is the basis for the remainder of the branch flow and pump curve adjustments, it could not be verified that the feedwater flow to a steam generator does not increase by more than 100% after the pos'ulated failure of the feedwater regulating valve as required by the analysis assumptions stated in FSAR 15.1.2.2, Case 2, item 2. i Review l Valid invalid Needed Date I initiator: Peebles, W. R.

O O O 8'3/S7 VT Lead: Raheja. Raj D 9 0 0 9/3'97 l

VT Mgr: schopfer, Don K O O O $'8/97 j IRC Chrnn: Singh, Anand K O O O S'5/97 Date:

INVALID:

)

Date: 5/4/98 RESOLUTION: Additional Background Information Supplied By NU:

Subsequent NU review determined that the correct " required pressure" on page 10 of the calculation is 1113 psia. This lower pressure results in a flow rate of approx. 8.9x10E6 lb/hr, instead of the 7.55x10E6 lb/hr listed by the calculation. This higher flow rate in 235% of the normal full load value instead of the 200%

stated in FSAR Section 15.1.2. FSAR Section 15.1.2 concludes that the feedwater malfunction accidents are enveloped by the uncontrolled rod cluster control assembly bank withdrawal accident of Sec.15.4.1. This statement needs to be reconfirmed for the feedwater control valve accident at 0% power with the higher flow rate.

Second Response:

S & L considers the NU response in M3-IRF-00397 to Discrepancy Report DR-MP3-0136 as unacceptable. S & L provides the following response:

The revision to calculation [12179-735P(T)], which corrected the math error, determined a flow rate that is 235% of nominal flow.

This exceeds the limit assumed in the FSAR 15.1.2 analysis, 200%.

, The FSAR identifies the controlling reactivity insertion event as a I Pnnted 5/6/98 3:30:18 PM Page 1 of 4

N:rthea:t Utilities ICAVP DR ND. DR-MP3-0136 Millstone Unit 3 Discrepancy Report i rod withdrawal from subcritical conditions. The deportability evaluation indicates that Westinghouse has been contacted to determine if the reactivity insertion limit will be exceeded by the higher flow rate (235% of nominal flow).

Closure of this DR requires the following documentation:

1) the results of the Westinghouse evaluation / analysis of the reactivity insertion for 235% of nominal feedwater flow for the zero power condition,

2) the reevaluation of the deportability of this issue, per 10CFR50.72, based on the results of the Westinghouse analysis (item 1), and

3) a summary of actions and schedule that NU proposes for closure of this condition.

Disposition:

NU has concluded that Discrepancy Report DR-MP3-0136 has identified a condition not previously discovered by NU which requires correction. Condition Report (CR) M3-97-3186 was written to provide the necessary corrective actions to resolve this issue. The Calculation 12179-735P(T) will be revised to correct the identified error. The FRV malfunction at Zero Power analysis will be rerun using the recalculated flow rate. NU has initiated a deportability evaluation per NGP 2.25 to determine if the identified condition is reportable. NU will submit a follow-up response describing the NGP 2.25 results as well as the additional corrective action results. Based on the response from NU, S&L may need to re-evaluate the significance level.

Second Response:

NU concludes that Discrepancy Report, DR-MP3-0136, has identified a condition not previously discovered by NU which has been corrected. The approved corrective action plan for CR M3-97-3186 (attached) provides the following: Calculation 735P(T) was changed to correct the mathematical error, and Change 1 to revision 0 (attached) was issued on November 10,1997. The maximum feedwater flow rate at zero power during the Feedwater Malfunction event increased to 235% of rated feedwater flow as a result of the correction.

Westinghouse analyzed the event again with the new value for peak flow, Westinghouse indicated in their letter of February 13, 1998 (attached) that the event is bounded by the hot full power case. The event was analyzed to demonstrate that the DNB (Departure from Nucleate Boiling) design basis is met. The results show that the increase in power, from zero, is less than 2%, and the DNB design basis is met. The continuous addition of excessive feedwater is prevented when the feedwater is isolated as a result of a Safety injection signalinitiated by a low steam line pressure or low pressurizer pressure.

The Deportability Determination was completed on 10/1/98, and concluded that the issue was not reportable. The Deportability Determination is attached as part of CR M3-97-3186.

The Westinghouse letter also included proposed paae chanaes Pnnted 5/6/98 3:30:18 PM Page 2 of 4

l N:rthea:t Utilities ICAVP DR No. DR-MP3-0136 Millstone Unit 3 Discrepancy Report ,

to the FSAR, including the affected figures. The FSAR change package (attached) to incorporate these new results was approved by PORC on 4/3/98 (meeting #3-98-110) and will be submitted to the NRC prior to Startup. Correction of this discrepancy does not affect the conclusion that the Feedwater event was, and remains, bounded by the plant design and licensing basis, therefore NU concludes that DR-MP3-0136 should be rated as Significance Level 4.

)

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0136 has identified a condition not previously discovered by NU which requires correction. The calculation will be revised to correct this error. Condition Report (CR) M3-97-3186 was written to provide the necessary corrective actions to resolve this issue. NU has initiated a deportability evaluation per NGP 2.25 to determine if I the identified condition is reportable. NU will submit a follow-up response describing the deportability evaluation results as well as the additional corrective action results. Based on the response from NU, S&L may need to re-evaluate the significance level.

Second Response:

by NU which has been corrected. The approved corrective 4 action plan for CR M3-97-3186 (attached) provides the following:

Calculation 735P(T) was changed to correct the mathematical  !

error, and Change 1 to revision 0 (attached) was issued on '

November 10,1997. The maximum feedwater flow rate at zero power during the Feedwater Malfunction event increased to 235% of rated feedwater flow as a result of the correction.

Westinghouse analyzed the event again with the new value for peak flow. Westinghouse indicated in their letter of February 13, 1998 (attached) that the event is bounded by the hot full power case. The event was analyzed to demonstrate that the DNB (Departure from Nucleate Boiling) design basis is met. The i results show that the increase in power, from zero, is less than l 2%, and the DNB design basis is met. The continuous addition of excessive feedwater is prevented when the feedwater is isolated as a result of a Safety injection signal initiated by a low .

steam line pressure or low pressurizer prcssure.The Deportability Determination was completed on 10/1/98, and concluded that the issue was not reportable. The Deportability Determination is attached as part of CR M3-97-3186.The Westinghouse letter also included proposed page changes to the FSAR, including the affected figures. The FSAR change package (attached) to incorporate these new results was approved by PORC on 4/3/98 (meeting #3-98-110) and will be submitted to the NRC prior to Startup. Correction of this discrepancy does not affect the conclusion that the Feedwater event was, and remains, bounded by the plant design and licensing basis, therefore NU concludes that DR-MP3-0136 should be rated as Significance Level 4.

Attachments:

CR M3-97 3186 Calculation 735P(T), rev 0, change 1 Westinghouse letter NEU-98-015 Printed s/6/98 3.30.18 PM Page 3 of 4

I Northeast Utilities ICAVP DR Ns. DR-MP3-0136 Millstone Unit 3 Discrepancy Report FSAR Change Request 98-MP3-43 (approved 4/3/98)

Previously identifled by Nu? (,) Yes t No Non Discrepant Condition?U Yes t No Resolution Pending?O ve. + No ne.oiution unre.oived?O ve. + No Review CePtable Not Acceptable Needed Date j initiator: Peebles, W. R.

VT Lead: Raheja. Raj D 0 0 =

VT Mgr: schopfer, Don K O =

IRc Chmn: Singh, Anand K Date: 5/1/98 SL Comments: The revision to calculation [12179-735P(T)], which corrected the math error, determined a flow rate that is 235% of nominal flow.

This exceeds the limit assumed in the FSAR 15.1.2 analysis, 200 %.

f i

The FSAR identifies the controlling reactivity insertion event as a .

rod withdrewt from subcritical conditions. The deportability evaluation indicates that Westinghouse has been contacted to l determine if the reactivity insertion limit will be exceeded by the j higher flow rate (235% of nominal flow).

Closure of this DR requires the following documentation: I

1) the results of the Westinghouse evaluation / analysis of the j reactivity insertion for 235% of nominal feedwater flow for the I zero power condition,  !

l

2) the reevaluation of the deportability of this issue, per i 10CFR50.72, based on the results of the Westinghouse analysis )

(Item 1), and

3) a summary of actions and schedule that NU proposes for closure of this condition.

Second Response provided by M3-IRF-02013 addressed the three criteria stated above by providing the revised calculation, the Westinghouse evaluation of the issue and the approved FSAR Change Request to correct the FSAR text.

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Pnnted S/6/98 3.30.18 PM Page 4 of 4 l

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N:rth:ast Utiliti;s ICAVP DR No. DR-MP3-0144 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p

Discipline: Mechanical Design Discrepancy Type: Drawing System / Process: OsS NRC Significance level: 4 Date faxed to NU:

Date Published: 12/20/97 Discrepancy: Discrepancies on P&lD EM-115A Revision 18 are as follows:

Descripuon: Item 1 P&lD EM-115A shows valves 3QSS*MOV34A and 3OSS*MOV34B closing on a low level signal from Refueling Water Storage Tank (RWST) level switches 3QSS*LS56A and 3QSS*LS568, respectively. This is inconsistent with Design Basis Summary Document (DBSD) 3DBS-NSS-002, Revision 0, Sections 3.1,7 and 12.2.7.3 According to the DBSD, valves 3QSS*MOV34A and 3OSS*MOV34B close on a RWST empty level signal.

Also, the P&lD is inconsistent witliin itself. First, a signal from both RWST level switches 30SS*L56A and 3OSS*L56C is shown going to valve 3QSS*MOV34A at coordinate N1.

Second, a signal from both RWST level switches SQSS*L56B and 3QSS*L56D is shown going to valve 3OSS*MOV348 at coordinate N4. However as stated above, the signals to valves 4 3OSS*MOV34A and 3OSS*MOV34B are shown at coordinates l JS & J7 only from switches 3QSS*LS56A and 3QSS*LS568, respectively.

Item 2 FSAR Section 6.3.5.1 requires the Refueling Water Storage Tank temperature to be recorded in the control room. P&lD EM-115A does not show this recorder.

Review Valid Invalid Needed Date intuator: Feingold. D J O O O 12/2/97 VT Lead: Neri, Anthony A O O O 12/5/97 VT Mgr: Schopfer, Don K O O O 12/11/97 IRC Chmn: singh, Anand K O O O 12/16/97 Date:

INVALID:

Date: 5/4/98 RESOLUTION: - Northeast Utilities' First Response -

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0144, has identified a condi' ion not previously discovered by NU which requires correction. This discrepancy meets the criteria specified Printed 5/6/98 3:30:32 PM Page 1 of 4

N:rthe:st Utilities ICAVP DR N2. DR-MP3-0144 Millstone Unit 3 Discrepancy Report in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concerns and meets the Unit 3 deferral criteria. CR M3-98-0514 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0144, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0514 has been written to develop and track resolution of this item per R P-4.

-- Northeast Utilities' Second Response -

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0144 does not represent a discrepant condition. NU has concluded that these issues are deferrable based on section 1.3.2.e of U3 PI 20. The corrective actions in CR M3-98-0164 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4.

The original discrepancy description was:

Item 1 P&lD EM-115A shows valves SQSS*MOV34A and 3QSS*MOV34B closing on a low level signal from Refuelirsg Water Storage Tank (RWST) level switches 3QSS*LS56A and 3OSS*LS56B, respectively. This is inconsistent with Design Basis Summary Document (DBSD) 3DBS-NSS-002, Revision 0, Sections 3.1.7 and 12.2.7.3. According to the DBSD, valves 3QSS*MOV34A and 3OSS*MOV34B close on a RWST empty level signal.

1 l

Also, the P&lD is inconsistent within itself. First, a signal from both RWST level switches 3QSS*L56A and 3OSS*L56C is l shown going to valve 30SS*MOV34A at coordinate N1.

! Second, c signal from both RWST level switches 3OSS*L56B l

and 3QSS*L56D is shown going to valve 3QSS*MOV348 at  ;

coordinate N4. However as stated above, the signals to valves 3OSS*MOV34A and 3OSS*MOV348 are shown at coordinates J5 & J7 only from switches 3OSS*LS56A and 3OSS*LS56B, respectively.

I ltem 2

,_Pnnted s/6/98 3:30:33 PM Page 2 of 4

l N:rthert Utilities ICAVP DR N3. DR-MP3-0144 Millstone Unit 3 Discrepancy Report FSAR Section 6.3.5.1 requires the Refueling Water Storage Tank temperature to be recorded in the control room. P&lD EM-115A does not show this recorder.

U3 Pt 20 section 1.3.2 e defines the type of discrepancies which will be completed during the next refueling outage or later.

Attachment 11 defines the type of issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

NU concludes that the assignment of priority 4 is correct and in accordance with U3 PI 20 section 1.3.2 e.

Significance level criteria does not apply to the new issue as this is not a discrepant condition.

CR M3-98-0514 was closed to CR M3-98-0164. The corrective actions in CR M3-98-0164 will correct these issues post startup as follows; Item 1 the level switches will be revised from " low" to " empty" and the common signal continuation reference from level switches A and C will be revised from "A" to "A and B" and switches B and D will be revised from "B" to "B and D".

Item 2 the P&lD shows the letter C inside a diamond shape, this represents a computer point thus the recording of the temperature. NU has concluded that this issue does not represent a discrepant condition.NU considers the overall classification of the DR to be significance level 4.

Conclusion:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0144 does not represent a discrepant condition. NU has concluded that these issues are deferrable based on section 1.3.2.e of U3 Pl 20. The corrective actions in CR M3-98-0164 will correct these issues post startup.

NU considers the overall classification of the DR to be significance level 4.

Previously identified by NU? O Yes 't ) No Non Discrepant Condition?O Yes IS) 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 IRC Chmn: singh. Anand K Pnnted $/6/98 3 30 33 PM Page 3 of 4

N:rth ast Utilities ICAVP DR No. DR-MP3-0144 Millstone Unit 3 Discrepancy Report

_ ,.. . " ' ' ~ ~ ' '

O O O Date: 5/4/98 SL comments: .-. Sargent & Lundy's Comments on Northeast Utilities' First Response --

The intended corrective action is not apparant from the Northeast Utilities disposition or from condition report CR M3-98-0514.

This discrepancy has a potential to affect critical control room drawings (P&lDs), and therefore, may not meet the deferral criteria.

--- Sargent & Lundy's Comments on Northeast Utilities' Second Response -

Sargent & Lundy finds the clarification provided in Northeast Utilities'second response acceptable.

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l Pnnted 5/6/98 3:30.33 PM Page 4 of 4 1

N:rthert Utilities ICAVP DR N3. DR-MP3-0202 (

Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Change Process p

Discipline: P: ping Design Discrepancy Type: Corrective Action Om systenvProceass: N/A NRC Signincance level: NA Date faxed to NU:

Date Published: 9/29/97 Discrepancy: Insufficient Justification Provided in Nonconformance Report Package

Description:

NCR # 3-92-0269 dealt with some cracked lines in the Radioactive Waste Boron Recovery System. The NCR states that m3tallurgical examination revealed that the cause was stress corrosion cracking. The disposition was to replace the cracked piping with piping fabicated from the same material and to make no design changes. No justification is provided for this disposition.

Review Valid invalid Needed Date initiator; sheppard, R. P. O O O S'15'97 VT Lead: Ryan, Thomas J O O O S/15/97 VT Mgr: schopfer, Don K O O O 9/22/97 IRC Chmn: Singh, Anand K O O 9/25/97 Date:

INVALID:

Date: 5/4/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0202, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B 16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 defenal criteria. CR M3-97-3698 has been written to develop and track resolution of this item per l

RP-4.  ;

Conclusion:

NU has concluded that Discrepancy report, DR-MP3-0202, has '

identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B 16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-97-3698 has been written to develop and track resolution of this item per RP-4.

2nd Response:

Disposition:

NU has concluded that this issue reported in DR-MP3-0202 has l Pnnted 5/6/98 3:30:50 PM Page 1 of 3 1

_._____U

N:rthenst Utilities ICAVP DR N3. DR-MP3-0202 Millstone Unit 3 Discrepancy Report _

identified a NON-DISCREPANT condition. Condition Report (CR) M3-97-3698 was closed reflecting the non-discrepant condition of this discrepancy report. The disposition of NCR 3-92-0269 will replace lines in which metallurgical exam indicated stress corrosion cracking, currently it is scheduled to be completed BRFOO6 (See AR No. 96036480), while other work is also currently planned as indicated in the " Disposition Details",

which references EWRs M3-96253 and M3-94206, and therefore references the documentation wh'ch will resolve the condition (i.e., stress corrosion cracking) that led to the nonconforming cracked piping. (Note: the work described in these documents is not yet complete.)

The technical basis is provided to resolve the nonconformance is in the following documentation:

EWR M3-96253 - Complete official abandonment of the LWS evaporator and resolve open issues assnciated with the LWS evaporator.

EWR M3-94206 - Incorporated deficiencies identified on LWS evaporator portion of the system into one tracking document.

This EWR is to be worked with EWR M3-96253.

ACR M3-96-0603 - Documents the fact that certain AWOs on the LWS evaporator could be considered to have implemented a design change via the work control process.

DCR M3-97022- In response to EWR M3-96253 this DCR will remove the LWS evaporator from service to resolve maintenance operational and licensing concerns.

DCN DM3-00-0697 h coordination with DCR M3-97022, removal of the Liquid Waste System (LWS) Evaporator from Service.

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

Conclusion:

NU has concluded that this issue reported in DR-MP3-0202 has identified a NON-DlSCREPANT condition. Condition Report (CR) M3-97-3698 was closed reflecting the non-discrepant condition of this discrepancy report. The disposition of NCR 3-92-0269 will replace lines in which metallurgical exam indicated stress corrosion cracking, currently it is scheduled to be completed BRFOO6 (See AR No. 96036480), while other work is also cunently planned as indicated in the Disposition Details, l

which references EWRs M3-96253 and M3 94206, and therefore l references the documentation which will resolve the condition

( (i.e., stress corrosion cracking) that led to the nonconforming cracked piping. (Note: the work described in these documents is not yet complete.) Significance Level criteria do not apply here as this is not a discrepant condition.

Pnnled 5/%8 3:30 So PM Page 2 of 3

Northeast Utilities ICAVP DR No. DR-MP3-0302 Millstone Unit 3 Discrepancy Report Attachments:

EWR M3-96-253 - (Note: This document is not yet closed.)

l EWR M3-94-206 - (Note: This document is not yet closed.)

ACR M3-96-0603 - (Note: This document is not yet closed.)

DCR M3-97022 - (Note: This document is not yet closed.)

DCN DM3-00-0697 (Note: This document is not yet closed.)

Previously identified by NU7 Q Yes * > No Non Discrepant Condstion? *) Yes O No Resolution Pending?O ve. '

• i No Resolution Unresolved?O ve. '*) No Review in!tiator: Sheppard R. P.

VT Lead: Ryan. Thomas J VT Mgr: schopfer. Don K IRC Chmn: singh. Anand K Date: 5/4/98 sL comments: Review of NU's 1st Response:

The DR disposition states that the DR identified a a condition which requires correction. Condition Report (CR) M3-97-3698 has been written to develop and track resolution. The CR states that no adverse condition exists because a technical justification is not required for rework dispositions.

" Rework" does not resolve the condition (i.e., stress corrosion cracking) that led to the nonconforming cracked piping.

Therefore, a technical basis is needed to resolve the nonconformance.

Review of NU's 2nd Response:

S & L agrees that this is not a discrepant condition. NU's Materials Testing Laboratory issued Report No. 13-92-011 titled

" Failure Anslysis of Liquid Radwaste Piping" on November 3, 1992. One of the recommendations of this report was to ascertain the pH and chemistry of the LWS process fluid to determine if a more corrosion resistant material was required.

