ML20247G361
| ML20247G361 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/15/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9805200224 | |
| Download: ML20247G361 (54) | |
Text
i
'Setge Lunciy c Senior Vee President 312 269-6078 '
4
- May 15c 1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company -
_ Millstone Nuclear Power Station, Unit No. 3
' Independent Corrective Action Verification Program
. United States Nuclear Regulatory Commission
- Attention: Document Control Desk Washington, D.C, 20555 :
I have enclosed the following discrepancy reports (DRs) identified during our review activities for the ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.
I have enclosed the following ten (10) DRs for which the NU resolutions' have been reviewed and -
accepted by S&L.
DR No.' DR-MP3-0077 DR No. DR-MP3-0908 DR No'. DR-MP3-0383 DR No. DR-MP3-0912
' DR No. DR-MP3-0428 -
DR No. DR-MP3-0942 DR No. DR-MP3-0546 -
DR No. DR-MP3-1010 DR No. DR-MP3-0694 DR No. DR-MP3-1100
/[
I have also enclosed the following two (2) DRs for which the NU resolutions have been reviewed j
but not, accepted. S&L comments on these resolutions have been provided. These DRs are-
- considered unresolved" and will need NRC involvement
-l DR-No. DR-MP3-0035
[
- DR No. DR-MP3-1074 '
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9905200224 990515 PDR ADOCK 05000423 P
PDR 55 East Monroe Street
- Chicago, IL 60603-5780 USA + 312-269-2000
' United States Nuclear Regulatory Commission May 15,1998 Document Control Desk Project No. 9583-100
. Page 2
' Please direct any questions to me at (312) 269-6078.
Yours very truly, 6
_-~
D. K. Schopfer SeniorVice President and ICAVP Manager DKS:spr.
Enclosures Copies:
' E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/1) NU m:\\icavpbvre8WO315 a. doc
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Northe:st Utliities ICAVP DR N3. DR-MP3-0077 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability lasue Discipline: Mechanical Design Om Discrepancy Type: Calculation System / Process: QSs NRC Significance level: NA Date faxed to NU:
Date Published: 9/29/97 Discrepancy: Discrepancies in QSS Effective Time, Actuation Time and EDG Start Time.
==
Description:==
Licensing documents and calculations contain discrepancies with respect to Quench Spray System (OSS) spray effective time, OSS spray actuation time, and Diesel Generator start time.
QSS Spray Maximum Effective
?
Reference Time (sec)
FSAR Sec 6.2.2.2 approximately 68.2 without offsite power 3DBS-NSS-002 no more than 70.2 without offsite power i
US(B)-253 Rev 4 71.2 without offsite power US(B)-225 Rev 6 70.2 without offsite power FSAR Table 6.2-16 71.5 with minimum ESF j
Orig SER Sec 6.2.2 64.0, power availability not l
provided FSAR Sec 6.5.2.2 less than 65.0, power availability not provided i
FSAR Sec 6.2.1.1.3.7 max of 57.2 with offsite power 3DBS-NSS-002 no more than 52.2 with offsite power
)
US(B)-253 Rev 4 57.2 with offsite power US(B)-225 Rev 6 52.2 with offsite power QSS Spray Maximum Reference Actuation Time (sec)
FSAR Sec 6.2.2.2 16 without offsite power, diesel generator starting, sequencer delay I
3DBS-NSS-002 19 without offsite power, l
diesel generator starting, I
sequencer delay l
Diesel Generator l
Start Time I
References (sec)
TRM Table 3.3.2.1
< 12 3DBS-NSS-002 14 US(B)-225 Rev 6 14 FRAP Ron A 9 9 9 11
[
Pnnted S/15/98 9:16:13 AM Page 1 of 8 l
Northe st Utilities ICAVP DR N2. DR-MP3-0077 MI:: stone Unit 3 Discrepancy Report
)
Notes:
Calculation US(B)-225 provides the predicted times based on system operating parameters.
Calculation US(B)-253 provides the times used in the design basis Loss of Coolant Analysis.
Review Valid invalid Needed Date initiator: Feingold. D. J.
B O
O S/18/S7 VT Lead: Neri, Anthony A O
O O
S/18/S7 VT Mgr: schopfer, Don K Q
O O
S/18/97 IRC Chmn: singh, Ansad K G
O O
9/25/97 Date:
INVALID:
1 l
I Date: 5/14/98
{
RESOLUTION:..- Northeast Utilities' First Response ---
Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0077, does not represent a discrepant condition. DR-MP3-0077 identifies potential inconsistencies between design and licensing documents for the quench spray effective times.
Some of these differences can be attributed to the revision of the calculation (US(BF225) determining the system response times.
The evaluation of the differing values conceming QSS effective time, is based upon the following:
Calculation US(B)-225 determines the fill time for the QSS piping system. This information was then input into US(B)-253 which establishes inputs to the containment analyses, US(B)-273 and US(B)-266. These calculations determine the peak containment pressures and temperatures post LOCA (US(B)-
273) or following an MSLB (US(B)-266). These evaluations use the QSS MAXIMUM response time to determine the rate of containmer:t depressurization following an eccident. The response time used in these calculations is the value important for the safety analysis. Since it is the ability of the QSS system to depressurize the containment which is analyzed, it is more conservative to assume a longer response time.
For all calculations associated with the containment depressurization analysis a conservative 14 second diesel start time is assumed. The maximum allowable diesel start time as defined in the Technical Specifications is 11 seconds. Technical Specifications Surveillance Procedure SP 3646.15 assures that this is met by specifying a 10 second acceptance criteria..
One of the reasons Calculation US(B)-225, " Quench Spray Effective Times" was revised is to include degraded pump curves for deterrrination of maximum system response times.
This revision calculated slightly faster system fill times resulting Printed 5/15/98 9:16:14 AM Page 2 of 8 j
I J
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Northe':st Utilities ICAVP DR fit DR-MP3-0077 Millstone Unit 3 Discrepancy Report l
in faster system respnse times, which is favorable for reduction of containrr ent presst e following a LOCA or secondary line break. Based upon this, revision of the containment anhlysis using these faster response times and revision of the FSAR is not necessary since the new values are bounded by the old.
However, the following will address each item listed in DR-MP3-0077 with respect to this latest calculation note revision:
Reference:
FSAR 6.2.2.2, " Containment Heat Removal System.
System Design" Statement: The QSS becomes effective in approximately 68.2 i
semnds assuming loss of offsite power andonly one pump operati, J. (This paragraph then identifies how 68.2 is detehnined)
Response: Using the new system fill time from US(B)-225, and the maximum Tech spec DG start time of 11 sec, the system effective time is 1 sec less, or 67.2 sec. The present FSAR uses a longer time therefore it is conservative.
Reference:
3DBS-NSS-002, " Design Basis Summary for the Quench Spray System" Statement ".. containment accident analysis spray time shall be no greate.r than 52.2 sec with offsite power available and no greater than 70.2 sec with offsite power unavailable.. "
l Re ponse: These values are the same as Rev 6 of calculation J
US(B)-225.
Reference:
US(B)-253 Rev 4," Documentation of LOCTIC Data Deck for Millstone Unit #3 LOCA Analysis" Statement: Min ESF:QSS Effective Time; Assuming LOP =52.2 sec (system fill + motor start time)+ 14sec (DG start time) + 5 sec (sequencer)= 71.2 Response: Using the new system fill time from US(B)-225, the system effective time becomes 1 sec less, or 70.2 sec, the present LOCA analysis uses a longer time, therefore it is conservative.
Reference:
US(B)-225 Rev 6, " Quench Spray Effective Times" Statement: Max QSS effective Time = 50.2 sec (system fill)+14sec (DG start)+5sec (sequencer)+1sec (pump accel)=70.2 sec Response: This is the latest revision to the calculation.
Reference:
FSAR Table 6.2-16," Accident Chronology Pump Suction DER with Min ESF" Statement: 71.5 s Quench Spray System becomes effective Response: This comes from the containment analysis, US(B)-
273, page 22. This value was input from US(B)-253 which contains a more conservative value than that resulting from l
revision of US(B)-225.
Reference:
SER 6.2.2 Statement: The QSS is actuated automatically on receipt of tne CDA signal, and spray flow becomes effective within 64 sec after the signal is received.
Response: This statement was appropriate for the oriainal FSAR Printed S/15/98 9:16:14 AM Page 3 of 8 l
l l
l Northeast UtWties ICAVP DR N3. DR-MP3-0077 Millstone Unit 3 Discrepancy Report analysis. The original FSAR, Section 6.2.2 and Table 6.2-16 reported a 64 second QSS response time, therefore the original NRC SER value of 64 seconds stated in the original NRC SER was appropriate. The analysis has since been revised.
Reference:
FSAR 6.5.2.2, " Containment Sprays as a Fission Product Cleanup System" Statement: The QSS becomes effective in less than 65 seconds after the postulated event.
Response: This statement is true for offsite power available.
Reference:
FSAR 6.2.1.1.3.7," Main Steam Pipe Break Results" Statement: The maximum time required to start the pumps and fill the headers is 57.2 seconds for both one and two pump with j
off site power availsbie operation.
Response: This is the value used in US(B)-253 which is input to the containment analysis US(B)-266. US(B) 266; Main Steam Line Break: " Containment Integrity and Temperature Evaluation" assumes 71.2 sec. Because the analysis uses a longer response time it is more conservative.
Reference:
3DBS-NSS-002 Statement: no more than 52.2 with offsite power.
Response: These values are the same as Rev 6 of calculation j
US(B)-225.
Reference:
US(B)-253 Rev 4 Statement: 57.2 with offsite power Response: Using the new system fill time from US(B)-225, the system effective time becomes 5 sec less, or 52.2 sec, the present LOCA analysis uses a longer time therefore it is conservative.
Reference:
US(B)-225 Rev 6 Statement: 52.2 with ofisite power Response: This is the latest revision to the calculation.
Reference:
FSAR 6.2.2.2 Statement: DG start + seg = 16 see Response: 11 sec tech spec start time + 5 sec sequencer time
Reference:
3 DBS-002 Statement: DG start + seg = 19 sec Response: 14 sec safety analysis DG start time + 5 sec sequencer time
Reference:
TRM Table 3.3.2.1, " Technical Requirements Manual, ESF Response Times" l
Statement: DG start time <12 sec l
Response: The Technical Requirements Manual contains a " start diesel generator" time of < or equal to 12 seconds following certain initiation signals. This acceptance criteria is based upon signal response times as well as the diesel start time. Ref SP31024 and SP 3646A.15.
Reference:
3DBS-NSS-002 Printed SMS/98 9:16:14 AM Page 4 of 8 l
Northe:st Utilities ICAVP DR ND. DR-MP3-0077 Millstone Unit 3 Discrepancy Report Statement: DG start time 14 sec Response: The maximum diesel generator start time in the Technical Specifications is 11 sec. Containment depressurization analysis calculations assume a longer diesel start time which results in accident mitigation equipment starting later in the accident, providing more conservative results.
)
Reference:
US(B)-225 Rev 6 Statement: DG start time 14 sec l
Response: This is the latest revision to the calculation.
)
As noted above, the items are applicable to later revisions of calculations and are conservative with respect to the Safety Analysis and Technical Specifications. Significance Level criteria do not apply here as this is not a discrepant condition.
J 1
)
QSS Spray Maximum EffectiveReference References Time (sec)
FSAR Sec 6.2.2.2 approximately 68.2 without offsite power 3DBS-NSS-002 no more than 70.2 without offsite power i
US(B)-253 Rev 4 71.2 without offsite power j
US(B)-225 Rev 6 70.2 without offsite power FSAR rable 6.216 71.5 with minimum ESF Orig SER Sec 6.2.2 64.0, power availability not provided FSAR Sec 6.5.2.2 less than 65.0, power availability not provided FSAR Sec 6.2.1.1.3.7 max of 57.2 with offsite power 3DBS-NSS-Lt2 no more than 52.2 with offsite power US(B)-253 Rev 4 57.2 with offsite power US(B)-225 Rev 6 52.2 with offsite power QSS Spray MaximumReference References Actuation Time (sec)
FSAR Sec 6.2.2.2 16 without offsite power, diesel generator
- starting, sequencer delay 3DBS-NSS-002 19 without offsite power, diesel generator
- starting, sequencer delay Diesel GeneratorReferences References Start Time (sec)
TRM Table 3.3.2.1
< 12 3DBS-NSS-002 14 14US(B)-225 Rev 6 14 FSAR Sec 6.2.2.2 11 Notes:
Calculation US(B)-225 provides the predicted times based on Printed 54::!98 9:10:14 AM Page 5 of 8 f
L
l N:rthet.st Utilities ICAVP DR N2. DR-MP3-0077 Millstone Unit 3 Discrepancy Report system operating parameters.
Calculation US(B)-253 provides the times used in the design basis Loss of Coolant Analysis.
==
Conclusion:==
l NU has concluded that Discrepancy Report, DR-MP3-0077, does not represent a discrepant condition. The items identify values used in analyses which are conservative with raspect to the Technical Specifications and are bounded by the Safety Analysis. Significance Level criteria do not apply here as this is not a discrepant condition.
-- Northeast Utilities' Second Response -
Disposition:
NU has concluded that this issue reported in DR-MP3-077 has identified a PREVIOUSLY IDENTIFIED condition. UIR 1129 identified the QSS start time discrepancies. The Closure Request Report for UIR 1129 and not DCR M3-97045, evaluated in detail the impact of revision 6 to calculation US(B)-225 upon the containment analyses calculations (US(B)-273 and US(B)266). The conclusion was reached that no further revisions are required to the calculations, but FSARCR 98-MP3-28 was issued to correct the FSAR with respect to QSS effective i
times. FSAR section 6.2.2 includes a discussion of the time it takes for the QSS system to become effective. This discussion uses the technical specification diesel start time of 11 seconds.
4 Containment post accident analysis calculations use 14 seconds to determine maximum containment pressure and temperature as well as iodine removal coefficients. This additional 3 seconds provides margin. The discussion in the FSAR section is addressing the actual system responses which would be expected following a CDA signal, not the safety analysis limits.
For this reason, the diesel start time of 11 seconds in FSAR section 6.2.2 is appropriate. Section 12.2.8 of the DBS clearly identifies the 14 second diesel start time as that used in the analysis.
==
Conclusion:==
NU has concluded that that the issue reported in DR-MP3-077 has identified a PREVIOUSLY IDENTIFIED condition. UlR 1129 identified the QSS start time discrepancies and the associated Closure Request Report evaluated the istues in detail. FSARCR 98-MP3-28 was issued to correct the FSAR with respect to QSS effective times. No calculation revisions are required.
