ML20247K777

Forwards Drs Identified During Review Activities for Independent C/A Verification Program

ML20247K777
Person / Time
Site:	Millstone
Issue date:	05/19/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9805220202
Download: ML20247K777 (87)

Text

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{s k Sar gerW& Lundyc Don K. Schopfer

)&>ll Senior Vice President 312-269-6078 May 19,1998 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 twenty-three (23) DRs for which the NU resolutions have been reviewed and accepted by S&L.

4 DR No. DR-MP3-0020 DR No. DR-MP3-0773 DR No. DR-MP3-0021 DR No. DR-MP3-0833 DR No. DR-MP3-0166 DR No. DR-MP3-0834 DR No. DR-MP3-0196 DR No. DR-MP3-0839 DR No. DR-MP3-0204 DR No. DR-MP3-0888 DR No. DR-MP3-0409

)

DR No. DR-MP3-1004 / i DR No. DR-MP3-0461 DR No. DR-MP3-1011 l DR No. DR-MP3-0563 DR No. DR-MP3-1049 [

DR No. DR-MP3-0638 DR No. DR-MP3-1057 DR No. DR-MP3-0670 DR No. DR-MP3-1094 l DR No. DR-MP3-0717 DR No. DR-MP3-1096 .-

j DR No. DR-MP3-0724 /

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r 9805220202 980519 PDR ADOCK 05000423 P PDR 55 East Monroe Street Chicago, IL 60603-5780 USA + 312-269-2000

United States Nuclear Regulatory Commission May 19,1998 Document Control Desk Project No. 9583-100 Page 2 Please direct any questions to me a: (312) 269-6078.

Yours very truly,

6. -

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

E. Imbro (1/1) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU m:hpM8'wvC519a. doc

Northent Utilities ICAVP DR N . DR-MP3-0020 Millstone Unit 3 Discrepancy Report Review Group: Accident Mdigation DR RESOLUTION ACCEPTED Potential Operabi!ity lasue Discipline: Other Discrepancy Type: Licensing Document System / Process: N/A g

NRC Significance level: NA Date Faxed to NU:

Date Published: 8/22/97 Discrepancy: Westinghouse Comments on FSAR Section 15.0 and 15.6

Description:

We have reviewed Westinghouse Electric Corporation letter NEU-06-615,

• Northeast Utilities Service Company Millstone Unit 3 Review of FSAR Chapter 15 - LOCA," dated November 1, 1996, which provided NU suggested page markups for FSAR Section 15.0, Introduction, and Section 15.6, Decrease in Reactor Coolant inventory. The purpose of these comments and markups was to provide assurance that the Millstone 3 FSAR is consistent with the Plant Safety Evaluation of record for the current fuel cycle.

The comments on this section identify changes to the input assumptions and results for the accidents analyzed in this section. The Westinghouse changes leave unresolved the observation that the analysis was performed using a 2% loop uncertainty whereas the FSAR lists the N-1 loop uncertainty as 2.3%. These changes have not been incorporated into the FSAR, making the FSAR and the Plant Safety Evaluation inconsistent.

A review of applicable corrective action databases for Millstone 3 has not identified any pending FSAR change notice items that will incorporate the Westinghouse comments into the FSAR.

Review Valid invalid Needed Date initiator: Johnson, W. J. O O O 6' '87 VT Lead: Raheja, Raj D G O O 8/11/97 VT Mgr: schopfer, Don K O O O 8/11/97 IRC Chmn: singh, Anand K B O O Bli2/97 Date:

INVALID:

Date: 5/15/98 RESOLUTION: Disposition:

INITIAL DISPOSITION 11/12/97 During the FSAR verification activities performed pursuant to the requirements of 10CFR50.54f, NU discovered the discrepancy involving the loop uncertainty value for N-1 loop operation.

Table 15.0-2 was revised to clarify that the value is 2% for N-1 loop pertaining to LOCA. Notes (g) and (h) were added to Table 15.0-2 in FSAR CR 97-MP3-91, initiated 2/27/97, to show the maximum initial power and the uncertainty value for the LOCA event. Since the text in section 15.0.3.2 is a generic explanation of typical values used in such evaluations, it was deemed i Pnnted 5/19/981:44 41 PM Page 1 of 3

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i Northerst Utilitie3 ICAVP DR N2. DR-MP3-0020 Millstone Unit 3 Discrepancy Report l unnecessary to revise the text and retain plant specific values in i Table 15.0-2.

Note that the maximum power limit of N-1 loop LOCA event is I analyzed at 75%. Unit 3 is procedurally limited to 65% power i during N-1 loop operation. Moreover, Unit 3 is administratively prohibited from N-1 operations altogether.

Refer to the copv > "SAR CR 97-MP3-91 attached to M3-IRF-00266 (ICAVP A- )nse to DR-MP3-0017) for changes associated wit a a section 15.0. The FSAR CR is awaiting PORC ar ,

Conclusion:

DR-MP3-0020 identified a discrepant condition with FSAR Chapter 15.0 previously addressed by NU. The clarifications written in Table 15.0-2 will be incorporated into FSAR section 15.0 through FSAR CR 97 MP3 91. Section 15.0.3.2 does not need to be changed because it is a generic explanation. Spccific information is found in the table. .

I SUPPLEMENTAL DISPOSITION 5/6/98 Disposition:

NU has concluded that this issue reported in DR-MP3-0020 has identified a NON-DISCREPANT condition. FSARC/R 97-MP3-69 has incorporated peak cladding temperature changes as identified in Westinghouse Letter NEU-96-615. No further FSAR changes are required.

Conclusion:

NU has concluded that this issue reported in DR-MP3-0020 has i identified a NON-DISCREPANT condition. FSARC/R 97-MP3- I 69 has incorporated peak cladding temperature changes as identified in Westinghouse Letter NEU-96-615. No further FSAR 4 changes are required. l Previously identifled by NU? O Yes (#) No Non Discrepant Condition?(#) Yes O No l

Resolution Pending?O Ye. r*> No Re.oiution unre.oived?O Ye. @)No t Review cap a Date initiator: Johnson. W. J.

0 0 mm VT Lead: Raheja. Raj D VT Mgr: schopfer, Don K O mm IRC Chmn: singh. Anand K Date: 5/15/98 l SL Comments: INITIAL COMMENTS 11/12/98 NU response addresses the issue of loop uncertainty and the effect of FSAR Section 15.0, but does not address the recommended changes to FSAR Section 15.6 identified in i Westinghouse letter NEU-96-615. These changes include items  !

such as changes to the peak cladding temperature in Table 15.6-PnrAad 5/19/981:44.45 PM Page 2 of 3 l

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N::rthert Utilities ICAVP DR Ns. DR-MP3-0020 Millstone Unit 3 Discrepancy Report

11. Since the NU response did not address these changes, ICAVP considers the response to be incomplete.

COMMENTS ON SUPPLEMENTAL DISPOSITION 5/6/98 ICAVP has reviewed the additional documentation provided by l NU and concurs that this DR represents a non-discrepant condition.

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Printed 5/19/981:44 46 PM Page 3 of 3

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N:rthe2:t Utilities ICAVP DR N2. DR-MP3 0021 Millstone unit 3 Discrepancy Report Review Group: Acektent MRigation DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Other Discrepancy Type: UceW h SystemfProcess: N/A

@ No

~

NRC Significance level: NA Date faxed to NU:

Date Published: 8/22/97 Discrepancy: Westinghouse Cornments on FSAR Section 15.0

Description:

We have reviewed Westinghouse Electric Corporation letter NEU-97 536,

• Northeast Utilities Service Company Millstona Unit 3 Review of FSAR Chapter 15," dated April 8,1997, which provided NU suggested page markups for FSAR Section 15.0, introduction. The purpose of these comments and markups was to provide assurance that the Millstone 3 FSAR is consistent with l the Plant Safety Evaluation of record for the current fuel cycle.

The comments on this section identify changes to Figure 15.0-21 and Table 15.0-2. These changes have not been incorporated into the FSAR, making the FSAR inconsistent with the Plant Safety Evaluation.

A review of applicable corrective action databases for Millstone 3 has not identified any pending FSAR change notice items that will incorporate the Westinghouse comments into the FSAR.

Review Valid invalid Needed Date initiator: Johnson. W. J. G O O 8/11/97 VT Lead: Rahoja. Raj D G O O 8/11/97 VT Mgr: schopfer, Don K B O O 8/11/97 mC Chmn: singh. Anand K O O O e/12/97 Date:

INVALID:

Date: 5/15/98 RESOLUTION INITIAL DISPOSITION 9/2/97 Disposition: ,

FSAR CR 97-MP3-91, initiated 2/27/97, incorporated all {

Westinghouse comments from letter NEU-97 536 pertaining to Chapter 15.0. Refer to attached copy of FSAR CR 97-MP3-91 ,

attached to M3-IRF-00266 (ICAVP Response to DR-MP3-0017) I for changes associated with FSAR section 15.0. The FSAR CR is currently in the review process with PORC approval expected by 10/21/97.

Conclusion:

DR-MP3-0021 identified a discrepant condition with FSAR Chapter 15.0 that NU has previously addressed. The subject Westinghouse letter and comments were evaluated and will be incorporated into FSAR section 15.0 through FSAR CR 97-MP3-

91. No further action is required.

SUBSEQUENT DISPOSTION 5/6/98 Printed 5/19/961:52:04 PM Page 1 of 2 l

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l N:rtherst Utilitie3 ICAVP DR No. DR-MP3-0021 Millsto ie Unit 3 Discrepancy Report I

I Disposition.

NU has concluded that this issue reported in DR-MP3-0021 has l identified a NON-DISCREPANT condition.FSARC/R 97-MP3-91 )

has incorporated both the steam 9enerator tube failure Reactor Trip Function " manual" and the Steam Generator tube failure Other Equipment " power operated relief valve or pressurizer spray"into FSAR Table 15-06 on page 5 of 5.