NCR 3-92-269 was issued on December 11,1992. DCR M3-97022 removes the system identified in NCR 3-92-269 from service.

Thus, it evident that NU was already investigating the stress corrosion cracking of the piping at the time NCR 3-92-269 was initiated and the concern about future use of the piping has been resolved.

Pnnted 5698 3 30:50 PM Page 3 of 3

N:rthent Utilities ICAVP DR N3. DR-MP3-0477 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Potential Operabihty issue Discipline: Othe' O yes Discrepancy Type: Calculation cG) No

~~

System / Process: SWP NRc Significance level: 4 Date faxed to NU:

Date Published: 1o/26/97 O!screpancy: Possible improper assumption about leak tightness of fire barriers

Description:

Calculations No.12179-P(R)-1087, Rev. O, " Control Building Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break,"12179-P(R)-1073, Rev. O, " Maximum Flood Levels and Effect on Safety-Related Equipment in the Diest Generator Building," P(R) 1194, Rev. 2, " ESF Bldg Flood Study:

Maximum Flood Height in the ESF Bldg due to a Pipe Break,"

and 12170-US(B)-287,PRA Bounding Estimated of Internal Flooding," calculate the potential flood levels in the various plant buildings. These calculations assume that all fire barriers are water tight. For this assumption to be valid, all of the features in the barrier (penetration seals and fire doors) would need to have a test or analysis demonstrating that they are water tight. In addition, fire doors are usually not water tight and any changes made to a fire door to make it water tight may invalidate the qualification as a fire barrier.

Review Valid invalid Needed Date '

Initiator: Launi, C. M. o'16'87 O O O VT Lead: Neri, Anthony A O O O 10/16S7 VT Mgr: schopfer, Don K O O O $o/20/97 IRc Chrnn: singh, Anand K O O O 1o/22/97 Date:

INVALID:

Date: 5/1/98 l I

RESOLUTION: FIRST RESPONSE Disposition:

NU has concluded that the issue reported in discrepancy report, DR-MP3-0477, does not represent a discrepant condition. No leakage from a building is a conservative position assumption when calculating maximum flood height, therefore, this is not a licensing or design basis concem. However, CR MP3-97-4725 has been initiated as an enhancement to provide the rationale for this assumption in these calculations. Significance Level Criteria do not apply here a this is not a discrepant condition.

l

Conclusion:

l NU has concluded that the issue reported in discrepancy Report, DR-MP3-0477, does not represent a discrepant condition. No leakage from the building is a conservative asumtion when calculating maximum flood height. CR MP3-97-4725 has been initiated as an enhancement to review the calculations and clarify assumption selecton. Significance Level Criteria do not apply here as this is not a discrepant condition.

l Pnnted 5/698 3 31:37 PM Page 1 of 3 1

N:rtheast Utilities ICAVP DR No. DR-MP3-0477 Millstone Unit 3 Discrepancy Report l SECOND RESPONSE Disposition:

NU has concluded that the issues reported in item 1 of Discrepancy Report, DR-MP3-0477, have identified conditions I

not previously discovered by NU which require correction. The I approved corrective action plan for CR M3-97-4725 (attached) has been revised to update and clarify post startup the 1 associated calculation and to provide a engineering evaluation or )

calculation post startup to address the leakage (fire doors, etc.)

from a flooding room to the adjacent rooms and areas where opposite train safety related equipment may be located. Our review of this discrepancy has determined that many of these rooms such as the Service Water cubicles and Diesel cubicles I open to the outside rather than to each other. Rooms which open to the opposite train such as the Auxiliary Feed Water pump cubicles are equipped with floor drains and the safety related equipment is located off the floor on high foundation.

Since these rooms have been evaluated for maximum flood levels due to pipe break within the room, it is not anticipated that the leakage through the fire door will adversely impact the redundant safety related equipment. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that the issues reported in item 1 of Discrepancy Report, DR-MP3-0477, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-97-4725 (attached) has been revised to update the associated calculation post startup and to provide a engineering evaluation post startup to address the leakage (fire doors, etc.) from a flooding room to the adjacent rooms. Our review of this discrepancy has determined that many of these rooms open to the outside rather than to each other Rooms which open to the opposite train are equipped with floor drains and the equipment is located off the floor on high foundation. Since these rooms have been evaluated for maximum flood levels due to pipe break within the room, it is not anticipated that the leakage through the fire door will adversely impact the redundant safety related equipment. 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 identired by NU? O Yes 18) No Non Discrepant Condition?O Yes t9: No Resolution Pending?O ve. <*' No Resolution Unresolved?O ve. <*) No Review initiator: Launi, C. M VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chnm: Singh. Anand K Date:

0 0 <

5/1/98 st Comments: FIRST RESPONSE Printed 5/6/98 3.31:38 PM Page 2 of 3 i i

Northeast Utilitias ICAVP DR No. DR-MP3-0477 Millstone Unit 3 Discrepancy Report While it is true that assuming that the fire barriers are leak tight is a conservative position for the room where the leak originated, it is not conservative when it comes to flood effects in adjacent rooms especially if the adjacent room contains redundant safety related equipment. The issue of this DR involves the adjacent rooms and areas.

SECOND RESPONSE The NU response is acceptable. This issue s being tracked by CR M3-97-4725. The significance level has been changed to Levt4.

Pnnted 5/6/98 3.31:38 PM Page 3 of 3

N:rthe2ct Utilities ICAVP DR NA DR-MP3-0482 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Potential Operability issue Discipline: Other Discrepancy Type: Calculation g

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

Date Published: 10/2&97 Discrepancy: The floor area for Cubicles Q,T and U is smaller than calcuiated resulting in a greater flood height

Description:

As a result of a review of Drawing 12179-EM-28, Rev.14, the floor area of Cubicle "Q"is approximately 442 sq. feet instead of

! the 599 sq. feet calculated in Calculation No. P(R) 1194, Rev. 2 "ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 24. The dimensions used for the cubicle in the calculation appear to include the wall thickness.

Using a floor area of 442 sq. feet results in a flood height of 9.5 feet. Calculation No. P(R) 1194 calculated a flood height of 7 feet.

As a result of a review of Drawing 12179-EM-2B, Rev.14, the floor area of Cubicle "T"is approximately 690 sq. feet instead of the 1121 sq. feet calculated in Calculation No. P(R) 1194, Rev.

2, "ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 28. The dimensions used for the cubicle in the calculation appear to include the wall thickness. Using a floor area of 690 sq. feet results in a flood height of 27 feet. Calculation No. P(R) 1194 calculated a flood height of 22 feet.

As a result of a review of Drawing 12179-EM-28, Rev.14, the floor area of Cubicle "U"is approximately 1359 sq. feet instead of the 1465 sq. feet calculated in Calculation No. P(R) 1194, Rev. 2, *ESF Bldg Flood Study: Maximum Flood Height in the ESF Bldg due to a Pipe Break," page 28. The dimensions used for the cubicle in the calculation appear to include the wall thickness. Using a floor area of 1359 sq. feet results in a flood height of 18.5 feet. Calculation No. P(R) 1194 calculated a flood height of 17 feet.

For Cubicles "T" and "U," this does not change the conclusions of the calculation (pages 30-32). However, Calculation No. P(R) 1194 requires that the wall between Cubicles "Q" and "R" and Cubicles "Q" ar.d "S" be water tight to a height of 7 feet. With the potential of flooding Cubicle "Q" to a height of 9.5 feet above the floor, Cubicles "Q," "R" and "S" could be flooded. Cubicle "R" contains the Loop A RHR pump and Cubicle "Q" contains the Loop B RHR pump. Technical Specifications 3.4.1.4.1 and 3.4.1.4.2 require at least one loop of RHR be operational during Mode 5. A flood in Cubicle "Q" to a height of 9.5 feet would l submerge the Loop B RHR pump.

! Assuming an unsealed penetraion a little more than 7 feet above l the floor, the potential exists to flow 1100 cubic feet of water to l Cubicle "R." This would flood Cubicle "R" to a height of annrnvimntniv

') fant nhnyn the finnr run in Finyntinn A A fonti Pnnted 5/6/98 3.32:09 PM Pagei of 3

Nnrthsast Utiliti:s ICAVP DR No. DR-MP3-0482 Millstone Unit 3 Discrepancy Report The Loop A RHR pump is located at Elevation 9' 3 3/4"(See Calculation No. P(R) 1194, Rev. 2, Attachment 2, page 3) or 4' 9 3/4" above the floor. Therefore, both RHR pumps would not be affected by such a flood.

The floor areas in this calculation were also used as input to Calculation No. 94-ENG-1013-M3, Rev.1.

Review Vahd Invalid Needed Date initiator: Launi, C. M-0 0 0 o' 'S7 VT Lead: Neri, Anthony A O O O 10/15'97 VT Mgr: Schopfer. Don K O O O o/20/97 IRC Chmn: singh, Anand K O O O so/2iis7 Date:

INVALID:

Date: 5/1/98 RESOLUTION: FIRST RESPONSE Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0482, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-97-4360 will correct calculation 12179-P(R)-1194 to address the reduction in floor area due to wall thickness post startup. The specific discrepancy noted for cubicle "Q" has been reviewed. As a result of other conservatism in the calculation it has been determined that there .

is no impact on the flood elevation in cubicle "Q'. On page 24 of  !

the calculation it is noted that the segment of the floor area l

adjacent to the containment structure was neglected in the calculation, apparently for the ease of calculation. Adding this area which was neglected and subtracting the area occupied by the wall thickness results in a gross area equal to that presented in the existing calculation and accordingly there is no change in flooding level for cubicle "Q". NU concurs with S&L that the area discrepancies for cubicles "T" and "U" do not impact the calculational results. Therefore there is no impact on the licensing or design basis and NU has concluded that this discrepancy is a Significance Level 4.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0482 has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-97-4360 will correct calculation 12179-P(R)-1194 to address the reduction in floor area due to wall thickness post startup. It has been determined that the discrepancies do not affect the conclusions of the flooding calculations and therefore do not impact the licensing or design bases. NU has concluded that this discrepancy is a Significance Level 4.

SECOND RESPONSE Printed 5/698 3 32:09 PM PaDe 2 of 3

N:rthert Utilities ICAVP DR No. DR-MP3-0482 Millstone Unit 3 Discrepancy Report Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0482, has identified a condition not previously discovered by NU which requires correction. Calculation Change Notice (CCN) Number 2 (attached) to calculation 12179-P(R)-

1194 concludes that the total area of cubicle Q (612 ft2) is greater than the area presently used in the calculation (599 ft2).

As such, their is no impact on the licensing or design bases. NU has concluded that this discrepancy is a Significance Level 4.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0482, has identified a condition not previously discovered by NU which requires correction. Calculation Change Notice (CCN) Number 2 (attached) to calculation 12179-P(R)-

1194 concludes) ~.A the total area of cubicle Q (612 ft2) is greater than the area presently used in the calculation (599 ft2).

As such, their is no impact on the licensing or design bases. NU has concluded that this discrepancy is a Significance Level 4.

Previously identified by NU? O Yes @ No Non Discrepant Condition?O ves @) No Resolution Pending?O ves '*) No Resolution Unresolved?O ve. + No Review A ceptable Not Acceptable Needed Date initiator: Launt, C. M.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K oate: 5/1/98 st convnents: FIRST RESPONSE This response is not acceptable. A review of drawing 12179-EB-10D (25212-24121) indicates that the floor area adjacent to the containment structure neglected in calculation 12179-P(R)-1194 is smaller than the area of the wall thickness included in the calculation. The calculation should be revised to determine the effect of not including the wall thickness and including the area adjacent to the containment structure or confirmig that there are no penetrations or unsealed penetrations above the calculated 7 foot flood height. The Significance Level remains at 3.

SECOND RESPONSE The response is acceptable. Calculation Change Notice 2 to Calculation 12179-P(R)-1194 calculated the floor area of Cubicle Q to be 612 sq. ft. This is greater than the area calculated in the present revision of Calculation 12179-P(R)-1194 and there is no impact on the design and licensing bases of the plant. The significance level has been changed to Level 4.

l l

Pnnted 5/6/98 3:32.10 PM Page 3 of 3

Northeast Utilities, ICAVP DR No. DR-MP3-0509 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: Mechanical Design O Yes Discrepancy Type: Component Data System / Process: HVX

$ No NRC significance level: 4 Date faxed to NU:

Date Published: 11/22/97 Discrepancy: Areas maintained at a negative pressure by SLCRS and ABVS

Description:

During review of the Supplementary Leak Collection and Release System (SLCRS) and the Auxiliary Building Ventilation System (ABVS) discrepancies regarding 1) which buildings and areas are maintained at a negative pressure durir.g a LOCA and

2) which systems are required to maintain the negative pressure were identified.

FSAR Section 1.2.10 states that following a postulated accident, particulate and gaseous radioactive material is ducted from the containment enclosure and the buildings contiguous to the containment structure to the supplementary leak collection and release system (SLCRS), where it is filtered and discharged to the atmosphere through an elevated stack rather than through a ground-level vent.

FSAR Section 3.1.2.41 states that the supplementary leak collection and release system (SLCRS) collects radioactive leakage from the containment to the containment enclosure and contiguous areas following a LOCA or release of radioactivity due to a fuel handling accident.

FSAR Section 6.2.3 states that the secondary containment is comprised of the containment enclosure building, engineered safety features building (partial), auxiliary building, main steam building (partial), and hydrogen recombiner building (partial). The secondary containment is kept under a negative pressure relative to atmoshperic pressure. The negative pressure is maintained with the SLCRS operating together with the charging pump, reactor plant component cooling water pump and heat i exchanger area ventilation system and auxiliary building filtration l portions of the auxiliary building ventilation system (ABVS). The I SLCRS operating together with the charging pump, reactor plant component cooling water pump and heat exchanger area l ventilation system and auxiliary building filtration portions of the auxiliary building ventilation system (ABVS) also maintains all l contiguous buildings (main steam valve building, engineered safety features building (partially), hydrogen recombiner building (partially), and auxiliary building) under a negative pressure following a DBA by exhausting air from these areas.

FSAR Section 6.2.3.1 states that the SLCRS is designed to maintain a negative pressure in areas contiguoas to the containment.

FSAR Section 6.5.1 states that the SLCRS system operated in conjunction with the charging pump, component cooling pump, Printed 5/6/98 3.33.33 PM Page 1 of 4 i

u --- _ _ - - - - - . - _ - - - - - - - - - - - - - - -

N:rthest Utilities ICAVP DR No. DR-MP3-0509 Millstone Unit 3 Discrepancy Report auxiliary building filters, is designed to maintain a negative pressure in the containment enclosure building and associated contiguous structures (auxiliary building, ESF building, main steam valve building, and hydrogen recombiner building) during a LOCA.

FSAR Section 6.5.3.2 states that the secondary containment at Millstone 3 consists of a containment enclosure structure and the contiguous buildings.

P&lD EM-148E-12 and ductwork drawings EB-72A-6 and EB-72B-6 shows that the SLCRS does not directly exhaust air from the hydrogen recombiner building as blankoff plates have been installed on the exhaust openings.

P&lD EM-148A-24 does not show the ABVS exhausting air from the main steam valve building.

P&lD EM-148E-12 does not show the SLCR exhausting air from the main steam valve building. P&lD EM-152B-10 shows 1,350 cfm transfer air to the SLCRS in the auxiliary building thru containment enclosure via MSV/ Cont shake space.

Review Valid invalid Needed Date j initiator: stout. M. D. O O O 1/6/97 I VT Lead: Nen, Anthony A O O O 11/7/57 1 /10'97 l

VT Mgr: schopfer, Don K O O O  !

IRC Chmn: singh, Anand K g ] O 11/18/97 Date:

INVALID:

Date: 5/2/98 RESOLUTION: First Response NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0509, do not represent discrepant conditions.

DR-MP3-0509 identifies that P&lDs EM-148E, EM-148A, and EM-152B do not provide the general area exhaust flow paths required to maintain the Secondary Containment under a negative pressure following a LOCA. The format and content of the MP3 P&lDs are established in procedure EDI 30255,"MP3 Piping and Instrumentation Diagrams Detailed Instructions for Format and Content." EDI 30255 does not require MP3 P&lDs to reflect the actual building arrangement. The P&lDs provide the systems configuration required to maintain the Secondary Containment under a negative pressure following a LOCA. The P&lDs are not required to provide general area exhaust flow rates, therefore, changes to P&lDs EM-148E, EM-148A, EM1528 are not required. 1 The Secondary Containment is comprised of the containment enclosure building, the auxiliary building, and sections of the  ;

engineered safety features building, the main steam valve l Pnnted 5/6/98 3 33:34 PM Page 2 of 4 l

N:rthe:st Utilities ICAVP DR Ns. DR-MP3-0509 Millstone Unit 3 Discrepancy Report l

l building, and the hydrogen recombiner building. The interior l walls of the engineered safety features building, the main steam j valve building, and the hydrogen recombiner building which i separate the areas contiguous to the containment from the remainder of the buildings serve as the secondary containment boundary. The areas that are not directly exhausted by an exhaust duct and registers located within the area are interconnected with adjacent areas that contain exhaust ducts and registers. The Secondary Containment Boundaries are identified on S&W EM-60 series drawings,

• Plant Fire Radiation and Pressure Boundaries." The areas of the hydrogen recombiner building that contain the capped off ducts are not part of the Secondary Containment Boundary The areas of the main steam building and hydrogen recombiner building that are within the Secondary Containment boundary are drawn down through the enclosure building by the SLCRS..

Calculation P(B)-1089," Establish Acceptance Criteria for Air Leakage Through Pipe and Electrical Penetration Seals,"

provides a summary table for the exhaust flow rates for the applicable areas. The summary table shows the exhaust flow rate for the containment enclosure building as 4950 cfm, the hydrogen recombiner building as 130 cfm and the main steam valve building as 1350 cfm. P&lD EM-148E indicates the total exhaust flow from these areas through the 36" X 18" screened opening as 6430 cfm As an enhancement, FSARCR 97-MP3-369 was initiated, on 7/28/97 to revise FSAR Section 6.2.3 to clarify the Secondary Containment Boundary. FSARCR 97-MP3-369 was initiated as a result of the CMP FSAR annotation process. Clarification of FSAR Sections 1.2.10, 3.1.2.41, and 6.5 is not required with respect to the Secondary Containment Boundary.

As an enhancement, CR M3-97-4557 was initiated to clarify the air flow rates on all of the MP3 P&lDs. CR M3-97-4557 corrective action requires a review of all air flows and notes on HVAC P&lDs, related Technical Specifications, and FSAR Sections. Based on the evaluation results, the P&lDs will be ,

revised to include clarifying notes or remove air flow information j and revise EDI 30225,if required. I Significance Level criteria do not apply here as this is not a discrepant condition.

Attachments:

CR M3-97-4557 FSARCR 97-MP3-369 (preliminary)

Second Response NU has concluded that Discrepancy Report DR-MP3-0509 has identified a condition not previously discovered by NU which requires correction.

1 NU has written CR M3-98-2065 to address the discrepancies in l Pnnted 5698 3.33:34 PM Page 3 of 4 1

1

! N:rthert Utiliti;3 lCAVP DR No. DR. MP3-0509 I Millstone Unit 3 Discrepancy Report FSAR Section 6.5.1.2 and P&lD EM-148E. The approved corrective action will revise FSAR Section 6.5.1.2 to say

" partially" after ESF Bldg., MSVB, and Hydrogen Recombiner l Bldg. P&lD EM-148E-12 will be revised to say that the 6,430 i CFM is drawn from the partial sections of the MSVB, and the Hydrogen Recombiner, as well as from the Containment Enclosure. Corrective action will be competed post startup.

