ML20247F773

Forwards forty-nine Listed Drs Identified During Review Activities for Independent Corrective Action Verification Program,Iaw Communications Protocol,PI-MP3-01

ML20247F773
Person / Time
Site:	Millstone
Issue date:	05/12/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9805200045
Download: ML20247F773 (195)

Text

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Sar ge tM Lundy c j

Don K. Schopfer Senior Vice President 312-269-6078 i

May 12,1998 l 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 Was'n ington, D.C. 20555 Enclosed are discrepancy reports (DRs) identified during our review activities for the ICAVP.

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

I have enclosed the following forty-nine (49) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0047 DR No. DR-MP3-0352 DR No. DR-MP3-0057 DR No. DR-MP3-0374 DR No. DR-MP3-0128 DR No. DR-MP3-0376 DR No. DR-MP3-0147 DR No. DR-MP3-0380 DR No. DR-MP3-0150 DR No. DR-MP3-0386 DR No. DR-MP3-0267 DR No. DR-MP3-0484 DR No. DR-MP3-0326 DR No. DR-MP3-0537 DR No. DR-MP3-0330 DR No. DR-MP3-0557 DR No. DR-MP3-0338 DR No. DR-MP3-0608 DR No. DR-MP3-0343 DR No. DR-MP3-0664 \

DR No. DR-MP3-0351 DR No. DR-MP3-0665 9805200045 980512 3 DR ADOCK 0500 '00 55 East Monroe Street = Chicago, IL 60603-5780 USA 312-269 2000

No .

United States Nuclear Regulatory Commission May 12,1998 Document Control Desk Project No. 9583-100 Page 2 DR No. DR-MP3-0693 DR No. DR-MP3-0966 DR No. DR-MP3-0703 k DR No. DR-MP3-0968 DR No. DR-MP3-0707 DR No. DR-MP3-1006 '

DR No. DR-MP3-0723 DR No. DR-MP3-1028 DR No. DR-MP3-0736 DR No. DR-MP3-1032 DR No. DR-MP3-0787 DR No. DR-MP3-1037 DR No. DR-MP3-0806 DR No. DR-MP3-1038 DR No. DR-MP3-0808 DR No. DR-MP3-1039 DR No. DR-MP3-0846 DR No. DR-MP3-1044 DR No. DR-MP3-0876 DR No. DR-MP3-1046 DR No. DR-MP3-0901 DR No. DR-MP3-1050 DR No. DR-MP3-0904 DR No. DR-MP3-1064 DR No. DR-MP3-0926 DR No. DR-MP3-1065 DR No. DR-MP3-0936 Please direct any questions to me at (312) 269-6078.

Yours very truly,

%I &

D. K. Sc opfer l Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:

E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/1) NU m:\icavpbwh98'or0512-aAw

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ICAVP DR N2. DR-MP3-0047 N:rthext Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design i

Potential Operability issue Discipline: Structural Design O Yes Discrepancy Type: Calculation (9) No systerrvProcess: SWP NRC Significance level: 4 Date faxed to NU:

Date Published: 8/28/97 Discrepancy: Pipe support calculation discrepancy

Description:

We have reviewed the Pipe Support Calculation Nos. NP(F)-

Z19A-159, Rev. 7

& NP(F)-Z19A-195, Rev. 8. Based upon this review we have noted the following discrepancy.

l These calculations do not address the welds shown on drawing BZ-19A-78, Rev.3, between items 5 & 6, and between item 6 and the strap plate.

Review Valid invalid Needed Date initiator: Patel, A. G O O 8/2a/97 VT Lead: Nort, Anthony A B O O 8/20/97 VT Mgr: schopfer, Den K G O O s/22/97 IRC Chmn: Singh, Anand K B O O 8/22/97 Date:

INVAUD:

Date: 5/8/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0047, does not represent a discrep t.it condition. The weld for items 5 to 6, item 6 to the strap plate, as well as item 5 to the embedded plate are all qualified on page 26 of calculation 12179-NP(F)-Z19A 159 utilizing the worst case bounding dimensions and loads.

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

SECOND RESPONSE:

NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0047, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concerns and meets section 1.3.2.e of U3 Pl 20 deferral criteria.

Calculation 12179-NP(F)-Z19A-159 will be revised to state that the welds qualified envelope the worst case conditions using the weakest weld profile.CR M3-98-2352 was closed to Bin CR M3-98-0138. The corrective actions of CR M3-98-0138 will correct the subject calculation post startup.There is no affect on License or Design Basis.

Previously identified by NU7 O Yes @ No Non Discrepant Cond6 tion?O Yes @ No Page 1 of 2 Printed 5/12/98 2:12:05 PM

ICAVP DR N:. DR-MP3-0047 N:rtherct Utilities Millstone Unit 3 Discrepancy Report Resolution Pending?O Yes (G) No Recolution Unresolved?O Yes @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Ctwnn: sngh, Anand K Date: 5/8/98 sL connents: In response to NU's disposition of the referenced discrepancy, S&L's position is further clarified as follows:

On page No. 26, the calculation has been performed for 1/4" Parallel welds between the following items as shown in the drawing 12179-BZ-19A-42-3 ( sht.1 of 3).

a) TS 6x4 to 1" thick plate.

b) 1" thick plate to embedment plate.

c) Plate 3/4"x 5 3/4"x 8" to TS 6x4 The above items do not include the weld calculations for the items as mentioned in our discrepancy report i.e. between item No's 6 ( TS 4x4x.25) & 5 ( TS 6x4x.25) and betraen item No. 6 & strap plate. These are 3/16" 4-sided and 1/4" all around welds respectively and therefore are different from the ones qualified on page No. 26.

While we agree with NU's assessment that these welds are not critical and could be bounded by the calc. on page #26 or by the

PREPS" qualified weld for member #4, joint #4 (See calculation page # 25), a statement documenting this engineering judgment must be included in the calculation.

SECOND RESPONSE:

S & L concurs that weld stresses are not critical for the design and may be added after the plant re-start.

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Page 2 of 2 Printed 5/12/96 2:12:09 PM

Ncrth;att Utilities ICAVP DR N2. DR-MP3-0057 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: structural Design Discrepancy Type: Caiculaton Ow I System / Process: sWP g j NRC Significance level: 4 Date faxed to NU:

Date Published: 9/22/97 Discrepancy: Liner Plate Pad calculation discrepancy Descript6on: We have reviewed Liner Plate Pad Calculation # 12179-S50-v1.113,R1. Based on this review, we have noted the following discrepancy.

1. This calculation references Calc. # SEO-V1.088,RO for the liner pad qualification. The FEM model used in Calc. #SEO-V1.088, page 14, conservatively specifies the attachment location at the anchor point which will produce maximum anchor load. However, this assumption would not produce maximum stress in the plate.

An evaluation of the maximum plate stress, using attachment location in the middle of the plate span, should be made to confirm that the plate stress is not critical.

Review i Valid inval6d Date Needed initiator: Patal. A. 8 O O 8/16/S7 VT Lead: Neri, Anthony A O O O S/17/87 VT Mgr: schopfer, Don K B O O S/17/S7 IRC Chmn: singh, Anand K G O O S/17/S7 Date:

INVALID:

Date: 5/8/98 RESOLUTION NU has concluded that Discrepancy Report, DR-MP3-0057, does not represent a discrepant condition. The criculatien preparer and reviewer had determined that the insert pad qualification is govemed by anchor loading and therefore modeled the attachment directly over a single stud as discussed on page 14 j of the calculation. Plate stress is not a critical parameter as discussed in the Master Calculation. The evaluation of maximum plate stress is generically addressed in calculation 12179-NS(B)-

054 Rev.1 "ContainmeM Liner Insert Plate Qualification - Master Calculation" which is Reference 1 in calculation 12179-SEO-

< V1.088.

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

SECOND RESPONSE:

NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0057, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of Printed S/12/98 2:12:30 PM Page 1 of 2

ICAVP DR No. DR-MP3-0067 N:rthea:t Utilities Miiistone unit 3 Discrepancy Report U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria.

Calculation 12179-SEO-V1.088 will be revised to state that the insert pad qualification is govemed by anchor loading and to provide justification as to why it is acceptable to compare a 4x4 TS from the master ca'culation to a 2x2 TS in the subject calculation.CR M3-98-2352 was closed to Bin CR M3-98-0138.

The corrective actions of CR M3-98-0138 will correct the subject calculation post startup.There is no affect on License or Design Basis.

Previously identified by Nu? O Yes (*) No Non Discrepant Condition?O Yes (c') No Resolution Pending?O Yes @ No Resolution Unresolved?O Ye. @ No Review Acceptable Not Acceptable Needed Date initistor: Klaic, N 5'8'S8 VT Lead: Nerl, Anthony A O O O VT Mor: schopfer. Don K B O O S11/S8 IRc Chmn: singh, Anand K O O O s/12/98 O O O Date: 5/8/98 SL Comments: NU disposition states that the preparer and reviewer had determined that the insert plate qualification is govemed by anchor loading and therefore modeled the attachment directly over a single stud.

This determination (engineering judgment) is not clearly

! documented in the Calc. #12179-SEO-V1.088, page 14. It is recommended that the NU disposition explanation with regards to the plate stress evaluation in the Master Calculation be included on page 14 of the subject calculation for documentation.

Also, Master Calculation # 12179-NS(B)-054, Rev.1, page 126 l shows that the attachment is TS 4x4 where as the subject calculation uses TS 2x2. The use of larger attachment size would produce smaller plate stress.This item needs further evaluation by NU for proper engineering disposition.

l S&L agrees with NU conclusion that the plate will not be overstres ,ed. However, the engineering judgment used for this determination needs to be documented.

SECOND RESPONSE:

S & L concurs that the insert plate qualification is not a re-start issue.

I Page 2 of 2 Printed 5/12/98 2:12:41 PM

ICAVP DR No. DR-MP3-0128 Northeast Utilitins Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Potential Operability issue Discipline: Mechanical Design Om Discrepancy Type: Corrective Action g System / Process: DGX l NRC Signifiunce level: 4 Date faxed to NU:

Date Published: 9/14a97 Discrepancy: Incomplete Corrective Action Package

Description:

1. ACR M3-96-0361 evaluated pitting found in the vicinity of a Monet/ Copper-Nickeljoint. The evaluation of the condition was performed by the Materials Testing Laboratory. The laboratory issued appropriate recommendations, but it is not clear from the ACR package whether these recommendat;ons are being implemented, whether each of the similar types of joints has been electrolytically isolated, or whether coating on other joints has been or is being monitored.

2. There is no evidence in the package that a safety evaluation screening or safety evaluation was performed to add the epoxy coating as required by paragraph 6.1.2 of NGP 3.12, revision 9, and NGP 8.06, revision 1.

3. There are a number of handwrnten questions (some unanswered) and comments in the ACR package (see pages titled " Corrective Action Review of Completed Assignments Prior to RP4 rev. 4 efed. date"). Condition Report packages are required to be Quality Assurance (QA) Records by pparagraph 1.17.1 of RP 4, revision 4, and by Technical Specifications 6.10.2.b and 6.10.3.1. Paragraph 3.2.1 of ANSI N45.2.9-1974 states that QA records are to be legible anc' completely filled out. ANSI N45.2.9-1974 is endorsed by Regulatory Guide 1.88 dated November,1976 which is a commitment of the Northeast Utilities' Quality Assurance Program Topical Report.

Review Valid invalid Needed Date initiator: Sheppard. R. P. O O O 8/29/97 VT Lead: Ryan, Thomas J B O O 9<2/97 VT Mgr: schopfer, Don K O O O S'a'S7 BRC Chrnn: singh, Anand K O O O S/S'S7 Date:

INVALID:

a Date: 5/11/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in item 1 of Discrepancy Report, DR-MP3-0128, does not represent a discrepant condition.

1. The concem that initiated this ACR is described as:" Pitting was found on the ID of the Monel pipe". The pipe in question is a 10" service water pipe. The corrective action plan (CAP) for the subject ACR does not include nor does it need to include for Pnnted 5/12/98 2:13:11 PM Page 1 of 5

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ICAVP DR ND. DR-MP3-0128 l I

Narthert Utilitie3 l Millstone Unit 3 Discrepancy Report the condition described the implementation of any of the recommendations provided in Materials Testing Laboratory l

Report Number 13-96-028. The approved corrective action plan I as documented on page 3 of 4 which pertains to the Lab Report l states: " Perform an investigation into the effects of Monel ana

Cu-Ni piping interfaces to evaluate these type of bimetal repairs in the future" and " Provide a report to the System Engineer".

The corrective action plan only requires the report. It does not require the implementation of the recommendations from the report. The report recommendations which are, to take wall l thickness measurements upstream of Monel to copper-nickel welds and redesign the piping in that area are not warranted or l appropriate for the minor pitting of the Monel stub ends described in this ACR. It is noted however that !bese recommendations are considered as part of a review of all Cu- 1 I

Ni/Monel interfaces on unit 3. This review is being performed per Action Request 97013654-03 titled, determine the need for i trending or replacement of service water piping. l l

Significance Level criteria does not apply to item 1 as this is not i a discrepant condition. l NU has concluded that the issue reported in item 2 of Discrepancy Report, DR-MP3-0128, has identified a condition not previously discovered by NU which requires correctio 1.

l l 2. Contrary to y' ur finding, there is evidence in the ACR package that a safety evaluation was performed to add the epoxy coating. The corrective action plan for the subject ACR provides reference to Action Request 96009509. This action request provides reference to NCR 396-309 which provides reference to D3 sign Change Notice DM3-S-74196. The technical justification delineated on the DCN cover sheet in block 8 refers to PDCR MP3-95-058. The safety evaluation for this l

PDCR adequately addresses the application of ARCOR coating to service water piping. It does not however specifically address l

coating to the pipe spool identified in the subject ACR and therefore, the safety evaluation will be 'r evised or a new safety evaluation will be written to specifically addred the ARCOR coating of the spool in question. Condition Report (CR) M3 3428 has been written to provide the necessary corrective l

actions to resolve this issue. No changes in the field are required.

NU has concluded that the issue reported in item 3 of l Discrepancy Report, DR-MP3-0128, does not represent a discrepant condition.

I 3. The forms referred to are work sheets that the closure review group use to provide a higher level of confidence that corrective actions completed prior to RP4, revision 4 resulted in the corrective action being completed as assigned or the corrective action plan being modified accordingly, it provided useful information and as such is a valuable tool.

This activity was not required by procedure but provides useful Page 2 of 5 Printed 5/12/98 2:13:14 PM

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ICAVP DR N2. DR-MP3-0128 N:rthe=t Utilities uilistone Unit 3 Discrepancy Report information and as such is left in the CR package as part of the record. This is similar to other information left in the package which provides useful information but is not in and of itself a QA record.

Significance Level criteria does not apply to item 3 as this is not -

a discrepant condition.

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Conclusion:

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NU has concluded that the issue reported in item 1 of Discrepancy Report, DR-MP3-0128, does not represent a discrepant condition.

1. The investigation into the subject ACR concluded that the ACR concem was not valid and did not warrant the implementation of the recommendations documented in the report. These recommendations however, are considered as part of a review of all Cu-Ni/Monelinterfaces for the Service Water System piping en unit 3.

Significance Level criteria does not apply to item 1 as this is not a discrepant condition. l NU has concluded that the issue reported in item 2 of i Discrepancy Report, DR-MP3-0128, has identified a condition not previously discovered by NU which requires correction.

2. The Technical Justification for adding the epoxy coating to the subject service water piping is provided in PDCR MP3 058. The safety evaluation for this PDCR addresses the application of ARCOR coating to service water piping. It does not specifically address the coating to the pipe spool identified in the subject ACR and therefore the safety evaluation will be revised or a new safety evaluation will be written to specifically address the ARCOR coating of the spoolin question. Condition Report (CR) M3-97-3428 has been written to provide the necessary corrective actions to resolve this issue. No changes in the field are anticipated as a result of the corrective action for l this CR.

NU has concluded that the issue reported in item 3 of Discrepancy Report, DR-MP3-0128, does not represent a discrepant condition.

3. The forms referred to are work sheets that the closure review group use to provide a higher level of confidence that corrective actions completed prior to RP4, revision 4 resulted in the i

corrective action being completed as assigned or the corrective l action plan being modified accordingly. This activity was not required by procedure but provides useful information and as such is left in the CR package as part of the record. This is similar to other information left in the package which provides useful information but is not in and of itself a QA record.

Printed S/12/96 2:13.15 PM Page 3 of 5

North:att Utilitiss ICAVP DR No. DR-MP3-0128 Millstone Unit 3 Discrepancy Report Significance Level criteria does not apply to item 3 as this is not a discrepant condition.

NU's 2nd Response:

Disposition:

NU has concluded that the issue reported in DR-MP3-00128 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. NU considers the new items 2 and 3 to be non discrepant conditions.

(item 2) We have established a program to inspect all Cu Ni

/Monel interfaces in the service water system using UT exam on an ongoing basis. A review of the entire system was performed and suspect locations identified. These were grouped by area or other similarity such as train, size, and/or location into 4 groups which are addressed by the attached Action Requests (AR's) 98003954 due 6/98,98003957 due 9/98,98003958 due 12/98 and 98003959 due 3/99.In each case the System Engineer will review the data and establish the appropriate next inspection date. These actions are independent of the 8913 program.

(item 3) The forms referred to are work sheets that the closure review group used to provide a higher level of confidence that corrective actions completed prior to RP4, revision 4 resulted in the corrective action being completed as assigned or the corrective action plan being modified accordingly. This one t;me interim process is no longer exercised. We know of no specific requirement violated and find no value added in the removal of these one time historical documents from Nuclear Document Services.

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

Conclusion:

NU has concluded that the issue reported in DR-MP3-00128 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. NU considers the new items 2 and 3 to be non discrepant conditions. For item 2, we have established a program to inspect all Cu Ni /Monel interfaces in the service water system using UT exam on an ongoing basis which are addressed by the attached Action Requests (AR's) 98003954 due 6/98,98003957 due 9/98,98003958 due 12/98 and 98003959 due 3/99. These actions are independent of the 8913 program.For item 3, the forms referred to were used to provide a higher level of confidence that corrective actions completed prior to RP4, revision 4 resulted in the corrective action being cornpleted appropriately. This one time interim process is no longer exercised. We know of no specific requirement violated and find no value added in the removal of these one time historical documents from Nuclear Document Services.

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

Printed Sh2S8 2:13:16 PM Page 4 of 5

ICAVP DR N2. DR-MP3-0128 N rtheast Utilities Millstone Unit 3 Discrepancy Report )

Attachments:

AR's 98003954,98003957,98003958 and 98003959 Previously identined by NU7 O Yes (9) No Non Discrepant Condition?O Yes (ej No Resolution Pending?O ve. (*) No Resolution Unresolved?O yes (s)No l Review initiator: sheppard. R. P.

VT Lead: Ryan, Thomas J O O O 5/11/98 g

VT Mgr: Schopfer, Don K g IRC Chnm: Singh, Anand K O

Date: 5/11/98 l SL Comments: Review of NU's 1st Response:

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1. The resolution of part 2 of the discrepancy is acceptable.

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2. The response states that a review of all Cu-Ni/Monel interfaces on unit 3 is being performed per Action Request I

97013654-03. Please elaborate on the monitoring being proposed for galvanic and pitting corrosion in the Service Water l system and how this will relate to the monitoring being performed ,

by the Geineric Letter 89-13 program.

3. It is recognized that the corrective action review sheets serve a valuable purpose. If portions of the final corrective action package are not considered to be QA records, those portions 1 I should be identified as such or those portions should not be forwarded to Nuclear Document Services for storage as QA records.

Review of NU's 2nd Response:

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1. Items 2 and 3 originally reported in this Discrepancy Report are not discrepancies. A safety evaluation was performed to add the epoxy coating and the handwritten questions were a temporary device used to ensure that corrective actions completed before the current NU corrective action was instituted were appropriately documented.

2. Item 1 originally reported in this Discrepancy Report is being resolved by the ongoing ultrasonic examination program instituted by Action Requests 98003954,98003957,98003958 and 98003959 which were initiated 3/2/98.

l Page 5 of 5 Printed 5/12/96 2:13:17 PM

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N::rthert Utilities ICAVP DR No. DR-MP3-0147 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue f Diu:ipline: structural Design Discrepancy Type: Calculation O Yes 9 No System / Process: N/A NRC Significance level: NA Date Faxed to NU:

Date Published: 9/19/97 Discrepancy: Seismic excitation of support steel members

Description:

Criteria Document no. NETM-45,Rev.1,titledfPipe Support Design Criteria"does not address the self weigh excitation of auxiliary steel support members, i l Section 3.2.1 of the FSAR requires that all Category l Structures i be designed to remain functional during a safe shutdown earthquake (SSE) and to be w; thin the elastic limit for a vibratory motion at 50 percent of the SSE,which

! is called the operating basis earthquake (OBE).

Review Valid invalid Needed Date  !

Initiator: Klaic. N O O O S'11/S7 VT Lead: Neri, Anthony A 8 O O S/11/S7 VT Mgr: schopfer, Don K B O O 9/12/97 S' 2/97 IRC Chmn: singh, Anand K O O O l

Date:

l INVALID:

Date: 5/11/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0147, does not represent a discrepant condition. The l design criteria for pipe supports do not require that the mass of J the support structure itself be considered when qualifying the j support for seismic loads. FSAR Section 3.2.1 refers to QA l

Category I structures, systems and components. Piping supports l

are QA Category I commodities which are designed to l 4

l accommodate seismic loads developed in the piping system.

However, self weight excitation of support members is not -

addressed in the design criteria and is not considered to be in the I I

l licensing / design basis for Millstone Unit 3. This is appropriate since the loads imposed on a pipe support are typically much greater than loads which would be attributed to the seismic response of the support structure (since support structures are ~

usually stiff and would respond in the rigid range), resulting in insignificant impact on the support design. Note however, that in a few unique cases, support structure calculations do consider self weight excitation (RSS piping supports with long cantilevers in ESF building), but only on an individual basis where the analyst utilized sound engineering judgment to address the unique circumstance.

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

SECOND RESPONSE Printed 5/12/98 2:13:45 PM Page 1 of 3

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N:rthent Utilities ICAVP DR No. DR-MP3-0147

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l Millstone unit 3 Discrepancy Report NU has concluded that the issue reported in Discrepancy Report DR, DR-MP3-0147, does not represent a discrepant condition.As l previously staied, the design criteria for pipe supports do not require that the mass of the support structure itself be considered when qualifying the support for seismic loads. FSAR Section l 3.2.1 refers to QA Categc4y I structures, systems and components. Piping supports are QA Category I commodities which are designed to accommodate seismic loads developed in the piping system. However, self weight excitation of support members is not addressed in the design criteria and is not considered to be in the licensing / design basis for Millstone Unit

3. This is appropriate since the loads imposed on a pipe support are typically much greater than loads which would be attributed to the seismic response of the support structure (since support structures are usually stiff and would respond in the rigid range),

resulting in insignificant impact on the support design.

Note however, that in a few unique cases, support structure l calculations do consider self weight excitation (RSS piping supports with long cantilevers in ESF building), but only on an individual basis where the analyst utilized sound engineering l Judgment to address the unique circumstance.

Previously identihed by Nu? (_) ves @ No Non Discrepant Condition?@ ve. ( ) No Resolution Pending?O ve. @ No Re.oiution unr..oiv.d?O v.. @ u.

Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A l VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 5/11/98 sL Comments: S&L does not accept the response provided by NU for the following reasons:

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- FSAR is a licensing / Design basis document that requires that

! ALL Category l Structures be designed to sustain OBE and SSE earthquake.

- The impact of seismic self-weight excitation could become a factor if the support design does not provide sufficient margin from the applied loads.Although the applied support loads are typically greater than the loads from the seismic self-weight excitation, the contribution of the smaller loads can still result in l the overall stress level that exceeds the allowable one where the design margin is insufficient.

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- There is no specific criteria that establishes the fact that the supports are to be designed to respond in the rigid range. Based on the inspection of the support configurations, the statement that the support structures are "usually stiff" cannot be verified.

SECOND RESPONSE Based on the results of the discussions held with NRC on 5/6/98, Printed 5/12/96 2:13:49 PM Page 2 of 3

l Northeast Utilities ICAVP DR No. DR-MP3-0147 Millstone Unit 3 Discrepancy Report NU's response to the issue of seismic self-weight excitation was clarified and deemed acceptable.

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Printed 5f12/98 2.13:50 PM Page 3 of 3 l

N rtheast Utilitie3 ICAVP DR No. DR-MP3-0150 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potsatial Operability issue Discipline: Structural Design Discrepancy Type: Caicuestion Om system / Process: N/A g

P'RC significance level: NA Date faxed to NU:

Date Published: 9/22/97 Discrepancy: Lower Pipe Support Stiffness Review and inspection Discrepancy--

Descripuon: Document EMD-80-2, dated March 5,1980, contains provisions and criteria for the support stiffness values to be used in the pipe stress analysis. In order to ensure consistency between the actual support stiffness and assumptions used in the stress analysis, Section 3.6 of the aforementioned report requires the review and inspection of pipe support configurations for cases where the support stiffness may be substantially reduced.

A sample review of the support configurations identified instances where the support stiffness is substantially lower than the one used in pipe stress analysis. However, for these supports, the review and inspection of pipe support configurations required by EMD-80-3 is not documented in the calculations. Thus, it could not be verified whether or not the required review was performed for the following supports:

Calculation no. NP(F)-Z79B-021,Rev.6, dated 07/25/85 ; Drawing no. BZ-79R-18 Stiffness used in pipe stress analysis: k = 1000 k/in

( From Stress Report no. NP(B)-X 7920,Rev.3,CCN 7, dated:

8/27/96).

Actual (calculated) support stiffness ka = 395 k/in < 1000 k/in.

Calculation no. NP(F)-Z79R-753-H002,Rev.1, dated 11/27/96 ;

Drawing no. BZ-79R-53-1 Stiffness used in pipe stress analysis: k = 200 k/in (From Stress Report no. NP(F)-961-XD,Rev.2).

Actual (calculated) support stiffness ka = 18.7 k/in < 200 Ir/in.

Review Valid invalid Needed Date initiator: Klaic, N 8 O O S' S'S7 VT Lead: Nerl, Anthony A B C O S' S'S7 VT Mgr: schopfer, Don K Q O O S'16'S7 IRC Chmn: singh, Anand K B O O S'27'S7 Date:

INVALID:

Date: 5/11/98 REsOLUTK)N: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0150, does not represent a discrepant condition. As part of the design and design review process for pipe supports, engineers comply with the Technical Guidelines provided in Engineering Mechanics Division (EMD) document 80-2.

Paragraph 3.6 of EMD 80-2 directs the Responsible Engineer to ensure that reasonable support functions are provided by the Pnnted 5/12/98 2:1433 PM Page 1 of 4 l

w Northeast Utilities ICAVP DR No. DR-MP3-0150 Millstone Unit 3 Discrepancy Report I

support design. The minimum requirement to show adherence to this EMD is documented with the signature of the preparer and I the reviewers on the support calculation cover sheet. In l addition, following the support design and installation, a Stress Reconcilianon Report was prepared for pipe stress calculations.

The purpose of this report is to reconcile the as-built piping location and the as-built pipe supports with the as-analyzed stress calculation. Question 7.f. of this report requires an {

y evaluation of " Support stiffness *. As for the supports in \

geestion, verification of support stiffness is provided in Calculation Change Notice (CCN) 3 for pipa stress calculation NP(B)-X7920, revision 3, the response to stress reconciliation report question 7.f states: "The input stiffness based on EMD-80-02 is judged adequate per walkdown observation".

Calculation Change Notice 1 for pipe stress calculation NP(F)-

961-XD, revision 2, the " Description of Change" states:

"Walkdown of the piping shown on the isometric drawing indicates that the installed pipe support structural assemblies are representative of the stiffness values utilized in the pipe stress calculation".

Significance Level criteria do not apply here as this is not a (

discrepant condition. \

SECOND RESPONSE NU has concluded that Discrepancy Report DR-MP3-0150, does not represent a discrepant condition. As part of the design and design review process for pipe supports, engineers comply with the Technical Guidelines provided in Engineering Mechanics Division (EMD) document 80-2. Paragraph 3.6 of EMD 80-2 directs the Responsible Engineer to ensure that reasonable support furctions are provided by the support design. The minimum requirement to show adherence to this EMD is documented with the sigrtature of the preparer and the reviewers on the support calculation cover sheet. In addition, following the support design and installation, a Stress Reconciliation Report was prepared for pipe stress calculations. The purpose ot'this report is to raconcile the as-built piping location and the as-built pipe supports with the as-analyzed stress calculation. Question 7.f. of this report requires an evaluation of

• Support stiffness". As for the supports in question, verification of support stiffness is provided in Calculation Change Notice (CCN) 3 for pipe stress calculation NP(B)-X7920, revision 3, the response to stress reconciliation report question 7.f states: "The input stiffness based on EMD 80-2 is judged adequate per walkdown observation *. Calculation Change Notice 1 for pipe stress calculation NP(F)-961-XD, revision 2, the

• Description of Change

• states: *Walkdown of the piping shown on the isometric drawing indicates that the installed pipe support structural assemblies are representative of the stiffness values utilized in the pipe stress calculation". This exercise is intended to be a

" sanity check" by the analyst to ensure that, there are no unreasonable support stiffnesses which might significantly affect the pipina analysis results. and that, in saareaate the support Pnnted 5/12/98 2:14.36 PM Page 2 of 4

1 ICAVP DR No. DR-MP3-0150 N:rthent Utilitisa Millstone Unit 3 Discrepancy Report l

i stiffnesses are representative of how the piping system was analyzed. It is not intended to represent a stiffness calculation.

l Therefore, the support stiffness values reported in the DR are l

l not considered unusual and in fact are to be expected.

As discussed in EMD 80-2 and as evidenced in the above cases, i

no specific pipe support deflection criteria need to be satisfied,

! and no specific requirement for calculating the transnational or rotational stiffness or deflection exists within the design criteria.

Correlation of actual stiffness to estimated (i.e. modeled) stiffness is not required. The design criteria specifies that one of three methods be utilized for modeling support stiffness, Generic, Calculated, or Judgmental. Typically the Generic stiffness method is utilized which requires that support stiffness be modeled consistently according te oredefined values. The criteria documents acknowledge tha; Aculated stiffness values generally will be less than the generic values specified in EMD

' 80-2. However, thic is discussed in EMTR-616 and justified based on the following factors. If supports are modeled more ,

I stiff than actual, this generally results in exaggerated pipe stress values and support loads from thermal growth and differential anchor movements (i.e. provides conservative results). For ,

seismic response, the input assumptions for seismic modeling are conservative such that use of generic stiffness is justified, and provides a consistent approach for piping analysis.The l stiffness criteria for pipe supports provided in EMD 80-2 and EMTR-616 have been applied consistently throughout the period from the original design of Millstone 3 to more recent piping i reanalyses. The design criteria for Millstone 3 were reviewed in detail and approved by NRC during the original licensing review.

The criteria were specified by SWEC and typical of criteria utilized on SWEC projects similar to Millstone which were also reviewed and approved by NRC, and found to be appropriate and acceptable. Therefore, based on both technical and licer: sing bases, the existing support stiffness criteria are acceptable. Significance Level criteria do not apply here as this is not a discrepant condition.

Previously identif:ed by Nu? O vos (8) No Non Discrepent Condition ~3) Yes O No Resolution Pending70 ve. @ No Re.oiution une iv.d70 v.. @ No Review initiator: Klaic, N VT Lead: Nort, Anthony A VT Mgr: schopfer. Don K IRC Chmn: Singh, Anand K Date: $/11/g8 st comrnents: Reference calculations provided in NU's response document the adequacy of the stiffness based on the "walkdown observations".However,two examples provided in the DR l demonstrate that the actual support stiffness is considerably lower i

than those used in the pipe stress analysis.

Therefore, walkdown observations cannot be accepted as a valid stiffness evaluation.

SECOND RESPONSE:

Page 3 of 4 Pnnted 5/12/96 2:14:37 PM

Nsrtheart Utilitizo ICAVP DR No. DR-MP3-0150 Millstone Unit 3 Discrepancy Report Based on the results of the discussions held with NRC on 5/6/98, NU's response to the issue of stiffness / deflection criteria was clarified and deemed acceptable.

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N:rthertt Utilities ICAVP DR Ns. DR-MP3-0267 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTK)N ACCEPTED PotentialOperability issue Discipline: structural Desgn Discrepancy Type: Calculation Om g

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

Date Published: 10/10/97 Discrepancy: Design Criteria Discrepancy

Description:

Criteria Document no. NETM-45,Rev.1,titledfPipe Support Design Criteria *does not address the impact of thermal stresses on the pipe support auxiliary steel.

Thermal growth is significant in all cases where support configuration includes auxiliary steel with rigid support points at both ends that preclude movement and relaxation of thermal stresses.

Review Valid invalid Needed Date Iniuator: Klaic, N B O O S'18/97 VT Lead: Neri, Anthony A B O O 9/23/97 VT Mgt: Schopfer, Don K B O O S'30/S7 IRc Chmn: singh, Anand K B O O 10/2/97 Date:

INVALID:

Date: 5/11/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0267, does not represent a discrepant condition. Thermal expansion of support members is not addressed in the design criteria and is not considered to be within the licensing / design basis for Millstone Unit 3. This is appropriate since pipe support frames are typically free to expand thermally such that intemal stresses and resultant connection loads are minimal. Piping supports do not typically span large distances between concrete structures which would respond more slowly to ambient temperature changes.

Therefore, pipe supports are generally not susceptible to constrained thermal expansion which would potentially result in sigriificant intemal thermal stresses.

SECOND RESPONSE Regarding the S&L comment subsequent to NU's initial response that the design criteria should either address this issue generically or the support design should include provisions for slotted hole type bolted connections to accommodate thermal expansion of the auxiliary steel members, NU offers the l following justification for addressing the issue generically.

l Constrained thermal expansion will result in intemal stresses and reaction loads. However, they are not expected to be significant due to the fact that member lengths are not excessive and differential displacements are expected to be small.

Additionally, the loads due to constrained thermal expansion are i

self-relieving under accident conditions, and therefore, will not Printed 5/12/96 2:15:08 PM Page 1 of 3

i ICAVP DR Ns. DR-MP3-0267 l N rthext Utilities Millstone Unit 3 Discrepancy Report l I

affect the load carrying capability of the support structure.

Furthermore, the design criteria does not require consideration of )

intemal thermal expansion for support structures. The design criteria for Millstone 3 were reviewed in detail and approved by NRC during the Disposition Continuation: original licensing review. The criteria were specified by SWEC and typical of criteria utilized on SWEC projects similar to Millstone 3 which were also reviewed and approved by NRC, and found to be appropriate and acceptable.As an additional consideration, note that this issue is similar to issues identified in DR's 147 and 150 in that they all discuss design criteria for piping and pipe supports. The criteria applied to piping and pipe supports at Millstone 3 result in a very conservative design basis. The stress allowable values for structural steel members, component standard support elements, and welds are very conservative.

The allowable loads and interaction equations for anchor bolts are very conservative. The inputs for seismic and occasional load cases are derived in a conservative fashion. Load combinations are specified in conservative terms. The ASME Code requirements for pipe stress analysis are very conservative. These and other conservative design attributes provide sufficient design margins to accommodate the issues raised in the referenced DR's, such that the as-designed piping and pipe supports are acceptable. This discussion supports the argument that when viewed in total as a conservative design philosophy, the criteria applied to piping and pipe supports at Millstone 3 result in adequate design margins. Significance Level criteria do not apply here as this is not a discrepant condition. )

Previously klentified by NU7 O Yes it) No Non D6.crepant CondiHon?@) Yes O No Resoiution Pending?O ve. @ No Re.oiution unre.oived?O ve. @ No Review initiator: Klaic, N O O mm ,

VT Lead: Nort, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: $/11/g8 sL Conwnents: S & L cannot accept the statement that pipe support frames are l

• typically free to expand thermally such that intemal stresses and the resultant connection loads are minimal".

Review of the support configurations identified several cases with rigid welded connections on both ends of the auxiliary steel members. This type of the configuration does not allow for the expansion due to thermal effects and will result in accumulation of high stresses in some instances. Therefore, the design criteria should either address this issue generically or support design should include provisions for the slotted hole type bolted connection at least at one end of the auxiliary member spanning between two fixed (rigid) structures to allow for the movement and release of thermal stresses.

SECOND RESPONSE:

1 Based on the results of the discussions held with NRC on 5/6/98, Page 2 of 3 Printed 5/12/98 2:15:11 PM

ICAVP DR No. DR-MP3-0267 Narthrst Utiliti:a Millstone Unit 3 Discrepancy Report NU's response to the issue of thermal expansion of support members was clarified and deemed acceptable.

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lCAVP DR No. DR-MP3-0326 l N:rthert Utilitie3 l Miiistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue i Discipline: Mechanical Design Q y,,

Discrepancy Type: calculation 9 No l System / Process: Oss NRC Significance level: 4 Date faxed to NU:

Date Published: 10/2397

~

Discrep.ncy: Calculatiori P(R)-931 - Basis for Result

Description:

The summary of results indicates the summer heat gain by the RWST Coolers is 351 Blu/hr. The document does not provide the calculation for this number nor does it provide a reference for the number. The value cannot be verified as a correct input to this calculation.

Review Valid invalid Needed Date initiator: Langel, D. @ O O 1o/10/97 o' o/97 VT Lead: Neri, Anthony A B O O O O 10' 3/87 VT Mgr: schopfer, Don K 8 IRC Chmn: singh, Anand K 8 0 0 iorie,s7 Date: 10/9/97

{

INVALID:

Date: 5/11/98 I RESOLUTION: Disposition:

NU has concluded that Discrepancy Report DR-MP3-00326 does not represent a discrepant condition. Although the details are not included in calculation P(R)-931, the stated results of 351 Blu/Hr can be reasonably repeated using the inputs to the calculation and the heat exchanger dimensions as shown on drawing 2214.603-056-001F, based on the K factor provided, calculated for two inches of insulation.

The value of 351 Btu /Hr shown in the calculation was probably included to provide assurance that the summer heat gain would not have an impact on the system performance. The value is insignificant as a portion of the overall capacity of the coolers which are sized to remove 6,252,000 Blu/Hr with the RWST at a maximum of 110 'F and 289,200 Btu /Hr. with the RWST at a minimum of 48'F.

The value stated in the calculation is therefore insignificant, since the heat transfer could t,e increased by a factor of 10 and not be great enough to affect system operation.

No system failure can derive from the correctness or incorrectness of the referenced heat transfer value.

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

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Conclusion:

Page 1 of 3 Printed S/12/96 2:15.55 PM

Nrrthea;t Utilities ICAVP DR N2. DR-MP3-0326 l

Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-00326 does not represent a discrepant condition. The value is insignificant as a portion of the overall capacity of the coolers, and although details common in current standards are lacking, the stated results of 351 Blu/Hr can be reasonably repeated using the inputs provided in the calculation. Significance level criteria do l not apply as this is not a discrepant condition.

Disposition to S&L Comment:

NU has concluded that Discrepancy Report, DR-MP3-0326, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. Condition Report M3-98-2352 will be closed out to Bin CR M3-98-0138.

The issue identified in DR-MP3-0326 is addressed as follows:

Bin CR M3-98-0138 corrective actions will correct the RWST Coolers summer heat gain value in calculation P(R)-931 as identified in DR-MP3-0326 post startup.

Conclusion to S&L Comment:

NU has concluded that Discrepancy Report, DR-MP3-0326, 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 attechment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. Condition Report M3-98-2352 will be closed out to Bin CR M3-98-0138.

The issue identified in DR-MP3-0326 !s addressed as follows:

Bin CR M3-98-0138 corrective actions will correct the RWST Coolers summer heat gain value in calculation P(R)-931 as identified in DR-MP3-0326 post startup.

Previously identified by NU? O Yes @ No Non Discrepant Condition?O yes (9) No Resolution Pending?O ve. @ No Resolution unresolved?O ve. @ No Review initiator: Langel, D.

VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K IRc Chrnn: singh, Anand K l Date: 5/11/98 ,

sL comments: Using the calculation methodology with the inputs as described, l the result is ten times the value in the calculation. The value calculated is for each cooler. The conclusions of the calculation are unchanged. We agree that this value is insignificant; however, there is an error in the calculation of this value.

Printed 5/12/98 2:15:59 PM Page 2 of 3 l

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Nstthenct Utilities ICAVP DR No. DR-MP3-0326 Millstone UnM 3 Discrepancy Report The revision of this calculation may be deferred.

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ICAVP DR No. DR-MP3-0330 N:rthenct Utilities i Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED l l Review Element: System Design p Discipline: Piping Design Ow Discrepancy Type: Calculaton g systern/ Process: Rss NRC significance level: 4 Date faxed to NU:

Date Published: 10/18/97 Discrepancy: Inconsistencies in the seism #c evaluation of spray nonle piping

Description:

During review of the following calculations (i) 12179-NP(F)-798-XD Rev 2 CCN 1 (ii) 12179-NP(F)-842-XD Rev 2, CCN 1 (iii) 12179-NP(B)-X7912 Rev 1.

(iv) 12179-NP(B)-X7918 Rev 1.

(v) 12179-NP(B)-X7900 Rev 1.

we noted the following discrepancies:

Background:

QSS and RSS spray nonles are cantilevered from the respective ring headers, and are not supported by the containment building structure. Therefore, these spray nonles will be subjected to the ring header accelerations and not the building structure accelerations.

Discrepancy:

1. QSS spray nonles are modeled and evaluated with the ring header piping in calculation (v). According to the ring header calculation (v), the spray nonle calculation (i) has been superseded by (v). However, calculation (i) has not been voided, ,

and is still active. l

2. For the RSS spray nonles, seismic response spectra curves used in the spray nonle calculation (ii) are not the same as those used in the ring header calculations [(iii) and (iv)]. Fluid transient time history accelerations have not been considered in the evaluation of the spray nonle piping. Acceleration 'g' values used for evaluating the spray nonle piping are much lower than the ring header accelerations.

The ring header calculations [(iii) and (iv)] generate acceleration values for the evaluation of the decoupled spray nonle lines.

But the acceleration values have not been used in the spray l

nonle calculation (ii).

Review l Date Valid invalid Needed initiator: Jain, R. C. G 0 0 10/S'S7 VT Lead: Nerl, Anthony A G O O $ o o'S7 VT Mg : schopfer, Don K G O O o/13'S7 O 10'$'S7 IRC Chmn: singh, Anand K G O Date:

INVALID:

1 Page 1 of 3 Printed 5/12/96 2:16:24 PM

ICAVP DR No. DR-MP3-0330 N:rthert Utilities Millstone Unit 3 Discrepancy Report Date: 5/8/98 RESOLUTION: Response 1. ID: M3-IRF-00716.

Disposition:

Discrepancy Report, DR-MP3-0330, has identified two separate  ;

conditions. NU has concluded that the second issue, regarding the RSS ring header end spray nonle calculations,is a discrepant condition previously discovered by NU which required correction. The discrepancy was corrected by Calculation Change Notice #2 to NP(F)-842-XD.

CCNs also were issued for calculations NP(B)-X7912, Rev.1 (CCN #1), and NP(B)-X7918, Rev.1 (CCN #1). These CCNs were issued as a result of EWR M3-97027 (dated 3/20/97) and l EWR M3-97088 (dated 6/20/97). l NU has concluded that the first issue, regarding the QSS ring header and spray nonle calculations, does not represent a discrepant condition. CCN 2 (dated 9/3/96) to cciculation NP(F)-

798-XD, Rev.1, indicates that the calculation, in its entirety, has been superseded by calculation NP(B)- X7900, Rev.1. Due to a large backlog, this CCN has not yet been entered into Passport.

(Current status of calculation in Passport is ' RESERVED".) As this calculation is still in the administrative process of being superseded as required per section 6 of Chapter 5 of NU's Design Change Manual (DCM), it is not considered ciscrepant

Conclusion:

Discrepancy Report, DR-MP3-0330, has it'entified two separate conditions. NU has concluded that the second issue, regarding the RSS ring header and spray nonle calculations, is a discrepant condition previously discovered by NU which required correction. CCNs which address the issue of run pipe accelerations have been issued for calculations NP(F)-

842 XD, Rev. 2, NP(B) X7912, Rev.1, and NP(B)-X7918, Rev.

1. These CCNs were initiated as a result of EWRs M3-97027 (3/20/97) and M3-97088 (6/20/97).NU has concluded that the first issue, regarding the QSS ring header and spray nonle calculations, does not represent a discrepant condition.  ;

Calculation NP(F)-798-XD has been superseded by NP(B)-

X7900, Rev.1.

Response 2. ID: M3 - IRF - 02333 Disposition:

NU has concluded that the issue reported in DR-MP3-00330 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which has been corrected. Condition Report (CR) M3-98 2212 (attached) was written to fulfill the requirement of PI-22 to write a CR for each Discrepancy Report confirmed to bo not pre-discovered by NU. S,ince the required corrective actions for this CR were completed.

by the design changes initiated by Engineering Work Request EWR M3-97027 and EWR M3-97088, this CR was recommended for immediate closure. 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 issue reported in DR-MP3-00330 has l Ment!Md 2 CONF!RMED S!GN!F!CANCE LEVEL 4 condit!ce Page 2 of 3 Printed 5/12/96 2:16:27 PM

ICAVP DR No. DR-MP3-0330

, N:rtheart UtilitiIs l l Millstone Unit 3 Discrepancy Report l which has been corrected. Condition Report (CR) M3-98-2212 l

(attached) was written to fulfill the requirement of PI-22 to write a l

CR for each Discrepancy Report confirmed to be not pre-discovered by NU. Since the required corrective actions for this CR were completed by the design changes initiated by Engineering Work Request EWR M3-97027 and EWR M3-97088, this CR was recommended for immediate closure. As l such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

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Attachments: CR M3-98-2212 Previously identified by Nu? O Yes (9) No Non Discrepent Condition?U Yes (ej No Rasolution Pending?O ve. @ No Resolution Unresolved?O yes @ No Review initiator: Jain. R. C.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 3/2/98 sL Comments: We agree that item #1 is non discrepant and item #2 has been corrected. However, there is no evidence that NU previously discovered item #2. Additional, since in our opinion this condition would not have resulted in an overstress condition, the DR level has been changed to 4.

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N;rthext Utilities ICAVP DR N2. DR-MP3-0338 Millstone UnM 3 Discrepancy Report Review Group: Operations & Mairdenance and Testing DR RESOLUTION ACCEPTED Review Element: Test Procedure Potential Operability issue Discipline: Operath Discrepancy Type: Test Requirements Ow (S) No System / Process: QSS NRC significance level: 4 Dete faxed to NU:

Dete Published: 10/31/97 Discrepancy: Surveillance Testing incomplete

Description:

For the Quench Spray System (QSS), Tech. Specs.