Previously identifled by NU? % Yes O No Non Discrepant Condition?O Yes @ No Printed 5/15/98 9:16:14 AM Page 6 of 8 L___-___________
l Northe:st Utilities ICAVP DR N2. DR-MP3-0077 Millstone Unit 3 Discrepancy Report j
ResolutionPending?O Yes (9) No Resolution Unresolved?O Yes (9) No Review Acceptable Not Acceptable Needed Date Inluator: Feingold. D. J.
B O
O S1
- VT Lead: Neri, Anthony A 8
O O
5/1m VT Mgr: schopfer. Don K l
O O
s/1e lRC Chmn: singh. Anand K d
O O
O Date:
5/14/98 l
sL comments: -- Sargent & Lundy's Comments on Northeast Utilities' First l
Response --
1 f
The QSS System Effective Time Calculation, US(B)-225, Rev. 6 is a design basis calculation which should be consistent with other l
design calculations, the FSAR and the DBSDs.
US(B)-225, Rev. 6 does not reach the conclusion that the revised QSS fill times are less limiting than Rev. 5 (or Rev. 4). It does j
not provide a justification for why downstream design documents do not need to be updated. Because it does not reach this conclusion, US(B)-255, Rev. 6 no longer substantiates the old values for QSS effective time of Rev. 5 (or Rev. 4).
Containment pressurization calculations US(B)-253, Rev. 4, US(B)-273, Rev. 5 and US(B)-266, Rev. 2 do not justify the use of outdated values for QSS effective time, (i.e., values that are different from the controlled, design basis information provided by US(B)-225, Rev. 6).
The design basis containment pressurization calculations and the FSAR (FSAR Sec. 6.2.1.1.3.7. 6.2.2.2 and 6.5.2.2 are the only references to QSS effective time identified in this DR) should have used the correct OSS effective times of 52.2 seconds for Max ESF with no LOP and 70.2 seconds for Min ESF with a LOP. 3DBS-NSS-002 was properly updated to reflect these values for QSS effective time.
The same comment applies to the OSS Spray Pump actuation time in FSAR Sec. 6.2.2.2. The QSS and containment design basis start time for the diesel generator is 14 seconds, as identified in US(B)-225, Rev. 6, US(B)-253, Rev. 4 and US(B)-
266, Rev. 2. This time should be used in the FSAR to indicate that the QSS Spray Pump actuation time is 19 seconds after a l
LOP /LOCA or LOP /MSLB. 3DBS-NSS-002 reflects the correct value for the QSS Spray Pump actuation time.
These discrepancies are currently being addressed in calculation revisions and FSARCRs resulting from Modification M3-97045.
However, this modification commenced in response to a condition (reported in LER 97-028) that NU discovered after the May 17, 1996 design audit of the QSS/RSS systems began.
Therefore, S&L concludes that differences between the QSS effective times in the FSAR, DBSD and design basis calculations are a discrepant condition.
Printed 5/15/98 9.16:15 AM Page 7 of 8 1
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Northeast Utilities ICAVP DR N2. DR-MP3-0077 Millstone Unit 3 Discrepancy Report
-- Sargent & Lundy's Comments on Northeast Utilities' Second Response -
Sargent & Lundy concurs with Northeast Utilities that the subject, OSS effective time inconsistencies, was previously discovered via UIR 1129. Even though every specific inconsistency was not addressed in the UIR, the Northeast Utilities' corrective action program is given credit for correcting all of the identified inconsistencies through the UIR closure process.
Two inconsistencies not specifically addressed in the close-out CR M3-98-2248 are:
- 1. FSAR Sec. 6.2.1.1.3.7 states that the maximum OSS effective time with offsite power is 57.2 seconds where the calculated maximum time is 52.2 seconds.
- 2. FSAR Sec 6.5.2.2 states that the maximum QSS effective time is less thaa 65 seconds, where power availability is not specified. The maximum QSS effective time without offsite power is calculated to be 70.2 seconds.
incerisistency item,1 above, is considered non-discrepant because the value in FSAR Sec 6.2.1.1.3.7 is conservative.
Inconsistency item 2, above, is considered non-discrepant because the value is conservative given that offsite power is available.
Even though Sargent & Lundy finds the above listed inconsistencies to be non-discrepar.t, the following is recommended to avoid future confusion.
- 1. Change the OSS effective time identified in FSAR Section 6.2.1.1.3.7 to a value that is consistent with the value for QSS effective time with offsite power available used in other sections of the FSAR.
- 2. Clarify FSAR Section 6.5.2.2 to identify that the QSS effective time provided is based on offsite power being available.
Furthermore, change the QSS effective time identified in FSAR Section 6.5.2.2 to a value that is consistent with the value for QSS effective time with offsite power available used in other sections of the FSAR.
I l
Printed 5/15/98 9:16:15 AM Page 8 of B r
N:rthea:t Utilities ICAVP DR Ns. DR-MP3-0383 Millstone Unit 3 Discrepancy Report Review Group: systern DR RESOLUTION ACCEPTED Review Element: system Design p
Discipline: Peping Desyn Om Discrepancy Type: Calculaton g
System / Process: sWP
~
NRC significance level: NA Date faxed to NU:
Date Published: 10/23/97 Discrepancy: Pipe stress analysis does not utilize latest design input
==
Description:==
During the review of service water piping calculations (i) 12179-NP(B)-X1902 Rev 5 (ii)12179-NP(F)-918-XD Rev 2, CCN 5 (iii) 12179-NP(F)-768-XD Rev 0, CCN 6 (iv) 12179-NP(F)-10033-XD Rev 0, CCN 4 (v) 12179-SDP-SWP Rev 10, dated 5/23/97 we noted the following discrepancies:
1 Pipe stress calculations (i) thru (iv) are performed using design i
input from a superseded Stress Data Package (SDP) calculation.
The current version of the SDP is Rev 10 (v). Calculations (1) thru (iii) are ba;ed on Rev 9 of the SDP, while calculation (iv) is based on Rev 6.
1 The operating temperature used in pipe stress calculations (i) &
(ii) is 105 deg F, while the revised operating temperature for conditions 3,10,11 and 14, according to (v), is 125 deg F. The operating temperature used in calculation (iii) is 95 deg F & in (iv) is 110 deg F, while the revised operating temperature for condition 14, according to (v), is 190 deg F.
Review l-Valid invalid Needed Date initiator: Jain, R. C.
O O
O 10/3'S7 VT Lead: Neri, Anthony A O
O O
o/7/S7 l
VT Mgr: schopfer, Don K O
O O
o' 4/S7 IRC Chrnn: singh, Anand K G
O O
1o' 7/97 Date:
INVALID:
Date: 5/14/98 l
RESOLUTION: Disposition: Response ID: M3-IRF-00835 NU has concluded that DR-MP3-0383 does not represent a discrepant condition. DR-MP3-0383 Identifies three issues, ench of which are addressed individually as follows:
l l
Issue 1: Operating Temperature used in calculations 12179-NP(B)-X1902 and 12179-NP(F)-918-XD Calculation NP(B)-X1902 is currently being revised for the increase in temperature of 125 *F as part of the CCP reanalysis task (initiated and tracked by ACR M3-96-0887 ), which identified an increase in temperature for the SWP system downstream of the CCP heat exchanger due to an increase in Printed 5/15/98 9:16:48 AM Page 1 of 5 l
L_______________
Northe:st Utilities ICAVP DR N2. DR-MP3-0383 Millstone Unit 3 Discrepancy Report the CCP system temperature. Therefore, the misunderstanding is due to the in-process nature of the design process.
Calculation NP(F)-918-XD addresses branch lines off the main piping analyzed under calculation NP(B)-X1902, and is currently i
being revised as part of the CCP reanalysis task (initiated and tracked by ACR M3-96-0887 ) to address the change in main header movements due to the increased temperature in the main run. Therefore, similar to the situation with calculation NP(B)-
X1902, the misunderstanding is due to the in-process nature of the design process.
Issue 2 : Operating Temperature used in calculations 12179-NP(F)-768-XD Calculation NP(F)-768-XD addresses small bore branch lines downstream of RSS coolers. The reference to 95 'F is relevent to the small bore branch lines. CCN #5 to this calculation evaluates the revised main header movernents due to the change in main run temperature to 190 'F in the Faulted case.
CCN #5 refers to Rev. 3 of the large bore stress calculation NP(F)-X1907 for input movements. The 190 'F is relevent to the main header movements only, therefore there is no discrepancy in analyzed temperature.
Issue 3 : Operating Temperature used in calculations 12179-NP(F)-10033-XD Calculation NP(F)-10033-XD addresses root valves and tubing to flow transmitters downstream of RSS coolers. The reference to 110 'F is relevent to he the root valves and tubing identified in the calculation. Similar to the situation with calculation NP(F)-
768-XD, CCN #3 to this calculation evaluates the revised main header movements due to the change in main run temperature to 190 *F in the Faulted case. CCN #3 refers to Rev. 3 of the large bore stress calculation NP(F)-X1907 for input movements.
The 190 'F is relevent to the main header movements only therefore, there is no discrepancy in analyzed temperature.
Note:
The revision level of the SDP calculation does not necessarily match the revision level referenced in the individual stress calculations since the SDP's were recently revised and updated to provide consistency with the technical content of the piping stress calculations. The misunderstanding is due to the in-process nature of the design process.
Significance level criteria does not apply as these are not discrepant conditions.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0383 does not represent a discrepant condition. The revision level of the SDP calculation does not necessarily match the revision level referenced in the individual stress calculations since the SDP's were recently revised and updated to provide consistency with the technical content of the piping stress calculations. The misunderstanding is due to the in-process nature of the design l
process. The 95 'F operatina temperature referenced in 12179-Printed 5/15/98 9.16.48 AM Page 2 of s
N rthe:st Utilitir,s ICAVP DR Ns. DR-MP3-0383 i
Millstone Unit 3 Discrepancy Report NP(F)-768-XD and the 110 'F temperature referenced in 12179-NP(F) 10033 are correct as presented. The reference to a 190
'F operating temperature is relevent only to the analysis of the main header movements.
Significance level criteria does not apply as these are not discrepant conditions.
Attachments: NONE Response 2. ID: M3 - IRF - 02326.
Disposition:
NU has concluded that this issue repolied in DR-MP3-0383 has identified a NON - DISCREPANT condition. As an addendum to M3-IRF-00835 the following additional information is provided to clarify the islationship between the referen?.ed ACR M3-96-0887
( m ICAVP response M3-IRF-00835 ), and the operating temperatures used in calculations 12179-NP(B)-X1902 and i
12179-NP(F)-918-XD (issue 1 as outlined in DR-MP3-0383 and M3-IRF-00835 ).
I Adverse Condition Report (ACR) M3-96-0887 was written as a l
result of Engineering identifying a potentialloss of safety function for the Reactor Plant Component Cooling Water (CCP) i system.
Normal!y the CCP heat exchanger outlet temperature control valves control CCP temperature, if these control valves lose non-category I instrument air, the bypass valves fail close and the outlet valves fail full open. This would result in maximum l
CCP cooling. The worst case overcooling would occur when the plant is in an extended rhutdown (low CCP heat load) and service water (SWP) temperature is low (33'F) during winter conditions. During the design process, this failure was also considered for when the (SWP) inlet temperature was at it's high (75 'F) during the summer months. If the CCP outlet valve fails open, this would result in the highest SWP CCP Heat Exchanger outlet temperature of 125'F. Engineering Record Correspondence, ER-96-0326, Rev.1 ( attached ) documents the scope of work (stress re-analysis effort) resulting in part from j
the corrective action plan of ACR M3-96-0887. As a result of l
the ERC, the SWP SDP and associated calculations (12179-NP(B)-X1902 and 12179-NP(F)-918-XD) were revised to incorporate the results of the re-analysis effort.
Significance level criteria does not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that this issue reported in DR-MP3-00383 has identified a NON-DISCREPANT condition. As an addendum to M3-IRF-00835 the following additional information is provided to clarify the relationship between the referenced ACR M3-96-0887 (in ICAVP response M3-lRF-00835 ), and the operating temperatures used in calculations 12179-NP(B)-X1902 and 12179-NP(F)-918-XD (issue 1 as outlined in DR-MP3-0383 and Printed 5/15/98 9:16:48 AM Page 3 of 5
l N:rtherst Utilities ICAVP DR N2. DR-MP3-0383 Millstone Unit 3 Discrepancy Report l
l M3-!RF-00835 ):
l Adverse Condition Report (ACR) M3-96-0887 was written to identify the potential for the CCP heat exchanger outlet l
temperature control valves to fail full open resulting in maximum l
CCP cooling. As a result, when the (SWP) inlet temperature is at it's high (75 'F) during the summer months, the SWP CCP Heat Exchanger outlet temperature was determined to be 125'F. Engineering Record Correspondence ( ERC ), ER 0326, Rev.1, dated February 23,1997 (attached), documents the scope of work (stress re-analysis effort) associated with the corrective action plan of ACR M3-96-0887. As a result of the ERC, the SWP SDP and associated calculations (12179-NP(B).
X1902 and 12179-NP(F)-918-XD) were revised to incorporate the results of the re-analysis effort.
-Significance level criteria does not apply as this is not a discrepant condition.
Attachments:
ACR M3-96-0887 Engineering Record of Correspondence ER-96-0326 Rev 1 Previously identified by NU? O Yes fel No Non Discrepant Condition?@) Yes O No Resolution Pending?O Yes # No Resolution Unresolved?O Y..
@)No Review Acceptable Not Acceptable Needed Date p
VT Lead: Neri. Antnony A VT Mgr: schopfer, Don K IRc Chrnn: Singh, Anand K Date:
5/14/98 SL Comments: First Response ID: M3-IRF-00835 Cut off date for all design analysis was 5/27/97. The SDP l
revision was issued before the cut off date, all effected desi0n l
analysis should have been completed by this cut off date.
For issue 1: On review of ACR M3-96-0887 which was issued for loss of air to CCP heat exchanger could cause over cooling of some of components in the CCP system. Based on the review this ACR'S tracking assignment (96031067-15 ) which list affected calculation, did not provide any reference or Indication to revise these specific calculations 12179-NP(B)-1902 and 12179-NP(F)-918-XD. Hence response is not acceptable.This is a discrepant condition and significance level 3 applicabl L For issue 2 &3 response is acceptable.