Attachments:CR M3-98-2065 with approved corrective action plan Previously identified by NU? O Yes ? No Non Discrepant Condition?O Yes IGl No Resolution Pending?O ve. *> No Resoiution unre.oived?O ve. @ No Review initiator: stout. M. D.

VT Lead: Neri. Anthony A VT Mgr: schopfer. Don K IRC Chmn: Singh, Anand K Date: 5/2/98 SL Comments: Comments on First Response {

1 \

FSAR Section 6.5.1.2 should be revised to agree with FSAR f Section 6.2.3 regarding waat portions of the ESF building, main i steam valve building, and hydrogen recombiner building are maintained at a negative pressure by SLCRS and ABVS.

Agree that EDI 30255, Rev.1 section 4.2.2.1.a does not require the P&lDs to reflect the actual building arrangements. However, section 4.1 states that the P&lD indicates the order and type of interconnecting piping, the direction of flow, and cross-connection  ;

with other systems. This implies that P&lD EM-148E and EM-152B should be consistent in how air leakage into the main steam valve building is exhausted from the containment enclosure by SLCRS is shown on the two P&lDs. The unducted airflow paths from the main steam valve building and hydrogen recombiner builing should be shown on the P&lDs but do not necessarily need to show the specific airflow quantities.

P&lD EM-148E-12 indicates an exhaust flow of 6,430 cfm at the 36" x 18" screened opening in the containment enclosure. It does )

not identify that a portion of the air exhausted is drawn into the I containment enclosure from the main steam valve building and hydrogen recombiner building as indicated in NU's response.

I As the items identified are documentation related and do not represent a technical discrepancy the DR is reclassified as Significance Level 4.

Comments on Second Response None. The corrective action plan in CR M3-98-2065 resolves the discrepancy.

Pnnted 5/6S8 3:33:34 PM Page 4 of 4~

l J

1 N:rthIast Utiliths ICAVP DR No. DR-MP3-0584 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p

Discipline: Mechanical Design g Discrepancy Type: Cornponent Data ,

Systern/ Process: HVX NRc Significance level:4 Date faxed to NU:

Date Published: 11/6/97 Discrepancy: SLCRS and ABVS Filter Unit lodine Loading and Adsorbent Quantity

Description:

During review of the Supplementary Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/S and the Auxiliary Building Ventilation System (ABVS) exhaust filter units l 3HVR*FLT1 A/B component data a discrepancy regarding the l iodine loading and charcoal adsorbent quantity was identified.

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

' Design, Testing, and Maintenance Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants' regulatory position C.1.c.

Per FSAR Table 6.5-1, the Charging Pump, Component Cooling Pump, and Heat Exchanger Exhuast System is in compliance with RG 1.52, Rev. 2, position C.1.c.

Per FSAR Table 6.5-1, the Supplementary Leak Collection and Release System is in compliance with RG 1.52, Rev. 2, position C.1.c.

Per RG 1.52 Position C.1.c, The design of each adsorber section should be based on the concentration and relative abundance of the iodine species (elemental, particulate, and organic) which should be consistent with the assumptions found in RG 1.3,1.4, and 1.25.

Per RG 1.52, Rev. 2, Position C.3.i, The adsorption unit should be designed for a maximum loading of 2.5 mg of totaliodine j (radioactive plus stable) per gram of activated carbon. FSAR 1 Table 1.8-1 and Table 6.5-1 do not take exception to this requirement.

Calculations that determine the total lodine loading on the charcoal adsorber are not available per NU response in M3-IRF-00718. This information is needed to verify that the total quantity of charcoalin the filter units meets the 2.5 mg of total iodine per gram of activated carbon requirement of RG 1.52, Rev. 2 Position C.3.1 Review Valid Invalid Needed Date initiator: Stout, M. D. O O O 10/28/97 (

VT Lead: Neri. Anthony A D 0 0 o/28/97 VT Mgr: Schopfer, Don K D 0 0 50/30/97 IRc Chmn: Singh, Anand K G O O 0/3'/S7 Printed s/6/98 3:34:42 PM Page 1 of 3

N:rth:ast Utilitiss ICAVP DR No. DR-MP3-0584 Millstone Unit 3 Discrepancy Report Date:

INVALID:

Date: 5/2/98

! RESOLUTION: NU has concluded that the Discrepancy Report, DR-MP3-0584, has identified a condition not previously discovered by NU which requires correction.

DR-MP3-0584 identified issues with the iodine loading and charcoal capacity of the SLCRS filter units 3HVR*FLT3A/B and the ABVS filter units 3HVR*FLT1 A/B. The ABVS and SLCRS l filter units are required to be designed in accordance with Reg.

Guide 1.52, Rev. 2 as stated in FSAR sections 6.2.3,6.5, and 9.4.3. The degree of compliance with Reg. Guide 1.52 is provided in FSAR Tables 1.8-1 and 6.5-1. Specification l 2170.430-065," Specification for Special Filter Assemblin,"

i states the design requirements for the SLCRS/ABVS filter l

including RG 1.52, Rev. 2 requirements. Specification 2170.430-065 makes no exception to RG 1.52, Rev. 2 regarding iooine loading and charcoal quantity.

CR M3-98-0691 was initiated to provide corrective action plan for the issue identified in DR-MP3-0584. CR M3-98-0691 corrective action plan requires a new calculation to determine the total iodine loading and resultant charcoal capacity. In addition, the corrective action plan requires a new calculation to determine the resulting heat load due to radioactive induced heat. DR-MP3-l 0588 and DR-MP3-0724 identified issues with the filter unit water l spray system with regard to requirements for charcoal adsorbent

! cooling. Following approval of the calculations the charcoal adsorbent capacity and cooling mechanisms will be evaluated for compliance with Regulatory Guide 1.52, Rev. 2, positions C.1.c, C.3.1 and C.3.k requirements and applicable FSAR sections. ,

Positions C.1.c and C.3.1 address the design criteria for charcoal adsorber units including the requirements for iodine removal.

Position C.3.k addresses the design criteria for charcoal l adsorber heat load removal due to radioactive induced heat which is a function of total iodine loading. The corrective actions will be completed prior to startup. ,

l l NU considers the condition identified by DR-MP3-0584 to be a l Significance Level 4 based on lack of calculations to provide justification of Reg. Guide 1.52, Rev. 2 requirements regarding iodine loading. Engineering Record Correspondence (ERC),

25212-ER-98-0129,"SLCRS and ABVS Filter Unit lodine Loading and Adsorbent Quantity," Rev. O, dated 4/10/98 provides an evaluation of the filter units while the formal calculations required by CR M3-98-0691 are being developed.

ERC 25212 ER-98-0129 is conservatively based on a bounding 3-day iodine release assuming that sprays are ineffective in I removing airborne iodine in containment atmosphere. ERC l 25212-ER-98-0129 concludes that the post LOCA iodine loading on both filtration units is well below the maximum permissible loading of iodine per Regulatory Guide 1.52, Rev. 2, position l C.3.1 and the iodine removal capacity of the charcoal filter units l Printed 5/6/98 3 34 43 PM Page 2 of 3 l

ICAVP DR No. DR-MP3-0584 Northeast Utilities Millstone Unit 3 Discrepancy Report is sufficient. Therefore based on the bounding evaluation, the filter units meet their licensing and design basis including Regulatory Guide 1.52, Rev. 2 requirements regarding lodine loading and charcoal capacity.

Attachments:

CR M3-98-0691 ERC 25212-ER-98-0129,"SLCRS and ABVS Filter Unit lodine Loading and Adsorbent Quantity," Rev. O, dated 4/10/98.

Previously identified by NU7 O Yes fG> No Non Discrepant Condition?O Yes f#l No Resolution Pending?O ve. < * > No Resoiution unre.oived?O Ye. + No Review initiator: stout, M. D.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K l lRC Chmn: singh. Anand K Date: 5/2/98 SL Comments:

References:

1. Engineering Record Correspondence 25212-ER-98-0129, Rev. l

0. (

2. Calc. MP3LOCA94-01048-R3, Rev. 3 The methodology described in Reference 1 to estimate the MP3 SLCRS and ABVS iodine loading using the calculational parameters described in Reference 1 has been reviewed and appears to be conservative. The approach of NOT using the spray as an iodine removal mechanism increases the amount iodine postulated to leak from containment being taken-up by the filters.

Based on the results in ERC 25212-ER-98-0129, Rev. O this is considered to be a level 4 discrepancy.

I Printed 5/6/98 3:34 43 PM Page 3 of 3

N:rthe st Utilities ICAVP DR No. DR-MP3-0655 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Elernent: Corrective Action Process Discipline: Other Discrepancy Type: Corrective Action g

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

Date Published: 12/8/97 Discrepancy: Insufficient Corrective Action Plan disposition in ACR # M3 0178

Description:

ACR # M3-96-0233 is in the out-of-scope corrective action sample, it was closed out to ACR # M3-96-0178. ACR # M3 0178 (and UlR 325) document cases where the battery room temperatures have fallen below the winter temperatures listed in the FSAR Table 9.4.1, entitled " Indoor Design Temperatures for Control Building "

The ACR # M3-96-0178 Corrective Action Plan does not provide a sufficient response to the following concerns:

1) The updated FSAR Table 9.4.1 dated 4/96 revised the Battery Room Indoor design temperatures (winter) for Control Building as follows:

Battery Rooms 1 and 2.. .65'F Battery Room 3.. .55'F Battery Room 4.. .60'F l These updated FSAR Table 9.4.1 temperatures appear to be )

based on limited historical data (noted in UIR 325) and not based on design calculations or analyzed conditions.

2) EDSFl IR 4517 and UIR 325 have stated that temperatures as low as 50 'F have been recorded. There is no analysis or calculation that the proposed designed changes outlined in EWA No. 3-94-00091 will limit the Battery Room temperatures to or above the values listed in the updated FSAR Table 9.4.1 dated 4/96.

I NOTE: EWA No. 3-94-00091 has been approved to address )

switchgear room humidity concerns which attribute to increased breaker failures during testing. In addition , EWA No. 3 94-00091 states that it will also resolve low temperature concerns in the battery rooms identified on EDSFI inspection Report No.

4517, which is the same concern as this ACR (M3-96-0178) and associated UIR (325).

ACR M3-96-0178 has been closed to EWA No. 3-94-00091.

Review Valid invalid Needed Date initiator: Caruso, A. O O 1 /20/97 VT Lead: Ryan, Thomas J B O O 11/20/97 O O 12/i/97 VT Mgr: schopfer, Don K O 0 12/4s7 IRC Chmn: Singh, Anand K 9 0 Date:

INVALID:

Pnnted 5/6/98 3:35:33 PM Page 1 of 9 j L__________________._________-__________________-..__-.__

N:rthe:st Utilities ICAVP DR N3. DR.MP3-0655 Milistone unit 3 Discrepancy Report Date: 5/5/98 RESOLUTION: . . .......

NU's First Response:

Disposition:

NU has concluded that the issue reported in DR-MP3-0655 does not represent a discrepant condition. The current configuration is in compliance with ourlicensing and design basis, and the proposed modification will result in reduced humidity levels and eliminate the low battery room temperature concems. As part cf the Design Change Process, the responsible engineering organization will determine the extent of testing and analysis required to qualify the modification.

Corrective Action, per ACR # M3-96-0178:

1. EWA No. 3-94-00091 has been approved to address switchgear room humidity concems which attribute to increased breaker failures during testing. In addition, EWA 3-94-0C091 states that it will also resolve low temperature concerns in the battery rooms identified on EDSFl inspection Report No. 4517, which is the same concem of this ACR (M3 0178) and associated UIR (325).

Therefore, this ACR can be closed to EWA No. 3-94-00091 (AR 96000365-02)

2. Implement EWA Design Change, write AWOs, and purchase parts and materialif needed.

(AR 96009277-04)

Proposed resolution, per EWA M3-94091:

The Open items identified in EWA M3-94091 are to identify the best solution, considering supply / exhaust fan qualified timers, modification of fans and ductwork, or shutting down supply fans and throttling exhaust flow.

The following resolutions will be pursued:

1. Shut down the supply air fans and leave them in place

2. Add registers to the exhaust fan duct and recirculate most of the battery room air, minimizing the actual exhaust flow.

3. Determine if the normal ambient room temperature can be raised above 70 F.

4. Determine if the chilled water system operation can be optimized (aside from the DCR) to lower the water temperature, and hence the supply air temperature

5. In parallel, investigate the availability of a fan start timer to cycle the exhaust fans, in case the preferred option does not work. l The above is being considered based on the fact that as designed and installed, the outdoor air supply ducts to the Control Building Switchgear Rooms are in close proximity to the Battery Rooms No. 3 and No. 4 ventilation intakes. The respe!veSattery Room exhaust system-draws veM!!?tioma!r Printed 5/6/98 3:35:34 PM Page 2 of 9

N::rthert Utilities ICAVP DR No. DR-MP3-0655 Millstone Unit 3 Discrepancy Report from the Switchgear Rooms and exhausts to the outdoors to preclude hydrogen accumulation in the battery rooms. The design of the outdoor air supply ductwork does not disperse the outdoor air within the Switchgear Rooms completely, hence, incomplete mixing of room air and outdoor occurs and this air is drawn into the Battery Rooms ventilation air intakes.

Temperatures below original design (65 F) have occurred in both Battery Rooms No. 3 and No. 4 during winter months. The design temperatures for these two rooms were lowered to 55 F and 60 F respectively, via FSARCR 95-MP3-55. The Tech Spec requirement,4.8.2.1.b.3, states that the average electrolyte temperature of the six connected cells is above 60 F. This is monitored ,per Tech Spec, once per 92 days. In addition, Surveillance Procedure SP 3712NA, Battery Surveillance Testing, provides instructions for weekly, quarterly, and 18 month battery surveillance,includina electrolyte temperature. A review of the battery surveillance oa. has shown the lowest battery electrolyte temperature occurred on 12/5/88, and was 60.1 F. i Battery Room 3 and 4 are more susceptible to low temperatures due to the location of the switchgear room supply fans. Fan 3HVC*FN3A discharges outside air above Battery Room 3. The ventilation inlet to Battery Room 3 is located on the ceiling because the room is surrounded by the other two battery rooms and the inverter room. Fan 3HVC*FN3B is located just south of Battery Room 4, which is south of Battery Room 2. The proposed modification will reduce or eliminate the supply of outside air by fans 3A/3B thereby reducing or eliminating the localized cooling affect on Battery Rooms 3 and 4.

Since the current configuration is in compliance with our design and licensing basis, and the proposed modification will result in less variance from the design temperatures, it would also meet our LB/DB. The proposed modification will be reviewed and verified to be in compliance with our LB/DB at the time of preparation of the modification via the design change process, including a safety evaluation.

Since temperatures are presently monitored by Operations su LB and DB is met, these corrective action will be completed after startup. Significance Level does not apply as this is not a discrepant condition

Conclusion:

NU has concluded that the issue reported in DR-MP3-0655 does not represent a discrepant condition. The corrective action in ACR M3-96-0178 will address and resolve the low temperature concems in the Battery Rooms. Current historical temperature and humidity data covers approximately 10 years. Several historical ACRs and UIRs, some of which are referenced in M3-DRT-0655, were generated to enhance the design such that the current large variations in seasonal temperatures do not occur.

The current configuration is in compliance with our licensing and design basis, and the proposed modification will result in reduced humidity levels and eliminate the low battery room temperature concems. As part of the Design Change Process, the responsible enaineerina organization will determine the extent of  ;

Pnnted 5/6/93 3:35:34 PM Page 3 of 9 l

l

{

---l

N::rthust Utilitiss ICAVP DR No. DR-MP3-0655 Millstone Unit 3 Discrepancy Report testing and analysis required to qualify the modification.

FSAR Section 9.4 discusses the Design Bases for the outdoor temperature selected for MP3 and that actual Indoor temperatures might vary coincident with outdoor air temperature excursions. Therefore dropping below the stated indoor temperatures is not outside the design basis.

The licensing basis, from Technical Specifications, is to maintain the batteries operable as defined in the Tech Specs. Tech Spec 3/4.8.2.1 requires that the average battery electrolyte temperature for 6 connected cells be 60 deg. F or greater. This is verified at least once every 92 days. As stated in the deportability eval done for ACR M3 96 0178,0179,0233, the i lowest recorded electrolyte temperature for the winter of 1995/1996 was 66.7 deg. F. The lowest overall battery electrolyte temperature recorded was 60.1 deg. F for Battery 3.

Battery Room 3 and 4 are more susceptible to low temperatures due to the location of the switchgear room supply fans. Fan 3HVC*FN3A discharges outside air above Battery Room 3. The ventilation inlet to Battery Room 3 is located on the ceiling because the room is surrounded by the other two battery rooms and the inverter room. Fan 3HVC*FN3B is located just south of Battery Room 4, which is south of Battery Room 2. The proposed modification will reduce or eliminate the supply of l

outside air by fans 3A/3B thereby reducing or eliminating the l localized cooling affect on Battery Rooms 3 and 4. J Since the current configuration is in compliance with our design and licensing basis, and the proposed modification will result in less variance from the design / nominal temperatures, it would also meet our LB/DB. The proposed modification will be reviewed and verified to be in compliance with our LB/DB at the

)

time of preparation of the modification via the design change process, including a safety evaluation. Significance Level does not apply as this is not a discrepant condition  !

NU's Second Response: )

Disposition: I NU has concluded that the issue reported in DR-MP3-0655 does  ;

not represent a discrepant condition. The current configuration is l in compliance with the licensing and design basis. The design temperature changes introduced by FSARCR 95-MP3-55 were based on valid historical data, therefore, additional calculations  !

are not required. This historical data was net adequately documented, other than being referred to in the Technical and Safety Evaluation of the FSARCR. As a result, CR M3-98-1878 has been issued to revise Calculation 91-019-337M3, Rev. O, to adequately document the historical data. This issue does not represent a discrepant condition, therefore Significance Level criteria does not apply.

Printed S/6/98 3.35:34 PM Page 4 of 9

1 Nathert Utilitim ICAVP DR No. DR-MP3-0655 Millstone unit 3 Discrepancy Report I

Calculation No. 91-019-337M3, Rev. O, determines the temperature requirements of the switchgear areas to ensure that I

the design minimum (winter) temperatures for each of the Control Building battery rooms is met. CR M3-98-1878 has been issued to revise Calc 91-019-337M3, Rev. O, for the following: .

1. Incorporate the values of the lowered minimum winter design l temperatures for battery rooms 3 & 4 as defined by FSARCR 95-  !

l M3-55.

2. Add, as an attachment, the historical temperature data that forms the basis of the design change by FSARCR 95-M3-55 to lower the temperatures in Battery Rooms 3 & 4, toS5 and 60F, respectively, as shown in FSAR Table 9.4-1.

Since the system meets its' Licensing and Design Basis requirements, the corrective action will be completed after unit .

restart. I Review of historical temperature data for the East and West j Switchgear rooms, the five battery rooms, and the outside air i temperature, via the EEQ data logger, shows that from Jan. i 1989 to Dec.1997, temperatures below 55F have occurred in Battery Room No. 3 on 3 occasions. The night of Jan. 4/5,1989, J there were two temperature readings below 55F (54.5F and 54.6F), and on the moming of Dec. 23,1989, the temperature reached 54.7F. In addition, in the same time period, there were 2 days (by the data logger) that the outdoor temperature averaged below 10F (5 days by the Met Tower data). On these occasions, ,

Battery Room 3 remained above 55F. There have been 38 days l with the outdoor temperature reaching 10F or below, but only the three times noteo above when Battery Room No. 3 went below 55F(by 1/2 deg). There were no recorded instances, by the data logger, that the site temperature went to 0F or below, and only 3 days by the Met Tower data when this occurred. On Jan 16,19,

& 27,1994, the Met Tower registered -1.48,-0.58. & -0.58F, i respectively. The outside air temperature, on the same days, as measured by the data logger, was 1.3,2.5, & 1.8F. Battery 1 Room No. 3 was at 56.2,56.2, & 56.4 on these days. See Table l 1, attached, for a tabulation of data for days experiencing temperatures at or below 10F.