3/4.6.2.1.c.1) & c.2) contain requirements to verify the automatic actuation of QSS flow path valves and pump start on a Containment Depressurization Actuation (CDA) signal.

Surveillance Procedure SP-3646A.17 and OPS Form 3646A.17-1 are performod to satisfy these requirements.

A review of test data from 7/24/96 revealed the following:

Procedure step 4.3.4, Pg. 29 requires the performer to refer to Section C of OPS Form 3646A.17-1, and with the exception of pump QSS*P3A, establish all

• Prior to CDA" conditions. Section C of OPS Forrn 3646A.17-1 requires that QSS*MOV34A Quench Spray Header isolation Valve be verified CLOSED prior to CDA.

This step was marked "Not Tested" during the surveillance peformed on 7-24-96. Procedure step 4.4.24 requires verification that this same valve has transferred to it's post-CDA OPEN position following initiation of the CDA signal. This step was marked "Not Tested" during the surveillance performed on 7 96. OPS Form 3646A.17-1 contains a note which states " Power is RTO-Test Exception." It was not verified that valve 3OSS*MOV34A opened on a CDA signal, as required by the Tech Specs., and this requirement was not met. The form cover page also contains a note stating that the MOV34A test was not performed, along with a reference to a retest performed on OPS l Form 3646A.17-2," Train A Engineered Safeguards Features (ESF) With Loss of Power (LOP) Test Failure And Retest Documentation."

Additionally, Step 4.3.3 requires that the POSITION PRIOR TO Safety injection System (SIS)/ LOP be verified for the listed components on OPS Form 3646A.17-2 Section A, and Step 4.4.16 requires that the POSITION AFTER LOP be verified for those same components. Recirculation Spray System Pump 1C is required to be ON prior to SIS / LOP and OFF after LOP. This verification block is marked "Not Tested" on the form and a note on the form cover sheet refers to a retest performed on OPS Form 3646A.17-2.

Step 4.4.23 requires verification that CDA/ LOP components sequence ON following initiation of a CDA event. OPS Form 3646A.17-1, Section B, is marked "Not Tested" for RSS*P1C Recirculation Spray System Pump. A note on the form cover sheet refers to a retest performed on OPS Form 3646A.17 2. No reason is given for not performing the initial test. Tech. Spec.

Section 4.6.2.2.c. requires that each Recirculation Spray System be demonstrated operable at least once each refueling interval Pnnted 5/12/98 2:17:0g PM gkof7

ICAVP DR No. DR-MP3-0338 N:rthe:st Utilitie3 Millstone unit 3 Discrepancy Report pump starts automatically after a 660 +/- 20 second delay. This requirement may not have been met for RSS*P1C.

Step 4.4.24 and OPS Form 3646A.17-1, Section C, requires that 3RSS*MOV20A, the Recirculation System Train A discharge isolation valve, be verified CLOSED prior to a CDA test signal, l

and OPEN after the CDA signal. The valve was marked 'Not i Tested," and it was not verified that it opened on a CDA test signal. A note on the form cover page refers to a retest on OPS Form 3646A.17-2.

Step 4.4.25 requires that a Manual Trip Block (MTB) check be performed for each component on OPS Form 3646A.17-1, l

Section B. Fan 3HVU-FN2A was not checked. A note states that it was not checked due to a fault in the procedure. The form cover sheet has a note stating that it was not tested because it was not included at step 4.4.20 and was already stopped by the time step 4.4.25 was performed.

1 Step 4.4.27 requires documer.tation of reset of all MOV Thermal l I Overloads. This documentation was left blank for MOVs l 3RSS*MOV20A and 3QSS*MOV34A because these valves were l not tested as previously noted. l Most jumper installation and removal steps on OPS Form 3646A.17-1, Sections F & G, Pgs. 13,14 & 15, were marked NA.

A note on Pg.14 states:"S/G H.H. Leveljumper installation and removal to be per Shift Manager direction at the end of outage."

Northeast Utilities has not demonstrated that retesting was performed and the surveillance completed satisfactorily.

Administrative procedure DC 4, " Procedural Compliance,"

classifies procedures according to level of use. Surveillance Procedure SP 3646A.17 is classified as a " Continuous Use" procedure. This means that the procedure controls a work activity that is critical, complex, or involves infrequently l

performed evolutions or activities. Continuous level of use procedures require step-by-step use to prevent immediate effects on nuclear or personnel safety and plant reliability.

Administrative procedure, DC 1," Administration of Procedures and Forms," requires, that if a certain procedure step cannot be performed, then a procedure change is required before j proceeding with the work. A change is performed to modify a

' document quickly and accurately to allow work to continue. Per l

DC 1, an

• Intent Change' would have been the proper mechanism for revision of SP 3646A.17. An

• Intent Change" involves the modification of a regulatory requirement, policy, technical basis, setpoint, acceptance criterion, safety limit, operating limit, tolerance, etc. Additionally, it includes anything that modifies the scope of the document or the basic method of task performance.

1 Based on the previously identified discrepancies and the Page 2 of 7 Printed 5/12/96 2:17:12 PM l

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ICAVP DR No. DR-MP3-0338 N:rther.t Utilitica Millstone Unit 3 Discrepancy Report administrative procedure requirements, performance of surveillance procedure SP 3646A.17 and OPS Form 3646A.17- l 1, which was completed 7-24-96, was deficient in the following areas:

The surveillance testing was not performed step-by-step, and several steps related to testing of critical components were omitted.

There were no procedure changes or revisions documents attached to or a part of this surveillance test data package, and a check of procedure change records does not show that a change was initiated.

Procedure performers failed to initiate a procedure revision when steps could not be performed as written.

No reasons are given for not performing the initial tests and no reasons are given for retests. Retest forms are not a part of the test data package. Retest results, if any, are unknown.

Based on the lack of documentation of procedure steps and the obvious omission of testing of critical components, procedural requirements were not met, and it has not been demonstrated that Tech. Specs. requirements have been satisfied.

Review Valid invalid Needed Date initiator: Petrosky,Al. O O O 10/16'S7 O o'i7/S7 VT Lead: Bass, Ken G O VT Mgr: schopfer, Don K O O O o/23/97 IRC Chmn: Singh, Anand K B O O io/28/97

+ Date:

INVALID:

Date: $/j j/98 RESOLUTION: DISPOSITION:

1 NU has concluded that the issue reported in Discrepancy Report, l DR-MP3-0338, does not represent a discrepant condition. I 1-4 & 6. ESF / LOP testing of various RSS and QSS components was not completed in June of 1996 during the l scheduled ESF / LOP test because of ongoing work on the l l i systems. In addition, the retests for these components have not been completed due to continuing design and field work. When all retests are complete, the sign-off copy of SP 3646A.17 will be finished. SP 3646A.18 (attached)is completely signed off.

3646A.17 is awaiting completion of RSS and QSS retests.

(NOTE: ESF / LOP testing will be completed again in its entirety prior to startup and is currently scheduled for January,1998.)

5. This item in the DR mistakenly refers to 3HVU-FN2A. The correct fan that was not checked was 3HVU FN1 A as noted on the cover sheet and page 8 of 15 of 3646A.171. Retest Page 3 of 7 l Printed S/12/98 2:17:13 PM

ICAVP DR No. DR-MP3-0338 N::rthext Utilitiea Minstone unit 3 Discrepancy Report i requirements were documented on 3646A.17-2 (attached) along I with 3RSS*MOV20A and 3RSS*P1C. No retest is required for )

l 3HVU-FN1A b cause testing occurred in 3646A.15 Train A Loss l of Power Test (IPTE) on 7/20/96 (see References at the end of l this section). 3646A.17-2 has not been signed off because of the unavailability of the RSS components. 3646A.17 and 3646A.18 are currently being revised in preparation for ESF / LOP testing l in January. This described procedural fault is being corrected in l the upcoming revision by checking the Manual Trip Block before CDA is initiated.

I

7. The jumpers for Hi Hi Steam Generator level (Section G) were installed in anticipation of the test cn Sn/96 per AWO M3 06798 (see References.) Steps 4.1.9 in 3646A.17 and 3646A.18

were appropriately signed-off in the procedure as there was still a l need to clear the FWI signal. Both tests were lacking in that the AWO should have been referenced to provide better documentation of the test requirements.

The first jumper required for Section F is associated with step 4.1.24 in 3646A.17 and step 4.1.25 in 3646A.18. The step states: "If 3HVU-FN2A(B) is available, START 3HVU-FN2A(B).

Otherwise PERFORM the following steps..." Because the fan was available, it was staited and the subsequent steps were not required. There was no need to install the jumpers called for in the steps that followed. The same applies to the last portion of Section F which documents removal of the jumper.

The second jumper required for Section F is associated with 3RCS*H1 A(B). Step 4.1.32 in 3646A.17 and 3646A.18 allows for two possible conditions: 1. Pressurizer level is below the letdown isolation setpoint and a jumper is required; or,2. Pressurizer level is above the letdown isolation setpoint and not jumper is required. Pressurizer level was above the setpoint so no jumper ,

was required. , j The tests were performed on a step by step basis. There are many steps that read "lF...Then..

• If the condition is not met, ,

the step is marked N/A and the test proceeds. A review of all the I LOP and ESF / LOP tests was conducted as part of this response. There was no indication of testing being performed out of sequence. The steps where testing of critical components I was not performed were either covered by retests, not significant to test or part of the restoration steps. It was not desirable to test these components at the time due to plant configuration. ODI 6.02 (attached) provides guidance for tracking surveillance and j transitioning from one MODE to another. It requires a signoff for each procedure that is required to be complete during a shutdown. The ESF / LOP procedures are included (Attachment A, p.2.) Therefore, the test is not complete and accepted for MODE char:ge until all retests for all out of service components are performed.

During the performance of the test, the majority of the sign-offs and all of the decisions to N/A a step are made by the Unit Supervisor with the concurrence of the Shift Manaaer and Test Printed 5/12/9e 2:17:15 PM Page 4 of 7

l 1 ICAVP DR N2. DR-MP3-0338 N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report  !

Engineer in accordance with DC 4 Revision 2. These are not actions taken by a single individual.

While the components not tested are listed on the cover sheets j for 3646A.17-1 and 3646A.18-1, there is no written description of j why the components were not tested. There is no formal j requirement for this documentation, but including this l l information would be beneficial. 3RSS*P1C and 3RSS*MOV20A l were not tested as they were tagged out for work and I

disassembled at the time. Because those components are not required by Tech Specs in MODE 5 (Ref. Tech Specs 3.6.2.1 and 3.6.2.2), management decided that not having them available for the scheduled test and retesting them at a later date was acceptable.

There were a number of steps where equipment could not be  !

tested because they were tagged out of service. In the case where components should have been tested per the procedure and were not, retests were necessary and were either carried out l (3SWP*P38,3CHS*MV8111 A and SCCP*P10, see References) l or are still waiting plant conditions to perform (3RSS*P1C, 3RSS*MOV20A and 3OSS*MV34A.) In some steps the equipment was already in the configuration desired (step 4.1.4, RHR pump was already on recirculation as required.)

Changes were made to all of the tests during their performance based on the standards established by DC4 Revision 2. A review conducted of the four tests determined that there were no situations where the intent of the test was changed without a required procedure change.

Our present standard is that if a step cannot be carried out, the supporting details must be documented per the requirements of DC4 revision 4, effective 10/31/97. Previous to this Revision 4, there was no such guidance. DC 4 Revis;on 2 was effective at the time of the test. Revision 2 allows a First Line Supervisor the authority to deviate from a procedure as long as the intent is neither changed nor compromised (Section 1.6). In addition, SF 371 Procedure Level of Use, itemizes procedure user responsibilities. It allows a First Line Supervisor the authority to deviate from step sequence or to partially perform procedures.

(The SF has been recently canceled due to the new requirements of DC4. However, it is still in limited use on procedures that have not been upgraded (per PUP) as it contains the procedure Level Of Use. Refer to DC 4 cover sheet.)

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

. CONCLUSION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0338, does not represent a discrepant condition NU concludes that this test was performed satisfactorily.

Printed 5/12/96 2:17:16 PM Page 5 of 7

ICAVP DR No. DR-MP3-0338 N rtheart Utilitie3 l

Millstone unit 3 Discrepancy Report Although various components were not available for testing, retests have been completed for components that have since been retumed to service. Some components are still not available for retest. The DR item regarding 3HVU-FN2A is in error. The fan that was not tested due to a procedural fault was l 3HVU-FN1 A. The requirements for this component were captured under LOP testing,3646A.15. Jumpers were installed in accordance with an AWO prior to the ESF / LOP test. This could have been better documented within the test procedure, but technically was not required. Based on DC 4 Revision 2, which was effective at the time, procedure changes were property implemented when necessary or steps waived by the Unit Supervisor, Test Engineer and Shift Manager. Significance level criteria do not apply as this is not a discrepant condition.

NU's Revised Response:

Disposition:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0338 has identified a NON-DIFCREPANT condition.

The attached Feedback / Notes Report for SP 3646A.15, Revision 12, SP 3646A.16, Revision 9 SP 3646A.17, Revision 10, and SP 3346A.18, Revision 11, show the feedback notes for these procedures have been clarified to define *other exceptions

• as l large loads, MOVs or other equipment that would effect diesel l loading or the integrity of the test. Technical Support  !

Engineering has reviewed the feedback notes related to this Discrepancy Report for these procedures and concurs with the proposed enhancements. They also agree that except for pumps there are no other exceptions that have the potential to automatically invalidate it a test. Engineering signifies their j review and concurrence by signing as Technical Reviewer on j this IRF.

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

Conclusion:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0338 has identified a NON-DlSCREPANT condition.

The attached Feedback / Notes Report for SP 3646A.15, Revision 12, SP 3646A.16, Revision 9, SP 3646A.17, Revision 10, and SP 3646A.18, Revision 11, show the feedback notes for these procedures have been clarified to define "other exceptions *.

Technical Support Engineering has reviewed the feedback notes related to this Discrepancy Report for these procedures and concurs with the proposed enhancements. They also agree that except for pumps there are no other exceptions that have the potential to automatically invalidate the test. Engineering signifies their review and concurrence by signing as Technical I Reviewer on this IRF.

Significance level criteria do not apply as this is not a discrepant PrWed t.'12/98 217:16 PM Page 6 of 7

l ICAVP DR No. DR-MP3-0338 N3rthert Utilitie3 ministone unit 3 Discrepancy Report condition.

Previously identir.ad by NU7 U ves (#) No Non Discrepant condition?U ves (G) No Resolution Pending?O ves @ No Resolution Unresolved?O yes @ No Review Acceptable Not Acceptable Needed Date S R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/11/98 sL Comments: S&L has reviewed NU's threo responses to this DR and has determined that the facts support a Level 4 Discrepancy. NU acknowledgment that the ESF/EOP procedures will be enhanced, that steps will be added to document that the OPS manager or the Unit Director will approve all component exceptions prior to testing, and the indication that the procedures will be enhanced with regards to equipment exceptions during testing in addition to the information described in the Discrepancy Report is the basis for S&L's position that this is a discrepant condition. As indicated above, this discrepancy has been downgraded to a Level 4 based on NU's information and responses.

l l

l I

1 i

Printed 5/12/98 2:17:18 PM Page 7 of 7

N:rthert Utilities ICAVP DR No. DR-MP3-0343 Millstone Unit 3 Discrepancy Report l

Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED l Review Element: Test Procedure Potentias Operability issue Discipune: OperaUons Discrepancy Type: Test Requirements Ow System / Process: QSs

@ No NRc signincance level: 4 Date faxed to NU:

Date Published: 11/13S7 Discrepancy: Surveillance Testing incomplete i

Description:

Various testing requirements for the emergency diesel generator )

test of 6/6/96 were either not completed or lack adequate I documentation. This is a discrepant condition.

Surveillance Procedure SP 3646A.18 and OPS Form 3646A.18-1 are performed to satisfy various Technical Specifications requirements related to emergency diesel generator and sequencer operation, plus testing of component response to various simulated signals, such as Safety injection System (SIS) initiation, Loss of Power (LOP) Engineered Safeguards Features (ESF) Actuation, Containment Depressurization Actuation (CDA), etc.

I A review of test data from 6/6/96 revealed the following.

Step 4.3.3 requires that the POSITION PRIOR TO SIS / LOP be verified for the listed components on OPS Form 3646A.18-2 Section A, and Step 4.4.13 requires that the POSITION AFTER LOP be verified for those same components. Reactor Plant Closed Cooling Water Pump 1C is marked "PTL" (locked out) on the form, but is required to be ON before and after receipt of a SIS / LOP signal. A note on form pg. 3 says "Not done - see note 1." Note 1 says "The breaker for CCP*P1C is tagged out and waiting parts (AWO M3-94-04800). The pump will be tested under a retest." A note on the form cover page states:

"3CCP*P1C tagged out - will be tested per SS46A.18-2, Retest."

A retest form OPS Form 3646A.18-2 is attached, with a cover page note stating that CCP*P1C needs to be retested, but no test was performed on that form.

Steps 4.3.3 and 4.4.13 require that the pcsition of valves j SSR*CTV19A,19B,19C, & 19D be verified OPEN before and CLOSED after receipt of a SIS / LOP signalin Section A. Section l A is initialed as if the test verification was performed correctly, but attached retest form 3646A.18-2 indicates that the valves l were not available for test. Under" Proposed Retest," reference l le made to testing these valves 13 months earlier (5-29-95) per procedure SP 3646A.9, Step 4.20, and again 16 months earlier (2-14-95) per procedure OP 3346A. Those test results were not attached.

Steps 4.3.3 and 4.4.13 require verification that CHS*CV8111 A l l

Charging Pump A Recirculation Valve be OPEN before receipt of a LOP signaland CLOSED after LOP. Section A test results are marked "N/A" with a note which says: " Marked N/A per SP 3646A.18, Rev.10, Step 4.3.8.d. - will be tested per 3646A.18-2, j

' ' I Printed 5/12/98 2:17A6 PM h[ge g or 7 l

Ncrthsast Utiliti:s ICAVP DR No. DR-MP3-0343 Millstone Unit 3 Discrepancy Report CHS*CV8111C be marked "N/A," depending on fast conditions, which is okay. What it does not require, however; is a retest of the valve marked "N/A."

, Steps 4.3.3 and 4.4.13 require verification that RCS*H1B Group B Pressurizer Heaters circuit breaker be CLOSED before LOP and TRIPPED after LOP. A Section A note indicates that the breaker did not trip as required, but the heaters simply went off.

Another note states:" Tech Support Engineering has determined that the Group B Pressurizer Heaters will trip as required; however, the green light will be lit vice the amber light. ACR-M3-96-0046 (copy attached) was written to investigate." The fact that the heater breakers did trip meets the intent of this surveillance and satisfies acceptance criteria." No copy is attached.

Step 4.4.27 requires documentation of reset of all MOV Thermal Overloads on OPS Form 3646A.18-1, Section E. Section E, pg.

12, is marked out, with a note to see attached Page 12 of Revision 9, and says " verified no changes." There is a Revision 9 Page 12 attached, with the verificat'ons performed. The procedure being performed, however, is Revision 10, and the wrong revision was used to document this verification data.

Most jumper installation and removal steps on OPS Fonn 3646A.18-1, Sections F & G, Pgs. 13,14 & 15, were marked NA.

A note on Pg.14 states: "Per Shift Manager - Jumper removal will be accomplished following A Train LOP and ESF/ LOP tests."

The test data package does not contain a record of jumper removal.

Administrative procedure DC 4,

• Procedural Compliance,"

classifies procedures according to level of use. Surveillance Procedure SP 3646A.18 is classified as a " Continuous Use" procedure. This means that the procedure controls a work activity that is critical, complex, or involves infrequently performed evolutions or activities. Continuous level of use procedures require step-by-step use to prevent immediate effects on nuclear or personnel safety and plant reliability.

Administrative procedure, DC 1, " Administration of Procedures and Forms," requires, that if a certain procedure step cannot be performed, then a procedure change is required before proceeding with the work. A change is performed to modify a document quickly and accurately to allow work to continue. Per DC 1, an

• Intent Change" would have been the proper mechanism for revision of SP 3646A.18. An " Intent Change" involves the modification of a regulatory requirement, policy, technical basis, setpoint, acceptance criterion, safety limit, operating limit, tolerance, etc. Additionally, it includes anything that modifies the scope of the document or the basic method of task performance.

Based on the previously identified discrepancies and the administrative procedure requirements, performance of surveillance procedure SP 3646A.18 and OPS Form 3646A.18-

1. which was completed 6-6-96. was deficient in the followina Pnnted 5/12/98 2:17.49 PM Page 2 of 7

Northsast Utilitiss ICAVP DR No. DR-MP3-0343 Millstone Unit 3 Discrepancy Report areas:

a) The surveillance testing was not performed step-by-step, and I several steps related to testing of critical components were

! omitted.

b) There were no procedure changes or revisions documents attached to or a part of this surveillance test data package, and a check of procedure change records does not show that a change was initiated.

c) Procedure performers failed to initiate a procedure revision when steps could not be performed as written.

d) No reasons are given for not performing the initial tests and no reasons are given for retests. Retest forms are not a part of the test data package. Retest results, if any, are unknown.

Based on 5 lack of adequde documentation and/or the omissior of testing of critical components, procedural requirements were not met. It cannot be determined whether or not the Tech. Specs. surveillance requirements were satisfied for the 6/6/96 test.

Review Valid invalid Needed Date initiator: Petrosky.Al. O O O 1 /5/S7 VT Lead: Bass. Ken 0 0 0 /6/97 VT Mgr: schopfer, Don K B O O 11/7/S7 IRC Chmn: singh, Anand K O O O 11/7/97 Date:

INVALID:

Date: 5/11/98 REsOLUDON: DISPOSITION:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0343, does not represent a discrepant condition.

1. ESF / LOP testing of various components was not completed in June of 1996 during the scheduled ESF / LOP test because of ongoing work on the plant. The retest for 3CCP*P1C has been completed (attached.) (NOTE: ESF / LOP testing will be completed again in its entirety prior to startup and is currently scheduled for January,1998.)

2. 3SSR*CTV19A/B/C/D were satisfactorily tested on 0/6/96 with no retest required. We believe that there is some confusion regarding the 5/29/95 retest. This retest was due to the valves being out of service for a PDCR implementation during the ESF /

LOP test performed for RFOS. It does not pertain in any way to the test completed in June of 1996.

3. 3646A.17 and 3646A.18 should be improved to require a Pr6nted 5/12/P12:17:50 PM Page 3 of 7

ICAVP DR N2. DR-MP3-0343 N:rthert Utilitie3 Millstone unit 3 Discrepancy Report retest on the CHS mini-flow recirc valve that is not tested during the ESF / LOP test. 3CHS*MV8111 A/B/C are powered off of B j train; 3CHS*MV8110 is powered from A train. Because of this j configuration, during the A train ESF / LOP test,3CHS*MV8110 (

must be jumpered out. This ensures that the operating Charging l Pump always maintains a minimum flow path. Likewise, when the B train is tested 3CHS*MV8111 A, B or C, the mini-flow recirc ,

valve associated with the operating Charging pump, must bc )

jumpered. Historically, this was completed only because of the cognizance of the test engineer and SROs and was not proceduralized. This is currently being incorporated into the latest revision of both procedures and is considered an enhancement to the procedures.

4. Attached is a copy of the ACR relative to the pressurizer heater trip. This investigation discovered a minor difference in the control schemes for the heaters. 3RCS*H1B control only I opens the breaker upon receipt of the SIS / LOP signal; it does I not illuminate the " trip" amber light. Per the corrective action for ACR M3 96 0046, the control circuit for 3RCS*H1B will be modified in RFO6 to be consistent with 3RCS*H1 A. This information will be incorporated into tbs pre-job brief when the test is conducted in January of 1998 (Reference attached electronic mail to B. W. Nichols and H. K. Covin).

S. The ESF / LOP test originally began on 5/26/97. However, the test had to be terminated due to the EDG trip during loading l

(ACR 10428). A significant amount of equipment had been prepared for testing up to that point, including MOV thermal overloads. During the interim of setting up for the test again, a decision was made to revise the procedure to incorporate various changes and to add cautions regarding EDG operation.

The MOV thermal overioads were still configured in accordance with revision 9 of SP 3646A.18. Because of this, procedural guidance and the applicable form in revisions 9 and 10 were verified to ensure that they were consistent. Revision 10 had no l

more requirements than Revision 9, so configuration of thermal i

overloads was not repeated. NU has concluded that while no l l requirements were missed or violated, this practice would not be  !

l acceptable under present standards (established in DC 4 Revision 4).

6. The jumpers for Hi Hi Steam Generator level (Sectron G) were installed in anticipation of the test on 5/7/96 per AWO M3 ) 06798 (see References). Step 4.1.9 in 3646A.17 and 3646A.18 was appropriately signed-off in the procedure as there was still a l

need to clear the FWI signal. Both tests were lacking in that the AWO should have been referenced to provide better documentation of the test requirements. The first jumper required for Section F is associated with step 4.1.24 in 3646A.17 and step 4.1.25 in 3646A.18. The step states: *lf 3HVU-FN2A(B) is available, START 3HVU-FN2A(B), otherwise PERFORM the following steps..." Because the fan was available, it was started and the subsequent steps were not required. There was no need to install the jumpers called for in the steps that followed. The same applies to the last portion of Section F which documents Printed 5/12/98 2:17:51 PM Page 4 of 7

N:rthe:st Utilities ICAVP DR No. DR-MP3-0343 Millstone Unit 3 Discrepancy Report  !

removal of the jumper.

J The second jumper required for Section F is associated with l 3RCS*H1 A(B). Step 4.1.32 in 3646A.17 and 3646A.18 allows for two possible condkons: 1. Pressurizer level is below the letdown i i

isolation setpoint and a jumper is required; or,2. Pressurizer j l level is above the letdown isolation setpoint and no jumper is required. Pressurizer level was above the letdown isolation I setpoint so no jumper was required.

The tests were performed on a step by step basis. There are q many steps that read "lF...Then...' If the condition is not met, j the step is marked N/A and the test proceeds. A review of all the LOP and ESF / LOP tests was conducted as part of this response. There was no indication of testing being performed out of sequence. The steps where testing of critical components was not performed were either covered by retests, not significant to test or part of the restoration steps. It was not desirable to test these components at the time due to plant configuration. ODI 6.02 (attached) provides guidance for tracking surveillance and transitioning from one MODE to another, it requires a signoff for l each procedure that is required to be complete during a shutdown. The ESF / LOP procedures are included (ODI 6.02 Attachment A, p.2.) Therefore, the test is not complete and accepted for HODE change until all retests for all out of service components are performed.

1 During the performance of the test, the majority of the sign-offs and all of the decisions to N/A a step are made by the Unit Supervisor with the concurrence of the Shift Manager and Test Engineer in accordance with DC 4 Revision 2. These are not actions taken by a single individual.

l i While the components not tested are listed on the cover sheets '

l for 3646A.17-1 and 3646A.18-1, there is no written description of i

why the components were not tested. There is no formal ,

requirement for this documentation, but including this

! information would be beneficial. 3RSS*P1C and 3RSS*MOV20A were not tested as they were tagged out for work and disassembled at the time. Because those components are not required by Tech Specs in MODE 5 (Ref. Tech Specs 3.6.2.1 and 3.6.2.2), management decided that not having them available for the scheduled test and retesting them at a later date l was acceptable.

Changes were made to all of the tests during their performance based on the standards established by DC4 Revision 2. A i review conducted of the four tests determined that there were no situations where the intent of the test was changed without a I required procedure change.

Our present standard is that if a step cannot be carried out, the l supporting details must be documented per the requirements of I DC4 revision 4, effective 10/31/97. Previous to this Revision 4, there was no such guidance. DC 4 Revision 2 was effective at the time of the test. Revision 2 allows a First Line Supervisor Printed 5/12/98 2:17:52 PM Page 5 of 7 L____ _ _ _ _ _ _ _ _ _ _ _ _ _____ ._

N:rthert Utiliti:s ICAVP DR No. DR-MP3-0343 Millstone Unit 3 Discrepancy Report the authority to deviate from a procedure as long as the intent is neither changed nor compromised (Section 1.6). In addition, SF 371 Procedure Level of Use, itemizes procedure user responsibilities. It allows a First Line Supervisor the authority to deviate from step sequence or to partially perform procedures.

(The SF has been recently canceled due to the new requirements of DC4. However, it is still in limited use on procedures that have not been upgraded (per the Procedure Upgrade Program) as it contains the procedure Level Of Use.

Refer to DC 4 cover sheet.)

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

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0343, does not represerit a discrepant condition. l l

NU concludes that the portions of this test that have been l completed were performed satisfactorily. Although various components were not available for testing, retests have been completed for components that have since been re'umed to service. Some components are still not available for retest. The i i configuration for testing MOV thermal overloads was initially completed on revision 9 of 3646A.18-1. An EDG trip terminated that test. Before ti)e new test was begun, the procedure was revised. Because the overloads were still property configured, l the new form was not completed for that section only. Although no requirements were missed or violated, this practice would not l

be acceptable under present standards established by DC 4 Revision 4. Jumpers were installed in accordance with an AWO ,

prior to the ESF / LOP test. This could have been better l I documented within the test procedure, but technically was not i required. Based on DC 4 Revision 2, which was effective at the time, procedure changes were property implemented when necessary or steps waived by the Unit Supervisor, Test Engineer and Shift Manager. Significance level criteria do not apply as this l is not a discrepant condition.

l NU's revised response:

l i

l Disposition:

l NU has concluded that the issue reported in Discrepancy Report DR-MP3-0343 has identified a NON-DISCREPANT condition.

l The attached Feedback / Notes Report for SP 3646A.15, Revision 12, SP 3646A.16, Revision 9, SP 3646A.17, Revision 10, and SP 3646A.18, Revision 11, show the feedback notes for these procedures have been clarified to define *other exceptions" as large loads, MOVs or other equipment that would effect diesel loading or the integrity of the test. Technical Support Engineering has reviewed the feedback notes related to this Discrepancy Report for these procedures and concurs with the proposed enhancements. Thev also aoree that except for Printed 5/12/96 2:17:s3 PM Page 6 of 7

N::rthent Utilitie3 ICAVP DR N3. DR-MP3-0343 Millstone Unit 3 Discrepancy Report  ;

pumps there are no other exceptions that have the potential to l automatically invalidate the test. Engineering signifies their review and concurrence by signing as Technical Reviewer on this IRF. f Significance level criteria do not apply as this is not a discrepant condition.

I I

l

Conclusion:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0343 has identified a NON-DISCREPANT condition.

The attached Feedback / Notes Report for SP 3646 A.15, Revision 12, SP 3646A.16, Revision 9, SP 3646A.17, Revision 10, and SP 3646A.18, Revision 11, show the feedback notes for these procedures have been clarified to define "other exceptions". Technical Support Engineering has reviewed the feedback notes related to this Discrepancy Report for these  ;

procedures and concurs with the proposed enhancements. They i

! also agree that except for pumps .

! there are no other exceptions that have the potential to I automatically invalidate the test. Engineering signifies their i review and concurrence by signing as Technical Reviewer on this IRF.

l

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

l

! Previously identined by NU7 O Yes @ No Non Discrepard Condition?O Yes (#) tb Resolution Pending?O Ye. @ No Resolution Unresolved 70 Yes @ No Review i Initiator: Speer, R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K O Wa IRC Chmn: Singh, Anand K Date: 5/1/98 l

l sL Comrnents: S&L has reviewed NU's three responses to this DR and has determined that the facts support a Level 4 Discrepancy. NU acknowledgment that the ESF/EOP procedures will be enhanced, that steps will be added to document that the OPS manager or the Unit Director will approve all component exceptions prior to testing, and the indication that the procedures will be enhanced l

with regards to equipment exceptions during testing in addition to the i,1 formation described in the Discrepancy Report is the basis for S&L's position that this is a discrepant condition. As indicated above, this discrepancy has been downgraded to a Level 4 based on NU's information and responses.

l l

l Printed 5/12/98 2:17:55 PM Page 7 of 7

l N:rthert Utilities ICAVP DR N3. DR-MP3-0351 Millstone Unit 3 Discrepancy Report ,

Review Group: Configuration DR RESOLUTION ACCEPTED l

Review Element: system Design Potential Operability issue Discipline: Electrical Design Discrepancy Type: Installation imp 6ementaten O Yes System / Process: Oss (5) No NRC Significance level: 4 Date faxed to NU:

Date Published: 11f2/97 Discrepancy: Walkdown discrepancies

Description:

The following discrepant conditions were identified during the field walkdowns:

l 1. Drawing EE-6EL Rev. 2 and the Cable and Raceway Program l (TSO2) indicate conduit number 3CK949ND9 runs between

, 3 HTS-JB982P and 3 HTS-JB980S. The conduit is tagged 3CK949NB9 in the field.

2. The ground wire running with the flexible conduit connecting to 3OSS-FIT 22 is not connected at the non instrument end.

Crounds for flexible conduits are required to be connected per Electrical Installation specification E-350.

The following material condition was noted;this is not a configuration issue:

1. The conduit connection fittings to boxes 3 HTS-JB979S and JB924S are very rusty.

2. The instruments (RTDs/TEs) of the heat tracing system are not tagged contrary to requirements of Electrical Installation Specification E-350.

Review Valid invalid Needed Date initiator: sarver, T. L. 8 O O o/28/97 VT Lead: Nerl. Anthony A B D 0 1or27/97 VT Mgr: schopfer, Don K O O O 10/30/97 BRC Chmn: singh, Anand K S O O 10/30'S7 Date:

INVALID:

Date: 5/8/98 RESOLUTION: INITIAL RESPONSE:

l Disposition:

NU has concluded that Discrepancy Report, DR MP3-0351, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability i

concems and meets the Unit 3 deferral criteria. CR M3-97-3997 l has been written to develop and track resolution of this item per j RP-4, 1

Printed 5/12/96 2:20.53 PM Page 1 of 3

. _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - = . . _ _ _ _ _ _ _ _ _ - _ _ -

ICAVP DR No. DR-MP3-0351 N::rth2ast Utilities Millstone Unit 3 Discrepancy Report

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0351, 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 four.d to have no operability or deportability concerns and meets the Unit 3 deferral criteria. CR M3-97-3997 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

l Disposition:

NU has concluded that the issues repcrted in Drt-MP3-0351 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition.

NU considers the referenced issue to be deferrable based on meeting U3 PI-20, section 1.3.2.e, deferral criteria. However the discrepancy has been corrected.

The conduit that runs between 3 HTS-JB982P and 3 HTS-JB980P was incorrect!y labeled as 3CK949NB9. The field has re labeled this conduit 3CK949ND9 under the Minor Maintenance Program,

! in accordance with the Cable and Raceway Control Program and Drawing Number 12179-EE-63L-2.

l l

Conclusion:

l NU has concluded that the issues reported in DR-MP3-0351 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition.

The issue conceming the conduit labeling discrepancy has been corrected. The conduit was re-label to agree with the Cable and Raceway Control Program and design drawing # 12179-EE-63L-2.

Previously identified by NU? O Yes (G) No Non Discrepent Condition?O Yes (S) No j Resolution Pending?O ve. @ No Resoluuon Unresolved?O ve. @ No Review initiator: Womer, I.

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

IRC Chmn: singh, Anand K I O O Date: 5/8/98 f SL Comments: INITIAL COMMENT l Based on the statement in the screening criteria it appears that this issue is not deferable.

" Plant labeling discrepancies which have a direct impact on plant Page 2 of 3 Printed 5/12/98 2:20:57 PM

ICAVP DR No. DR-MP3-0351 Northeast Utilities Millstone Unit 3 Discrepancy Report configuration, operation or personnel safety."

COMMENTS ON NU'S SECOND RESPONSE:

We accept NU's second response.

y Printed S/12/90 2:20:59 PM Page 3 of 3

)

l N rthert Utilities ICAVP DR No. DR-MP3-0352

! Millstone unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACr,EPTED Review Element: system Design Potentk e Operability lasue Discipline: Electrical Design Discrepancy Type: Drawing O Yes Systern/ Process: Oss

1. No NRC Significance level: 4 Date faxed to NU:

Date Published: 10/18/97 Discrepancy: Drawing Discrepancies

Description:

1. Conduit Support Logs (CSLs) 12179-FSK-YD-035 Rev. 2 and YD-043 Rev.1 A show conduit 3CC9100K1 as 2 inch which is consistent with the field installed condition. The Cable and Raceway Program (TSO2) indicates the conduit is 1 inch diameter.

2. Drawing EE-55S, Rev. 3 shows conduit 3CX910NK2 connected to SQSS-TE38. Per the Cable and Raceway Program (TSO2) and the installed condition, the conduit number is 3CX910NL.

3. Drawing EE-55S, Rev. 3 shows conduit 3CX910NK4 connected to 3OSS-TE23. Per the Cable and Raceway Program (TSO2) and the installed condition, the conduit number is 3CX910NL1.

Review Valid invalid Needed Date initiator: sarver. T. L. 8 O O S/30/97 VT Lead: Nort. Anthony A B O O 1o/2/97 VT Mgr: schopfer. Don K B D D 10/13/97 BRC Chmn: singh, Anand K O O O 10/1'S7 Date:

INVAUD:

Date: 5/8/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that items 2 & 3 of Discrepancy Report, DR-MP3 0352, have identified conditions not previously discovered by NU which require correction.

The as-built condition and TSO2 show conduit's 3CX910NL and 3CX910NL1 ending at 3OSS-TE38 and SQSS-TE23, respectively. Drawing EE-SSS details conduit's 3CX910NK2 and 3CX910NK4 ending at 3QSS-TE38 and 30SS-TE23, respectively. A review of drawing EE-55S, Rev. 3 by Design Engineering indicates E&DCR F-E-37496 and N&D NF-09367 were incorporated incorrectly into the present revision. These two documents identify the as-built cor.duits connected to these temperature elements. Therefore, drawing EE-55S needs to be revised to agree with the as-built conditions for the referenced temperature elen ents, as well i for 3QSS-TE20 and 3QSS-FIT 22.

Printed 5/12/96 2:27:31 PM Page 1 of 3

l DR N;. DR-MP3-0352

, N:rther t Utilitiea ICAVP Miiistone unit 3 Discrepancy Report Condition Report (CR) M3-97-3887 has been written to provide the necessary corrective actions to resolve these issues. The approved Corrective Action Plan (CAP) for M3-97-3887 is attached.

The drawing EE-SSS has been updated via a Design Change Notice (DCN) DM3-00-1806-97, no additional work is required in the field.

NU has concluded that the item #1 issue reported in Discrepancy Report, DR-MP3-0352, does not represent a discrepant condition.

l DR-MP3-0352 reports Raceway 3CC9100K1 was stated to be a 1" conduit in TSO2. Conduit Support Log YD-035, drawing EE-SSS and the as-built condition depict this raceway as a 2" conduit. Upon reviec/ of TSO2 for this raceway by Design Engineering, the database displayed 3CC9100K1 as a 2" conduit. As a result, this item is not a discrepant condition. A printout of TS02 raceway number 3CC9100K1 is attached.

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

Conclusion:

NU has concluded that items 2 & 3 of Discrepancy Report, DR-MP3-0352, have identified conditions not previously discovered by NU which require correction.

Condition Report (CR) M3-97-3887 was written to provide the necessary corrective actions to resolve these drawing errors.

Drawing EE 55S has been updated via Design Change Notice (DCN) DM3-00-1806-97.

NU has concluded that item # 1 reported in Discrepancy Report, DR-MP3-0352, does not represent a discrepant condition.

Conduit Support Log YD-035, drawing EE-SSS, the as-built condition and the raceway program TSO2 depict this raceway as a 2" conduit. Therefore, this item is not a discrepant condition.

Significance Level criteria does not apply to item 1 as this is not a discrepant condition.

SECOND RESPONSE:

Disposition:NU has concluded that the issue reported in l Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition. Conduit support logs 12179-FSK YD-35 and 43 do not show conduit 9CC9100K1 which is a flexible conduit extending fromjunction box 3QSS*JB27 to 3QSS

• AOV27. The conduit logs do not typically show flexible conduit.

The listing for 9CC9100K1 is correct in TS02 and matches the field size of 1 inch. This conduit actually runs from lunction box Pnnled 5/12/98 2:27:34 PM Page 2 of 3

N:rthert Utilitie3 ICAVP DR N2. DR-MP3-0352 Millstone Unit 3 Discrepancy Report 3OSS*JB27 on support 34 which is shown on conduit support log 12179-FSK YD-034 Rev. 2. There does not appear to be a size j inconsistency with either 9CC9100K1 or 3CC9100K1.

1 l

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

Conclusion:

l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition.

Conduit support logs 12179-FSK-YD-35 and 43 do not show conduit 9CC9100K1 which is a flexible conduit extending from junction box 3QSS*JB27 to 3QSS *AOV27. The conduit logs do not typically show flexible conduit. The listing for 9CC9100K1 is -

correct in TS02 and matches the field size of 1 inch. There does not appear to be a size inconsistency with either 9CC9100K1 or 3CC9100K1.

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

Previously identified by NU7 O Yes, @ No Non Discrepant Condetion?O Yes @ No Resolution Pending70 ve. @ No Resolution Unresolved?O yes @ No Review initiator: Warner, I.

VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K 1RC Chrnn: singh, Anand K Date: 5/8/98 sL comments: COMMENTS ON INITIAL RESPONSE:

The responses to the identified discrepancies are adequate.

However, there was a typographical error in the description of item 1; the conduit with an apparent size inconsistently is 9CC9100K1 (not 3CC9100K1).

l COMMENTS ON NU'S SECOND RESPONSE:

We accecpt NU's response.

1 Printed 5/12/981:27:35 PM Page 3 of 3 l

N:rtheast Utilities ICAVP DR No. DR-MP3-0374 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue l Discipline: Pip 6ng Design

! O yes Discrepancy Type: calculaten

@) No Systen#rocess: Rss NRC significance level: 4 Date faxed to NU:

Date Published: 10/23/97 Discrepancy: ASME Code edition specified in NUPIPE stress analysis is inconsistent with design criteria

Description:

In the process of reviewing the following documents, (i) FSAR Section 3.9B.1.4.1 Seismic Analysis Methods - Piping Systems (ii) Pipe Stress Analysis Ciiteria Document, NETM-44, Revision 2 (iii) Pipe Stress Calculation 12179-NP(B)-X900-XD Rev 1 CCN's 1 to 4 we noted the following discrepancy:

Background:

According to (1): The procedure used for modeling of Seismic Category I ASME Code Class 1,2 and 3 piping systems and the analytical methods employed for pipe stress analysis comply with ASME lll Subsections NB, NC, ND (1971 through Summer 1973 addenda) and Appendix F.

According to (ii): All Safety Related , QA Category 1, ASME Class 1,2 and 3 piping is designed to meet the requirements of l ASME B&PV Code Section Ill,1971 edition, including addenda through Summer 1973.

According to (iii): The code specified in general cor' trol for NUPIPE analysis is 1977 edition, winter 1978 addenda, or 31.1 Power Piping, post summer 1973 addenda. The same edition is ,

specified in all NUPIPE analyses in the scope or review.

One difference between the 1971 code and the 1977 code is the Stress intensification Factor (SIF) for Socket welded fittings -

(1.3 in the 1971 code, and 2.1 in the 1977 code).

In (iii), the NUPIPE analysis for Model-B uses an SIF of 1.3 at one end (NP 385) of valve 3RSS*V67 and 2.1 at the other end (NP 395). The NUPIPE analysis for Model-A uses an SIF of 1.3 at one (NP 185) of valve 3RSS*V66, and no SIF at the other end (NP 195).

Discrepancy:

The ASME code edition used in the computer analyses is not consistent with the edition specified in the licensing documents.

In the case of (iii), SIF values from both codes are used.

Althnsinh" the ince nf RIF uninac frnrn the inter rneta arfitinn Ic Pnnted 5/12/98 2:28.18 PM Page 1 of 4 l

l

ICAVP DR No. DR-MP3-0374 N:rthert Utilitlas Millstone Unit 3 Discrepancy Report conservative in this case, a full reconciliation between the two

! codes is not documented in the design criteria document (ii), nor in the pipe stress calculations.

No SIF is applied at the downstream socket welded end of valve 3RSS*V66 (NP 195). l Review l l I Valid invalid Needed Date l

i initiator: Prakash, A. B 0 0 tot 2/97 l VT Lead: Neri, Anthony A 8 0 0 So/7/87 10/ 4/S7 VT Mgr: schopfer, Don K G O O 10/17/S7 IRC Chmn: singh. Anand K G O O Date:

i INVALID:

Date: 5/7/98 RESOLUTION: First Response ,

l lD:M3-IRF-00836 Disposition: f NU has concluded that Discrepancy Report DR-MP3-0374 has l identified a condition not previously discovered by NU which  !

requires correction. Condition Report (CR) M3-97-4188 (See l Attached) was written to provide the necessary corrective actions to resolve this issue. The corrective action outlined in Condition Report M3-97-4188 necessary to correct this issue is to perform l I

and document a code reconciliation demonstrating that the use of NUPIPE with an ASME Ill 1977 edition for the earliest Code of Record selection complies with Unit 3 licensing requirements.

The reconciliation task has been performed and resulted in the conclusion that the use of the NUPIPE analysis was acceptable.

This corrective action has been completed.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0374 has l

identified a condition not previously discovered t>y NU which requires correction. The corrective action necessary to resolve the issue detailed in DR-MP3-0374 will be implemented and tracked under the auspices of condition report M3-97-4188 ( See

( Attached ). The corrective action outlined in Condition Report M3-97-4188 necessary to correct this issue is to perform and document a code reconciliation demonstrating that the use of NUPIPE with an ASME Ill 1977 edition for the earliest Code of Record selection complies with Unit 3 licensing requirements.

l The reconciliation task has been performed and resulted in the conclusion that the use of the NUPIPE analysis was acceptable.This corrective action has been completed.

Attachments:

1) Condition Report M3-97-4188 (12 pages)

Pnnled 5/12/98 2:28:21 PM Page 2 of 4

N:rthent Utilities ICAVP DR N2. DR-MP3-0374 Millstone Unit 3 Discrepancy Report Second Response Response ID: M3-IRF-02203 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0374 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Subsequent to NU's initial response, S&L reiterated an apparent discrepancy regarding the stress intensification factor (SIF) applied at the downstream socket welded end of valve 3RSS*V66 (node point 195 of 'Model A').

NU has determined that the identified discrepancy is not valid.

Stress calculation NP(F)-900-XD, Rev.1, CCN #4 models the piping from node point 195 to node point 200 as an "SRUN" which is defined as a socket welded connection. The NUFIPE computer code automatically applies a SIF of 2.1 at SRUN locations. Therefore, the piping configuration is properly modeled and SIF appropriately considered.

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

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0374 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Subsequent to NU's initial response, l S&L reiterated an apparent discrepancy regarding the stress intensification factor (SIF) applied at the downstream socket welded end of valve 3RSS*V66 (node point 195 of 'Model A').