Second Response ID: M3-IRF-02326 For remaining issue 1: NU's response indicates that the revised temperature and required reanalysis for the affected SWP piping Printed 5/15/969:16:48 AM Page 4 of 5 I
l
N:rthert Utilitie2 ICAVP DR N3. DR-MP3-0383 Millstone Unit 3 Discrepancy Report had been identified in ERC, ER-96-0326. Additionally, NU has indicated that the affected stress calculations and SDP were revised. (in the prior response, M3-IRF-00835, it was stated the
)
calculations were in progress) j Based on the identified ERC and NU's statement that the affected calculations are revised, the response for this issue is acceptable and the issues addressed by this DR are considered non discrepant conditions.
J l
}
l l
I Printed 5/15/98 9:16:49 AM Page 5 of 5 l
l N:rthert Utilities ICAVP DR No. DR-MP3-0428 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p
Discipline: Mechanical Design g
Discrepancy Type: Calculation System / Process: SWP NRC Significance level: 4 Date faxed to NU:
Date Published: 11/15/97 Discrepancy: The setpoint for (7) valves could not be verified in calculation SP-3SWP-29, Rev 0, CCN#1
==
Description:==
Calculation SP-3SWP-29, Rev 0, CCN#1, determines the control range for (8) valves: 3SWP*PV112A1,81, A2, B2 &
3SWP*PV113A1, B1, A2, B2; to be between 170 and 210 psig.The calculation references E&DCR N-ME-02985 and Vendor Manual OIM-144-003A as the basis for the setpoints.
E&DCR N-ME-02985 states that the (8) valves required replacement of the freon actuators because the wrong ones were supplied by the manufacturer. Per E&DCR N-ME-02985, the control range for the valves should be between 170 and 210 psig after modifications have been made 'o the actuators.
i E&DCR N-ME-02985 has been stamped " SUPERSEDED" by DCN DM3-S-1009-95 because the modifications had not yet been made to the actuators. DCN DM3-S-1009-95 has also been stamped " SUPERSEDED" and was replaced by DCN DM3-00-1500-96, which states that (1) flow regulating valve, 3SWP*PV113A1, was in fact modified by the valve manufacturer with the correct actuator. DCN DM3-00-1500-96 also states that DCN DM3-S-1009-95 incorrectly superseded E&DCR N-ME-02985 and therefore re-establishes E&DCR N-ME-02985 as the goveming document to determine the control range for the valves which have been modified with the correct actuators.
Based upon the information referenced in this set-point calculation, only (1) valve,3SWP*PV113A1, has been modified and therefore only this (1) valve has a control range of 170 - 210 psig. There is no referenced documentation to conclude that the modification has been made to the remaining (7) valves. If the modifications to the actuators have not been made per E&DCR N-ME-02985, then the control range has been incorrectly determined for the remaining (7) valves.
Review Valid invalid Needed Date initiator: Dionne. B. J.
O O
O 10/31/S7 VT Lead: Neri, Anthony A O
O O
1 /1/97 VT Mgr: Schopfer, Don K G
O O
1/S/97 1RC Chmn: singh, Anand K 9
0 0
11/11/S7 l
Date:
INVAUD:
Date: 5/14/98 RESOLUTION: FIRST RESPONSE:
Printed 5/15/96 9:17:11 AM Page 1 of 3 l
l
t Northert Utilities ICAVP DR No. DR-MP3-0428 Millstone Unit 3 Discrepancy Report l
Disposition:
l NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0428, does not represent a discrepant condition. The setpoint calculation was revised as a result of the PI 31 assessment of service water calculations. The correct setpoint for all the valves is as specified in CCN#1 to SP-3SWP-29, Rev 0, N-ME-02985 and the manufacturer's drawing 2178.430-144-043. As stated in DCN DM3-S-0414-96 (5/96), only the operator for 3SWP*PV113A1 has been replaced. Revisions / modifications to the other seven valves are included in the scope of DCN DM3-00-0790-97. 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-MP3-0428, does not represent a discrepant condition.
Revisions / modifications to the seven valves are included in the J
scope of DCN DM3-01-0790-97. Significance Level criteria do not apply here as this is not a discrepant condition.
SECOND RESPONSE:
Disposition:
NU has concluded that Discrepancy Report DR-MP3-0428 has identified a condition not previously discovered by f JU. GRITS is providing an incorrect status of E&DCR N-ME-0298s. The approved corrective action plan for CR M3-98-1915 corrects the status of the E&DCR in GRITS after startup.
)
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3 0428 has identified a condition not previously discovered by NU. GRITS is providing an incorrect status of E&DCR N-ME-02985. The approved corrective action plan for CR M3-98-1915 will correct the status for E&DCR N ME-02985 in GRITS after plant startup.
Previously identified by NU? O ves (9) No Non Discrepant Condition?O ves (9) No Resolution Pending?O vos @ No Resolution Unresolved?O vos @ No Review initiator: Dionne, B. J.
VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K
~
IRc Chmn: singh, Anand K Date:
5/14/98
(
sL Comrnents: FIRST RESPONSE:
E&DCR N-ME-02985 is stated as the correct reference for the setpoint basis, it was also stated in DCN DM3-00-1500-96 that Printed 5/15/98 9:17;11 AM Page 2 of 3
Northsast Utilitiss ICAVP DR No. DR-MP3-0428 Millstone Unit 3 Discrepancy Report E&DCR N-ME-02985 was incorrectly superseded. This document was superseded by NU document control and is still labeled as superseded in the GRITS system (as of 3/6/98). Thus, the basis document for the setpoint of these valves is still not a valid document.
Since the paperwork to correct the problem with the seven other valves was initiated to rectify the issue, the significance level can be reduced from level 3 to level 4, as it is still applicable.
SECOND RESPONSE:
No further comments.
Printed 5/15/98 9:17:12 AM Page 3 of 3
j N:rthert Utilities ICAVP DR N2. DR-MP3-0546 Millstone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED 1
Review Element: System Installation p
Discipline: Electrical Design Ow Discrepancy Type: Installation implementation g
System / Process: Rss NRC O ~ ='s level: 4 Date faxed to NU:
Date Published: 11/9/97 l
Discrepancy: Inadequate support of conduit
==
Description:==
Conduits 3CX014NH2 and 3CX014NH3 are installed with a span of approximately 9 feet between adjacent supports and 2-90 degree bends plus a 90-degree LB fitting. This is not in accordance with the criteria of standard support drawing BE-52AV, Rev. 4, which indicates maximum support spacing to be 8 feet and the maximum bends to be 1-90.
Review Valid invalid Needed Date initiator: Sarver, T. L.
8 O
O 1o/28/97 VT Lead: Neri, Anthony A B
O O
1o/27/97 VT Mgr: Schopfer, Don K 8
0 0
10/30/97 j
IRC Chmn: singh, Anand K O
O O
11/4S7 Date:
INVALID:
Date: 5/14/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0546, 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-l 20 criteria an# found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0495 has been written to develop and track resolution of this item per RP-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0546, 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 Pl-
)
20 criteria and found to have no operability or deportability i
concems and meets the Unit 3 deferral criteria. CR M3-98-0495 has been written to develop and track resolution of this item per RP-4, 1
i l
SECOND RESPONSE:
i NU has concluded that the issue reported in Discrepancy Report i
DR-MP3-0546 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 170010. It has been screened per attachment 11 of U3 PI 20 criteria and was found tc, have no operability or deportability concems and Printed 5/15/98 9:17.34 AM Page 1 of 2
I N:rthext Utilities ICAVP DR No. DR-MP3-0546 Millstone Unit 3 Discrepancy Report meets section 1.3.2.e of U3 Pl 20 deferral criteria.
Two Non-QA conduits,3CX014NH2 and 3CX014NH3 span approximately 9 feet. The 8 foot span criteria referenced is intended for seismically qualified conduits. The fact that these i
l two conduits exceed this span criteria is not an operability concern and the minor nature (less than one foot) indicates it is j
not a Seismic two-over-one (ll/l) concem. The number of 90 degree bends in a conduit run is also a requirement for QA conduits but not Non-QA conduits. This item is deferrable based on U3 PI 20 Section 1.3.2.e and civil design engineering determination that the installation is adequate. The corrective actions for CR M3-98-0495 will address this issue post startup.
Previously klentiged by NU? O Yes (9) No Non Discrepant Condition?U Yes
(#) No Resolution Pending?O vos @ No ResolutionUnresolved?O ves @ No Review Acceptable Not Acceptable Needed Date initiator: Klaic, N O
O O
5'1d'S8 VT Lead: Neri, Anthony A O
S14/98 VT Mgr: schopfer. Don K G
O Si e IRc Chmn: singh. Anand K O
O O
i Date:
5/14/98 I
sL Comments: The adequacy of conduit span has to be demonstrated prior to re-start.
SECOND RESPONSE:
S & L concurs with NU's resolution that the impact of the i
discrepancy is minor for Non-QA conduits.
l l'
t Printed S/15/98 9:17:34 AM Page 2 of 2 L_____-.___*. _ _ _ _ _
Northe:st Utilities ICAVP DR No. DR-MP3-0694 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design p
Discipline: Mechanical Design Om Discrepancy Type: Calculation g
System / Process: DGX NRc Significance level: 4 Date faxed to NU:
Date Published: 12/8/97 Discrepancy: Basis for Cale'.llations SP-EGO-10 and SP-EGO-11
==
Description:==
Calculations SP-3 EGO-10 (Rev. 0) and SP-3 EGO-11 (Rev. 0) determine the setpoint for relief valves 3 EGO *RV38A/B and 3 EGO *RV37A/B. The basis for both calculations is a Telecon between P. Naughton and G. Olson (Fairbanks & Morse) dated 10-26-82. This reference was not attached to either calculation.
The telecon was requested in RFI MP3-636/ item 3. According to MP3-lRF-0880, the requested item was not sent because it could not be identified in the Nuclear Document System. Since the referenced Telecon could not be found, the basis for these calculations cannot be verified.
Review Valid Invalid Needed Date initiator: Langel, D.
O O
O 1/ S'S7 VT Lead: Neri, Anthony A B
O O
11/24/97 VT Mgt: Schopfer, Don K G
O O
12/1/97 IRC Chmn: singh, Anand K G
O O
12/4/97 Date:
INVALID:
Date: 5/14/98
)
RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0694, 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 M3-98-0138 has been written to develop and track resolution of this item per R P-4.
==
Conclusion:==
NU has concluded that Discrepancy Report, DR-MP3-0694, 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 M3-98-0138 has been written to develop and track resolution of this item per RP-4.
Disposition to S&L Comment:
NU has concluded that the issue reported in DR-MP3-0694 has Pnnted 5/15/98 9.18 09 AM Page 1 of 3
N:rthe:st Utilities ICAVP DR N3. DR-MP3-0694 Millstone unit 3 Discrepancy Report 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 U3 PI-20 criteria and found to have no operability or deportability concems and meets Section 1.3.2d of U3 Pt 20 deferral criteria. The diesel generators and ancillary equipment such as engine driven lube oil pumps (P3A, P3B), rocker arm lube oil pumps (P2A, P28), and asmociated piping, valving (including pump discharge relief valves) and instrumentation were provided by the vendor as a package.
A review of SP-EGO-10 and SP EGO-11 reveals that the
" calculations" timply state that the valves will open to relieve pressure at the pressure specified in the telecon. There is no actual calculating done in SP EGO-10 and SP-EGO-11. The purpose of the calculations was to provide a document that contained the setpoints of valves 3 EGO *RV37A,3 EGO *RV378, 3 EGO'RV38A,3 EGO *RV388. This was necessary in order to enter the setpoints into the Millstone PMMS system.
Although the telecon is the basis for the calculation, it is not the basis for the setpoints of the relief valves. The vendor supplied the pumps and valves as part of the diesel generator package; therefore, the current relief valve setpoints are adequate because they were set by the vendor. There is no operability or l
deportability concems associated with a missing telecon. There is no affect on License or Design Basis. The corrective actions in Bin CR M3-98-0138 will correct this issue post-startup. The l
corrective action will be to reconstruct the telecon and record the information on an ERC so it is retrievable.
Conclusion to S&L Comment:
NU has concluded that the issue reported in DR-MP3-0694 has l
identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria I
specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concerns and meets Section 1.3.2d of U3 PI 20 deferral criteria. The corrective actions in Bin CR M3-98-0138 will reconstruct and document this information post-startup.
Previously identined by NU? O Yes 4) No Non Discrepant Condition?U Yes @ No Resolution Pending?O Yes (5) No Resolution Unresolved?O Yes @ No l
Review Acceptable Not Acceptable Needed Date Initiator: Wakeland, J. F.
VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date:
5/14/98 SL Comments:
FIRST RESPONSE:
Printed 5/15/96 9:18:1o AM Page 2 of 3
N:rtheart Utilities ICAVP DR N2. DR-MP3-0694 Millstone Unit 3 Discrepancy Report l
i The telecon is the basis for the relief valve setpoints. Justification that the current setpoints are adequate is needed in order to verify deferralis acceptable.
Justification for the setpoints was not provided.
SECOND RESPONSE:
After further review, Sargent & Lundy concludes that the missing vendor teleconference memo is a documentation deficiency and that there is not implication that the tube oil pump relief valve setpoints are incorrect. These relief valves are part of a vendor-supplied package unit. The vendor originally set these relief valves to lift at the same pressures which were later specified in SP-3 EGO-11, SP-3 EGO-12, and in the missing vendor teleconference memo. Sargent & Lundy agrees that CR M3 0138 will find and replace the missing design documentation for the relief valve setpoints and that this task may be deferred until after Unit 3 restart.
Printed 5/15/98 9:18:10 AM Page 3 of 3~
u______________
Northea:t Utilities ICAVP DR N. DR-MP3-0908 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue l
Diecipline: Mechanical Design l
Discrepancy Type: component Data g
SystenVProcess: DGX NRC Significance level: 4 Date faxed to NU:
Date Published: 1/17/98 Discrepancy: Discrepancies in the EGA System Component Data i
==
Description:==
Review of the EGA system components resulted in following discrepancies:
- 1. 3EGA*FLT3A,B,C,D, Engine Mounted Air Filters PDDS identifies these Specification 2447.300-241 filters as QA Cat. 2. Per Design Basis Summary Document " Emergency Diese! Engine",3DBS-EDG-001, Rev.1, (paragraphs 12.1.1 and 12.4.1) these filters should be ASME 111, Class 3, and Seismic Category 1.