Table 2 shows that during this same time period, the Tech Spec Surveillance for Battery No. 3 did not reach 60F or below. The weekly surveillance for the first week of January,1989, showed an electrolyte temperature for Battery No. 3 of 60F, However, the weeks immediately preceding and following this week had the electrolyte at 61.5 and 66.3, respectively, and the quarterly Tech Spec surveillance, on 12/5/89 had a temperature of 60.9F.

FSARCR 95-MP3 55 also lowered the design temperature of Battery Room No. 4 from 65F to 60F, and, with the exception of Jan.18 & 19,1997, when the low temperatures for those days was 59.3F( Avg. 59.6) and 58.9F(Avg. 59.7) respectively, the temperatures in Battery j Room No. 4 have remained at or above 60F.

With the exception of 2 days in Jan.1989 (4th & Sth, with daily Pnnted 5/6/98 3.35:34 PM Page 5 of 9

N:rthea:t Utilities ICAVP DR No. DR-MP3-0655 Millstone Unit 3 Discrepancy Report low temperatures of 62.8 and 62.7 resp.in Battery Room No.1) and 4 days in Dec. 1989 (22nd,23rd,24th, & 27th, with daily low temperatures of 64.5,64.4,64.3, & 63.8 resp. In Battery Room No.1), Battery Rooms 1 and 2 have remained at or above 65F during this same time period.

The revision to Table 9.4-1 of the FSAR, via FSARCR 97-MP3-55, lowering the design temperature of Battery Rooms 3 & 4, to 55 and 60F respectively, was based on valid historical data, and calculations are not required to validate the change.

The low temperature of 50F, as stated in UIR 325, based its conclusion on a statement in CRR No.106 that 50F had been recorded in October of 1989, without stating in what area.

Information for the last 3 weeks of October,1989 are available from the data logger. Review of the Data logger for this period could not corroborate that figure. There were no temperatures of 50F or less in any of the battery rooms or the East or West Switchgear rooms for the month of October,1989.

The proposed modifications, not yet finalized, by EWR 3 00091 are intended to provide a more uniform temperature profile in the battery rooms, but, as noted above, are not necessary to meet design conditions. As part of the Design Change Process, the responsible engineering organization will determine the extent of testing and analysis required to qualify the modification. In review of these proposed design changes, the hydrogen evolution in the battery rooms was reviewed, and determined that there would be no problem using only the battery rooms' exhaust fans, and relying on normal air infiltration.

The required flow rate for each battery room to maintain H2 concentration at or below 1% varies from 2-8% of the room' available exhaust fan capacity, depending on the battery room.

In addition, on LOP, with the exhaust fans not running,16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> would be required for the H2 to reach 2% within any battery roorn

Conclusion:

NU has concluded that the issue reported in DR-MP3-0655 does not represent a discrepant condition. The current configuration is in compliance with the licensing and design basis. The design temperature changes introduced by FSARCR 95-MP3-55 were based on valid historical data, therefore, additional calculations are not required. This historical data was not adequately documented, other than being referred to in the Technical and Safety Evaluation of the FSARCR. As a result, CR M3-98-1878 has been issued to revise Calculation 91-019-337M3, Rev. O, to adequately document the historical data.

Since the system meets its' Licensing and Design Basis requirements, the corrective action will be completed after unit restart This issue does not represent a discrepant condition, therefore Significance Level criteria does not apply. I Peview of historical temperature data for the East and West Switchaear rooms, the five battery rooms, and the outside air Pnnted 5/6/98 3 35:34 PM Page 6 of 9 l

North:ast Utiliti;s ICAVP DR N3. DR-MP3-0655 l Millstone Unit 3 Discrepancy Report temperature, via the EEQ data logger, shows that from Jan.

1989 to Dec.1997, temperatures below 55F have occurred in Battery Room No. 3 on 3 occasions, and then only by 1/2 degree or less, and at no time during the survey period has the Tech Spec surveillance for electrolyte temperature been at or below 60F. Therefore we can conclude that the design temperature changes introduced by FSARCR 95-MP3-55 were based on valid historical data, and calculations are not required.

Review of the Data Logger for October,1989, could not confirm the low temperature of 50F in any switchgear or battery room, as stated in UIR 325.

ACR M3-96-0178, referenced in the DR, was closed to EWR 3 94-00091 which proposes design changes which, although not necessary to meet the design basis, will enhance the design of the ventilation system such inat the battery rooms are not so easily influenced by variations in seasonal temperatures. As part

of the Design Change Process, the responsible engineering organization will determine the extent of testing and analysis required to qualify the modification. In review of these proposed l design changes, the hydrogen evolution in the battery rooms was reviewed, and determined that there would be no problem using only the battery rooms' exhaust fans, and relying on normal air infiltration. The required flow rate for each battery room to maintain H2 concentration at or below 1% varies from 2-8% of the room' available exhaust fan capacity, depending on the battery room. In addition, on LOP, with the exhaust fans not running,16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> would be required for the H2 to reach 2%

within any battery room.

Attachments:

CR M3-98-1878 FSARCR 95-MP3-55 12179-P(8)-1103, Rev.1, including CCN-01 Table 1, Area Temperatures vs. Outside Temperature Table 2, Battery No. 3D Electrolyte Temperature Surveillance Data Previously identified by NU? C) Yes

• No Non Discrepant Condition?C) Yes (*) No Resolution Pending?O Yes # No Resolution Unresolved?O Yes No Review initiator: Caruso, A.

VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K O

Date: 5/4/98 SL Comments: -. -

l S&L's Comments on NU's First Response:

l l NU's response is not acceptable.

I

1. NU's response concludes that the current configuration is in compliance with design basis but does not identify calculations or Printed 5/6/98 3.35:34 PM Page 7 of 9 I

N:rthert Utilities ICAVP DR No. DR-MP3-0655 l

Millstone Unit 3 Discrepancy Report evaluations that support that statement. To determine if the current configuration does meet design requirements the l following is needed:

Calculation that determines winter room temperatures with a l

0*F outside air temperature & loss of normal power (reduces internal heat loads) l Calculation that determines the minimum room temperature required in order to maintain battery electrolyte temperature above Technical Specification and electrical calculation limits.

2. In addition, NU's response should provide the fo!!owing :

What are the final recommendations of EWA 3-94-00001 to resolve the low battery room temperature and what calculations /

l evaluations support the recommendations.?

Note: FSAR Section 9.4.0 states that the winter outdoor design temperature is 0*F S&L's Comments on NU's Second Response:

l NU's second response provided the evaluation basis for the FSAR design change in the form of historical data for the Battery Room temperatures for the past 8 years. Because of the localized cochng effects that are experienced in Battery Rooms 3 and 4, the use of historical temperature d9ta is a more accurate and reliable approach for design basis criteria than theoretical calculations. Based on the above NU response and on the above referenced Tables 1 and 2, it was shown that Battery Room indoor design temperatures (winter) for the Control Building are normally above the values listed in the FSAR Table 9.4-1 dated 4/96 with a few exceptions as listed in below; a) Battery Room #1: On Jan. 4 & 5,1989, the room temperatures were 62.8'F and 62.7'F respectively. On Dec. 22, 23, 24 & 27, the room temperatures were 64.5'F, 64.4'F 64.3*F, and 63.8'F respectively.

b) Battery Room #2: Battery Room #2 has remained at 65'F or above during the same time period. i c) Battery Room #3: On the nights of Jan. 4 & 5,1989, the j room temperatures were 54.5'F and 54.6*F and on the moming of Dec. 23.1989, the room temperature was 54.7'F.

d) Battery Room #4: On Jan.18 & 19,1997, the room temperatures were 59.3*F ( Ave. 59.6*F) and 58.9'F ( Ave.

59.7'F) respectively.

These temperature deviations are considered to be insignificant for the following reasons:

l a) Battery Room #1: Since Dec.1989, the outside air temperature, as measured at the outdoor Met Tower, has dropped below the Jan. 4 & 5,1989 and the Dec. 22,23,24 &

27,1989 outside air temperatures yet the Battery Room #1 temperature was maintained et 65'F or above.

b) Battery Room #2: No temperature deviations below 65'F.

c) Battery Room #3: The Battery Room #3 temperature deviations were limited to less than 0.5'F for 3 days in 8 years.

Pnnted 5/rW98 3.35:34 PM Page 8 of 9

l N:rthertt Utilities ICAVP DR N3. DR-MP3-0655 Millstone Unit 3 Discrepancy Report d) Battery Room #4: The Battery Room #4 temperature deviations were limited to less than 1.1'F for 2 days in 8 years.

1 i Based on the historical data for the Unit 3 Battery Room #1,2,3

& 4 temperatures, it was noted that battery sizing calculations are I

not affected . The battery sizing calculations use a 60*F value for the design temperatures of Batteries 1,2 & 4 and a 55'F value for Battery 3. Note: While the Battery Room #3 temperature did fal1 below the 55'F design temperatures by approximately 0.5'F for 3 days, the Weekly Surveillance records of Battery #3 electrolyte temperatures (hence the battery temperature) are hlgher than the room temperatures by 3.2*F to 8.2'F as noted in the referenced Table #2 on the days of 2/3/93,12/27/ 93, 1/17/94,2/6/95 and 2/5/96. Consequently, Battery 3 temperature did fall below the 55'F design temperature.

The low temperature of 50*F is not a concern because NU has shown that it did not actually occur in the battery rooms.

S&L also acknowledges the following NU actions:

1.) CR M3-98-1878 has been issued to revise Calc 91-019- q 337M3, Rev. O, for documentation purposes as follows: 1 A. Incorporate the values of the lowered minimum winter design temperatures for tattery rooms 3 & 4 as def.ned by FSARCR 95-M3-55.

B. Add, as an attachment, the historical temperature data that forms the basis of the design change by FSARCR 95 M3-55 to lower the temperatures in Battery Rooms 3 & 4, to 55 and 60F, respectively, as shown in FSAR Table 9.4-1.

Since the system meets its' Licensing and Design Basis requirements, the corrective action will be completed after unit restart.

2) ACR M3-96-0178, referenced in the DR, was closed to EWR 3-94-00091 which proposes design changes which, although not i necessary to meet the design basis, will enhance the design of the ventilation system such that the battery rooms are not so easily influenced by variations :n seasonal temperatures.

In summary, S&L agrees with NU's disposition of the issue. I However, because a document deficiency existed, DR-MP3-0655 is considered to be a discrepant condition having a Significance Level of 4. Based on a 5/4/98 conference call, NU agrees that DR-MP3-0655 is discrepant and agrees with a Significant Level 4 ,

rating. l Printed 5/6/98 3:35:34 PM Page 9 of 9

I N:rthezt Utilities ICAVP DR No. DR-MP3-0687 Millstone Unit 3 Discrepancy Report Review Group: system DR REsOLUrlON ACCEPTED Review Element: system Design Potential operability issue Discipline: Mechancal Design Discrepancy Type: Calculation Sys2em/ Process: HVX NRC significance level: 3 Date faxed to NU:

Date Published: 12/8/97 Discrepancy: Fan Blade Missiles

Description:

During review of NERM 69 and calculation NM(S)-685-DKB discrepancies were identified regarding the identification and evaluation of fan blade missiles for auxiliary building fans 3HVR*FN6A/B,3HVR*FN13A/B, and 3HVR*FN14A/B.

References FSAR Section 3.1.2.4 Environmental and Missile Design Basis (Criterion 4)

NERM 69, Rev.1, dated 1/21/86, Hazards Review Program Summary Calculation NM(S)-685-DKB, Rev.1, dated 7/26/85, Evaluation of Internally Generated Missiles from High Speed Rotating Machinery Calculation NM(S) 685-DKB, Rev.1, CCN 1, dated 1/14/86 Calculation NM(S)-685-DKB, Rev.1, CCN 2, dated 10/23/96 Calculation HAZ-01449-M3, Rev. O, dated 9/: t/97, Hazard Review Program for Auxiliary Building Calculation HAZ-01449-M3, Rev. O CCN 1, dated 10/4/97 P&lD EM-148A-24 P&lD EM-1488-15 Drawing EB-45A-12 Drawing EB-45G-9 Drawing EB-45H-12 Drawing EB-45L-13 Drawing EB-45M-9 Drawing EB-45N-9

Background

FSAR Section 3.1.2.4 states that structures important to safety shall be appropriately protected against dynamic effects, including the effects of missiles.

NERM 69 Rev.1 Paragraph 2.4, page 10 (lines 7.39-7.42), states "A review is 1 required of high speed rotating machinery in order to determine their potential for generating missiles resulting from destructive overspeed conditions or failure resulting from base metal fatigue, fastener failures, or manufacturing defects, and are included in the interaction tables where applicable (see Attachment 1 Description of interaction Tables)"

Paragraph 2.4, page 11 (lines 8.10-13), states " Missiles resulting from axial fan vane and from centrifugal fan rotor or blade failure resulting from material failure or assembly error are t

considered credible if the fan housing is inadequate to retain the fragments. A destructive overspeed induced failure is not credible for fans."

Printed 5/6/98 3:35:50 PM ge 1 of 8

N:rthe st Utilitin ICAVP DR N). DR-MP3-0687 l Millstone unit 3 Discrepancy Report noted that while the above intemal missiles are considered j credible, they may be excluded from additional consideration )

based on not penetrating the casing, or the improbability of (zone I I

of influence) striking safety-related components necessary to mitigate the consequences of the postulated failure event."

Calculation NM(S)-685-DKB, Rev.1 Page 27: Concludes that any credible axial flow fan missile is not expected to have sufficient energy to penetrate its casing.

Missiles escaping through flexible ducting connected to the fans are considered credible and their trajectories are established on page 70.

Page 70 & 71: Fan blade missiles escape through any flexible ducting at the fan blade rotor end of the fan. Considers trajectory to be perpendicular to the axis of htion thru 25* back from the plane of rotation.

Page 71: The missile trajectory is used to review for safety-related system equipment and components which r,an be affected by the missile. (this effort is not within the scope of this calculation).

Page 61 Fan HVR*FN14A/B: Fan casing penetration energy required is less than kinetic energy of the blade missile.

Therefore missile has sufficient energy to penetrate the fan casing. Calculation states "It is unreasonable to expect the missile to unacceptably damage any adjacent safety-related equipment." The calculation states that the type of blade failure that results in the blade penetrating the casing is not credible while acknowledging that that type of blade failure has be reported at other stations. The calc then evaluates another type of blade failure that does not result in the blade penetrating the fan casing. Calc does not provide an adequate basis to support the conclusion that there would be no damage to adjacent safety related equipment or that the type of failure resulting in the blade penetrating the casing is not credible.

Calculation HAZ-01449-M3, Rev. 0 Page 536 Note: The 66'-6" elevation of the Auxiliary Building was reviewed for the effects of pipe rupture and rotating machinery generated missiles. Protection has been provided to preclude HVH HELB pipe whip interaction with 3HVR*ACU1 A ducting (ref. E&DCR 06598). All other potentially unacceptable interactions are precluded by analysis.

Page 537,3. Axial Ventilation Fans: Missile ejection through the casing or the fan inlet flexible connection is precluded by analysis for the following fans (ref. calculation 12179-NM(S)-685-DKB); HVR*FN6A, HVR*FN658. HVR*FN14A, HVR*FN148, HVR*FN13A, HVR*FN13B Discrepancies

1. NERM 69 Rev.1 does not address fan missiles escaping through the flex connection for fans 3HVR*FN6A/6B, 3HVR*FN13A/138,3HVR*FN14A/14B

2. Statement in HAZ-01449-M3 does not agree with referenced J calculation regarding missiles escaping through the fan inlet flex connection.

l 3. Calculation NM(S)-685-DKB. Pace 61: Fan casina penetration Printed 5/6/98 3 35 51 PM Page 2 of 8 1 l

N:rthZsi Utiliti:s ICAVP DR No. DR-MP3-0687 Millstone Unit 3 Discrepancy Report energy required is less than kinetic energy of the blade missile.

Therefore missile has sufficient energy to penetrate the fan casing. Calc does not provide an adequate basis to support the )

conclusion that there would be no damage to adjacent safety l related equipment or that the type of failure resulting in the blade penetrating the casing is not credible. This is also in conflict with paragraph 2.4 of NERM 69 lines 7.39 to 7.42. Applies to fans 3HVR*FNBA/B,3HVR*FN13A/B, and 3HVR*FN14A/B l Review I Valid invalid Needed Date Initiator: Stout, M. D. O O O 1 / 7/97 VT Lead: Neft, Anthony A @ Q [ 11/20/97 I VT Mgr: Schopfer, Don K O O O 12/1/97 1RC Chmn: singh. Anand K O O O 12/4/97 Date:

{

INVALID:

Date: 5/4/98 REs0LUTION: First Response NU has con ubd that the issues reported in DR-MP3-0687, items 2 and 3, have identified conditions not previously discovered by NU which require correction. CRs M3-98-0765 and M3-98-1105 have been written to develop the corrective actions associated with this DR.

Item 2:

There is a discrepancy between the Millstone 3 hazards analysis and calculation 12179-NM(S)-685-DKB. Hazards analysis HAZ-01449-M3 indicates that fan missiles for HVR fans are precluded by analysis referring to calculation 12179-NM(S)-685-DKB.

Calculation 12179-NM(S)-665-DKB indicates that missiles are precluded from penetrating the casing, but are not precluded from penetrating the flexible connection. Modifications per  !

E&DCR T-P-04338, have been made to reinforce the flexible l connections, but these are not addressed in the calculation. l l

Although the above modification was not originally intended as a missile shield, the disposition to Deficiency Report No. UNS-7302, addressing potential missiles from HVP and HVQ fans, j states that modification similar to that shown in E&DCR T-P- )

04338 is sufficient to prevent missile ejection. The fans j referenced in DR-0687 are: 3HVR*FN6A/B,13A/B, & 14A/B. l This modification is further shown on Drawing 25212 24057.

In addition to the above, the statement in Section 3a, page 537, I

of HAZ-01449-M3 also includes fans 3HVR*FN10A/B. Although fans FN10A/B do not have a shield in accordance with the above referenced drawing, each has an 18"long Variable inlet Vane (VIV) Damper (3HVR*VIV1004/1006 respectively) between the flex connection and the fan that will effectively prevent ejection of missiles through the flex connection.

Calculations 12179-NM(S)-685-DKB / HAZ -01449-M3 will be updated to indicate why missiles from the HVR fans are not a Pnnted SM/98 3.3s:51 PM Page 3 of 8 l

l

ICAVP DR N2. DR-MP3-0687 N:rtherst Utilities Millstone Unit 3 Discrepancy Report credible hazard. Also other similar fans will be reviewed to ensure that the documentation for precluding fan blade missiles is accurate.

Item 3:

Calculation NM(S)-685-DKB, Page 61 concludes that the fan casing penetration energy required is less than kinetic energy of the blade missile. Therefore the missile has sufficient energy to penetrate the fan casing, but with the low residual energy, it would not be expected to unacceptably damage any safety related equipment. It is further stated in the calc that a number of very conservative assumptions are involved in reaching the above conclusions. The calc, on pages 62-64, then evaluates another type of blade failure, with more realistic assumptions, that does not result in the blade penetrating the fan casing.

Sargent & Lundy did not agree with the documentation provided to preclude missiles from HVR fans as a credible hazard source.