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Conclusion:

NU has concluded that this issue reported in DR-MP3-0021 has j identified a NON-DISCREPANT condition.FSARC/R 97-MP3-91 1 has incorporated both the steam generator tube failure Reactor l Trip Function " manual" and the Steam Generator tube failure i Other Equipment " power operated relief valve or pressurizer spray" into FSAR Table 15-06 on page 5 of 5. j Previously identified by NU? O vos (9) No f Non Discrepent Condition? f) ves O No Dsolution Pending?O ve. @ No no.ouion unre.oiv.d?O ve. @ No i Review initiator: Johnson, W. J.

VT Lead: Raheja, Raj D VT Mgr: Schopfer, Don K ,

IRC chmn: Singh. Anand K l Date: 5/15/98 sL comments: INITIAL COMMENTS 11/18/97 A comparison of FSAR CR 97-MP3-91 with Westinghouse letter NEU-97-536 confirmed that most of Westinghouse comments have been included in the FSAR change. There were two exceptions noted on Table 15.0-8, page 4 of 4:

1. The steam generator tube failure Reactor Trip Function

" manual" was not included.

2. The Steam generator tube failure Other Equipment

" pressurizer power operated relief valve or pressurizer spray" was not included.

The text of the FSAR change did not discuss why these were omitted.

COMMENTS ON SUPPLEMENTAL DISPOSITION 5/6/98 ICAVP has reviewed the add?ional documentation provided by NU and concurs that this DR represents a non-discrepant i l condition. l f

Pnnted 5/19/901:52:08 PM Page 2 of 2

N:rthert Utilities ICAVP DR N2. DR-MP3-0166 Ministone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: I & C Design Discrepancy Type: Calculation Om SystenVProcess: SWP g

NRC Significance 'evel: 4 Date faxed to NU:

Date Published: 10/18S7 Discrepancy: Calculation SP-3SWP-1 methodology vs. RG1.105 commitment

Description:

The purpose of calculation SP-3SWP-1, Rev. 2 is to determine differential pressure setpoint for switches 3SWP*PDIS24A,B,C,D giving start permissiive to 3SWP*STRI A,B.C,D strainer motors.

During the review of Calculation SP-3SWP-1, the following was discovered:

1. Per objective section of the calculation, the calculation has been performed to compensate for the !nstrument channel inaccuracy as per the requirements of Reg. Guide 1.105. The Reg. Guide endorses ISA 67.04-1982, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Plants". Various components identified in this document that need to be considered for calculating the setpoint uncertainty - e.g.,

calibration uncertainty, measuring and test equipment uncertainty, calibration tolerance, seismic event impact etc. have not been addressed.

Review Valid invalid Needed Date initiator: Hinde, R. O O O 9/2ss7 VT Lead: Neri, Anthony A O O O o/187 VT Mgr: Schopfer, Don K O O 10'13S7 ,

IRC Chnwn: srigh, Anand K O O O o' d/97 j

Date:

INVALID:

Date: 5/18/98 RESOLUTION: RESPONSE #1 Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0166, does not represent a discrepant condition.The qualification program and performance specifications for the Barton differential p. essure switches were not available when this calculation was performed. Calculation SP-3SWP-1 revision was issued as requiring confinnation. The calculation revision assumed an encompassing inaccuracy for the differential pressure switch instrument of i 10% of Full Scale which was l provided by the vendor. This encompassing inaccuracy ensured I that the established instrument setpoint would be conservative once the final performance specifications were received. After the vendor test report data was received the calculation confirmation was performed and it was determined that no revisions to the calculation were required. This was documented via Interoffice Correspondence dated 9-10-85. While it is not Pnnted 5/19/901:52:37 PM Page 1 of 4

Northext Utilitie3 ICAVP DR Nr. DR-MP3-0166 Millstone Unit 3 Discrepancy Report clearly stated in the Interoffice Correspondence that all inaccuracies, both instrument and non-instrument related, were reviewed and accounted for. It is assumed that the engineer who completed the confirmation effort took all inaccuracies into account based upon the input assumptions that referenced RG 1.105 revision 1 effective in 1985. Millstone Unit 3 licensing basis uses Reg. Guide 1.105 revision i for setpoints. Significance Level criteria do not apply here as this is not a discrepant condition. Attachments: Calculation SP-3SWP-1 with interoffice Correspondence 9-10-85. I

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0166, does not represent a discrepant condition. The calculation was in accordance to Regulatory Guide 1.105 revision 1, the Millstone Unit 3 licensing basis. Significance Level criteria do not apply he,e as this is not a discrepant coadition.

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RESPONSE #2 Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0166, has identified a condition not previously discovered by NU that requires correction. The licensing basis for MP3 with respect to Regulatory Guide 1.105, Revision 1, applies to protective instruments and alarms in systems important to safety. A system important to safety is defined as those systems that are necessary to ensure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe condition, or (3) the capability to prevent or mitigate the consequences of accidents that could further result in potential offsite exposures comparable to the guideline exposures of 10CFR Part 100," Reactor Site Criteria". The Regulatory Guide Position sections C1 through C6 provides further guidance indicating that the requirements of the Regulatory Guide are to be applied in the development of setpoints with appropriate margins to account for expected uncertainties between the setpoint and the limiting safety settings contained in the Technical Specifications. This provides clarification that the protective instruments and alarms in systems important to safety whose limiting safety settings for which we must maintain margin for uncertainty are listed in Technical Specifications.

Calculation SP-3SWP-1, Rev.1, "3SWP*PDIS24A, B, C, and D Pressure Differential Switch Setpoint" primary objective was to compennte the high differential pressure setpoint for instrument channel inaccuracies in accordance with Regulatory Guide 1.105 requirements. A review of the Technical Specification, Technical i Specification bases, and Technical Specification requirements documents did not show this setpoint to be a Technical Specification limit value. Therefore. these instruments are not Printed 5/19/981:52.40 PM Page 2 of 4 i

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Northert Utilities ICAVP DR Nm. DR-MP3-0166 Millstone unit 3 Discrepancy Report required to have instrumentation uncertainties included in their setpoints and the objective for Calculation SP-3SWP-1 is in error. CR M3-98-1288 corrective action plan has been approved for post startup implementation.

Condition Report M3-98-1288, dated March 6,1998, was written to provide the necessary corrective actions to resolve the calculation discrepancies. The approved Corrective Action Plan for M3-98-1288 will revise instrument setpoint calculation SP-3SWP-1 to remove the reference to Regulator Guide 1.105 and clearly identify what instrument uncertainties must be included in the setpoint calculation to be in accordance with the MP3 licensing basis and instrument setpoint methodology.

These changes are administrative in nature and do not impact the design or licensing basis of the service water system.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0168, has identified a condition not previously discovered by NU that requires correction. Condition Report CR M3-98-1288 has been written and its corrective action plan approved to revise the setpoint calculation to remove the reference to Regulatory Guide 1.105 and clearly identify what instrument uncertainties must be included in the setpoint calculation to be in accordance with the MP3 licensing basis and instrument setpoint methodology. These changes are administrative in nature and do not impact the design or licensing basis of the service water system since, these switches are not required to have instrumentation uncertainties included in their setpoints. CR M3-98-1288 corrective action plan has been approved for post startup implementation.

Previously identified by Nu? O Yes (G) No Non Discrepent Condition?O Yes (9) No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ wo Review CC*Ptable Not Acceptable Needed Date initiator: DeMarco, J.

O O O Si m VT Lead: Neri, Anthony A VT Mgt: Schopfer Don K O O O Si m l 1RC Chmn: Singh, Anand K O O si m O O O  !

I Date: 5/18/98 sL Comments: RESPONSE #1 The assumed 110% of Full Scale (FS) inaccuracy in the calculation SP-3SWP-1, Rev. is non conservative for the following reasons:

1. Report no. R3-580A-9, dated 12/22/83 titled " Class 1E Qualification Test Program and Results for ITT Barton Models 580A, 581 A, and 583A Differential Pressure Switches" identifies the following:

An inaccuracy value of 110% of FS with a repeatability value of

• 1% of FS for the Seismic effect on setpoint accuracy (refer to sheet 3 of 16 of document R3-X759-7).

Pnnted U19/981:52:42 PM Page 3 of 4

Northenct Utilities ICAVP DR N2. DR MP3-0166 Millstone unit 3 Discrepancy Report An inaccuracy value of 110% of FS with a repeatability value of 11% of FS for the Radiation effect on the setpoint accuracy (refer to page 2 of 12 of document R3-580A-7). Since the switch is located in the mild area CWO1 (CW/SW Pump House) this inaccuracy is not applicable for this calculation.

An inaccuracy value of 110% of FS with a repeatability value of 11% of FS for the LOCA effect on the setpoint ac::uracy (refer to page 40 of document R3-580A-9). Since the switch is located in the mild area CWO1 (CW/SW Pump House) this inaccuracy is not applicable for this calculation.

Since the inaccuracy value used in the calculation is equal to the error due to seismic setpoint drift value it is not in conservative direction. Errors due to repeatability (since repeatability is not independent of inaccuracy value), calibration uncertainty, measuring and test equipment (M&TE), calibration inaccuracy should be considered in the calculation. The assumed M&TE error should be verified or should be controlled by the use of known instrument inaccuracy in the calibration procedure.

2. Abovementioned switch incccuracles are in agreement with the ITT corporation product bulletin 580A series -1,1994 edition titled

" Nuclear Safety DP Indicating Switch".

Based upon above discussion if all of the uncertainties identified above are accounted for the total error value will be more than 10% figure identified in the calculation.

=================

RESPONSE # 2 Based on a telecon among NU, NRC, and S&L on 5/18/98, this instrumentation is not classified as Tech Spec and is not subject to RG 1.105 error analysis. Additionally, NU's response in M3- I 1RF-01951 and actions identified in CR M3-98-1288 have been l reviewed and found to be acceptable, since the other error terms are negligible compared with the 10% value used.