- 2. 3EGA* HOSE 1 AA/B,2A/B, l
PDDS indicates that these hoses are QA Cat.1 and were purchased per Specification 2472.800-653. Review of the Specification could not verify this information. No technical documentation was identified for these hoses.
- 3. 3EGA-RV20A1/2,B1/2, Air Compressor Relief Valve l
Per P&lD's EM-116B-25 and EM-116D-5 the valve is set at 500 J
l psig. PMMS shows that the set point is 450 psig.
- 4. 3EGA*TK3A/B, Air Tank l
No technical documentation (specification, drawing, calculation) was identified for this tank in the vendor technical manual OlM-i 241 or elsewhere.
t
- 5. 3EGA*V1,V2,V27,V28,V53,V54, 3/4" Globe Valves Per PDDS these globe valve were purchased from Dresser per Specification 2362.150-162. The valves are ASME 111, Class 3.
PMMS states that the valves are seismically designed.
However, no seismic qualification requirement could be found in the Purchase Specification. No documentation was found to verify that the valves are seismically qualified.
- 6. 3EGA*V20,V44, 2" Globe Valves Per PDDS these valves were procured per Specification Printed 5/15/98 9:19:27 AM iage of 5 L______________________
l Norther _t Utilitie3 ICAVP DR ND. DR-MP3-0908 l
Millstone Unit 3 Discrepancy Report found in the vendor technical manual OlM-241, or elsewhere, to verify PDDS/PMMS data. Also, PDDS and PMMS describe i
valve 3EGA*V20 as a plug valve, while the P&lD EM-116B-25 shows it as a globe valve.
- 7. 3EGA*V23,V49, Check Valve in Shutdown Air Line Per P&lD's EM-116B-25 and EM-116D-5 this check valve is in 3/8"line. It is assumed that the valve is the same size. Valve size could nct be found in either PDDS or PMMS. Per PDDS the valve was procured per Specification 2447.300-241. However, no data for a 3/8" check valve were found in the vendor technical manual OIM-241, Chapter 8, Section 7, Starting and Control Air Systems, or elsewhere.
- 8. 3EGA*V5,V13,V31,V38, 3/4" Globe Valve at Air Receiver Tank Inlet Per PDDS this valve was procured per Specification 2447.300-241. However, no data were found this valve in the vendor technical manual OlM-241, Chapter 8, Section 7, Starting and Control Air Systems, or elsewhere.
- 9. 3EGA*V6,V14,V32,V40,V981,V982,V994,V995,1/2" Plug Valve Per P&lD's EM-116B-25 and EM-116D-5 each of these valves is in a 1/2" lines. Per PMMS, however, only valve V6 is 1/2" valve; the rest are 3/4" valves. Since the vendor technical manual OlM-241 does not reference equipment numbers on provided information, no positive identification of appropriate Colt drawing for valve specifications could be made in order to verify valve size.
- 10. 3EGA*V973, V972, Generator B Air Receiver Tank Drain Valve Per P&lD EM-116D-5 and PMMS these valves are plug valves.
PDDS, however, describes these valves as gate valves.
- 11. 3EGA*V979,V980,V992,V993, Strainer Drain Plug Valves PMMS shows these valves to be 3/4". However, Specification 2447.300-241, page 1 17 requires that the drain connection of l
the Wye Strainer be provided with 1/2" ASME lit, Class 3 valves. Also, drawing 2447.300-241-008, Starting Air and Control Air Schematic shows the valves 1/2".
Northeast Utilities ICAVP DR No. DR-MP3-0908 l
l Millstone Unit 3 Discrepancy Report Per P&lD's Em-116B-25 and EM-116D-5 these valves are in 3/4" lines, and are therefore presumed to be the same size.
l However, PDDS shows them to be 1/2" valves.
- 13. 3EGA*V968,V969. Drain Valve in Diesel Generator i
Shutdown Air Line Per P&lD's EM-1168-25 and EM-116D-5 these valves are in 1/4" drain lines, therefore presumed 1/4" valves. PMMS shows them 3/4" valves, while PDDS shows V969 as 1/4" valve.
i 1
14, 3EGA*V970,V971, Air Tank Vent Valve Per P&lD's EM-116B-25 and EM-116D-5 these plug valves are in 1 1/2" vent lines, and therefore presumed 1 1/2" plug valves.
PDDS has no information on valve size, however, PMMS shows them to be 3/4" valves. PDDS describes valve V971 as gate valve, and valve V970 as a plug valve.
- 15. 3EGA-C1A/B,C2A/B, Air Compressor Air Compressor equipment number is 3EGA-C1 A,C2A,C1B,C2B, per P&lD's and per PDDS database, The component drawing no. 2447.300-241-027D, however, designates this component with an equipment mark number 3EGA-CA1,CA2,CB1,CB2.
i 16, 3EGA*EFV29A, This valve was found entered in both, the PDDS and PMMS database. The valve however, could not be found on the system P&lD's EM-116B-25.
Review Valid invalid Needed Date initiator: Obersnel.Bojan.
B 0
0 12/30/97 VT Lead: Neri, Anthony A B
O O
12'3 '97 VT Mgr: schopfer, Don K O
O O
sitzse IRC Chmn: Singh, Anand K O
O O
1'13/98 Date:
INVALID:
l Date: 5/14/98 RESOLUTION: Disposition:
NU has concluded that this issue (s) repor1ed in DR-MP3-0908 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Items 1,2, 3,7,9,10,11, 12,13 & 14 are discrepancies which meet the criteria specified in NRC letters B16901 and 17010. They have been screened per attachment 11 of U3 Pl-20 criteria and found to have no operability or deportability concems and meet section 1.3.2.e of U3 PI 20 deferral criteria.
Printed 5/15/98 9.1927 AM Page 3 of s 1
Northeast Utilities ICAVP DR No. DR-MP3-0908 Millstone Unit 3 Discrepancy Report Condition Report M3-98-2311 will be closed out to Bin CR M3 0217. The corrective actions for CR M3-98-0217 will ensure the following are completed post startup:
- 1) Revise 3DBS-EDG-001 and PDDS to correctly identify the l
classificai'on of 3EGA*FLT3A, B, C, and D Engine mounted air filters.
- 2) Hoses 3EGA* HOSE 1 A/2,2A/B Titeflex Corp. NO. N-2572 were originally identified as 3EGA*EJ1 A/B,2A/B as indicated on vendor drawing 2472.800-653-035 REF.: E&DCR F-P 16581.
This vendor drawing will be updated to revise the 3EGA*EJ1 A/B, 2A/B designation to 3EGA* HOSE 1 A/2,2A/B.
- 3) DCN DM3-S-1269-93 revised the set point from 450 to 500 psig. PMMS will be revised to reflect a set point of 500 psig for 3EGA-RV20A1/2, B1/2.
- 7) Valves 3EGA*V23 & V49 are 1/4" valves Vendor No.
11907303. This Vendor No. and drawing No. N81-180 exist in Vendor Manual 25212-241-001 Rev.1, Vol. 2, Section B6. These valves have 1/4" NPT X 3/8" tube adapters installed on both ends which should be depicted on P&lD EM-116B AND EM-116D. PMMS ar,d PDDS should be revised to reflect the 1/4" size.
- 9) PMMS will be updated to reflect the correct 1/2" size of valves 3EGA*V6, V14, V32, V40, V981, V982, V994 & V995.
- 10) PDDS will be revised to depict valves 3EGA*V973 & V972 as plug valves.
- 11) PMMS will be revised to correct the size of valves 3EGA-V979, V980, V992 & V993 to 1/2".
- 12) Valves 3EGA-V955, V958 & V961 are 3/4" valves in agreement with piping isometrics CP-360255 & CP-360261.
PDDS will be revised to reflect the 3/4" size.
- 13) PMMS, PDDS and PalD EM116B & D will be revised to reflect the correct 1/2" size of 3EGA*V968 & V969.
- 14) PMMS will be revised to depict the valves as 1/2" and PDDS will be revised to depict 3EGA*V971 as a plug valve.
Nu has concluded that items 4,5,6,8,15 & 16 do not represent discrepant conditions. Justification is as follows:
- 4) The Vendor Technical Manual 25212-241-001 Rev.1, Vol 2, Section 86 and Vol.1 Section A5 PO27-055 cor tains a vendor drawing of 3EGA*TK3A/B. In addition they are depicted on drawing 2447.300-241-008.
- 5) Tne valve specification technical requirements under the section titled " General Design", requires that the valves be constructed to the rules of Section ill, except that the design shall be modified as required by Code Case 1635-1, and the stamping and Manufacturer's Data Report shall indicate the case number. Code case 1635-1 does not require the manufacture to provide a Design Report or Stress Report qualifying the valves to Upset, Emergency and Faulted Operating Conditions.
- 6) Valves 3EGA*V20 & V44 are tagged with vendor No.
11907299. this vendor No. exists in vendor manual 25212-241-001 rev.1, vol. 2, section B6.
P&lD EM-1168 was revised by DCN DM3-00-1004-97 to depict V20 as a plug valve.
- 8) This is not discrepant. Valves 3EGA*VS, V13, V31 & V38 are identified on pipina isometrics CP 360255 & CP-360261 with Printed 5/15/98 9:19:28 AM Page 4 of 5
N:rthert Utiliti;s ICAVP DR N2. DR-MP3-0908 Millstone Unit 3 Discrepancy Report unique identification mark numbers. The reference in PDDS to specification 241 provides traceability to the Diesel Specification.
l
- 15) Vendor drawing 2447.300-241-027 Rev. E presently depicts i
the correct equipment identification mark numbers as 3EGA-l C1 A/B, C2A/B.
- 16) Valve 3EGA*EFV29A does not presently exist in PDDS or l
PMMS. This valve was deleted by DCN DM3-00-1215-96. This l
s a duplicate item from DR-MP3-0821 NO. 3.
l i
l Significance Level Criteria is not applicable to these items as they are not discrepant conditions.
==
Conclusion:==
NU has concluded that this issue (s) reported in DR-MP3-0908 l
has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Items 1,2,3,7,9,10,11, 12,13 & 14 are discrepancies which meet the criteria specified in NRC letters B16901 and 17010. They have been screened per attachment 11 of U3 Pl-20 criteria and found to have no operability or deportability concems and meet section 1.3.2.e of U3 Pl 20 deferral criteria. Condition Report M3-98-2311 will be l
closed out to Bin CR M3-98-0217. The corrective actions for CR M3-98-0217 will correct the PDDS, PMMS and drawing discrepancies post startup.
I Nu has concluded that items 4,5,6,8,15 & 16 do not represent discrepant conditions. Justification for each is provided by referencing the appropriate vendor documentation or drawings to resolve each item. Significance Level Criteria is not applicable to these items as they are not discrepant conditions.
Previously identified by NU? O Yes @ No Non Discrepant Condition?U Yes @ No ResolutionPending?O Yes @ No no.osution unr..oived?O Yes @ No Review r
initiator: Obersnel,Bojan.
VT Lead: Nerl, Anthony A VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K l
Date:
5/14/98 sL comments: S&L agrees with the NU disposition that the determination of required corrective action for the items of this DR can be deferred as recommended in the CR M3-98-2311. S&L also accepts suggested item by item resolution with the following exception:
> Re item 4, S&L agrees that the Air Tank 3EGA*TK3A/B is depicted on the starting air & control air schematic 2447.300-241-008. However, S&L was unable to locate a tank vendor drawing in the Vendor Technical Manual OIM-241-001 A, revision (or insert) 1 AW, dated 6/20/97.
Printed 5/15/98 9.1928 AM Page 5 of 5
Northe::t Utilities ICAVP DR N2. DR-MP3-0912 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Modircation Design p
Discipline: Other Om Discrepancy Type: Component Data g
System / Process: N/A
~
NRC Significance level: NA Date faxed to NU:
Date Published: 1/18/98 Discrepancy: Missing justification for fire seal design
==
Description:==
Engineering has developed and issued seal types when seal designs developed by Transco Products Inc. (TCl) did not fit the conditions. The report " Fire Stops and Seals, Historical Information Report, Millstone Unit 3" dated 12-31-87 states that
" Testing of all TPI fire seals was done in accordance with ANI, IEEE-634 and ASME-E119 standards by independent labs." It continues to state that "All fire seals designed by engineeritig use the same material and thickness as TPl but do not have individual fire tests."
The discrepancy is that the information could not be located which. supports the use of the ' engineering designed' seals in the absence of test data.
Review Valid invalid Needed Date initiator: Rich, J. M.
O O
O 1/7/98 VT Lead: Neri, Anthony A O
O O
1/7/98 VT Mgr: schopfer, Don K O
O O
1/12/98 1RC Chmn: singh. Anand K B
O O
1/15/S8 Date:
INVAllD:
Date: 5/14/98 RESOLUTION: FIRST RESPONSE NU has concluded that the issue reported in DR-MP3-0912 does not represent a discrepant condition. Every seal installed,
)
whether Fire Stop, Radiation, or Pressure Seal is installed in accordance with Specification 2400.000.680 and either Engineering and Design Coordination Reports (E&DCRs) or Design Change Notices (DCNs) generated by Design Engineering. Significance Level criteria do not apply as this is not a discrepant condition. The seals that were developed for unique applications were evaluated based on their similarity to
" standard" designs.
]
NU Drawings 25212-29680 Shs 0001 through 0041 represent Transco Seal Designs. NU Drawing No. 25212-29680 Sh. 0042 of Specification 2400.000-680 provides Engineered Seal Designs for pressure, fire, radiation, or in combination to meet barrier requirements. This drawing includes grout (cementitious) and water curtain cable tray internal foam seals. This drawing is developed from Vendor Information Requests, Engineering and Design Coordination Reports, and Design Change Notices.
These documents are included as references on the drawing.
(
Printed 5/15/98 9:19.43 AM Page 1 of 7
N:rthe:st Utilities ICAVP DR N3. DR-MP3-0912 Millstone Unit 3 Discrepancy Report For each seal installation, the level of evaluation varies with the l
degree of deviation from the tested configuration and seal usage.
l Following is a description of some of the details that were l
developed for these unique applications.
l Referring to Drawing 25212-29680-00042:
Examples of engineered fire seals include Detail CT which was used for fire stop seals at the Auxiliary Building Water Curtain, Details G1 and G2, Detail F3, Details F2A, F28, F2C, Detail F6, Detail SBTHIM, and Detail E-14.
Seal Detail E-14 was a method of sealing blank openings within spare blockout openings using Transbond 150M material.