Sargent & Lundy questioned the fact that the basis for some of the assumptions in the calculation were not documented.

Without this documentation Sargent & Lundy could not confirm the adequacy of the calculation.

Calculations 12179-NM(S)-685-DKB , HAZ-01449-M3 and/or NERM 69 will be updated to further document why any potential fan missiles from the HVR fans are not of concern.

Because fan missiles are precluded, and no apparent targets were identiiied on a preliminary walkdown, the discrepancies are limited to inconsistencies in the calculations which do not affect system licensing or design basis, or the conclusions of the Hazards Program. Therefore NU considers this to be a Significance Level 4.

Since this is a documentation issue it can be completed post start-up.

NU has concluded that the issue identified in item #1 of DR-MP3-0687 does not represent a discrepant condition. .

I Item # 1: I This item states that NERM 69 Rev.1 does not address fan missiles escaping through the flex connection for fans 3HVR*FN6A/6B, 3HVR*FN13A/13B, 3HVR*FN 14A/14 B NERM 69, (Intemally Generated Missile Analysis), Rev.1, Section 2.4, Page 10 states " ..A review is required of high speed rotating machinery in order to determine their potential for I generating missiles resulting from destructive overspeed conditions or failure resulting from base metal fatigue, fastener failures, or rnanufacturing defects, and are included in the interaction tables where applicable (see Attachment 1)"

The area in question is El. 66'-6" of the Aux Building, as shown in Fig.12A & 128 of Attachment 6 of NERM 69. The interactions for the equipment in this area are shown in Attachment 5 to NERM 69, Interaction Summary Table, Page 3 of 10, reference Notes 16 and 19, on page 2 of 10 of Attachment 5, interaction

! Summary Table, which conclude that the fans in Question pose Pnnted 5/6/98 3.35:51 PM Page 4 of 8 1

N:rthe:st Utiliti2s ICAVP DR No. DR-MP3-0687 Millstone Unit 3 Discrepancy Report no hazard.

The area is also listed on Attachment 7, as "No Confirmation Required", indicating all assumptions used in analyzing this area are considered valid. Therefore, NERM 69, Rev.1 does address fan missiles escaping through the flex connection for fans 3HVR*FNBA/68,3HVR*FN13A/13B, and HVR*FN14A/14B.

The response to items 2 and 3 of the DR will further document these conclusions.

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

Conclusion:

NU has concluded that the issues reported in DR-MP3-0687, items 2 and 3 have identified conditions not previously discovered by NU which require correction. CRs M3-98-0765 and M3-98-1105 have been written to develop the corrective actions associated with this DR.

The approved corrective action plans for CRs M3-98-0765 and M3-98-1105 will update Calculations 12179-NM(S)-685-DKB, HAZ -01449-M3 and/or NERM 69 to adequately document why missiles from the HVR fans are not a credible hazard. Also other similar fans will be reviewed to ensure that the documentation for precluding fan blade missiles is accurate.

Because fan missiles are precluded, and no targets were identified on a preliminary walkdown, the discrepancies are limited to inconsistencies in the calculations which do not affect system licensing or design basis, or the conclusions of tne Hazards Program. Therefore NU considers this to be a Significance Level 4.

Since this is a documentation issue it can be completed post start-up.

Item 1 of DR-M3-0687 does not represent a discrepant condition.

This item states that NERM 69 Rev.1 does not address fan I missiles escaping through the flex connection for fans 3HVR*FN6A/6B,3HVR*FN13A/13B,3HVR*FN14A/14B. NERM 69, Rev.1 does address the issue of fan missiles escaping through the flex connection for fans 3HVR*FN6A/68, 3HVR*FN13A/138, and 3HVR*FN14A/14B. The interactions for equipment in the El. 66'-6" area of the Aux Building are shown in Attachment 5 to NERM 69, Interaction Summary Table, Page 3 of 10, reference Notes 16 and 19 on page 2 of 10 of Attachment 5, which conclude that the fans in question pose no missile hazard. The area is also listed on Attachment 7, as *No Confirmation Required", indicating all assumptions used in analyzing this area are considered valid. In addition, the above referenced Interaction Summary Table also includes fans 3HVR*FN10A/B, which are included in the statement in Section 3a, page 537, of HAZ-01449-M3.

Printed 5/6/98 3.35:51 PM Page 5 of 8 u

N:rthe t Utilities ICAVP DR No. DR-MP3-0687 Millstone Unit 3 Discrepancy Report The response to items 2 and 3 of DR-MP3-0687 will further document these cor?clusions.

i Attachments:

CR M3-98-0765 E&DCR T-P-04338 25212-24057 (12179-EB-45A), Rev.12 J CR M3-98-1105 j Deficiency Report UNS-7302 1 1

Second Response (M3-IRF-02095)

. i NU has concluded that the issue reported in DR-MP3-0687 has identified a condition not previously discovered by NU which requires correction. CR M3-98-1745 has been written to address the discrepancy in the sheet metal thickness of the flex connector reinforcement and provide additional corrective j actions associated with DR-0687. j Per the approved corrective action plan for CR M3-98-1745, Design Engineering has issued CCN-04 to Calc.12179-NM(S)-

685-DKB, concluding that the 16 gage flexible connection reinforcement installed on the inlet connection of fans 3HVR*FN6A/B,13A/B, & 14A/B per the Fan inlet Flex Conn.

Detail shown on drawing 25212-24057, Rev.12 (12179-EB-45A-12), is not sufficient to prevent fan blade missile missile ejection through the flexible inlet connector. Engineering walkdown MP3-WLKDWN-98-042 was performed, per Engineering Department Instruction EDI-30555, of EL. 66'-6"in the Aux. Bldg. to determine if there are any unacceptable i consequences as a result of these potential missile ejections j from fans 3HVR*FN6A/B,13A/B, &14A/B. Also, although not I' having a support installed for the flexibl6 connector, Fan 3HVR*FN10A/B was also included in the walkdoun.

Technical Evaluation M3-EV-98-0088 reviewed the results of the walkdown and concluded that due to the installation of dampers on the inlet of fans 3HVR*FN6A/B and 10A/B, between the fans and the inlet flexinble connector, missile ejection from these fans l was not a credible event. J The evaluation further concluded that, though considered highly I unlikely, missiles could theoretically eject from fans 3HVR*FN13A/B (Charging Pump and CCP Area Ventilation Exhaust Fans) and 3HVR*FN14A/B (Charging Pump and CCP ,

Area Ventilation Supply Fans) and impact adjacent safety related I ductwork. 3HVR*FN14A/B could impact adjacent safety related supply or return ductwork of the East MCC & Rod Control Area air conditioning system. A potential missile from any of the 4 f ans could also impact its' own parallel fans' suction ductwork.

Due to the large volume of flow in the ducts, and the small losses estimated through impact area, there is no effect on safety or operability. To be consistent with other similar fans, and provide an additional level of assurance, missile shields will be provided around the inlet flex connectors for fans 3HVR*FN13A/B and 3HVR*FN14A/B.

Pnnted s/6/98 3:3s s1 PM Page 6 of 8

ICAVP DR No. DR-MP3-0687 N:rtherct Utilitle3 Millstone Unit 3 Discrepancy Report The effect of 6"x2" penetration in the supply ductwork from 3HVR*ACU1 A to the East MCC & Rod Control Area caused by fans 3HVR-FN4A or B or 3HVR-FN5 was analyzed in Calculation P(B)-1184, and found to have no significant effect.

Per the approved corrective action plan for CR M3-98-1745, DCN DM3-00-0355-98 has been issued to provide details for the installation of missile shields around the inlet flex connectors for fans 3HVR*FN13A/B & 14A/B. Work orders will be initiated for the installation of these missile shields.

NU concurs that this issue is Significance Level 3, and the corrective action will be completed prior to unit restart.

Attachments:

CR M3-98-1745 CR M3-98-0765 CR M3-98-1105 VIR-4530 Desktop Instruction 3DE-EDI-98-001 Walkdown MP3-WLKDWN-98-042 Technical Evaluation M3-EV-98-0088, Rev 0 CCN-04 to Calc 12179-NM(S)-685-DKB DCN DM3-00-0355-98 OSCR(Outage Scope Change Request) No.98-032 Previo'Jsly identified by NU? O Yes t#) No Non Discrepant Condition?O Yes IG) No Resolution Pending?O Yes '9) No Resolution Unresolved 70 Yes (3) No Review initiator: stout. M D.

VT Lead: Neri. Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date: 5/4/98 SL Comments: Comments of First Response NU's response does not provide sufficient information to conclude that fan blades would not penetrate the inlet flex connections for 3HVR*FN6A/B,3HVR*FN13A/B and 3HVR*FN14A/B. The detail shown on EB-45A-12 (drwg 25212-24057) calls for piece #4 to be 16 ga. galvanized sheet metal while E&DCR calls for the piece to be 12 ga. Calculation NM(S)-685-DKB on page 61 shows that a fan blade could penetrate the 8 ga. fan housing. As fans 3HVR*FN6A/B,3HVR*FN13A/B and 3HVR*FN14A/B run at 3500 rpm the 16 ga. sheet metal in the fan inlet flex connection appears to be too light a gage when compared to the 12 ga.

missile shield for the HVP fans which run at 1750 rpm .

Results of the walkdown referenced in NU's disposition are needed to support conclusion that there are no safety related components that are in the trajectory of potential fan blade missiles.

Comments on Second Response Pnnted s/6/98 3 35 52 PM Page 7 of 8

ICAVP DR No. DR-MP3-0687 Northeast Utiliti:3 l

Milistone Unit 3 Discrepancy Report l

The corrective actions for CR M3-98-1745 resolve the potential l for fan blade rnissiles to penetrate the fan inlet flex connection.

l Primed 5/6/98 3.35:52 PM Page 8 of 8

N rthant Utilities ICAVP DR N3. DR-MP3-0702 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: Mechanical Design O ves Discrepancy Type: Drawing l

Y No l SystenVProcess: HVX NRC Significance level: 4 Date faxed to NU:

Date Published: 12/20/97 Discrepancy: HVAC P&lD Discrepancies j

Description:

During review of the auxiliary building ventilation system, supplementary leak collection and release system, and emergency generator enclosure ventilation system the following discrepancies on the piping & instrumentation diagrams were identified.

l 1. The fail position vent direction for the following solenoid valves is show incorrectly on EM-148A:

3HVR*SOV44B 3HVR*SOV44B1 3HVR*5 OV44A 3HVR*SOV44A1 3HVR*SOV42B

2. The fail 5.osition of 3HVR*AOD42B,3HVR AOD43B are not shown on Eli-148A.

3. Drain lines for MCC and Rod Control Area air conditioning units,3HVR*ACU1 A/B are not shown on EM-148A

4. P&lD EM-1500 does not show the class break between the non-safety related normal exhaust duct and safety related tornado dampers 3HVP-DMPT2A-D.

5. P&lD EM-148E does not show the variable inlet vane dampers for SLCRS exhaust fans 3HVR*FN12A/B.

Review Valid invalid Needed Date initiator: stout, M. D. O O O 2/11/97 VT Lead: Nari, Anthony A O O O 12/11/97 VT Mgr: schopfer, Don K g ] ] 12/11/97

!RC Chrnn: singh. Anand K O O O 12/16/97 Date:

INVALID:

Date: 5/1/98 RESOLUTION: First Response NU has concluded that Discrepancy Report, DR-MP3-0702, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the ^

Unit 3 deferral ceteria. CR M3-98-0514 Pnnted 5/6/98 3.36:14 PM Page 1 of 2

N;rthecct Utilities ICAVP DR No. DR-MP3-0702 Millstone unit 3 Discrepancy Report has been written to develop and track resolution of this item per RP-4.

Attachments:

CR M3-98-0514 Second Response (M3-IRF-02035)

NU has concluded that the issue reported in DR-MP3-0702 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Item 5 of the DR states:"5. P&lD EM-148E does not show the variable inlet vane dampers for SLCRS exhaust fans 3HVR*FN12A/B." A review of the fanconfiguration reveals that the inlet vanes are an integral part of the fan as opposed to a separate entity and are " fixed"in their position.

They are set in position and are not opened or closed or aligned or otherwise manipulated. No surveillance procedure exists to operate the vanes.

NU believes that this condition is not a functional or configuration discrepancy that would confuse or mislead the user nor impact system configuration, operation, or safety. Therefore the assignment of Priority 4 requiring completion during the next refueling outage or later is correct and in accordance with U3 PI 20 section 1.3.2 e. This section requires assignment of the Priority 4 code for " enhancements in Operations Critical Drawings which improve presentation and clarify the users understanding by adding, rearranging and restating information".

Previously identified by NU? O yes t*! No Non Discrepant Condition?O ves fel No Resolution Pending?O yes *> No Resolution Unresolved?O ves <*) No Review initiator: stout, M D.

VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chrnn: singh. Anand K j Date: 5/1/98 sL Comments: Comments on First Response Response needs to address basis why adding the SLCRS inlet )

vane dampers to the P&lD (item 5 of DR) is considered a drawing i l

enhancement that can be deferred.

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Comments on Second Response None l

Pnnted 5/6/98 3 36.14 PM Page 2 of 2

N:rth:a:t Utiliti;s ICAVP DR No. DR-MP3-0813 I Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Modification Design p

Discipline: Mechanical Design Discrepancy Type: Component Data SysterrvProcess: HVX NRC Signifw:ance level: 4 Date faxed to NU:

Date Published: 1/10/98 Discrepancy: PDCR MP3-93-067 Hazards Review

Description:

PDCR MP3-93-067 installed eight safety-related electric heaters in the component cooling water pump area of the auxiliary building.

Each unit heater has an integral fan which adds a potential missile source in the area. This potential hazard was not addressed in the safety evaluation for the modification.

Review Valid invalid Needed Date initiator: stout. M. D 0 0 0 12/17/97 VT Lead: Nerl, Anthony A O O O 12/17/97 VT Mgr: schopfer, Don K O O O 12/23/97 IRC Chmn: singh, Anand K O O O 12/3i/97 Date:

INVALID:

Date: 5/4/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0813, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letters B16901 and 17010. It has been screened per attachment 11 of U3 PI 20 criteria and found to have no operability or deportability concems and meets section 1.3.2d of U3 Pl 20 deferral criteria.

The units are small space heaters, approximately 2 feet tall by 12 feet wide by 1 foot deep. The fan is a 1/3 horsepower,1725 rpm. The fan blades are flimsy. If the fan were to throw a blade ,

it would be unlikely to get through the protective housing. If a blade did succeed in clearing the housing, its force would be insignificant due to its small mass and low velocity. l l

CR M3-98-2306 was issued to document this discrepancy. The l corrective action for this CR is to perform a hazards analysis and document it on an Engineering Record Correspondence. The i corrective action will be completed post-startup. There is no affect on the licensing or design basis.

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Attachment:

CR M3-98-2306 Previously identified by NU7 O Yes ! # > No Non Discrepant Condition?O Yes (#1 No Resolution Pending?O Yes + No Resolution Unresolved?O Yes *) No Review Acceptable Not Acceptable Needed Date Printed s/6/98 3 36-3s PM Page 1 of 2 1

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N:rth2att Utilitiss ICAVP DR No. DR-MP3-0813 Millstone Unit 3 Discrepancy Report

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VT Lead: Neri, Anthony A O O O 5'd'S8 O si4/98 VT Mgr: Schopfer Don K IRC Chmn: Singh, Anand K O O O 5/4/98 O O O Date: 5/4/98 SL Conments: No comments 1

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Pnnted 5/6/98 3-35.35 PM Page 2 of 2

f N:rthea:t Utilities ICAVP DR Ns. DR-MP3-0910 l Millstone Unit 3 Discrepancy Report l Review Group: system DR RESOLUTION ACCEPTED j Review Element: System Design Potential Operability issue Discipline: structural Design O ves I Discrepancy Type: Calculation l

4 SystenVProcess: DGX l NRC significance level: NA Date faxed to NU:

l Date Published: 1/17/98 Discrepancy: Pipe Support Calculation Discrepancy

Description:

We have reviewed Calculation no. NP(F)-2060R-260-H004,Rev.4, dated: 8/20/85.

Based on this review,the following discrepancy has been noted:

On page 5,the support configuration has been qualified by comparison to the " identical" support structure and design loads I for the support qualified in calculation no. NP(F)-Z060R-258-H004.

Based on the review of NP(F)-Z060R-256-H004 support calculations and configuration,no similarities have been found between the supports addressed in aforementioned calculations.

Therefore,the qualification by the comparison is not valid.

Review l date Valid invalid Needed initiator: Klaic, N O O O 12/23/97 VT Lead: Neri, Anthony A 0 0 0 12/23/97 VT Mgr: schopfer, Don K G O O / 2/98 1RC Chmn: singh, Anand K O O O 1' 3'98 Date:

INVALID:

Date: 5/4/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0987, does not represent a discrepant condition.1)

The latest revision to calculation NP(F)-Z060R-260-H004 is Rev.

3 dated 08-17-65. The Rev. 4 dated 08-20-85 information is applicable to calculation NP(F)-Z060-258-H004.

2) The page 5 statement " based on identical support structure and design loads" appeared in rev. O of calculation NP(F)-Z060R-260-H004 dated 08-03-82. This calc. has been revised anc' the reference to an " identical" support structure has been changed.

Page 6 of calculation NP(F)-Z060-H004 Rev. 3 dated 08-17-85, references calculation NP(F)-2060R-257-H005. Per revision 2 of this calculation, pages 6 and 9, support CP360260-H004 (calc.

NP(F)-Z060R-260-H004) is correctly referenced. Therefore, this is not a discrepant condition. Significance Level criteria does not apply here as this is not a discrepant condition.

Previously identified by NU? () Yes 'G) No Non Discrepant Condition? #l ves O No Resolution Pending?O yes to) No Resolution Unresolved?O yes * > No Review j

Acceptable Not Acceptable Needed Date VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K Printed 5/6/98 3.36.58 PM Page i of 2

N rthrast Utiliti;s ICAVP DR Ns. DR-MP3-0910 Millstone Unit 3 Discrepancy Report

. . .yo ~ ~rm , - n IRC Chmn: Singh, Anand K Date: 5/4/98 SL Comments: S & L has reviewed the following referenced calculations provided by NU:

Calculation 12179-NP(F)-Z060R-260-H004 , Rev.3 , dated 8/17/85 Calculation 12179-NP(F)-Z060R-257-H005, Rev.2, dated 8/17/85 Calculation 12179-NP(F)-ZO60R-260-H004 , Rev.0 , dated 8/03/82 Calculation 12179-NP(F)-ZO60R-258-H004 , Rev.4 , dated 8/20/85 Based on the results of the review of the aforementioned calculations, the NU's response is deemed acceptable.

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l mmma N:rthr t Utilities ICAVP DR ND. DR-MP3-0957 l

Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p

Discipline: Structural Design Discrepancy Type: calculation Om system / Process: HVX NRC significance level: NA Date faxed to NU:

Date Published: 1/25/98 Discrepancy: Duct Support Calculation Discrepancy

Description:

We have reviewed Duct Support Calculation No.12179--NP(F)-

Z545H-980, Rev.3.

Based on this review we have noted the following discrepancy.

We have requested STRUDL run & STARDYNE output thru RFI no. MP3-705 (items 2,3,4 & 5) to complete the review of i calculation. Since the computer disk sent by NU for the above request does not have the required computer data for base plate design, qualification of the base plate can not be confirmed.