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Printed 5/19f981:52.43 PM Page 4 of 4 O___-________.__. ._

Northe st Utilities ICAVP DR No. DR-MP3-0196 )

Millstone Unit 3 Discrepancy Report {

Review Group: Operetsons & Maintenance and Testin0 DR RESOLUTION ACCEPTED Review Element: Operating Procedure '

Potential Operability lasue Discipline: OWW Discrepancy Type: Test Requirements O Yes

@) No SystenVProcess: Rss NRC Significance level: NA Date faxed to NU:

Date Published: 10/3/97 l Discrepancy: Missing guidance in the Containment inspection Pmcedure.

Description:

The containment is to be inspected at least once per refueling l interval by performing a visual inspection of the containment l sump, verifying the sumps are not restricted by debris, and that I there is no evidence of structural distress or abnormal corrosion.

Tech Spec 4.5.2.d.2 requires the containment inspection. The

[ Tech Spec requirement is qualitative. SP 3612A.1, Containment l Inspections, provides the direction for performing the inspection.

The procedure gives examples of loose debris in Attachment 1.

The procedure does not provide similar examples of structural distress or abnormal corrosion. Attematively, the procedure does not specify either minimum training requirements or personal qualifications.

t l The procedure and completed OPS Form do not provide adequate information to independently verify that the inspection required by Tech Spec 4.5.2.d.2 is met.

Review Valid invalid Needed Date initiator: Pleniewicz, R. O O O st22ro7  ;

VT Lead: Bass, Ken O O O sr22/97 VT Mgr: schopfer Don K O O O S*7 1RC Chmn: Singh, Anand K O O O 9/27/97

)

Date:

INVAUD:

[

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR MP3-0196, does not represent a discrepant condition. The procedure and form as written are sufficient to satisfy the requirements of Tech Spec 4.5.2.d.2. The inspection of the CTMT sump for structural distress and abnormal corrosion is a general inspection to identify visible debris restrictions, material deformation and degradation of the sump components. While not explicitly required in the procedure, the final CTMT inspection at the end of an extended outage (including refueling) is performed and signed off by a senior licensed operator (see attached copies of SP 3612A.1-2 for RFO4 and RFOS). The training and operating experience required for an individual to become an SRO is extensive and comprehensive. In addition, an SRO is responsible to know good housekeeping practices and to recognize equipment degradation when it exists.

As an enhancement to SP 3612A.1, two changes have been Pnnted 5/19/981:53.17 PM Page 1 of 3 l

Northe:st Utilities ICAVP DR Ns. DR-MP3-0196 Millstone Unit 3 Discrepancy Report requested via DC1 Attachment 10, Feedback Form,

1. Specifically require the final CTMT close-out inspection be performed by an SRO;

2. Provide specific examples of structural distress and abnormal corrosion as defined in ASME XI,1986 to ensure consistency among SROs.

With the enhancements requested, any question regarding the training requirements necessary to perform the inspection should be dispelled.

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-MP3-0196, does not represent a discrepant condition. SP 3612A.1 is inspecting the CTMT sump for obvious deformation and degradation. It is part of the Operations department's responsibility to identify and correct poor housekeeping practices and equipment deficiencies. However, to enhance the procedure and ensure consistency among SROs, a change request has been submitted to the procedure group to specifically require an SRO be the responsible individual performing the final CTMT close-out inspection and to provide examples extracted from ASME XI,1986 for comparison. Significance Level criteria do not apply here as this is not a discrepant condition.

Revised Response:

Disposition:

NU has concluded that the issue reported in DR-MP3-00196 has identified a NON DISCREPANT condition. The procedure and form as written are sufficient to satisfy the requirements of Tech Spec 4.5.2.d.2. The inspection of the CTMT sump for structural distress and abnormal corrosion is a general inspection to identify visible debris restrictions, material deformation and degradation of the sump components. As an enhancement to SP 3612A.1, procedure and form change request SP 3612A.1, revision No.13, change No. 2 (attached) has been issued which adds a statement und6r 4.2.2.b," Sump Components (trash racks, screens, etc..) intact: No evidence of structural distress or abnormal corrosion. (For example: metal with evidence of cracking, pitting, excessive corrosion, gouges, surface discontinuities, dents, or other signs of surface irregularities)".

l In addition, the second Objective statement is correctly delineated in the attached for the visual inspection of the containment sump.

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

Conclusion:

Pnnted 5/19/981:s3:20 PM Page 2 of 3 l

l Norther _t Utilitie3 ICAVP DR No. DR-MP3-0196 Millstone Unit 3 Discrepancy Report  ;

NU has concluded tW Se issue reported in DR-MP3-00196 has I identified a NON D' * ' PANT condition. The procedure and form as written a ' .J., lent to satisfy the requirements of Tech Spec 4.5.2.d.2. 3 r.ispection of the sump for structural j distress and abnormal corrosion is a general inspection to J identify visible debris restrictions, material deformation and degradation of the sump components. As an enhancement to SP 3612A.1, revision No.13, change No. 2 (attached) has been issued which adds a statement under 4.2.2.b, " Sump Components (trash racks, screens, etc..) intact: No evidence.of structural distress or abnormal corrosion. (For example: metal with evidence of cracking, pitting, excessive corrosion, gouges, surface discontinuities, dents, or other signs of surface irregularities)".

In addition, the second Objective statement is correctly delineated in the attached for the visual inspection of the containment sump.

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

Previously identified by NU? O Yes @ No Non Discrepant Condition?ie) Yes O No Resolution Pending?O ve. (M)No Re.oiution unre.oived?O ve. (e3 No Review Acceptable Not Acceptable Needed Date M s R.

VT Lead: Bass. Ken VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/18/98 st Comnwnts: S&L concurs with NU's response and agrees that this is not a discrepant condition. The original proceddure did address the inspection of the CTMT sump. Changes to the inspection procedures enhanced it and prodived additional information.

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Northeast Utilities ICAVP DR No. DR-MP3-0204 Millstone Unk 3 Discrepancy Report Review Group: Programrnatic DR RESOLUTION ACCEPTED Discipline: Piping Design Potential Operability issue Discrepancy Type: Corrective Action Om System / Process: N/A gg NRC significance level: NA Date faxed to NU:

Date Published: 9/29/97 Discrepancy: Incomplete Nonconformance Report Package

Description:

1. NCR # 3-91-0018 deals with weld indications on the travelling screen wasn piping welds. The pipng had pin hole leaks. In an attempt to remove the defects, a cavity of approximately 6 inches by 3 inches was opened in the piping. The disposition was to weld repair the cavity without determining the extent of the remaining linear indications and porosity. The NCR states:

"The defects probably exist throughout the circumference of the welds."

Quality Control was to note any remaining indications after weld repair for information only. The disposition states that the weld defects were caused by the manufacturer and that the piping had been in service for approximately three years. No further justification for the disposition was provided.

2. No safety evaluation, environmental evaluation, safety evaluation screening or environmental screening was found in the package.

3. Parts of the NCR package are difficult to read. This does not meet the requirements of NU's commitment to NRC Regulatory Guide 1.88.

Review Valid invalid Needed Date initiator: sheppard, R. P.

8 0 0 S/15/S7 VT Lead: Ryan, Thomas J B O O S/1587 VT Mgr: Schopfer. Don K B O O 9/22/97 IRC Chrnn: Singh, Anand K B O O S/26/97 Date:

INVALID:

Date: 5/19/98 RESOLUTION: Disposition:

NU has concluded that DR-MP3-0204 does not represent a discrepant condition.

1) The disposition of the NCR states that " leaving the remaining linear indications will not detrimentally affect the structural integrity of the welded joint". No further technical justification is required in this case.

2) The nonconformance procedure at the time of the NCR did not require an environmental or safety screening,but required a safety evaluation if necessary. A safety evaluation was not Pnnted 5/19/981:53 45 PM Page 1 of 4

Ncrtheast Utilities ICAVP DR No. DR-MP3-0204 Millstone Un't 3 Discrepancy Report required as indicated on NCR form NEO 3.05, Rev 1. The proper evaluation was performed in accordance with applicable procedures.

3) Reg. Guide 1.88 concems storage and maintenance of records. The copy of the NCR reviewed is stored and maintained in NDS records on microfilm. Any reduction in legibility of the hard copy provided is due to the reproduction process. The NCR on microfilm is both legible and maintained in accordance with the requirements of Reg Guide 1.88. A legible copy of NCR 391-018 is being transmitted with this IRF.

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

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0204 does not represent a discrepant condition. As detailed in the disposition, adequate technical justification was provided in this NCR, a proper evaluation of this NCR was performed in accordance with applicable procedures, and NU's records comply with Reg Guide 1.88. Significance level criteria do not apply as this is not a discrepant condition.

NU's 2nd Response:

Disposition:

NU has concluded that this issue reported in DR-MP3-0204 has identified a NON-DISCREPANT condition. The disposition of the NCR is acceptable. The leak tight condition was assured by functional verification (See M3-90 04332). Only the surface of the weld is required to pass a visual examination. The indications in the interior of the weld are not relevant. The minimum code requirements for this pipe have been satisfied.

The NU piping class for this pipe is 153. This pipe is Class 4 and the weld repair satisfies the requirements of ANSI B31.1.

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

The subject NCR was written to address pin hole leaks from weld joints on pipes 3SWT-016-35-4 and 3SWT-016-47-4. The pin holes in the welds were ground and revealed linear indications and arosity that continues through the welded joint. Chasing the avfects did not remove them.

The following justifies that the condition of the subject welds are acceptable.

The pipes in question are Non-Safety Class 4 lines

. Since the subject pipes are Non-Safety Class 4, they are considered acceptable by passing the visual examination in accordance with ANSI B31.1. Specific weld criteria requirements are stated in ANSI B31.1, it is only required that the welded joint extemal surface be examined and free of injurious defects such as cracks. undercut, lack of fusion.

Pnnted 5/19/981:s3 A9 PM Page 2 of 4

N:rthert Utilities ICAVP DR N . DR-MP3-0204 Millstone unit 3 Discrepancy Report incomplete fusion (only when inside is accessible) [B31.1, Section 136.4.2]. Therefore, the presence of porosity below the extemal surface is inconsequential.