Transbond is a cementitious material similar to grout. This is identical to the E-8 and E-9 Details from drawing 12179-2400-000-008 (NU Drawing No. 25212-29680 Sh. 008) with the exception that the penetrant item was added because the seal was tested in a configuration with penetrants rather than a spare opening. The two specific openings where the seal design was applied are penetrations EWG09 and EWG10 of Map CWOO6.
They are dimensionally 15 inches by 6 inches and 12 inches by 18 inches, respectively. The seal depth was 12 inches, which is 4 inches greater than used in the applicable fire testing for details E-8 and E-9. The use of 1/8 inch and 3/16 inch threaded through rods were evaluated as acceptable for this seal design as well as for Seal Details E-8, and E-9 via VIR V-4068.
Seal Detail F6 was a method of sealing blockout openings with aluminum conduit and cable trays in penetrations SBEF26 of Map SB017 (See VIR V-4345) and SBEF126 of Map SB059 (See VIR V4344). The openings were sealed with an 8 inch depth of Transco TCO-002 Medium Density Silicone Elastomer (Dow Coming Sylgard 179 A & B Silicone Elastomer). This is the same material depth as used for Transco fire seal details E-16 of Map Drawing No. 12179-000-680-020 and details E 16A, B, C, D, E of Map Drawing No. 12179-000-680-31. These designs are supported by Transco Fire Tests TR-158 and TR-169. The only differences between Detail F6 and " -16E are:
d
- 1) the top two inches of silicone elastomer for the F-6 detail installed within steel angle framing on the top side of the barrier as opposed to no steel angle framing for the Transco E-16E detail and
- 2) the less than 8 inch barrier is not poured over sheet metal decking.
This detail could have been evaluated as an E-16 detall type.
l There is essentially no difference. Typical industry elastomer j
seal designs consist of 6 inches Dow Coming Sylgard 170 A & B j
silicone elastomer with damming optiortal or 5 inches of i
elastomer with permanent damming. The minimum 8" design
'l depth is conservative.
i Seal Details F2A. F2B, and F2C are the same details as Detail E-i Pnnted 5/15/98 9:19:44 AM Page 2 of 7
l
\\
N:rthr;t Utilities ICAVP DR No. DR-MP3-0912 Millstone Unit 3 Discrepancy P eport 6, E 16. and E-10, respectively. The only difference is an j
additional 1/4 inch thick layer of GE RTV Silicone (7403) or DC 96-081 adhesive sealant which is applied to the surface of the F2A, F2B and F2C details for hydrostatic pressure requirements l
(refer to E&DCRs F-E-41848 and F E-41408).
I Seal Details G1 and G2 are grout engineered seal designs i
installed in accordance with E&DCR F S-44136. These seal l
designs are supported by Construction Technology Laboratories l
Test Plan for Fire and Hose Stream Tests of Penetration Seals i
Made With Embeco 636 and Masterflow 713 Grout (Document ID #1382E/CR-15773-4324), dated August 1985.
)
Detail F3 adds a 1/4 inch thick layer of GE RTV Silicone (7403)
I l
or DC 96-081 adhesive sealant applied to the surface of 24 inch l
l thick silicone RTV foam seals for pressure resistance. The minimum 24 inch seal depth exceeds the 12 inch minimum
{
depth for detail E-18 of Drawing No. 12179-2400.000-880-023 (NU Drawing No. 25212-29680 Sh. 0023). All other parameters are the same.
\\
Engineering & Design Coordination Report (E&DCR) N-CS-03368 provides details (i.e., Detail CT) for seals installed intemal
)
of cable trays that penetrate through the Auxiliary Building 24' elevation Charging Pump Water Curtain. This configuration uses two 6 inch minimum depth silicone foam seals in series separated by a spacing protected by the in-line sprinklers.
Supporting information is provided in E&DCR N-CS-03529. The basic difference between this seal and a solid 12 inch depth j
silicone RTV foam seat installed within a barrier is the cooling provided by the sprinklers as opposed to heat loss to the surrounding concrete substrate.
For silicone RTV foarn intemal conduit seals installed extemat of the barrier, Engineering & Design Coordination Report N-CS-l 03240 allows installing a minimum depth of 12 inches of silicone RTV foam within the pull box when construction does not allow i
installation within the conduit due to cable.
Detail SBTHIM is a ceramic blanket & board fire seal for a spare opening in a non-TRM fire boundary (for fire protection purposes only). This sealis installed at penetration SBMF124 of Map SB052.
Because of the conservative seal design depths, these earlier i
Engineered designs have not been formally re-evaluated by l
means of a current Engineering Evaluation.
l Where non-rated assemblies have been installed in fire barriers l
required to be maintained in accordance with the MP3 Fire Protection Technical Requirements Manual 3TRM-7.4, Section H, evaluations have been submitted and transmitted to the NRC as deviations. Refer to Licensing Letter B11534 and B11658 for non-rated fiberglass drain lines in the ESF Building and Intake Structure fire barriers.
Printed 5/15/96 9:19:44 AM Page 3 of 7 L_____-___
Northert Utilities ICAVP DR No. DR-MP3-0912 Millstone Unit 3 Discrepancy Report Additional fire testing has been obtained to support lesser seal design depths. This testing includes but is not limited to the following:
- 1) ASTM E814-88 & IEEE 634-1978 Three-Hour Fire Test of Multiple Penetration and Penetration Seal Configuration for Brand industrial Services, Inc. and Public Service Electric Gas Company Final Report SWRI Project No. 01-3105-602 (PSE&G Test No.89-006).
- 2) PLC Conduit Fire Protection Research Program Final Report, i
l dated 6/1/87.
- 3) Promatec Final Report CTP 1001 A, Three Hour Fire Qualification Test,10" and 6" depth silicone RTV foam, dated July 25,1980.
Note: While these tests may support lessor seal depths, there has been no changes to the Transco seal details or the NNECo Engineered seal details to decrease material depths. These fire tetts are typically used for supporting operability determinations reg.irding fire barriers for seals found in a degraded state.
Sincs this is not a discrepant condition, the Significance Level 3 does '10t apply.
Additianal Generic Engineering Evaluations have been prepared for addressing seal parameters.
{
- 1) Fire Protection Engineering Evaluation No.136, Use of DC 96-081 Adhesive Sealant for Silicone RTV Foam Edge Separation.
- 2) M3-EV-970103 Penetration Fire Stops and Seals in Openings with Piping Penetrants Larger Than Used in Qualified Fire Tests.
SECOND RESPONSE Disposition: NU has concluded that the issues reported in DR-MP3-0912 nave identified NON-DISCREPANT conditions. In addition, the follow-up issues reported in DR-MP3-0912 have identified NON-D:SCREPANT conditions. Generic Engineering Evaluation M3-EV-970103, Rev. O " Penetration Fire Stops and Seals in Openings with Piping Penetrants Larger Than Used in Qualified Fire Tests", was prepared to assess whether penetration seal designs will fulfill functional requirements to maintzin a three hour fire rating when installed in openings with carbon or stainless piping penetrants larger than those used in the qualification fire test assemblies.
Item 1.
Based on seal application, material type, and barrier configuration. the penetration se, critical desian_ parameters Printed 5/15/98 9:19:44 AM Page 4 of 7 l
N:rthe:st Utilities ICAVP DR N1 DR-MP3-0912 Millstone Unit 3 Discrepancy Report may vary. Evaluation M3-EV-970103 addresses a concem with regards to a design parameter consideration for maximum size of piping penetrants in qualified three hour rated fire stops, to establish a basis for the use of selected seal designs in openings which contain pipe penetrants larger than those in the tested configuration. The evaluation does not assume that field conditions are less demanding. What is stated in the evaluation is that the larger penetrants will remove heat more efficiently when subjected to an equivalent exposure. Fire loadings in the field are based on the BTUs associated with a known quantity of combustibles, as opposed to test fumace assemblies which base heat input on the amount of BTUs needed to maintain fumace temperature. The quantity of BTUs required for the test apparatus changes, as necessary, to maintain the temperature profile of the standard ASTM E-119 time-temperature curve and is, in part, dependent on the amount of heat removed by the penetrants. To maintain the same endpoint temperature on the seal's unaffected side, larger penetrants, which due to their size remave a greater amount of heat, require more BTUs to elevate the temperature of the penetrant in the test fumace, in addition, in the field heat is expected to be lost to the fluid medium in the pipe. This is not the case in test configurations, which typically have the piping sleeves capped to prevent flame-through via the penetrant during the fire test exposure.
Therefore, endpoint temperatures of larger pipe penetrations in field applications are expected to be less than those recorded for the test fire exposure since it takes much more BTUs to raise their unexposed side end point temperature and even more BTUs to maintain higher temperatures for larger penetrants because heat is more efficiently removed by fluid flow.
The use of the thermocouple readings for the fire test using SE-i Foam was used as an example to show that penetrant size did not cause significant impact to unexposed side endpoint temperature when subjected to an ASTM E-119 three-hour exposure. For any given material, the seal depth is selected, in part, based on the materials thermal conductivity, which governs the heat transmission through the seat, and therefore the surface temperature of the unexposed ':ide of the seal, and its' resistance to the erosive effects of fire exposure. Based on the design of the seal, the relationship between pipe size and endpoint temperatures is expected to hold regardless of the material, as long as the minimum required material depth is maintained. This example was used for comparison of end point temperature of different pipe sizes in configurations using the same seal material and depth, and not for any specific qualification of the examples used.
The above considerations establish that the larger penetrants do not adversely affect the seal's qualification.
Item 2.
The E&DCR was the process implemented by Stone & Webster Engineering at the time of construction to provide engineering direction to the field. The ties between the seal designs, fire tests, and other related oocuments are through Specification 2400.000-680 and the fire testino that supported the Transco Printed 5/15/98 9:19 44 AM Page s of 7 l
l L____----_--__.
N rtherct Utilities ICAVP DR N2. DR-MP3-0912 Millstone Unit 3 Discrepancy Report Products Inc. (TPI) penetration fire seals.
NU Drawings 25212-29680 Shs 0001 through 0041 represent Transco Seal Designs. NU Drawing No. 25212 29680 Sh. 0042 of Specification 2400.000-680 provides Engineered Seal Designs for pressure, fire, radiation, or in combination to meet barrier requirements. This drawing is developed from Vendor information Requests, Engineering and Design Coordination Reports, and Design Change Notices. These documents are included as references on the drawing. For each seal installation, the level of evaluation varies with the degree of deviation from the tested configuration and seal usage.
A review of the Transco seal designs ard associated fire tests shows that the minimum design depths for the electrical opening seals in question, for medium density silicone elastomer and high density silicone elastomer penetration fire seals, is 8 inches and 12 inches, respectively. The Engineer developing the E&DCR would have provided a seal with a design depth that corresponds to the minimum design depth of the material being used, which is evident by the choice of material design depths in the two E&DCRs.
The standards and procedures used at the time of field installation dictated that unless the seal detail assigned to a given penetration varied from existing test data, the E&DCR process would not have required additional design justification in support of the detail provided to the field via the design document. The choice to identify these three engineering seals by their own seal detail design identification as opposed to the equivalent TPI seal detail design tends to be confusing, since they are the same detail.
Seal Details F2A, F2B, and F2C are the same details as Detail E6, E16, and E10, respectively. The only difference is 3/8 inch of GE RTV Silicone (7403) adhesive sealant applied to the interface of the sealant to penetrant surface shown on the details E6 and E16. Details ES, E10, F2A. F2B & F2C all have 1/4" silicone adhesive applied to the entire sealing surface, overlapping the adhesive onto any penetrating element and substrate. This was to provide an additional moisture barrier where the seal also performed a water barrier fundion.
E&DCR F-E-41848 specifies Details F2B cnd F2C. These are the same as Details E16 and E10, shown on drawings 29680-00020, Rev. 7 and 29860-00010, Rev. 6 respectively. Detail E16 was qualified by Transco fire tests TR-158 and TR-169. E-10 was qualified by Transco fire tests TR-121 TR-138, j
TR-151, and TR-168.
E&DCR F-E-41408 specifies Detail F2A. This is the same as Detail E6, shown on Drawing 29860-00007, Rev. 8. Detail E6 was qualified by Transco fire test TR-168.
Reconciliation of these details is provided in Specification SP-l Pnnted 5/15/98 9.19 44 AM Page 6 of 7 L________.____________
Northeast Utilities ICAVP DR N2. DR-MP3-0912 Millstone Unit 3 Discrepancy Report GD-001, Rev. O," Standard Specification for Millstone Unit 3 Electrical and Mechanical Penetration Fire Stops and Seals."
The Cross-Reference and Matrix, Attachment No.1, identifies, on page 8, that Seal Details F2B and F2C are the same as Seal Details E16 and E10, respectively. Page 9 identifies Seal Detail F2A the same as Seal Detail E6.
Significance Level criteria do not apply as this is not a discrepant condition.
Previously identified by NU7 O ves
(#1 No Non Discrepant Condition?f9) Yes O No Resolution Pending7O ve.
@ No Resolution Unresolved 7O v. Col No Review Acceptable Not Acceptable Needed Date Initiator: Rich. J. M.
VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K IRc Chmn: Singh, Anand K Date:
5/8/98 l
sL Comments: FIRST RESPONSE l
Additional support is required for the provided resolution.
l l
- 1. The report titled " Penetration Fire Stops & Seals in Openings With Piping Penetrants Larger Than Used in Qualification Fire Seals" justifies the conclusions, in part, by assuming that the field conditions are less demanding than the test conditions, and that data from penetrations which use materials other than those used at MP3 is applicable to the MP3 designs. These assumptions should have technical support to justify their application to the design modifications.
- 2. E&DCR F-E-41408 F.O. and E&DCR F-E-41848 do not appear to provide a technical justification for deviating form existing designs. The original issue, that justification was not clearly documented, has, thus, not been fully addressed for these E&DCRs.
SECOND RESPONSE The second response is acceptable and there are no comments.
i Pnnted 5/15/98 9:19:44 AM Page 7 of 7 l
w_-_____-_______-_____-
i N:rthe st Utilities ICAVP DR N2. DR-MP3-0942 Millstone Unit 3 Discrepancy Report Review Group: configuration DR RESOLUTION ACCEPTED I
Review Element: system Installation p
Discipline: Electrical Design Om Discrepancy Type: Drawing g
l System / Process: DGX NRC Significance level: 4 Date faxed to NU:
Date Publisi.ed: 1/18/98 Discrepancy: Differences between approved design documents and installed tray supports
==
Description:==
The following items were noted in the review of documentation for the walkdown of tray supports as part of the systems walkdowns.