Review Valid Invalid Needed Date l

Initiator: Patel, A. O O O 1/9/98 i VT Lead: Neri, Anthony A B O il 2/98 VT Mgr: Schopfer, Don K O O O '19/98 I

IRC Chmn: Singh, Anand K O O O 1/22/98 Date:

INVALID:

Date: 5/4/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0957, does not represent a discrepant condition. NU is providing the complete computer disk and microfiche for calculation NP(F)-Z545H-980 Rev. 3, and a copy of the pages pertain:ng to the base plate qualifications for this calulation. This information will allow S & L to complete their review of this calculation. Significance Level Criteria does not apply as this is not a descrepant condition.

Previously identined by NU? O Yes '91 No Non Discrepant Condition? 9) Yes O No Resolution Pending?O ves t No Resolution Unresolved?O yes + No Review j initiator: Klaic, N VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K O O O Date: 5/4/98 SL Comments: S & L has reviewed the reference documentation provided by NU.

STARDYNE Computer Run has not been attached to the 4 reference calculation. Only results of STARDYNE are available.  !

Based on the review of low interaction ratios for both base plates, the analysis is deemed acceptable due to the high design margin available.

Pnnted 5/6/98 3:37:16 PM Page 1 of 1

N:rth =t Utiliti2s ICAVP DR N3. DR-MP3-0987 Millstone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: system Design p , ,

Discipline: structural Design Discrepancy Type: calculaton Om SysterrVProcess: NEW g

NRC Significance level: NA Date faxed to NU:

Date Published: 2/5/90 Discrepancy: Pipe Support Calculation Discrepancy

Description:

We have reviewed the Pipe Support Calculation no. NP(F)-Z79B-421, CCN # 1, Rev.0 and stress report calculation no. NP(F)-

7923,Rev.2.

Based upon this review,we have noted the following discrepancy:

The latest revision of the Stress Report models the support as a one way restraint in z direction.

The modified support now consists of 72" long cantilever that carries the load in all three dirrctions.

Therefore,the support should be modeIed as a three directional restraint.

Review Valid Invalid Needed Date initiator: Klaic. N O O 1/27/98 VT Lead: Neri, Anthony A O O O 1/29/98 VT Mgr: schopfer, Don K O O O 1/29/98 IRc Chmn: singh, Anand K O O O 2/2/98 Date:

INVALID:

Date: 5/4/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0987, does not represent a discrepant condition. Pipe support 3-RSS-4-PSR421 is a one way (Z-d;rection) support and the loads and functions are correctly applied in calculation 12179-NP(F)-Z798-421 Rev. O CCN 1.

In addition to this support, another support CP379020-H001 (Vertical / Lateral) is attached to the frame of the support above but at a different location. Support CP379020-H001 is skewed from the primary axis and was modeled that way in the pipe stress analysis. This would produce loading in two directions, a vertical load and a lateral load. The loads in the support calc. for this support were broken down into primary axis directions which produces loads in three directions, a vertical load, and (2) horizontal loads equivalent to the single lateral load by SRSS.

Subsequently, these loads are compared to the input loads (primary direction applied) at the applicable attachment point.Therefore, the loads are applied correctly. Significance Level criteria do not apply here as this is not a discrepant l condition Previously identified by NU? O Yes

• No Non Discrepant Condition? $1 Yes (_) No Resolution Pending?O ves <6) No Resolution Unresolved?O yes

• No Review a.... m_ u Acceptable Not Acceptable Needed Date

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Printed 5698 3:37:35 PM Page 1 of 2

Ngrtheast UtilitiGs ICAVP DR Ns. DR-MP3 0987 Millstone Unit 3 Discrepancy Report VT Lead: Nert Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/4/98 SL Comments: S & L has reviewed the NU's response and accepted the explanations regarding the modeling of the applied load components.

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N rthert Utilities ICAVP DR ND. DR-MP3-0997 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: Mod 6 cation Design p ,

Discipline: Mechanical Design Discrepancy Type: Licensing Docurnent System /Prr etss: NEW NRC Significance level: NA Date faxed to NU:

Date Published: 2/9/98 Discrepancy: Safety eval S3-EV-97-035 in DCR M3-97063 is inconsistent w/

DCN DM3-00-1463-97 & calc US(B)-361

Description:

The safety evaluation for DCR M3-97063, RSS Expansion Joint / Support Modification, is S3-EV-97-035.

J Page 3 of safety evaluation S3-EV-97-035 states, Based on the f existence of the orifices and based on calculation 03705-US(B)-

361 (Rev 0), the effect on system flow due to the utilization of a '

smaller OD expansion joint liner is considered insignificant". A change in expansion joint liner OD is not shown in DCN DM3 1463-97 which provides the updated vendor information for expansion joints 3RSS*EJ1 A-D and 3RSS*EJ2A-D.

Furthermore, calculation US(B)-361 Revision 0 does not provide a basis for the flow resistance coefficient, (i.e., K-factor), used in the analysis for the expansion joints. Therefore, the conclusion in the safety evaluation, (i.e., the effect on system flow due to the smaller expansion joint liners is insignificant), cannot be confirmed.

Review

)

Valid invalid Needed Date initiator: Feingold, D. J. O O O 2as8 VT Lead: Neri, Anthony A O O O 2tas8 VT Mgr: schopfer, Don K O O O 2/4/98 IRC Chmn: singh, Anand K O O O 2/s/98 Date:

INVALID:

Date: 4/30/98 RESOLUTION: .-- Northeast Utilities' first response to DR-MP3-997 ---

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0997, does not represent a discrepant condition. DR-MP3-00997 states that inadequate detail was provided to reach the conclusion that the effect on system flow due to the installation of the reduced diameter expansion joint liners was negligible. Since sufficient detail is provided within the DCR, the safety evaluation, and their associated references (specifically based on the relative inner diameters : the orifice diameter is 3.28 inches and the liner diameter is 7.75 inches), the safety evaluation is considered to address the issue in adequate detail and revision of the safety evaluation is not considered warranted. Post installation testing per US(B)-366 Rev.0, has confirmed the adequacy of the associated calculation.

Printed 5/6/98 3 37.49 PM Page 1 of s

I Nsrth ast Utiliti s ICAVP DR No. DR-MP3-0997 Millstone Unit 3 Discrepancy Report i

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

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0997, does not represent a discrepant condition. DR-MP3-00997 states that inadequate detail was provided to reach the conclusion that the effect on system flow due to the installation of the reduced diameter expansion joint liners was negligible. Since sufficient detail is provided within the DCR, the safety evaluation, and their associated references (specifically based on the relative inner diameters : the orifice diameter is 3.28 inches and the liner diameter is 7.75 inches ),

the safety evaluation is considered to address the issue in adequate detail and revision of the safety evaluation is not considered warranted.

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

--- Northeast Utilities'second response to DR-MP3-997 ----

Disposition:

1 NU has concluded that the issues reported in Discrepancy l l

Report, DR-MP3-0997, have identified NON-DISCREPANT conditions. 1 With respect to item 1, DCR M3-97063, Revision 0 (attached) I states in item (d) of Section 4.0 on page 4-l

" Liners for expansion joints 3RSS*EJ2A/B/C/D will be replaced with a liner having a smaller diameter. Replacement of the liner with a smaller OD liner eliminates potential of liner interference with normal expansion joint movement. (See DCN DM3-00-1463-97 for details)."

DCN DMS-00-1463-97, previously numbered DM3-00-1530-96 (attached), shows the before and after conditions of the expansion joints on pages 20 and 21, respectively. On page 20 the liner OD is shown as 91/4 inches and on page 21 the liner OD is shown as 7 3/4 inches.

Based on the above information, consistent with the original NU response, the revised liner OD is shown correctly on the referenced DCN (page 21 of DCN DM3 00-1463-97). DON DMS-00-1463-97 was not included in the initial response; it is included with this response.

With respect to item 2, at the time that calculation US(B)-366 I

was issued there were two expansion joints in each of the four RSS pipina loops. Loop A contained pump 3RSS*P1 A. heat Printed 5/6/98 3 37.49 PM Page 2 of 5

ICAVP DR Na. DR-MP3-0997 N:rtheast Utilities Millstone Unit 3 Discrepancy Report exchanger 3RSS*E1 A and two expansion joints (3RSS*EJ1 A at the pump discharge and 3RSS*EJ2A near the heat exchangtr inlet). It is important to note as stated in DCR M3-97063 and DCN DM3-00-1463-97, only the liners in expansion joints 3RSS*EJ2A - D were changed (refer to the statement above in quotes extracted from the DCR. The liners in expansion joints 3RSS*EJ1 A - D were not modified and maintained a liner OD l dimension of 91/4 inches. Calculation US(B)-366 is primarily l focused on the K-factor for the restriction orifice and the i expansion joint attached to the restriction orifice. Attachment 1 l which shows the liner OD of 91/4 inches for expansion joints

3RSS*EJ1 A - D is correct and is consistent with the DCR (M3-l 97063).

With respect to the original concem, the effect on system flow due to the smaller expansion joint liner, NU repeatedly stated that the effect was insignificant. Safety Evaluation S3-EV 035 used this term, and it was later used in US(B)-361, Revision 1 (attached), in which Assumption 7 (page 9) states "The hydraulic resistance of expansion joints is not modeled since it is considered to be insignificant (i.e., K > 0.25)."

The following quote is extracted from page iv of calculation l US(B)-361, Revision 1.

"1. Assumption section, item No. 7 The hydraulic resistance of the expansion joints has increased somewhat, due to joint modification. There is a decrease in the i

flow area (9.75" to 7.5") inside the joint which translates into a K-factor of 0.4, assuming an abrupt area change. This loss factor l is still considered insignificant when compared to the overall K factor for the line. Therefore, the results of the analysis are still valid."

The above statement was referring to the 3RSS*EJ2A-D which had the liner OD modification (reduction). The K-factor for the 3RSS*EJ1 A-D was unchanged. The above statement extracted from the calculation demonstrates that NU recognized that the K-factor for the modified expansion joint liners was impacted, that the change to the K-factor was small and that it had a negligible

! affect on the results of the analysis.

To quantify the degree of change, consider the Hot Leg Recirculation flow path. The value for flow resistance, K, is given as 905.39 (page 37, US(B)-361, Revision 1). The size of l the change, given as an increase of 0.4, is less than 0.05%.

This would result in a flow decrease of less than 0.05%, which has no effect on the results. It is reasonable to consider this as insignificant. This provides additional assurance that the judgment neglecting the K-factors for the expansion joints has a negligible impact on the results and was appropriate.

The issue was addressed by NU and the appropriate judgment regarding the impact of neglecting the K-factor was made. As such, they did not have any adverse affect on the desian basis of Printed S/6/98 3.37.49 PM Page 3 of 5 i

L___________________-____________-_______.

N:rther;t Utilitiro ICAVP DR No. DR-MP3-0997 Millstone Unit 3 Discrepancy Report the RSS system.NU considers that none of these represent a discrepant condition.

Significance level does not apply as this is not a discrepant condition.

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0997, have identified NON-DISCREPANT conditions. A copy of DCN DMS-00-1463-97 is attached which shows the change in expansion joint liner diameter to 7.75 inches. The second item is due to confusion over the two expansion joints in each line. The upstream joint , the subject of Calculation US(B)-366, was not changed. The downstream joint was changed to a smaller diameter. Thus, when Calculation US(B)-366 and the referenced DCN, DM3-00-1530-96 (since renumbered to DM3-00-1463-97) refer to an outside diameter of 9.25 inches, they are correct, because there was no change to the upstream joint. The original concem, the effect on system flow of the reduced expansion joint liner diameter, is less than 0.05%, and is considered insignificant. NU considers that none of these represent a discrepant condition. Significance level does not apply as this is not a discrepant condition.

Previously identified by NU? O Yes (8) No Non Discrepant Condition? 8) Yes O No Resolution Pendir.g?O Yes (3) No Resolution Unresolved?O Yes @ No Review initiator: Feingold, D. J.

VT Lead: Nerl, Anthony A VT Mgr: schopfer. Don K IRc Chmn: singh. Anand K Date: 4/30/98 sL Cornments: -- Sargent & Lundys' comment on Northeast Utilities' first response to DR-MP3-997 ----

Northeast Utilities' response to DR-MP3-997 does not address the discrepancy represented.

No DCN is provided to show the change in expansion joint liner diameter to 7.75 inches as provided in Northeast Utilities' response to this discrepancy report. Furthermore. Attachment 1 to calculation US(B)-366, Rev. O, shows the expansion joint liner outside diameter to be 9.25 inches. The reference in the calculation is DCN DM3-04-1530-96. A review of all revisions to DCN DM3-00-1530-96 shows no change to the liner outside diameter. This issue is a level 3 discrepancy.

-- Sargent & Lundy's comment on Northeast Utilities'second l response to DR-MP3-997 -- l I

Printed 5/6/98 3.37:50 PM Page 4 of 5

og u ,,gg,yp,,,,97 North 2ast Utiliti:s ICAVP Millstone Unit 3 gscrepancy Report l

Modelling the expansion joint liner as a flow nozzle results in a

! change in the K-factor closer to 0.7, not 0.4 as provided in Northeast Utilities'second response. However, Sargent & Lundy concurs that the change in flow resistance is insignificant compared to the system flow resistance. Therefore, Sargent &

Lundy concurs with Northeast Utilities that this discrepancy report does not represent a discrepant condition.

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l N':rthert Utilitie3 ICAVP DR ND. DR-MP3-0998 Mmstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: I & C Design $; Yes Discrepancy Type: Drawin9 1

system / Process: sWP O No NRC significance level: NA Date faxed to NU:

Date Published: 2/5/98 Discrepancy: Conflict between LSK-9-10L, Rev 4 and FSAR Section 9.2.1.3

Description:

3WTC-SOV25A2 is identified on logic diagram LSK-9-10L, Rev 4 and P&lD EM-133C-16 as a non-safety related component.

The valve is located in the instrument air supply line between safety related solenoid valve 3WTC*SOV25A1 and the diaphragm operator of safety related air operated valve 3WTC*AOV25A. Since 3WTC-SOV25A2 is non-safety related, it cannot be assumed that the valve would either remain as-is or failin a safe position in the event of an accident. Therefore,if it is postulated that the air path through the "A" port of 3WTC-SOV25A2 is blocked, it would prevent 3WTC*AOV25A from closing. In addition, if it is also postulated that a single failure of 3WTC*AOV25B prevents it from closing, it is conceivable that the path between the safety related portion of the service water system and the non-safety related portion (chemical feed chlorination system) would not be isolated upon receipt of a CDA signal. This conflicts with the requirement to provide isolation as stated in FSAR section 9.2.1.3, Safety Evaluation. This potential design deficiency could impact the ability of the service water system to provide adequate flow to various safety related components.

Review Valid Invalid Needed Date initiator: Pinelas, H. O O O 1/23/98 VT Lead: Neri, Anthony A O O O 1/24/98 VT Mgr: schopfer, Don K O O O 1/26/98 IRC Chrnn: singh, Anand K O O O /27/98 Date:

INVALID:

Date: 5/4/98 RESOLUTION: FIRST RESPONSE .

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0998, does not represent a discrepant condition. The fact that SOV 3WTC-SOV25A2 is non-QA is of no consequence.

In the event that non-QA SOV 3WTC-SOV25A2 fails, AOV 3WTC*AOV25A will still fail closed by venting through QA SOV 3WTC*SOV25A1. Should QA SOV 3WTC*SOV25A1 fail at the f same time , preventing closure of AOV 3WTC*AOV25A, l redundant AOV 3WTC*AOV25B would close providing isolation of the safety related portion of the Sevice Water System from the non-safety related portion upon receipt of the of a l Containment Depressurization Accident (CDA) signal.A single failure of two separate QA components is not a credible failure scenario. A credible failure scenario for this situation would be Pnnted 5/6S8 3.38:01 PM Page 1 of 4

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! N:rthert Utilities ICAVP DR N3. DR-MP3-0998

Millstone Unit 3 Discrepancy Report l

for one of the two QA isolation valves, positioned in series, to fail to close leaving the other isolation valve available to close and isolate the safety related portion of the Service Water System from non-safety related portion, upon receipt of CDA signal.

AOVs 3WTC*AOV25A and 3WTC*AOV25B are redundant. The I failure of one of AOV will always leave the other AOV available I for isolation upon receipt of a CDA signal. Therefore, this item is not a discrepant. Significance Level criteria do not apply here as this is not a discrepant condition.

I

Conclusion:

l NU has concluded that the issue reported in Discrepancy Report, J DR-MP3-0998, does not represent a discrepant condition.The failure of non-QA SOV 3WTC-f iA2 is of no consequence because AOV 3WTC*AOV25A wn, otill fail closed by venting I through QA SOV 3WTC*SOV25A1.The single failure of one of l two redundant AOVs will always leave the other available for isolation of the safety related portion of the Service Water System from the non-safety related portion, upon receipt of a Containment Depressurization Accident signal. Therefore, this item is not a discrepant. Significance Level criteria do not apply here as this is not a discrepant condition.

SECOND RESPONSE (

Disposition: l NU has concluded that the issue reported in Discrepancy Report,

]

DR-MP3-0998, does not represent a discrepant condition. j Chlorine Dilution Water Isolation Valves 3WTC*AOV25A and i 3WTC*AOV25B are air-operated normally-opened valves that I are required to isolate (close) on a Containment Depressurization l Actuation (CDA) signal. The safety function for these valves is l that they close and remain closed until the CDA is cleared and l deliberate operator action is taken to reopen the valves. MP 3 licensing and design bases requires that no single failure shall I prevent proper protective action at the system level when required. Non-quality and non-safety components can failin any condition, at any time, and cannot be credited for performing a safety function. Considering this, Sargent & Lundy postulates that tnere are failure modes in which 3WTC-SOV25A2 can block the release of air from the actuator of 3WTC*AOV25A at the time when 3WTC*AOV25B fails to close when demanded by a CDA signal. Thereby, preventing the Chlorine Dilution Water isolation Valves from performing their safety related function and causing a reduction of Service Water flow to safety-related loads. Solenoid Operated Valves (SOVs) and their control circuits can failin any one of the following ways,1) circuit fails to de-energize upon demand,2) circuit fails to remain energized,3) solenoid plunger faiis to reposition (open or close) upon demand,

4) solenoid plunger sticks midway, 5) exhaust port plugs. The subject solenoid valve does not receive an automatic isolation signal (ESK-7XH) and is assumed to remain energized during the event. In order to block the release of air from actuator I 3WTC*AOV25A there is only one sequence of events or failures that could cause this to occur,1) 3WTC-SOV25A2 exhaust port would need to be plugged solid and be able to withstand the discharae air pressure and 2) the solenoid valve would need to Pnnted 5/6/98 3:38:01 PM Page 2 of 4

i North;ast Utiliti:;s ICAVP DR ND. DR-MP3-0998 Millstone Unit 3 Discrepancy Report l

de-energize prior to de-energization of 3WTC*SOV25A1. There ,

are several items that prevent or mitigates this sequence of events from occurring. First, the solenoid valve has an exhaust ,

port elbow and/or tubing to direct the discharge air downwards l and prevent debris from entering the exhaust port which j prevents plugging. Second, solenoid valve 3WTC-SOV25A2 is '

located within the intake structure and is not subjected to the

- consequences of the CDA accident. Therefore, there are no j initiating events or conditions that could cause this sequence of I multiple failures to occur and cause loss of the protective function. Additionally, if the single failure is assumed to be the 3WTC*SOV25B valve, then both trains of Service Water are operable and isolation of SW to WTC is not necessary. This failure is bounded by the single failure of a train of Service Water. 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, 1 DR-MP3-0998, does not represent a discrepant condition. The failure of solenoid valve 3WTC-SOV25A2 in such a manner to block the release of air from the actuator of 3WTC*AOV25A at j the time when 3WTC*AOV25B fails to close when demanded by 1 a CDA signal is not credible.