NU has determined that the identified discrepancy is not valid.

Stress calculation NP(F)-900-XD, Rev.1, CCN #4 models the piping from node point 195 to node point 200 as an "SRUN" which is defined as a socket wolded connection. The NUPIPE computer code automatically applies a SIF of 2.1 at SRUN locations. Therefore, the piping configuration is properly modeled and SIF appropriately considered.

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

Previously identified by NU? O Yes (9) No Non Discrepent Condition?O ves (#) No Resolution Pending?O ve. @ No Re.oiution unre.oived?O ve. ce] No Review initiator: Prakash. A.

VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K Date: $/7/98 SL comments: First Response:

NU's response regarding the issue of ASME Code reconciliation is acceptable. However, the issue regarding the Stress intensification Factors used in Calculation NP(B)-X900-XD has Pnnted S/12/98 2:28:23 PM Page 3 of 4

N:rthenct Utilities ICAVP DR N3. DR-MP3-0374 Millstone Unit 3 Discrepancy Report not been resolved, Specifically, the discrepant condition that no SIF is applied at the downstream socket welded end of valve 3RSS*V66 (NP 195) remains unresolved.

Second Response:

We concur with NU's clarification regarding the SIF issue, and that this issue is a non-discrepant condition.

l l

l l

Printed 5/12/98 228.25 PM Page 4 of 4 ,

1

l N:rthert Utilitiea ICAVP DR N2. DR-MP3-0376 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Teetog DR VALID Potential Operability issue  !

Discipline: Other Discrepancy Type: Correctrve Acton Om System / Process: SWP g

l NRC Significance level: 4 Date faxed to NU:

Date Published: 10/18/97 Discrepancy: Inadequate documentation to verify commitment Close-out. I

Description:

in their response to NRC's Generic Letter describing Service Water System Problems Affecting Safety-Related Equipment (GL 89-13), Northeast Utilities (NU) committed to review Service Water System maintenance practices, operating and emergency procedures, and training program. The objective of the review was to confirm that procedures and program are adequate to ensure safety related equipment will function as intended. In their response to the Request for Information (RFI), which asked for documentation of the NU review, NU did not provide l sufficient information to verify that the review satisfied the l commitment.

The maintenance portion of the supplied documentation identified three periodic inspections, called PM's and made the statement that "Since the above PM's have been generated, this item is complete." No information was provided that indicated what other surveillance /PM's were performed on the safety related equipment or what maintenance procedures were reviewed The Operations portion of the supplied documentation did not document the review of any alarm responses. Only three operating procedures were identified as having been reviewed.

No Justification was provided why other procedures such as Control Room and Plant Equipment Rounds; Train A & B ESF with LOP Test (IPTE), or Operating Strategy for Service Water System at Millstone Unit 3 were not included in the review.

l Additional information is needed to verify the close-out of the commitment to review Service Water System Maintenance practices and operating procedures as described in GL 89-13.

The following discrepancy was noted:

NU did not provide adequate documentation to complete the independent verification of the GL 89-13 Service Water System review.

Review Valid invalid Needed Date initiator: spear, R. O O O 11'1S'S7 VT Lead: Bass, Ken G 0 0 11/21/97 l VT Mgr: Schopfer, Don K 8 0 0 12/iro7  ;

IRC Chmn: singh, Anand K 8 O O 12t3/97 .

l Date: 11/19/97 ,

Pnnled 5/12/98 2:37:51 PM""~ Page 1 of 2 l

l

N rthsect Utilities ICAVP DR No. DR-MP3-0376 Millstone Unit 3 Discrepancy Report ,

i wwauu.

Date:

RESOLUTION:

Previously identified by NU7 O Yes is) No Non Discrepent Condition?O Yes (f) No Resolution Pending?O yes @ No Resolution Unresolved?O ves @ No l Raview Acceptable Not Acceptsbie Needed Date l VT Lead: Bass, Ken VT Mgr: Schopfer, Don K ,

IRC Chmn: Singh, Anand K ,

Date:

SL Comnvents:

l 1

1 Ponted 5/12/98 2.37:55 PM Page 2 of 2

N:rthea .t Utilities ICAVP DR N2. DR-MP3-0380 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Test amcedure Potential Operability issue Discipline: Operh

• Discrepancy Type: Test Requirerrants O Yes Systern/ Process: Oss

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

Date Published: 10/31/97 Discrepancy: Surveillance Procedure Test Methods inadequacies Descripuon: Quench Spray System (OSS) Tech. Specs. Surveillance Requirements are as follows: 4.6.2.1.c. states: "Each Containment Quench Spray subsystem shall be demonstrated operable at least once each refueling interval, by 1) verifying that each automatic valve in the flow path actuates to its correct position on a CDA test signal, and 2) verifying that each spray pump starts automatically on a CDA test signal." The test methods used in the applicable surveillance procedures, SP-3646A.17 & 18, and OPS Forms 3646A.17-1 & 18-1, may be inadequate to demonstrate operability of either the QSS "A" or "B" Train components.

Procedure step 4.1.3 requires the pump circuit breaker to be placed in the REMOTE TEST position, and it remains there throughout the test. This methodology activates the circuit breaker indicating lights but does not check the breaker auxiliary contacts operation, or that the breaker would have operated to start the pump with a CDA signal.

Automatic valves in the flow path which are required to actuate to the correct position on a CDA test signal are 3QSS"MOV34A

& B. For 3QSS*MOV34A, the Train A valve, the test was marked "Not Tested" on OPS Form 3646A.171, Section C, Pg.

9, and it was not verified that the valve opened on a CDA signal.

The form cover page also contains a note stating that the MOV34A test was not performed, along with a reference te a retest performed on OPS Form 3646A.17-2. Retest data was not attached to the surveillance data package, and retest results, if any, are unknown.

Other problems were noted as well:

1) OPS Forms 364BA.17-1 & 18-1 Jumper Document Sheets, Sections F & G, were all marked as "Not Applicable." This procedure requires a significant number of Jumpers to be installed. Based on the test data reviewed, it cannot be determined that appropriate jumpers were installed to property configure the system to support the intent of the test.

2) Test methodology is confusing and extremely hard to follow.

SIS and LOP tests are performed almost simultaneously, l followed very closely by a CDA test, using a single test procedure. Results of all three tests are recorded in multiple sections of the OPS forms, and no one form section seems to .

apply exclusively to any one test. The related procedure steps l f are not included on the data collection forms, and doubt exists as l l

Pnnted 5/12/98 2:29:09 PM ge 1 of 6 I

Northent Utilities ICAVP DR Ns. DR-MP3-0380 wilstone Unit 3 Discrepancy Report which test. Load shedding is supposed to be verified on the the forms, but there is no procedure step that clearly identifies this requirement. There is a great potential for error on the part of the procedure performer, espec: ally if he hasn't performed the procedure several times before. Since this is an infrequently used procedure, it is unlikely that the performer will have a great amount of experience performing it.

It is concluded that these t, surveillance test procedures may be inadequate to perform their stated function of satisfying Tech.

Specs. requirements. Additionally, the testing requirements of NRC Generic Letter No. 96-01," Testing of Safety-Related Logic Circuits," may not have been met.

Review Valid inval6d Needed Date Initiator: Petrosky.Al. 8 0 0 10/16S7 VT Lead: Bass. Ken O O O 10/17/S7 VT Mgr: schopfer, Don K S O O or23S7 IRC Chrrus: singh. Anand K B O O 1or28/97 Date:

INVAllo: )

l Date: 5/11/98 )

RESOLUTION: DISPOSITION: l NU has concluded that Discrepancy Report, DR-MP3-0380, has identified a condition previously discovered by NU which requires correction.

NU conducted an extensive review of MP3's compliance with GL 96-01 in response to LER 97 017 (see attached Root Cause investigation.) During this review, one portion of the ESF / LOP test was found to not comply with Tech Specs. Tho testing method for the Control Room Ventilation Chilled Water Chillers I was inadequate (see attached CR M3-97-D17). LER 97-017 l (attached) documents this deficiency and all other reportable i deficiencies associated with the 96-01 review. Non-reportable deficiencies that were identified during the 96 01 review, were  ;

documented on CRs (see the attached list of associated CRs.)  !

Corrective actions for these CRs are required prior to startup.

This is the only item that NU concludes to be discrepant.

Running the ESF / LOP test v.ith the QSS pump breaker in

• remote test" does not check the auxiliary contacts or verify that the CDA signal will start the pump. The quarterly pump surveillance, SP 3609.1 and 3609.2 (attached) verifies that the pumps start from ti,e sequencer, Slave relay testing, SP 3646A.8 and 3646A.D (see References at end of this section),

verify tl~..t the sequencer. when simulating a CDA signal, provides the signals to the breakers. These two together provide verification that the auxiliary contacts would have operated to start the pump on the CDA sign &l.

ESF / LOP testing of various RSS and QSS components was not Pnnted 5/12/96 2:29:12 PM Page 2 of 6

N:rthea:t Utilities ICAVP DR N2. DR-MP3-0380 milistone unit 3 Discrepancy Report completed in June of 1996 during the scheduled ESF / LOP test because of ongoing work on the systems. In addition, the retests for these components have not been completed due to continuing design and field work. SP 3646A.18 (see References) is completely signed off. 3646A.17 is awaiting completion of RSS and QSS retests. When all retests are complete, the sign-off copy of SP 3646A.17 will be finished. (NOTE: ESF / LOP testing will be completed again in its entirety prior to startup and is currently scheduled for January,1998.)

While the components not tested are listed on the cover sheets for 3646A.17-1 and 3646A.18-1, there is no written description of why the components were not tested. There is no formal requirement for this documentation, but including this information would be beneficial. Those components not tested or retested immediately are not required by Tech Specs in MODE 5 (Ref. Tech Specs 3.6.2.1 and 3.6.2.2), management decided that not having them available for the scheduled test and retesting them at a later date was acceptable.

The jumpers for Hi Hi Steam Generator level (Section G) were j installed in anticipation of the test on 5/7/96 per AWO M3 06798 (attached.) Steps 4.1.9 in 3646A.17 and 3646A.18 were appropriately signed-off in the procedures as there was still a need to clear the FWI signal. Both tests were lacking in that the AWO should have been referenced to provide better documentation of the test requirements.

l The first jumper required for Section F is associated with step 4.1.24 in 3646A.17 and step 4.1.25 in 3646A.18. The steps state: "If 3HVU-FN2A(B) is available, START 3HVU-FN2A(B), ,

otherwise PERFORM the following steps..." Because the fan  !

was available, it was started and the subsequent steps were not required. There was no need to install the jumpers called for in the steps that followed. The same applies to the last portion of Section F which documents removal of the jumper.

The second jumper required for Section F is associated with the pressurizer heater,3RCS*H1B. Step 4.1.32 in 3646A.17 and 3646A.18 allows for two possible conditions: 1. Pressurizer level is below the letdown isolation setpoint end a jumper is required; or, 2. Pressurizer level is above the letdown isolation setpoint and no jumper is required. Pressurizer level was above the letdown isolation setpoint, so no jumper was required.

The ESF / LOP test is a complex surveillance that requires integration of many departments and disciplines. For this reason, extensive pre-job briefs are held to ensure that all personnel understand their roles and responsibilities during the test. The only personnel or procedural mistake that occurred during the test was associated with 3HVU-FN1 A and is discussed in detail in DR-MP3-0338 item 5. In addition, at times when major events occur in the test (LOP or CDA), multiple people are assigned to obtain data. While the surveillance form may appear overwhelming, the work load is split among many people to prevent errors.

Pmted 5/12/98 2.29:14 PM Page 3 of 6

ICAVP DR Ns. DR-MP3-0380 N::rth=ct Utilities l Millstone Unit 3 Discrepancy Report Step 4.4.14 in 3646A.18 and step 4.4.13 in 3646A.17 directs documentation of load sequencing. While it is not explicitly written, the intent of the step is to also document proper load l

shedding. This will be changed in the next revision to specifically direct documentation of load shedding.

NU concurs with the significance level of the issue regarding GL 96-01, Overlap testing inadequacies. All other issues in this DR are not discrepant and, therefore, no significance level applies.

CONCLUSION:

NU has concluded that Discrepancy Report, DR-MP3-0380, has identified a condition previously discovered by NU which requires correction. The issues relating to GL 96-01 were previously discovered by NU to be discrepant. However, the ESF / LOP test performed in June 1996 was performed satsifactorily and all applicable Tech Spec requirements were satisfied. The inadequacies of GL 96-01 Overlap Testing is a discrepant condition and is well documented in 3 revisions of l I

LER 97-017 and in numerous CRs. Corrective actions are in progress and required prior to startup. l The QSS pumps' auxiliary contacts are tested via the overlap testing program. This is accomplished by slave relay testing (CDA signal to the sequencer) and quarterly pump testing (sequencer to the breaker.) The automatic valves in the QSS flow path were not tested during that ESF / LOP test because they were tagged out of service for work. Retests will be performed when work on the components is completed.

Jumpers for Steam Generator levels were installed under AWO M3-96-6798. This could have been better documented within the test procedure, but technically was not required. Other jumpers for Section F were not installed as they were not procedurally required.

The ESF / LOP test is a complex surveillance that requires integration of many departments and disciplines. For this reason, extensive pre-job briefs are held to ensure that all personnel understand their roles and responsibilities during the test.

' NU concurs with the significance level of the issue regarding GL 96-01, Overlap testing inadequacies. All other issues in this DR are not discrepant and, therefore, no significance level applies.

l NU's revised response:

Disposition:

NU has concluded that the GL 96-01 issue reported in Discrepancy Report DR-MP3-0380 has identified a PREVIOUSLY IDENTIFIED condition and the other issues reported in Discrepancy Report DR-MP3-0380 are NON.

DISCREPANT. The attached Feedback / Notes Report for SP Prmted 5/12/96 2:29:15 PM Page 4 of 6 c______

1 N:rthert Utilities ICAVP DR N2. DR-MP3-0380 l

l Millstone Unit 3 Discrepancy Report 3646A.15, Revision 12, SP 364JA.16, Revision 9, SP 3646A.17, Revision 10, and SP 3646A.18, Revision 11, show the feedback notes for these procedures have been clarified to define "other exceptions

• as large loads, MOVs or yther equipment that would effect dieselloading or the integrity of the test. Technical Support Engineering has reviewed the feedback notes related to this Discrepancy Report for these procedures and concurs with the proposed enhancements. They also agree that except for pumps there are no other exceptions that have the potential to automatically invalidate the test. Engineering signifies their review and concurrence by signing as Technical Reviewer on this IRF.

NU previously concurred with the significance level 3 for the issue identified in DR-MP3-0380 regarding GL 96-01 overlap testing inadequacies. All other issues in this DR were determined to be non-discrepant and therefore, no significance level applies.

Conclusion:

NU has concluded that the GL 96-01 issue reported in 4 Discrepancy Report DR-MP3-0380 has identified a l PREViOUSLY IDENTIFIED condition and the other issues reported in Discrepancy Report DR-MP3-0380 are NON-DISCREPANT. The attached Feedback / Notes Report for SP 3646A.15, Revision 12, SP 3646A.16, Revision 9, SP 3646A.17, Revision 10, and SP 3646A.18, Revision 11, show the feedback notes for these procedures have been clarified to define "other exceptions". Technical Support Engineering has reviewed the feedback notes related to this Discrepancy Report for these procedures and concurs with the proposed enhancements. They also agree that except for pumps there are no other exceptions that have the potential to automatically invalidate the test.

Engineering signifies their review and concurrence by signing as Technical Reviewer on this IRF.

NU previously concurred with the significance level 3 for the issue identified in DR-MP3-0380 regarding GL 96-01 overlap testing inadequacies. All other issues in this DR were determined to be non-discrepant and therefore, no significance level applies.

Previously identified by NU? O Yes (*J No Non Discrepent condition?O Yes (*) No Resolution Pending?O yes @ No Resolution Unresolved?O vos @ No Review Acceptable Not Acceptable Needed Date initlator: spear, R VT Lead: Bass, Ken B O O 5'1 'S8 VT Mgr: schopfer, Don K O O O 5'15/S8 IRC Chmn: singh, Anand K O O O 5/12/90 O O O Date: 5/1/98 sL comments: S&L concures that the GL 96-01 issue is a previously identified condition. S&L has reviewed NU's three responses to this DR l and has determined that the facts support a Level 4 Discrepancy.

l Printed 5/12/98 2:29:16 PM Page 5 of 6

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N::rthert Utilities ICAVP DR N3. DR-MP3-0380 Millstone Unit 3 Discrepancy Report NU acknowledgment that the ESF/EOP procedures will be enhanced, that steps will be added to cocument that the OPS manager or the Unit Director will approve all component I exceptions prior to testing, and the indication that the procedures will be enhanced with regards to equipment exceptions during testing in addition to the information described in the Discrepancy i Report is the basis for S&L's position that this is a discrepant l condition. As indicated above, this discrepancy has been l downgraded to a Level 4 based on NU's information and l responses. I 1

Pnnted 5/12/98 2:29:18 PM Page 6 of 6

N rther_t Utilitie3 ICAVP DR No. DR-MP3-0386 MiiistOne Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: Piping Design Discrepancy Type: calculation O ves (ii) No system / Process: sWP NRC Significance level: 4 Date faxed to NU:

Date Published: 10/23/97 Discrepar.cy: Small bore calculation does not reflect the latest header movements from large bore piping analysis.

Description:

In the process of reviewing the calculation no.12179-NP(B)-

X9904, it was noted that calculation utilizes header displacements and accelerations from revision 0 of the large bore piping analysis 12179-NP(B)-X1903.

The current revision of the large bore piping calculation is revision 3. The small bore calculation 12179-NP(B)-X3904, REV. 3, CCN #2 has not been updated to incorporate the latest header displacements and accelerations.

Review l' Valid invalid Needed Date initiator: singh, R. O O O 10/3'87 VT Lead: Neri, Anthony A O O O 1o/7/97 VT Mgr: schor,'er, Don K 8 O O 'o/14/97 IRc Chrnn: singh,i nand K 8 0 0 1o7/87 Date:

INVALID:

Date: 5/7/98 RESOLUTION: Response ID: M3 - IRF - 02135 Disposition:

NU has concluded that this issue reported in DR-MP3-0386 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 CONDITION which requires correction. The approved corrective action plan for CR M3-98-1874 will revise calculation 12179-NP(B)-X9904 after startup to include the header displacements and accelerations from calculation 12179-NP(B)-X1903. A review of the revised displacements indicates the differences are insi0nificant. The only displacements which are larger are the static displacements (0.008,0.003, and 0.002 inches in the X, Y, and Z directions respectively). All other displacements are l smaller than the previously assumed value. There is no impact i on the calculation conclusions.

l

Conclusion:

l NU has concluded that this issue reported in DR-MP3-0386 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 CONDITION which requires correction. The approved corrective action plan for CR M3-98-1874 will revise calculation 12179-NP(B)-X9904 after startup to include the header displacements and accelerations from calculation 12179-NP(B)-X1903. The conclusions of calculation 12179-NP(B)-X9904 are not impacted.

Attachments: CR M3-98-1874 with approved corrective action Pnnted 5/12/96 2:29 40 PM Page 1 of 2

ICAVP DR No. DR-MP3-0386 N:rtheart Utilities Millstone Unit 3 Discrepancy Report plan Previously identired by NU7 U Yes (8) No Non Discrepent Condition?O Yes (8) No Resolution Pending?O Ye. @ No Resoiotionuoresoived70 Yes @ No Review Ce e ceMa M Date initiator: Prakash, A.

O O =

VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K O O Si m IRC Cluta: Singh, Anand K O O si m O O O Date: 5/7/98 SL comments: We concur with NU's assessment of the revised displacements, and that there is no impact on the calculation conclusions. The approved corrective action plan to revise calculation 12179-NP(B)-X9904 after startup is acceptable.

Prtnted 5/12/98 2:29.44 PM Page 2 of 2

trthert Utilities ICAVP DR N2. DR-MP3-0484 Millstone Unit 3 Discrepancy Report i

l Review Group: System DR f4EsOLUTION ACCEPTED l l

Review Element: systern Design Potential Operability issue l Discipline: Mechanical Design O ves Discrepancy Type: Calculation

@ No SystenVProcess: RSS NRC Significance level: 4 Date faxed to NU:

Date Published: 11/2497 Discrepancy: RSS Overpressure Protection items l

Description:

Calculation P(R)-1192 (Rev,0) determines the overpressure protection requirements for the RSS System. The requirements are based on the pressures and temperatures from the Stress Data Package (SDP), SDP-RSS-1361, Rev. 4.

1. The calculation Indicates that the limiting design condition from the SDP is Condition 1. For the limiting temperature, this is not the case for the piping downstream of Valves MOV8837 A/B and MOV8838 A/B. For the limiting pressure, this is not the case for any of the piping. j

2. The calculation indicates the design conditions for the pump suction piping, according to the SDP, are 40 psig @ 256 'F. The design conditions from the SDP are 39 psig @ 257 *F. This will have an insignificant affect on the calculation.

3. Numerical error in interpolation for the pump discharge piping. The calculation indicates the maximum design pressure at 260 'F is 459 psir,. Linear interpolation between the value given in ASME Section lit,1971 results is a pressure of 456 psig.

4. The calculation indicates the design conditions for the pump discharge piping, according to the SDP, are 260 psig @ 256 'F.

The design conditions from the SDP are 190 psig @ 257 'F.

This will have an insignificant affect on the calculation. l l

S. The calculation indicates the design conditions for the containment piping, according to the SDP, are 148 psig @ 116

'F. The design conditions from the SDP are 150 psig @ 257 'F.

The maximum design pressure at 116 'F for Pipe Class 153 is 270 psig. The maximum design pressure at 257 *F is 223 psig.

This is non-conservative.

6. Solenoid Valves SOV50A/B do not exist any longer and should be removed from the calculation.

Review Valid invalid Needed Date initiator: Langel, D. O O O 11 '97 O O 5'1 'S7 VT Lead: Nort, Anthony A O VT Mgr: schopfer, Don K O O O $ $'27'S7 O O O 1 i2o/97 1RC Chmn: smgh, Anand K Date:

INVALID:

Date: 5/7/98 Pnnted 5/12/98 4 02:29 PM Page 1 of 2

1

\

ICAVP DR N2. DR-MP3-0484 N:rthenct Utilitie3 Miiistone Unit 3 Discrepancy Report 1

REsOLUTKW: Disposition:

NU has concluded that the issues reported in DR-MP3-0484 have identified CONFlRMED SIGNIFICANCE LEVEL 4 conditions which require correction. These discrepancies meet the criteria specified in NRC letters B16901 and 17010.

l S&L has compared the Stress Data Package (SDP) calculation, Rev. 4 issued in the 1997 time frame with the original issue of the Overpressure Protection Analysis Calculation, Rev. O issued in the 1985 time frame. The OP calculation should have been updated when the SDP was revised and issued. There is no violation of the LB or DB since the design pressures and temperatures are still greater than the maximum operating pressures and temperatures.

Condition Report M3-98-2313 will be closed out to Bin CR M3 0138. The corrective actions for CR M3-98-0138 will revise the Overpressure Protection Analysis Calculation post startup.

Conclusion:

NU has concluded that the issues reported in DR-MP3-0484 have identified CONFIRMED SIGNIFICANCE LEVEL 4 conditions which require correction. These discrepancies meet the criteria specified in NRC letters B16901 and 17010. They have been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meet section 1.3.2.e of U3 PI 20 deferral criteria. The Stress Data l Package (SDP) calculation, Rev. 4 (1997 time frame) was compared to the originalissue of the Overpressure Protection Analysis Calculation, Rev. 0 (1985 time frame). The OP calculation should have been updated when the SDP was revised and issued. There is no violation of the LB or DB since the design pressures and temperatures are still greater than the i maximum operating pressures and temperatures. The corrective l actions for Bin CR M3-98-0138 will revise the Overpressure Calculation post startup.

Previously identified by NU7 U Yes @ No Non Discrepent Condition?O Yes @ No ResolutionPending?O Yes @ No Re.oiution unre.oived70 ve. @ No Review

' initietor: Langel, D.

VT Lead: Nerl. Anthony A

< VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Dete:

SL Comments:

Printed 5/12/98 402:33 PM Page 2 of 2

Ncrth:ast Utilitiss ICAVP DR No. DR-MP3-0537 Millstone unit 3 Discrepancy Report Review Groep: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: calculaton Om g-Systern/ Process: Oss NRC Significance level: 4 Date faxed to NU:

Date Published: 11/24/97 Discrepancy: Calculation P(R)-943

Description:

Calculation P(R)-943 (Rev. 0; CCN 1) determines the overpressure protection requirements for the QSS System. The requirements are based on the operating pressures and temperatures from the Stress Data Package (SDP), SDP-QSS-1358, Rev. 6.

1. The calculation indicates the pump discharge piPing design conditions are 175 psig @ 150 'F. The limiting temperature from the SDP is 242 'F. The maximum design pressure for Class 153 piping at 242 'F is 227 psig. This is still higher than the design pressure of 175 psig.

2. The calculation indicates the pump suction piping design conditions are 60 psig @ 150 'F. The design conditions from the Line List are 40 psig @ 140 'F. The maximum design pressure at 150 *F for Pipe Class 153 is 258 psig. The maximum design pressure at 140 'F is 261 psig. The maximum design pressure used in the calculation is conservative.

Review Valid invalid Needed Date initiator: Langel. D. O O O 15' 1/S7 VT Lead: Neri, Anthony A B O O 1 /87 VT Mgr: schopfer Don K O O O $1/17/97 IRC Chmn: singh, Anand K O O O i i20/97 Date:

INVALID:

Date: 5/7/98 RESOLUTION: Disposition:

NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0537, has identified a CONFlRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria, in item 1 Calculation P(R)-943 is discrepant in that it does not reflect the current design conditions. DCR M3-96063 (attached),

as revised by DCN DM3-00-0163-98 (attached), has raised the design temperature of the QSS discharge piping to 260 degrees F. This is above the 242 degrees F specified in the Stress Design Package, thereby satisfying that design requirement.

(Note that this change was made by CR M3-98-0334 (attached)

Printed 5/12/98 4 02:59 PM Page 1 of 2

l e, 1 N:rthe ct Utilitie2 ICAVP DR N2. DR-MP3-0537 i Millstone Unit 3 Discrepancy Report l in response to DR-MP3-00515, which identified the sama l discrepancy in Calculation P(R)-1171.) Calculation P(W K3 will be revised to reflect the correct design condition,260 d@es F, after startup.

In item 2 the design condition was changed from 60 psig/150 degrees F to 40 psig/140 degrees F on Revision 12 of FSK 27-128. Calculation P(R)-943 (attached) should have been changed at this time, but was not. Subsequently CCN #1 to P(R)-

943 (attached) deleted the FSKs as a reference and substituted the P&lDs. The FSKs should have been replaced by both the P&lD and the Line List, since the FSKs wero originally referenced for both the line numbers and the design conditions.

Because the FSKs were not used as input, Revision 12 of FSK ,27-12B did not get incorporated into Calculation P(R)-943. l Calculation P(R)-943 will be corrected to reference the Line List, I and the correct values for the design conditions,40 psig/140 degrees F, will be incorporated after startup. There is no effect on License or Design Basis. CR M3-98-2313 was closed to bin CR M3-98-0138. The approved corrective action for CR M3098-0138 will correct Calculation P(R)-943 post startup.

Conclusion:

NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0537, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria.

Calculation P(R)-943 will be corrected to incorporate the correct design conditions for the QSS discharge Diping,260 degrees, and for the suction piping,40 psig and 140 degrees. The corrective actions of CR M3-98-0138 will correct the calculation's deficiencies post startup. There is no affect on License or Design Basis.

Previously identirmd by Nu? O Yes @ No Non Discrepant Condition?U Yes @ No Resolution Pending?O Ye. @ No Resoiution unre.oiv.d?O ve. @ No Review initiator: Langet, D.

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

sL Conwnents:

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l Printed 5/12/98 4 o3:03 PM Page 2 of 2 l

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l N:rthert Utilities ICAVP DR No. DR-MP3-0557 Millstone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED i

Review Element: System Installation

! Potential Operability lasue Discipline: Electrical Design l Discrepancy Type: Installation Irnpiementation O vos SystemrProcess: RSS 9 No NRC significance level: NA Date faked to NU:

j Date Published: 11/9/97 Discrepancy: Wall Penetration sealing not in accordance with commitment

Description:

1. Conduit 3CX970G is routed though a wall penetration which has a 4 inch conduit encased within it. The encased sleeve was observed to be sealed only with Kaewool Response to questions on the Fire Protection Evaluation, all penetrations will be sealed with silicone. Further, this embedded sleeve is not shown on any of the wall penetration drawings.

Review Valid invalid Needed Date initiator: sarver, T. L.

8 O O o'18'87 l VT Lead: Nort, Anthony A B O O o/27/97 l VT Mgr: schopfer, Don K B O O 1o/28/97 1RC Chmn: singh, Anand K B O O 11/5/87 l Date:

INVALID:

Date: 5/11/98 RESOLUTION: INITIAL RESPONSE:

l l

l Disposition-l I

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0557, does not represent a discrepant condition. ,

Conduit 3CX970G could not be found in the TSO2 Database,  !

! therefore it is assumed that the conduit in question is )

3CX9700G, which passes through the Supplemental Leak J Collection and Release System (SLCR) wall in the ESF Building. The Wall Penetration MAP Drawings 25212-24279-l ES007A, ES007B and ES007C (attached) show blockout #10 l with several sleeves and conduits including 3CX9700G which passes through the sleeve designated as "E". A Design Engineering inspection in the field concluded that looking West l at the G.7 Line wall, the blockout was found to be sealed with l high density silicone elastomer and the sleeve sealed with l

silicone foam. Looking East at the G.7 Line wall, the sleeve was observed to be dammed with kaewool to stop the foam from running out when applied. Both of these seats comply with the design requirements specified on the above drawings and are j installed per the installation requirements of drawing 25212- l

, 29680, sheet 23 (attached).

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

Conclusion:

Printed S/12/98 4.03:32 PM Page 1 of 3 I i

L

N:rthert Utilities ICAVP DR Ns. DR-MP3-0557 Millstone Unit 3 Discrepancy Report l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0557, does not represent a discrepant condition.

l Conduit 3CX970G could not be found in the database, therefore i it is assumed that the conduit in question is 3CX9700G, which I l passes through the Supplemental Leak Collection and Release System (SLCRS) wallin the ESF Building. The Drawings (attached) for this area show blockout #10 with several sleeves and conduits including 3CX9700G which passes through the l sleeve designated as *E". A field walkdown concluded that the blockout was sealed with high density silicone elastomer and the sleeve was sealed with silicone foam on the west side of the wall and was dammed with kaewool on the east side (may be left in l place) to stop the foam from running out when applied. Both of these seals comply with the design requirements specified and are installed per the installation requirements of drawing 25212- l 29680, sheet 23 (attached). Significance Level criteria do not l apply here as this is not a discrepant condition.

l SECOND RESPONSE:

Disposition: l NU has concluded that this issue reported in Discrepancy report, DR-MP3-0557, has identified a NON-DISCREPANT condition. A review of drawing EM-60A & B (attached) for the rating of this wall indicates it is classified as a SLCRs, Fire, Radiation and i Water boundary. Water is not a concem however since the l blockout is above the flood line of EL 3'-9". Wall penetration drawings 25212-24279-ES007A, ES007B & ES700C detailed the blockout to be sealed with high density silicone elastomer (E-11),

which is rated for radiation in any combination with fire / air / water per drawing 25212 29680-00010 (attached). The two spare sleeves installed at the time the blockout was sealed were to be sealed with high density silicone elastomer (E-5) per E&DCR F-E.

41212 (attached). Prior to the sealing of both spare sleeves, penetration EWEB5 - E was used to run conduit 3CX9700G i

through the G.7 line wall per E&DCR F-E-43847 (attached). This E&DCR required the sleeve and conduit to be sealed with high density silicone elastomer (E-5) and (E-11). Before these seals were installed, an ALARA review was performed which relaxed the radiation resistant seal to Silicone Foam (E18). This was documented on E&DCR N-CS-01014 (attached) which is referenced in the remarks column on drawing 25212-24279-l ES007C for penetration EWE 85 - E & G. Also referenced in the remark column of several sleeves in E&DCR N-CS-04394 (attached) which documents the additional ALARA reviews and the resulting softer density seal. As a result, blockout #10, penetration EWE 85 - D, E, F and G are sealed correctly and applicable drawings document the installed configuration.

Significance Level criteria do not apply here as this is not a <

discrepant condition.

Printed 5/12/98 403:35 PM Page 2 of 3 l

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N;rtherct Utilities ICAVP DR NL DR-MP3-0567 Millstone Unit 3 Discrepancy Report

Conclusion:

! NU has concluded that this issue reported in Discrepancy report, l l DR-MP3-0557, has identified a NON-DISCREPANT condition. j i Wall penetration drawings 25212-24279-ES007A, ES0078 & I l ES700C detailed the blockout to be sealed with high density j l

silicone elastomer (E-11), which is rated for radiation in any combination with fire / air / water per drawing 25212-29680-00010 (attached). The two spare sleeves installed at the time the blockout was sealed were to be sealed with high density silicone l elastomer (E-5) per E&DCR F-E-41212 (attached). Prior to the i

sealing of both spare sleeves, penetration EWE 85 - E was used to run conduit 3CX9700G through the G.7 line wall and ealed with high density silicone elastomer (E-5) and (E-11) per E&DCR F-E-43847 (attached). Prior to installation, an ALARA review was performed which relaxed the radiation resistant seal to Silicone Foam (E18). As a result, blockout #10, penetration EWE 85 - D, E, F and G are sealed correctly and applicable drawings document the installed configuration.

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

Previously identified by NU? O Yes @ No Non Discrepent Condition?@ Yes O No Resolution Pending?O ve. @ No Resolution unresolved?O ve. @ No i Review l Initiator: Warner, l.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Date: 5/11/98 )

sL Cornments: INITIAL COMMENTS:

1 We concur with your assumption that the correct conduit is l 3CX9700G. However, we have a question with respect to the l

appropriate seal detail. In your response you state that the seal I complies with the design requirements of drawing 25212-29680, sheet 23. While we don't disagree with that statement we do question the type of seal being used. Blockout #10, shown on

! drawing 25212-24279, Sh ES007 indicates that the seals are to be configured for "T.S, Fire, SLCRS and Radiation". Detail "CRF" on sheet 23, which matches the description of the actual configuration, is rated for fire and/or air, it appears that the correct detail might be detail M4A on drawing 25212 -29680 sheet 1, or some other detail clearly radiation rated. Without an explanation of why detail"CRF"is acceptable, we have left this DR as a level 4 discrepancy.

COMMENTS ON NU*S SECOND RESPONSE We accept NU's response.

Printed s/12/98 4.03:37 PM Page 3 of 3

N:rthent Utilities ICAVP DR N3. DR-MP3-0608 Millstone unit 3 Discrepancy Report Review Group: F'rogiammatic DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Discipline: Operations

• "

• I'**"*

Discrepancy Type: Corrective Action System / Process: N/A g j NRC Significance level: NA

{

Date faxed to NU:

Date Published: 11/22/97 Discrepancy: Lack of Generic implications Assessment i

Description:

MP3 LER 97-020-00 provides a description of a condition where the design placement of flow throttle valves for cooling water to the containment air coolers was set such that insufficient cooling would be provided to the containment during a loss offsite power condition. The issue is primarily related to inadequate cooling for an operator to perform credited fire event related mitigation actions in the containment. The action requests generated by NU to address this issue appear to be limited to remediation of this particular issue. The NU corrective action for this condition did not include an assessment of the generic implications on l other post-fire credited actions with regard to conditions that could interfere with completion of the required actions.

Attemately, a review could be made to determination if the existing basis documentation for these actions adequately accounts for such conditions. Specifically, such a review or basis should consider design and operation subtleties that might be overlooked relative to environmentalimpacts or other obstructions to complete the actions.

Review

Valid invalid Needed Date initiator

Bennett, L. A.

I 8 O O 1 '11/97 VT Lead: Ryan, Thomas J B O O 11i12/97 VT Mgr: schopfer, Don K G O O 31/12/97 IRC Chmn: singh, Anand K B O O 1ita/97 Date:

INVALID:

Date: 5/8/98 1

RESOLtrilON: Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0608, does not represent a discrepant condition. The corrective action for CR M3-97-0392 did require an evaluation of environmental conditions for operator action feasibility for containment entry, it was considered adequate to only look at ,

the containment because this condition was believed to be an I isolated issue, and that loss of ventilation would have no significant impact on operator action for other fire events. An additional CR M3-97-0634 identified problems with the ability to perform a safe shutdown if all charging pumps were lost. As part of that CR's corrective action, AR 97005496-04 required a l review of Altemate shutdown capability credited actions to ensure compliance with performance goals. Compliance with the performance goals ensures a safe shutdown. ERC 25212-ER-97-0007, Manual Action Fessability" documents this review.

Printed 5/12/98 4:04:31 PM Page 1 of 5 L_______________.--__.-.________----__ - - - - _ . _ .-

N:rthert Utilities ICAVP DR N2. DR-MP3-0608 Millstone Unit 3 Discrepancy Report i This report summarizes the results of a number of activities that l relate to feasibility of manual operator actions taken as a result l of a fire. The development of EOPs for all fire areas ensured I that operator access to various areas of the plant was pcssible for the manual actions, (i.e. that actions did not require entry to l the area (or zone) on fire until after the fire has been i extinguished.) The ERC also evaluate the use of emergency l lighting and communications that support operator actions during I a fire event. In this regard, these reviews ccptured design and operational subtleties and other obstructions that may have impacted the operator action. However, it must be noted that specific evaluations on loss of ventilation on operator action was l not included in these reviews. l Significance level criteria do not apply here as this is not a l discrepant condition.

Conclusion l

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0608, does not represent a discrepant condition. The corrective action for CR M3-97-0392 did require an evaluation of environmental conditions for operator action feasibility for containment entry. It was considered adequate to only look at the containment because this condition was believed to be an isolated issue, and that loss of ventilation would have no j

significant impact on operator action for other fire events. ERC 25212-ER-97-0007, Manual Action Feasibility" documents this review. This report summarizes the results of a number of activities that relate to feasibility of manual operator actions taken as a result of a fire. The development of EOPs for all fire areas ensured that operator access to various areas of the plant was possible for the manual actions, (i.e. that actions did net require entry to the area (or zone) on fire until after the fire has been extinguished.) The ERC also evaluate the use of emergency lighting and communications that support operator j actions during a fire event. In this regard, these reviews captured design and operational subtleties or other obstructions l that may have impacted the operator action.

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

1 NU's second Disposition NU has concluded that the issue reported in DR-MP3-0608 has identified a NON-DISCREPANT condition. The intent of the statement referred to was to clarify that specific heat up calculations have not been performed for ALL scenarios on loss of ventilation for plant systems. It was intended to mean that the operator can re-enter the areas required and he would not be going into an area on fire or an area suspected of being ,

inaccessible. The loss of a train of a ventilation system will l render safe shutdown equipment that the train services .

Inoperable, unless the redundant train of ventilation is cross tied I and can supply both trains of safe shutdown eauloment. If l Printed 5/12/98 4:04:34 PM Page 2 of 5 l

ICAVP DR No. DR-MP3-0608 N:rthea:t Utilities Millstone Unit 3 Discrepancy Report cooling is not available, the SSD equipment is not relied upon for shutdown.

Most, if not all operator actions are performed on the train relied upon for shutdown. In almost all cases, this train will have l ventilation to support system operability, hence, operations l l

personnel will be able to perform their actions. We conclude that '

l the containment issue was an isolated fire scenario. Loss of ventilation for both trains occurs for a specific Aux building fire area (AB-1) and the containment building. Review of the Compliance Report indicates that all other fire areas have either redundant ventilation systems to support system operation or

loss of both ventilation systems will not affect shutdown (e.g.

loss of control room cooling is mitigated by a control room l evacuation and using the aux shutdown panel). This is why the conclusion was reached that the issue is not discrepant and was l

isolated to the containment fire only.

The BTP 9.5-1 Compliance Report evaluates the loss of i ventilation due to fire on the operability of systems required for safe shutdown. Critical scenarios have been evaluated by calculations (aux building and containment) to ensure that temporary ventilation or at least one CAR fan is available to mitigate these losses. Actions are in place to instruct the operators to open doors and or place temporary fans in service if required for additional cooling. NU also addressed the DR conceming other issues besides ventilation that may prohibit the operator from performing his required actions, such as emergency lighting in the arec, his ability to get to the area once l the fire has been extinguished, and his ability to communicate with the control room. These are operational subtleties and other ,

obstructions that may have impacted the operator action. The l Compliance report addresses these issues, as well as ventilation issues on a global sense, in summary, based upon a review of the BTP Complianco l

Report's ventilation summary, we conclude that this issue i:, an l isolated event.

l

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

NU's second Conclusion l

l NU has concluded that the issue reported in DR-MP3-0608 has

! identified a NON-DISCREPANT condition. The intent of the statement referred to was to clarify that specific heat up

, calculations have not been performed for ALL scer.arios on loss l of ventilation for plant systems. It was intended to mean that the l operator can re-enter the areas required and he would not be going into an aies on fire or an area suspected of being inaccessible. The loss of a train of a ventilation system will render safe shutdown equipment that the train services inoperable, unless the redundant train of ventilation is cross tied and can supply both trains of safe shutdown equipment. If coolina is not available. the SSD eculpment is not relied upon for Printed 5/12/98 4:04:35 PM Page 3 of 5

Northeast Utilities ICAVP DR No. DR-MP3-0608 Millstone Unit 3 Discrepancy Report shutdown.

Most, if not all operator actions are performed on the train relied l upon for shutdown. In elmost all cases, this train will have l ventilation to support system operability, hence, operations l

personnel will be able to perform their actions. We conclude that the containment issue was an isolated fire scenario. Loss of ventilation for both trains occurs for a specific Aux building fire f

area (AB-1) and the containment building. Review of the Compliance Report indicates that all other fire areas have either redundant ventilation systems to support system operation or loss of both ventilation systems will not affect shutdown (e.g.

loss of centrol room cooling is mitigated by a control room evacuation and using the aux shutdown panel). This is why the conclusion was reached that the issue is not discrepant and was 7 t

isolated to the containment fire only. The BTP 9.5-1 Compliance (

Report evaluates the loss of ventilation due to fire on the operability of systems required for safe shutdown. Critical scenarios have been evaluated by calculations (aux building and containme9t to ensure that temporary ventilation or at least one CAR fan is available to mitigate these losses. Actions are in place to instruct the operators to open doors and or place temporary fans in service if required for additional cooling. NU also addressed the DR conceming other issues besides ventilation that may prohibit the operator from performing his required actions, such as emergency lighting in the area, his ability to get to the area once the fire has been extinguished, and his ability to communicate with the control room. These are operational subtleties and other obstructions that may have impacted the operator action. The Compliance report addresses these issues, as well as ventilation issues on a global sense, in summary, based upon a review of the BTP Compliance Report's ventilation summary, it is believed that this issue is an isolated event.

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

Prev 6ously identified by NU? O Yes @ No Non Discrepant Condition?@ Yes O No ResolutionPending?O ves @ No Resolution Unresolved?O Yes @ No Review initiator: Navarro, Mark VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K 1RC Chmn: singh, Anand K Date: 5/8/98 sL comments: S&L comments to NU's first response:

In discussing the Altemate Shutdown capability Review which was documented in ERC 25212 ER-97-0007, The Disposition section of the DR reponse states "However, it must be noted that specific evaluations on loss of ventilation on operator action was not included in these reviews". This statement appears contrary Prnnted 5/12/98 4:o4.36 PM Page 4 of 5

N::rtherct Utilitie3 ICAVP DR N . DR MP3-0608 Millstone Unit 3 Discrepancy Report to Attachment 2 (page 2-1, item 6.0 b) of 25212-ER-98-0007 which states: "The proposed manual actions were also reviewed to ensure habitability issues were addressed" and also appears contrary to Attachment 2 (page 2-2, section 6.1.2 under EOP procedural verification) of 25212-ER-98-0007 which states: "The field verification of these procedures included the following criteria-Environmental conditions in the area where task is to be accomplished will allow its performance",

if loss of ventilation to any specific area which must be entered to perform manual actions occurs due to the LOP coincident with a fire, the resultant ambient conditions need to be considered to ensure feasibility of the manual action.

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

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l ICAVP DR No. DR-MP3-0664 N:rthext Utilities Millstone Unit 3 Discrepancy Report

! Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: System installation rotential Operabihty issue Discipline: Operations Discrepancy Type: O & M & T Implementation O vos

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

Date Published: 11/24/97 Discrepancy: Monitor light operation at the simulator does not match the plant.

Description:

The Engineered Safety Features (ESF) monitor lights provide information in a concise grouping as to the status of important plant equipment. At the simulator, the power to individual ESF lights is from the same source as the equipment it monitors.

Therefore when power to the equipment is lost, its indication is also lost. At the plant, the power to individual ESF lights is from a more reliable source, Safety Related DC, and equipmer,t status would have been available.

Observation of simulator training showed that the control room (

staff was confused by this loss of ESF monitor light indication. l This mismatch between the plant and simulator decreases the l effectiveness of the training to the operators. Plant / simulator differences are to be minimized, but if they exist, then the i differences are to be noted in the lesson plan. Notation of the i difference was not contained in the lesson plan. l Review Valid invalid Needed Date initiator: Pieniewicz. R. G O O 1 tis 2/97 VT Lead: Bass, Ken O O O s tii2/97 VT Mgr: schopfer, Don K O O O 11/17/97 IRC Chmn: Singh, Anand K B O O ' ' S'S7 Date:

INVALID:

Date: 5/11/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0664, 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 M3-98-0137 has been written to develop and track resolution of this item per RP-4.0 0

Conclusion:

0 NU has concluded that Discrepancy Report, DR-MP3-0664, 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 M3-98-0137 has been written to develop and track resolution of this item per RP-4.

Printed 5/12/98 4:05:04 PM Pc)e 1 of 2

ICAVP DR No. DR-MP3-0664 N:rthcrt Utiliti:s Millstone Unit 3 Discrepancy Report l Revised Response:

Disposition:

i NU has concluded that this issue reported in Discrepancy

! Report, DR-MP3-0664 has identified a CONFlRMED l SIGNIFICANCE LEVEL 4 condition which has been corrected.

Monitor light operation at the simulator has been corrected by Simulator Deficiency Report DR #1997-3-0191; the work was '

completed on 3/3/98 as indicated on the Activity Summary Report for this simulator deficiency. NU considers the l

classification of this DR to be significance level 4.

Conclusion:

NU has concluded that this issue reported in Discrepancy l Report, DR-MP3-0664 has identified a CONFIRMED l

SIGNIFICANCE LEVEL 4 condition which has been corrected.