- 1. CCD F-E-06385 adds conduit to a tray support type C220 but is unclear which support is actually modified. (this was discovered in the review of support C220-078 shown on drawing E-34KC, Rev. 3, which was included as part of the detail review sample.). There is no key plan in this FE to show locations of any supports. The document also states that the proposed conduit addition to the tray support is not apprevod as of the document date it also states approval of thu sigports will come later. The approval status of the proposed dcagn and its applicability is indeterminate based on these documents and the open change documents for the drawings.
- 2. CCD F-E-41069 adds conduit supports to tray hangers C-052 and C-057 and lists arawing EE-34KD Rev. 4 as an affected document. Grits also lists F-E-41069 as an open (unincorporated) document against drawing EE-34KD Rev. 4.
However, tray hangers types C-052 and C-057 are on drawing EE-34LK Rev. 5. Grits does not list F-E-41069 as an open l
document against drawing EE-34LK Rev. 5.
- 3. The following FEs add conduit to existing tray hangers: F-E-16414, F-E-25718, F-E 16574,F-E-35143, F-E-35338, and F-E-35542. Tray hanger C166A-153 is impacted by these additions.
This hanger is on detail drawing EE-34LJ Rev. 7. However, none of the F-E accuments listed show drawing EE-34LJ Rev. 7 as an affected document and Grits does not show any of the listed F-E documents as open against drawing EE-34LJ Rev. 7.
- 4. CCD F E-35143 shows ten 2", one 3", five 4" and two 5" diameter conduits attached to tray hangers C166A-153, C011-155, and C011-156 (Reference Drawing EE-34LJ - Rev. 7).
However, it does not show the actual orientation of the conduit by size on the tray hangers. The positioning and therefore load distribution in unknown.
- 5. Field walkdown of sample support C228-156 (Reference
)
Drawing EE-34KD - Rev. 4) found the following attachments with no change control documentation providing description or approval of such attachments:
- Twelve-inch cantilever "W" with item "X" spanning south at nnnmvimnte plevntinn 47.10 M" Pr!nted 5/15/98 9:20:07 AM Page 1 of 5
N:rthe:ct Utilities ICAVP DR N:. DR-MP3-0942 Millstone Unit 3 Discrepancy Report i
- Four 12" cantilever "W" struts with item "X" strut spanning
]
north (four outer cable supports) at approximate elevation 38'-0",
j 39'-10", 41'-9" and 44'-0"
-- Item "W" strut spans south at approximate elevation 43'-0" supporting two 3" conduits (3CX490NB, 3CX490NC).
-- Item "AU" strut spans south at approximate elevation 42'-9" supporting three 2" conduits.
- Item "W" strut spans south at approximate elevation 41'-9" supporting one 2" conduit.
-- Three-inch conduit 3CX4170B runs north / south at approximate elevation 38'-6" with Sil-temp when crossing trays 3TC427P and 3TC450P
- 6. Field walkdown of sample support C258-216 (Reference Drawing) EE-34KH - Rev. 2) found the following attachment with no installation documentation. Twelve-inch cantilever "W" strut type with item "X" strut types spans east at approximate elevation 39' 0".
- 7. Field walkdown of sample support C274-268 (reference Drawing EE-34KK - Rev. 3) found the following attachments with no installation documentation:
Five cable support type item "X" struts span north at approximate elevation 35'-9", 37'-2", 39'-9", 41'-0" and 42'-6" Item "X" strut spans north at approximate elevation 42'-6".
Two item "X" struts span south at approximate elevation 39'-0" and 40'-6".
Three dummy members - item "W"- are installed between the vertical legs at approximate elevation 39'-10",41'-2" and 42'-
6".
- 8. Field walkdown of sample support C279-281 (Reference Drawing EE-34KK - Rev. 3) found the bottom horizontal member has been removed and the verticallegs trimmed to suit. No documentation has been found to authorize this change.
- 9. Field walkdown of sample support C292-237 (Reference Drawing EE-34KM - Rev. 4) found one 5" conduit (3CC516NJ) and one 4" conduit (3CC516NG) supported from horizontal member at approximate elevation 30'-6'. No documentation has been found to install these conduits. F-E-15020 authorizes two 4" and one 3" conduit to be supported (CB-983) from the bottom horizontal member. However, these three conduits were not found during the walkdown.
l
- 10. Field walkdown of sample support C305-121 (Reference Drawing EE-34KP - Rev. 4) found the following attachments with no installation documentation:
Pnnted 5/15/98 9:20 07 AM Page 2 of 5 L ___________ _ _ _ _
Northe:st Utilities ICAVP DR N;. DR-MP3-0942 Millstone Unit 3 Discrepancy Report Cable support cantilever item "W" strut with item "X" strut spanning east at approximate elevation 41'-6" Six item "W" cantilevers on north leg -- five have one item "X" strut spanning either east or west. Top cantilever has two item "X" struts, one spanning east and one spanning west. Item "W" lengths vary from 6" to 12".
- 11. Field walkdown of sample support C309-104 (Reference Drawing EE-34KP - Rev. 4) found the following attachments with no installation documentation: Six 9" cantilever item "W" struts
)
with item "X" struts spanning east and west alternately; and Junction box 3FPA-JB88 is mounted to the vertical leg.
- 12. Field walkdown of sample support C325-107 (Reference Drawing EE-34KQ - Rev. 3) found the following attachment with 4
no installation documentation: three cable support item "X" struts spanning east at approximate elevation 37'-2",35'-10" and 34'-6".
- 13. Field walkdown of sample support C342-094 (reference Drawing EE 34KS - Rev. 2) found the following attachments with no installation documentation:
Horizontal member No. 9 (from top) has two 4" conduits (CB-976A) and horizontal No.10 has four 5' conduits (CB-j 976B). However, F-E-15020 shows four 4" and two 5" conduits supported by horizontal No.10 and No.11 (CB-976).
Four cantilever item "W" struts with item "X" strut spanning east at approximate elevation 39'-10", 38'-6", 35'-10" and 33'-2".
On east vertical leg, above the top riser attachment member, is a similar member to support two 4' conduits (3CC446PA, 3CC446PB) and one 1 1/2" conduit (3CC436PA).
- 14. Field walkdown of sample support C120-173 (reference drawing EE-34LG - Rev. 4) found Conduit Support CB-1356 for conduit 3CC4460H mounted on embed between the fourth and fifth (from top) horizontal member. The evaluation / approval (previously observed for other supports via an FE) of the impact of the additional loads from the conduit support on the tray support due to the attachment to a common embed could not be l
located.
Review Valid invalid Needed Date initiator: sarver, T. L.
O O
O 1/6/S8 VT Lead: Nerl, Anthony A O
O O
1/S'98 VT Mgr: schopfer, Don K 8
0 0
ti12/9e IRC Chmn: singh. Anand K O
O O
1/14'S8 Date:
INVALID:
Pnnted 5/15/98 9.20:07 AM Page 3 of 5 l_______________________________________________
Northeast Utilities ICAVP DR Na DR-MP3-0942 Millstone Unit 3 Discrepancy Report Dre: 5/14/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0942, 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 M3-98-0968 has been written to develop and track resolution of this item per RP-4.
SECOND RESPONSE:
NU has coricluded that the issues reported in Discrepancy Report, DR-MP3-0942, have identified CONFIRMED SIGNIFICANCE LEVEL 4 conditions which require correction.
However, the following support specific items requested in the S&L Follow-up to DR 942 are non-discrepant.
Item 1 A review of these conduits in the Cable Raceway Program shows that these supports were approved under various E & DCR's F-E-15502, F-E-15023 F-E-30334 and are supported as intended by the applicable Support Drawings. Ref. CB-0061,CB-0062,CB-0063,CB-082 AND CB-083.ltems 2 & 3 are documentation issues, not support issues. Item 4 The orientation of the conduit based on size is not required. The conduit supports are designed by using the weight per foot of the individual conduit (weight varies based on diameter) multiplied by the span in feet between the supports and then applying the total load to the respective support.ltems 5 & 6,10,11,12,13 (question 2) The Cable Support attachments are documented as shown on cable tray location drawing EE-34DL and are based on E & DCR F E-23925 which is posted against EE-34DL. The North side attachments are Z-161 which are listed on the E &
DCR. The South side attachments are identified on detail "K" on i
l EE-34DL. Attachments to Z-161 and Detail"K" are detailed on l
the other E & DCR's listed withia E &DCR F E-23925. Therefore this is not a discrepant condition.ltem 8 E & DCR F-E-4245 deletes cable tray X12 and modifies various cable tray supports.
l Type C279 is one of the cable tray supports that has been l
modified by removing the lower horizontal member.ltem 9 Documentation does exist for both of these conduits (3CC516NJ)
& (3CC516NG). The latest revision (REV. 2) of drawing CB-983 l
shows both of these conduits installed. E&DCR 15020 shows a l
PRELIMINARY copy of CB-983 showing 2-4" conduits & 1-3" conduit. These were changed by later E&DCR's. Item 13 (question 1) The documentation does exist for all 5 of these conduits. Drawing CB-976 (rev. 5) shows all 5 of these conduits installed. E & DCR 15020 shows a PRELIMINARY copy of CB-l 976 showing 4 4" conduits & 2-5" conduit. These were changed by later E & DCR's. Therefore this is not a discrepant condition.
l Item 13 (question 3) The documentation does exist for this item. DWG. CB-2230 (rev. 4) shows the listed items with the appropriate conduit numbers. Therefore this is not a discrepant condition.ltem 14 The attachment to the embedded strut is qualified on E & DCR F-E-25038 which is listed against DWG.
CB-1356.-
Prtnted mEJFaw nm pynur 1es no non unscrepanTC5nenonr ves Page FBI 5
l N::rthea:t Utilities ICAVP DR No. DR-MP3-0942 Millstone Unit 3 Discrepancy Report l
Previously identified by NU? v Yes
'e> No Non Discrepant Condition?v Yes te> No Resolution Pending?O ve.
<W) No Resolution Unresolved?O ve.
@ No Review initiator: Klaic, N l
VT Lead: Nerl. Anthony A VT Mgr: Schopfer, Don K g
g IRC Chmn: Singh, Anand K O
O O
Date:
5/14/98 SL Comments: Adequacy of the tray supports for the additional loads and/or configuration changes needs to be verified prior to start - up.
SECOND RESPONSE:
S & L concurs with NU's dispositions based on the review of the reference documents provided as an attachment to the DR disposition (E&DCR's and drawings).
Printed 5/15/98 9:20:06 AM Page 5 of 5
N:rthert Utilities ICAVP DR NA DR-MP3-1010 3
Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Om Discrepancy Tyse: Calculation g'
systenVProcess: NEW NRC Significance level: 4 Date faxed to NU:
l Date Published: 2/7/98 Discrepancy: Appropriate Calculation Change Notices are not consistently being referenced.
==
Description:==
Calculations are being referenced without the current Calculation Change Notices (CCN's) included in the reference. This DR reports a programmatic issue rather than a technical discrepancy.
This discrepancy applies to calculations 97 041,97-035 and 97-ENG-01427D3 with a sample of the problems this creates as follows:
Calculation 97-041 was written on 8/13/1997 (by Proto Power) and approved by NU on 9/1/1997. This calc. references calculation 90-069-1065M3 Rev. O when CCN's up to #4 were approved by 5/30/1997 and should have been referenced j
accordingly. This calc. also referenced calculation 90-069-l 1130M3 Rev. O. CCN #3 is later refered to in this calculation but is not so referenced.
l Review i
Valid invalid Needed Date initiator: Dionne, B. J.
O O
O 2/2/98 l
VT Lead: Neri, Anthony A B
O O
2/2/98 VT Mgr: schopfer, Don K B
O O
2/2/98 IRC Chmn: singh, Anand K O
O O
2/3/98 Date:
INVALID:
Date: 5/14/98 RESOLUTION: FIRST RESPONSE:
Disposition:
NU has concluded that Discrepancy Report, DR-MP3-1010, 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 PI-j 20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0967 has been written to develop and track resolution of this item per RP-4.
I
==
Conclusion:==
NU has concluded that Discrepancy Report, DR MP3-1010, has identified a condition not previously discovered by NU which i
requires correction. This discrepancy meets the criteria specified i
Printed 5/15/98 9.20:20 AM Page 1 of 3 l
N:rthert Utilitie3 ICAVP DR N2. DR-MP31010 Millstone Unit 3 Discrepancy Report I
in NRC letter B16901 and 17010. It has been screened per U3 PI-l 20 criteria and found to have no operability or deportability j
concerns and meets the Unit 3 deferral criteria. CR M3-98-0967 l
has been written to develop and track resolution of this item per i
RP-4.
SECOND RESPONSE:
Disposition:
NU has concluded that this issue reported in DR-MP31010 has identified a CONFlRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria l
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.NU has concluded that the new issue documented in S & L's follow-up to NU's response M3-IRF-001871 does not represent a discrepant condition. The Design Control Manual (DCM) clearly
)
states, in Chapters 4 & 5, that the revision of a document being used be specified, which includes CCNs against calculations.
The calculation tracking system in Passport indicates the current revision of a calculation, the CCNs in effect, and the CCNs soon to be in effect. The DCM requires that pending changes be considered in the design process.CR M3-98-0967 was written to develop and track resolution of this issue reported in DR-MP3-1010 per RP-4, and has subsequently been closed to CR M3 0138. The corrective actions in CR M3-98-0138 provide the necessary corrective actions to respond to the discrepant condition.
i
==
Conclusion:==
NU has concluded that this issue reported in DR-MP3-1010 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 U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria.NU has concluded that the new issue documented in S & L's follow-up to NU's response M3-IRF-001871 does not represent a discrepant condition. The Design Control Manual (DCM) clearly states, in Chapters 4 & 5, that the revision of a document being used be specified, which includes CCNs against calculations.
The calculation tracking system in Passport indicates the current revision of a calculation, the CCNs in effect, and the CCNs soon to be in effect. The DCM requires that pending changes be considered in the design process.The corrective actions in CR l
M3-98-0138 provide the necessary corrective actions to respond to the discrepant condition.
Previously identified by NU7 O Yes
(*) No Non Discrepant condition?O Yes
(#1 No Resolution Pending?O Yes @ No Resoiution unresoived70 Yes @ No Review initiator: Denne, B. J.