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

Previously identified by NU? O Yes

• No Non Discrepant Condition? IGl Yes O No Resolution Pending?O Yes + No Resolution Unresolved?O Y . + No Review Acceptable Not Acceptable Needed Date initiator: DeMarco, J.

O O si4sa VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K O O 5'4'S8 IRC Chrnn: singh. Anand K O O O 5/4/S8 O O O Date: 5/4/98 SL Comments: COMMENT TO FIRST RESPONSE:

Non-quality /non-safety components can fail in any condition, any time, and cannot be taken credit for performing a safety function.

It is therefore postulated that 3WTC-SOV25A2 can block the release of air from the actuator of 3WTC*AOV25A at the time when 3WTC*AOV25B fails to close when demanded by a CDA signal. The non-safety portion of the piping would not be isolated from the safety portion, and flow required for safety-related loads would be reduced.

COMMENT TO SECOND RESPONSE:

l The last sentence of NU's second response is correct:

l "This failure is bounded by the single failure of a train of Service Water."

This is true because the Chlorination System is connected to only

]

one Service Water Systein train.

MP3 is committed to R.G.1.26, Quality Group Classifications and Standards for Water , Steam, and Radioactive-Waste-Containing l

Printed 5/6/96 3.38:01 PM Page 3 of 4

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i N:rthea:t Utilities ICAVP DR N2. DR-MP3-0998 Millstone Unit 3 Discrepancy Report Components of Nuclear Power Plants. R.G.1.26 Paragraph 2.b refers to Cooling water systems such as the Service Water System. This paragraph references footnote 4 which states:

"The system boundary includes those portions of the system required to accomplish the specified safety function connected piping up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure when the safety function is required."

Since the nonsafety solenoid valve 3WTC-SOV25A2 is associated with the second isolation valve 3WTC*AOV25A downstream of the Service Water System supply, the original condition described is non-discrepant.

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1 N:rthert Utilities ICAVP DR NJ. DR-MP3-1005 Millstone Unit 3 Discrepancy Report

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Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p i Discipline: Mechanical Design l Diseropancy Type: Corrective Action 4

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systenVProcess: Oss NRC significance level: NA Date faxed to NU:

Date Published: 2/7/98 Discrepancy: Failure to follow Corrective Action Process

Description:

UIR-1952 identifies inconsistencies in the FSAR relative to QSS .

I

& RSS containment spray droplet size, and related errors in supporting design calculations. This issue questions the operability of the QSS & RSS systems. Additionally, the issue was potentially reportable under 10CFR50.72. Pt 14, Rev. O, paragraph 1.3.2 states, "lF item is potentially reportable OR impacts operability, Refer to RP-4,' Corrective Action Program,'

and INITIATE CR." No CR has been initiated for this issue.

(Refer to DR-MP3-0314 for similar issues)

Review Valid invalid Needed Date i Initiator: Wrona, s. P. G O O 1/27/98 VT Lead: Ryan, Thornas J B O O /27/98 VT Mgr: schopfer, Don K O O O 2/2/98 lRC Chmn: singh, Anand K B O O 2/3/98 Date:

INVALID:

Date: 5/4/98 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1005, does not represent a discrepant condition. Based on interviews with Design Engineering personnel, UIR 1952, identified a condition within the FSAR which required clarification. FSAR Section 6.2.2.2, identified that the RSS and QSS mean surface droplet diameter from the spray nozzles to be less than 1000 microns. UIR 1952, raised a question over the droplet sizes identified within the design calculations being larger than the limit stated in the FSAR. In the early period of the PI-14 program and resulting from the FSAR review, the UlR screening process was used in making the determinations as to whether an ACR was warranted due to potential operability and deportability concems. The Expert Panel, upon review of UIR 1952, concluded that variations from the stated surface mean and mass mean droplet sizes would not have a significant impact on the thermal efficiency nor on the iodine scavenging capability of the droplets. The effectiveness of the spray systems was found to be acceptable over a range of containment atmospheric conditions and spray droplet sizes. This was viewed as strictly a FSAR clarification issue and since the 10CFR50.54f project had initiated an extensive FSAR review and upgrade project, a UIR was determined to be sufficient to ensure a FSARCR was initiated for the clarification. Operability and Deportability were Pnnted 5/6/98 3.38.12 PM Page 1 of 2

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N rthert Utilities ICAVP DR NA DR-MP3-1005 Millstone Unit 3 Discrepancy Report l

l never issues after the subject was reviewed. FSARCR 97-MP3-l 543 was initiated to remove the statement that RSS and QSS j spray droplet mass mean diameters be less than 1000 microns.

NU does not consider this to be a discrepant condition.

Conclusion NU has concluded that the issue reported in Discrepancy Report, j DR-MP3-1005, does not represent a discrepant condition, it is l correct that an ACR / CR shall be initiated during the PI-14 process for items that are potentially reportable or impacts operability to refer to RP-4, ' Corrective Action Program.'

Members of the Expert Panel were aware of the variable nature of droplet size relative to thermal effectiveness and lodine scavenging over a range of atmospheric conditions as identified by original design calculations. During the UIR screening process, the Expert Panel reviewed the issue and made a determination that this item required clarification within the FSAR and no operability or reportibility concems were directed at the spray functions of the RSS and QSS systems. Therefore NU does not consider this to be a discrepant condition.

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

Previously identified by NU? O Yes (S) No Non Discrepant Condition? 03 Yes O No Resolution Pending?O Yes ch No Resolution Unresolved?O Yes @ No Review initiator: Navarro. Mark VT Lead: Ryan. Thomas J VT Mgr: schopfer. Don K lRC Chmn: Singh. Anand K Date: 5/4/98 SL Comments: NU's response is accepted on the basis of their stated conclusion that the effects of the droplet size variation were previously considered by NU's expert panel and determined not to have any significant effect. This information was not originally included in the final disposition of the UIR which we reviewed.

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Pnnted 5/6/98 3 3812 PM Page 2 of 2

I N:rthe st Utiliti2s ICAVP DR Ns. DR-MP3-1016 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p

Discipline: Mechanical Design Discrepancy Type: Calculation g System / Process: N/A -

NRC Significance level: 3 Date faxed to NU:

Date Published: 2/23/98 l

Discrepancy: Secondary Containment Bypass Leakage Penetrations

Description:

During review of calculation P(R)-1150, Rev. O " Containment Bypass Leakage Penetrations" the following discrepancies were identified:

1. On page 20 of calculation P(R)-1150, penetration 121 was not considered as a bypass leakage path because a blind flange is attached to the opening of the containment vacuum test line inside the containment. P&lD EM-153A-19 shows the blind flange installed on line 3-CVS-002-34-4. Since this is a class 4 line, penetration #121 should have been considered as a bypass leakage path similiar to penetration #35 & 36.

2. On page 17 of calculation P(R)-1150, penetrations 93,94,95:-

a) calculation references FSAR section 6.3.2.8 for minimum elapsed time from a LOCA signal to the receipt of the RWST low-low level signal instead of referencing a design calculation.-

b) calculation does not provide a reference for the 25'-5" low-low RWST water level.

c) Calculation uses a containment pressure of 0 psig at 1000 sec (max ESF) and 2000 see (min ESF) based on calculation US(B)-273 Rev. 3. Calculation US(B)-273 Rev. 5 & 6 shows a containment pressure of approx. 5.5 psig at 2000 sec (min ESF).

The top elevation of the piping in the containment is approximately 19'. Calculation needs to address the impact of the higher containment pressure and elevation of the piping inside containment has on the differential pressure across check valve *V9 and *V3.

d) Calculation does not address the time it takes for the upstream and downstream pressure at valve *V9 (or *V3) to equalize and if it occurs before isolation valve *MV8809A/B is manually closed. With stagnant conditions and the isolation valves open, diffusion of radionuclides back to the RWST should be addressed.

3. On page 18 of calculation P(R)-1150, penetrations 91 & 92:-

Calculation usesjustification for penetrations 93,94, & 95 to exclude penetrations 91 and 92 as bypass leakage penetrations.

Comments on 93,94, & 95 also apply to penetrations 91 & 92.

4. FSAR Table 6.2-65 " Containment Penetrations" identifies bypass leakage penetrations. The table does not include the following penetrations that are identified in calculation P(R)-1150 as bypass leakage penetrations: #24, 27, 39, 59, 60, 99,100, Printed 5/6/98 3:38:25 PM

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N:rtheast Utiliti:s ICAVP DR Nr. DR-MP3-1016 Millstone Unit 3 Discrepancy Report l

124.

l S. OPS Form 3273 - 3/4.3.6.1.2 Table 3.6.1.2-1 ' Secondary Containment Boundary Bypass Leakage Paths' does not include the following penetrations that are identified in calculation P(R)-

1150 as bypass lea 4 age penetrations: #24,27,28,29,39,99, 100,102,103,104,105,109,110,111,112,113,114,115,and 120.

Review Valid invalid Needed Date initiator: Stout. M. D. O O O 2/im VT Lead: Neri, Anthony A B O O 2/13/98 VT Mgr: Schopfer, Don K O O O 2/is/98 1RC Chmn: Singh, Anand K O O O 2/19/98 Date:

INVALID:

Date: 5/2/98 RESOLUTION: First Response NU has concluded that Discrepancy Report, DR-MP3-1016, has identified a condition not previously discovered by NU which requires correction. A CCN must be issued to calculation P(R)-

1150 to clarify that penetration 121 is a bypass leakage path, provide correct references for elapsed LOCA signal time duration from receipt of low-low RWST level signal and the elevation for the low-low RWST water level, and the effect of positive containment pressure transient post LOCA on check valves 3RSS*V9 and 3RSS*V3 and reevaluate penetrations 91 and 92 as bypass leakage penetrations. Calculation US(B)-273 '

provides the containment pressure response following a LOCA.

FSAR Table 6.2-65 must be revised to include all of the bypass leakage penetrations determined in calculation P(R)-1150. OPS l Form 3273-3/4.3.6.1.2 Table 3.6.1.21 must be ;ikewise revised to include all bypass leakage penetrations. The approved corrective action plan for CR M3-98-1048 will track these activities to completion before startup.

I The discrepancies of CR M3-98-1048 were determined to be reportable to the NRC and will be included in LER 98-007-00 now in preparation for CR M3-98-0467. The Significance Level is considered to be Level 3.

I Attachments: l CR M3-98-1048 w/ approved correction action plan l l

Second Response (M3-IRF-02262) 4 NU has concluded that this issue reported in DR-MP3-1016 has

{

identified a CONFIRMED SIGNIFICANCE LEVEL 3 condition '

which requires correction. The approved corrective action plan for CR M3-98-1048 required (in part) a CCN be issued to calculation 12179-P(R)-1150. CCN 3 to calculation 12179-P(R)-

1150has been completed and is attached.

Printed 5/6/98 3:38:2s PM Page 2 of 3 i

N:rthext Utilities ICAVP DR N3. DR-MP3-1016 Millstone Unit 3 Discrepancy Report Attachments:

CCN 3 to calculation 12179-P(R)-1150 Previously identified by NU? O Yes e) No Non Discrepant Condition?O Yes tOJ No Resolution Pending?O Yes 5) No Resolution Unresolved?O Yes + No Review initiator: stout, M. D.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date: 5/2/98 sL Comments: Comments on First Response Results of CCN to calculation P(R)-1150 are required to determine the final classification level of the DR.

Comments on Second Response Based on the results of CCN 3 to calculation P(R)-1150, Rev. O the DR is classified as a Level 3 discrepancy.

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Pnnted 5/6/98 3.38:25 PM Page 3 of 3 L_____________._______________---_________

Northe:st Utilities ICAVP DR N3. DR-MP3-1026 Millstone Unit 3 Discrepancy Report l

Review Group: systern DR RESOLUTION ACCEPTED Review Element: systern Design p

Discipline: Mechanical Design Discrepancy Type: Calculation Om 4

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System / Process: NEW NRC Signincance level: 3 Date faxed to NU:

Dete Published: 2/7/98 Discrepancy: Revision of Calculation US(B)-353 for DCR M3-97045

Description:

The purpose of Calculation US(B)-353, Rev. 0/CCN 1 is to determine the containment recirculation spray system (RSS) piping temperature transients following a set of potentially limiting design basis LOCA scenarios. The calculated piping temperature transients are then to be used in the pipe stress analysis and support load calculations.

Two discrepancies were identified in Calculation US(B)-353:

1. CCN 1, dated 11/13/97, should be re-numbered CCN 2. CCN 1 to US(B)-353, Rev. O was issued 4/23/97.

2. Calculations US(B)-322 Rev. 2, US(B)-352, Rev. O, and US(B)-353 Rev. O all develop input for the analysis of RSS piping thermal stresses following a LOCA. It appears that US(B)-

352 and US(B)-353 would supersede US(B)-322 (from a RSS piping temperature stand point) since US(B)-322 determines limiting sump water and spray water temperatures and concludes that the RSS piping temperature will be between these temperatures. Whereas, US-353 uses RELAPS/ MOD 3 to determine the time varying temperature of the RSS piping based on various LOCA scenarios documented in US(B)-352. These calculations also determine containment pressure and liner temperature. The results of these calculations are to be used for piping stress and support analysis. However, these analyses do not address a MSLB. Calculation US(B)-296, Rev. 2, CCN 1 determines the peak liner temperature to be 255.9 oF which I exceeds the peak liner temperature of 235.1 oF documented in l US(B)-352 and US(B)-353. The results of US(B)-296 should be addressed in the RSS piping and support analysis. Additionally, Calculation US(B)-354, Rev. O determines the QSS piping temperature transients following a LOCA, using the same methodology used in US(B)-353, based on LOCA scenarios in US(B)-352. The results of US(B)-296 should be addressed in the QSS piping and support analysis.

l The latest controlled documents are not properly tracked to ensure the latest design input is used. )

Review Valid invalid Needed Date initiator: Wakeland, J. F, O O O 1'31'S8 '

VT Lead: Neri, Anthony A O O O 2/2/98 l

l VT Mgr: schopfer, Don K O O O 2/2/98 IRC Chmn: singh, Anand K O O O 2/3/98 j i

Printed s/G/98 3:38.38 PM Page 1 of 4

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Ntrthea:t Utilities ICAVP DR NA DR-MP3-1026 Millstone Unit 3 Discrepancy Report Date:

INVALID:

Date: 5/4/98 RESOLUTION: DISPOSITION:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1026, have identified conditions not previously discovered by NU which require correction. The corrective action plan for CR M3-98-0815 (attached) will correct Calculation US(B)-353 with respect to each of the two discrepancies identified. The status of calculation US(B)-322 will be checked, and withdrawn if it is indeed superseded. Calculations US(B)-

296, US(B)-352, US(B)-353 and US(B)-354 will be reviewed with respect to the RSS and OSS piping and support analyses. The revised results will then be carried forward into the calculations and documents which use results from US(B)-353 as an input.

Item 1 is an administrative item only. The CCN dated 11/13/97 should be CCN #2 not CCN #1. The CCN will be corrected.

Item 2 - During the re-analysis of QSS and RSS piping in 1996, calculations US(B)-352, US(B)-353 and US(B)-354 concluded that LOCA events were more limiting than MSLB events since piping responds more slowly to a MSLB than a LOCA. This is due to the fact that the LOCA results in bounding containment pressures and the steam line breaks are expected to be less limiting than LOCAs since the saturation temperature in containment, which drives condensation heat transfer to the piping, rises more slowly than for a large break LOCA. The peak stresses and support loads for QSS and RSS systems are influenced be the piping heatup in the early part of the transient prior to system flow. The MSLB which causes the most limiting containment liner temperature is a relatively sma!! MSLB (0.4 sq ft) which causes a slow response in containment energy and piping temperature.

The rationale for determining the most limiting case for QSS and RSS piping and support design is provided in calculation US(B)-

352 and is generally based on a sensitivity study which evaluated the thermal range for piping and maximum support loads due to the various accident scenarios. This methodology reviewed the family of accident scenarios to determine that the most limiting conditions were developed during two distinct time phases. Phase one occurs when the piping temperature is maximized prior to fluid flow conditions and containment movements are minimized. Phase two occurs after fluid flow conditions when piping temperature is minimized and containment movement is maximized. Containment movements are a function of four parameters: deadweight, concrete temperature, liner temperature, and containment pressure.

{ Deadweight and concrete temperature have little influence over containment movement, which is dominated by liner temperature and containment pressure.

Printed 5/6/98 3:38 39 PM Page 2 of 4 l

N:rthe st Utilities ICAVP DR No. DR-MP3-1026 Millstone Unit 3 Discrepancy Report initial screening of the DR determined that this issue had no impact on the operability of the RSS and OSS systems (reference CR M3-98-0815). However, in the process of responding to the DR, a detailed justification far why the MSLB is bounded by LOCA required that the d!fference in parameters which have the dominant influence on piping qualification (i.e.,

containment liner temperature, containment pressure, and piping system temperature) be addressed. For the OSS piping system, these parameters associated with the MSLB in the later stage of the transient were detemiined to exceed those predicted for the most limiting LOCA scenarios. Therefore, upon further review, the MSLB was determined to be a more limiting case for the QSS system. The RSS system was determined to be still bounded by the LOCA scenarios.

Subsequently, an additional CR, M3-98-1875 (attached) was initiated to address the QSS issue. Operability Determination MP3-053-98 determined that the QSS system is operable.

Further engineering is proceeding to ensure the QSS system is fully qualified and meets design basis criteria. The basis for why the LOCA scenarios are bounding for the RSS system design will be provided in the applicable calculations.

CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSF related calculation discrepancies identified by the ICAVP prop'am. This corrective action will be completed after startup, ar'J will ensure that the errors in US(B)-

353 are corrected. The carrective action plan for CR M3 0815 is tied to CR M3-p3-0619 by AR 98002805. j l

As part of the ICAVP program, trending CR M3-98-1132 has l 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.

1 Each of the discrepancies in DR-MP3-1026 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR MP3-98-1026 significantly affect the results of the RSS related calculations, and do not affect 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 l the operability of the RSS system.

Regarding the QSS system, the discrepancies identified in DR- )

MP3-1026 have an effect on the QSS calculations and may have  ;

an effect on whether the system meets its design basis.

Therefore CR M3-98-1875 was initiated and an Operability Determination is in place to document that '.he QSS system is operable. NU concurs that this is a Significance Level 3 issue.

CONCLUSIONS:

NU has concluded that the issue reported in Discrepancy Report.

Pnnted 5/6/98 3:38:39 PM Page 3 of 4

N:rthe:st Utilities ICAVP DR No. DR-MP3-1026 Mit! stone Unit 3 0;screpancy Report DR-MP3-1026, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0815 (attached) will correct Calculation US(B)-353 with respect to each of the two discrepancies identified after startup. Associated calculations US(B)-296, US(B)-322, US(B)-352, US(B)-353 and US(B)-354 will be reviewed for consistency, and revised as necessary, in addition, an assessment will be performed prior to Startup of the issues related to calculational discrepancies. This will ensure that any generic implications are clearly identified and addressed. Each of the discrepancies identified in DR MP3 1026 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS system meets its design basis.

Regarding the QSS system, the discrepancies identified in DR-MP3-1026 have an effect on the QSS calculations and may have an effect on whether the system meets its design basis.

Therefore CR M3-98-1875 was initiated and an Operability Determination is in place to document that the QSS system is operable. NU concurs that this is a Significance Level 3 issue.

Previously identified by NU? O ves '91 No Non Discrepant Condition?O ves (#l No Resolution Pending?O ve. 9 No Resolution Unresolved?O ves <#) No Review l Initiator: Wakeland, J. F.