The monitor light discrepancy at the simulator has been corrected. NU considers the classification of this DR to be significance level 4.

Previously identified by NU? O Yes (#) No Non Discrepant Condition?O yes () No Resolution Pending?O ve. C*) No Resolution Unresolved?O ves (E)No Review initiator: Speer, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/11/98 sL comments: Clarification of the proposed corrective action is not apparent.

The DR identifies that the operation of the simulator does not match the plant. The proposed corrective action does not indicate if the difference will be noted in the lesson plans of if the computer will be rewired to ensure that the power to the individual ESF lights is different from the same source as the equipment that it monitors.

S&L consideres the revised response acceptable.

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Printed 5/12/96 4 05:08 PM Page 2 of 2 l

i N:rthe:st Uti ties ICAVP DR N2. DR-MP3-0666 Millstone Unit 3 Discrepancy Report l Review Group: Operatons & Maintenance and Testing DR RESOLUTK)N ACCEPTED Potential Operability issue Discipline: Operations Discrepancy Type: O & M & T implementation Om g~

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

Date Published: ti/24/97 Discrepancy: Control Room labels and operator lesson plans do not conform to industry standards.

Description:

The industry has developed standards and a code of conduct to enhance professionalism ared ensure conservative decision making by the operators. The labels for the megawatt output indicator and the clock as well as the language used in certain lesson plans do not conform to generally recognized standards in l the industry.

The labels for the megawatt output indicator is " Big Bucks" and the clock is " Big Ben". These labels promulgate or condone an attitude that does not support professionalism and conservative decision making. The message sent is that the generation of megawatts , rather than safe operation, is the priority of management.

Additionally, the language, in some lesson plans used for operator training, minimizes the seriousness of the specific topic.

Some examples are:

A note on the lesson plan for changes to AOP's and EOP's states "Does it matter in the great scheme of things what the order of the steps are? (NO)."

The ECA 0.0 lesson plan states " this will be your worst day if you lose all AC and aux. feed cannot be established to the CG's.. "

Again, this language dilutes the importance of the message and does not support the industry standards.

Review Valid invalid Needed Date l l

Initiator: Pleniewicz, R. G O O 11/12/97 VT Lead: Bass,Kan fB O O sii2/97 VT Mgt: schopfer, Don K B O O 5'/17/S7 IRC Chmn: singh. Anand K B O O ' S'S7 Date:

INVALID:

Date: 5/11/98 RESOLUTION Disposition:D NU has concluded that Discrepancy Report, DR-MP3-0665, 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 M3-98-0137 has been written to develop and track resolution of this item per RP-4.0 Printed 5/12/98 4:o5:32 PM Page 1 of 3

N rthert Utilities ICAVP DR Ns. DR-MP3-0665 l

Millstone Unit 3 Discrepancy Report l

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Conclusion:

0 l

NU has concluded that Discrepancy Report, DR-MP3-0665, has identified a condition not previously discovered by NU which l requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 Pl.

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

Reavised Response Disposition:

NU has concluded that the issues reported in DR-MP3-0665 have identified a CONFlRMED SIGNIFICANCE LEVEL 4 condition which requires correction. CR M3-98-0137 corrective actions will correct the lesson plan post startup. The labels have been removed from the Control Room and the Simulator. These issues do demonstrate cultural issues which ultimately resulted in Millstone being placed on the NRC Watch Li.st. NU management has taken extensive measures to deal with these and many other station issues. Specifically, standards and expectations have been raised significantly over the past year.

Our progress in this area has been continually demonstrated quarter 1y with formal presentations to the NRC and is summarized in

• Progress Toward Restart Readiness at Millstone Station - Northeast Utilities Briefing for the U.S. Nuclear Regulatory Commission". This briefing documents our progress and provides measures to monitor performance in these areas including associated trends and supporting data.

With regard to the specific issues identified by this DR, OP3260 (Conduct of Operations) and OA-9 (Plant Labeling) have been revised to reflect management expectations in these and other areas. OP 3260 oversees training on the simulator. The professional conduct that the procedure requires is evaluated and addressed as appropriate for each simulator training session. Training has similarly provided their personnel with management expectations by discussions at staff meetings and issuing a NUTIMS action item against all training materials for the instructors to check for unprofessional terms and phrases.

Conclusion:

NU has concluded that the issues reported in DR-MP3-0665 have identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. CR M3-98-0137 corrective actions will correct the lesson plan post startup. The labels have been removed from the Control Room and the Simulator.

Previously identified by NU7 O Yes @ No Non Discrepant Condition?O Yes (G) No I

Resolution Pending?O ve. @ No Resolution Unresolved?O vos @ No Review initiator: Spear, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Printed 5/12/98 4o5:36 PM Page 2 of 3

___-_____ A

l N:rthe=t Utilities ICAVP DR No. DR-MP3-0665

.l l Millstone Unit 3 Discrepancy Report i

i ,m....... . . . . ~ ~ "

O O O pate: 5/11/98 sL comments: 11is not apparent from the proposed corrective action what programmatic changes are intended. Nor is it apparent how the proposed changes will address the conformance to industry standards for the preparation of operator lesson plans and control room labeling.

S&L considers the revised response acceptable:

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l PrWed 5/12/98 4 05:37 PM Page 3 of 3

N:rthestt Utilities ICAVP DR Ns. DR-MP3-0693 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Electrical Design Discrepancy Type: Installation implementatxm Om i System / Process: Oss g

NRC Signincance level: NA Date faxed to NU:

Date Published: 1/iB/98 Discrepancy: Simulator was not revised to match changes made to the main control board with Mod MP3-94-135.

Description:

This modification is to install Trisodium phosphate (TSP) deodecahydrate stored in wire baskets upon the lowest floor of the containment building so that during a DBA the containment sump water will have the proper required pH. It eliminates the need for and abandons in place the existing chemical addition tank and associated pump, solenoid valves and controls. The TSP baskets are a passive means of controlling the pH and do not require any electrical power, control, etc. Interface.

1) The modification included the removal of the chemical addition tank (CAT) associated controls from the main control board and patching of the board. There were no drawings in the modification or DCNs listed which identified that the simulator was revised to match the changes made to the main control board.

]

i

2) Calculation NL-038, Rev. 2, CCN #6 (Station service study j voltage profiles) has not been revised to eliminate the loads associated with the CAT subsystem.

Review Valid invalid Needed Date initiator: Crockett. Ed. B 0 0 '/S/98 '

VT Lead: Nerl. Anthony A B O O 1/6'S8 VT Mgr: Schopfer, Don K O O O / 2/98 IRC Chmn: singh. Anand K S O O 1/ 4/S8 Date:

INVAUD:

oste: 5/8/98 RESOLUTION: Disposition:

DCN DM3-S-0761-94 to

• Revise OPAL Data Base (SP-EE-342) to delete 3OSS*MOV29A/B,3QSS-P2 and 3CWS-MOV30". SP-EE-342 provided the mechanism for electrical loading data to be inputted into the load profile calculation NL-038. Significance level criteria does not apply since neither item is a discrepant condition.

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0693, has identified a NON-DlSCREPANT condition. Item # 1, the simulator was modified under DCN-DM3-S-0702 94. Item # 2, deletions of electricalloads was Printed 5/12/98 4:06:03 PM Page 1 of 2

ICAVP DR No. DR-MP3-0693 Northe=t Utilities Millstone Unit 3 Discrepancy Report accomplished by means of DCN DM3-S-076194. Significance level Criteria does not apply as these issues were not discrepant conditions.

Previously identifled by NU? O Yes (#j No Non Discrepent Condition?(G) Yes U No Resolution Pending?O Y.. (se) No R..oiotion unr. iv.e2O Yes @ No Review ce ceptaW W Date initiator: Womer. l. =

VT Lead: Neri, Anthony A O O O I#

VT Mgr: Schopfer, Don K O si m lRC Chmn: Singh, Anand K O O O Date: 5/8/98 SL Comments: We have no comments on NU's response.

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Narthorst Utilities ICAVP DR Ns. DR-MP3-0703  ;

l Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTK)N ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Drawing Om g

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

Date Published: 12/21/97 .

Discrepancy: Emergency Generator Enclosure V 'llation inlet Damper l Minimum Position l

Description:

During review of P&lD EM-150C-16 for the emergency generator enclosure ventilation system a discrepancy regarding the minimum open position for the inlet dampers was identified:

FSAR Section 9.4.6.5 states "When the emergency generator diesel engines have stopped (less than 360 rpm), the supply fans are stopped manually from the main heating and ventilation panel in the contro' room. The inlet damper goes to the minimum open position, the outlet and recirculating dampers go fully close and open, respectively."

PalD EM-150C-16 does not identify the minimum open position (minimum airflow) for inlet dampers 3HVP* MOD 23A/B Review l Valid invalid Needed Date l initiator: stout, M. D.

O O O 1/24/97 VT Lead: Nerl. Anthony A B D 0 11/29/97 VT Mgr: Schopfer, Don K 8 O O 2/5/97 1Rc Chmn: Singh, Anand K S O O 12/9/97 Date:

INVALID:

Date: 5/8/98 RESOLUTION First Response NU has concluded that Discrepancy Report, DR MP3-0703, has l identified a condition not previously discovered by NU which i requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0164 has been written to develop and track resolution of this item per RP-4.

4 Attachments:

CR M3-98-0164

! Second Response (MS-IRF-02033)

NU has concluded that the issue reportd in DR-MP3-0703 has identified a PREVIOUSLY IDENTIFIED condition.

The original description of DR-MP3-0703 was:

} During review of P&lD EM-150C-16 forthe emergency Pnnted 5/12/98 4:06:31 PM Page ' of 2

N::rthezt Utilitie3 ICAVP DR N3. DR-MP3-0703 Millstone Unit 3 Discrepancy Report generator enclosure ventilation system a discrepancy regarding l the minimum open position for the inlet dampers was

! identified:

l FSAR Section 9.4.6.5 states "When the emergency generator l diesel engines have stopped (less than 360 rpm), the supply fans are stopped manually from the main heating and ventilation i panel in the control room. The inlet damper goes to the minimum l open position, the outlet and recirculating dampers go fully close and open, respectively." P&lD EM-150C-16 does not ident'fy the minimum open position (minimum airflow) for inlet dampers 3HVP* MOD 23A/B Further investigation has determined that OIR99 issued 6/8/96 identified that the FSAR needed to be revised.FSARCR 98-MP3-42 approved 3/12/08 reworded section 9.4.6.5 from " minimum open* to " fully closed". . Therefore the P&lD does not require revision.

Attachments:

section 9.4.6.5 and cover from FSARCR 98-MP3-42 and OIR99 AR 810 report.

Previously identified by NU? (*) Yes O No Non Discrepent Condition?U Yes @) No Resolution Pending?O ve. @ No Resoiution unr.soiv.d?O yes @ u.

Review initiator: stout, M. D.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/8/98 sL Comments: Comments on First Response The corrective action is not apparent from the description in CR M3-98-0164 and comment *P&lD not required to show this level of detail" entered on DR screening form.

The DR should have been put in the FSAR " bin"instead of the Drawing " bin" Comments on Second Response A/R Assign No 9600939 01 regaring OIR #99 on Action Request -

Report printed 5/22/97 previously identified the discrepancy. l l

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I Printed 5/12/98 4:o6.35 PM Page 2 of 2 j

N:rthe:ct Utilities ICAVP DR N2. DR-MP3-0707 Millstone Unit 3 Discrepancy Report 1 Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design potential Operability issue Discipline: Electrical Design Qy Discrepancy Type: Calculaton System / Process: HVX

@ No l

NRC Significance level: 4 Date faxed to NU:

Date Published: 12/21/97 Discrepancy: Arc Suppression Capacitors for Solenoid Operated Valves (Calculation 3-ENG-097)

Description:

Calculation 3-ENG-097 selects capacitors to be installed across the coils of some solenoid operated valves to suppress arcing across the relay contacts that control the valves. We have the following comments on this calculation:

Because of the way the loop current is defined, there is a sign error in Equation 6 on page 4. There is also a sign error in Equation 9 on page 5. As a result, the solution of the differential  ;

equation is a sinusoid, not exponential. Since the relay contacts intemJpt the current at a current zero, and since the circuit is essentially purely inductive, the current zero will occur at the voltage peak. Therefore, the magnitude of the vcitage across the solenoid coil will be equal to the peak value of the control voltage or about 170 volts.

In order to understand how to suppress the arc, it is necessary to review what happens when the current is first broken. The voltage across the relay coil will oscillate at a natural frequency that is determined by the inductance of the solenoid coil and the capacitance in parallel with it. (If the proposed capacitor was not installed, the naturally occurring stray capacitances determine the natural frequency.) The transient recovery voltage seen by I the relay contacts is the difference between the control voltage i and the voltage across the relay coil. At the time that current is i first broken, this voltage is zero. The voltage across the solenoid l coil will then oscillate at the natural frequency of the relay coil  !

l and parallel capacitance. Assuming that this frequency is much higher than the 60 Hz mains frequency, a voltage equal to twice the peak control circuit voltage will appear across the relay contacts after a half cycle of the solenoid coil oscillation. Since the insulation strength of the contacts cannot recover instantaneously, there is a possibility for the contacts to break down, striking an arc (restrike). Depending on how fast the insulation strength of the contacts recovers, there can be multiple restrikes, and the voltage of the restrikes can escalate.

Increasing the capacitance across the relay coil does not change the magnitude of the voltage across the solenoid coil following the initial current interruption. However, adding the capacitance lowers the natural freqJency of the voltage oscillations across the solenoid coll. Lowering this natural frequency allows more time for the insulation strength of the opening contacts to recover. This reduces the likelihood of restrikes.

Review Valid invalid Needed Date initiator: Bloethe.G William 11/22/97 Printed 5/12/98 4:07:28 PM Page 1 of 3

N:rthert Utilities ICAVP DR No. DR-MP3-0707 Millstone Unit 3 Discrepancy Report inet6stor: B60ethe, G. Wilharn 8 0 0 sir 22/97

! VT Lead: Neri, Anthony A B O O 1 r29/97 VT Mgr: schopfer, Don K B O O 12/5/97 1RC Chmn: singh, Anand K B D O 2/9/97 Date:

INVAlto:

Date: 5/8/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0245, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which require correction. This discrepancy meets the criteria specified in NRC letter 816901 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 1.3.2.e of U3 Pl 20 deferral criteria.

Capacitors are used in parallel with solenoid coils to prevent contact restrike. Capacitors at MP3 have been installed based on the requirements presented in calculation 3-ENG-RlY10B,198. There hasn't been any history of contact restrike problems because of the inappropriate selection of capacitors.

Possibly the reason is, that because of the requirernent stated in the calculation "A capacitor of 0.05 micro Farads or less, rated at 170 volts or more can be used" might have prevented restrika problems. Using lower (or less) valued capacitors will prevent (or lower the natural frequency of the voltage oscillations across the coil) contact restrike even if the voltage across the capacitor (the mistake that S&L pointed out) is larger than calculated. The initation of a CCN to calculation 3-ENG-097 is deferrable as these conditions do not affect Nuclear Safety, Licensing Design Basis, Employee Concems or the safe operation of the Plant. CR M3-98-2313 was issued to address this DR. CR M3-98-2313 was closed to BIN CR M3-98-0138.

Corrective actions for CR M3-98-0138 will be completed post i start-up. I

Conclusion:

l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0707, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It i has been screened per Attachment 11 of U3 Pl-20 criteria and I found to have no operability or deportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. The corrective l actions for CR M3-98-0138 will require a revision to Calculation 3-ENG-097 which will be addressed by issuing a CCN. The initiation of a CCN is deferrable as this condition does not affect Nuclear Safety, Licensing Design Basis, Employee Concems or the safe operation of the Plant.

pg,yglypefyg Dy NU( TOS NO Non LM&CrepetN GonORion[ Tes Page f9r 3

N rthea:t Utilities ICAVP DR No. DR-MP3-0707 Millstone Unit 3 Discrepancy Report Preveously identified by NU? U Yes @ No Non Descrepant Condition?U Yes @ No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Date initiator: Warner,1, VT Lead: Neri, Anthony A g

VT Mgr: Schopfer, Don K

, gg IRC Chmn: Singh, Anand K O

l Date: 5/8/98 I

sL comments: NU's response is acceptable.

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I ICAVP DR Ns. DR-MP3-0723 ]

N:rthenct Utilitie3 l

Millstone Unit 3 Discrepancy Report l Review Group: Programmetc DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Other g Discrepancy Type: Corrective Acton System / Process: DGX Om NRC Significance level: NA Date faxed to NU:

Date Published: 12/20/97 Discrepancy: Justification for hardware issues documented in UlR 431 which are designated as post startup

Description:

Sufficient information has not been provided for evaluation of the appropriate characterization of certain issues (documented in UIR 431) as post startup.

Discussion UIR 431 documents several material conditions which were observed during walkdown of the A & B Emergency Diesel Generators by the Licensee. Many of the issues are hardware related, eg. bent tubing, inappropriate routing of tubing, missing or loose bolts / screws / clamps, missing insulation, etc.

To evaluate appropriate corrective action, RFI 241 was issued to request the closure package (DICP) for UIR 431. The Licensee's response to RFI 241 (M3-IRF-00226) states that UIR 431 is not closed and has " scheduled completion dates which are post startup".

Issue evaluation and resolution (proposed corrective action) for the hardware related items must be reviewed to confirm appropriate characterization of the issues as post startup.

Adequate information to conduct this evaluation (eg. submittal of DICP or technical justification to support post startup designation) has not been provided.

Review Valid invalid Needed Date initiator: Navarro, Mark 8 0 0 2/2/97 VT Lead: Ryan, Thomas J G O O 12/s/97 VT Mgr: schopfer, Don K O O O 12/11/97 0 52/is/97 IRC Chmn: singh, Anand K 9 0 Date: J INVALID:

Date: 5/8/98 RESOLUTION: Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0723, does not represent a discrepant condition.

The findings that were identified during walk-downs of the  :

emergency diesel generator enclosures were reported under UlR l 431.

l House Keeping Concems:

Page 1 of 6 Printed s/12/98 4:08.19 PM i

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DR N2, DR-MP3-0723 l N:rthert Utilities ICAVP I

Millstone Unit 3 Discrepancy Report I

Insulation near MCC 32-1T is stored in bag. Personnel Safety (PS):No, Start-Up item (SUI):No - Items Removed Fuses in bag on floor behind 3EGS-PNLA - Items Removed A fuse puller is stored inside the panel. - Item Removed Hoses left on floor with Chicago fittings (evidently for draining

! heat exchangers)-item Removed l Wrench beneath keep-warm skid (looking beneath the engine gage board)- Item Removed Hose with Chicago fitting stored near STR1B coiled up against the wall? - Item Removed Insulation in bag near grounding resistor enclosure: looks to be from service water heat exchanger pip ng - Item ORemoved Spare washers (not used for turt>o mouming) are hung from turbo of both diesels -ltem Removed 3EDG-P1 A motor and motor side casing area needs cleaning (same item with 3EGD-P1B) - Item 0 Corrected 3EGD-P1B motor and motor side casing area needs cleaning -

Item Corrected Spare ground wire just beyond tomado door is coiled. This wire does not present any hazard to personnel or equipment. This item does not pose an equipment operability or personnel safety l

Issue. TR 24M3175345 {

The housekeeping concems reported above have been reviewed by the expert panel in accordance with the criteria stated in Unit 3 PI 20," Unit 3 Startup item Administrative Instructions.* The panel's determination of these items are "The discrepancy has no impact on operability, plant configuration, operation, or result l in a personnel safety issue. Therefore, in accordance with PI-20 this may be deferred *,

Tagging and Labeling Concems:

Tags for 3EGS-TS30A/TC31 A?? PS:No Sul:No - Tracked by UIR 1356 with A/R 97007329 to l&C Tags for 3EGS*Tl28A MADE OF PAPER. Needs A TAG. - Tl does not exist Condensate makeup and draw-off valve 3CNS*V932 has incorrect description the valve say its CCW make-up water.

Should be more descriptive: CNS make-up to fresh water

expansion tank. - Corrected

Lube oil are labeled 3EGS*PS23B1, B2 & B3. They should be l

3 EGO *. ..

! 0 Recommended Resolution: Tags need to changed. Blue tags should be yellow and relabel 3 EGO *.. 0- Corrected 3EGS*V3A & V3B are not tagged - Corrected RO45B 2 is not tagged. None of the RO's on the Diesels are labeled - Corrected 3EGS-Tl29B is not labeled - Corrected 3EGS*RO338 not labeled - Corrected 3EGS-Tl26B is not labeled - Corrected 3EGS-TKiB the diesel fresh water expansion tank is not labeled - Corrected 3EGS*RO20B1 is not labeled - Corrected Oil separators do not have label 3EGD-SP1 A (and 3EGD-SP18)- Corrected Page 2 of 6 Printed S/12/98 408:22 PM I

ICAVP DR N3. DR-MP3-0723 N:rthenct Utilities Millstone unit 3 Discrepancy Report (3EGD-SP18) oil separator is not labeled Corrected DG090 tag type: is this type of labeling sat? - Corrected Note both 3EGS*P3A & B need to be labeled. - Corrected The labeling concems reported above have been reviewed by the expert panel in accordance with the criteria stated in Unit 3 Pl 20," Unit 3 Startup Item Administrative Instructions." The pancl's determination of these items are "The discrepancy has no impact on operability, plant configuration, operation, or result in a personnel safety issue. Therefore, in accordance with PI-20 this may be deferred *.

Material Condition Concems: 1 Fuel oil sample valve,3EGF*V950, has tygon tubing attached w/~1/2 cup of fuel oil present in tied up tubing 0- Item Removed Molding on QA storage locker below 3SCV*PNL250 - Item Removed 3EGS*JBFLD-A cover is missing 2 bolts,- Appears to be Sat by design, no threaded holes.

Insulation removed from piping at elbow of Jacket water HX -

Insulation not required - Low Temp. I Missing floor deck plate bolting - All bolts installed where holes exist, anchorage SAT.

Insulation removed from portions of the Jacket water and air j (intercooler) heat exchangers - ltem DCorrected Hose holder and tygon tubing mounted on wall.

Authorization?? - ltem Removed Lube oil filter splash guard for neutral grounding resistor: Is this sat?? Chicken wire enclosure dented / broken at 0 bottom - Item Corrected, Design is satisfactory through previous E&DCR T-P-07916.

Continuous vent tubing bent out of STR1/5B running along floor before platform - Not a problem Compressor motor belt guard (3EGA-C28) missing shield screw -

Item Corrected Oil leaking at engine over speed micro switch mounting flange and from 3 EGO *P3B engine driven Lube oil pump Opiping. A plastic bag is installed over suction piping flange (to catch leak-off?) Item Corrected 1-1/2? line off suction side of intercooler P3B has leaking coupling. - ltem Corrected RTD pecker-head (which seems to be spared) is dangling near the pillow box behind 3EGS*TBEG18. RTD is not 0 installed but has wires running into the TBEG1B - Item Repaired AWO M3-97-05812 Insulation missing off of the Jacket water heat-exchanger service water piping as well as - ltem Corrected 3EGS*V960B is not capped - ltem Corrected 3EGS*V959B is not capped - Item Corrected 3EGS*V987 is not capped - ltem Corrected Loose deck grating clamps on fuel oil day tank platform - ltem Corrected 3EGA-RV208178 diesel start air compressor C1B discharge relief handle is loose and rubbing. - ltem Corrected Pillow box drain line and the condulet for the spared RTD condulet at 3EGS*TBGE1 A have red plastic pluas Olnstalled. -

Printed 5/12/98 4-08:23 PM Page 3 of 6

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ICAVP DR No. DR-MP3-0723 N::rthert Utilities Millstone Unit 3 Discrepancy Report Item Corrected AWO M3-97-11010 Insulation (piece) falling off the silencer on the 51 foot elevation -

Item Corrected Ground wire strand near 3EGA*V993 is coming out? verify the j valve identification - ltem Corrected Signs of rust near air cooler heat exchanger from service water spills during repair or PM work - Oltem Corrected insulation on the exhaust is off and on the floor, installed insulation around the exhaust line is bad and should be Oreplaced -Item Corrected Insulation on muffler section is bad 09 the 51 foot elevation -

Item Corrected General comments: floors for the EDG enclosures should be cleaned and painted. Particular1y the areas around the Dair cooler heat exchangers for both EDG's and the jacket water coolers as well. Spalling paint and rust is Devident - Item Corrected Both the A & B EDG's have missing paint on the floor plates -

ltem Corrected i The material condition concems reported above have been reviewed by the expert panel in accordance with the criteria l stated in Unit 3 PI 20," Unit 3 Startup Item Administrative Instructions." The panel's determination of these items are "The discrepancy has no impact on operability, plant configuration, operation, or result la a personnel safety issue. Therefore, in accordance with PI-20 this may be deferred".

Equipment Concems: 1 Black cable from 3SCV*BKR250 not in SILTEMP out of conduit l to tray - Item is Satisfactory 3EGS*TBEG1 A door not secure. - ltem Corrected Expansion joint forjacket water heat exchanger bolting is tight.

Is this acceptable? Most EJ's have loose botting 0- ltem SAT. per Gary Swider 5/22/96 walk-down Govemor settings: O speed droop; max. fuel 16.9 setting; oil sight glass full Recommended Resolution: N/A for Information only.

Light on crankcase vacuum pp. platform is de-energized (ref.

3EGD-P1 A) Recommended Resolution:

Oltem SAT. on 6-3-96.

Support for 3EGD*V995 (valve is QA) is unnecessary construction and poses a hazard; should be re-designed: it is Oright in front of gage board - Satisfactory as is.

Tubing run on skid from 3 EGO *V278 should be re-routed. it hits against Lube oil line and is bent in other areas OPS:No Sul:No -

AWO M3-98-05218 to correct vibration concems Sample line (hard black tubing with instrument isolation valve) attached to 3EGF-V28 (B) and the other diesel's Odrain line has the same configuration 3EGF-V21 (A)). Valves are shown capped on P&lD. OTemporary/ permanent mod PS:No SUl:No -

l DCN M3-00-1443-96 to corred l The correct expansion joint type coming out of EDG-A (crankcase vacuum) question. It appears to be consistent Dwith the other diesel PS:No SUl:No - No action required Crankcase vacuum drain line runs are obstructions-- run with Printed 5/12/98 4:0824 PM Page 4 of 6

ICAVP DR No. DR-MP3-0723 N:rthext Utilitien Millstone Unit 3 Discrepancy Report obstructive anchors near engine gage board. These Danchors can be modified / moved to allow better passage PS:No sui:No -

No Cost Benefit, item is Sat Vents for both the A & B EDG Jacket / fresh water expansion tanks are lower than the overflow lines. Overflow will Ospill from the overhead rather be run to the drains - Not a system problem - original design The equipment concems reported above have been reviewed by the expert panel in accordance with the criteria stated in Unit 3 Pl 20," Unit 3 Startup item Administrative Instructions." The panel's determination of these items are "The discrepancy has no impact on operability, plant configuration, operation, or result in a personnel safety issue. Therefore, in accordance with PI-20 this may be deferred *. In accordance with PI-20, no Disposition item Closure Package (DCIR) is req::lred for the items identified on UIR 431 since the Expert Panel has provided its justification that the UIR open items can be corrected post-startup.

Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0723, does not represent a discrepant condition. The Expert Panel concluded that the items identified by UIR 431 are deferrable based on the ciiteria established in Unit 3 PI-20 section 1.3.2.e. The Panel's justification, "The identified discrepancies have no impact on operability, plant configuration, operation, or result in a personnel safety issue". Most of the identified items have been corrected. Those items needing correction post start-up will be documented in A/R 96008463 tracking each item associated with UlR 431. Therefore NU does not consider this to be a discrepart condition.

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

Previously identified by NU? O Yes @ No Non Discrepent Condition?% Yec Q No Resolution Pending?O ve. @ No Resoluuon Unresolved?O ve. @ No Review initiator: Navarro, Mark VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K B O =

IRC Chmn: Singh, Anand K O

Date: 5/8/98 sL comments: S&L accepts NU's response with the following observations:

Discussion of NU's previous response to DR1052 S&L issued DR 1052 as a result of inadequate post tubing l

changeout vibration check. This involved a lack of documentation to indicate appropriate tubing vibration check during D/G following tubing changeout per AWO M3 9215905. NU's response (in part) which was accepted by S&L included the following statement:"given the lengthy time duration from the Printed 5/12/96 4:o8:25 PM Page 5 of 6 L__________-_-_____-________

l N:rthert Utilitica ICAVP DR Ns. DR-MP3-0723  :

Millstone Unit 3 Discrepancy Report I i

l referenced AWO's in question (1987 and 1992), and the numerous monthly EDG surveillance which have been performed over this time duration, it can be concluded that if any excessive tubing vibration resulting from the work activities of the i referenced AWO's, such tube vibration would have been )

identified and corrected by now".

The work performed under AWO M3 9215905 involved the repair of the tube oil tubing downstream of valve 3 EGO *V27B of the diesel generator system.

l Discussion of NU's response to DR 723 NU's response (Disposition) to DR 723 under equipment concems (7th item) notes the following: " Tubing run on skid from 3 EGO *V278 should be re-routed. It hits against lube oil line and l is bent in other areas. AWO M3-98-05218 to correct vibration concems".

Summary Given that NU recently solved a vibration concem via AWO M3-98-05218 for the subject tubing, this calls into question the accuracy of NU's statement shown above in quotes in Discussion of NU's Response to DR 1052. Nevertheless, S&L has no indication that the subject tubing failed since the work performed under AWO M3 9215905 was completed. And while specific review of the more recent work performed under AWO M3 05218 was not performed, it is reasonable to expect that such work served to enhance overall DG reliability.

Printed 5/12/98 4:08:27 PM Page 6 of 6

North 2 cst Utilitiss ICAVP DR No. DR-MP3-0736 Millstone Unit 3 Discrepancy Report Review Group: Conrguration DR RESOLUTION ACCEPTED Review Element: system Installation p

Discioline: 1 & C Design Discrepancy Type: Installatm lw@ ...Wiion Om System' Process: N/A g NRC Signl5cance level: 4 Date faxed to NU:

Date Published: 1/3/98

~

Discrepancy: Improper module installation Foxboro Spec 200 Panels

Description:

Foxboro Installation and operation requirements for Contact Output isolators are set forth in Instruction Mi-240-113 May 1990. It requires that:

The isolator is held by two captive screws on the top and bottom of the front plate.

- A protective cover for the lower six te;rminals must be attached when circuits are live.

These requirements are applicable to all four systems: SWP, Q/RSS, HVX and DGX as well as others.

During walkdowns of the Foxboro cabinets in the Control Room Instrument Rack Room, the following deviations fr:m these vendor lostallation requirements were noted. These include both safety (*) and non-safety (-) related panels. The lack of hold done screws may impact seismic qualification and the lack of covers present a personnel safety hazard as well as a inadvertent contact with circuits resulting unintended operations of components.

1) 3CES*lPNLl01 Drawings: 12179.2472.710-392-001C Rev. 2

& EE-278 Rev. 22 Nest 3 - Slot 5: Protective cover screw broken off in module and bottom module captive screw missing Nest 4 - Slot 8: Bottom module captive screw missing Nest 5 - Slot 6: Bottom module captive crew missing Nest 5 - Slot 9: Protective cover screw and bottom module captive screw missing Nest 5 - Slot 10: Protective cover screw missing

2) 3CES-IPNLl02 Drawings: 12179 2472.710-392-019 Rev. J &

EE-278 Rev. 22 Nest 1 - Slot 5: Prc:ective cover screw missing Nest 1 - Slot 4: Bottom module captive screw missing Nest 4 - Slot 7: Bottom module captive screw missing Nest 5 - Slot 6: Bottom module captive screw missing Nest 5 - Slot 7: Protective cover screw missing Pnnted 5/12/98 4:23.46 PM 8"

N:rtheast Utilities ICAVP DR N2. DR-MP3-0736 ministone Unit 3 Discrepancy Report

& EE-27B Rev. 22 Nest 2 - Slot 6: Bottom module captive screw missing Nest 4 - Slot 3: Bottom module captive screw missing Nest 5 - Slot 3: Bottom module captive screw missing

4) 3CES-IPNL104 Drawings: 12179-2472.710-392-015 Rev. 3

& EE-27B Rev. 22 Nest 2 - Slot 8: Upper captive screw not installed properly and is touching energized wires 104-2-8-4 to TB of module. Bottom module captive screw missing Nest 4 - Slot 5: Bottom module captive screw missing Nest 6 - Slot 7: Bottom module captive screw missing

5) 3CES-IPNLl05 Drawings: 12179-2472.710-392-017 Rev. 3

& EE-278 Rev. 22 Nest 1 - Slot 3: Bottom module captive screw missing Nest 1 - Slot 4: Protective cover screw missing Nest 2 - Slot 3: Bottom module captive screw missing Nest 3 - Slot 7: Bottom module captive screw missing Nest 4 - Slot 3: Bottom module captive screw missing Nest 5 - Slot 3: Bottom rnodule captive screw missing l Nest 6 - Slot 9: Bottom module captive screw missing l l

6) 3CES-IPNLl06 Drawings: 12179-2472.710-392-392 Rev. 4

& EE-278 Rev. 22 Nest 1 - Slot 3: Bottom module captive screw missing Nest 2 - Slot 5: Bottom module captive screw missing Nest 2 - Slot 7: Bottom module captive screw missing Nest 3 - Slot 4: Bottom module captive screw missing Nest 3 - Slot 9: Bottom module captive screw missing Nest 4 - Slot 3: Bottom module captive screw missing Nest 5 - Slot 4: Bottom module captive screw missing Nest 6 - Slot 4: Bottom module captive screw missing Nest 6 - Slot 9: Bottom module captive screw missing

7) 3CES*lPNLl08 Drawings: 12179-2472.710-392 390 Rev. F

& EE-278 Rev. 22 l Nest 1 - Slot 4: Bottom module captive screw missing Nest 3 - Slot 5: Protective cover screw missing Nest 4 - Slot 8: Protective cover screw broken off in module Nest 5 - Slot 7: Bottom module captive screw missing Nest 5 - Slot 9: Bottom mooule captive screw missing

8) 3CES*iPNLl09 Drawings: 12179-2472.710-392-389 Rev. G

& EE-278 Rev. 22 Nest 2 - Slot 4: Protective cover screw broken off in module Nest 5 - Slot 9: Protective cover screw broken off in module Printed 5/12/98 4:23:49 PM Page 2 of 8

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l N:rthea t Utilities ICAVP DR N3. DR-MP3-0736 Millstone Unit 3 Discrepancy Report l

9) 3CES-IPNLl11 Drawings: 12179-2472.710-392-226 Rev. 5

& EE-27B Rev. 22 Nest 1 - Slot 5: Bottom module captive screw missing Nest 2 - Slot 6: Bottom module captive screw missing Nest 6 - Slot 6: Protective cover screw missing

10) 3CES-IPNLl12 Drawings: 12179-2472.710-392-225 Rev. 3

& EE-278 Rev. 22 Nest 1 - Slot 4: Protective cover screw missing

Nest 3 - Slot 5

Bottom module captive screw missing Nest 4 - Slot 5: Protective cover cap screw broken off in module and bottom module captive screw missing Nest 6 - Slot 8: Bottom module captive screw missing

11) 3CES-IPNLl13 Drawings: 12179-2472.710-039-200-78 Rev.1 & EE-278 Rev. 22 Nest 1 - Slot 3: Protective cover cap screw and bottom module captive screw missing Nest 2 - Slot 3: Bottom module captive screw missing Nest 3 - Slot 5: Bottom module captive screw missing Nest 4 - Slot 4: Bottom module captive screw missing Nest 5 - Slot 3: Bottom module captive screw missing Nest 6 - Slot 4: Bottom module captive screw missing

12) 3CES-IPNLl15 Drawings: 12179-2472.710-392-009 Rev.1

& EE-27B Rev. 22 Nest 5 - Slot 9: Bottom moduie captive screw missing

13) 3CES-IPNLl17 Drawings: 12179-2472.710-392-011 Rev. 3 i

& EE-27B Rev. 22 '

l Nest 4 - Slot 9: Protective cover screw and bottom module captive screw missing Nest 4 - Slot 10: Protective cover screw missing Nest 6 - Slot 9: Bottom module captive screw missing Nest 4 - Slot 9: Bottom module captive screw missing Nest 5 - Slot 1: Bottom module captive screw missing Nest 5 - Slot 3: Bottom module captive screw missing

14) 3CES*lPNLl19 Drawings: 12179-2472.710-392-386 Rev. C

& EE-278 Rev. 22 Nest 1 - Slot 3: Protective cover screw missing Nest 1 - Slot 4: Protective covsr screw missing l Nest 4 - Slot 6: Bottom module captive screw missing Nest 4 - Slot 9: Bottom module captive screw missing Nest 5 - Slot 9: Protective cover screw and bottom module captive screw missing Printed 5/12/98 423 50 PM Page 3 of 8'

1 l N2rthert Utilities ICAVP DR No. DR-MP3-0736 Millstone Unit 3 Discrepancy Report l 15) 3CES*1PNLl20 Drawings: 12179-2472.710-392-513 Rev. C

& EE-278 Rev. 22 Nest 3 - Slot 4: Protective cover screw and bottom module captive screw missing Nest 5 - Slot 3: Bottom module captive screw missing

16) 3CES*lPNLl21 Drawings: 12179-2472.710-392-542 Rev. C

& EE-27B Rev. 22 Nest 3 - Slot 3: Protective cover screw ar'd bottom module captive screw missing Nest 3 - Slot 4: Protective cover cap screw broken off in module Nest 5 - Slot 3: Protective cover cap screw broken off in module Review Valid invalid Needed Date initiater: sarver, T. L.

O O O 12/1/97 VT Lead: Neri, Anthony A B O O 12rs/97 VT Mgr: schopfer, Don K O O O 1271tra7 BRC Chmn: singh, Anand K O O O 12/24/97 Datu:

INVALID:

Date: 5/11/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0736, has identified a condition not previously discovered by NU that has been corrected.

Relay isolator card (N-2AO-L2C-P) is a dual width logic card that occupies two card spaces in the Spec 200 nest assembly. This configuration utilizes two front panels were each front panel has two screw holes inoicating that its to be mounted with two l mounting screws. The seismic qualification report for the relay l

isolator card is silent on the number of screws that are required or were used during the seismic qualification testing. Foxboro engineering was contacted to determine the proper configuration j for the relay isolator card. Foxboro stated that the proper mounting configuration is provided on the assembly drawings for  :

the applicable card. Foxboro further stated this card had not  ;

been tested or qualified with the lower left captive screw installed and did not know whether or not the card would function properly with the left captive screw installed. Further discussion with Foxboro component engineers indicated that there were several l

reasons why the lower left capuve screw had been removed.

Some of the reasons provided by Foxboro range from the l consideration that the weight of the relays and circuit card is I

predominately located on right front panel to the concem that the additional captive screw places an undue strain on the adjacent circuit card power connector causing the pins to become distorted. In either case Foxboro was unable to provide the applicable documentation providing the reason why the captive screw had been removed. Foxboro further stated that the output Pnnted 5/12/96 4:23:52 PM Page 4 of 8

NtrtheT.t Utilitie3 ICAVP DR Ns. DR-MP3-0736 Millstone Unit 3 Discrepancy Report

' Isolator relay assembly print C0159YE identifies the mounting configuration that was used during the seismic qualification (QOAAB34) testing. Assembly drawing C0159YE identifies the top mounting screw as item 19 and the bottom screw as item 20 and the quantities are provided on sheet 2. Item 19 has a quantity of two whereas item 20 has a quantity of one. Based on this the N-2AO-L2C-R modules identified in background section i

of this DR are installed in accordance with the seismic

! qualification requirements.

1 Distribution control module (N-2AC-M3) is a triple control module that occupies three card spaces in the Spec 200 nest assembly.

l' This configuration requires only two power bus plug connectors to be installed for the power and ground connections. Power bus ,

connectors are installed on the outer two card slots on the triple l control module. The center card slot is a terminal strip that does not require a power bus p!ug connector to be installed. For i similar reasons as the relay isolator card the center card slot should not have the lower screw installed as indicated on the distribution control module assembly drawing (NO310WS). The  !

distribution control module assembly drawing identifies the I mounting configuration that was used during seismic qualification. A walkdown of the Foxboro panels indicate that all distribution control module (N 2AC-M3) assembles are installed  ;

in accordance with the seismic qualification requirements. l l

National Electrical Safety Code, ANSI C2-1990, sections 1800 i and 180E requires that control panels or switchboards with i uninsulated connections shall be installed in rooms or spaces that are capable of being adequately guarded or locked, with access limited to qualified personnel. The affected Foxboro logic cabinets are located in the vital areas of the plant where access is limited to qualified personnel. In addition the Foxboro logic cabinets are locked and are accessible only by qualified personnel. The protective covers are not required to be installed per the National Electrical Safety Code requirements. NU however, takes personnel safety seriously and requires the protective covers to be !nstalled. The protective covers are compression fitted onto the module while the screw provides additional assurance that the cover will not dislodge during a seismic event. The covers have been inspected by Mechanical Engineering and determined to have insufficient mass to impact any equipment should the compression grip fail to hold the cover in place during a seismic event.

l Condition Report M3-96-1168, dated November 21,1996, was l issued to document that the mounting screws for specific Foxboro SPEC 200 cards were missing. Corrective action for this CR was to inspect all Foxboro SPEC 200 cabinets for proper l

seismic mounting hardware and to incorporate applicable Foxboro drawings into the NU system. These corrective actions have been completed. The corrective actions for this CR were not comprehensive since they failed to identify that the N-2AO-L2C-R cards with lower left mounting screw installed were not in accordance with the seismic qualification requirements.

Printed 5/12/96 4:23:53 PM Page s of 8

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N:rthert Utilitin ICAVP DR N3. DR-MP3-0736 Millstone Unit 3 Discrepancy Report Condition Report M3-98-0202, dated January 14,1998, was l Issued to document that the protective covers, protective cover mounting screws and captive screws for specific Foxboro SPEC 200 cards are either missing, broken or not installed properiy. i This CR credited the corrective actions in CR M3-96-1168 for '

resolving the missing captive screw issue. Corrective action for this CR correctly installed the upper captive screw for the card located in 3CES-IPNLl04, Nest 2, Slot 8. The corrective actions  ;

have been completed. However, the corrective actions for this l CR did not reevaluate the N-2AO-L2C-R card screw l l configuration. Cards mounted with the bottom left captive screw l f installed are not in accordance with Foxboro mounting l configuration or the seismic qualification requirements, in i addition the rack loading drawings were not revised to indicate l l the proper mounting configuration for the distribution control l module and relay isolator cards.

l CR M3-98-1169, dated February 28,1998, was written to I document the following discrepancies discovered during the l subsequent NU walkdowns of the Foxboro panels to resolve the I issues identified in this DR: 1) three relay isolator cards (N-2AO- l L2C-R) Identified below have the bottom left captive screw l installed which is not in accordance with seismic qualification l QOAAB34 requirements 2) several non-safety SPEC 200 nest l assemblies have empty card slots that are missing the dummy modules as required by the rack loading drawings 3) rack loading l drawings contain errors in the type of cards that are installed (for l example, a dummy modules is shown in location Nest 3 - Slot 9 l on drawing 25212-39392 Sh. 216 Rev. K whereas the card l l installed in this slot is a V2l card). The following provides a listing of the affected panels and card slots which has either the l bottom left captive screw installed or has a different type of card installed:

l Nest 2 - Slot 10: This is listed as a dummy module but is a val card 3CES-IPNLl18 25212-39392 Sh. 216 Rev. K Nest 3 - Slot 9: This is listed as a dummy module but is a VA! card 1

3CES*1PNLl20 25212-39392 Sh. 519 Rev. D Nest 4 - Slot 2: Has bottom module captive screw installed i 30ES*1PNLl21 25212 39392 Sh. 520 Rev. E Nest 4 - Slot 2: Has bottom module captive screw installed

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0736, has identified a condition not previously discovered by NU that has been corrected. Condition Report CR Printed 5/1298 4:23.54 PM Page 6 of 8 E___________

N::rthert Utilitie3 ICAVP DR No. DR-MP3-0736 Millstone Unit 3 Discrepancy Report M3-98-0202 has been written with the corrective action plan l approved to install the upper captive screw for the non-safety l related card located in Foxboro cabinet 3CES-IPNL104, Nest 2, Slot 8. Improper installation of the holding screw in a non-safety related panel does not effect the design or licensing bases for MP3. This screw has been correctly installed. NU considers the issue associated with the upper captive screw not installed

property to be a Significance Level 4 issue.

i l Condition Report CR M3-98-1160 has been written with an l l approved corrective action plan to remove the bottom left captive screw to bring the non-conforming output isolator relay l cards into conformance with the seismic qualification requirements by removing the lower left captive screw. The non-conforming output isolator relay cards provides alarm functions only and do not affect any safety related function. Corrective actions have been developed to determine if the dummy modules are required to be installed in the non-safety related panels or if the rack loading drawings for the non-safety related l panels are to be revised deleting references to the use of dummy modules in empty card slots. In addition, rack loading drawings l will be revised as required to include a note identifying the mounting configuration for the output isolator relay cards and i distribution control modules. CR M3-98-1169 corrective action l plan has been approved for post startup implementation. Based on the above NU Considers this to be a Significance Level 4 issue.

l Mounting configuration for the output isolator relay (N-2A0-L2C-R) cards and distribution control modules (N-2AC-M3) identified in this DR are in accordance with the seismic qualification requirements. NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0736, associated with the missing captive screws on the output isolator relay cards and distribution control modules does not represent a discrepant condition.

The output isolator relay cards that are missing the protective covers and/or protective cover holding screws are in accordance with the National Electrical Safety Code, ANSI C2-1990, sections 180C and 180E requirements. The Foxboro panals with uninsulated connections are installed in rooms that are adequately guarded and locked with access limited to only l qualified personnel. The missing protective cover screws have bee'1 evaluated and determined not to cause a hazard since the

covers have insufficient mass to impact any equipment should

! the compress grip fail to hold the cover in place during a seismic l

event. NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0736, associated with the protective covers screws missing does not represent a discrepant condition.

Previously identified by NU? O Yes (9) No Non Discrepant Condition?O Yes (9) No Resolution Pending?O Ye. @ No Re.oiution unre.oived?O ve. (3) No Review initiator: Johnson, Jay VT Lead: Neri, Ar.thony A Printed 5/12/98 4:23:55 PM Page 7 of 8

Northeart Utilitias ICAVP DR No. DR-MP3-0736 Millstone Unit 3 Discrepancy Report I

wi 6.wou. nur i, now n.n iy a VT Mgr: Schopfer, Don K G O O S1 m IRC Chmn: Singh, Anand K O O O Date:

SL Comments:

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l r

I 1

I Printed 5/12/98 4:23:57 PM Page 8 of 8

(

Northeast Utilities ICAVP DR No. DR-MP3-0787 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Discipline: Electrical Design Potential Operability issue Discrepancy Type: Calculaton Om Systern/ Process: N/A g

NRC Significance level: NA Date Faxed to NU:

Date Published: 1/18/98 Discrepancy: Incorrect S.C. Current Value & Potential Associated Circuits issue (Calculation 178E)

Description:

This calculation determines the SkV and 8kV power cable temperatures under fault conditions.