The repair of the weld defect was performed to the same procedure as the original welds [B31.1, Section 127.4].

Therefore, the fact that indications were welded over is irrelevant. The surfaces to be welded are required to be clean and free from paint oil rust or other material which is detrimental to welding.

Conclusion:

NU has concluded that this issue reported in DR-MP3-0204 has identified a NON-DISCREPANT condition. The disposition of the NCR is acceptable. The leak tight condition was assured by functional verification (See M3-90-04332). Only the surface of the weld is required to pass a visual examination. The indications in the interior of the weld are not relevant. The minimum code requirements for this pipe has been satisfied.

The NU piping class for this pipe is 153. This pipe is Class 4 and the weld repair satisfies the requirements of ANSI B31.1.

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

Attachments: None Previously idenufled by NU? O Yes @ No Non D6screpent Condition?@ Yes O No ResolutionPending?O yes @ No Resoiuiion unr..oiv.d?O ve. @ No Review i Acceptable Not Acceptable Needed Date initiator: Sheppard, R. P.

VT Lead: Ryan, Thomas J O O O 5' S'S8 O O S'S'S8 VT Mgr: Schopter, Don K IRC Chmn: Singh, Anand K G O uts/98 O O O Date: 5/19/98 sL Comments: Review of NU's 1st Response:

1. The resolution of item 3 of this discrepancy is acceptable.

2. The visual weld inspection plan lists ANSI B31.1 as the design code for this piping. Paragraph 127.4.11 of ANSI B31.1-1973 requires that the type of examination and the limits of imperfections for repair welds shall be the same as for the original I weld. Paragraph 136.4.2 of B31.1 requires that visual examination consist of observation of whatever portions of a component or weld are exposed to such observation, either before, during or after fabrication. It further requires welds and l j piping have no extemal cracks or meet the limitations of the I piping material specification. A-312-72a, section 12, requires that pipes be reasonably free from injurious defects.

Leaving the linear indications in the pipe without repair appears to be a design change. Section 6.2.2 of NEO 3.05, Revision 1, states that a disposition to correct an inadequate design should Pnnted 5/19981:53.50 PM Page 3 of 4

l Northe:st Utilities ICAVP DR Nr. DR-MP3-0204 Millstone Unit 3 Discrepancy Report l include a requirement to change the design or the NCR should l reference a design change document.

3. NU's response states that the NCR indicates that a safety evaluation was not required. Possibly the reference is to a "SSH Evaluation" not being required. Substantial Safety Hazards (SSH) are defined in 10 CFR 21.3 and the evaluation to i determine whether a deviation or failure to comply could cause or l be associated with a SSH is not necessarily related to safety l evaluations. If in fact the design was changed by this NCR, a

design change should have been processed which would have l

evaluated the safety and environmentalimplications of the l

change.

NU is requested to provide further information Justifying the adequacy of the pipe and its compliance with the licensing bases.

l Review of 2nd Response:

l NU provided a copy of Technical Evaluation M3-EV-98-0103, Rev. 00, titled " Disposition and Technical Justification Evaluation of NCR #391-018 issued May 14,1998. This together with information presented in the 2nd Response and a telecon shows I that the original welds had porosity, and not linear indications visible on the surface prepared for the weld repair. The repairea weld was visually inspected and was acceptable. Thus the welding met ANSI B31.1 1973 and no safety or environmental evaluation was required.

l Pnnted 5/19/981:53:51 PM Page 4 of 4 l

l l

Northe st Utilities ICAVP DR N2. DR-MP3-0409 Millstone unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Correct!ve Action Process p

Discipline: Mechanical Design Discrepancy Type: Correctwe Action Om SystemProcess: Oss gg NRC Signincance level: 4 Date faxed to NU:

Date Published: 11/13/97 Discrepancy: Incomplete Evaluation Package for Material Condition l

Description:

The resolution of ACRs regarding rust found in stainless steel piping and support connections lacks sufficient justification.

ACRs M3-96-0301 and 013789 evaluate ruct found on stainless l steel piping and on connections with a support and a saddle. In ACR 013789 rust was not found on similar equipr icnt fabricated from the same materials located in close proximity in a similar environment. The evaluation for the ACRs stries that rust is not unusual on stainless steels in a humid environment and is most pronounced in areas which have been heavily Ground. In addition, the evaluation states that a complete welding material document review was conducted prior to the N-5 Code Data Repnrt certification. Finally, reference is made to a study by Dravo Corporation during the construction of Unit 2 which concluded that the rust was strictly a surface condition.

While rust on stainless steels may be a surface condition, we do not agree that the ACR evaluations support this conclusion for the conditions described nor do we see the connection to the I heavy grinding based on the information provided. We  !

recommend that the conclusion be verified by some positive means such as removing a small area of the rust with a flapper wheel. Altemately, a copper sulfate test could be used followed by an appropriate flushing.

The lack of sufficient justification to support the conclusions reached, represents a discrepant condition in the resolution or the subject ACRs.

Review Valid invalid Needed Date initiator: sheppard, R. P. O O O 15'3'87 VT Lead: Ryan. Thomas J B O O 5t/*S7 VT Mgr: schopfer, Don K O O O 11/7/S7 BRC Chmn: singh, Anand K O O O 15/7/S7 Date:

INVALID:

Date: $/4/98 RESOLUTION Disposition:

NU has concluded that this issue reported in DR-MP3-0409 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. ACRs M3-96-0301 and 013789 (References 1 and 2) both discuss the finding of " red rust" on stainless steel piping and/or pipe supports. For the purposes of Pnnted s/19/981:s428 PM Page 1 of 4

Northert Utilitica ICAVP DR No. DR-MP3-0409 Millstone Unit 3 Discrepancy Report this discussion stainless steel is understood to mean a 300 series stainless steel, i.e. type 304 or type 316. This rust was noted on welds or adjacent to welds. As noted in the earlier response to DR-MP3-0409, the fmding of red rust on stainless steel is not a new issue. The observation of red rust on " stainless" steel has been an industry issue for a long time. 300 series stainless steel have about 18% chromium and 10% nickel which under most ambient atmospl.eric conditions will prevent oxidation. However as the ACRs indicate some rust does appear under certain ,

circumstances, particularly after welding. As indicated in Reference 3, current and past personnel of the NU Welding & ,

Materials Engineering group have been queried about this " rust" )

for over 14 years. This time period includes some of the {

construction of Millstone Unit 3. The author of Reference 3 was one of the NU welding engineers during much of the construction of Millstone Unit 3.

Similar concems also had surfaced during the construction of Millstone Unit 2. The A&E for Millstone Unit 2 (Bechtel),

contracted with one of the piping suppliers, Dravo, to perform a j study of the causes of rust on stainless steel weldments  !

(Reference 4). This study was done in 1970. The experimental plan for this study was to make up a number of butt welds with 6" type 316 pipe using the three weld processes generally used in j shop and field fabrication ( MIG, TIG, and SMA). The surfaces '

of each of these welds was then wire brushed and passivated l with 10% nitric acid or contour ground or left in the as-welded condition. The ends of the pipe were also cut with either an abrasive saw or a lathe to evaluate if these cutting methods had i any influence on the " rusting". The samples were left outdoors to weather for a month. The Dravo facility where this work was done was in Marietta, GA. The laboratory investigation of these samples include not only visual examination but also metallographic sectioning. The findings of this Dravo study were that:

1. The rust was a surface phenomena and had no depth.

2. There was no relationship between microstructure and the

" rusting".

3. The abrasive cutting almost always led to " rusting".

4. Occasional rust was noted with the wire brush plus passivation.

Numerous other articles can be found in the literature on the subject of surface treatments for stainless steel and how their effect on corrosion performance. Several of the factors that can lead to " rust" are excessive grinding and embedment of carbon steel during wire brushing. References 5 and 6 are two articles that discuss these two causes. The walkdowns discussed in Reference 3 were done by personnel familiar with the research discussed above. The " rusting" observed was always on welds l or adjacent to them.11 was concluded that " rusting" was from the

( same causes as discussed in the Dravo report and other articles since it was on the same materials and had been fabricated by welding. In particular many of the welds were prepared for inspection and had therefore been ground smooth. No further investigation was needed since the observations so closely matched the " text book" and were done by personnel with the Pnnted 5/19/981:54 31 PM Page 2 of 4

1 Norther _st Utilities ICAVP DR NA DR-MP3-0409 l

Millstone Unit 3 Discrepancy Report {

appropriate technical expertise (i.e. welding engineers). Since grinding may have been the cause of any " rusting", further flapping or grinding would only have made the condition worse.

The approved corrective action plan for CR M3-98-1916 links the following documents in Passport: ACR M3-96-301, ACR 013789, CR M3-98-1916, DR-MP3-0409 and IRF M3-IRF-02152. Also, the approved corrective action plan for CR MP3-98-1916 states this linking of documents has been done and IRF M3-IRF-02152 provides an expanded discussion for the resolution of ACRs M3-96-301 and 013789. This corrective action will be completed after startup.

References:

1. ACR M3-96-0301, " Rust was noted on Stainless Steel Pipe (

UIR 734)",6/28/96.

2. ACR 13789, " Rust on Weld between Stainless Steel Pipe and Stainless Steel Saddle", 5/25/96.

3. CES-96-219, A.J. Silvia to T. J. Calzetta and T. J. Mawson,

' Rust on Austenitic Stainless Steel",6/24/96.

4. Letter from W. A. Molvie (Dravo Corporation) to J. Trudeau (Bechtel Corporation), " Stainless Steel Weld Study", 9/29/1971.

5. " Fabrication and metallurgical experience in stainless steel process vessels exposed to corrosive environments", Avery, R.

E. and Moller, G. E., Nidi Technical Series No.10 026.

6. " Cleaning, Pickling, and Passivation of Stainless Steei",

Dillon, C. P., Material Performance, May,1994.