VT Lead; Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K g

Date: 5/4/98 sL Comments: Sargent & Lundy concurs that the corrective action plan for CR M3-98-0815, issued 2-12-98 (AR 98003225-02) will resolve the discrepancies identified in DR-MP3-1026 for both the RSS and the QSS systems.

l Sargent & Lundy agrees with the preliminary finding (S&W Letter MP3-375/SRE-MP3-9805, dated 3-6-98) that the issue raised in DR-MP3-1026 does not affect the design basis of the RSS system because RSS is not required to operate during a postulated MSLB.

Sargent & Lundy also concurs that the error identified in DR-MP3-1026 may have placed QSS piping within the containment hiilding outside of its design basis, but that OD MP3-053-98 l (attached to CR M3-98-1875) demonstrates that the QSS system j is operable. With respect to the QSO. system, DR-MP3-1026 is a I level 3 discrepancy. ,

I Pnnted 5/6/98 3 38:39 PM Page 4 of 4 I

N rthe:st Utilities ICAVP DR NO. DR-MP3-1093 Millstone Unit 3 Discrepancy Report

( -

l Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Discipline: Operations P OWWh )

I Discrepancy Type: Corrective Action implementation Om g

System / Process: N/A

~

l NRC significance level: NA Date faxed to NU:

i Date Published: 4/9/98 Discrepancy: Closure of CR M3-97-0713

Description:

The issue described in this CR is with respect to adequacy of surveillance in verifying the operability of electrical busses pursuant to technical specifications 4.8.3.1 and 4.8.3.2.

Included in the closure package was related corrective action I assignment AR 97005722-02 which was closed on the basis that procedures 3670.1-2 Rev. 9 and 3672.1-2 Rev.12 wsIL 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 3670.12, 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 explanation provided for such exclusion.

2. In addition, in the memo from J. Plourde to WhiteWE and HallerJ dated 5/13/97 (copy contained in the closure package for this CR), item (1) reads as follows: "The term indicated bus voltages used in TS and Surv. procedure should be interpreted as bus nominal voltage, i.e.120V system (120V),480V system (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 i

Valid invalid Needed Date J Initiator: Navarro, Mark O O O 3'3o'98  !

VT Lead: Ryan. Yhomas J O O O d'3/98 VT Mgr: schopfer, Don K O O O 4'3'98 1RC Chmn: singh. Anand K O O 4/4'98 O

i i Pnnted 5/6/98 3:39.01 PM Page 1 of 2

, i 1

N:rth2c;t Utilities ICAVP DR No. DR-MP3-1093 Millstone Unit 3 Discrepancy Report Date:

INVALID:

Date: 4/23/98 RESOLUTION: Disposition NU has concluded that Discrepancy Report DR-MP3-1093 does not represent a discrepant condition. The DR does, however, identify a typographical error in procedure SP 3670.1, Change Summary 7.14, which references engineering evaluation M3-EV-970399, Rev. O. For this reason, the requested evaluation was not provided to S&L. The correct number is M3-EV-970300, Rev. O. An OSCAR feedback form has been generated to correct the typographical error. Engineering evaluation M3-EV-970300 explains that for the 4160VAC,125VDC and 120VAC systems, the appropriate method to check bus operability is by confirming breaker alignments and verifying no undervoltage alarms are present. The evaluation further explains that for the 480VAC system, the undervoltage alarm is set for 70% voltage, so a conservative voltmeter reading is derived from the 90% low limit, and adjusted for meter accuracy.

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

Conclusion NU has concluded that Discrepancy Report DR-MP3-1093 does not represent a discrepant condition. The DR does, however, identify a typographical error in procedure SP 3670.1, Change Summary 7.14, which references engineering evaluation M3-EV-970399, Rev. O. For this resason, the requested evaluation was not provided to S&L. The correct number is M3-EV 970300, Rev. O. An OSCAR feedback form has been generated to correct the typographical error. Engineering evaluation MS-EV-970300 (attached) explains the reason for requiring a voltmeter reading only on the 480VAC busses, and includes a basis for the acceptable value. Significance level criteria do not apply as this is not a discrepant condition.

Previously identir:ed by NU? O Yes '91 No Non Discrepant Condition? S' Yes O No Resolution Pending?O Yes + No Resolution Unresolved?O Yes @ No Review initiator: Navarro. Mark VT Lead: Ryan. Thomas J VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Date:

SL ^omments:

l Pnnted 6/6/98 3:39:02 PM Page 2 of 2

l l

N:rthert Utiliti:s ICAVP DR No. DR-MP31011 Millstone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION REJECTED Review Elernent: Modification Design p

Discipline: Mechanical Design Discrepancy Type: Design Control Procedure 4 l Systern/ Process: DGX NRc significance level: 3 Date faxed to NU:

Date Published: 3/5/98 Discrepancy: Unreviewed Safety Questions Conceming the MP-3 Emergency Diesel Generators

Description:

Modification 3-91-196 (MOD) was reviewed and issued by NU's PORC on 12/4/91. The PDCR package was completed and submitted to Nuclear Records on 8/15/92. The need for the modification was that the fuel oil sample point was down stream of the strainers that remove particulate of 200-mesh size or larger from the fuel oil. Consequently,'he t strainers could affect the sample particulate analysis. The purpose of the modification is to pemianently remove the strainer elements from strainer housings 3EGF*STR1C and 3EGF*STR1D (one of two on each Diesel) allowing for a more representative sample of sediment in the fuel oil.

The design requirements for the Emergency Diesel Fuel Oil System, in part, are as stated below:

Section 9.5A.1 of the FSAR, ' Design Bases', states that the design bases for the EGF shall be:

1. In accordance with Regulatory Guide 1.137, for fuel oil systems design, fuel oil quality, and tests.

2. In accordance with General Design Criterion 17, for the capability of the fuel oil system to meet independence and redundancy criteria.

The removal of one of the strainers from each Diesel, removes I the redundancy which is required in the two fuel oil transfer systems on each Diesel. This item is also described in MP3's FSAR, Section 9.5.4.2 System Description, which states: "Each flow path consists of a fuel oil storage tank, two 100 percent capacity fuel oil transfer pumps and strainers, a day tank, and piping to each respective diesel engine..

Regulatory Guide 1.137, Section C, ' Regulatory Position states',

"1. The requirements for the design of fuel-oil systems for diesel generators that provide standby electrical power for a nuclear power plant that are included in ANSI N195-1976, ' Fuel Oil Systems for Standby Diesel-Generators,' prtvide a method acceptable to the NRC staff for complying wid the pertinent requirements of General Design Criterion 17.. ".

ANSI N195-1976, Section 6.3, ' Strainers', states: "A strainer shall be provided for each engine. The mesh of the strainers shall be as required to prevent overloading of the engine fuel filter. The .

strainer shall be of duplex design". ,

l The original design of the EDG Fuel Oil System is also in non-mmnfinnm with A_NRI N198i 1Q78 whir h rannirac Onnlov i Pnnted 5/6/98 3:39.35 PM Page 1 of 4 l

l 1

1 1

N:rthea:t Utilities ICAVP DR ND. DR-MP31011 Millstone Unit 3 Discrepancy Report Strainers. A single Y-type strainer is installed in each Fuel Oil Subsystem instead of the Duplex Strainers.

Table 1.8-1 of MNPS-3 FSAR states that NU will comply with Reg. Guide 1.137 except for the cited clarifications and exceptions. The only exception taken,is that MP-3 has 3-day storage tanks for each Diesel, instead of the required 7-day tanks.

It should also be noted that ACR M3-96-0240 was written to track a ' Difference in Professional Opinion (DPO), due to a

'concem' from NU's Nuclear Safety Engineering group. The 50.54f EDG Review Team questioned the technicaljustification for this MOD and whether or not it could result in a potential reduction in reliability. The conclusion of this ACR was that the strainers should remain removed, because "There is also less risk of an EDG failure with the cartridges removed than with them installed". No basis for this assumption is included in the ACR.

The Safety Evaluation performed by NU determined that NO Unreviewed Safety Question (USQ) exists. However, ICAVP believes that this Safety Evaluation is deficient. This is due to the fact that NU's Safety Evaluation appears to have only looked at the 'C' and 'D' strainers being used during the Fuel Oil Sample Surveillance. No evaluation of the long term effects of operating with the unstrained oil pump was performed. Further, no analysis was performed to determine the effects on sludge carry-over or its effect on the engine fuel filters as the tank levels diminish. This review should have included an analysis of the 10% minimum level allowed in the Fuel Oil Storage Tanks and some minimal level in the Day Tanks when operated in manual utilizing operators. NU did not take into account that the unstrained pumps 'C' and 'D' are also the ones which have dual electrical feeds, making them the more reliable Fuel Oil Transfer Sub-Systems during a LOP event ,

NU's FSAR Section 9.5.4.2, ' System Description', Item 2 states:

"Each pump has sufficient capacity to fill both day tanks with both emergency generators running, since the fuel consumption at rated load and speed for one emergency generator is 6.16 gpm." This implies that if one Fuel Oil Storage Tank were inoperable, then both EDG's would be feed from one tank. This means that the operable storage tank would be filled on approximately a daily bases, without any provision for settling time. Worst case would be with an unstrained pump in-service.

i l The FSAR does not adequately address that any exceptions to the design requirements was taken for the MOD (see Table 1.8-1 of NU's FSAR). It should be noted that the language conceming the MOD in Sections 8 and 9 of the FSAR is ambiguous and not all required parts of the FSAR reflect the MOD. These include, in part:

1, FSAR, Section 9.5.4.2: "Each flow path consists of a fuel oil j storage tank, two 100 percent capacity fuel oil transfer pumps i

Pnnted 5/6/96 3:39:35 PM Page 2 of 4 L------_-_--------_---_-

N:rthe::t Utiliti;s ICAVP DR N3. DR-MP3-1011 Millstone Unit 3 Discrepancy Report and strainers, a day tank, and piping to each respective diesel engine."

2. FSAR, Section 9.5.4.2, item 6: "A duplex fuel oil strainer is provided for each diesel generator by the manufacturer "

3. FSAR, Section 9.5.4.3: As a result of the redundancy incorporated in the system design, the EGF system provides its minimum required safety function under any one of the following conditions: . loss of off-site power coincident with maintenance outage or failure of one emergency generator fuel oil transfer pump associated with each emergency generator; and loss of off-site power coincident with maintenance outage or failure of either emergency generator fuel oil storage tank.

It is not clear that the pumps without strainers installed are still in their 'as designed' system alignment. By NU's admission (ACR M3-96-0240), this means that the unstrained pump may start before the normal lead pump and deliver unstrained oil for a prolonged period of time.

From the available information, the ICAVP Team could not determine if the MOD design of the EDG Fuel Oil System would definitely result in both EDG's being inoperable. Thus, a NRC Significance Level of 3 is assigned. However, based on NU's response, the DR's NRC Significance Level could escalate.

Review Valid inv. lid Needed Date initiator: Ungeran, R. 0 0 2/24/98 VT Lead: Bass, Ken 9 0 0 2/25/98 VT Mgr: schopfer, Don K @ O [ 2/26/98 IRC Chmn: singh, Anand K 9 0 0 3/2/98 Date:

INVALID:

Date: 4/29/98 RESOLUTION: Disposition:

Northeast Utilities RP4-2 CR Change Form (attached), revised the corrective action plan for CR M3-98-1373 as follows: " Revise FSAR Table 1.8-1 to identify the differences between MP3 DG fuel oil piping strainer design and section 6.3 of ANSI N195-1976. Revise FSAR Section 9.5.4 as required to clearly describe the configuration of the strainers in the transfer pump discharge lines. The justification for this difference from the ANSI standard is supported by the MP3 procedures which assure that the oil quality stored exceeds the standards recommended by the diesel manufacturer. The justification shouid include discussion of the following points: (1) Sampling of the oil received; (2) Condition of the storage tank; (3) Condition of the fuel oil piping; (4)

Methodology of the sampling (specifically draining the dead leg of the sample line prior to taking the sample

• NU has concluded this DR to be a " CONFIRMED DISCREPANT" Significance Level 4 issue.

l

Conclusion:

Northeast Utilities RP4-2 CR Change Form (attached) revised Printed s/6/98 3 39.36 PM Page 3 of 4

Northrst Utiliti:s ICAVP DR Ns. DR-MP3-1011 Millstone Unit 3 Discrepancy Report the corrective action plan for CR M3-98-1373 to revise FSAR Section 9.5.4 as required to clearly describe the configuration of the strainers in the transfer pump discharge lines, revise FSAR Table 1.8-1 to identify the differences between MP3 DG fuel oil l piping strainer design and section 6.3 of ANSI N195-1976 and to l provide the justification for this difference from the ANSI standard. NU has concluded this DR to be a "CONFlRMED DISCREPANT" Significance Level 4 issue. l l Previously identified by NU? O Yes (p No Non Discrepant Condition?O yes @ No Resolution Pending?O yes (W) No Resoiution unresolved?@ ves O No Review Acceptable Not Acceptable Needed Date S R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K O 4=

IRc Chmn: singh. Anand K Date: 4/29/98 sL Comments: S&L concurs with revised corrective action plan for CR M3 1373 as described in the discrepancy response. S&L considers the item as pending resolution until we have reviewed the FSAR /

Safety Evaluation described in the response.

We do not concur that the discrepancy is a significance level 4 issue. The configuration of the diesel oil transfer system was placed outside the design and licensing basis when the strainer was removed. The correactive action plan will revise the licensing basis to be consistant with the as installed configuration.

Pnnted SRv98 3.39:36 PM Page 4 of 4 I

l l

-_ - - - - _ - - i

Northeast Utiliti;s ICAVP DR No. DR-MP3-1088 f

l Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION REJECTED Review Element: Corrective Action Process Discipline: I & C Design Discrepancy Type: Corrective Action implementation Om 4"

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

Date Published: 3/30/98 J

Discrepancy: Insufficient documentation for post startup closure of instrument qualification issue.

Description:

CR M3-97-1444 addresses the operating temperature range of l

the Emergency Generator Load Sequencer (EGLS). IEEE 279 requires conditions which render the EGLS inoperable be statused in the Control Room. The vendor's O&M manual documents the equipment's operating temperature range as 75

+/ 5 deg. F. The instrument rack room's normal temperature is documented in the purchase specification as 75 +/- 5 deg F.

Setpoint Calculation SP-3HVC-8 documents the rack room's temperature setpoint as 75 deg. F; however, actua! rack room temperature measurements vary around 68.7 deg. F. Without an approved design change, the HVAC's temperature controller setpoint was change to 65 deg. F by operation's initiated EWR#

3-94-00128 that was approved but not released. The UFSAR documents the rack room's temperature range as 70 deg. F to 80 deg. F; however, Calculation No. P(B)-0954, titled

• Temperature rise in the Control Building during temporary loss of air conditioning" and Calculation No. 88-032-090GF, titled

• Station Blackout Transient Room Temperature Analysis for the Instrument Rack Room at MP3" documents that room temperature can be higher than 80 deg. F. The Tech. Spec.

documents that rack room's equipment can be declared operable as long as the rack room temperature is below 95 deg. F. The EGLS Qualification Test Report No. 2404.01 documents the equipment's minimum / max; mum test temperatures as 70 deg. F and 95 deg. F. however, if the Tech. Spec.'s rack room temperature limit of 95 deg. F is exceeded, the required action is to record the temperature and duration for EQ purposes. No minimum temperature alarm or required action is provided for the instrument rack room.

Corrective action requests ARs 97011501-01,02, & 03 and 97011973-01 are scheduled for completion after start-up.

Justification for scheduling the completion and closure of these action requests, associated with CR M3-97-1444, is based on a EGLS critical subcomponent operating temperature range analysis and critical subcomponent comparison, between the EGLS and similar equipment supplied by Westinghouse. The critical subcomponent operating temperature range analysis is based on the specified operating temperature range for each manufacturer's subcomponent inside the EGLS The comparasion is based on similarity of critical subcomponents in a piece of equipment supplied by Westinghouse thet was qualified with a greater minimum / maximum testing temperature range, as documented in test report WCAP-8687. None of this data wc 3  ;

! submitted with the review package. The following information is needed in rmnfirm nnernhility nf the FAI R-Printed S6/98 3:39:16 PM Page 1 of 3 d

N::rthe It Utilities ICAVP DR N3. DR-MP3-1088 Millstone Unit 3 Discrepancy Report

-EGLS critical subcomponent list and associated operating temperature range data,

-critical subcomponent list for the Westinghouse supplied equipment used in the EGLS comparison and qualification report WACP-8687.

Review Valid invalid Needed Date initiator: Dombrowski, Jim O O O 3/25/98 VT Lead: Ryan, Thomas J B D 0 3/25/98 VT Mgr: schopfer, Don K O O O 3/25/98 1Rc Chmn: singh, Anand K O O O 3/27/98 Date:

INVALID:

Date: 4/27/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1088, does not represent a discrepant condition. The following information is being provided as requested to confirm operability of the EGLS:

The following information is provided as requested per the DR.

1. EGLS critical subcomponent list and associated operating temperature range data:

OSubcomponento 00perating Temp. EReference0 Range 0 Lambda power 0-10 'C to 71 'C OVendor Manual supply LRS-54 OIM-427 Lambda power 0-10 'C to 71 *C OVendor Manual supply LRS-56 OIM-427 j l

Agastat control CO 'C to 60 *C OVendor Manual )

relays GP series OlM-427 Motorola MHTL 0-30 'C to 75 *C OVendor Manual Integrated Circuits OIM-427 MC660 Series Sprague Integrated 00 'C to 70 'C OVendor Circuits series OIM-427 ULN-2000A Motorola MDTL 00 'C to 75 *C OVendor Manual Integrated Circuits OlM-427

2. Critical subcomponent list for the Westinghouse supplied equipment used in the EGLS comparison and qualification report WCAP-8687:

Printed 5/6/96 3:3917 PM Page 2 of 3

Northsast Utilitiss ICAVP DR No. DR-MP3-1088 Millstone Unit 3 Discrepancy Report Westinghouse SSPS (Solid State Protection System) equipment was used as a similar equipment to EGLS. The critical subcomponent list is provided below:

! a. Motorola MHTL Integrated Circuits MC660 Series

b. Basler Electric Co. Power supply, part Nos. 90 73700101, 90 73800-101, 90 73900-101, 90 74000-101

c. Relays, Midtext Inc. part Nos.156-14T300 (120vac),156-14C300 (24vdc),156-14D200 (48vdc) d. Relays, Potter &

Bmmfield rotary type MDR Series 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-MP3-1088, does not represent a discrepant condition. The requested infonnation is being provided within the disposition. Significance Level criteria do not apply here as this is not a discrepant condition.

Attachment:

None Previously Identified by NU7 [Yes 4) No Non Discrepant Condition 70 Yes 4) No Resolution Pending70 ves + No Resolution Unresolved 70 ves @) No Review initiator: Caruso, A. Acceptable Not Acceptable Needed Date VT Lead: Ryan. Thornas J VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 4/27/98 st Comments: NU's response is unacceptable.

With the exception of the Motorola MHTL Intergrated Circuit Series MC600 Series component, the critical subcomponents in the EGLS equipment and the Westinghouse SSPS equipment are not identical; consequently, the asssessment that the minimum / maximum temperatures for the Westinghouse SSPS equipment as documented in the test report WCAP-8687 is applicable to the EGLS equipment is not valid. (Note: The WCAP-8687 test report was not provided as an attachment to the DR.)

The following information is needed to comfirm operability of the EGLS:

An EQ calculation / amended EQ report with engineering anaysis justifying that the EGLS can operate within the temperure limits that the Instrument Rack Room is subjected to during nomal /

abnormal conditions.

If operability of the EGLS cannot be comfirmed, NU is to state how they are meeting the !EEE 279 requirement that the an inoperable EGLS is statused in the Control Room.

Printed 5/6/98 3 39:17 PM Page 3 of 3