The revised calculation for the SkV cable (contained in CCN No.

1, Rev. O to this calculation) uses a value of 41,921 amperes for the available fault current as derived from Calculation NL-051 Rev. 3. This value of short circuit current was changed to 44,594 amperes in CCN No. 2, Rev. 3 to NL-051, Pg. 20 of 169, dated 12/10/96. This higher value of short circuit current should be used in this calculation.

The temperature of the smallest and shortest SkV aluminum b cable when using a short circuit value of 41,921 amperes is

} calculated to be 309.78 degrees C - well above the 250 degrees C insulation limit (refer to pg. 3 of 4 CCN No.1). This temperature will be higher once the 44,594 amperes short circuit value is used.

FPER section 6.3 states: " Associated circuits - The final concem raised by power cable faults relates to the potential for an electrical fault, which is not property cleared, to damage adjacent or nearby circuits which are required in the safe shutdown situation (common enclosure).

Because some power cables, during fault conditions, can reach temperatures in excess of accepted industry practice there is a potential that an associated circuits issue exits. Since the calculation did not address the consequences of exceeding 250 degrees C, there may be a discrepancy with the statement in the FPER.

Rei'ew van Invalid Needed Date initiator: Crockett. Ed O O O 1/6/98 VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K B O O 1/6/98 O O O 1/12/98 IRC Chmn: Singh, Anand K O O O 1/14/98 Date:

INVALID:

Date: 5/11/98 RESOLUTION: INITIAL RESPONSE: l NU has concluded that Discrepancy Report, DR-MP3-0787, has identified a condition previously discovered by NU which has Printed 5/12/98 4:24:25 PM Page 1 of s

N:rthertt Utilities ICAVP DR N3. DR-MP3-0787 Millstone Unit 3 Discrepancy Report been corrected. The issues identified in this Discr*pancy Report involving incorrect short circuit current values used in Calculation 178E, "5KV & 8KV Power Cable Temperature Under Fault Condition" with potential associated circuit problems will be addressed via corrective actions identified in existing CR No. M3-97-2358 & M3-97 3413.

(1.) CR No. M3-97-2358, Dated 7/24/97; This CR issue was identified during reviews conducted to revise the following Specifications, to resolve items contained in Conditim Reports (CR) No.10519 & 10785. l l

1. 25212-SP-EE-321, " Specification For Control of Electrical Setpoint Data Base, Vol.1 Relay Setting Sheet, Vol. 2-Circuit Breaker Setting, Vol. 3-Electrical Setpoint Calculation And Curve" l

2. SP-EE-269 " Specification For Electrical Design Criteria for Millstone Unit 3" The CR identifies cables used in the 4KV system have ,

manufacturer's listed temperature limits of 250 Deg. C. l Calculations contained in DCN DM3-S-1027-94 (4/0 aluminum power cable) Indicated that the temperature for a three phase fault could reach approximately 489 Deg. C. Also this calculation is based on 44Ka short circuit current. The revision to calculation NL 51 "MP3-6.9 KV,4.16 KV,480 V Short Circuit

& Equipment Duty Analysis" indicates currents could reach 45.5Ka.

NOTE: CR No.10519, Dated 3/20/96 identified field protective ,

relay setting for Vital 4.16KV Breakers not in accordance with l FSAR.

CR No.107P,5, Dated 3/22/96 cited a review of the electrical protection criteria contained in NERM 46,"4.16KV & 6.9KV Station Service Protection Philosophy" and NERM 45, " Station Service Protection Philosophy" against the actual setpoints controlled by Specification SP-EE-321, " Control of Electrical Setpoint Database" which identified three discrepancies. This review was being performed in response to questions posed during a NRC inspection.

(2.) CR No. M3-97-3413, Dated 10/6/97, This CR issue was identified while performing activities associated with the previous CR No. M3-97-2358 (evaluaticn of 4.16KV system protective relaying and cable thermal capability under worst case short circuit conditions). A discrepancy was discovered between the actual plant design and the required fault clearing times. It appeared the design basis calculation 178E, "5KV & BKV Power Cable Temperature Under Fault Condition" evaluation included inappropriate instantaneous relays models when determining fault clearing times. This discrepancy impacts seventy-one 4.16KV feeder circuits (non-Class 1E and Class 1E). This discrepancy resulted in License Event Report, LER 97-051-00.

(3.a) AR No. 97018497 is trackino the Corrective Actions for CR PrWed 5/12/98 4:24:28PM Page 2 of 5

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N:rthert Utilitie3 ICAVP DR N3. DR-MP3-0787 l Millstone Unit 3 Discrepancy Report l

i No. M3-97 2358. The corrective actions include; perform i additional analysis of issues raised by the CR; revise calculation NL-051 and Specification SP-EE-269 accordingly and based on the results initiate additional Condition Reports a necessary.

(3.b) AR No. 97024703 is tracking the Corrective Actions for CR No. M3-97 3413. The corrective actions assignments include; the electrical protection relaying scheme for the individual 4.16KV affected circuits will be restored to conform with the design basis; the design change must comply with R. G.

1.32(IEEE 380-74) and NRC Branch Technical Position BTP 9.5-1 (Fire Protection).

(4.) Corrective actions (Items 3.a & 3.b) to revise calculation NL-51 and Specification SP-EE-269, prepare, issue and implement the electrical protection relaying schemes / modifications for the applicable 4.16KV circuits will be completed prior to startup.

1

Conclusion:

NU has concluded that Discrepancy Report, DR- l l

MP3-0787, has identified a condition previously discovered by NU which has been corrected. The issues identified in this Discrepancy Report involving incorrect short circuit current values used in Calculation 178E. "5KV & 8KV Power Cable ,

Temperature Under Fault Condition" with potential associated l circuit problems will be addressed via corrective actions identified in existing CR No. M3-97-2358 & M3-97-3413.

(1.) CR No. M3-97 2358, Dated 7/24/97, identified cables used in the 4KV system have manufacturer's listed temperature limits of 250 Deg. C while calculations indicated that the temperature could reach approximately 489 Deg. C. Also existing calculation short circuit currents conflict with NL-051, *MP3-6.9 KV,4.16 KV, 480 V Short Circuit & Equipment Duty Analysis".

(2.) CR No. M3-97 3413, Dated 10/6/97, identified a discrepancy between the actual plant design and the required 4.16KV protective relaying fault clearing times per design basis calculation 178E, "5KV & 8KV Power Cable Temperature Under Fault Condition" (3.a) AR No. 97018497 & (3.b) AR No. 97024703 are tracking l the corrective actions respectively. '

The corrective actions include; perform additional analysis of issues raised by the CR; revise calculation NL-051 and Specifications as required; the electrical protection relaying scheme for the individual 4.16KV affected circuits will be restored to conform with the design basis.

(4.) Corrective actions (Items 3.a & 3.b) to revise calculation NL-51 and specifications, prepare, issue and implement the l electrical protection relaying schemes / modifications for the applicable 4.16KV circuits will be completed prior to startup.

f SECOND RESPONSE:

l Pnnted 5/12/98 4:2429 PM Page 3 of 5 I l l

l N:rtherst Utiliti:o ICAVP DR N 2. DR-MP3-0787 l Millstone Unit 3 Discrepancy Report I 1

l

Background:

The response provided to S&L on IRF M3-IRF-01570 was found j acceptable. However, S&L still considered the discrepancy a  ;

level three (3) because the cited document, CR M3-97-2358, l 7/24/97, for establishing previous discovery was written after the l ICAVP audit start date. S&L correctly reached this conclusion I based on the information provided in the IRF. Additional information in the IRF, not amplified in the discussion section, supports the claim of previous discovery. I Disposition:

The cited CR identifies in the " Event description" section (See l Attachment 1) two other CRs: ACR 10519 (See Attachment 2) I and ACR 10785 (See Attachment 3) which were written on 3/20/96 and 3/22/96, respectively. These ACRs were created as a result of three pre-EDSFl audit finding reports: 1302,3300, 3312 (See Attachment 4,5, and 6) and are referred in the

" Problems and Failure Modes" section of the cited CR. These audit finding were written in 199'5 and the corrective actions were implemented under ACR 10519 and 10785.

Conclusion:

NUs conclusion that Discrepancy Report, DR-MP3-0787, as i

presented on IRF M3-IRF-01570, was a previously discovered discrepancy is still applicable. The discrepancy was identified  ;

prior to the start of the ICAVP inspection as documented in ACR l 10519 and ACR 10785 on 3/20/96 and 3/22/96 respectively.

Previou.ty klentified by NU? (#) Yes O No Non Di.crepent Condition?O Yes (8) No Re.olution Pending?O ve. @ No Re.oiuiion unre.oiv.d?O ve. @ No Review AcceptaW Not AccepteW Needed Date initiator: Warner,1.

O O O si m VT Lead: Neri, Anthony A VT Mgr: schopfer. Don K O O O sm IRC Chmn: singh. Anand K O O sm O O O Date: 5/11/98 SL Cornment.: INITIAL COMMENTS:

NU's conclusion states:

NU has concluded that Discrepancy Report, DR-MP3-0787, has identified a condition previously discovered by NU which has been corrected. The issues identified in this Discrepancy Report involving incorrect short circuit current values used in Calculation 178E, "5KV & 8KV Power Cable Temperature Under Fault Condition" with potential associated circuit problems will be addressed via corrective actions identified in existing CR No. M3-97-2358 & M3-97-3413.

Printed 912/98 4:24 30 PM Page 4 of s l

N:rtheast Utilities ICAVP DR N , DR-MP3 0787 Millstone Unit 3 Discrepancy Report I

l (1.) CR No. M3-97-2358, Dated 7/24/97, identified cables used in the 4KV system have manufacturer's listed temperature limits of l 250 Deg. C while calculations indicated that the temperature could reach approximately 489 Deg. C. Also existing calculation short circuit currents conflict with NL-051,"MP3-6.9 KV,4.16 KV, 480 V Short Circuit & Equipment Duty Analysis".

(2.) CR No. M3-97 3413, Dated 10/6/97, identified a discrepancy l between the actual plant design and the required 4.16KV l protective relaying fault clearing times per design basis

) calculation 178E, "5KV & 8KV Power Cable Temperature Under Fault Condition" 1

NU's response lists two CRs which address the overtemperature issue:

CR M3-97 2358 is dated 7/24/97 CR M3-97-3413 is dated 10/6/97.

Although we concur that the issue identified in this DR was identified before the DR was written, it is still classified as a level 3 discrepancy because the identification took place after the ICAVP audit start date.

COMMENTS ON NU'S SECOND RESPONSE: l We accept NU's additional documentation that this issue was previously identified.

l l

l Printed 5/12/98 4:24:32 PM Page 5 of 5

N:rtherct Utilities ICAVP DR N . DR-MP3-0806 Millstone Unit 3 Discrepancy Report l

l Review Group: system DR RESOLUTION ACCEPTED l Review Element: system Design potential Operability issue l Discipline: Electrical Design

} Discrepancy Type: Calculation O ves

! (5) No System / Process: N/A l NRC significance level: 4 Date faxed to NU:

Date Published: 1/10/98 Discrepancy: Battery and DC System Calculation Discrepancies

Description:

A. Calculation SP-M3-EE-011 (Rev.1)

1. This calculation contains tabs which derive data from numerous calculations which heve been superseded.

Calculation SP-M3-EE-011 does not state if the data from these superseded sources is still valid, only that SP-M3-EE-011 "is to maintain and preserve documentation that serves as references for the DC calculations", including " portions of previous calculations". The superseded sources should be evaluated to determine if they are still valid and, if they are, confirm in writing as part of Calculation SP-M3-EE-011, and if they are not, to be replaced with data from active calculations. For example, Tab 65 references and includes selected pages from Calculation 188E. Page 2 of Tab S5 shows the battery profile of Battery #3 and this profile shows a minimum voltage of 108.6 volts at a constant amp rate of 163 amps. However, the current battery l

calculation used for Millstone Unit 3 is BAT 3-96-1245E3 (Rev.

, 0), and it shows (on Pages 3 and 5 of Attachment H) that the

! minimum voltage is 106.66 volts at a varying load of 165.66 to l

177.03 amps.

A listing of these superseded calculations which are referenced and include portions of themselves in Calculation SP-M3-EE-011 ,

are: l Reference to Calc. Which Tab Superseded Calc. Supersedes ,

4,9,69,70,71,72, 91-019-086E3 BAT 2-96-1243E3 109,111,113 15,28,29,30,108 214E BAT 1-96-1241E3 17,27 215E BAT 1-96-1241E3 17,25,26,107 216E BAT 1-96-1241E3 17 223E BAT 2-96-1243E3 l 17.110 225E BAT 2-96-1243E3 17,112 226E BAT 2-96-1243E3 31,32 213E BAT 1-96-1241E3 105,106 91-019-087E3 BAT 1-96-1241E3 65,67,68,116 188E (see X" below)

"X" = BAT 1-96-1241E3, BAT 2 96-1243E3, BAT 3-96-1245E3, BAT 4-96-1246E3, and BAT-SYST-1240E3

2. Installed cable lengths, which are documented as attachments to this calculation, are often substituted for cable lengths listed in NU's cable raceway database *M3CBLRWY".

Pnnt@NM PM Heviever, *M3CSLRtYf" hcc nc! t;cca updcted4%g.g

N:rthea:t Utilities ICAVP DR No. DR-MP3 0806 Millstone Unit 3 Discrepancy Report installed cable lengths, therefore, it is not clear how NU maintains control to guarantee that the same cable length is used for the same cable in all calculations. Examples of the differences in cable lengths are shown on Tabs 16 through 21 of the calculation. Calculation SP-M3-EE-011 states on Tab 16 that triplex cables should have their linear length increased by an {

additional 3% to account for the twisted conductors. It is not )

clear if this calculation or other calculations which use triplex i cables for voltage drop calculations (e.g.,209E,210E,212E, etc.) have increased the cable lengths by 3%.

B. BAT 1-96-1241E3 (Rev.1) & BAT 2-96-1243E3 (Rev.1)

1. Calculation SP-M3-EE-011 (Rev.1) Tab 66 states that the minimum voltage required for an HFA relay is 60% (of 125 volts) for the operate coil and 75% (of 125 volts) for the reset coil, but the Path Voltage Drop Summary sheets of Calculations BAT 196-1241E3 and BAT 2-96-1243E3 use a minimum voltage of 76 volts (75 volts plus 1 volt for intemal wiring) for both coils.

Calculations BAT 196-1241E3 and BAT 2-96-1243E3 should be revised to agree with Calculation SP-M3-EE-011. This

! discrepancy does not have an affect on Calculations BAT 196-l 1241E3 and BAT 2-96-1243E3 because the node voltage is

always much greater than the rating of the HFA reset coil (94 volts). I

2. Calculation SP-M3-EE-011 Tab 33 states that the wattage of an Amerace (Agastat) 7000 series coil is 8 watts which equates to 8W /125V = 0.064 amps. Calculation SP-M3-EE-011 Tab 4 states that the amps of this coil is 0.07 amps or 0.14 amps. The l value used in the Load Tabulation sheets of Calculations BAT 1-l 96-1241E3 and BAT 2-96-1243E3 is 0.06 amps which is less than l Calculation SP-M3-EE-011 and is therefore not conservative.

l Calculations BAT 1-96-1241E3 and BAT 2-96-1243E3 should be ,

revised to agree with Calculation SP-M3-EE-011. This discrepancy does not have an affect on Calculations BAT 1 1241E3 and BAT 2-96-1243E3 because these devices are not energized during the battery load profile.

l

3. Calculation SP-M3-EE-011 Tab 4 states that the inrush current of a Gould J131TE relay is 160 volt-amperes, but Calculations BAT 196-1241E3 and BAT 2-96-1243E3 use a value of 160 amps for inrush in the Load Tabulation sheets.

Calculations BAT 1-96-1241E3 and BAT 2-96-1243E3 should be revised to agree with Calculation SP-M3-EE-011. This

discrepancy does not have an affect on Calculations BAT 196-1241E3 and BAT 2-96-1243E3 because the inrush current is not used during the battery load profile.

4. Calculations BAT 196-1241E3 and BAT 2-96-1243E3 state, in the " Summary of Results" (" Device Voltage"), that a voltage drop analysis is not performed for all devices. Documentation could not be found in this calculation or other calculations wnich justify that adequate voltage will exist at these devices when these devices are required to operate in any of the scenarios listed in Printed 5/12/98 4:24:59 PM Page 2 of 14

l N2rthert Utilities ICAVP DR N2. DR-MP3-0806 Millstone Unit 3 Discrepancy Report I

Calculation BAT-SYST-1240E3 (Rev.1).

5. Appendix A includes a one line diagram for the battery, l charger, and battery panels and loads. In Calculation BAT 1 1241E3, Cables 3EGFBPK600,3ENSBPK605,3EGEBPK600, 3EGSBPK600, and 3EGSBPK601 have lengths which are twice as long as shown in NU Cable Database M3CBLRWY. Other l cables shown in the one line, as well as all cables shown in the one line of Calculation BAT 2-96-1243E3, agree with M3CBLRWY.

In the one line diagram in Calculation BAT 2-96-1243E3, Cable 3ENSAOK605 is shown as a #12 AWG cable, but M3CBLRWY shows this cable with a Mark Number NHT-93 which is a #6 AWG cable.

! In the one line diagram in Calculation BAT 2-96-1243E3, Cable 3CES80C110 is shown as a #14 AWG cable, but M3CBLRWY shows this cable with a Mark Number NHQ-47 which is a 24/C

1. 16 AWG cable.

Review Valid invalid Needed Date Initiator: Kendall, D. J.

6 O O 12/18/97 VT Lead: Neri, Anthony A B O O 12/18/97 VT Mgr: schopfer. Don K S O O 2/23/97 BRC Chmn: singh, Anand K 8 O O 12/31/97 Date:

INVALID:

Date: 5/11/98 RESOLUTION: First Disposition:

NU has concluded that Discrepancy Report DR-M3-0806 has identified two conditions (B.3, B.5) not previously discovered by NU which require correction.

Item B.3.

Calculation BAT 196-1241E3 & BAT 2-96-1243E3 has to be revised to reflect the correct inrush rating for Gould J131TE relays. Correct inrush rating is 160VA, not 160 amperes as currently used in the two calculations. This error does not affect the calculated values used in the battery load profiles presented in the calculations.

Because this discrepancy does not have an affect on the calculations, NU considers this discrepancy to be a Significance Level 4.

The corrective action plan approved in CR M3-98-0668 will correct this error post startup.

Item B.S.

Issues presented in item B.5 that are discrepancies.

In the one line diagram of Calculation BAT 2-96-1243E3, cable 3EGEBPK600 is desigr'ated as a #12 AWG, which agrees with Printed 5/12/98 4:25:00 PM Page 3 of 14

r

-- m l

\

N:rtherst Utilitie3 ICAVP DR Nr. DR-MP3-0806 Millstone unit 3 Discrepancy Report the cable raceway schedule. The database within the calculation indicates that it is a 210 foot #4 AWG cable. The voltage drop calculated using the correct cable conductor (#12 AWG) is .74 volts compared to a voltage drop of .22 volts used in Calculation BAT 2-96-1243E3, Attm. B, page 4 of 187. This results in a margin of 7.61 volts instead of the previous margin of 8.12 l

volts. This is a discrepancy which has no impact on the calculation conclusion, therefore NU considers it a Significance Level 4.

The corrective action plan approved in CR M3-98-0668 will correct this error post startup.

Cable 3ENSAOK605 is not identified correctly on the one line diagram (Appendix A page 2 of 2)in Calculation BAT 1 1241E3 (Note - discrepancy report references the wrong calculation - BAT 2-96-1243E3) . It's correct cable Mark Number is NHT-93 which is a #6 AWG cable rather than a #12 AWG cable. Calculation Change Notice #7, Rev.1 has corrected this error. The correct cable values were used in the calculation.

Because this discrepancy has only a minor impact on the l calculation NU considers it a Significance Level 4.

Issues presented in item B.5 which are not discrepancies. l Cable 3CES80C110 has a Mark Number of NHT-93 which is a

1. 6 AWG cable. What is presented in the One Line Diagram (BAT 196-1241E3) is an equivalent length in terms of a #14 AWG cable for all the cables. CCN #7 has required the terms

" equivalent level" to be added to the diagram. The correct cable values were used in the calculation.

NU considers this part of item 5.B to not represent a discrepant condition.

Cables 3EGFBPK600,3ENSBPK605,3EGEBPK600, 3EGSBPK600 & 3EGSBPK601 are in shown on the one line diagram in Appendix A, page 2 of 2 of Calculation BAT 2 1243E3 (not in BAT 1-96-1241E3 as indicated in the discrepancy report). The cable lengths shown on the one line diagram are loop lengths (exactly double the cable length value presented in the calculation). This issue in item B.5 does not constitute a discrepancy because the correct cables lengths are used in the calculation.

NU has concluded that the other five items (A.1, A.2, B.1,8.2, 6.4) reported in Discrepancy Report DR-MP3-0806 do not represent discrepant conditions.

Item A.1.

The specification SP-M3-EE-011 is referenced as a calculation throughout the DR. This document is not a calculation but a l specification as stated on its title page. The purpose of this i document is to ease the tracking of references and can be used to find other reference sources that are readily available such as specifications. An example of this is the solenoid operated valves. While minimum voltaaes are indicated in the reference Pnnted 5/12/98 425:02 PM Page 4 of 14

N:rthert Utilities ICAVP DR N3. DR-MP3-0806 Millstone Unit 3 Discrepancy Report  !

specification, the original specification numbers are also provided as the real source document. In this respect, the I reference specification is used to capture documents that are in the nuclear documentation system for ready retrieval and also as i an engineering tool to lead the user to original source {

documents. The difference in values between SP-M3-EE-011 and Calculations BAT 1-1241E3 and BAT 2-1243E3 as explained in item A.1 do not represent a discrepant condition.

Item A.2.

The control in the DC calculations are provided by having a centralized or main database. For consistency, calculation of l voltage drop to panels and components are performed using this l single database. The NU's cable raceway database contains 'as I l designed' or ' cut length's' of cables which was used to facilitate l construction. It is acceptable to have this conservatism in the l calculations. To move a step further, if 'as installed' cable length information is available to use in the calculations, it is be i acceptable. The main DC feeder cables from the battery to the l main distribution switchboards and from these switchboards to l distribution panels have been reviewed (via walkdown inspections) to provide more accurate values.

Since the most conservative value (cut length) is used in these j calculat;ons unless a more accurate length is determined (by  !

walkdown). NU does not consider this a discrepancy.

Item B.1. f The HFA relay has a minimum voltage of 60% of its 125VDC l

rating to pickup. Calculations BAT 1-1241E3 and BAT-1243E3 uses this value (75VDC) plus one volt (one volt accounts for l l

contact and intemal wiring resistance) to develop the 76VDC l l requirement for both coils. This value envelopes the 75% value l to reset the coil. As stated in the DR this issue voltage does not l effect the calculations because the node voltage (94VDC) is always much greater than the rating of the HFA reset coil. NU does not consider this a discrepancy because the difference in values between SP-M3-EE-011 and Calculations BAT 1-1241E3 l and BAT 2-1243E3 as explained in item A.1 do not represent a

! discrepant condition.

Item B.2.

, The 8 watts Agastat rating was used as an input to the l calculation. The computer program rounds calculated values to

! the accepted method of rounding up when the value is 5 or j above and down when it is 4 or below. This is acceptable when l considering the third decimal place in a calculation.

1 NU does not consider this a discrepancy because the difference in values between SP-M3-EE-011 and Calculations BAT 1-1241E3 and BAT 2-1243E3 as explained in item A.1 do not represent a discrepant condition.

Item B.4.

The majority of components have voltage drop calculated to ensure proper operation and are documented in Attachment B of the calculations. All critical components that are connected directiv to the DC distribution system are calculated for voltaae Printed 5/12/98 4:2s:o2 PM Page 5 of 14

l N:rthext Utilitie3 ICAVP DR N2. DR-MP3-0806 uillstone unit 3 Discrepancy Report drop. The assumption is that if the specified voltage for the control panel (i.e. skid mounted equipment) is available, then voltage drop does not necessarily have to be calculated to individual components for that panel.

NU does not consider this a discrepancy.

The above five issues do not represent discrepant conditions only clarification of specific issues, as a consequence, determination of Significance Levelis not required.

First

Conclusion:

NU has concluded that Discrepancy Report DR-M3-0806 has identified two items (B.3, B.5) not previously discovered by NU which require correction. The wrong component rating identified in item B.3 did not effect either calculation and the wrong cable designation in item B.5 caused a minor change to the cable's voltage drop determination. The approved corrective action plan for CR M3-98-0668 will correct both issues post startup. Because these items represent minor errors which have no impact on the calculation conclusions, NU considers this a Significance Level 4 DR.

NU has concluded that the other five items (A.1, A.2,8.1, B.2, B.4) reported in Discrepancy Report DR-MP3-0806 do not represent discrepant conditions. Only issue clarification was needed for these items.

Second Disposition:

NU has concluded that the " Follow-Up" items to Discrepancy Report DR-M3-0806 do not represent discrepant conditions. The approved corrective action plan for CR M3-98-0668 will provide additional clarification for users not familiar to the Battery and DC System Calculations.

Item A.1 A change to the Purpose section of SP-M3-EE-011 will be processed to clarify the use of historical and superseded data contained in the specification. The corrective action plan for CR No. M3-98-0663 has been changed to track this activity as a post-start-up item.

Item A.2 Follow-Up response to DR No. 763 (IRF No. 2016)- answers the same question on 120V SCV panel voltage drop calculation.

Item B.4

1. The fast transfer circuit for the 34C bus was reviewed. NU concurs with the S&L computation that there is approx. 6 ohms of circuit resistance in the breaker control circuit (Path C). The l close coilis rated 6 amps @ 125VDC. The minimum voltage I required to close the circuit is 90V. The current drawn by the l close coil will be 4.34 A (6* available coil voltage /125). We can i take credit for conductor resistance at a lower temperature (40 1 Pnnted 5/12/96 4:25:03 PM Page 6 of 14 1

L____________._____.

r 1 l l DR No. DR-MP3-0806 l

N:rthe:st Utilitie2 ICAVP Millstone Unit 3 Discrepancy Report j l deg. C) since the conductors to the closing coil are not energized l until the closing coil operates and will assimilate ambient temperature. This equates to an approx. 25V control circuit voltage drop requiring the battery voltage to be greater than 115V to assure the fast transfer circuit will function properiy.

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

At a minimum, the loss of a battery charger would be alarmed on Low DC volts @ 129V. The plant TS dictate a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> LCO, therefore, the swing charger will be placed into service promptly, long before a voltage of 115V is reached.

3. NU does not rely on the chargers to support DC voltage for the operation of the fast transfer circuit. A formal calculation change will be processed to address this specific scenario. The corrective action plan for CR M3-98-0668 was revised to track this activity as a post-start-up item.

Item B.5 A & B - Cable No. 3CES80C110 is 38ft. of NHQ-47. This is a 24/c #16 copper pre-fabricated cable. The calculation properly models this a an equivalent #14 conductor and the cable / raceway program is correct.

C - The calculation one-line diagrams indicate a single run cable length and were shown for diagrammatic purposes. To avoid futther confusion of the cable length versus loop length issues, the one-line diagrams contained in the calculation will be revised to eliminate any reference to circuit lengths. The corrective action plan for CR M3-98-0668 was revised to track this activity as a post-start-up item.

I Significance level criteria does not apply to the above items, as they do not represent discrepant conditions. However the overall I

significance level of this DR remains a level 4 as described in the previous IRF-01616.

Second

Conclusion:

NU has concluded that the

• Follow-Up" items to Discrepancy Report DR-M3-0806 do not represent discrepant conditions.

Response to these items only provides clarification of the issues. Significance level criteria does not apply to the above items, as they do not represent discrepant conditions. However the overall significance level of this DR remains a level 4 as described in the previous IRF-01616.

l Previously identified by NU? O Yes (e) No Non Discrepent Condnion?O Yes (e) No Resolution Pending?O Y.. @ No R.soiuiion unr oiv.d?O Yes @ No Review initiator: Kendall. D. J.

VT Lead: Nerl, Anthony A Pnnted 5/12/98 4.25:05 PM Page 7 c.f 14 w_________ _ _ _ _ _

l N:rthext Utilitie3 ICAVP DR N2. DR-MP3-0806 Millstone Unit 3 Discrepancy Report

, . um. ~~y r.

gg VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K O O Sm Date:

O O 5/11/98 st. comments: Comments on First NU Response:

Item A.1 Sargent & Lundy agrees that SP-EE-011 is a specification and not a calculation. This document states that it's purpose "is to maintain and preserve documentation that serves as references for DC calculations". The example provided in this Discrepancy Report is just one example of how documentation was not maintained. Until the purpose is revised, this is still a discrepancy because the inconsistencies between this specification and the battery calculations.

Item A.2 As far as SP-EE-011 is concemed, Sargent & Lundy agrees that this is not a discrepancy. However, the generic question raised in this Discrepancy Report of how NU maintains control of their cable lengths was not addressed by NU in their response.

Furthermore, the statement that the most conservative value (i.e.,

cut length) was used in the battery sizing calculation is only true in regard to voltage drop calculations and is not true of short circuit calculations (where the shortest cable length would be the most conservative) which are also performed in the battery sizing calculation, l

items B.1 & B.2 I Sargent & Lundy agrees with NU's response that this is not a discrepancy.

1 llem B.4 Sargent & Lundy agrees that, for those circuits required to operate under the scenarios described in Calculation BAT-SYST-1240E3, NU has modeled and analyzed each of those circuits and that NU has concluded these circuits are able to perform their safety-related function. The point in question is for circuits included in the battery sizing calculations (e.g., BAT 1-96-1241E3, ,

BAT 2-96-1243E3, BAT 3-96-1245E3, BAT 4-96-1246E3) but which are not required to operate, Sargent & Lundy could not find evidence (e.g., a calculation) which addresses whether safety-related circuits such as the following breaker circuits would have adequate voltage at the close and trip coils (90 and 70 volts, respectively) to be able to perform their safety-related function under normal operating conditions:

l Bkr Load: Description (Device ID) l 32R01-2: 480V Bus 32R Supply Breaker (3EJS*ACB-AC) 32R04-2: MCC Aux Bldg (3EHS*MCC3A1) l j 32R05-2: MCC Rod Control Area (3EHS*MCC3A2)

Prtnted 5/12/98 4:25 06 PM Page B of 14 l

i

l ICAVP DR N2. DR-MP3-0806 N:rthext Utilities l Millstone Unit 3 Discrepancy Report 32R06-2: Aux Bldg Air Filter Unit (3HVR*FLT1 A) 32S-1T-2: Bus Tie to Bus 32R (3EJS*ACB-T2A) l 32S01 2: 480V Bus 32S Supply Breaker (3EJS*ACB-AB) 32S07 2: Fuel Bldg Filter Assembly (3HVR*FLT2A) l 32T-1T-2: Bus Tie to 32S (3EJS*ACB-T1 A) 32T01-2: 480V Bus 32T Supply (3EJS*ACB-AA) 32T05-2: MCC Control Building (3EHS*MCCA12) 32T06-2: MCC Circ. & Serv. Wtr. Pump Hse. (3EHS*MCCA15) 32T09-2: MCC Safeguards Area (3EHS*MCC1 A4) 32Y-1T-2: Bus Tie to 32R (3EJS*ACB-T4A) 32YO12: 480V Bus 32Y Supply (3EJS*ACB-AD) 15G-14U-2N: EDG Neutral Breaker (3 ENS *ACB-GNA) 23SA3-34C-2: RSST Supply to 34C (3 ENS *ACB-AR) 34C012: 480V Load Center 32Y (SENS*ACB AD) 34C03-2: 480V Load Center 32T (3 ENS *ACB-AA) 34C04-2: 480V Load Center 32S (3 ENS *ACB-AB) 34C05-2: 480V Load Center 32R (3 ENS *ACB-AC) 34C06-2: Quench Spray Pump (30SS*P3A) 34C07-2: Residue Heat Removal Pump (3RHS*P1 A) 34C08-2: Safety injection Pump (3SlH*P1 A) 34C10-2: Reactor Plant CCW Pump (swing pump) (3CCP*P1C) 34C20-2: Containment Recire. Pump P1C (3RSS*P1C) 34C21-2: CVCS Charging Pump P3A (3CHS*P3A) 34C22-2: CVCS Charging Pump P3C (swing pump)

(3CHS*P3C)

To illustrate the point in question, Sargent & Lundy reviewed the control circuit for 4KV Circuit Breaker 3 ENS *ACB-AR which is not required to either close or trip as shown in Calculation BAT 1 1241E3. The following are the results of this review.

Five circuit paths were reviewed from the incoming fuses at Switchgear 3 ENS *SWG-A to the close coil 52X for breaker 3 ENS *ACB-AR (Schematic Diagram 12179-ESK 5BD, Revision 24), and the associated cable number and Mark #, conductor size, conductor length, and 900C resistance are shown below, starting at the load side of the fuse at the positive polarity:

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

Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MBS (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MB5 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB5 to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, a;16, 38 feet,0.0055465 W/ft); Wire CO1 from 3CES*MCB-MB80 to l

3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet, 0.0021421 W/ft); Wire C01 from 3 ENS *SWG-A to 3RPS*PNI.AS l

(Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to SENS*SWG-A (Cable 3ENSAOC353,

}

NHT 26, #14,130 feet,0.0034171). Total resistance is 4.0237 ohms at 6 amps, or 24.14 voltage drop for Path A.

l Path B: Wire PC1 from 3 ENS *SWG-A to 3CES*TB-MB80 Pnnted 5/12/98 425:07 PM Page 9 of 14

North 2ast Utiliti:s ICAVP DR No. CR-MP3-0806 Millstone Unit 3 Discrepancy Report (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft);

Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MBBO to 3RPS*RAKOTXA (Cable 3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wire CO9 from 3RPS*RAKOTXA to 3CES*MCB-MB80 (Cable 3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wire CO9 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16, 38 feet,0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MBS (Cable 3ENSAOC356, NHT 32, #14,298 feet, 0.0034171 W/ft); Wire C01 from 3CES*MCB-MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHO-47, #16,38 feet,0.0055465 W/ft);

Wire C01 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet, 0.0021421 W/ft); Wire CO1 from 36NS*SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to SENS*SWG-A (Cable 3ENSAOC353, NHT-26,

1. 14,130 feet,0.0034171). Total resistance is 6.2977 ohms at 6 amps, or 37.79 voltage drop for Path B.

Path C: Wire PC1 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire PC1 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire COS from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO6 from 3 ENS *SWG-A to 3CES*PNLBG30 (Cable 3ENSAOC354, NHT-35, #14,110 feet,0.0034171 W/ft); Wire CO7 from 3CES*PNLBG30 to SENS*SWG-A (Cable 3ENSAOC354, NHT-35, #14,110 feet,0.0034171 W/ft); Wire CO7 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO7 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16,33 feet, 0.0055465 W/ft); Wire CO2 from 3CES*MCB-MB8 to 3CES*MCB-MB5 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire CO1 from 3CES*MCB-MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft);

Wire CO1 from 3CES*MCB-MB8 to 3CES*MCB-MB80 (Cable 3CES80C102, NHQ-47, #16,38 feet,0.0055465 W/ft); Wire C01 from 3CES*MCB-MB80 to SENS*SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO1 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26,

1. 14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to SENS*SWG-A (Cable 3ENSAOC353, NHT-26, #14,130 feet, 0.0034171). Total resistance is 5.8739 ohms at 6 amps, or 35.24 voltaae drop for Path C.

Printed 5/12/98 425:08 PM Page 10 of 14

N:rthe:st Utilities ICAVP DR NO. DR-MP3-0806 Millstone Unit 3 Discrepancy Report Path D: Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft);

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

Path E: W!re COS from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); CO5 l from 3CES*MCB-MB80 to 3RPS*RAKOTXA (Cable j 3ENSAOC357, NHT-26172 feet,0.0034171 W/ft); Wire CO9 i from 3RPS*RAKOTXA to 3CES*MCB-MB80 (Cable l 3ENSAOC357, NHT 26172 feet,0.0034171 W/ft); Wire CO9 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3 ENS *SWG-A to 3CES*TB-MB80 (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire CO3 from 3CES*TB-MB80 to 3CES*MCB-MB8 (Cable 3CES80C102, NHQ-47, #16, 38 feet,0.0055465 W/ft); Wire CO2 from 3CES*MCB-MBS to 1 3CES*MCB-MB5 (Cable 3ENSAOC356, NHT-32, #14,298 feet, 1 0.0034171 W/ft); Wire C01 from 3CES*MCB-MBS to 3CES*MCB-MB8 (Cable 3ENSAOC356, NHT-32, #14,298 feet,0.0034171 W/ft); Wire C01 from 3CES*MCB-MB8 to 3CES*MCB-MB80  !

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

Wire CO1 from 3CES*MCB-MB80 to 3 ENS *SWG-A (Cable 3ENSAOC350, NHT-60, #12,158 feet,0.0021421 W/ft); Wire C01 from 3 ENS *SWG-A to 3RPS*PNLAS (Cable 3ENSAOC353, NHT-26, #14,130 feet,0.0034171); Wire COO from 3RPS*PNLAS to SENS*SWG-A (Cable 3ENSAOC353, NHT-26,

1. 14,130 feet,0.0034171). Total resistance is 5.8739 ohms at 6 amps, or 35.24 voltage drop for Path E.

Similarly, the circuit resistance from the switchgear fuses to the trip coil of Circuit 3 ENS *ACB-AR is 1.0984 and 3.1350 for two paths that were reviewed, resulting in voltage drops of 6.59 and 18.81 volts, respectively.

As noted in the review, the voltage drop for the close coil of Circuit 3 ENS *ACB-AR, ranging from 24.14 to 37.79 volts, is significant. Since 90 volts is required at the close coil, a voltage of 114 to 128 volts is required (90 + 24 = 114 and 90 + 38 = 128) at Switchgear 3 ENS *SWG-A (and an even higher voltage at 3BYS*PNL1 and the battery terminals). This would suggest that NU is taking credit for the charger, and not the battery, supplying power to de loads durina normal operation, for the battery would Pnnted 5/12/98 4:25:00 PM Page 11 of 14

N:rthesct Utilities ICAVP DR No. DR-MP3-0806 Millstone Unit 3 Discrepancy Report not be able to sustain a voltage level of that magnitude.

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

In addition, if the charger, and not the battery, is supplying power to de loads dering normal operation, then on a 4KV bus undervoltage, the charger is disabled (on loss of power) and a bus fast transfer from the normal supply to the reserve supply cannot be performed because this Breaker 3 ENS *ACB-AR cannot close (because the battery cannot provioe the required 90 volts to the close coil). Sargent & Lundy requests that NU:

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

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

discrepancy report. I

2. Verify that NU relies on the charger rather than the battery for supplying power under normal operating conditions to the de loads. If the battery is relied upon, explain how the battery can supply these loads with adequate voltage to operate the close and trip coils. If the spare charger is relied upon, explain how the

! loads are adequately powered from the time the normal charger fails until the time the spare charger is energized.

3. If the charger is relied upon for supplying dc loads during normal operation, either concur with Sargent & Lundy's conclusion that fast transfer cannot be accomplished, or if NU disagrees with Sargent & Lundy's assessment, then explain how l fast transfer is accomplished.

Item B.5 A) NU's disposition states that Cable 3CES80C110 is a NHT-93 cable (#6 AWG) disagrees with the Cable Schedule M3CBLRWY l which was reviewed on 2/25/98. M3CBLRWY does not have an entry for Cable 3CES80C110 (referenced in NU's response to this Discrepancy Report), but it does have an entry for 3CES80C110 (the letter O after number 8), and it is identified as Mark # NHQ-47 which is a 24/C #16 AWG cable. Therefore, there is still a discrepancy, if not in the battery sizing calculations, then in the PrWed 5/12/98 4:25:10 PM Page 12 of 14

(

N:;rthert Utilities ICAVP DR N3. DR-MP3-0806 l Millstone Unit 3 Discrepancy Report Cable Schedule M3CBLRWY.

B) NU states that an equivalent length of #14 AWG cable is used for the cable run from 3BYS*PNLDG1F to 3EGS*TBEG1 A (Circuit #5). This is only true if 3CES80C110 is a #16 AWG cable:

At 20 degrees C,1049 feet of #14 AWG cable = 1049

• 0.00268 ohms /ft = 2.8 ohms.

At 20 degrees C, (350 feet of #12 AWG cable) + (700 feet of

1. 14 AWG cable) + (82 feet of #16 AWG cable for 3CESSOC110)

= 350

• 0.00168 ohms /ft + 700

• 0.00268 ohms /ft + 82

• 0.00435 ohms /ft = 2.8 ohms.

If 3CES80C110 is a #6 AWG cable, this would equate to 2.5 ohms (#6 AWG is 0.00419 ohms /ft at 20 degrees C) and is not equal to 1049 feet of #14 AWG. (Cable lengths taken from M3CBLRWY.)

Sargent & Lundy agrees that the change made to the calculation in CCN #7 addresses the " equivalent length" issue, however, this is still a discrepancy for the reasons noted above.

C) NU states that the lengths shown on the One Line Diagram for Cables 3EGFBPK600,3ENSBPK605,3EGEBPK600, 3EGSBPK600, & 3EGSBPK601 are loop lengths and not cable lengths. Sargent & Lundy concurs that, upon performing a manual voltage drop computation, the correct lengths were used in the voltage drop calculations of BAT 2-96-1243E3. However, this is still a discrepancy because the One Line Diagram represents these cables in the same manner as Cables 3ENBBPK600, 3EJBBPK620, 3MSSNPK601, 3BYSNPK601, 3BYSNPK607, 3BYSNPK603, 3BYSNPK604, 3BYSNPK605, 3BYSNPK606, 3EJBBPK605, 3RPSBPC601, 3EJBBPK610, 3EJBBPK615, 3EGFAOK600, 3ENSAOK605, 3EG EAOK600, 3EGSAOC600, 3EGSAOK600, 3ENBAOK600, 3EJBAOK621, 3MSSNOC602, 38YSAOC600, 3BYSNOK610, 3BYSNOK601, 38YSNOK602, 3BYSNOK603, 3BYSNOK604, 3BYSNOK605, 3BYSNOK606, 3EJBAOK605, 3RPSAOC601, 3EJBAOK610, and 3EJBAOK615, yet the lengths shown on the One Line Diagrams i for these cables are cable lengths and not loop lengths. In other words, the lengths must all be assumed to be cable lengths OR loop lengths, unless otherwise noted on the One Line Diagrams.

Comments on Second NU Response:

l Item A.1:

Sargent & Lundy agrees with NU s Second Response which is to

! revise SP-M3 EE-011.

l item B.S.C: i Sargent & Lundy agrees with NU's Second Response which is to revise Calculation BAT 2-96-1243E3.

PrWed 5/12/96 4:25:11 PM Page 13 of 14

N:rthea:t Utilitie3 ICAVP DR N2. DR-MP3-0806 Millstone Unit 3 Discrepancy Report item B.4:  !

Sargeat & Lundy accepts NU's conclusion that battery chargers are not required to support DC voltage for the operction of the fast transfer circuit. Based on NU's commitment to perform the required calculations and the belief that the most limiting condition has already been analyzed, SarCent & Lundy has classified this as a Level 4 discrepancy.

Note that NU's Second Response states that items A.1, B.4, and B.S.C are non-discrepant. Sargent & Lundy disagrees that these issues are non-discrepant although Sargent & Lundy accepts the technical content of NU's Second Response for these items.

Item A.2: 1 NU's Second Response references DR-MP3-0763 because this l item is similar to item C.2 of DR-MP3-0763. Based on the additional information provided by NU on DR-MP3-0763, Sargent

& Lundy concludes that item A.2 in Sargent & Lundy's First Response is non-discrepant.

Items B.S.A and B.S.B:

NU's Second Response verifies that the information contained in NU's First Response about Cable 3CES80C110 is in error. NU's Second Response adequately explains and justifies the modeling of this cable in the battery sizing calculation BAT 1-96-1241E3, On this basis, Sargent & Lundy agrees that this issue is non-discrepant.

l PrWed 5/12/98 4.25:11 PM Page 14 of 14

N:rtherst Utilities ICAVP DR No. DR-MP3-0808 Millstone unit 3 Discrepancy Report  ;

Review Group: Systern DR RESOLUTK)N ACCEPTED Potential Operability issue i Discipline: Electrical Design Discrepancy Type: Licensing Document Om i System / Process: DGX g j l

NRC Significance levet: NA Date faxed to NU: -

l Date Published: 1/1c/98 i Discrepancy: Frequency and Voltage Values in DBSD do not appear to match Tech Spec Values Descript6on:

Background:

l Emergency Diesel Generator A Operability Test, OPS Form '

l 3546A.1-1, Page 2 of 3, dated 5/6/97 lists a number of Generator Operability Tests and Tech Spec Acceptance Criteria.

Step Parameter / Condition T/S Acceptance Criteria 4.2.7 EDG A Voltage 3740 - 4580 V l 4.3.6 EDG A Frequency 59.2 - 60.8 Hz  ;

l Design Basis Summary Document 3DBS-EDG-002, paragraph

8.1 states

Generator Terminal Voltage - Steady State: 4160 Volts nominal j steady state (4347 volts maximum,3973 volts minimum) within

+/- 21 volts Design Basis Summary Document 3DBG-EDG-002, paragraph

8.2 states

Generator Frequency - Steady State: 60 Hz Nominal steady state (60.5 Hz maximum in the no load, droop mode, 59.85 Hz minimum)

Conclusion:

The nominal values stated in the Design Basis Summary Document do not appear to match the limit on "as found" values in the Tech Spec Operability tests.

Review Valid invalid Needed Date in.tiator: Warner, l. B 0 0 32/ie/97 VT Lead: Neri, Anthony A O O O 12/17/97 VT Mgr: Schopfer, Don K B O O 12/23/97 1RC Chmn: Singh, Anand K -

0 12/31/97 Date:

I INVALID:

Date: 5/8/98 RESOLUTK)N: INITIAL RESPONSE:

Disposition:

Printed 5/12/98 4:25:34 PM Page 1 of 5 t

J

Northeart Utilitin ICAVP DR No. DR-MP3-0808 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report, DR-MP3-0808, has identified a condition previously discovered by NU which reqdnss correction.