Conclusion:

NU has concluded that this issue reported in DR-MP3-0409 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. The resolutions to ACRs M3-96-301 and 013789 lack sufficient justification as to why rust formed and is acceptable on a segment of stainless steel piping and a pipe hanger. The approved corrective action plan for CR M3 1916 requires the resolutions to both ACRs be linked to include the technical information and references presented in this DR.

The corrective action will be completed after startup.

Attachments:

CR M3-98-1916 with approved correction action plan / References 4,5, and 6 noted above.

Page 4 of 4 Previously identifled by NU? O Yes (S) No Non Discrepant Condition?Q Yes @) No l

Resolution Pending?O Ye. @ No Resduuon Unresolved?O Ye. @ No Review initiator: sheppard, R. P.

VT Lead: Ryan, Thomas J Printed 5/19f981:s4:33 PM Page 3 of 4

N:rthert Utilities ICAVP DR No. DR-MP3-0409 Millstone Unit 3 Discrepancy Report v i s.wesu, ny.i.,i,y, y VT Mgr: Schopfer, Don K O O Si m IRC Chmn: Singh, Anand K B O O stim O

Date:

SL Comments:

Printed 5/19/981:54:34 PM p, 74

Northert Utilities ICAVP DR ND. DR-MP3-0461 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Corrective Acton Process p

Discipline: Other Discrepancy Type: Component Data Om System / Process: N/A

($ No NRC Significance level: 4 Date faxed to NU:

Date Published: 1o/31/97 Discrepancy: Numerous Deficiencies .a Production Maintenace Management System (PMMS)

Ds acription: The ICAVP includes review of proposed corrective actions for various UIRS. Our review has noted a trend in that there are numerous UIRs (at least 74) which identify deficiencies related to PMMS data inconsistencies with the plant design drawings and/or plant labeling. The number of components with reported PMMS data deficiencies is considerr2ble. Some individual UIRs list over 100 components where deficient PMMS data has been identified, on safety related systems such as the Class 1E Emergency Diesel Generators. Taken individually, the final disposition of each UlR to *fix" the discrepancy is considered acceptable, however the aggregate eifect of such a large number of deficiencies in the PMMS system in conjunction with ,

the management's decision to resolve these items post startup i requires generic consideration.

RFI M3-RF1-00402 requested a basis for categorization of the resolution of PMMS deficiencies as non-startup (This RFI listed a small sample of PMMS-related UIRs) . The response to RFI 402

{.RF 415) has been reviewed, and it did not provide the required information.

There was no basis or supporting justir :ation provided as to why the aggregate of all PMMS deficiencies discovered to date does not represent a safety concem warranting resolution prior to startup. The RFl response implies that NUs initiative to correct the deficiencies is justification for NUs determination that such deficiencies "were not considered required for restart".

Justification is needed to establish that the existing errors in PMMS will not pose a safety concem for maintenance activities or other plant operations after startup. Appropriate justification l could involve a description of the use of the various fields in the l

database, how they affect safety-related activities, and the effect the errors would or would not have on plant operations.

Review Valid invalid Needed Date initiator: Navarro, Mark O O O tor 21/97 VT Lead: Ryan. Thomas J B O O sor25/97 VT Mgr: schopfer. Don K O O O o/23/97 1RC Chmn: singh. Anand K O O O tor 28m7 Date:

INVALID:

Date: 5/19/98 RESOLUTION: Disposition Pnnted 5/19/981.55:02 PM Page 1 of 6

Northext Utilities ICAVP DR N2. DR-MP3 4461 l Millstone unit 3 Discrepancy Report l

NU has concluded that the issues reported in DR-MP3-0461 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

Historical Review OThe PMMS Program has undergone many reviews and upgrade initiatives over the last two years. Looking back at past performance, CR M3-97-0287 corrective action plan addressad the correctness of quality designations and the use of non-QA parts in QA equipment or systems. This was addressed by starting with a review of Attachments 6 and 7 of OP 3260A, Conduct of Outages, and identifying all the components credited for defense in depth. The review identified 545 active components which required review. Excluded from further review were 152 components which either 1) had a recent parts level BOM/MEPL completed,2) had no BOM or 3) had a BOM with all QA parts. The remaining 393 components were reviewed to ensure Non-QA parts / materials were appropriately classified based on the origina; design basis component criteria. For each major component and inline component with "N" or "U" PMMS Q designators, an evaluation was made to determine the correctness of the designation. A work history review of active and closed AWOs for these components was also made to ensure that no parts with an inappropriate Q designation had been used in the past. This review was documented iri Technical Evaluation MS-EV 970009 and Operability Determination MP3-010-97. The conclusion of this review was that the existing parts / materials installed in the field are adequate and no defense in depth safety system functions are compromised. A further review was made of the adequacy of installed parts and materials associated with QA Category 1 Automated Work Order (AWO) maintained plant components identified as of January 1997 in the PMMS with parts identified with QA CAT 1 as *N' and "U" without a valid MEPL evaluation referenced in the BOM. This is documented in Technical Evaluation M3-EV-980022. Of 14,906 parts reviewed, only 3 discrepancies were iderdified. These were detailed in section 3.0 of the Evaluation.

NCR 397-010 was initiated on January 24,1997 and documented that numerous part safety classifications had been changed from "U" or *N' to "Y" in order to be consistent with current parts level design philosophy as reflected in current industry standards and recently approved MP3 Generic Parts MEPL Evaluations. The NCR addressed the upgrade of parts associated with approximately 2400 components. The Operability and Deportability Determination for the reclassification of these parts was documented in CR M3 0287 and ACR M3-96-1442. The associated Operability Determination concluded that the installed parts are considead operable because programmatic measures have provided reasonable assurance that parts installed to QA components during maintenance meet the technical requirements for the application. However, the review and justification done under NCR 397-010 did not include a w.o history and/or procurement documents to ensure any replacement parts used were procured to the oriainal specifications. Subsequently another Technical Printed 5/19/981:55 05 PM Page 2 of 6 I

Nrrthext Utilitie3 ICAVP DR N2. DR-MP3-0461 l Millstone Unit 3 Discrepancy Report Evaluation, M3-EV-980086, was performed which included the work history review for the components identified in NCR 397-J 010. Four CRs were written to document parts issues identified j in the Evaluation. The results of the maintenance history reviews substantiate the conclusions reached in NCR 397-010, associated Condition Reports and Operability Determinations.

While in some cases the parts identified in the NCR lack full dedication documentation, there is reasonable assurance that parts installed during maintenance activities meet their technical requirements for the application. During the CMP Project a horizontal system readiness review was performed for maintenance rule systems. These reviews involved system walkdowns as well as documentation reviews for any inadvertent design changes or inappropriate parts or material substitutions used in Q equipment. The following historical documentation from initial startup to the time of the system readiness review was evaluated:

AWOs- Open and Closed Design Changes NCRs Trouble Reports Maintenance Rule implementation j EWRs .

Bypass / Jumpers Operability Determinations /JCOs Control Room Panel Deficiencies Operator Burdens Pre-Outage Work List items j Rejected OSCRs A/Rs ACRs Punch List items LERs Abnormal Plant Conditions List Long Standing System issues UIRs Startup Items Miscellaneous issues These 50.54f System Readiness Reviews have beba forwarded previously under transmittal number 3,1/10/97, from the ICAVP project. Additionally, a Vertical Slice Review was done of 11 systems picked based on PRA significance, coverage of known outstanding issues, inclusion of fluid / mechanical components / systems, electrical and l&C systems important to FSAR safety analyses and engineering l judgment. This selection process resulted in a representative l number of fluid, electrical and I&C systems including six systems l which appeat in core damage sequences which contribute to j approximately 85% of the calculated core damage i frequency (CDF). The accuracy and conformance of system documentation with the as-built configuration and the licensing and design basis were established by taking a vertical slice I through the design and licensing documentation for several key attributes of each system to assess design control, configuration control and complementary procrams. This effort included  ;

Pnnted 5/19981:55:06 PM Page 3 of 6 l

Northe:st Utilitie ICAVP DR No. DR-MP34451 Millstone Unit 3 Discrepancy Report examining: 1) selected parts of key design, licensing and operating and maintenance documentation and drawings, and 2) the results of application of the design and configuration control processes. This effort also included selected walkdowns of the systems to confirm configuration, particular1y when changes have been made since startup, and to identify and confirm system and component attributes. Neither the Vertical Glice or System Readiness Reviews uncovered any significant issues associated with non-Q parts being used in Q components.

During the MP3 Component MEPL Project conducted during 1996-1997,100% of the components in the PMMS database were reviewed. Several thousand nonvalid ids were eliminated and approximately 4000 new component ids were added.

Generally, safety related components found on draviings and augmented Quality components which have maintenai.ce performed have been added to the database. Those sub-components / parts which do not get maintenance separate from the whole cortponent would not be listed in the database. Non-safety related components are not in the database unless they i receive periodic maintenance or have received corrective {

maintenance in the past. I The Inte0 rated Preventive Maintenance Program has reviewed the existing preventive maintenance activities for selected systems, based on safety related and safety significant components, to ensure that all vendor re7.mmended maintenance has been evaluated along with maintenance hMory and failure reviews, and that the required maintenance activities are being performed. The maintenance requirements begin with the component, safety function and vendor recommendations from the vendor's manual. A historical search of maintenance history as well as a commitment search covering documents such as procedures, FSAR, AWOs, LIST, etc., was made to identify additional needed tasks. Over eight thousand tasks were I reviewed and/or identified for Millstone Unit 3. Less than 15% of j these tasks were additions to the existing PM program. Most of the changes to the program have been to standardize frequencies and replace time based maintenance with condition checks. Activities such as vibration monitoring and more frequent tube oil sampling have been recommended. Any components requiring maintenar'ce whose component ID was not in PMMS would have been added. Preventive Maintenar'ce requirements did not begin with existing component ID numbers so that it is unlikely that there are safety related components which do not get the required maintenance because the component ID is not in PMMS. The " components" which are not listed in PMMS tend to be sub-components which do not receive maintenance individually but as part of an assembly which will have a component ID; or the sub-component is worked on a

" loop" level and again the maintenance is performed on the entire assembly or loop.