5/1498 j
Printed 5/15/98 9:20:27 AM Page 2 of 3
N:rthe st Utilities ICAVP DR No. DR-MP3-1010 Millstone Unit 3 Discrepancy Report O
O O
S1
- VT Lead: Nerl, Anthony A O
O O
S1 e l
VT Mgr: Schopfer. Don K O
C Si e IRC Chmn: singh, Anand K O
O O
Date:
5/14/98 SL Comnwnts: FIRST RESPONSE:
The disposition of this requirement does not outline or identify how the appropriate documents will be referenced or tracked.
There is no reference to NU procedures as to how the CCN's posted against calculations referenced as design inputs will be tracked along with the calculation revision.
SECOND RESPONSE:
This response clarifies the comments noted against the first response and is acceptable.
l l
f Printed 6/15S8 9:20:27 AM Page 3 of 3
l N:rthext Utilities ICAVP DR No. DR-MP3-1100 Millstone Unit 3 Discrepancy Report Nov6ew Group: Programmata DR RESOLUTION ACCEPTED l
Review Clement: Corrective Action Process p
Discipline: Other Discrepancy Type: Corrective Action implementaten g
System / Process: DGX l
NRC SigniAcance level: NA Date faxed to NU:
Date Published: N24/98 Discrepancy: Incomplete Closure Documentation for CR # M3-97-1256
==
Description:==
The Corrective Action Plan for CR # M3-97-1256 contained Cat I Corrective Action items designated CA 1 through CA 4. Items CA 1, CA 2, and CA 4 were completed. Item CA 3 required that the l&C Dept. was to review a list of controllers, Cat. I only, fumished under A/R 95052812 in order to: 1) verify that the controllers have knobs, 2) identify the ones adjusted by knobs,
- 3) note applicable Ops procedure, 4) note operating ranges, 5) note alarm settings. No documentation was included in the CR Closure Package to verify that the review of above 5 parameters was performed for each of controllers listed under A/R 95052812. Item CA 3 is tracked per A/R 97010194 - 05.
Therefore, closure of CR # M3-97-1256 is considered incomplete.
Note: NU's Memo MP3-DE-97-1640 was included as closure documentation for CA4. Although this memo relates to parameter 4 of CA 3, it does not document the closure of CA3.
Review Valid invalid Needed Date l
Initiator: Caruso. A.
O O
O
- 17/98 VT Lead: Ryan, Thomas J B
O O
- 17/98 VT Mgr: schopfer, Don K O
O O
v20/98 1RC Chmn: singh. Anand K O
O O
v20/98 Date:
l INVAllD:
L Date: $/14/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in DR-MP3-1100 has identified a NON-DISCREPANT condition. CR number M3 1256 is not yet closed. Therefore any reference to this package as a closure package is incorrect. V" hat Sargent & Lundy received was a snapshot of work in progress. Sargent & Lundy l
may use PASSPORT to determine the status of any CR or AR.
Sargent & Lundy correctly identified that the closure notes for AR No. 97010194-05 were incomplete in that they did not reference l
or attach documentation as was required by RP 4 Rev. 5.
l However, the documentation existed and was in the file which will be used to address the NON Cat 1 controllers. This documentation was separated from the other documentation and is now included with the CR documentation package and documents the work completed to close CA 3. The omitted documentation would have been assembled in the CR closeout process.
Printed 5/15/98 9:20 49 AM Page 1 of 2
{
l t
Northezt Utilitle3 ICAVP DR N;. DR-MP3-1100 Millstone Unit 3 Discrepancy Report Significance Level criteria do not apply here as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that the issue reported in DR-MP3-1100 has identified a NON-DlSCREPANT condition. CR number M3 '
1256 is not yet closed. Therefore any reference to this package as a closure package is incorrect. What Sargent & Lundy received was a snapshot of work in progress. Sargent & Lundy may use PASSPORT to determine the status of any CR or AR.
Sargent & Lundy correctly identified that the closure notes for AR No. 97010194-05 were incomplete in that they did not reference or attach documentation as was required by RP 4 Rev. 5.
However, the documentation existed and was in the file which will be used to address the NON Cat 1 controllers. This documentation was separated from the other documentation and is now included with the CR documentation package and documents the work completed to close CA 3. The omitted documentation would have been assembled in the CR closeout process.
Significance Level criteria do not apply here as this is not a discrepant condition.
Attachments:0 OAR 97010194-05 Review documentation Previously identified by NU? C) Yes te) No Non Discrepant Condition? O) Yes
(.) No I
ResolutionPending?O yes @ No Resolution Unresolved?O yes @ No Review CC8Ptable Not Acceptable Needed Date initiator: Caruso. A.
G O
O mm VT Lead: Ryan, Thomas J O
O me VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
5/14/98 SL Comments: NU's response is acceptable.
The above attachment AR 97010194-05 provided the necessary documentation that confirmed that the revievi of a list of Cat. I controllers was performed to: 1) verify that the controllers have knobs, 2) identify the ones adjusted by knobs 3) note applicable Ops procedure, 4) note operating ranges, 5) note alarm settings as required per CR # M3-971256 Corrective Action item designated CA 3.
The attachment confirms the closure of CR # M3-97-1256 l
Corrective Action item designated CA 3.
i Note: The CR Action Closecut sheet for AR & Assignment # AR 97010194-05 was included without the attachment in the CR # M3-97-1256 Closure package sent to S&L. This CR Action Closeout sheet was signed off on 11/21/97. The concern of this DR was the missing documentation and it has been received as part of NU's response.
Pnnted 5/15/98 9:20:50 AM Page 2 of 2
N rtheast Utiliti:s ICAVP DR No. DR-MP3-0035 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION REJECTED Review Element: Operating Procedure p
Discipline: Operations g
Discrepancy Type: Licensing Document g
System / Process: SWP NRc Significance level: 3 Date Faxed to NU:
Date Pubilshed: 8/31/97 Discrepancy: Not all Service Water heat exchangers are included in the surveillance procedure per LER 90-020-00
==
Description:==
Licensing event report (LER) 90-020-00 dated July 16,1990 was issued as a result of both trains of Quench Spray and High Pressure Safety injection being inoperable due to a deficient surveillance procedure. The corrective action section of this LER stated in part... "To prevent the recurrence, the surveillance procedure covering all Service Water System heat exchangers has been changed. When the established limits for a heat exchanger are exceeded the unit will be declared inoperable and the appropriate Technical Specification Limiting Condition of Operations Actions Statement entered".
Contrary to the above commitment, not all Service Water System heat exchangers are included in the applicable surveillance procedure. The applicable surveillance procedure is SP 3626.13, Service Water Heat Exchangers Fouling Determination, Rev 15, Change 1 with an effective date of April 1,1997. This procedure does not include any reference to or established limits for the following heat exchangers:
Containment Recirculation Heat Exchanger, 3RSS*E1 A Containment Recirculation Heat Exchanger,3RSS*E1B Containment Recirculation Heat Exchanger,3RSS*E1C Containment Recirculation Heat Exchanger,3RSS*E1D Post Accident Sampling Sample Cooler,3 SSP-SCL3 Review Valid invalid Needed Date Initiator: Spear, R.
O O
O 8/22/97 VT Lead: Bass, Ken 8
O O
a/22/97 VT Mgr: schopfer, Don K O
O 8/25/97 IRC Chrnn: Singh, Anand K B
O O
6/29/97 Date:
IWALID:
Date:
5/1/98 RESOLUTION Disposillon:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0035, does not represent a discrepant condition.
Millstone Unit 3 has a history of mussel fouling of the sen/ ice l
water heat exchangers. Upgrades and corrective actions to l
address mussel fouling include: new hypochlorite metering l
pumps; weekly surveillance of active or filled heat exchangers (3626.13); scheduled preventative maintenance and inspection on heat exchangers per EN 31084 ' revision 3 attached); and, Pnnted 5/15/98 9:52 53 AM Page 1 of 6
N:rtheast Utilities ICAVP DR Nr. DR-MP3-0035 Millstone Unit 3 Discrepancy Report development of a Special Procedure (SPROC 96 3-07) to flush j
the RSS heat exchangers on a quarterly basis, in addition, prompted by corrective actions for ACR 02994, permanent screens on the inlet of the RSS heat exchangers are scheduled to be installed during RFO6. Currently, during flushes these are Installed, procedurally controlled and then removed.The l
corrective actions on LER 90-020-00 were intended to include the requirements of Generic Letter 89-13. GL 89-13 was issued to address safety related portions of the Service Water system.
Post Accident Sampling System sample cooler,3 SSP-SCL3,is not safety related nor is it QA. It does not fall under the requirements of GL 89-13. 3 SSP-SCL3 is kept in dry lay-up (i.e.
not filled) so it is not as susceptible to fouling.The RSS heat exchangers are not included in 3626.13 for the following reasons:1. The service water side of the heat exchangers are kept in dry lay-up (i.e. not fille
- Mring normal operating i
conditions. Fouling cannot ow.. a dry system.2. The heat exchangers are surveilled for fouling during ESF / LOP testing each refueling (3646A.17 and 3646A.18 step 4.4.26.)3. Tl e system is flow tested quarterly, and is completely flushed per SPROC 96-3-07.4. 3626.13 is a weekly surveillance. Significant bio-fouling of large bore upstream piping will not occur over a quarter, therefore, a quarterly inspection cycle is sufficient.
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-MP3-0035, does not represent a discrepant condition.
Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and as such, does not fall under the requirements of GL 89-13. The RSS heat exchangers are survellied and inspected under ESF / LOP Testing Surveillance (3646A.17 and 3646A.18 step 4.4.26.) and the regular quarterly preventative maintenance schedule. Significance level criteria do not apply here as this is not a discrepant condition.
Revised Disposition and
Conclusion:
Disposition:
NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procecure 3626.13 surveils all service water heat exchangers excepf for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not safety-related and does not fall under the t
requirements of Generic Letter 89-13, additionally it is maintained in a dry lay-up condition. The RSS heat exchangers are kept in dry lay-up so they are not susceptible to fouling. The RSS heat exchangers are surveilled and inspected each refuel under ESF/ LOP Surveillance (3646A.17 and 3646A.18 step 4.4.26) and the regular quarterly preventative maintenance
[
schedule to ensure no biofoulina exists in staanate lea pipina l
Printed 5/15/98 9;52.54 AM Page 2 of 6 l
I
l l
Northe:st Utilities ICAVP DR NO. DR-MP3-0035 Millstone Unit 3 Discrepancy Report l
upstream of the heat exchanger.
in their response to M3-IRF-00301, Sargent & Lundy noted that -
no determination is made after the RSS heat exchangers are l
l flushed as to whether they are functional considering the amount of debris removed and if the periodicity of the flushes is appropriate. Sections 1.3.1 and 1.3.2 of EN31084, Operating Strategy For Service Water System At Millstone Unit 3, require the Containment Recirculation Spray Heat Exchangers to be flushed and inspected 4 times a year using SPROC 96-3-07.
Frequency of performing the flushes is tracked automatically by PMMS and AWO's are issued when the need for flushes j
becomes due. Permanent inlet debris screens have been installed in the inlet of each heat exchanger (DCR M3-97111).
Inlet heat exchanger screens are used since the service water side of the heat exchangers are kept in dry lay-up (i.e. not filled) during normal operating conditions. Fouling cannot occur in a dry system. EN31084 requires a formal assessment (Attachment 4 of the procedure) of the amount of captured mussels on the inlet screens relative to the heat exchanger performance, if the flush criteria for foreign materialis exceeded, a Condition Report must be issued (per RP-4) which in turn will require an operability assessment to be performed.
Thus, the effectiveness of the flushing and the frequency of flushes is assessed by the System Engineer using this method.
As stated in the MP3 Service Water System Heat Exchanger l
Performance Monitoring Program, heat transfer surveillance or performance testing of the RSS heat exchangers is not required.
The RSS system configuration precludes inducing a heat load across the heat exchangers such that meaningful test data can be obtained. However, the RSS heat exchangers are inspected regularly as described above.
\\
CR M3-98-1693 evaluated the additionalissue raised by S&L concerning micro-fouling inspection criteria contained in EN 31084, rev. 3. Micro-fouling inspection criteria is considered to be important since the heat transfer capability of each RSS heat exchanger cannot be verified by performing a test due to the unique system configuration of the RSS. Each RSS heat exchanger is flushed and inspected at least 3 times a year as required by EN 31084. Following each flush of the heat exchanger (per SPROC 96-3-07), which utilizes service water, the heat exchanger is then isolated and completely filled with demineralized water in accordance with OP 3326, section 4.7.
After filling, the heat exchanger is drained and then restored to the RSS system in dry lay-up. Formation of any scale or other micro-fouling condition / deposit is thus significantly minimized by l
the combination of flushing with service water and then filling
(
and draining with demineralized water. Furthermore, the piping configuration for RSS is such that no significant heat load can be applied (or has ever been applied) across the heat exchanger tubes, consequently there is no heat mechanism present for developing scale. However, to ensure the ability of each RSS heat exchanger to perform its safety function as designed, the visual inspection requirements in EN 31084 will be enhanced (A/R 98008002-01) to include (1) reviewina previous inspection Pnnted S/15/98 9:52:54 AM Page 3 of 6
l N:rtheast Utilitie3 ICAVP DR No. DR-MP3-0035 Millstone Unit 3 Discrepancy Report results prior to performing each inspection so that any changes can be readily identified and (2) bullets to advise inspector to l
Inspect in accordance with ASME OM-S/G-1994, part 21.
Significance Level Criteria does not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and Generic Letter 89-13 therefore does not apply. The RSS heat exchangers are surveilled and inspected for micro-fouling each i
refueling per ESF/ LOP Testing Surveillance (3646A.17 and 3646A.18) and quarterly per SPROC 96-3-07. Any foreign material removed from the RSS heat exchanger inlet screens is evaluated in accordance with EN 31084 for any effect on the performance of the heat exchangers. Prior to being placed in dry lay-up during normal plant operations, each RSS heat l
exchanger is visually inspected for micro-fouling after the service water flush and then filled with demineralized water and drained.
The fouling inspection of EN 31084 will be enhanced (A/R 98008002-01) to require review of the previous inspection results prior to performing the next inspection and trending the inspection results to evaluate the heat exchanger condition.
Significance Level Criteria does not apply as this is not a discrepant condition.
NU's revised response:
Disposition:
NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not safety-related and does not fall under the requirements of Generic Letter 89-13. The RSS heat I
exchangers are kept in dry lay-up so they are not susceptible to fouling. The RSS heat exchangers are surveilled and inspected each refuel under ESF/ LOP Testing Surveillance (3646A.17 and 364SA.18 step 4.4.26) and the regular quarterly preventative maintenance schedule.