The Emergency Diesel Generator (EDG) Voltage limits provided in the Technical Specification is common to all power plants and represents the reasonable EDG performance. The MP3 Technical Specification for diesel generator operability requires verifying that the diesel starts from standby conditions and achieves generator voltage and frequency of 4160 +/- 420 volts (4580 to 3740 Volts) and 60 +/- 0.8 Hz. Condition Report (CR)

M3-97-0730 was written to address operatlog outside the equipment requirements. The Design Basis Summary Document (DBSD) 3DBS-EDG-002 section 8.1 and 8.2 steady state terminal voltage 4160 (4347 volts maximum,3973 volts minimum ) within +/- 21 volts and frequency 60 Hz nominal (60.5 Hz maximum in no load and droop mode 59.85 Hz) come from the Stone and Webster motor and generator system specification " Emergency Diesel Generator System (E-241)".

The DBSD is not discrepant with the Technical Specifications because the Emergency Diesel Generator System specification is more restrictive and the equipment is better bounded by the values in the Technical Specifications. The approved Corrective Action Plan (CAP) (attached) for Condition Report (CR) M3 0730 will " Revise proceaures to include steady state voltage limits to be monitored between 4350 and 3950 Volts." This activity is not a startup issue.

Conclusion:

NU has concluded that Discrepancy Report, DR MP3-0808, has identified a condition previously discovered by NU which requires correction.

Condition Report (CR) M3-97-0730 was written to address operating outside the equipment requirements. The approved Corrective Action Plan (CAP) (attached) for Condition Report (CR) M3-97-0730 will revise procedures to include steady state voltage limits to be monitored between 4350 and 3950 Volts.

This activity is not a startup issue.The DBSD is not discrepant with the Technical Specifications because the Emergency Diesel Generator System specification is more restrictive and the equipment perfor. nance is better then required by Technical Specifications.

SECOND RESPONSE:

Disposition: l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition. The values used in the Design Basis Summary Document are taken from the EDG specification and the requirements of NEMA MG Pmted 5/12/96 4:25:37 PM Page 2 of 5

_ - _ _ _ _ _ _ _ _ i

Northe=t Utilities ICAVP DR Nr. DR-MP3-0808 Millstone Unit 3 Discrepancy Report i 1

1. The nominal rating of the machine is 4160 volts and NEMA allows a 15% variation under steady state conditions. The allowable 5% variation on nominal voltage equates to 208 volts or the 4160 volt basis. The values used in the Design Bases Summary Document allow a 1187 volt variation with the i additional 121 volts allotted to tolerances and reading errors. The total of the allowable deviation from nominal is 208 volts or 5%

The DBSD has set the limits in the following manner: 4160 volts i4.5% within t0.5%. This is consistent with the specification and the NEMA standard. The voltage range used in the EDG operating procedure is consistent with the Technical Specifications and encompass the DBSD values. The intent of the wording in the original response to this Discrepancy Report was to indicate that as long as the EDG performed in accordance with the limits of the design specification and NEMA, the technical specification values would not be challenged and would fully bound all operations. It is in this sense that there is no j discrepant condition even though the Technical Specification i values and the Design Basis Summary Document values do not I agree.

With regard to calculations, the 4160v bus voltage maximum and minimum values calculated in NL-038 are based on load flow analysis of various scenarios with respect to switchyard minimum and maximum voltage, power source (NSST, RSST or EDG), and Normal or LOCA conditions.

The minimum and maximum voltages are as a result of the station loading (maximum LOCA loading vs. minimum Refueling Outage loading) and the offsite supply voltage regulation (363kV to 345kV). The non-LOOP cases for minimum and maximum voltages envelope the LOOP cases when the isochronous EDG controls the voltage. The EDG voltage regulator is set at 4160 volts with a 10.5% regulation (4140v to 4180v). This voltage range is clearly enveloped by the NL-038 non-LOOP profiles (3698v to 4272v).

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-MP3-0713, does not represent a discrepant condition. The values used in the Design Basis Summary Document are taken from the EDG specification and the requirements of NEMA MG 1.

The intent of the wording in the original response to this Discrepancy Report was to indicate that as long as the EDG performed in accordance with the hmits of the design specification and NEMA, the technical specification valuas would not be challenged and would fully bound all operations. It is in this sense that there is no discrepant condition even though the Technical Specification values and the Desian Basis Summary PrWed 5/12/98 4:2s:38 PM Page 3 of 5

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ICAVP DR No. DR-MP3-0808 N:rtheast Utilitie3 milistone unit 3 Discrepancy Report Document values do not agree.

l With regard to calculations, the 4160v bus voltage maximum )

and minimum values calculated in NL-038 are based on load j flow analysis of various scenari',s with respect switchyard minimum and maximum voltage, power source (NSST, RSST or EDG), and Normal or LOCA conditions.

The minimum and raaximum voltages are as a result of the station loading (maximum LOCA loading vs. minimum Refueling Outage loading) and the offsite supply voltage regulation (363kV to 345kV). The non-LOOP cases for minimum and maximum voltages envelope the LOOP cases when the isochronous EDG controls the voltage. The EDG voltage regulator is set at 4160 volts with a iO.5% regulation (4140v to 4180v). This voltage range is clearly enveloped by the NL-038 non-LOOP profiles (3698v to 4272v).

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

Previously klentified by Nu? O Yes (*) No Non Di.crepent condition?@ Ye. O No Re.olution Pending?O ve. @ No Re.oiution unr..oiv.d70 ve. @ No l Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K ,

IRC Chmn: singh, Anand K Date: 5/8/98 sL Comment.: COMMENTS ON INITIAL REPONSE:

We concur that Condition Report (CR) M3-97-0730 (initiated 3/7/97) identified an issue with respect to operating the diesel generstors at more than 5% above or below its rated voltage. We do not concur that the CR addresses the DR issue.

The DR response states:

"The DBSD is not discrepant with the Technical Specifications because the Emergency Diesel Generator System specification is more restrictive and the equipment is better bounded by the values in the Technical Specifications."

The definition of

• restrictive" is dependent on how the DBSD is l being used. If the high end voltage value stated in the DBSD was i used to estimate a fault current, then the value in the DBSD l would not be more restrictive. In addition, the CR states that the l voltage values in calculation NL-038 are 3744V (min) and 4310V (max) which do not bound the values in the DBSD.

If the DBSD is to contain a value, such as 4160V +/- 4.5%, there should be some stated relationship between this value and the values used in other documents.

Printed 5/12/98 425:39 PM Page 4 of 5

ICAVP DR No. DR-MP3-0808 N:rthscst Utilitira Millstone Unit 3 Discrepancy Report COMMENTS ON SECOND RESPONSE:

We accept Ntts response.

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N2rthert Utilities ICAVP DR No. DR-MP3-0846 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Electrical Design Discrepancy Type: Calculation Om system / Process: N/A g

NRC significance level: NA Date faxed to NU: I Date Published: 1/10/98 Discrepancy: Documentation to verify " associated circuits" statement in FPER '

could not be located Descripuon:

l Section 6.3.1.3.1, Page 6-10 of the FPER states: l

" Associated circuits - The final concem raised by power cable  ;

faults relates to the potential for an electrical fault, which is not j properly cleared, to damage adjacent or nearby circuits which are required in the safe shutdown situation (common enclosure).

l As part of the Appendix R review the ICAVP review team attempted to verify this statement. The types of power circuits analyzed fall into the following categories:

1. 4 kV power circuits

2. 480V switchgear power circuits

3. 480V MCC power circuits 4,125V DC switchgear control circuits 5.120V AC control circuits (MCC control power transformer fed) 6.120V AC miscellaneous power / control circuits 7.125V DC miscellaneous power / control circuits in the review we determined:

1. 4 kV power cimuits have the necessary documentation to determine relay settings, but a potential question exits with respect to transleat temperature during fault conditions - See discrepancy DR-MP3-0787,

2. 480V switchgear power circuits have the necessary documentation to determine relay settings.

3. For power cable fed from MCCs, discrepancy M3-DR-00765 was issued because we could not locate documentation of the actual setting of the equipment and we could not confirm that the proper breakers and overloads settings were, in fact, installed.

4.125V DC switchgear control circuits are all fused at the switchgear. We could not identify a calculation which verified that the control circuit fuses would adequately protect the control circuit cable from damage.

5.120V AC control circuits (MCC control power transformer fed) are all fused and the control transformer sizes are small enough that cable damage is not a credible issue.

f Printed 5/12/98 4'26:07 PM Page 1 of 5

N:rthe:st Utilities ICAVP DR No. DR-MP3-0846 Millstone Unit 3 Discrepancy Report 6.120V AC miscellaneous power / control circuits fed from distribution panels may be fused or protected with circuit breakers. We could not identify a calculation which verified that the cable protected by the fuse / breaker was adequately protected.

7.125V DC miscellaneous power / control circuits fed from distribution panel's may be fused or protected with circuit breakers. We could not identify a calculation which verified that the cable protected by the fuse / breaker was adequately protected.

Conclusion:

We could not locate calculations or data required to verify the FPER statement.

Review Valid invalid Needed Date Ininator: Warner, l. O O O 12/18/97 VT Lead: Neri, Anthony A B O O 2/19/97 VT Mgr: schopfer, Don K G O O 12/23/97 IRC Chrnn: Singh, Anand K G O O 12/31/97 >

Date:

INVALID:

Date: 5/11/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that the issue reported Discrepancy Report, DR-MP3-0846, does not represent a discrepant condition.

Attachment 4.2 of Specification SP-M3-209 Rev.1 demonstrates adequate circuit breaker coordination for all circuits that share a common enclosure or power supply with Appendix R circuits (those circuits required to bring the plant to a cold or hot shutdown condition after a fire). Significance level criteria do not apply as this is not a discrepant condition.

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Conclusion:

NU has concluded that the issue reported in Discrepancy Report l DR-MP3-0846 does not represent a discrepant condition.

Attachment 4.2 of Specification SP-M3-269 Rev.1 demonstrates adequate circuit breaker coordination for all circuits that share a common enclosure or power supply with Appendix R circuits, and covers items 1-7 of the Discrepancy Report. ,

Significance level criteria do not apply as this is not a discrepant condition. 1 i

Printed 5/12/98 4:26:11 PM Page 2 of 5 I

N:rthert Utilitiea I AVP DR Ns. DR-MP3-0846 Millstone Unit 3 Discrepancy Report 1

SECOND RESPONSE:

Disposition:  !

Items # 1 & 2 of this DR have been responded to in DR-MP3-0787 & 0765. NU has concluded that the " Follow-Up" item # 3 to Discrepancy Report DR-MP3-0846 does not represent a discrepant condition.

Item #1 This issue has been addressed in DR-MP3-0787. As stated in DR-MP3-0787, Corrective Action Items associated with the closure of CR No's. M3-97-2358 and 3413 will verify that there are no associated circuit problems. The corrective actions will consist of a review of the following calculations and evaluations: Calc.178E, Rev.1; CCN No. 4 to Calc. NL-051, Rev. 3; Eng. Eval. No. M3-EV 970296; Eng. Eval. No. M3-EV-970295; DCR No. M3-97-095 and associated safety evaluation; EWR No. 97171; EWR No. M3-97172; and DCN No. DM3 1766-97 to Spec. SP-EE 269.

Item #2 This issue has been addressed in DR-MP3-0765, M3-IRF-02196, As a result, a duplication of the response will not be presented in this DR. Items 1 & 2 are Significant Level 4 issues which are addressed by DR-MP3-0787 & DR-MP3-0765.

Item #3 (Item # 6 of the DR) Curve 12 in SP-EE-269, Att.

4.2.1, p.12 of 18, documents the adequacy of electrical coordination of the Vital 120VAC system. The coordination curves for electrical components that are shown on curve 12 are:

the 480V MCC breaker (which feeds the regulating transformer),

the main 120V panel,150A fuse, and the largest panel feeder fuse of 60A (SP-EE-269, Att. 4.2.2, p. 3 of 5, Figure 3). It should be noted that the coordination curves are plotted on a 480V ,

basis, not a 120V basis, and this explains the area of confusion  ;

or basis of this question. The maximum fault level at the 120V level is approximately 4000A (Calc. No.177E,120V System Short Circuit Study). Therefore, it can be seen that proper coordination is achieved and this item does not represent a j discrepant condition. Cable protection against faults such as those that could occur from associated circuits is addressed in  !

Calculation 120E "AC Cable Size Verification for Vital Bus 1 Feeders".  !

l Significant Level criteria is not applicable to item # 3 since it j does not represent a discrepant condition.

Conclusion:

Items # 1 & 2 of this DR have been responded to in DR-MP3-0787 & 0765. NU has concluded that the two issues in " Follow-  ;

i Up" item # 3 to Discrepancy Report DR-MP3-0846 do not I represent discrepant conditions.The coordination curves plotted on Curve 12 of SP-EE-269 are plotted on a 480V basis, S&L presented their question using a 120V basis thus giving the apparence of a lack of coordination. Usina a 480V basis. it can i Printed 5/12/98 4:26:12 PM Page 3 of 5 4 I

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1 N:rthext Utilitiea ICAVP DR No. DR-MP3-0846 l

Millstone unit 3 Discrepancy Report be seen that proper coordination is achieved. Cable protection against faults such as those that could occur from associated circuits is addressed in Calculation 120E.

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

Prev 6ously identified by NU? O Yes (9) No Non Discrepant Condition?@) Yes O No Resolution Pending?O Yes @ No Resolution Unresolved?O Y.s @ No Review initiator: Warner, l.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Civnn: singh. Anand K Date: 5/11/98 sL Com nents: INITIAL COMMENTS:

We concur that SP-M3-EE-269 demonstrates coordination of the l 4kV power circuits - with respect to each other. The unresolved issue regarding the 4kV circuits is how NU addressed the issue of cable temperatures exceeding 250 deg. C in the event of a fault.

DR-MP3-0787 addresses this issue and NU's response to the DR was:

"NU has concluded that Discrepancy Report, DR-MP3-0787, has identified a condition previously discovered by NU which has been corrected. The issues identified in this Discrepancy Report i involving incorrect short circuit current values used in Calculation l 178E, "5KV & 8KV Power Cable Temperature Under Fault i Condition" with potential associated circuit problems will be addressed via corrective actions identified in existing CR No. M3-  !

j 97-2358 & M3-97-3413." l l

Because the CR does not identify how the issue will be addressed, we lack information to verify that there are no associated circuit problems.

We concur that SP-M3-EE-269 demonstrates coordination of the 480V power circuits, as long as the largest MCC feeder breaker is no larger than a 150A trip. The unresolved issue regarding the 480V circuits is how NU confirms breaker settings. DR-MP3-0765 addresses this issue and NU's response to the DR was:

" While verifying the breaker settings and TOL sizes is time consuming and tedious, the settings and sizes can be determined and field verified. The cumbersome process does not represent a discrepant condition."

Because the DR response does not provide any confirmation of breaker sizes we lack information to verify that there are no associated circuit problems.

Prtnted 5/12/98 4 26:14 PM Page 4 of 5 L________________________

N:rthe:st Utilitie3 ICAVP DR N3. DR-MP3-0846 Millstone unit 3 Discrepancy Report item #6 - 120V AC Vital Distribution Panets We questioned whether or not the cable associated with these  !

panels were properly protected. This question was not directly )

ansvered, but with the fault current identified as approximately 1100A, this does not appear to be a problem. Please note, that SP-M3-EE 269 Section 6E and Section 8 conclude that adequate breaker coordination is provided for these panels. Based on curve 12, for any fault between 600 sad 1100A, coordination does not exist.

General- One portion of this DR questioned whether or not cable was adequately protected against faults such that no associated circuit problems could possibly arise. Since NU's response did not address that question and since the items discussed above are still unanswered, this DR is still classified as a level 3 deviation.

COMMENTS ON NU'S SECOND RESPONE:

We accept NU's response.

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Printed 5/1256 4:26:15 PM Page 5 of 5 l

N rtheast Utilities ICAVP DR No. DR-MP3-0876 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation System / Process: HVX g

NRC Significance level: NA Date faxed to NU:

Date Published: 1/17/98 Discrepancy: Seismic reports are not available for ICAVP review for the following equipments.

Description:

(1) 3HVR*RE10A/B,19A/B: Seismic report # K-84-50/16435 does l not quahry the equipment mounting. l (2) 3HUR* MOD 140A/B. Report requested per RFl#756, item #3.

NU response in IRF#1175 provided qualification report number 730.1.140. This report does not address seismic qualification of this equipment.

(3) 3HVR*RlY10A/B,19A/B Seismic report #K-84-50/16435A Report requested per RFl#669, item #3 & RFl#814, item #1 Reports received per NU IRF#1098 and 1246 do not address the seismic qualification of these equipments.

Review Valid invalid Needed Date initiator: Patel, Ramesh @ [ [ 1/7/98 VT Lead: Neri. Anthony A g [ [ 1/7/98 VT Mgr: schopfer, Don K O O O is 2/98 IRC Chmn: singh, Anand K B D D il 3/98 Date:

INVALID:

Date: 5/11/98 RESOLUTION: FIRST RESPONSE FROM NU:

NU has concluded that the issue reported in Discrepancy Report DR-MP3-0876 does not represent a discrepant condition.

(1) 3HVR*RE10A/B,19A/B, are Wall Mounted Microprocessors.

Report No.16435-A, Revision 1, dated 10/09/81, " Qualification of Digital Radiation Monitoring Microcomputer System" states on page 1 in Section 1.2, " Objective" that this report presents the testing methods and technical justifications for the qualification of the KEM microcomputer. Section 7.1," Testing Mounting" on page 38 states that the test fixture will be mounted in a manner which simulates as closely as possible its service mounting.

(2) Qualification of 3HVR* MOD 140A/B:

ITT General Controls Engineering Report No. 730.1.140, Revision 1, dated 4/24/84 shows Mark Numbers 3HVR* MOD 140A/B in Section 2, pages 1 to 4. These component replacement schedules state the equipment type as an Electro-Hydraulic Actuator, Model NH-92.

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Nerthsast Utilitiss ICAVP DR No. DR-MP3-0876 Millstone Unit 3 Discrepancy Report ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89, on page 4 of 57, Table I shows NH90 Series Actuators with NH92 listed.

ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89 on page 36 of 57, Section 4.3

" Extension of qualification by Similarity" states in item 4.3.1.4, "Model NH92" that "The model NH92 actuator is identical to the Model NH94 tested . .".

ITT General Controls Engineering Report No. 730.1.140, Revision 5, dated 10/89, page 20 of 57, Section 3.2.10 states the seismic testing was performed in accordance with ITT General Controls Report 730.1.128, Revision 4.

Appendix A of ITT General Controls Engineering Report No.

730.1.140, Revision 5, dated 10/89 presents ITT General Control Report No. 730.1.128, Revision 4, dated 2-12-82 Test Plan for Requalification of ITT-GC NH-90 Series Hydramotor Actuators.

(3) Qualification of 3HVR*RlY10A/B,19A/B:

These devices are normal range vent microprocessors. Report No.16435-A, Revision 1, dated 10/09/81, " Qualification of Digital Radiation Monitoring Microcomputer Sptem" states on page 1 in Section 1.2, " Objective" that this report presents the testing methods and technicaljustifications of the KEM microcomputer.

Significance Level criteria do not apply here as Inis is no a discrepant condition.

SECOND RESPONSE FROM NU:

NU has concluded that the issues reported in Discrepancy Report DR MP3-0876 has identified a NON-DlSCREPANT condition.

ITEM 1: The mounting details for the isokinetic nozzle is qualified in the attached calculation 12179-NM(S)-767-CZC.

ITEM 2: Seismic Qualification of 3HVR* MOD 140A/B is included in McMahon Engineering Company Report ME-82-910/21 (attached).

ITEM 3: The qualification of the support for 3HVR*RlY10A/B is included in calculation 12179-SEO-BES2.1849. The qualification of 3HVR*RlY19A/B is included in calculations 12179-SEO-BE52.2107 and 12179-SEO-BE52.1297 (attached).

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

Previously identified by NU? O Yes r#') No Non Discrepant Condition?f*) Yes O No Resolution Pending?O ves @ No Resolution Unresolved?O yes @ No Review Printed 5/1296 4:26:45 PM Page 2 of 3

North:azt Utilitiso ICAVP DR No. DR-MP3-0876 Millstone Unit 3 Discrepancy Report initiator: Johnson, Jay VT Lead: Neri, Anthony A VT Mgt: schopfer, Don K IRC Chmn: Singh, Anand K l

Date: 5/11/98 l

SL Comments: S&L COMMENTS ON FIRST NU RESPONSE:

(1) HVR*RE10A/B,19A/B:

The mounting of the microprocessors has been addressed; however, the mounting of the radmonitoris not complete. The isokinetic nozzle associated with 3HVR*RE10A/B,19A/B is installed inside the duct as shown in Kaman Drawing No. 400325, Rev. E and Sketch No. B-313-5. No calculation has been provided for Details B and C on Sketch B-313-5 which show the details for mounting the isokinetic nozzle, or for Kaman Drawing No. 410808-TAB which shows the nozzle support socket. These items need to be addressed.

(2) 3HVR* MOD 140A/B:

ITT General Controls Engineering Report No. 730.1.140 adequately addresses the seismic qualification of the actuator.

However, it does not address the damper itself. Seismic qualification of the damper needs to be addressed.

(3) 3HVR*RlY10A/B,19A/B:

Seismic qualification of these microprocessors has been addressed; however, their mounting is not addressed.

3HVR*RlY10A/B is mounted on a steel support frame and 3HVR*RlY19A/B is mounted to a concrete wall or column.

Calculations addressing the steel support frame and attachment to the building structure are needed.

S&L COMMENTS ON SECOND NU RESPONSE:

Additional calculations and seismic reports provided with the second response from NU adequately address the seismic qualification of the subject equipment.

Printed 5/12/98 4:26:47 PM PaDe 3 of 3

ICAVP DR N3. DR-MP3-0901 N::rtheast Utilities Millstone Unit 3 Discrepancy Report 1 Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System installation p

Discipline: I & C Design Discrepancy Type: Installation implementation g systemfProcess: DGX NRC Significance level: 4 Date faxed to NU:

Date Published: 1/25/98 Discrepancy: Inadequate labeling of Instruments Descripuon:' Millstone Station Procedure OA-9 Revision 1 requires iabeling for all plant components. Contrary to this requirement, the following labeling discrepancies were discovered during system walkdowns:

1. The following instruments are not labeled in the field 3EGS*TS30 3EGS*TS30B 3EGS-TS28B 3EGS-TC31B 3EGD-TE22B1 3EGD-TE21B1 3EGD-TE22B2 3EGS PS27B1 3EGS-PS27B2 3EGD-TE26A1 3EGD-TE26B1 3EGD-TE2682 1

3CES-RK12-08

2. Drawings 12179-ESK-4J-5 Rev 11 and 12179-ESK-4J-6 Rev 15 show that the level indicators for the Emergency Generator Day Tank should have a scale of 0 - 550 gals. Level indicators 3EGF-L129A1,3EGF-Ll-29A2,3EGF-Ll29B1, and 3EGF-Ll29B2 do not meet this requirement. The scales presently installed on the referenced indicators show a range of 0 - 530 gals, they are hand written not machine printed, and have red printing on white scale plates, not the required black printing on white scales.

Review Valid invalid Needed Date j initiator: Sarver, T. L. O O O 1'13/S8 VT Lead: Neri, Anthony A B O O 1/14/98 VT Mgr: Schopfer, Don K O O O 5/18/S8 lRC Chmn: Singh, Anand K O O O 1/22/98 Date:

l INVALID:

1 Date: 5/8/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0901, has identified a condition not previously discovered by NU which Pnnted 5/12/98 4:27;12 PM Page 1 of 3

ICAVP DR No. DR-MP3-0901 N:rthert Utilities Millstone Unit 3 Discrepancy Report 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 M3-98-0650 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0901, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 an117010. 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 M3-98-0650 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

Disposition:

NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0901 does not represent a discrepant condition.

U3 Pl 20 section 1.3.2 e defines the type of labeling discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the type of labeling issues which will be completed prior to startup. The intent of attachment 11 is to 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 M3-98-0650 was closed to CR M3-98-0137. The corrective actions in CR M3-98-0137 will correct these issues post startup.

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

Conclusion:

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NU has concluded that the new issue reported in Discrepancy Report, DR-MP3-0901 does not represent a discrepant condition.

l NU has concluded that these labeling issues are deferrable based on section 1.3.2.e of U3 Pl 20. The corrective actions in CR M3-98-0137 will correct these issues post startup.

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

Pmted 5/12/98 427:15 PM Page 2 of 3

ICAVP DR ND. DR-MP3-0901 N:sthent Utilitie3 Millstone Unit 3 Discrepancy Report Previously identmed by NU7 O Yes (*) No Non Discrepent Condition?Q Yes (y) No Resolution Pending?O ve. @ No Re.oiution unr.soiv.d70 ve. @ No Review l Initiator: Warner, l.

VT Lead: Nert, Anthony A VT Mgr: schopfer, Don K l lRC Chnm: skgh, Anand K oste: 5/8/98 st Comments: INITIAL COMMENTS:

l Based on CR M3-98-0650 is is not apparent why the labeling changes can be deferred based on the deferral criteria.

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

l RESPONSE TO NU'S SECOND RESPONSE:

We accept NU's response.

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N:rthert Utilities ICAVP DR N3. DR-MP3-0904 Millstone Unit 3 Discrepancy Report Review Group: Conrguration DR RESOLUTION ACCEPTED Review Element: system Installation p

Discipline: I & C Desen Discrepancy Type: Installation implementation Om System / Process: N/A g

NRC significance level: 4 Date faxed to NU:

Date Published: 1/17/98 Discrepancy: Control Panel layout not in accordance with design drawings.

Descripuon: The following differences were observed during the review and walkdown of the Main Control Boards and other panels within the Control Room.

1. Main Control Board 8: Front view drawing 12179-EE-025S Revision 7 shows item 10 as tag number VM-BYS*PNL-3 while equipment lists drawing 12179-ESK-4J-2 Revision 12 indicates that item 10 is AM-BYS*PNL-3. Walkdown of the Main Control Board confirmed that installed is AM-BYS*PNL-3. A similar problem exists with item 132, the front view shows the tag number as VM-EGS*EG-A while the equipment list and the walkdown indicates that the tag number as AM-EGS*EG-A.

2. Main Control Board 1: Front view drawing 12179-EE-258 l Revision 8 shows that two switches item 275 (Tag number l SWP*MOV115A) and item 276 (Tag number SWP*MOV1558) have been removed from the vertical section of the main board.

Walkdown of the Main Control Board resulted in the discovery that the switches are stillinstalled. Review of the drawings and the associated change documents has led to the discovery of I DCN DM3-S-0794-94 which changed the configuration of Main Control Board 1. DCN DM3-S-0794-94 pages 124 and 125 show that removal of the switches in question, but this is not statused as incorporated into this affected document.

3. Main Control Board 1: Front view drawing 12179-EE-25B Revision 8 and Nameplate, Engraving and Arrangement drawing 12179-EE-25EA Revision 1 show a nameplate with the words

" SERVICE WATER" engraved on it. Walkdown of the Main Control Board confirmed that this nameplate is not installed.

4. Drawing 2424.300-246-104 Rev. O provides the nameplate engraving for control room control panel VP1. The following discrepancies were noted between this drawing and the panel layout: Nameplate no. 2, third line, HVR* TIC 45A should be removed as the instrument is no longer on the panel: Nameplate no. 202, third line, HVR* TIC 45B should be removed as the instrument is no longer on the panel; Nameplate nos. 81 and 237 should be removed as the air mixing dampers are no longer on the panel .

Review Valid invald Needed Date initiator: Sarver, T. L B O O 12/22/9' VT Lead: Neri, Anthony A G O O 12/23/97 VT Mgt: Schopfer, Don K 9 O O ii2/98 IRC Chmn: Singh, Anand K B O O $'13/S8 Printed 5/12/98 4:27:39 PM Page 1 of 3

ICAVP DR No. DR-MP3-0904 Northsast Utiliti:s Millstone Unit 3 Discrepancy Report Dete:

INVALID:

Date: 5/8/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0904, 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 M3-98-0511 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0904, has identified a condition not previously discovered by NU which requires ccrrection. 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 M3-98-0511 has been written to develop and track resolution of this item per RP-4.

SECOND RESPONSE:

Disposition:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0904 has identified a CONFIRMED SIGNIFICANT LEVEL 4 condition which requires correction.

This corrective action can be deferred to post startup per U3 Pl 20.

The switches for valves 3SWP*MOV115A and 3SWP*MOV115B are installed and correctly labeled per the existing plant design.

The switches were removed from drawing EE-25E (non operations critical) prior to the cancellation of the design modification that was to delete the valves, switches and associated items. The non operations critical drawing discrepancies identified in M3-DRT-00904 do not have a direct impact on plant configuration, operation or personnel safety.The corrective actions in Bin CR M3-98-0165 will respond to and address the issues of the DR post startup. The corrective actions will be to put the switches back on drawing EE-25E as necessary post startup.NU believes that the assignment of priority 4 is correct and in accordance with U3 Pt 20 section 1.3.2 e.These drawings are non OPS critical and do not meet the required for startup definition of attachment 11 of U3 PI 20.NU considers the overall classification of the DR to be significance level 4.

Printed 5/12/98 4:27:42 PM Page 2 of 3

1 ICAVP DR N2. DR-MP3-0904 N:rtheast Utilitir l

Millstone Unit 3 Discrepancy Report l l

l

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0904 have identified a CONFIRMED SIGNIFICANT LEVEL 4 condition which requires correction. The corrective actions in Bin CR M3-98-0165 will respond to the issues raised by the DR by revising the drawing as necessary post startup. NU considers the overall classification of the DR to be significance level 4.

Previously k!entified by NU? O Yes (9) No Non Discrepent Condition?U Yes (*) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Date Initiator: Warner,1.

O S8'88 VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K O O S11'S8 IRC Chmn: singh, Anand K Q O O 5'12/98 O O O Date: 5/8/98 st Comments: INITIAL COMMENTS:

Since control switches for valves 3SWP*MOV115A and 3SWP*MOV155B are still located on the control board but the design drawings indicate that the switches are no longer required, this issue does not appear to meet the deferral requirements of the labeling criteria:

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

RESPONSE TO NU'S SECOND RESPONSE:

We accept NU's response.

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Page 3 of 3 Printed 5/12/98 4:27:44 PM 1

______________a

ICAVP DR Ns. DR-MP3-0926 N:rthent Utilitie2 l

Millstone Unit 3 Discrepancy Report Review Group: Conrguraton DR RESOLUTION ACCEPTED f Review Element: system Installabon Discipline: Electrk:al Design Om l Discrepancy Type: Installation imp 6ementation g Systun/ Process: HVX NRC significance level: 4 Date faxed to NU:

Date Published: 1/18/98 D6screpancy: Electrical Installation not in accordance with Design Documents Descripuon: The following deviations from installation standards and design documents were observed during system walkdowns.

1. Electrical installation Specification E350 requires that ground conductors be routed along with flexible conduits when terminating to equipment and that raceways be bonded via a ground conductor. Furtherwhen terminated at equipment / instruments, there should be 3-inches of slack in the ground wire. Contrary to these requirements the following items were observed during system walkdowns: Flex conduits to 3HVR* MOD 49C1 and C2 do not have the required 3-inches of slack.,

2. Electrical Installation Specification E350, Rev. 9 section 3.1.3.9 limits the length of flexible conduit to equipment to 6 feet. Installed flexible conduit 9CC2070A3 was observe to be longer than six feet.

3. Electrical installation Specification E350 indicates that all i equipment should be grounded. Contrary to this requirement, j panel grounds were not observed for 125 Vdc distribution Panel  !

3BYS-PNL34F and 125 Vac distribution panel 3VBA*PNL-VB1. (

4. Drawing EE-11 A, Rev.13, shows a neutral bus within 125 Vac l distribution panel 3VBA*PNL-VB1. There is no neutral bus installed. ,

5. Drawing EE-9ES Rev.11 does not reflect actual field conditions. Cable from MCC181 Compartment 2C to Compartment 1D terminates at a Terminal strip in compartment 1D and then is extended to second ACB for pump 3EGF*P1D,

6. The actual installed fuses installed in 125 Vdc panel 3BYS*PNLDG2F can not be verified without removal. However, markings on the fuse holders / blocks 1 and 2 are not in i agreements with the ratings shown on drawing EE 10Q Rev. 6,

7. Contrary to the separation requirements of Specification E076 for safety and non-safety related wiring within panels of a minimum of 6 inches, non-safety cabling / wiring from 3HVR-i FE10 is within inches of safety related wiring inside Panel 3HVR*RlY10A

8. Specification E-076 provides separation requirements for safety and non-safety related cabling within panels. This specification does not permit the bundling together of safety kige1 ofY Printed 5/12/98 428:14 PM l

l

ICAVP DR No. DR-MP3-0926 N:rtherrt Utilities Millstone Unit 3 Discrepancy Report l 1

- safety related and non-safety related wiring within panel 3CES*lPNLCB1P is bundled (ty-wrapped) together.

9. In the area near support A336-016, one orange cable has been pulled beyond the confines of the tray 3TC1350 as it makes a slight tum to the south (E-W run).

10. Conduit 3CK1060H is wrapped with Sil-temp for approximately 8 feet of its run. The reason for this wrapping and the design document providing for such, could not be located.

Typically for separation purposes, the non-safety related cables l with in a foot would need to be wrapped not a conduit which, as such, already is provided with a barrier. (Reference location 51.3 - F.3; elevation 24'-6")

11. Penetration opening for cable tray 3TC163N is not sealed.

Seal appears to have degraded. (Reference loccion 51.3 - F.3 el. 34'-6")

12. Per drawing EE-34Y Rev. 9 and TSO2, tray 3TL2030 is a mark number (commodity type) DAK-01 Indicating that the tray is 30 inches wide. The installed tray was observed to be 24 inches -

wide. f

13. There are two tray section installed in the field which carry the same identification. These two risers are separated by a significant distance and require additional raceway to connect them to provide for routing of cables. The tray identity is 3TK2080. The first of the two trays is shown on drawing EE-34Z, Rev.11; the second is a riser located at the end of trays 3TK2040/3TC2060 Several rays and conduits of C and K services levels connect to these trays and it is not clear that service level separation is maintained as required by the Cable and Raceway Control Program manual on page 20. The Program manual also indicates that unique identification should be used for individual raceways.

14. Specification E-076 requires separation be maintained between safety and non-safety related raceways. For covered trays, this minimum spacing can be as little as an inch. Contrary to this requirement, the tray cover on tray 3TL102P was found to be in direct contact with tray 3TJ102N.

The following material conditions were noted during the system walkdowns. These are not configuration management issues.

1. The ground wire running with the flexible portion of conduit 3CL2040E1 is not connected at the connection to the rigid conduit.

2. Junction box 3HVR-TS109A appears to be missing a bolt and spacer plate.

3. The ground cable for the flexible conduit connection to 3HVR-TS109B is not connected.

Page 2 of 7 Printed S/12/98 4:28:17 PM l

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ICAVP DR N2. DR-MP3-0926 N:rtheart Utilitie3 Millstone unit 3 Discrepancy Report

4. Junction box 3FPW-JB07A was found in the field without a cover.

Review Valid invalid Needed Date initiator: sarver, T. L 8 0 0 /2/98 VT Lead: Nerl. Anthony A O O O 1/5'S8 VT Mgr: schopfer, Don K O O O i 2/98 IRC Chmn: singh. Anand K B D 0 15'S8 Date:

INVALID:

Dete: 5/11/98 RESOLUTION: INITIAL RESPONSE:

Disposition:

NU has concluded that items 3,5,9,12 and 13 and material condition items 1,3 & 4 in Discrepancy Report, DR-MP3-0926, have identified conditions not previously discovered by NU which require correction.

Item 3) A field walkdown reveals that panel 3BYS*PNL34F has no extemal ground connection, other than the rigid conduit connection. Therefore this is a discrepant condition. The FIN Team will generate AWOs for TR # 09M3132905 and will track work to completion.

A field walkdown reveals that panel 3VBA*PNL-VB1 has a ground connection from the station ground grid to the top of the cabinet. Therefore this is not a discrepant condition.

Item 5) A field walkdown reveals that in 3EGF*TRS1B, a compartment 2C, there is a terminal block not shown on the drawing EE-9ES. Therefore this item is discrepant, DCN DM3-00-0122-98 has been issued to show the as-built condition on Engineering drawings.

Item 9) A field walkdown reveals that there is a cable that extends above the side rails of tray sections 3TC1350. i Therefore this is a discrepant condition. Work has been l completed by AWO M3-98-02932. l 1

Item 12) Drawing EE-34Y and TSO2 indicates that tray 3TL2030 is a mark number DAK-01 indicating the tray is 30 inches wide. A field walkdown reveals that the installed tray is 24 inches wide.

Therefore this is a discrepant condition and a DCN DM3-00-0122- l 98 has been issued to correct the drawing and TSO2 error. I i

item 13) A field walkdown reveals Oat there are two trays with l the identification 3TK2080. Therefore this is a discrepant item, DCN DM3-00-0114-98 will be issued to verify / correct labelling of both trays.

Materialitem 1) A field walkdown reveals that the ground bond Printed 5/12/98 4:28:18 PM Page 3 of 7

N:rthea:t Utilitie3 ICAVP DR No. DR-MP3-0926 Millstone Unit 3 Discrepancy Report for flex conduit 3CL2040E1 was disconnected. Therefore this is a discrepant condition. Work has been completed by AWO M3-98-02932.

Material item 3) A field walkdown reveals that the ground cable for the flexible conduit connection to 3HVR-TS109B was not connected. Therefore this is a discrepant condition. Work has been completed by AWO M3-98-02932.

Material item 4) Junction Box 3FPW-JB07A, an empty spare junction box mounted on 3HVR*FLT-3A, is missing it's cover.

Therefore this is a discrepant condition. CR M3-98-0591 was written to resolve this issue. Condition Reports (CR) M3-98-0497 and M3-98-0591 were written to provide the necessary corrective actions to resolve these issues.

The Approved Corrective Action Plans for CR M3-98-0497 and M3-98-0591(attached) will issue DCNs/AWOs to correct these discrepancies. These corrections will be completed post startup.

NU believes that this DR is a Significance Level 4 discrepancy, since the discrepant conditions have no impact on the design and/or license basis for the unit.

NU has concluded that items 6,7,8,10, and 14 in Discrepancy Report, DR-MP3-0926 have identified conditiont previously discovered by NU which require correction.

Item 6) This item describes markings on the fuse blocks in 3BYS*PNLDG2F not being in agreement with Design Drawings.

ACR M3-97-0003, dated 1/2/97, noted that fuse stickers are not controlled or updated. AWOs M3-97-08854,08855,08856, 08857,08859,08860,08861,21946,21947,21948,21949, 21950 and 21951 removed labels that had been installed. A field walkdown reveals that there are no markings visible on fuse blocks 1 and 2 of 38YS*PNLDG2F.

Item 7) Within cabinets and panels, a minimum of six (6) inches is required between exposed contacts and terminals of Class 1E circuits or Class 1E and Non-Class 1E circuits and the minimum j separation between Class 1E wire bundles or Class 1E and Non- j Class iE wire bundles is one (1) inch. Therefore, one (1) inch j between Class 1E and Non-Class 1E wire bundles within i 3HVR*RlY10A is an acceptable configuration. Note: ACR No.  !

12850, dated 05/03/96, identified a discrepancy, in that, the l signal output from 3HVR FT/FE10 to 3HVR* ply 10A was not electrically isolated. DCR No. M3-97003 installed a qualified isolator to alleviate this problem.

Item 8) CR M3-97-2851, dated 08/29/97, identified safety to non-safety wiring separation issues in 3CES*1PNLCB1P that were corrected immediately upon discovery. A walkdown of the panel found it to be in order. This item was rediscovered by NU, and I repaired and is no longer discrepant. There is no further action required by Design Engineering.

Printed 5/12/98 4282o PM Page 4 of 7

ICAVP DR N3. DR-MP3-0926 N:rthert Utilities Millstone Unit 3 Discrepancy Report item 10) E&DCR N-EC-02083 identified and accepted this configuration. The electrical separation criteria for Class 1E to non-Class 1E circuits is to enclose either circuit in a qualified barrier (conduit, tray cover-vented or flat, or Sil-Temp protective wrap) and having one (1) inch between the barrier and the circuits not enclosed. A variation to this criteria is allowed for

• X", 'C', and *K" service circuits, in that, if both circuits are enclosed in a qualified barrier, the separation distance can be reduced to 1/8 inch between them.

Also, as part of the corrective action for ACR No. M3-96-1016, dated 10/23/96, and LER No.96-045, FSAR No. 97-MP3-461, SE S3-EV-97-0257, M3-EV-970136, and DM3-00-0992-97 were generated and these documents identified, analyzed and accepted these deviations to the electrical separation criteria. i These deviations will be listed in section 11.10 of SP-EE-076, l Rev 6. The " wrapped" conduit 3CK1060H was one of the l

acceptable deviations. l Item 14) CR M3-97-1634, dated 05/23/97, identified electrical separation violations between 3TL102P and 3TJ101N/3TJ102N.

DCN No.'s DM3-00-1440-97, DM3-01-1440-97 and AWO No. M3-97-18275 addressed and corrected the electrical separation violations associated with cable trays 3TL102P and 3TJ101N/3TJ102N.

NU has concluoed that items 1,2,4,11 and material condition item 2 issues reported in Discrepancy Report, DR-MP3-0926, do not represent discrepant conditions.

Item 1) This item discusses the Electrical Installation Spec E350 requirement to have 3* allowable movement in the ground bond for flex conduit. A walkdown of the conduits associated with 3HVR* MOD 49C1 & C2 reveals that the ground bond is securely fastened to the flex conduit with tie wraps. The conduit does have sufficient extra length to allow for 3" of movement, therefore, the ground bond is of sufficient length.

Item 2) A field walkdown reveals that the flex portion of conduit 9CC2070A3 is not longer than 6' as stated in the DR.ltem 4)

PNL 3VBA*PNL VB1 was verified as part of Self Assessment DE-3-96-008. The neutral bus was found to be in place and unused as per vendor drawing 2424.200-637-011. Therefore this is not a discrepant condition and this item considered closed, item 11) Afield walkdown by Civil / Mechanical design reveals that no degradation of the seal for tray 3TC200N/3TC163N.

Therefore this is not a discrepant condition and this is item is considered closed.

Material item 2) A field walkdown reveals that the junction box associated with 3HVR-TS109A is mounted securely to the wall with a spacer behind it.

Significance Level criteria do not apply to items 1. 2. 4.11 and Page 5of 7 Printed 5/12/96 (28:20 PM

ICAVP DR No. DR-MP3-0926 N:rthe:ct Utilitie3 Millstone Unit 3 Discrepancy Report material item 2 as there are not a discrepant conditions. I Conciusion:

NU has concluded that items 3,5,9,12 and 13 and material condition items 1,3 & 4 in Discrepancy Report, DR-MP3-0926, have identified conditions not previously discovered by NU which t

require correction.

Condition Reports (CR) M3-98-0497 and M3-98-0591were written to provide the necessary corrective actions to resolve these issues.The Approved Corrective Action Plans for CR M3-98-0497 and M3-98-0591(attached) will issue DCNs/AWOs to correct these discrepancies.These corrections will be completed post startup.

NU has concluded that this DR is a Significance Level 4 discrepancy, since the valid discrepant conditions have no impact on the design and/or license basis for the unit.NU has concluded that items 6,7,8,10, and 14 in Discrepancy Report, DR-MP3-0926 have identified conditions previously discovered by NU which requires correction. ACRs M3-97-0003,12850, CRs M3-97-1634 and M3-97-2851 have previously identified these ,

issues. 1 j

s NU has concluded that items 1,2,4,11 and material 2 issues reported in Discrepancy Report, DR-MP3-0926, do not represent j discrepant conditions. Design Engineering reviewed and verified the field condition and found no changes are required by these issues.

Significance Level criteria do not apply here as these are not discrepant conditions.

SECOND RESPONSE:

Disposition:

NU has concluded that item 8 of the DR should be classified as

" Invalid". The cables identified in the cited CR, M3-97-2851 of 8/29/97, had satisfied the separation criteria as evidenced by the satisfactory audit performed durin9 the CMP walkdown evolution's. These particular panels were walked down under AWO M3-97-035090n 3/11/97 and 3/19/97 respectively.

Subsequent to the walkdowns, PDCR M3-96-065 was implemented and these cables of CR M3-97-2851 were orientated to create a separation violation. The violation was corrected by the cited CR and by AWO M3-97-16015 on 8/30/97.

Conclusion:

Page 6 of 7 Printed S/12/98 4:28:21 PM

1 ICAVP DR No. DR-MP3-0926 N::rthert Utilities Millstone Unit 3 Discrepancy Report NU has concluded that Item 8 should be classified as " Invalid" within the ICAVP inspection process. The discrepant condition was created after the completion of CMP, was self-identified, and was immediately corrected. This discrepancy should be considered out of scope for the ICAVP process.

Prev 6ously identified by NU7 O Yes (#1 No Non Discrepant Condition?Q Yes (#) No Resolution Pending?O ve. @ No Re.oiution unre.oived70 ves @ No Review initiator: Warner, l.

VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/11/98 sL Comments: INITIAL COMMENTS:

l This DR remains at a level three because of item 8. Item 8 defined a separation violation that was addressed by CR M3 2851, dated 8/29/97. Although this discrepancy has been closed out it was not identified until after the ICAVP audit cutoff date.

COMMENTS ON NU'S SECOND RESPONSE:

l We accept NU's response on item 8 and agree that it is outside the scope of the ICAVP.

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l Page 7 of 7 Pnnted 5/12/96 4:28:23 PM

ICAVP DR N3. DR-MP3-0936 Nuthea:t Utilities Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Other Discrepancy Type: Corrective Action system / Process: DGX g

NRC Significance level: 4 Date faxed to NU:

Date Published: 1/18/98 Discrepancy: Insufficient Documentation to Verify Closure of UIR 639

Description:

Two areas have insufficient documentation in the UIR 639 Closure Package as follows:

1) The UIR 639 Discussion Details block, Item 2b states

" Verified that 3SCV*PNL90 & PNL50 are de-energized as a result of de-energized 3EJS*US-3A & 4A, but both MCC3A1 &

3A2 are fed from US-3A". The UIR 639 Discussion Details block also states that item 2b is a discrepancy.

The UIR Closure Package documentation does not address the above item 2b. It is indeterminate based on item 2b whether there is a discrepancy in the Appendix R Analysis Assumption requiring a corrective action or whether the Originator of the UIR incorrectly identified item 2b as an Unresolved item

2) The UIR 639 Discussion Details block, item 2c states

" Verified that 3SCV*PNL90 & PNL50 are de-energized as a result of de-energized 3EJS* MCC3A1 & 3A2 respectively.

Note: MCC3A1 & 3A2 were not ID'd on front and rear *.