Historically, another area of concera has been inconsistent nomenclature relative to PMMS ids. in general this has been a concem in the electrical area particularly with protective relays.

The relays are set and maintained by the Generation Test Services Group (GTS) which beaan their maintenance and Pnnted 5/19/981:55:07 PM Page 4 of 6

(

Northert Utilitie3 ICAVP DR NA DR-MP3-0461 Millstone Unit 3 Discrepancy Report calibration prior to PMMS being utilized at Millstone. The procedures utilized by GTS prior to startup had a numbering scheme used throughout the NU system which contained compononts that would indicate type device, the frequency of calibration, the voltage level or system source, the location / cubicle / power source and the device number of the relay. This numbering schame continues to be used and the numbers are in the PMMS database, though they do not show up on design drawings. There are long term plans to correct this but it does not pose a safety concem since the relay calibration and maintenance is performed exclusively by GTS and the numbering scheme is well understood by that group.

Current Process and Going Forward The current process has been mapped to identify work flow and interaces. Those areas considered weaknesses are work control / parts control, scheduling and post maintenance testing.

Process improvements have included enhancement of the

following procedures

0 Procedure Title l OWC-100000 Work Control Process 0 WPC-20000AWO Preparation and Scheduling OWC-1600000 Engineering Program Indicators l NUC MPM 1.00000 Requesting items and Services l WPC-30000 Post Maintenance Testing l

NGP 6.100000Use of PMMS Database to indicate Quality Assurance and 000000 Engineering Program Applicability EP-ST-ME-944000 Standard Specification for Material Equipment Parts List 000000for Inservice Nuclear Generation i Facility MEPL Program All of the above procedures have either been developed, revised or are in the process of being changed to enhance the Work l Control Process.OO 3

As a result of the Corrective Actions to CR M3-98-0407, the Q and augmented Q components go through a design verification )

t down to the BOM level. Each piece /part must be verified for Q

[ level and correctness for it's intended fanction/end use. This is performed by the 3Config alert group which has members from Design Engineering. The 3PTIA alert group ensures that the MIMS database and warehouse inventory are correct. The i validation of Q parts in tied to design source documents. If not l previously done, parts get  !

l validated prior to release from the warehouse to ensure that the  !

j part is correct for it's intended end use. Non-Q components

! have their narts validated at a lower level. All non Q parts are  !

! validated prior to being placed on a BOM.

Long term changes planned for Millstone is to go to a single station work management process to apply to all units. This will include the migration of PMMS data into the Passport Work / Material / Data Screens. When the transition is complete the integrated system will be comprised of Action Tracking, Materials Management, Engineering Change Control and Component Data, Work Management, Records Management i and Controlled Documents and Contract and Project Printed 5/1998 ts5:08 PM Page 5 of 6 l

E-----_____________

Northent Utilitie3 ICAVP DR NO. DR-MP3-0461 Millstone Unit 3 Discrepancy Report  !

Management.

The completion of the transition for all the programs into Passport is scheduled for the first quarter of 2000. Nuclear indicators and program indicators have the priority for being moved to Passport and validated. The project is in it's very early I stages and all procedures and plans for the transition have not been finalized. Many procL%:s in the work control area will be i consolidated into few which will serve all units. The commitment and funding of the Integrateri information Managerr.ent Strategy has been provided by senior musgement to facilitate long term improvement and increase efficiency.

I NU considers the changes described above to be enhancements to tho process which will eliminate confusion and errors and therefore that this is a significance level 4 discrepancy. q Conclusion NU has concluded that the issues reported in DR-MP3-0461 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Based on the Technical Evaluations performed during the 50.54f process, M3-EV-970009, M3-EV- l 980022 and M3-98-0086, and the results of the Vertical Slice and System Readiness reviews there is reasonable assurance that i the components installed in Q and augmented Q equipment are fully capable of performing their intended safety function and that the effected equipment is fully operable. The PMMS program and Work Control Process are undergoing enhancements which will increase efficiency and effectiveness.

These changes are long term improvements and do not effect the design orlicensing basis.

Previously identified by NU? O ves @ No Non Discrepant Condition?O ves @ No Resolution Pending?O ves @ No Resolution Unresolved?O yes @ No Review l Initiator: Navarro, Mark VT Lead: Ryan, Thornas J VT Mgr: schopfer, Don K IRC Ctann: singh. Anand K Date: 5/19/98 SL Comments: NU's response confirms that despite errors and inconsistencies )

which were found in PMMS. mistakes in plant maintenance and operations activities which would pose a safety concem did not occur. In addition to NU's short term and long term improvements (completed or being implemented in PMMS), NU has made and is implementing process improvements which will provide further assurance that no safety concems will exist for maintenance and operatioas activities as they relate to the use of PMMS on a going-forward basis. (See also NU's response to DR-MP3-1004).

Printed 5/1&991:55:09 PM Page 6 of 6

Northert Utilities ICAVP DR N3. DR-MP3-0563 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Test Procedure Discipline: Operations Yes Discrepancy Type: Licer. sing Document System / Process: sWP NRC Significance level: NA Date faxed to NU:

Date Published: 11/24/97 Discrepancy: Service Water Pump Testing inconsistent with FSAR Requirement

Description:

Service Water Pump Testing inconsistent with FSAR Requirement FSAR Section 7.3.1.1.5 states:

"The service water system is periodically 16sted in accordance with the Technical Specifications.

"This testing will consist of manually starting the pump during normal surveillance of L'ne system or the breaker for the pump will be in the test position. Once the pump is running or the breaker is in the test position, the AUTO start and tripping is verified using the emergency generator load sequencer with safety signals generated intemally or extemally to the sequencer."

The following two surveillance that test the operation of the service water pumps were reviewed to confirm that the above requirements were being satisfied, SP 3626.4, " Service Water Pump 3SWP*P1 A Operational Readiness Test" (including j checksheet OPS Form 3626.4-1) and SP 3646A.18," Train B ESF With LOP Test (IPTE)". No evidence could be found to confirm that the requirements were being met. Neither procedure documents a manual start of the pump. Page 2 cf SP 3626.4 (Basis Document edition) states in the Basis information block on page 2 that:

"This procedure provides for two sequencer starts and eliminates the manual start from the control room. No written requirement for a manual start has been found checking the FSAR and the ISI manual. The conclusion has been made that a manual start is not necessary since the pumps are started for other reasons during the month. If a manual start is needed, credit can be taken for pump C in this procedure and for pump A in 3626.6, since the pumps are started to switch lineup."

Our interpretation of the FSAR requirement is to manually start the pumps so that the AUTO trip function and sequencer loading on the EDG can be verified. Both procedures test the AUTO start of the pumps on the load sequencer but do not test the AUTO trip function.

l Additionally, a review of the OPS forms associated with these procedures indicate that change of pump operating states are not documented.

l Pnnted S/19/981:s5:33 PM Page i of 4

Northe:t.t Utilitie3 ICAVP DR No. DR-MP3-0563 Millstone Unit 3 Discrepancy Report It was also noted that the FSAR requirement that the pumps be started manually or that the breaker for the pump be in the test position are not equivalent actions. The equivalent action to a manual pump start would be to place the breaker in the test position and close the breaker.

The testing currently performed does not adequately demonstrate that the FSAR requirements are being satisfied.

Review Valid invalid Needed Date initiator: Tomtyn, Tom O O O 10/3 '87 VT Lead: Bass, Ken G O O 1o'31/87 VT Mgr: Schopfer, Don K O O ' /S'97 O

IRC Chmn: Singh, Anand K O O O 11/19'S7 Date:

INVALID:

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0563, 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 concerns and meets the Unit 3 deferral criteria. CR M3-98-0167 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3 0563, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the critena 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 M3-98-0167 has been written to develop and track resolution of this item per RP-4.

Revised Response:

Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0563, has identified a NON-DlSCREPANT condition.

The issue raised in this DR is that the Service Water System is not being tested in accordance with the Technical Specifications requirements or the statements made within FSAR Section 7.3.1.1.5. Technical Specifications testing requirements are provided under the surveillance requirements of section 3/4.7.4

" Service Water System." Part 't." is not applicable to this discussion or the issue reported in this DR. Part "b" requires that at least once each refueling interval the following be verified:

Pnnted 5/19/981:55:36 PM Page 2 of 4

ICAVP DR N2. DR-MP3-0663 N:rthert Utilitie3 l Millstone Unit 3 Discrepancy Report 1)DEach automatic valve servicing safety-related equipment actuates to its correct position on its associated Engineered Safety Feature actuation signal, and l

2)CEach Service Water System pump starts automatically on an SIS test signal.

Work performed in response to Generic Letter GL 96-01 verified that the surveillance procedures SP 3626.4 " Service Water Pump 3SWP*P1 A Operational Readiness Test", SP 3646A.15

" Train A Loss of Power Test (IPTE)", and SP3646A.17 " Train A ESF With LOP Test (IPTE)* are in compliance with and meets Technical Specifications testing requirements. Surveillance procedure SP 3626.4 tests the diesel lo 4 sequencer and pump logic twice, once with the " LEAD /FOLLC /* selector switch, selected to the " FOLLOW" position and once with the selector switch selected to the " LEAD" position to verify the different logic combinations for starting the A Train Service Water Pump configuration . Additionally, surveillance procedures SP 3646A.15 and SP3646A.17 verify the proper operation for starting and tripping the A Train Service Water Pumps under simulated loss of power conditions and loss of power conditions coincident with an Engineered Safeguards Feature actuation signal respectively. These three surveillance's together demonstrated the ability of the A Service Water Pump to perform it's intended safety function upon receipt of an SIS actuation signal and fulfills Technical Specifications testing requirements. The above discussion is applicable to the B Train Service Water Pumps.