In their response to M3-IRF-00301, Sargent & Lundy noted that no determination is made after the RSS heat exchangers are flushed as to whether they are functional considering the amount of debris removed and if the periodicity of the flushes is I
appropriate. Sections 1.3.1 and 1.3.2 of EN31084, Operating
)
Strategy For Service Water System At Millstone Unit 3, require i
the Containment Recirculation Heat Exchangers to be flushed i
and inspected 4 times a year using SPROC 96-3-07. Frequency l
of performing the flushes U tracked automatically by PMMS and l
AWO's are issued when the need for flushes becomes due, j
Permanent inlet debris screens have been installed in the inlet of l
Printed 5/15/98 9 52 54 AM Page 4 of 6 i
i N:rtheast Utilitie3 ICAVP DR N2. DR-MP3-0035 Millstone Unit 3 Discrepancy Report each heat exchanger (DCR M3-97111). Inlet heat exchanger screens are used since the service water side of the heat i
l exchangers are kept in dry lay-up (i.e. not filled) during normal operating conditions. Fouling cannot occur in a dry system.
i EN31084 requires a formal assessment (Attachment 4 of the procedure) of the amount of captured mussels on the inlet screens relative to the heat exchanger performance. If the flush criteria for foreign material is exceeded, a Condition Report must be issued (per RP-4) which in tum will require an operability assessment to be performed. Thus, the effectiveness of the flushing and the frequency of flushes is assessed by the System Engineer using this method.
As stated in the MP3 Service Water System Heat Exchanger Performance Monitoring Program, surveillance or performance testing of the RSS heat exchangers is not required. The RSS system configuration precludes inducing a heat load across the heat exchangers such that meaningful test data can be obtained.
However, the RSS heat exchangers are inspected regularly as described above.
1 CR M3-98-1693 evaluated the additionalissue raised by S&L conceming micro-fouling inspection criteria contained in EN 31084, rev. 3, and concluded additional inspection criteria are not required. Micro-fouling inspection criteria is considered to be important by S&L since the heat transfer capability of each RSS heat exchanger cannot be verified by performing a test due to the unique system configuration of the RSS. However, each RSS heat exchanger is flushed and inspected at least 3 times a j
year as required by EN 31084. Following each flush of the heat exchanger (per SPROC 96-3-07), which utilizes service water, the heat exchanger is then isolated and completely filled with j
demineralized water in accordance with OP 3326, section 4.7.
j After filling, the heat exchanger is drained and then restored to the RSS system in dry lay-up. Formation of any scale or other micro-fouling condition / deposit is thus significantly minimized by the combination of flushing with service water and then filling and draining with demineralized water. Furthermore, the piping configuration for RSS is such that no significant heat load is applied (or has ever been applied) across the heat exchanger tubes, consequently there is no heat mechanism present for developing scale. Hence additional micro-fouling criteria is not warranted. Significance Level Criteria does not apply as this is not a discrepant condition.
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and Generic j
Letter 89-13 therefore does not apply. The RSS heat exchangers are surveilled and inspected each refueling per ESF/ LOP Testing Surveillance (3646A.17 and 3646A.18) and quarterly tested per SPROC 96-3-07. Any foreign material removed from the RSS heat exchanger inlet screens is evaluated in accordance with EN 31084 for any effect on the Printed 5/15/98 9:52;54 AM Page 5 of 6
r- ~
Northezt Utilities ICAVP DR Nr. DR MP3-0035 Millstone Unit 3 Discrepancy Report performance of the heat exchangers. Inspection for micro-fouling is also performed. Significance Criteria does not apply as this is not a discrepant condition.
l Previously identified by Nu? O Yes f No Non Discrepant Condition?O Yes @ No ResolutionPending?O Yes
- ) No Resolution Unresolved? 5) Yes O No l
Review initiator: spear, R.
VT Lead: Bass, Ken I
VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date:
5/1/98 SL Cornments: We have reviewed NU's resolution to Discrepancy Report # DR-MP3-0035 and have determined that it does not provide enough additional information to resolve the discrepancy.
NU's response identified that the Containment Recirculation heat exchangers are surveilled for fouling during ESF/ LOP testing each refueling. The identified surveillance for the Containment Recirculation Heat Exchangers is actually a system flush intended to remove biofouling debris from the long stagnant legs that are not in dry lay-up and not a surveillance with criteria for determination of degraded and inoperable heat exchangers. NU recognizes that biofouling will occur in these stagnant portions and has determined that flushing is the appropriate method for removal.
There is no determination made after flushing as to whether the quantity of material removed from the heat exchangers or if other fouling was present sufficie.11 to render the heat exchangers non-functionalif the system had been called upon between the flushing intervals. Additionally, since the amount of debris is not j
quantified, no determination can be made if the periodicity of the flushes is appropriate Additional S&L comments:
NU has not provide enough additional information to resolve this Issue. S&L has determined that the intent of GL 89-13 is that all safety related heat exchangers be tested on a regular basis.
Section two of GL 89-13 states that altemative actions such as frequent regular maintenance is acceptable provided there is an evaluation that focuses on demonstrating heat removal capability, not only physical condition. NU has not identified any tests or j
maintenance activity that focuses on demonstrating heat removal capability.
Pnnted 5/15/98 9:52:54 AM Page 6 of 6 a_____
N:rthert Utiliti:3 ICAVP DR No. DR-MP3-1074 Millstone Unit 3 Discrepancy Report j
Review Group: Operations & Maintenance and Testing DR RESOLUTION REJECTED Review Element: Corrective Action Process p
Discipline: Other O yes Discrepancy Type: Corrective Action implernentation g
System / Process: SWP
~
NRC Signincance level: 3 Date Faxed to NU:
}
Date Published: 3/5/98 Discrepancy: Inadequate implementation of Service Water System testing corrective action.
==
Description:==
Item 2 of Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment, requires that a test program be conducted to verify the heat transfer capability of all safety-related heat exchanges cooled by service water.
The Generic Letter states that the initial frequency of testing should be at least once each fuel cycle, but after three tests the best frequency for testing should be determined to provide assurance that the equipment will perform the intended safety functions.
Unresolved issue Report (UIR) # 515, GL 89-13 Heat Exchanger Testing documents that heat exchanger testing was not being accomplished as required by the Generic Letter. The corrective action for this UIR includes developing a
- position on heat exchanger testing schedule."
A review of the UIR corrective action implementation determined that the heat exchanger testing program is inadequate and does not meet the intent of Generic Letter 89-13. The testing schedule does not include all safety related heat exchangers cooled by service water. The action tracking items do not assure that each safety related service water heat exchanger will be tested at least once each fuel cycle for the next three cycles.
)
Review Valid invalid Needed Date initiator: spear, R.
O O
O 2/26/98 j
I VT Lead: Bass, Ken O
O O
2/26/98 VT Mgr: schopfer, Don K O
O O
3/2/98 IRc Chmn: singh. Anand K O
O O
3/2/98 Date:
INVALID:
\\
Date:
5/1/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR #515 corrective action (AR96008622-
- 01) required the development of a firm and accelerated schedule for completing the Generic Letter 89-13 service water system heat exchangst tests and evaluations of the test data. Both AR96008622-01 and AR97000669-02 tracked the development of the MP3 Service Water Heat Exchanger Performance Monitoring Program which formalize the commitment to Generic f
Letter 89-13 requirements and to provide the programmatic Pnnted 5/15/98 9:53:23 AM Page 1 of 4 L
Northext Utilitie3 ICAVP DR N2. DR-MP3-1074 l
Millstone unit 3 Discrepancy Report means to schedule the testing of heat exchangers and to evaluate the test results. The discrepant Final Disposition of UIR
- 515 will be corrected after startup by the approved corrective i
l action plan for CR M3-98-1279 to reference the performance l
monitoring program which provides the requested heat j
l exchanger testing schedule and commitment to GL 89-13.The Significance Level is concluded to be Level 4 since there is no impact on MP3 DB or LB or plant equipment.
l
==
Conclusion:==
NU has concluded that Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR 515 Closure Request Final Disposition will be corrected after startup by the approved corrective action plan of CR M3-98-1279 to reference the MP3 GL 89-13 Service Water System Heat Exchanger Performance Monitoring Program which implements the requirements of Generic Letter 89-13 and provides testing schedules. The Significance Levelis concluded to be Level 4 since there is no impact on MP3 LB or DB or plant equipment.
Revised response received 4/23/98:
Disposition:
NU has concluded that the new issue reported in Revised Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. The heat exchanger testing frequency stated in the conclusion to UlR 515 deviates from the testing requirements contained in Generic Letter 89-13.13 are included in the licensing bases. This Discrepancy Report and NU's conclusion establish that the Heat Exchanger Testing program is not being accomplished as required by the Generic Letter and therefore does not meet the licensing bases. The criteria for determining the relative discrepancy significance level establishes that if a discrepancy does not meet its licensing and design bases but the system is capable of performing its intended function, it is a level 3 discrepancy. After discussion and agreement with the NRC Inspection Team, clarification of the responses to Generic Letter 89-13 is required prior to start-up. AR 97030287-08 requires preparation of a NRC submittal formally proposing the change in heat exchanger testing frequency from the requirements of Generic Letter 89-13.
The submittal is to be made prior to start-up. The proposed testing frequency is consistent with the Generic Letter 89-13 recommendations for initial test frequencies. The retest and cleaning schedules will be based upon the initial testing results.
The maximum period between tests is five years once a retest frequency is established. In addition the conclusion of UIR 515 will be revised accordingly after startup by the approved corrective action plan for CR M3-98-1279. Testing of individual groupings of MP3 SW heat exchangers in the program will be l
tracked by the following AR's:
97019658 3EGS*E1 A/E2A 97019660 3EGS*E1B/E2B Printed 5/15/98 9.53:24 AM Page 2 of 4
Northeast Utilities ICAVP DR Nr. DR-MP3-1074 Millstone unit 3 Discrepancy Report 97019655 3CCL*E1A/E1B 97019657 3CCE*E1 A/E1B l
97019670 3HVK*CHL1A/1B 97019661 3CCP*E1 A/B/C 97019662 3HVR*ACU1A/1B 97019667 3HVQ* ACUS 1A/1B 97019669 3HVQ* ACUS 2A/2B The Significance Level is concluded to be Level 4 since there is no impact on LB or DB.
Conclusion.
NU has concluded that the issue reported in Revised j
Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UlR 515 Closure Request wil! be revised as required by the approved corrective action plan for CR M3-98-1279 after startup to reference the MP3 GL 89-13 service Water System Heat Exchanger Performance Monitoring Program testing i
requirements for the SW heat exchangers. The change in testing requirements will be contained in a submittal to the NRC which
)
will made prior to startup. The Significance Level for DR-MP3-l 1074 is concluded to be Level 4 since LB and DB are met.
Additional NU response:
Disposition:
NU has concluded that the new issue reported in Revised Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. The heat exchanger testing trequency stated in the conclusion to UlR 515 deviates from the testing requirements contained in Generic Letter 89-13. After discussion and agreement with the NRC Inspection Team, clarification of the responses to Generic Letter 89-13 is required prior to start-up. AR 97030287-08 requires preparation of a NRC submittal formally proposing the change in heat exchanger testing frequency from the requirements of Generic Letter 89-13. The submittal is to be made prior to start-up. The proposed testing frequency is consistent with the Generic Letter 89-13 recommendations for initial test frequencies. The retest and cleaning schedules will be based upon the initial testing results. The maximum period between tests is five years once a retest frequency is established. In j
addition the conclusion of UIR 515 will be revised accordingly after startup by the approved corrective action plan for CR M3-98-1279. Testing of individual groupings of MP3 SW heat i
exchangers in the program will be tracked by the following AR's:
97019658 3EGS*E1A/E2A 97019660 3EGS*E1B/E2B 97019655 3CCL*E1A/E1B 97019657 3CCE*E1 A/E1B 97019670 3HVK*CHL1A/1B 97019661 3CCP*E1 A/B/C 97019662 3HVR*ACU1 A/1B 97019667 3HVQ' ACUS 1A/1B 97019669 3HVQ* ACUS 2A/28 l
The Significance Level is concluded to be Level 4 since there is j
i l
==
Conclusion:==
NU has concluded that the issue reported in Revised Pnnted 5/15/98 9:53:24 AM Page 3 of 4 j
l Northea:t Utilities ICAVP DR Nr. DR-MP3-1074
)
Millstone Unit 3 Discrepancy Report Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR 515 Closure Request will be revised as required by the approved corrective action plan for CR M3-98-1279 after startup to reference the MP3 GL 89-13 service Water System Heat Exchanger Performance Monitoring Program testing requirements for the SW heat exchangers. The change in testing requirements will be contained in a submittal to the NRC which 1
l will made prior to startup. The Significance Level for DR-MP3-1074 is concluded to be Level 4 since LB and DB are met.
Previously identified by NU7 O Yes (G) No Non Discrepant condition?O Yes (8) No Resolution Pending?O ves + No Resoiutionunresoivedet ves O No Review Acceptable Not Acceptable Needed Date i
initiator: spear. R.
VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K l
Date:
5/1/98 l
SL Comrnents: S&L concurs with NU's resolution and conclusion for Discrepancy Report DR-MP3-1074 but does not concur that the l
Significance Levelis Level 4 as proposed by NU. The I
requirements of Generic Letter (GL) 89-13 are included in the licensing bases. This Discrepancy Report and NU's conclusion establish that the Heat Exchanger Testing program is not being accomplished as required by the Generic Letter and therefore does not meet the licensing bases. The criteria for determining the relative discrepancy significance level establishes that if a discrepancy does not meet its licensing and design bases but the system is capable of performing its intended function, it is a level 3 discrepancy.
Additional S&L Comments:
NU has not provide enough additionalinformation to resolve this issue. S&L has determined that the intent of GL 89-13 is that all safety related heat exchangers be tested on a regular basis.
Section two of GL 89-13 states that initial testing frequency should be at least once per cycle, but after 3 tests the frequency I
my be adjusted. This listing of SW heat exchangers included in the latest response does not include the Containment Recirculation Coolers (3RSS*E1 A-D). GL 89-13 does not provide for excluding safety related heat exchangers when an adequate heat load can not be applied to the heat exchanger. As
[
stated previously, implementation of GL 09-13 is a licensing basis l
issue and as such this is a Level 3 Discrepancy.
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l i
l Pnnted 5/15/98 9:53:24 AM Page 4 of 4 a