The UIR Closure Package documentation does not include a

• Label Request Form (OA9 Attachment 2. Rev 1)" and a *Non-ACR Corrective Action Plan Assignment Form (NCU PI-20, Rev.1)" ; consequently, there is insufficient documentation that OPS received instructions to install labels for each of the 3EJS*

MCC3A1 & 3A2.

Note: A

• Label Request Form (OA9 Attachment 2, Rev 1)*

and a *Non- ACR Corrective Action Plan Assignment Form (NCU PI-20, Rev.1)* were generated, and included in the UIR Closure Package, for the purpose of adding labels to equipment 3VHR-FN18A & B listed under the UIR 639 Discussion Details block, item 3.

Review Valid invalid Needed Date initiator: Caruso, A. O O O 12/31/97 VT Lead: Ryan. Thomas J G O O 12/31/97 VT Mgr: schopfer, Don K O O O i 2/98 BRC Chmn: singh. Anand K B D D 1'15'S8 Date:

INVALID:

Date: 5/7/98 RESOLUTION Disposition:

Printed 5/12/98 4:28:46 PM Page 1 of 3

ICAVP DR No. DR-MP3-0936 Northeart Utilitiss Millstone Unit 3 Discrepancy Report NU has concluded that the issues reported in DR-MP3-0936 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 which has been corrected. The issues are addressed in Revision 1 to the closure request report for Tracking No. 96009830-04 which is now contained in the UIR 639 Closure Package. Item No.1 consists of an editorial correction to the BTP Appendix R Compliant Report. Item No. 2 verified, by a field walk-down on April 23,1998, that labels are installed on the front and back of MCC3A1 & 3A2 (Note: MCC3A1 & 3A2 is Stone & Webster nomenclature whereas MCC 32-1R & 32-[12]R is NU r70menclature. Typographical (1 in closure package should be a

2) error in Rev.1 of closure package}. CR M3-98-2210 has been written to track resolution of this item per RP4.)

Conclusion:

NU has concluded that the issues reported in DR-MP3-0936 has identified a CONFlRMED SIGNIFICANCE LEVEL 4 which has been corrected. The issues are addressed in Revision 1 to the closure request report for Tracking No. 96009830-04 which is now contained in the UlR 639 Closure Package. Item No.1 consists of an editorial correction to the BTP Appendix R Compliant Report. Item No. 2 verified, by a field walk-down on April 23,1998, that labels are installed on the front and back of MCC3A1 & 3A2. CR M3-98-2210 has been written to track resolution of this item per RP4.

Attachments:

Revision 1 to the closure request for Tracking No. 96009830-04.

Previously identified by NU? O Yes (#1 No Non Discrepant Condition?Q Yes (8) No Resolution Pending?O Yes @ No R..aution unre.av.d?O Y.. @ No Review inittstor: Caruso, A.

VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K '

LRC Chmn: Singh, Anand K Date: 5/7/98 SL comments: NU's response is acceptable.

Revision 1 of the Closure Package confirms that Panels 3EJS*3SCV*PNL90 & PNL50 are de-energized as a result of de-energized 3EJS*US-3A only, not 3EJS*US-3A & 3EJS*US-4A.

Revision 1 of the Closure Package also confirms that the Appendix R needs to be updated. The deletion of 3EJS*US-4A does not affect the design basis; hence, the revision to to the Appendix R is not a critical item and will be corrected by NU after startup. CR M3-98-2210 has been written to track resolution of this item per RP4. (Reference DR ltem # 1 above.)

A field walkdown on April 23,1998 verified that the labels are installed on the front and back of MCC 32-1R and MCC 32-2R as requested in the UIR 639. (Reference DR ltem # 2 above.)

Printed 5/12/98 4:28 40 PM Page 2 of 3

ICAVP DR No. DR-MP3-0936 N::rthea.t Utilities Millstone Unit 3 Discrepancy Report Note: MCC3A1 & 3A2 is Stone & Webster nomenclature whereas MCC 32-1R & 32-2R is NU nomenclature.

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I l N:rthert Utilitie3 ICAVP DR N2. DR-MP3-0966 l Millstone Unit 3 Discrepancy Report Review Group: Operatens & Maintenance and Testing DR RESOLUTION ACCEPTED l I Review Element. Maintenance Procedure Discipline: hm Potentia bility issue l Discrepancy Type: Test implementeen System / Process: DGX g j NRC significance level: NA Date faxed to NU:

Date Published: 1/25/98 Discrepancy: No program has been established to measure DG cylinder firing l

pressures and evaluate results

Description:

The letter from Northeast ()tilities to the NRC dated June 14, 1995 (B15245) states that " ..we have decided to implement a l

supplemental inspection in order to better evaluate engine performance. Currently only rack settings and temperatures are monitored during diesel surveillance runs. Maintenance on a six-month basis will measure cylinder firing pressure and evaluate the results. This will allow an evaluation of the engine timing (retard or advance) and fuel mixture (too rich or too lean)."

RFI 0824 was submitted to obtain the procedure and data sheet that is used to perform the task as described in letter B15245.

The RFl provided a copy of Maint. Form 3720CD-1, Rev 3 and i

referred the reviewer to MP 3720CD, Rev 4 even though j OSCAR identifies a Rev 6. The RFl also requested copies of the l

' three most recent uses of Maint. Form 3720CD-1 which had I 4

l been provided earlier in response to RFI 0715.

Contrary to the above commitment, the reviewer was not able to confirm the following:

1. A program has been established to perform a twice year 1y evaluation of the diesel cylinder firing pressures.

2. That when data is collected on Maint. Form 3720CD-1 that there is a documented process to calculate the high/ low differential exhaust temperature and firing pressure.

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3. That any documented evaluation is performed to determine proper engine timing or fuel mixture.

l 4. A process that describes follow-up actions that the evaluation might require.

The work orders associated with " copies of the three most recent l uses of Maint. Form 3720CD-1" provided were dated 9/8/93, 1

2/1/94 and 5/16/95. It therefore appears that this surveillance has not been performed since 5/16/95 which includes all of 1996 and 1997.

l The RFI also requested copies of evaluations performed as a result of the testing program. The site responded that "there have been no evaluations performed because cylinder pressures have not exceeded the limits and rework was not performed."

The subject letter appears to commit the station to a twice yearly cylinder firing pressure surveillance test of the diesel which includes a subsequent evaluation for engine timing and fuel mixture. It cannot be determined that this program is in place and therefore this is a discrepancy.

Review Pnnted 5/12/96 4:29:14 PM Page 1 of 2

l N:rthenct Utilities ICAVP DR No. DR-MP3-0966 Millstone Unit 3 Discrepancy Report Valid invalid Needed Date initiator: Tamtyn, Tom O O O 1'13/98 VT Lead: Bass, Ken B 0 0 1'14/98 VT Mgr: schopfer, Don K B O O '1S/98 IRC Chrnn: singh, Anand K B O O tr22/98 {

Date:

INVAllD:

Date: 5/11/98 RESOLUTKW: Disposition:

NU has concluded that this issue reported in DR-MP3-00966 has  !

identified a NON-DISCREPANT condition. Contrary to that )

reported in RFI 0824, the attached Diesel Technical Reports i provide the documentation required to verify adherence to the cornmitment to implement a supplemental inspection in order to better evaluate engine performance and measure cylinder firing pressure and evaluate the results.

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

Conclusion:

NU has concluded that this issue reported in DR-MP3-00966 has identified a NON-DISCREPANT condition. . Contrary to that reported in RFI 0824, the attached Diesel Technical Reports provide the required documentation to verify adherence to the commitment delineated in the Northeast Utilities to the NRC letter (B15245) dated June 14,1995, to measure cylinder firing pressure.

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

Previously identified by NU? O Yes (e) No Non Discrepent ConditionKS) Yes O No Resolution Pending?O Ye. @ No Re.aiution unresolvedtO Yes @ No Review initiator: spear, R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K BRC Chmn: Singh, Anand K Date:

SL Comments:

l l

Pnnted 5/12/98 4:29:17 PM Page 2 of 2

Northscst Utilities ICAVP DR No. DR-MP3-0968 Millstone Unit 3 Discrepancy Report Review Group: Conrguraton DR RESOLUTION ACCEPTED Discipline: I 8 C Design Potential Operability issue Discrepancy Type: Drawing Ow SysterrvProcess: DGX g

NRC significance level: 4 Date faxed to NU:

Date Published: 1/2558 Discrepancy: Incorrect location of indicators shown on P&lD

Description:

In the course of drawing reviews the following error in the location of the deisel fuel oil storage tanks level indication was noted. P&lD EM-117A Rev.10 (boundary document issue) indicates that 3EDG-Ll25A and Ll29A2 are located at panel EGPA and that 3EDG-Ll25B and Ll2982 are located at panel EGPB. The correct location for these instruments are wall mounted local panels 3EDG-PNLLI-A and 3EDG-PNLLI-B, respectively, located within the EDG building rooms. Other drawings and the installed configuration reflects the correct locations.

Review Valid invalid Needed Date initiator: Sarver, T. L.

O O O il SS8 VT Lead: Neft. Anthony A B O O /14'S8 VT Mgr: schopfer, Don K O O O 1/2 ass IRC Chrnn: Singh, Anand K 8 0 0 1i22/98 Date:

INVALID:

Date: 5/8/98 REsOLUTK)N: INITIAL RESPONSE:

Disposition:

NU has concluded that Discrepancy Report DR-MP3-0968, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 Pl.

20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0971 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0968, 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 M3-98-0971 has been written to develop and track resolution of this item per RP-4.

Printed 5/12/98 4:29'43 PM Page 1 of 2

l l l I l

l N::sthe=t Utilities ICAVP DR No. DR-MP3-0968 l Millstone Unit 3 Discrepancy Report i

SECOND RESPONSE:

{

l Disposition: l NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0968 has identified a CONFIRMED SIGNIFICANT LEVEL 4 condition which has been corrected. P l

& ID EM-117A, Rev.17 has been changed to show the correct  !

local panel ID's for the instrument location discrepancies identified in this DR. Levelinstruments 3-EGF-L125A and 3-EGF-L129A2 are shown at location at 3-EGF-PNLLI-A. Level instruments 3-EGF-Ll258 and 3-EGF-Ll29B2 are shown at location 3-EGF-PNLLl-B. DCN DM3-00-0375-98 corrected the P&lD. It should be noted that the instrument prefix for these instruments is "EGF", not "EDG" as originally indicated.

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0968 has identified a CONFIRMED 1 SIGNIFICANT LEVEL 4 condition which has been corrected. P I

& ID EM-117A, Rev.17 has been changed to show the correct local panel ID's for the instrument discrepancies identified in this DR.

Previously identihed by NU? O yes @ No Non Discrepant Condition?O yes @ No l

Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review initiator: Wamer, I.

VT Lead: Neri, Althony A VT Mgr: schopfer Don K IRC Chmn: singh, Anand K Date: 5/8/98 SL Comments: INITIAL COMMENTS:

Based on CR M3-98-0968 it is not apparent why the labeling changes can be deferred based on the deferral criteria.

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

COMMENTS ON NU'S SECOND RESPONSE:

We accept NU's response.

] Printed 5/12/96 4:29.46 PM Page 2 of 2 1

[. .__ - - - _ . _ _ . - _ _ . _ _ . _ _ _ - - - _ _ _ . _ _

r N:rthent Utilities ICAVP DR Ns. DR-MP31006 l Millstone Unit 3 Discrepancy Report Review Group: Operabons & Maintenance and Testing DR RESOLUTION ACCEPTED I

i Discipline: Maintenance Potential Operability issue Discrepancy Type: Design Control Procedure Om i System / Process: sWP g

NRC significance level: NA Date faxed to NU:

Date Published: 2/5/98 1

Discrepancy: Adequate information was not provided to verify documents were updated to reflect support changes l

Description:

Adequate documentation was not provided to verify that the appropriate snubber listing and spring can hanger set point documents were updated to reflect the larger snubbers and l adjustments to the spring can hangers. We could not verify that l the correct size snubber would be inspected or replaced or the l

proper spring can setting would be maintained during subsequent maintenance or inspection activities.

The supports that were impacted by the PDCR is:

3-SWP-4-PSSH131 3-SWP-4-PSSP423 3-SWP-4-PSSP427 Review Valid invalid Needed Date initiator: spear, R.

B 0 0 1/27/98 l VT Lead: Bass, Ken B O O 1/28/98 VT Mgr: schopfer, Den K Q Q Q 1/29/98 1RC Chmn: singh, Anand K B O O 2/2/98 Date:

INVALID:

Date: 5/11/98 RESOLUTION: Disposition:

NU has concluded that this issue reported in DR-MP3-1006 has identified a NON-DISCREPANT condition. The three supports l noted by Sargent & Lundy were installed per the DCN and DCR l processes as defined in the Design Control Manual using DCR M3-96056. DCR M3-96056 references Specification SP ME-570 for the installation and inspection of pipe supports. The DCN requires specification SP-ME-570 Appendix R (Spring Cans for which Hot Set Verification is Required) to be updated for the new spring can settings. The in-Service-Inspection Program refers to specification SP-ME 570, Appendix R for tne latest spring settings and Appendix U for the latest snubber list. Also, GRITS is reviewed to identify all outstanding change documents (e.g.

DCN's DM3-S-0817 96 and DM3-S-0720-96) against this specification for both springs and snubbers which have not yet been incorporated. Therefore, within the issued documents for modification of the three SWP pipe supports (3-SWP PSSP423,3-SWP-4-PSSP427, and 3-SWP-4-PSSH131), there is adequate documentation to assure these supports were installed properly, have the proper settings on the spring cans, and can be inspected in the future to the latest information.

Printed 5/12/98 4:30:14 PM Page 1 or 2 L------------------_------------

N:rtheast Utilities ICAVP DR No. DR-MP3-1006 Millstone Unit 3 Discrepancy Report

Conclusion:

l NU has concluded that this issue reported in DR-MP3-1006 has

! identified a NON-DISCREPANT condition. Specification SP-ME-570 for the installation and inspection of pipe supports has been revised per DCR M3-96056 to incorporate the modification of the 3 SWP pipe supports. The ISI Program refers to this specification for the latest data on spring can settings and I snubber listing. Therefore, adequate design documentation I exists to ensure these supports have the proper spring can settings and can be readily inspected in the future.

Previously identified by NU? O Yes (0) No Non Discrepent Condition?(9) Yes Q No l Resolution Pending?O ve. @ No Re oiution unre.oiv.d?O Ye. @ No Review initiator: spear, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date:

sL Comments:

l Printed 5/12S8 4:30:18 PM Page 2 of 2

N:rtheist Utiliti:s ICAVP DR No. DR-MP3-1028 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation O Yes

(']

e No System / Process: NEW NRC Significance level: 4 Date faxed to NU:

Date Published: 2/12/98 Discrepancy: Revision to Calculation US(B)-362 for DCR M3-97045

Description:

The purpose of Calculation US(B)-362 is to determine if the RSS pumps have an adequate water supply and adequate NPSH, including the effects of insulation debris and vortexing.

Seven discrepancies were identified in Calculation US(B)-362:

1. Section 7.2, pp.19-21, explains how the LOCTIC model for the mass of water reaching the containment floor is altered to l account for holdup and holdup time delays. However, the l

LOCTIC model for computing the temperature of water on the l containment floor is not altered to account for holdup and holdup I time delays. This creates a discrepancy in the worst-case sump 1 conditions for RSS operation. The limiting event for RSS pump l water supply and NPSH is the 4-inch LOCA in Cubicle D with failure of one QSS pump. In this scenario a large fraction of the .

mass of hot water released from the break makes its way into  !

the instrument tunnel. The effect of the holdup of this LOCA j spillage would be to decrease the sump water temperature to j less than the value computed in LOCTIC. This has a non-conservative effect. The head loss through debris on the fine mesh screens with the unmodified LOCTIC temperature is too low (due to the use of a temperature which is too high in equation (27), Section 7.7, p.27. This discrepancy may not j significantly change 'he computed NPSH margins, but the issue should have been identified in the assumptions and methodology {

section of the calculation.

2. A 4" break size is selected as the small break LOCA which t produces the worst-case RSS water supply based on preliminary analysis (p.16). However, no documentation is included, or referenced, to support the small break size selected.

3. The values for MIT in Table 4d, page 38, are less than the )'

l values calculated when using equation (2b) on page 20. The i smaller values for MIT used in the analysis are not conservative since they result in more water on the containment floor than actual.

4. The calculation states that the required NPSH at the I centerline of the 1 st stage impeller of the RSS pump, (including {

can loss) at 3000 gpm is 4.0 feet (page 28, 30) based on  !'

Attachment 3 of Ref.15 (US(B)-253, Rev. 5) . However, per Attachment 3 of US(B)-253 (upper curve) the required NPSH at 3000 gpm is 11 feet. The available NPSH is still in excess of 11 feet (Table 13, p.72).

E Th a s ,ala .nc fne IrnAnf e niti da n\ In Takin itA /n EC E7\(neihn J ,,

Printed 5/12/96 4:30:41 PM

' ""'" "" W " " " " I '"pg"t og 4 i _

N:rthert Utilitie3 ICAVP DR Ns. DR-MP3-1028 Millstone Unit 3 Discrepancy Report LOCA in cubicle D were not properly transposed from Table 5e (p. 45). The values in Table 6d for(mdotspill-30) appear to be the larger values from Table Se for the term (Break Spillage Rate). As a result, the region (Inflows) should be smaller in Table 6d than the values listed in Table 6d. This effects the region velocities calculated in Table 9d (p.64) and the transport distances and times calculated in Table 10d (p.68). The smaller j velocities would reduce the debris transport distance for a given '

time period and therefore reduce the quantity of debris on the l fine screens at a given time. Therefore, this discrepancy does not appear to have an adverse affect on the calculated results.

6. Appendix C determines the head loss across the coarso and fine mesh screens (no debris) in order to show that the head loss is negligible (assumption 19, p.13). The calculation for Reynolds Number in Table C-2 (p. C-3) is incorrect. The Reynolds number in Table C-2 is based on the wire diameter (0.092" for the coarse screens and 0.032" for the fine screens). The Reynolds number should be based on the hydraulic diameter. The resulting higher Reynolds numbers should not adversely impact the expected head loss across the coarse and fine mesh screens.

! 7. The values for u1 (velocity at screens) in Table C-2 do not agree with the values in Tables 8a,8b, Sc and 8e or the values

in Tables 11a,11c and 11d. The values in Table C-2 are higher l than actual and therefore conservative since they result in higher than expected head loss.

Calculation US(B)-362 should be evaluated for the impact of the l above discrepancies.

l Review Valid invalid Needed Date initiator: Wakeland, J. F. O O O 2/2/98 VT Lead: Nerl. Anthony A O O O 2ra/98 VT Mgt: schopfer, Don K B O O 2/e/98 l

1RC Chmn: singh, Anand K B O O 2<7/98 Date:

INVALID:

l Date: 5/11/98 RESOLUTION: DISPOSITION:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1028, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan forCR M3-98-0821 (attached) will correct Calculation US(B)-362 with respect to each of the seven discrepancies identified.. The revised results will then be carried forward into the calculations and documents which use results from US(B)-362 as an input.

CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action will be Printed 5/12/98 4:30:45 PM Page 2 of 4

N::rthert Utilitie3 ICAVP DR N2. DR-MP3-1028 Millstone Unit 3 Discrepancy Report completed by May 31,1998, and will ensure that the errors in US(B)-362 are clearly identified and addressed. The corrective action plan for CR M3-98-0821 is tied to CR M3-98-0619 by AR 98002805.

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

This assessment is scheduled to be completed prior to Startup.

Each of the discrepancies in DR-MP3-1018 has been reviewed j by the vendor (the Unit 3 architect engineer), who has  !

determined that none of the discrepancies enumerated in DR I MP3-98-1028 significantly affect the results of the RSS related calculations, and do not affect the conclusion that the RSS ,

system maets its design basis. In addition, each of these discrepancies has been reviewed by NU design engineers, who

)

have further determined that none of the discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

CONCLUSIONS:

NU has concluded that the issue reported in Discrepancy Report, DR-MP31028, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0821 (attached) will correct Calculation US(B)-362 with respect to each of the seven discrepancies identified. In addition, an assessment will be performed prior to Startup of the issues ralated to calculational riiscrepancies. This will ensure that these issues are clearly identified and addressed. Each of the discrepancies identified in DR MP3-98-1028 has been reviewM by the vendor ana by NU, and none of them affect the conclusion that the RSS system meets its design basis. As such there is no effect on the ;icense or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by NU? O Yes T No Non Discrepent Condition?O Yes (9) No Resolution Pending?O Yes @ No Re.oiutioa unre.olved?O Ye. @ No Review inXiator: Wakeland, J. F.

G O O S1'/S8 VT Lead: Neri, Anthony A gg g VT Mgr: schopler, Don K O O si2/98 iPC Chmn: singh, Anand K O O O Date: 5/11/98 sL Comments: Sargent & Lundy concurs that DR-MP3-1028, issues #4 and #6 are not discrepant conditions.

I Sargent & Lundy also concurs that the c9rrective action plan of CR M3-9S-0821 (AR 98002805-03) will address discrepant issues

1. 1-3,5 and 7 of DR-MP3-1028.

Printed 912/96 4:30.47 PM Page 3 of 4

Northert Utilitie3 ICAVP DR N2. DR-MP3-1028 l Millstone Unit 3 Discrepancy Report Sargent & Lundy concludes that the severity level of DR-MP3-1028 should bo changed to Level 4 for the following reasons:

l Item 1: Calculated sump water temperature is too great because it calculated on the basis of all of the mass release entering the sump when in fact a large fraction of it is held-up in the instrument tunnel for a postulated 4-inch SB LOCA in Cubicle D.

Correction of this error leads to a small reduction in the calculated '

i margin in the RSS pump NPSHa. This non-conservative error, l however, does not apply to the limiting scenario for RSS pump NPSHa, a posulated 4-inch SB LOCA in the reactor cavity. For this limiting scenario none of the mass released from the break reaches the sump, so the margin in RSS pump NPSHa is significantly less than it is for the 4-inch break in Cubicle D.

l Therefore the error does not place the RSS system outside its design basis and does not reduce the margin in the minimum RSS pump NPSH.

Item 2: Sensitivity runs of the containment sump model are not part of the documentation of US(B)-362, however they indicate that the worst case scenario is a postulated 4-inch SB LOCA in the reactor cavity. This error is a documentation isste which does not affect any conclusions of the calculation.

Item 3: The error is a typographical error in the equation, not a transposition error, The correct value for the mass of water in the instrument tunnel was carried forward and used to develop the calculation's conclusions. Thus, the calculation conclusions are not affected by the error.

item 5: This error is conservative. its correction will increase the calculated design margin in RSS pump NPSHa for a postulated 4-inch SB LOCA in Cubicle D.

Item 7: This error is conservative. its correction will increase the calculated design margin in RSS pump NPSHa for several of the posulated design basis scenarios.

Pnnted 5/12/96 4:30 48 PM Page 4 of 4

l ICAVP DR N . DR-MP3-1032 N:rthenct Utilitie3 Millstone Unit 3 Discrepancy Report Review Group: syvem DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: Mechanical Design Discrepancy Type: Installation implementation g j system / Process: NEW NRC significance level: NA Date faxed to NU:

l Date Published: 2/12/98 Discrepancy: DCR M3-97042 does not provide for adding new vendor  ;

drawings & manual into Millstone documentation. l

Description:

Modification DCR M3-97042 installs new test lines for the l containment recirculation spray pumps 3RSS*P1C and )

3RSS*P1D. The new test lines contain new manual valves, l 3RSS*V895 and 3RSS*V897. The modification also installs clamp-on ultrasonic flow instrumentation, made by Controlotron, l to measure flow during inservice testing of all four containment recirculation spray pumps.

DCNs DM3-00-813-97 and DM3-00-614-97 identify and ,

reference Controlotron drawing 990TNDM-78. However, no  !

documentation shows that this drawing is being added to the Millstone Unit 3 drawing system.

No documentation is identified that adds the Controlotron vendor manual for the new flow instrumentation to the Millstone Unit 3 vendor manual system. j DCNs DM3-00-813-97 and DM3-00-614-97 identify Westinghouse drawing 8374D02 for the new manual valves (

3RSS*V895 and 3RSS*V897. However, no documentation is identified that adds this drawing to the Millstone Unit 3 drawing system.

Review l Valid invalid Needed Date initiator: Feingold. D. J. O O O 2/3/98 VT Lead: Neri, Anthony A B D O 2r3/98 VT Mgr: schopfer, Don K G O O 2/st98 1RC Chmn: singh. Anand K O O O 2/7/98 Date:

INVALID:

l l

l Date: 5/11/98 RESOLUTION: - Northeast Utilities' First Response -

1 1

Disposition:

1 NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1032, does not represent a discrepant condition.

Design Change Request (DCR) M3-97042 is an ongoing design change. Attachment 1 of form 3-2B,

• Design Change Administrative Checklist",in the Design Change Manual (DCM) requires that all vendor manuals and drawings needed with the addition of components to a system be added to the vendor PMed 5/12/98 4:31:20 PM Page 1 of 4

N:rthea t Utilities ICAVP DR No. DR-MP31032 Millstone Unit 3 Discrepancy Report manual system and/or the drawing system prior to closure of the DCR.

All field modifications for DCR M3-97042 have been made.

DCR M3-97042 is scheduled for administrative closure within 90 days. 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-MP3-1032, does not represent a discrepant condition.

Design Change Request (DCR) M3-97042 is an ongoing design change. Attachment 1 of form 3-28," Design Change Administrative Checklist", in the Design Change Manual (DCM) requires that all vendor manuals and drawings needed with the addition of components to a system be added to the vendor manual system and/or the drawing system prior to closure of the DCR.

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

- Northeast Utilities' Second Response -

I Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1032, does not represent a discrepant condition. The subject DCR and vendor drawings were identified in Discrepancy Report, DR-MP3-1046 and responded to in M3-lRF-01903 and the follow-up response, M3-lRF-02187. These vendor valve drawings have not been incorporated into NDS because the Design Control requires that ve.Tdor drawings to be incorporated into NDS after the modification has been implemented.

Specifically, section 4.5 of the Design Control Manual (DCM) requires Form 3-21, Engineering Release Transmittal, be issued to document the Engineering release for the design change to Operations for system operation. Upon issuing Form 3-21, section 4.5.10 of the DCM requires an AITTS commitment to the Design Engineer or Design Engineering Department be initiated to close-out the DCR within 90 days from tumover to Operations. During Design Change Close-out (Section 5.2 Note re-emphasizes the 90 day close-out time requirement.), changes are made to plant design cata bases (DCM section 5.1.7). In addition DCM section 5.1.10 requires all other administrative items specified as being a requirement for design change close-out are completed. Thus , the DCN's incorporating vendcr drawings into GRITS and changes to vendor specifications are non-technical and must be completed (DCN block 22 signed) within the 90 days. Upon completion of the DCN's, section IV of DCM Form 3-28. Supportina Desian Chanae Packsae Details.

PrWed s/12/96 4:31:23 PM Page 2 of 4

ICAVP DR Nr. DR-MP3-1032 N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report can be signed which indicates close-out of the DCR package and ready for the package to be transmitted to NDS. Once block 21 l

sign off is complete, the DCN is an as-built controlled document l which can be referenced as a design document. Issuance of the vendor drawings as stand alone documents is processed according to the significance of the drawing in the DCR. In the case of the vendor valve drawings for the RSS modifications, it is planned to issue them within the 90 day close-out window from project tum over. The DCM close-out process for DCR M3-97042 is ongoing and will be completed within the required 90 days.

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-MP3-1032, does not represent a discrepant condition. Close-out of DCR M3-97042 is ongoing in accordance with the requirements of the DCM. Vendor drawings and vendor specifications will be incorporated into NDS during the 90 day close-out period as permitted by the DCM Significance Level criteria do not apply here as this is not a discrepant condition.

Previously identified by NU7 O Yes (#) No Non Discrepent condition?(#') Yes O No Resolution Pending?O ves @ No Re.oiution unre.oived70 ve. @ No Review initiator: Feingo6d. D. J.

VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chrnn: singn, Anand K oste: 5/11/98 sL comments: - Sargent & Lundy's Comments on Northeast Utilities' First Response -

Design Control Manual Revision 5, page 22 of Chapter 3, states,

" Design change close-out shall be completed within 90 days of final Engineering Release for Operation". Page 6 of Chapter i states that this close-out includes procedures, lists, and databases.

DCM Form 3-28,Section IV, is the Design Change Close Out.

Item IV.4 is tumover of any required Vendor Manual changes or additions. Northeast Utilities response is with respect to vendor manuals is acceptable, assuming item IV.4 is included in the items stated for close-out within 90 days after final Engineering Release for Operation.

No items can be identified in Section IV of DCM Form 3-2B, or any other part of the Design Control Manual, that apply to update of vendor drawings. According to NU, vendor drawings are updated in the same manner as design drawings. Therefore, Page 3 of 4 Pnnted 5/12/96 4 31:24 PM 1

I

ICAVP DR No. DR-MP3-1032 N::rthea:t Utiliti:o l Millstone Unit 3 Discrepancy Report l Sargent and Lundy considers the Design Control Manual to require inclusion of identified vendor drawing additions and revisions in modification DCNs prior to issue for implementation.

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

Northeast Utilities'second response to DR-MP3-1046 via M3-IRF-02187 provided the following document previously identified as missing:

. ... Westinghouse drawing 8374D02 providing the vendor drawing for valves 3RSS*V895,897.

No DCN was provided to incorporate this drawing as a control document.

In Northeast Utilitics' follow-up to their second response to DR-MP3-1046 they provided the following with respect to Westinghouse drawing 8374D02:

"The drawing copy received was not of sufficient quality to be incorporated into GRITS. A better quality drawing which can be f incorporated into GRITS has been requested from Westinghouse. Once the new drawing has been received, a DCN to DCR M3-97042 will be issued within 90 dayr of tumover to Operations to formally incorporate the drawing into GRITS."

Sargent & Lundy considers this appropriate, ginven the condition of the original drawing . Therefore, no discrepant issue is identified with respect to drawing 8374D02.

l l

l l

l Printed 5/12/96 4:31:26 PM Page 4 of 4

ICAVP DR No. DR-MP3-1037 N rthrast Utilitiss Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p g Discipline: Mechanical Design Om Discrepancy Type: Calculation gg System / Process: NEW NRc Significance level: 4 Date faxed to NU:

Date PubHshed: 2/12/98 Discrepancy: Hydraulic Analysis US(B)-361

Description:

Calculation US(B)-361 [Rev. 0] is the hydraulic analysis for the ECCS Systems Spray and Cold Leg injection Modes. It was produced due to Modification DCR 97045 which reduced the RSS System flow to address several design issues.

A. This calculation supplements Calculation US(B)-245 [Rev.

0; CCN 1 & 2] which is the original hydraulic analysis for the RSS and the SlH Systems. According to the Revision Record

[Page 4] of US(B)-361, Calculation US(B)-245 is not superseded since input data and the LHSl Function (RHS System) analysis is still valid. Calculation US(B)-361 provides the analysis for functions: a) HHSI (SlH/CHS) from the RWST; b) LHSI (RHS) from the RWST; c) HHSI from the Sump and d) RSS Spray

[Pages 5-6]. The analyses were completely re-performed except for the LHS! Function [Page 6].

The following items were duplicated in Calculation US(B)-361 from Calculation US(B)-245, Rev. 0; CCNs 1,2 & 3:

1. Piping and fitting input data for all of the ECCS Functions (Tables 8 through 13)

2. Assumptions

3. References

4. Calculation for the resistance coefficients for all fittings and in-line components The information contained exclusively in Calculation US(B)-245:

1. Attachment 8 (Energy Difference Calculation for LOCTIC input)

2. The model development for the LHSI Function Calculation US(B)-359 supersedes CCN 3 of Calculation US(B)-

245, Rev. O. CCN 3 included RSS degraded pump performance curves and deleted the RSS System and ECCS Cold Leg injection Analysis (Section 5).

Calculation US(B)-245 is a valid analysis for the ECCS Functions. This includes all modes, including RSS System Cold Leg injection. Calculation US(B)-245 needs to be revised to delete Sections 2,4 and 5 since these ECCS Functions were reanalyzed in Calculation US(B)-361.

B. Figure 3 [Pages 49-50] shows the 'B' RSS Pump supplying the CHS System and the 'A' RSS Pump supplying the SlH System. The input data for Lines 3 & 4 suggest that the 'A' RSS Pump is supplying the CHS System and the input data for Lines Printed 5/12/98 4:31:47 PM agie 1 of 4

l l

ICAVP DR No. DR-MP3-1037 l N:rthert Utilitie3 Millstone Unit 3 Discrepancy Report i System. Only one of the cross-tie lines between the SlH and i CHS Systems is modeled. Omitting the second cross-tie line l affects the flow balance of the system. Changing the flow balance could potentially alter the flow through the SlH and CHS Systems and the overall ECCS flow.

C. The Figure 7 Model determines the flow rates for the RSS Pump testing modes. Calculation 97 ENG-1431M3, Appendix 7 is a vendor letter indicating 1000 gpm is the minimum flow through the mini-flow recirculation line for the 'A' & 'B' RSS Pumps. Calculation US(B)-361 determines the flow through these lines will be 975 gpm during the quarterly test given an undegraded pump. ,

This calculation section used the pressure drop across the mini-flow orifice as sized in Calculation P(R)-610, Rev. O. Calculation P(R)-610 deterrnined the orifice size based on an outdated piping layout. Including this and all other comments and discrepancies against this calculation, the maximum flow through this line is under-estimated. Accoriding to Calculation US(B)-

245, Rev. 0; CCN 2 the flow is 1150 gpm.

However, Modification DCR 97045 added an orifice at the RSS pump discharge which results in additional pressure drop through this piping. The flow for this case is calculated in US(D)-361 as i described above.

Review Valid invalid Needed Date Inidator: Langel, D. 8 O O 2/s/98 2/sse VT Lead: Nort. Anthony A B O O VT Mgr: schopfer, Don K B D 0 2/s/98 IRC Chmn: singh, Anand K B O O 2/7/98 Date:

INVALID:

1 Date: 5/11/98 RESOLUTION: Disposition; NU has concluded that the issues reported in items A and C of Discrepancy Report, DR-MP3-1037, have identified conditions not previously discovered by NU which require correction. The I

approved corrective action plan for CR M3-98-0822 (attached) will correct Calculation US(B)-361 with respect to the discrepancies identified in items A and C.

Item A is an administrative item only. Calculation US(B)-245 will be revised to provide reference to calculation US(B)-361, or the i

appropriate information will be incorporated into US(B)-361 and US(B)-245 voided.

item C addresses several calculations. Calculation US(B)-361 determines the flowrates for both testing configurations (quarteriy testing through miniflow lines, and testing at each refueling Printed 5/12/98 4:31:51 PM Page 2 of 4

Northsast Utiliti:s ICAVP DR No. DR-MP3-1037 Millstone Unit 3 Discrepancy Report through test lines back to the RWST). This calculation determined that with the new orifice on the pump discharge, the flow during quarterly testing through the miniflow lines will be 975 gpm. This calculation needs to be revised to reconcile this value with the vendor requirement for 1000 gpm minimum.

However, the 975 gpm calculated is well within acceptable limits for this type of pump, and the vendor imposed 1000 gpm limit is very conservative for miniflow protection. Therefore, the calculated flow rates are acceptable. Calculation US(B)-361 will be revised accordingly.

Calculation US(B)-245 determined that the flow through the miniflow lines is 1150 gpm. This part of the calculation is superseded by calculation US(B)-361. As stated in item A, calculation US(B)-245 will be either revised or voided in favor of calculation US(B)-361.

CCN #1 to calculation P(R)-610 refers to Calculation US(B)-361 for hydraulic performance with the new orifice installed and states that P(R)-610 only addresses the sizing of the miniflow orifice. Therefore P(R)-610 is acceptable as written.

Calculation 97-ENG-1431M3 sizes the new miniflow/ test lines for the C and D pumps. This calculation requires revision to address the flows reported in calculation US(B)-361. Tnis an administrative change only since the calculation is utilized solely for sizing of the new test lines in the C and D loops.

The revised results will then be carried forward into the calculations and documents which use results from US(B)-361 as an input.

NU has concluded that the issue reported in item B1 of Discrepancy Report, DR-MP3-1037, has identified a condition not previously discovered by NU which has been corrected in revision 1 of US(B)-361. NU has concluded that the issue reported in item B2 of Discrepancy Report, DR-MP3-1037, does not represent a discrepant condition. Item B2 implies that a second cross tie line is available between the CHS and SlH pumps during sump recirculation. There is only one credited cross tie which is comprised of line numbers 3-SlH-006-39-2, 3-SlH-006-140-2, 3-SlH-006-40-2, and 3-SlH-006-110-2, which connect the suction headers of the CHS and SlH pumps. This cross tie is considered in the calculation. Note that the discharge header of the RHS pumps is not utilized as a cross connect since valves 3RHS*MV8716A and B are closed during sump recirculation. The calculation accurately models the applicable flow paths, therefore, this item is not a discrepant condition.  ;

l CR M3-98-0619 contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action will be completed after startup, and will ensure that the errors in US(B)-

361 are corrected. The corrective action plan for CR M3 0822 is tied to CR M3-98-0619 by AR 98002805.

Pnnted 5/12/98 4.31:52 PM Page 3 of 4 1

i I

N:rthert Utilities ICAVP DR N2. DR-MP3-1037 Millstone Unit 3 Discrepancy Report i

As part of the ICAVP program, trending CR M3-98-1132 has {

been written to ensure that any process-related issues related to  ;

these calculations are clearly identified and are being dealt with. I This assessment is scheduled to be completed prior to Startup.

Each of the discrepancies in DR-MP3-1037 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR MP3-98-1037 significantly affect the results of the RSS related calculations, and do not affect the conclusion that the RSS l system meets its design basis. In addition, each of these discrepancies has been reviewed by NU design engineers, who have further determined that none of the discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

I

Conclusion:

l 1

NU has concluded that the issues reported in items A and C of Discrepancy Report, DR-MP3-1037, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0822 (attached) will correct Calculation US(B)-361 with respect to the discrepancies identified in items A and C after startup. NU has concluded that the issue reported in item B1 of Discrepancy Report, DR-MP3-1037, has identified a condition not previously discovered by NU which has been corrected. NU has concluded that the issue reported in item B2 of Discrepancy Report, DR-MP3-1037, does not represent a discrepant condition because the valves in the additional cross tie line will remain closed during recirculation. 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 MP3-98-1037 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS system meets its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by NU? (_) Yes (9) No Non Discrepard Condition?C) Yes (*) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No Review Acceptable Not Acceptable Needed Date initiator: Langel. D VT Lead: Neri, Anthony A 8 O O 5/ 1/S8 VT Mgr: schopfer, Don K O 5/11/S8 IRC Chmn: singh, Anand K B D sii2/98 O O O Date:

SL Comments:

Printed 5/12/98 4:31:53 PM Page 4 of 4

N:rthert Utilitie3 ICAVP DR N3. DR-MP3-1038 Millstone Unit 3 Discrepancy Report Review Group: systern DR RESOLUTION ACCEPTED Discipline: Mechanical Design Potential Operability lasue Discrepancy Type: Design Control Procedure System / Process: NEW g

NRC significance level:4 Date faxed to NU:

Date Published: 2/12/98 l Discrepancy: Modific) tion DCR 97045 l l

l Descripuon: Modification DCR 97045 changed the design flow of the RSS System to address several system deficiencies. The modification included installing an orifice at the pump discharge to limit the design flow to 3000 gpm. It also included capping almost half of the RSS spray nozzles and control circuit changes for the MOV20 and MOV38 Valves.

The modification failed to address the following calculations:

P(R)-1020 - The hydraulic analysis for the post accident sampling system. The added orifice will increase the pressure I drop which could affect the flow rate to the sampling system. '

This calculation estimates the flow rate through the sampling system.

ES-107 - Pump NPSH under Min SI and Max ESF. The NPSH analysis is performed entirely under QS(B)-362. This is an extraneous calculation that should be voided or superseded.

US(B)-295 - RWST Drawdown Rates. The hydraulic analysis (US(B)-361) determines new flow rates for the ECCS function -

from the RWST.

US(B)-257 - Water Hold-Up. The reduced flows for the RSS System changes the time line for water hold-up in various containment areas. This calculation is the basis for other calculations performed for this modification.

Review l l Valid invalid Needed Date I initiator: Langel, D. 8 O O 2r3/98 i VT Lead: Nor1, Anthony A B O O 2r3/98  !

VT Mgr: schopfer, Don K B O O 2/6/98 1RC Chmn: singh, Anand K B D 0 2r7/98 l Date: i INVALID:

Date: E 11/98 RESOLUTION Disposition:

NU has concluded that the issues reported in items 1,2 and 4 of I Discrepancy Report, DR-MP3-1038, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0823 (attached) will correct Calculations P(R)-1020, ES-107 and US(B)-257 with respect to each of the discrepancies identified..

l Printed 5/12/96 4:32:16 PM Page 1 of 4 l

N:rthe ct Utilities ICAVP DR N2. DR-MP3-1038 Millstone Unit 3 Discrepancy Report l

Item 1 describes how the pressure drop across the new RSS orifice will result in a lower pressure in the RSS system. The PASS system will still perform acceptably although sample flow is decreased. This has been confirmed via Surveillance testing.

Calculation P(R)-1020 will be revised accordingly.

Item 2 is an administrative item only. Calculation ES-107 will either be voided or revised scenrdingly, in item 4, Calculation US(B)-257 determines hold up volume for input into calculation US(B)-362 which uses QSS and RSS spray fractions reaching the containment floor vs. time. The effect of modifying US(B)-257 to account for reduced RSS flow rate as a result of the orifice installation is expected to be insignificant because RSS fractions calculated in US(B)-257 depend on integrated amounts of RSS water and these are not expected to change significantly with flow rate. However, in order to provide consistent assumptions, the calculation will be revised to document the change in flow rates for RSS.

The revised results will then be canied forward into the calculations and documents which use results from these calcMations as an input.

NU has concluded that the issue reported in item 3 of Discrepancy Report, DR-MP3-1038 does not represent a discrepant condition. Calculation US(B)-295 does indeed use different ESF flow rates than US(B)-361, however this is l because the two calculations have different objectives. US(B)- j 361 models actual conditions, while US(B)-295 conservatively assumes maximum ESF flow rates to determine the minimum l time to switchover to sump recirculation, and also assumes that the ECCS pumps are delivering runout flow against zero containment backpressure which results in maximum RWST drawdown. Calculation US(B)-295 ignores the loss factors associated with piping which is conservative with respect to the objective to estimate the minimum time to switchover to sump recirculation. f Calculation US(B)-361 presents hydraulic models of various ECCS and RSS line-ups to evaluate the effect of the installation of the orifices on the RSS pump discharge piping. In comparison to the input assumed in Calculation US(B)-295, the model used on Calculation US(B)-381 predicts lower ECCS flows with a slower drawdown from the RWST, since it considers the 2 l effect of piping losses, which are modeled to provide a conservative value for ECCS performance.

l We conclude that item 3 is not a discrepant condition since both of these calculations make appropriate assumptions consistent with their respective objectives CR M3-98-0619 contains the 4 corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action will be completed after startup, and will ensure that the errors in P(R)-1020. ES-107 and US(B)-

I Printed 5/12/98 4:32:20 PM Page 2 of 4 l

L__________________. _

N:rthe:st Utliities ICAVP DR N3. DR MP3-1038 Millstone Unit 3 Discrepancy Report 257 are clear 1y identified and corrected. The corrective action plan for CR M3-98-0823 is tied to CR M3-98-0619 by AR 98002805.

As part of the ICAVA program, trending CR M3-98-1132 has been written to ensure that any process-related issues related to these calculations are clear 1y identified and are being dealt with.

This assessment is scheduled to be completed prior to Startup.

Each of the discrepancies in DR-MP3-1038 has been reviewed by the vendor (the Unit 3 architect engineer), who has determined that none of the discrepancies enumerated in DR MP3-98-1038 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 Dy NU design engineers, who have further determined that none of the discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that the issues reported in items 1,2 and 4 of j Discrepancy Report, DR-MP3-1038, have identified conditions i not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-0823 (attached) will correct three calculations (P(R)-1020, ES-107 and US(B)-  !

257) with respect to the discrepancies identified after startup. NU l has concluded that the issue reported in item 3 of Discrepancy Report, DR-MP3-1038, does not represent a discrepant condition. This calculation, US(B)-295, differs from US(B)-361 due to the different assumptions that are made about the input parameters, 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 MP3-98-1038 has been reviewed by the vendor and by NU, and none of them affect the conclusion that the RSS System meets its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Previously identified by NU? O Yes (*) No Non Discrepent condition?U Yes (e) No Resolution Pending?O vos @ No Resolution Unresolved?O v.s @ No Review l initiator: Langel. D.

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

SL Comments:

l Printed 5/12/98 4:32:21 PM Page 3 of 4 l

Narthsa2t Utilitics ICAVP DR No. DR-MP3-1038 Millstone unit 3 Discrepancy Report l

l I

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PrWed 5/12S8 4:32:22 PM Page 4 of 4

N:rthe:st Utilities ICAVP DR N2. DR-MP3-1039 Millstone Unit 3 Discrepancy Report l

Review Group: system DR RESOLUTION ACCEPTED Review Element: Systern Design p

Discipline: Mechanical Design Discrepancy Type: Calculaton Om g

SysterrVProcess: NEW ~

NRC Significance level: 4 Date faxed to NU:

Date Published: 2/12/98 Discrepancy: Hydraulic Analysis US(B)-361; Part 2

Description:

Calculation US(B)-361 [Rev. 0] is the hydraulic analysis for the ECCS Systems Spray and Cold Leg injection Modes. It was produced due to Modification DCR 97045 which reduced the RSS System flow to address several design issues.

1. The bases for the following Assumptions [Pages 7-8) are not provided.

Assumption 12: The RCP seal flow of 80 gpm. l Assumption 16: Closing the mini flow recirculation lines.

2. The drawing references [Pages 9-14) were copied directly from Calculation US(B)-245 including the reference number.

The FSK drawing series was superseded by the EM drawing series (P&lDs) and the line list. The FSKs are 'For information only' and do not accurately reflect the installed piping configuration.

3. The hydraulic resistance coefficients for 45' and 30' elbows

[Page 22) were determined from Reference 127. Only one part of the equation was used. The reference indicates that the resistance for elbows has two parts: 1) a fitting resistance and

2) a friction resistance. The calculation only determines the fitting resistance, underestimating the coefficient.

4. The resistance coefficient for control valves [Page 24] is determined to be the same as for fully open gate valves. Control valves are seldom used fully open; therefore, the resistance coefficient is under-estimated.

5. A density of 60 lb/ft3 is used to determine the resistance coefficients for the annubar flow elements, the RSS Coolers, the RHS Coolers and the mini flow recirculation orifices [Pages 25 26). This contradicts Assumption 4 which specifies a Specific Gravity of 1.0 (i.e., density is 62.4 lb/ft3).