Technical Specifications do not require the Service Water Pumps to be manually started. Although, not required by Technical Specifications it is reasonable to assume that the Service Water Pumps will be started manually at least once from the control room during a refueling interval.

NU's interpretation of the FSAR statement "This testing will consist of manually starting the pump during no.Tnal surveillance of the system or the breaker for the pump will be in the test position" to mean that once the pump and pump circuitry has been verified to be operable from the logic cabinet up to and including starting of the pump at least once,it is permissible to place the breaker in the test position. This allows tecting of the logic up to and including the breaker without starting the pump for each logic combination since the pumps have a starting limitation that needs to be observed. Generic Letter GL 96-01 permits this methodology since circuit cordinuity and operability have been verified between the logic cabinet and Service Water Pump. Although, the FSAR statement may be considered 1 potentially ambiguous, it does not represent an operability or I deportability concem nor does it affect the design and licensing basis. NU has concluded that the current surveillance procedures are in accordance with Technical Specifications testing requirements.

Printed 5/15V981.55:37 PM Page 3 of 4

Northeast Utilitie3 ICAVP DR Nr. DR-MP3-0563 Millstone Unit 3 Discrepancy Report Significance Level criteria do not apply here as this item is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0563, has identified a NON-DISCREPANT condition.

Technical Specifications testing requirements are being fulfilled by the performance of SP 3026.4,3646A.15, and SP3S46A.17 for the A Service Water Pump and similar procedures for the other pumps. These three surveillance's demonstrated the operability of the A Service Water Pump to perform it's intended safety function upon receipt of an SIS actuation signal while fulfilling Technical Specifications testing requirements. Additionally, Technical Specifications do not require the Service Water Pumps to be manually started. It's also reasonable to assume that the Service Water Pumps will be started manually at least once from the control room during each refueling interval. NU has concluded that the current surveillance procedures are in accordance with Technical Specifications testing requirements.

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

Previously identified by Nu? O Yes (#1 No Non Discrepant Condition?@) ves O No Resolution Pending?O ve. @ No Re.osution uore.oived70 ve. @ No Review

• • d

• initiator: Spear R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/18/98 sL Comments: S&L does not concur with NU's determination that this discrepancy meets the Unit 3 deferral criteria. The DR identifies a discrepancy between the FSAR and plant procedures which have a direct impact on plant safety and operation.

S&L concurs that this is not a discrepant condition based on the additionalinformation supplied by NU. The intent of the FSAR section is to test the AUTO start and tripping functions not the manual starting function.

Pnnted 5/19/981:55:39 PM Page 4 of 4

Northe st Utilitiea ICAVP DR N3. DR-MP3-0638 Millstone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Operating Procedure Discipline: Operations Discrepancy Type: Test implementation Om SystemProcess: SWP gg NRC Significance level: 4 Date faxed to NU:

Date Published: 11/24/97 Discrepancy: Surveillance program does not assure that all SWPs are tested for all operating requirements.

Description:

Technical Specification 4.7.4.a.2 requires that "Each Service Water System pump starts automatically on an SIS test signal."

It could not be determined that the existing surveillance tests assure that this requirement is met. SP 3646A.15, SP 3646A.17, OPS Forms 3646A.15-1 and 3646A.17-1 are used in conjunction to verify that both service water pumps in Train A are started automatically with an SIS signal. Ideally OPS Form 3646A.15-1 tests pump A and OPS Form 3646A.17-1 tests pump C.

At the bottom of OPS Form 3646A.15-1, page 2, note 2 states that "3SWP*P1 A should be the lead pump. If 3SWP*P1 A is not available, select 3SWP*P1C as th.: lead pump and ensure 3SWP*P1 A is the lead for SP3646A.17 or is documented on 3646A17-2 as requiring a retest when it is available." It is not apparent how this requirement is followed through since there is no requirement on OPS Form 3646A17-1 to test the opposite pump. The only notation is "If possible, the SW pump not tested in lead during SP3646A.15 should be lead pump." This doesn't j reflect a requirement to verify and document. Neither SP3646A.15 or SP3646A.17 list the completion of the other as a prerequisite so the order of performance isn't required to assure that equipment isni missed.

OPS Form 3646A.15-1 (16-1,17-1,18-1) footnotes suggest that a specific pump be made the lead pump for the test but the form does not provide a place to document that this requirement is met. Footnote 2 on OPS Form 3646.17-1 states that "If possible i the SW pump not tested in lead during SP3646A.15 should be I lead pump." The same footnote on the corresponding procedure f for B train states "The SW pump not tested in lead during  ;

SP3646.16 must be lead pump." These two requirements are I not equivalent.

A review of the test results of SP 3646A.15,16,17 and 18 and their associated OPS Forms 3646A.15-1,16-1,171 and 18-1 for the period 5/96 through 7/96 reveal the following:

No requirement exists that all equipment associated with a specific test is to be available prior to performing the test.

Testing prerequisites are not specific regarding system l alignment. The SPs are mute on prerequisites for SWP status and leaves the decision on which pump should be running to the test director based on footnotes on the OPS Forms.

Annroc nn fnrme that nra inhalad "thllTIAl " havn hann charind Printed 5/19/981:56:06 PM Page 1 of 4

l N:rthert Utilitie3 ICAVP DR N . DR-MP3-0638 i

Millstone unit 3 Discrepancy Report in some instances and initialed in others. However, the test was l accepted and approved as satisfactory.

l SP 3646A.15,16,17 and 18 are also used to satisfy the sequencing of equipment following a loss of off site power (TS 4.8.1.1.2.G.4 (6)). The testing does not require that any pump is in " follow" and therefore the testing does not demonstrate that the " follow" pump will start if the " lead" pump fails to start.

Review Valid invalid Needed Date initiator: Tamlyn, Tom O O O 11/6/97 VT t. sad: Bass, Ken 0 0 0 11/5/87 VT Mgr: schopfer. Don K 1 / o'S7 O O O IRC Chmn: singh. Anand K O O O 1 /19/87 Date:

INVALID:

1 l

Date: 5/15/98 RESOLUTION: NU has concluded that Discrepancy Report DR-MP3-0638, has identified a condition not previousiy 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 M3-98-0169  !

has been writ 9n to develop and track resolution of this item per I RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0638, 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 reportabiiity concerns and meets the Unit 3 8ferral criteria. CR M3-98-0169 has been written to develop and track resolution of this item per RP-4.

Revised Response:

Disposition:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0638 have identified CONFlRMED SIGNIFICANT LEVEL 4 conditions which require correction. NU has concluded that review of the test results of SP 3646A.15,16, 17, and 18 and their forms identified in the original DR have identified conoitions not previously discovered by NU which require correction. These discrepancies meet the criteria

! specified in NRC letter B16901 and 17010. NU believes that the I assignment of priority 4 is correct and in accordance with U3 PI l 20 section 1.3.2.e. The corrective pla 1 for CR M3-98-0169 has l been written to review the test results and clarify the procedures l as required. The test results issues do not affect plant safety or f

operation as they are inherent for the specific test but not Pnnted 5/19/981:50:10 PM Page 2 of 4

Northenst Utilities ICAVP DR N2. DR-MP3-0638 Millstone Unit 3 Discrepancy Report specifically identified.

The footnotes in OPS Forms 3646A.15-1,16-1,17-I and 18-1 (attached) have been revised for pump selection clarity and consistency. The footnotes in OPS Form 3646A.15-1, Rev.12, Chg. 2, and OPS Form 3646A.17-1, Rev.11, Chg. 2, documents the selection of the 'A' or "C" Service Water Pump which ever is used to perform the test. OPS Form 3646A.15-1, page 5, note 4, states

• indicate pump tested by circling proper letter

[SWP*P1 A or SWP-1C]. ONLY that pump should start". OPS Form 3646A.17-1, page 3, note 1, states "the SW pump not tested in lead during SP3646A.15 must be lead pump or documented on 3646A.17-2 as requiring a retest when available*. This change is the same for the "B" and "D" Sentice Water Pump footnotes. Therefore, this issue has been corrected.

NU has concluded that the existing surveillance test issues reported in DR-MP3-0638 has identified a NON- DISCREPANT condition. Work performed in response to Gerieric Letter GL 96-01 verified that the surveillance procedures SP 3626.4 " Service Water Pump 3SWP*P1 A Operational Readiness Test", SP 3646A.15 " Train A Loss of Power Test (IPTE)", and SP3646A.17

" Train A ESF With LOP Test (IPTE)" are in compilance with and meet Technical Specification testing requirements. Surveillance procedure SP 3626.4 tests the diesel load sequencer and pump logic twice, once with the

• LEAD / FOLLOW" selector switch, selected to the

• FOLLOW" position and once with the selector switch selected to the " LEAD

• position to verify the different logic combinations for starting the A Train Service Water Pump ,

configuration .

l Additionally, surveillance procedures SP 3646A.15 and  ;

SP3646A.17 verify the proper operation for starting and tripping the A Train Service Water Pumps under simulated loss of power ,

conditions and loss of power conditions coincident with an Engineered Safeguards Feature actuation signal respectively.

Therefore, these three surveillance together demonstrate the ability of the A Service Water Pump to perform it's intended l safety function upon receipt of an SIS actuation signal and fulfills l Technical Specifications testing requirements. The above discussion is also applicable to the B Train Service Water Pumps. Reference DR Number: DR-DRT-00563(NU), Response ID: M3-IRF-02335 for a detailed response on FSAR and plant procedures.

NU considers the classification of the unresolved issues of this DR to be significance level 4.

Conclusion:

NU has concluded that the issues repotted in Discrepancy Report, DR-MP3-0638 have identified CONFIRMED SIGNIFICANT LEVEL 4 conditions which require correction. NU i does not believe that a direct impact on safety or operations exists based on this original DR issue which identified discrepancies from reviewing the test results of SP 3646A.15, .