1

6. The input data including the cumulative pipe resistance i coefficients were transposed directly from Calculation US(B)-

245. Few changes were made to these pipe resistance coefficients. This is despite recalculating resistance coefficients for fittings and components. The following are examples of the

" " ~ ~

Pnnted 5/12/06 4:324g PM Psge 1 of 3

1 N:rthert Utilities ICAVP DR N2. DR-MP3-1039 Millstone unit 3 Discrepancy Report l

l A. Some of the resistance coefficients do not correspond with the previously detemiined coefficients (e.g., the RSS Cooler coefficient is 13.7 from US(B)-361 and is 15.5 from US(B)-245. j The analysis was performed using a coefficient of 15.5). {

i B. Resistance coefficients for some fittings were never l determined (e.g.,5 Diameter bends,180* SR retums or 12" 90' short radius elbows).

C. Some resistance coefficients determined in this calculation are not included (e.g., the sump ring flange).

Review Valid invalid Needed Date initiator: Langel. D. 8 O O 2/5/98 VT Lead: Neri. Anthony A B O O 2xas VT Mgr: schopfer, Don K O O O 2/6/98 IRC Chmn: singh, Anand K O O O 2/7/98 Date:

INVALID:

Date: 5/7/98 REsOLUTKNJ: Disposition:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1039, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-1506 (attached) will correct Calculation US(B)-361 with respect to each of the discrepancies identified after startup. The revised results will then be carried forward into the calculations and documents which use results from US(B)-361 as an input.

CR M3-98-0619 (attached) contains the corrective action plan to complete the review of all RSS and QSS related calculation discrepancies identified by the ICAVP program. This corrective action will be completed after Startup, and will ensure that the errors in US(B)-361 are clear 1y identified and addressed. The corrective action plan for CR M3-98-1506 is tied to CR M3 0619 by AR 98002805.

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

This assessment is scheduled to be completed prior to Startup. 1 Each of the discrepancies in DR-MP3-1039 has been reviewed l by NU design engineers, who have determined that none of the

! discrepancies impacts the operability of the RSS system. As such there is no effect on the license or design basis.

Conclusion:

NU has concluded that the issues reported in Discrepancy Pnnted 5/12/98 4.32:53 PM Page 2 of 3

N:rthent Utilitie3 ICAVP DR No. DR-MP3-1039 Millstone Unit 3 Discrepancy Report Report, DR-MP3-1039, have identified conditions not previously discovered by NU which require correction. The approved corrective action plan for CR M3-98-1506 (attached) will correct Calculation US(B)-361 with respect to each of the discrepancies identified after Startup. In addition, an assessment will be performed prior to Startup of the issues related to calculational l discrepancies. This will ensure that these issues are clearly l identified and addressed.

Each of the discrepancies identified in DR MP3-98-1039 has been reviewed by NU, and none of them affect the conclusion that the RSS system meets its design basis. As such there is no

, effect on the license or design basis.

1 Previously identified by NU? O Yes @ No Non Discrepant Condition?O Yes @ No Resolution Pending?O ve. @ No Re.oiution unre.oived?O yes @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri. Anthony A j i VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: {

SL Comments:

l Printed 5/12/98 4:32:s5 PM Page 3 of 3 u______-______________ _

l N:rthert Utilitie3 ICAVP DR Ns. DR-MP3-1044 Millstone Unit 3 Di'screpancy Report l

Review Group: system DR RESOLUTION ACCEPTED l Review Eleinent: Sydem Design Potential Operability issue l Disciphns: & C Design Discrepancy Type: Calculation Ow System / Process: QSs

@ No NRC Significance level: NA Date faxed to Nu:

Date Published: 3/14/98 Discrepancy: Use of obsolete / superseded references in various I&C calculations Ductipuon: Various calculations use references to obsolete / superseded design documents. It is recognized that during the preparation of the calculation this input might have been verified but the historical tracking of the input to the superseded calculation for future use is lost with this action. This can become a potential configuration control problem. Some of the examples of this are ,

as follows .

1

1. Calculation 3451B01-1231, Rev. 0: Reference 3.4 (calculation 3-ENG-099, Rev. 2) is identified as an input reference for Boron ,

Concentration in the RWST tank. The same input is used for I calculation 3451B03-1232E3, Rev. O. Per calculation 3-ENG-099

~

Rev. 3, this calculation has been superseded by calculation l 3451801-1231, Rev. O. From the copy of calculation 3-ENG-099 Rev. 3 it is not clear what considerations were used in deriving the boron concentration or what references were used in deriving the number. Calculation 3451801-1231, Rev. O has used the results of boron concentration value from the calculation 3-ENG-99 without showing actual methodology.

2. Calculation 3451B03-1232E3, Rev. 0: Reference 3.7 l (calculation 3-ENG-111, Rev.1) is identified as an input document for " Calibration Data for Procedure SP3451B03 RWST Level Interlock Calibration". Review of latest revis!ons on Worte View for I&C Forms 3451B03-1,3451B04-1,3451B05-1

& 3451806-1 indicate references to calculation 3-ENG-111, Rev.

1. Calculation 3451803-1232E3, Rev. O was issued to account for a 24 months fuel cycle. The values used in the l&C forms listed above could be in less conservative direction if 3ENG-111, Rev.1 calculation is base on 18 months fuel cycle.

NOTE: A copy oflatest revision of 3ENG-111, calculation was requested under RFI-306, item 1 (IRF# M3-IRF-00248), but was not received due to its superseded status. Hence, the fuel cycle period used in that calculation could not be verified.

3. Calculation NSP-101-RSS, Rev.1 is a setpoint calculation for the instrument loop associated with 3RSS*FT38A and B.

Procedure IC3481 A08, Rev. 6 is identified as a design input (reference 21) to this calculation for defining drift uncertainties l associated with the flow transmitters. Scope of this procedure is to provide calibration instructions for Rosemount Model 1153 f and 1154 differential pressure transmitters. Per PMMS database l

and procurement specification 2472.510-662 the model number of the transmitters 3RSS*FT38A and 38B is Rosemount i 11GrTPARN Hnwaumr ('r'hl i rdatad 7/1Q/Qaiin tha nrnnndura Printed 5/12/98 4:33:19 PM Page 1 of 3

North 2ast Utilitiss ICAVP DR No. DR-MP3-1044 Millstone Unit 3 Discrepancy Report IC3481 A08 removed 3RSS*FT38A and B from its scope. The procedure taking place of IC3481 A08 is not identified.

Review Valid invalid Needed Date Initiator: Handia. R. O O O 3'3/98 VT Lead: Neri, Anthony A O O O 3/4/98 VT Mgr: schopfer. Don K B O O 3'SS8 IRC Chmn: singh. Anand K O O O aziose Date:

INVALID:

Date: 5/11/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in DR-MP3-1044 has identified a PREVIOUSLY IDENTIFIED condition which has been corrected.

Item 2: At the time S&L performed their review the l&C forms had not been revised to incorporate the results of calculation 3451803-1232E3. However, we were in process with the Den (M3-97106) on ECCS flow rate changes / RWST drawdown times / RWST level switch setpoint changes. This DCR had these procedure revisions as part of its scope. The present revision of these l&C forms (attached) are based on the 3451803-1232E3 calculation results. Because these changes were not approved documents at the time of the review, NU considers this to be a previously identified condition which has been corrected.

Item 1: Calculation 3-ENG-099 did not " develop

• any boron concentration results. It would have been more appropriate if the calculations referenced Technical Specifications as the source of the RWST boron concentration and stated an assumption that nominal concentration (2800 ppm) would be used. Information from calculation 3-ENG-099 was transferred to the 3451803-1231E3 calculation therefore the initiators felt that referencing it as a source was appropriate. Rev. 3 of 3-ENG-099 was issued to document the calculation was superseded at the time 3451B03-1231E3 was issued superseding it.

Item 3: To support the 24 month fuel cycle effort several procedures were revised to list specific transmitters that

• cumulative drift data" was to be taken on prior to calibration of the instrument. In 1994 when CCN 1 to the procedure was issued, and these instruments removed from that list, the effort to gather drift data was completed. Reference to the procedure for drift data as input to the calculation is appropriate as it was the source of the information and it is also appropriate that the data is no longer taken. The procedure is for the calibration of Rosemount Differential Pressure Transmitters and is still i applicable to the calibration of the 3RSS*FT38A, B instruments l even though there is no longer a specific step to record drift data l for the instruments.

Pnnted 5/12/98 4 33 22 PM Page 2 of 3 i

ICAVP DR N3. DR-MP3-1044 N:rthent Utilities Millstone Unit 3 Discrepancy Report Significance Level criteria do not apply to items 1 and 3 as they are not discrepant conditinns

Conclusion:

NU has concluded that the issue reported in DR-MP3-1044 has identified a PREVIOUSLY IDENTIFIED condition which has been corrected. The calculations referenced within this DR were either being revised at the time of S&L review or have been superseded. Referencing the procedure that obtained the drift data used within these calculations is appropriate since, it was the source (bases) of the information. Additionally, the 24 month fuel cycle effort has been completed for the 3RSS*FT38A & B transmitters and drift data is no longer required to be taken.

Previously identified by NU? O Yes @ No Non Discrepent Condition?@ Yes U No Resolution Pending?O ve. @ No ResolutionUnresolved?O vs. @ No i Review initiator: Hindia, R.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/11/98 SL Comments: Item 2 was not available at the time of S&L reiview. However, the concems of the DR have been addressed in the present revision of the documents identified in the DR.

PrWed 5/12/96 4:33:24 PM Page 3 of 3

ICAVP DR No. DR-MP3-1046 N:rthent Utilitie3 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Elenwnt: Modircation Design p

Discipline: Mechanical Design Discrepancy Type: Component Data Om g

I j

~

SystemProcess:

r NEW l NRc Significance level: 4 Date faxed to NU:

Date Published: 2/2398 Discrepancy: New valves added by DCRs M3-97042,97045, & 97094 Descripuon: The FSAR contains specific requirements with respect to design of valves in the emergency core cooling systems.

New valves have been added to the containment recirculation spray system as follows:

1. DCR M3-97094 adds new safety related gate valves 3RSS*V890,891,892,893.

11. DCR M3-97042 adds new safety related gate valves 3RSS*V895,897.

Ill. DCR M3-97045 adds new safety related gate valves 3RSS*V899,901,902,903, 904, S05,906, and safety related check valves 3RSS*V907,908,909,910.

The valves listed above are procured to design specification SP-ME-574. Design drawings for these valves, excluding valves 3RSS*V890,891,892,893, have not been entered into the Millstone Unit 3 drawing system. Drawing 2282.150-713-016 is l added by DCNs DM3-00187197 and DM3-00-1872-97 for valves 3RSS*V890, 891, 892, 893. Based on the information in specification SP-ME-574 Revision 0 and the available drawings for the new valves, discrepancies against system requirements are identified as follows:

1. Use of stainless steelis in accordance with Regulatory Guide 1.44.

(FSAR Section 6.1.1.1, and Tables 1.8- 1 & 1.8N-1)

Compliance with the requirement for all new valves cannot be confirmed.

2. Cold-worked austenitic stantess steels do not have a yield strench in excess of 90,000 psi.

(FSAR Section 6.1.1.1) i Compliance with the requirement cannot be confirmed for components of gate valves 3RSS*V895,897,899, 901,902,903,904,905,906, and check valves 3RSS*V907,908,909,910, (excluding the body & bonnet of the gate valves and excluding the body of the check valves).

The valve stem and bonnet studs for valves 3RSS*V890,891,982,893 are ASTM A-564 Type 630.

The yield stress for this stainless steel is greater than nn

"' ggg ~ "t Printed 5/1298 4:33:50 PM Page 1 of to

i l

ICAVP DR No. DR-MP3-1046 Northe=t Utilities Millstone Unit 3 Discrepancy Report l 3. Valve stem materials are corrosion & scoring resistant l and have high tensile strength.

(FSAR Sectio : 6.3.2.4)

Compliance with the requirement cannot be confirmed for gate valves 3RSS*V895,896,899,901,902,903,904, 905,906.

4. Valve seating surfaces are hard-faced with Stellite number 6 or equivalent.

(FSAR Section 6.3.2.4)

Compliance with the requirement cannot be confirmed for gate valves 3RSS*V895,897,899,901,902. 903,904, 905,906, and check valves 3RSS*V907,908,909,910.

5. Check valves are spring loaded lift piston for sizes 2 inches & smaller.

(FSAR Section 6.3.2.2.5)

Compliance with the requirement cannot be confirmed for check valves 3RSS*V907,908,909,910.

6. Manual gate valves employ a straight through wedge design with either split or solid wedge.

(FSAR Section 6.3.2.2.5)

Compliance with the requirement cannot be confirmed for gate valves 3RSS*V895,897,899,901,902,903,904, 905,906.

7. Aluminum and zinc are not used in safety related components that function post accident.

(FSAR Section 6.1.1.2)

Compliance with the requirement cannot be confirmed for components of gate valves 3RSS*V895,897,899,901, 902,903,904,905,906 and check valves 3RSS*V907, 908,909,910, (excluding the body & bonnet of the gate valves and excluding the body of the check valves).

8. Materials employed for components of ESF systems are in accordance with FSAR Table 6.1-1.

Compliance with the requirement cannot be confirmed for components of gate valves 3RSS*V895,897,899,901, 902,903,904,905,906 and check valves 3RSS*V907, 908,909,910, (excluding the body & bonnet of the gate valves and excluding the body of the check valves).

The valve yoke nut, packing nuts, and bonnet studs for l valves 3RSS*V890,891,982,893 are ASTM B-183, A-582, and A 564 Type 630, respectively. These materials f do not conform to FSAR Table 6.1-1 for their respective parts.

j l

Pnnted 5/t2/98 4:33:53 PM Page 2 of 10

t I

1 N:rthe ;ct Utilities ICAVP DR N3. DR-MP3-1046 Millstone Unit 3 Discrepancy Report

9. High quality coatings are applied to items with small surface areas (e.0., valve hand wheels). 1 (FSAR Section 6.1.2.2)

Compliance with the requirement cannot be confirmed for ,

gate valves 3RSS*V895,897,899,901,902,903,904, )

905,906.

10. Manual gate valves have backseat and outside screw and yoke construction. Containment recirculation system valves are selected to reduce potential leakage.

(FSAR Sections 6.3.2.2.5 & 6.2.2.2., respectively)

Compliance with the requirement cannot be confirmed for gate valves 3RSS*V895,897,899,901,902,903,904, 905,906.

No backseat can be identified on valves 3RSS*V890, 891,982,893. '

Review Valid invalid Needed Date initiator: Feingold, D. J. 8 O O 2/is/98  ;

VT Lead: Neri, Anthony A B O O 2/ir/98 l VT Mgr: schopfer, Don K S O O 2/18/98 1RC Chmn: singh, Anand K G O O 2/19/98 Date:

l INVALID:

Date: 5/8/98 RESOLUTION: - Northeast Utilities' First Response -

Disposition:

NU has concluded that Item # 2 of Discrepancy Report DR-MP3-1046 has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-1025 requires the FSAR to be revised after startup to clarify the appropriate applicability or exclusion of the material l

limitations within the ECCS per the response to DR-MP3-0613 (M3-IRF-01153). The DB or LB of MP3 is not impacted by this discrepancy and the Significance Level is considered to be Level 4.

NU has concluded that identified items 1 and 3 thru 10 of Discrepancy Report DR-MP3-1046 are not discrepant, but reflect work in progress. These items will be verified as part of the individual project close-out per the Design Control Manual l prior to startup. However, the approved corrective action plan for CR M3-98-1025 will provide an additional assurance of completion of the verification of each item by requiring review of the valve design data shown on the valve drawings and re-verifying compliance to the FSAR criteria. Items 1 and 3 thru 10 will be completed prior to startup. The valve characteristics Printed 5/12/96 4:33.54 PM Page 3 of 10 1

N:rthent Utilitie3 ICAVP DR Ns. DR-MP3-1046 (

Millstone Unit 3 Discrepancy Report required to determine compliance with the FSAR criteria is contained in the following DCN's. Those DCN's which have been transmitted to S & L are so indicated. DCR's M3-97094,-

97042, and - 97045 remain open and will be closed out prior to startup.

3RSS*V890,891: DCN DM3-00-1871-97, RFI-833/lRF-1716, l TRA-215,2/7/98 l 3RSS*V892,893: DCN DM3-00-1872-97, RF1-833/lRF-1716 TRA-215,2/7/98 ,

3RSS*V895,897: DCN DM3-00-614-97 & DCN DM3-00-613-97, both sent RFI 843/lRF-1423, TRA-207,1/30/98 3RSS*V899,901,902,903,904,905,906: DCN DM3-00-1926-  !

97 Attached to this IRF 3RSS*V907,908,909,910: DCN DM3-01-1926-97 Attached to this IRF Significance Level Criteria does not apply to items 1 and 3 thru 10 since there are no discrepancies. I

Conclusion:

NU has concluded that item #2 of Discrepancy Report DR-MP3-1046 has identified a condition not previously discovered by NU )

which requires correction. Discrepant item 2 will be implemented after startup as described in the response to DR-l l MP3-0613 (M3-IRF-01153). The DB or LB of MP3 is not l Impacted by this discrepancy and the Significance Level is.

concluded to be Level 4.

NU has concluded that items 1 and 3 thru 10 of Discrepancy Report DR-MP3-1046 has identified conditions not considered to be discrepant but reflect work in progress. These items will be verified as part of the project closed-out per the Design Control Manual prior to startup. The approved corrective action plan for l CR M3-98-1025 for items 1 and 3 thru 10 wili provide additional assurance of verification by requiring the review of valve design

) data and re-verification of compliance to the FSAR criteria.

l Significance Level Criteria does not apply since there are no discrepancies. j l

' l

-- Northeast Utilities' Second Response -

Disposition:

i l

NU has concluded that the issue reported in Revised Discrepancy Report DR-MP3-1046 does not represent a discrepant condition. NU concurs that confirmation of the new l

valves against the FSAR criteria cannot be made without the I

vendor valve drawings. Response M3-IRF-01903 provided Sargent & Lundy with both the vendor drawing number for each new valve and the transmittal reference which provided the information to Sargent & Lundy. These vendor valve drawings i have not been incorporated into NDS because the Desian l Printed 5/12/98 4:33 56 PM Page 4 of 10 I

1 1 i

ICAVP DR Ne. DR-MP3-1046 l Nrrthert Utilitie3 l Millstone Unit 3 Discrepancy Report j Control Manual requirements permit vendor drawings to be incorporated into NDS after the modification has been l

implemented. Specifically, section 4.5 of the Design Control l l Manual (DCM) requires Form 3-21, Engineering Release j Transmittal, be issued to document the Engineering release for  !

the design change to Operations for system operation. Upon issuing Form 3-21, section 4.5.10 of the DCM requires an AITTS commitment to the Design Engineer or Design Engineering Depaitment be initiated to close-out the DCR within 90 days from tumover to Operations. During Design Change Close-out (Section 5.2 Note reemphasizes the 90 day close-out time requirement.), changes are made to plant design data bases (DCM section 5.1.7). In addition, DCM section 5.1.10 requires that all other administrative items specified as being a requirement for design change close-out be completed. Thus. l the DCN's incorporating vendor drawings into GRITS and I changes to vendor specifications are non-technical and must be ,

I completed (DCN block 22 signed) within the 90 days. Upon completion of the DCN's section IV of DCM Form 3-2B, Supporting Design Change Package Details, can be signed which indicates close-out of the DCR package and the package is ready to be transmitted to NDS. Once block 21 sign off is complete, the DCN is an as-built controlled document which can be referenced as a design document. Issuance of the vendor drawings as stand alone documents is processed according to the significance of the drawing in the DCR. In the case of the vendor valve drawings for the RSS Modifications, it is planned to issue them within the 90 day close-out window from project tum over. The DCM close-out process for CCR's M3-97094, MS-97042, and M3-97045 is ongoning and will be completed within the required 90 days. Since the changes to the vendor documentation is administrative in nature, the vendor valve data provided by RFI M3-IRF-01903 can be reviewed for compliance to the FSAR.

Item 10 of DR-MP3-1046 states (in part)" Manual gate valves have backseat and outside screw and yoke construction.

Containment recirculation system valves are selected to reduce potential leahage. (FSAR Sections 6.3.2.2.5 and 6.2.2.2, respectively)". NU concurs with the overall intent of the statement but disagrees with the need for valve backseats in the i

' new manual valves installed by the three modifications which are the subject of DR-MP31046. FSAR section 0.2.2.2 states (in part) "During recirculation, leakage could occur through valve l packing and from leaks in the suction and discharge piping of the containment recirculation pump. Valves are appropriately selected to reduce this potential leakage to a negligible amount." To implement minimization of leakage, the third section of FSAR section 6.3.2.2.5 states (in part):

"The design features used to minimize valve leakage include:

1. Valves which are normally open, except check valves and those which perform a control function, with backseats to limit stem leakage.

Printed 5/12/9e 433:57 PM Page 5 of 10

Narthzct Utiliti;s ICAVP DR No. DR-MP3-1046

)

Millstone Unit 3 Discrepancy Report j 1

2. Normally closed globe valves installed with recirculation fluid l pressure under the seat to prevent stem leakage of recirculated I (potentially radiasctive) water."

The manual valves installed by the subject modification are 3 manual vent and drain valves which remain closed except during i maintenance activities. The valve seats in the redundant I manual valves form the pressure boundary isolation in each of the vent and drain lines. Thus there is no need for backseats in the new manual valves and no deviation has occured from the referenced FSAR sections in the design of the three modifications.

Item 1 of DR-MP3-1046 states:'Use of stainless steelis in accordance with Regulatory Guide 1,44 (FSAR Section 6.1.1.1 ,

and Tables 1.8-1 & 1.8N-1) - Compliance with the requirement I for all new valves cannot be confirmed." Paragraph 4 of the section in FSAR Table 1.8N-1 conceming Regulatory Guide 1.44 states " simple shapes need not be corrosion tested provided that the solution heat treatment is followed by water quenching.

Simple shapes are defined as all plates, sheets, bars and tubes l as well as forgings, fittings and other shaped products which do I not have inaccessible cavities or chambers that preclude rapid cooling when water quenched." The new valves were procured to a specification that only required the parts to be solution annealed and water quenched. Thus compliance with Regulatory Guide 1.44 criteria has been met.

In summary, no discrepant conditions have been determined to exist with revised DR-MP3-1046. However, since item # 2 of DR-MP3-1046 remains discrepant as stated in M3-IRF-01153, the Significance Level is concluded to remain as Level 4.

1

Conclusion:

l NU has concluded that the issue reported in Revised Discrepancy Report DR-MP3-1046 does not represent a discrepant condition. Close-out of DCR's M3-97094, M3-97042, and M3-97045 is ongoing in accordance with tne requirements of the DCM. Vendor drawings and vendor specifications will be incorporated into NDS during the 90 day close-out period as permitted by the DCM. The vendor valve data provided Sargent

& Lundy contains the technical data which can be reviewed for compliance to the FSAR criteria. Significance Criteria uoes not apply as no discrepancy exists for the revised DR. However since item # 2 of DR-MP3-1046 remains discrepant as stated in M3-IRF-01153, the Significance Level is concluded to remalin Level 4.

- Northeast Utilities' Follow-up To Their Second Response -

Disposition:

Printed 5/12/98 4:33:57 PM Page 6 of to

ICAVP DR No. DR-MP3-1046 I N:rthea:t Utilitbo Millstone Unit 3 Discrepancy Report i NU has concluded that this issue reported in DR-MP3-1046 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. NU provides the following information l in response to the verbal request of Sargent & Lundy. DCN DM3-00-0614-97 to DCR M3-97042 provides reference to Westinghouse drawing 8374D02 since it was an input into the l design. A copy of the Westinghouse drawing was provided with shipment of the valves and this copy was used in developing the design details as documented in the DCN. However, the drawing copy received was not of sufficient quality to be incorporated into GRITS. A bener quality drawing which can be incorporated into GRITS has been requested from Westinghouse. Once the new drawing has been received, a DCN to OCR M3-97042 will be issued within 90 days of tumover to Operations to formally incorporate the drawing into GRITS. For DCR close-out, the Design Control Manual requires Form 3-2B be completed and this will require completion of the DCN.

Conclusion:

1 NU has concluded that this issue reported in DR-MP3-1046 has l identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. NU provdes the following information in response to the verbal request of Sargent & Lundy. DCN DM3-00-0614 to DCR M3-97042 provides reference to Westinghouse drawing 8374D02 since it was an input into the design. A copy of the Westinghouse drawing was provided with shipment of the valves and was used in developing the design details as documented in the DCR. However, the drawing copy received was not of sufficient quality to be incorporated into GRITS. A better quality drawing which can be incorporated into GRITS has been requested from Westinghouse. Once the new drawing has been received, a DCN to DCR M3-97042 will be issued within 90 days of tumover to Operations to formally incorporate the drawing into GRITS. For DCR close-out, the Design Control Manual requires Form 3-2B be completed and this will require l completion of the DCN. However, since item #2 of DR MP3- l 1046 remains discrepant as stated in M3-lRF-01153, the Significance Level is concluded to remain Level 4.

Previou ly identifwki by NU? O Yes (9) No Non Discrepant Condition?O Yes (9) No Re.olution Pending?O ve. @ No Re.oiution unre.oived70 ve. @ No Review initiator: Feingold. D. J.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K l lRc Chmn. singh, Anand K O O O Date: 5/8/98 sL Conwnents: .- Sargent & Lundy's Comments on Northeast Utilities' First l

Response -

l l

Printed 5/12/98 4:33 59 PM Page 7 of 1o

1 l

N::rth:c t Utilities ICAVP DR No. DR-MP3-1046 Millstone Unit 3 Discrepancy Report Confirmation cannot be made that the subject modifications comply with the listed FSAR requirements without knowing the design details for the new valves added by the modifications.

These design details would normally be provided by vendor drawings and/or purchase specifications. This information is not l provided for the referenced valves added by the subject ,

j mo'iifications.

l Northest Utilities states that the missing design information is not l

required at this time because the modifications are still in

! progress, according to the Design Control Manual.

I Design Control Manual Revision 5, page 22 of Chapter 3, states,

" Design change close-out shall be completed within 90 days of l final Engineering Release for Operation". Page 6 of Chapter 1 I

states that this close-out includes procedures, lists, and databases.

l

! DCM Form 3-28,Section IV, is the Design Change Close Out.

I No items in this section apply to update of vendor drawings or purchase specifications.

No statements can be identified in the Design Control Manual that I

apply the 90 day close-out period to vendor drawing and purchase

specification changes and additions. According to NU, vendor i drawings are updated in the same manner as other design drawings. Therefore, Sargent and Lundy considers the Design l Control Manual to require inclusion of identified vendor drawings and purchase specification additions and revisions in modification DCNs prior to issue for implementation. Only after these l documents are updated can an evaluation be completed on the j new valves with respect to the FSAR requirements.

I

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

Response -

l l

The original DR, DR-MP3-1046, did not find discrepant the fact that the new vendor drawings were not added to GRITS prior to modification close-out. The DCNs provided Sargent & Lundy did not contain the subject vendor drawings.

l l Northeast Utilities'second response via M3-IRF-02187, provided the following docuriients previously identified as missing:

1. DCN DM3-00-1926-97, page 4, providing the vendor drawing for gate valves RSS*V899,901,90.2,903,904,905,906

2. DCN DM3-00-1926-97, page 3, providing the vendor drawing for check valves 3RSS*V907,908,909,910.

3. Westinghouse drawing 8374D02 providing the vendor drawing for 3RSS*V895,897. No DCN was provided to incorporate this drawing as a control document.

l Prtried 5/12/98 4:34.01 PM Page 6 of to I

I - - - - - - _ - - - - - - -

N:rtheast Utilities ICAVP DR N2. DR-MP3-1046 Millstone Unit 3 Discrepancy Report In their follow-up to their second response, Northeast Utilities provided the following with respect to Westinghouse drawing 8374D02: "The drawing copy received was not of sufficient quality to be incorporated into GRITS. A better quality drawing which can be incorporated into GRITS has been requested from Westinghouse. Once the new drawing has been received, a DCN to DCR M3-97042 will be issued within 90 days of tumover to Operations to formally incorporate the drawing into GRITS."

Sargent & Lundy considers this appropriate, given the condition of ,

the original drawing. Therefore, no discrepant issue is identified {

with respect to drawing 8374D02. J The following is Sargent & Lundy's position on the 10 system requirements for the subject valves as states in the FSAR:

1. The exception to Regulatory Guide 1.44 stated in FSAR Table 1.8N-1 is applicable to the subject valves. The subject valves do not have inaccessible cavities or chambers that preclude rapid cooling when water quenched. Therefore, item #1 is not a discrepant condition.

2. As stated in Northeast Utilities' response, item # 2 is a Level 4 discrepancy. Austenitic stainless steels used in the subject valves have yield strengths in excess of 90,000 psi. Northeast Utilities' response to DR-MP3-0613 applies to this item. The response to DR-MP3-0613 states,"The corrective action to correct this issue is to issue a FSARCR to clarify the appropriate applicability or exclusion of the material limitations within the ECCS. This corrective action is an enhancement to the FSAR to clarify plant configuration and is an administrative task for FSAR clarification only. Based upon the preceding discussion, the LB /

DB of MP3 is not impa ted by this discrepancy therefore NU considers this issue to be a level 4 discrepancy."

3. The valve stems for the subject gate valves were found to be corrosion & scoring resistant and to have high tensile strength.

Therefore, item # 3 is not a discrepant condition.

4. The seating surfaces for the subject valves were found to be hard-faced with Stellite number 6 or equivalent. Therefore, item

1. 4 is not a discrepant condition.

5. The subject check valves were found to be the spring loadsd, lift piston, type. Therefore, item # 5 is not a discrepant condition.

6. The subject gate valves employ a straight through wedge design with either split or solid wedge. Therefore, item # 6 is not a discrepant condition.

7. The requirement that the safety related valves not contain aluminum or zinc applies only to valves inside containment. The subject valves are not located inside containment. Therefore, item # 7 is not a discrepant condition.

8. Not all materials in the subject valves conform to FSAR Table Pnnted 5/12/98 4:34:01 PM Page 9 of 10

N:rthert Utilitie3 ICAVP DR Nr. DR-MP3-1046 Millstone Unit 3 Discrepancy Report 6.1-1. However, this does not represent a discrepant condition as l documented in discrepancy report DR-MP3-0292. According to Northeast Utilities' response to DR-MP3-0292, FSAR Table 6.1-1 is not intended to be an all-inclusive compendium of component materials as noted by the table's title, " TYPICAL MATERIALS EMPLOYED FOR COMPONENTS OF ESF SYSTEMS". As the i

table's purpose is simply to list typical materials, components with

material not listed in the table is not considered a discrepancy.

9. The requirement that high quality coatings be applied to items with small surface areas applies only to valves inside containment. The subject valves are not located inside containment. Therefore, item # 9 is not a discrepant condition.

10. According to FSAR Section 6.3.2.2.5, only normally open gate valves require a backseat. The subject valves are normally closed. Therefore, item # 10 does not represent a discrepant condition.

I In summary, only item # 2 represents a discrepant condition.

This discrepant condition is classified Level 4, consistent with response to DR-MP3-0613. The corrective action identified in DR-MP3-0613 also resolves the discrepant condition identified as item # 2 in DR MP3-1046.

I l

l l

Pnnted 5/12/96 4.34 02 PM Page toof to

1 N rthert Utilities ICAVP DR N2. DR-MP3-1050 Millstone Unit 3 Discrepancy Report 1 Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: structural Design Discrepancy Type: Installation implementation Ow Systern/ Process: NEW g l NRC Significance level. NA Date faxed to NU: j Date Published: 2/28/98 Discrepancy: Modification DCR M3-97580 references the incorrect specification for structural steel.

Descripuon: Modification DCR M3-97580 implements repairs and corrections to the containment structure sump enclosure.

1 1

Page 2 of the modification package states that the modification i is consistent with the original installation of the nump enclosure I framing and specification 2199.142-993. RFI-845 specifically requested specification 2199.142-993 as referenced in DCR M3-97580. However, the response to the RFI, IRF-1467, stated that the wrong specification was requested and that the correct specification was 2199.292 993.

1 A review of specification 2199.292 993 confirms it to be the '

correct specification. However, no evidence is found which demonstrates that the work on the sump screens specified in the subject modification is performed in accordance with specification 2199.292-993.

kview Valid invalid Needed Date initiator: Feingold, D. J. O O O 2/19/98 VT Lead: Neri. Anthony A B D O 2/19/98 VT Mgr: schopfer, Don K G O O 2/21/98 BRC Chann: singh. Anand K O O O 2/2s/98 Date:

IN'/ ALLO:

Date: 5/11/98 RESOLUTION

• Disposition:

i NU has concluded that the issue reported in DR-MP3-1050 has l identified a NON-DISCREPANT condition. Page 2 of Modification DCR M3-97500 regires the work to be completed in accordance with Specification SP-CE-247. The reference to specification 2199.292-993 on I I

page 2 was intended only to show consistency with the original installation. Note: The error 11 the referenced specification i number has been addressed. See the enclosed Memo to MMOD I M3-97580 File.  !

l l

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

l

Conclusion:

Printed 5/12/98 4:34:27 PM Psge 1 of 2 f

1 l

\ _ . _ _ _ _ _ _ _ _ _

i N:rthert Utilitie3 ICAVP DR N2. DR-MP3-1050 Millstone Unit 3 Discrepancy Report NU has concluded that the issue reported in DR-MP3-1050 has identified a NON-DISCREPANT condition. The modification was not required to be performed in accordance with specification 2199.292-993. The work was performed to SP-CE-247 as required by the modification package.

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

Previously identified by NU7 O Yes (9) No Non Discrepent condition?(#) Yes O No Resolution Pending?O ve. @ No ne.oiuinon unre.oived70 ve.

• No Review initiator: Feingold. D. J.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K Date: 5/11/98 sL comments: Based on Northeast Utilities' response, Sargent & Lundy considers the issue in DR-MP3-1050 an editorial error which is outside the Sargent & Lundy scope of review. Therefore, Sargent

& Lundy accepts Northeast Utilities' resolution.

Printed 5/12S6 434 31 PM Page 2 of 2 l

N::rthe tt Utilities ICAVP DR N3. DR-MP3-1064 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED RevW EW: MW W Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Drawing Ow System / Process: NEW

@ No NRc Significance level: NA Date faxed to NU:

Date Published: 2/28/98 I Discrepancy: DCR M3-97094 adds new non-safety valves for which drawings are not added to the drawing system. l Descripuon: DCR M3-97094 adds new valves 3RSS-V866,867,868,869 via DCNs DM3-00-1829-97 and DM3-00-1830-97. No new vendor drawings for these valves are identfied as being added to the Millstone Unit 3 drawing system.

Review Valid invalid Needed Date initiator: Feingold, D. J. O O O 2/19/98 VT Lead: Neri, Anthony A B O O 2/i9/98 VT Mgr: schopfer, Dor. K B O O 2t21/98 IRC Chmn: singh. Anand K O O O 2r2sse Date: 2/19/98 INVALID:

Date: 5/11/98 RESOLUTION: - Northeast Utilities' First Response -

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1064, does not represent a discrepant condition. The subject DCR and vendor drawings were identified in Discrepancy Report, DR-MP3-1046 and responded to in M3-IRF-01903 and the follow-up response, M3-IRF-02187.

These vendor valve drawings have not been incorporated into NDS because the Design Control Manual requirements permit vendor drawings to be incoTorsted into NDS after the modification has been implemented.Specifically, section 4.5 of the Design Control Manual (DCM) requires Form 3-21, Engineering Release Transmittal, be issued to document the Engineering release for the design change to Operations for system operation, Upon issuing Form 3-21, section 4.5.10 of the DCM requires an AITTS commitment to the Design Engineer or Design Engineering Department be initiated to close-out the DCR within 90 days from tumover to Operations. During Design .

Change Close-out (Section 5.2 Note re-emphasizes the 90 day l close-out time requirement.), changes are made to plant design -

data bases (DCM section 5.1.7). In addition DCM section 5.1.10 requires all other administrative items specified as being a ,

requirement for design change close-out are completed. Thus , j the DCN's incorporating vendor drawings into GRITS and changes to vendor specifications are non-technical and must be  !

completed (DCN block 22 signed) within the 90 days. Upon  !

Pnnted 5/12/98 4MS4 PM Page 1 of 3

I I

l N:rthext Utilities ICAVP DR N3. DR-MP3-1064 Millstone Unit 3 Discrepancy Report completion of the DCN's, section IV of DCM Form 3-28, Supporting Design Change Package Details, can be signed l which indicatet close-out of the DCR package and ready for the I package to be transmitted to NDS. Once block 21 sign off is complete, the DCN is an as-built controlled document which can be referenced as a design document. Issuance of the vendor drawings as stand alone documents is processed according to the significance of the drawing in the DCR. In the case of the vendor valve drawings for the RSS modifications, it is planned to issue them within the 90 day close-out window from project tum over. The DCM close-out process for DCR M3-97094 is ongoing and will be completed within the required 90 days.

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-MP3-1064, does not represent a discrepant condition. Close-out of DCR M3-97094 is ongoing in accordance with the requirements of the DCM. Vendor drawings and vendor specifications will be incorporated into NDS during the 90 day close out period as permitted by the DCM. Significance Level criteria do not apply here as this is not a discrepant condition.

l

- Northeast Utilities' Second Response -

Disposition:

NU has concluded that this issue reported in DR-MP3-1064 has identified a NON - DISCREPANT condition. Pursuant to discussions with S&L for clarification of the issue, NU submits the following additional information:

The original response provided by NU in M3-IRF-02247 was in error. Further investigation by NU has revealed that the valves in question 3RSS V866,867,868, and 869 are Class 4 / Non QA valves located outside of containment. As such, no vendor drawings are required of these valves.

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

Conclusion:

NU has concluded that this issue reported in DR-MP3-1064 has j identified a NON - DISCREPANT condition. Pursuant to discussions with S&L for clarification of the issue, NU submits the following additional information:

The oriainal response provided by NU in M3-IRF-02247 was in l PrWed 5/12/98 4.34.57 PM Page 2 of 3

l N:rthertt Utilities ICAVP DR No. DR-MP3-1064 Millstone Unit 3 Discrepancy Report error. Further investigation by NU has revealed that the valves in question 3RSS-V866,867,868, and 869 are Class 4 / Non QA l valves located outside of containment. As such, no vendor drawings are required of these valves.

Significance level criteria does not apply as this is not a i

' discrepant condition.

Previously identified by NU? O Yes (S) No Non Discrepent Condition?'l) Yes O No Resolution Pending?O ve. @ No Resolution Unresolved?O Yes @ No Review initiator: Feingold, D. J.

VT Lead: Neri, Anthony A O O mm

• /T Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Dete:

SL Comments:

1

)

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7 N:rthert Utilities ICAVP DR N2. DR-MP3-1064 MilistOne Unit 3 Discrepancy Report f Review Group: System DR RESOLUTION ACCEPTED Review Element: Modrication Design Discipline: Mechanical Des 4pn Discrepancy Type: Drawing System / Process: NEW @)No NRC Significance level: NA Date faxed to NU:

Date Published: 2/28/98 Discrepancy: DCR M3-97094 adds new non-safety valves for which drawings are not added to the drawing system.

Description:

DCR M3-97094 adds new valves 3RSS-V866,867,868,869 via DCNs DM3-00-1829-97 and DM3-00-1830-97. No new vendor drawings for these valves are identfied as being added to the Millstone Unit 3 drawing system.

Review Valid invalid Needed Date initiator: Feingold, D. J.

B 0 0 2/19/98 ,

VT Lead: Neri, Anthony A O O O 2/19/98 VT Mgr: schopfer, Don K S O O 2/21/98 IRC Chmn: singh. Anand K S O O 2/2s/98 Date: 2/19/98 INVALID:

l Date: 5/11/98 '

RESOLUTION: - Northeast Utilities' First Response -

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1064, does not represent a discrepant condition. The subject DCR and vendor drawings were identified in Discrepancy Report, DR-MP3-1046 and responded to in M3-IRF-01903 and the follow-up response, M3-IRF-02187.

These vendor valve drawings have not been incorporated into NDS because the Design Control Manual requirements permit vendor drawings to be incorporated into NDS after the modification has been implemented.Specifically, section 4.5 of the Design Control Manual (DCM) requires Form 3-21, En0ineering Release Transmittal, be issued to document the Engineering release for the design change to Operations for system operation. Upon issuing Form 3-21, section 4.5.10 of the DCM requires an AITTS commitment to the Design Engineer or Design Engineering Department be initiated to close-out the DCR within 90 days from tumover to Operations. During Design Change Close-out (Section 5.2 Note re-emphasizes the 90 day close-out time requirement.), changes are made to plant design data bases (DCM section 5.1.7). In addition DCM section 5.1.10 requires all other administrative items specified as being a requirement for design change close-out are completed. Thus ,

)

the DCN's incorporating vendor drawings into GRITS and I changes to vendor specifications are non-technical and must be completed (DCN block 22 signed) within the 90 days. Upon  !

Printed 5/12/96 4.48.s7 PM Page 1 of 3 I

i I

North:ast Utilitiss ICAVP DR No. DR-MP3-1064 Millstone Unit 3 Discrepancy Report e

completion of the DCN's, section IV of DCM Form 3-28, Supporting Design Change Package Details, can be s!gned which indicates close-out of the DCR package and ready for the package to be transmitted to NDS. Once block 21 sign off is complete, the DCN is an as-built controlled document which can l be referenced as a design document. Issuance of the vendor drawings as stand alone documents is processed according to the significance of the drawing in the DCR. In the case of the vendor valve drawings for the RSS modifications, it is planned to issue them within the 90 day close-out w;ndow from project tum over. The DCM close-out process for DCR M3-97094 is ongoing and will be completed within the required 90 days.

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

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1064, does not represent a discrepant condition. Close-out of DCR M3-97094 is ongoing in accordance with the requirements of the DCM. Vendor drawings and vendor specifications will be incorporated into NDS during the 90 day close-out period as permitted by the DCM. Significance Level criteria do not apply here as this is not a dLicrepant condition.

- Northeast Utilities' Second Response -

Disposition:

NU has concluded that this issue reported in DR-MP3-1064 has identified a NON - DISCREPANT condition. Pursuant to discussions with S&L for clarification of the issue, NU submits the following additional information:

Thc original response provided by NU in M3-lRF-02247 was in error. Further investigation by NU has revealed that the valves in question 3RSS-V866,867,868, and 869 are Class 4 / Non QA valves located outside of containment. As such, no vendor drawings are required of these valves.

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

Conclusion:

NU has concluded that this issue reported in DR-MP3-1064 has identified a NON - DISCREPANT condition. Pursuant to discussions with S&L for clarification of the issue, NU submits the following additionalinformation:

The oriainal response provided by NU in M3-IRF-02247 was in Prued 5/12/98 4 49.00 PM Page 2 of 3

N:rtherct Utilitier, ICAVP DR No. DR-MP3-1064 l Millstone Unit 3 Discrepancy Report error. Further investigation by NU has revealed that the valves in question 3RSS-V866,867,868, and 869 are Class 4 / Non QA i

valves located outside of containment. As such, no vendor drawings are required of these valves.

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

Previously identified by NU? O Yes @ No Non Discrepent condition?@ Yes Q ho Resolution Pending7O Ye. @ m2 Re.oiution unre.c4ved?O Yes @ ko Review initiator: Feingold, D. J.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date:

SL Comments:

I l

I Printed 5/12/96 4 49.01 PM Page 3 of 3

Ntrtherst Utilities ICAVP DR No. DR-MP3-1065 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Modification Design p

j Discipline: Mechanical Design Discrepancy Type: Design Control Procedure System / Process: NEW NRC Signincance level: 4 Date faxed to NU:

Date Published: 2/28/98 Discrepancy: Change to Calculations Descripuon: DCR 97045 changed the design flow of the RSS System by I adding an orifice at the discharge of each pump. DCR 97042 installed recirculation lines for the RSS C & D Pumps to provide a quarterly testing path.

The system changes due to the modifications required the following calculations to be addressed. It could not be confirmed that the calculations were reviewed due to the modifications.

US(B)-294 - The NPSH analysis for the SlH and CHS Pumps.

The new onfice in the RSS pump discharge will increase the pressure drop and decrease the NPSH available to the ECCS pumps.

P(R)-1192 - The over-pressure protection calculation for the RSS System. Lines were added for testing the RSS C & D pumps.

Review Valid invalid Needed Date initiator: Langel. D. O O O 2/19<98 I VT Lead: Neri, Anthony A B O O 2/21/98 i VT Mor: schopfer. Don K O O O 2/21/98 IRC Chmn: Singh, Anand K O O O 2/25/98 Date:

INVAUD:

Date: 5/7/98 RESOLUTION Disposition:

NU has concluded that the issue reported in Discrepancy Report, l DR-MP3-1065, has identified a condition not previously discovered by NU which requires action. This discrepancy meets the caiteria specified in NRC letter B16901 and 17010. It l has been screened per attachment 11 of U3 PI-20 criteria and i found to have no operability or deportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria.

Item 1: This not a valid discrepancy. Calculation US(B)-294 Rev. 5 dated 2/13/98 addresses this issue.

Item 2: Calculation P(R)-1192 requires revision to correct this discrepancy. However, the piping is consistent with Pipe Spec (SP-ME 572) for line class and pressure / temperature. In this case the DCR allows 90 days following the release to operations to close this type of administrative issue. CR M3-98-2094 was closed to CR M3-98-0138. The corrective actions in Bin CR M3-Printed 5/12/96 4.49:36 PM Page 1 of 2 l

N:rthe:tt Utilities ICAVP DR N3. DR-MP3-1065 I

Millstone unit 3 Discrepancy Report 98-0138 will correct this issue post startup.

There is no affect on License or Design Basis.

l

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1065, has identified a condition not previously discovered by NU which requires action. This discrepancy meets the criteria specmed in NRC letter B16901 and 17010. It has ,

been screened attachment 11 of U3 PI-20 criteria and found l to have no op - uy or deportability concems and meets I section 1.3.2.e. at L ; PI 20 deferral criteria.

Item 1 is non-discrepant as calc. US(B)-294 Rev. 5 addresses this issue. Item 2 (calc. P(R)-1192) requires correction within 90 days as allowed by the DCR. CR M3-98-2094 was closed to Bin j CR M3-98-0138 which will correct this error. j There is no affect on License or Design Basis.

Previou.ly identined by NU7 O Yes (9) No Non Discrepent Condition 70 Yes (#) No Resolution Pending70 Ye. @ No Re oiution unr..oived70 Yes @ No Review l

,,,,,,,,.,, accept.

• Noi accept. m usedeo we VT Lead Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date:

sL Comm.rds:

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