16.17. and 18. NU believes the assianment of priority 4 per l Printed 5/19/961:56:11 PM Page 3 of 4

Northext Utilities ICAVP DR No. DR-MP3-0638 Millstone Unit 3 Discrepancy Report attachment 11 of U3 PI-20 criteria is correct. The corrective actions in CR M3-98-0169 will review the OPS forms test results and determine which information is correct and revise any incorrect information post startup. The pump test footnotes in OPS Forms 3646A.15-1,16-1,17-1 and 18-1 have been revised for pump selection clarity and consistency and are no longer an issue. Technical Specifications testing requirements are being fulfilled by the performance of SP 3626.4,3646A.15, and SP3646A.17 for the A Service Water Pump and similar procedures for the other pumps. The discrepancy between the FSAR and plant procedures has been determined to be NON-DISCREPANT, Reference DR No: DR-DRT-00563(NU),

Response ID: M3-lRF-02335. NU considers the classification of the unresolved issues of this DR to be significance level 4.

Previously idenufled by NU? O Yes (9) No Non Discrepent Condation?O Yes (#) No Resolution Pending?O ves @ No ResoluuonUnresolved7O ves @ No Review Acceptable Not Acceptable Needed Date VT Leed: Bass, Ken VT Mgr; schopfer, Don K IRC Chmn: singh. Anand K Date: 5/15/98 st comments: It is not apparent from the corrective action description how the inconsistent requirements identified in the DR wil: be resolved.

The DR identifies that footnote 2 on OPS Form 3646.17-1 and the  !

conesponding B train OPS Form footnote are not equivalent.

Further, S&L does not concur with NU's determination that this discrepancy meets the Unit 3 deferral criteria. The DR identifies a discrepancy between the FSAR and plant procedures which have a direct impact on plant safety and operation.

The revised response addresses S&L concems identifed above.

S&L concurs with the revised response and finds it acceptable.

l l

l Pdnted 5/19/981:56:13 PM Page 4 of 4 ,

I l

Northert Utilitie3 ICAVP DR N2. DR-MP3-0670 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operaldity lasue Discipline: mchancal Design Discrepancy Tyre: Calculation Ovs SystenVProcess: HVX NRC Significance level: 3 Date faxed to NU:

Date Published: 12/21/97 Discrepancy: CCP & CHS Area Ventilation System Winter Operation

Description:

During review of the charging pump and component cooling water pump area ventilation system calculations discrepancies I regarding the minimum temperatures in the rooms were I identified.

References:

1. Calculation 3-92-103-191M3, Rev.1

2. Calculation 3-92-103-191M3, Rev.1, CCN 1-001

3. Calculation 3-92-103-191M3, Rev.1, CCN 1-002

4. Calculation 3-92-103-191M3, Rev.1, CCN 1-003

5. Calculatiore 3-92-103-191M3, Rev.1, CCN 1-004

6. Calculation 3-92-103-191M3, Rev.1, CCN 5

7. PDCR MP3-92-103, Rev.1

8. FSAR Appendix 3B

9. FSAR Section 9.4.3.1

10. PDCR MP3-93-067

11. P&lD EM-1488-15

Background:

The charging pump and component cooling water pump area ventilation system provides ventilation for the charging pump cubicles, component cooling heat exchanger area , and the MCC

& rod control A/C booster pumps area as shown on P&lD EM-148B-15.  !

FSAR Section 9.4.3.1 states that the charging pump cubicle temperature is maintained above the solubility temperature limit of 59'F for a 4 percent boron concentration.  ;

1 The minimum room temperature listed in FSAR Appendix 3B for the charging pump cubicles and component cooling pump area is 50*F. The minimum temperature listed for the MCC & rod control area A/C booster pumps is 65'F. I During the winter months the ventilation system mixes outside air and retum air and supplies this air to the component cooling i pump area , and the MCC & roa control A/C booster pumps l area. Retum air is drawn from all three areas served by the i system. The minimum outside air flow is set to maintain auxiliary building ventilation system filter exhaust fan (3HVR*FN6A/B) airflow above stall conditions. Eight safety-related electric unit heaters (four per division) are located in the component cooling water pump area.

PDCR MP3-92-103, Mechanical Technical Review ME-3, states that safety related equipment in these areas are operable at a p g, pg 22*c Ombient O!r t0mperature w^ tw0 except!Onc: 1) pogi,og-

Northext Utilitiea ICAVP DR N2. DR-MP3-0670 Millstone Unit 3 Discrepancy Report boric acid system may be subject to precipitation at temperatures below 59'F and 2) the charging pumps should not be started at temperatures below 65'F, but once started may be operated at an ambient temperature of 30'F.

Discrepancies:

1) Calculation 3-92-103-191-M3, CCN 5 case 10 resWis show a 29.6*F minimum temperature in the component cooling pump area. This temperature is lower than the 32'F evaluated in Mechanical Technical Evaluation ME-3 of PDCR MP3-92-iO3. -

2) Calculation 3-92-103-191-M3 Rev.1 [ including CCNs 1 to 5]

does not address the minimum temperature in the MCC & rod control A/C booster pumps area.

3) The minimum room temperatures shown in calculation 3 103-191-M3 Rev.1 [ including CCNs 1 to 5] are lower than the temperatures shown in FSAR Section 9.4.3.1 and Appendix 3B Review Valid invalid Needed Date initiator: stout, M. D.

8 O O '13'S7 VT Lead: Neri. Anthony A B O O 1/18'87 VT Mgr: schopfer, Don K O O O 12/5/97 lRc Chmn: singh, Anand K l

G O O $2/s/97 Date:

INVALID:

Date: 5/15/98 RESOLUTION: First Response NU has concluded that the Discrepancy Report, DR-MP3-0670, has identified a condition not previously discovered by Nt) wnich requires correction.

CR M3-98-0224 was initiated to identify and provide a corrective action plan for the discrepancies noted in DR-MP3-0670. The DR-MP3-0670 discrepancies relate to the minimum temperatures in the Auxiliary Building areas of the charging pump cubicles, component cooling pump and heat exchanger area, and MCC & rod control A/C booster pump area. The temperatures in the areas are maintained by Charging Pump, Component Cooling Water Pump, and Heat Exchanger (CHS/CCP) Area Ventilation System which is a subsystem of the Auxiliary Building Ventilation System (ABVS). The following is a timeline of events and actions relating to the minimum temperatures in the Auxiliary Building areas.

On 10/31/92, Rev.1 of PDCR MP3-92-103, " Auxiliary Building Filtration Systems / SLCRS Enhancements," was approved for construction. PDCR MP3-92-103 modified the ABVS including the CHS/CCP Area Ventilation System to enable the systems to operate in conjunction with the SLCRS to achieve the required drawdown of the Secondary Containment. PDCR MP3-92-103 modifications included removal the temperature control Printed 5/19/98 $:56.42 PM Page 2 of 8

Northea:t Utilities ICAVP DR N3. DR-MP3-0670 Millstone Unit 3 Discrepancy Report capabilities of the CHS/CCP Area Ventilation System.

Calculation 3-92-103-M3, Rev.1, "CCP & CHS Pump Area Ventihtion," was approved on 10/30/92 to support PDCR MP3-92-103. Calculation 3-92-103-M3 calculates the additional heat required to maintain 65oF in the areas during winter and a Loss of Offsite Power (LOP). As a result of the PDCR MP3-92-103, modifications and calculation results, Bypass Jumper 3-92-051 installed non-QA heaters to maintain 650F in the areas.

However, following a LOP the non-QA heaters will not be available and the minimum temperature in the areas could be 32'F.

Safety Evaluation (SE) MP3-92-103-9, Rev.1, "ABVS / SLCRS Enhancements - ABV Low Ambient Temperatures," evaluated the lowering of the Auxiliary Building minimum temperature from 65'F to 32*F following a LOP. SE MP3-92-103-9 concluded that the modification and the lowering of the Auxiliary Building areas temperatures to 32*F is safe and does not constitute an unreviewed safety question. The SE conclusions were based, in part, on the PDCR MP3-92-103 Technical Evaluations.

PDCR MP3-92-103 Technical Evaluation, ME-3, " Minimum Acceptable Temperature for the Auxiliary Building," evaluated the effects of the 32*F temperature on the operability of safety related equipment in the Auxiliary Building. The Technical Evaluation concluded that the equipment is capable of functioning adequately at 32*F.

On 8/25/93, PDCR MP3-93-067, Rev. O, " Auxiliary Building CHS/CCP Area Ventilation Heaters," was approved for construction. PDCR MP3-93-067 replaced the temporary non-QA heaters lastalled under Bypass Jumper 3-92-051 with a permanent QA Cat i heating system including eight unit heaters to maintain the winter temperature of the Auxiliary Building Areas at 65'F. With the loss of one train, four of the unit heaters installed under PDCR MP3-93-067 are sufficient to maintain the temperature above 32*F. SE MP3-93-067-1 evaluated the failure of one train of heaters to operate and concluded the modification is safe and does not constitute an unreviewed safety question. The SE conclusions were based, in part, on the l PDCR MP3-92-103, Rev.1 and Calculation 3-92-103-191-M3, Rev.1, including CCr4s 001 through 003.

l On 10/29/96, UIR 1074 was initiated to identify discrepancies in l FSAR Section 9.4.3.1. The final disposition for UIR 1074 l required a FSARCR to correct the winter design temperature in the Auxiliary Building areas to reflect PDCR MP3-92-103 and PDCR MP3-93-067 modifications. FSARCR 97-MP3-573 was approved on 12/12/97 to include changes to FSAR Section 9.4.3.1 as described in UIR 1074.

On 1/13/97, ACR M3-97-0119 was initiated to document discrepancies identified during the design basis review of the MP3 electrical calculations. The discrepancies documented in l

ACR M3-97-0119 relate to the voltaae profile, dearaded voltaae

( Printed 5/19/961:56:44 PM Page 3 of 8 l

1 Northert Utilitiea ICAVP DR N2. DR-MP3-0670 Millstone Unit 3 Discrepancy Report setpoint calculations, and downstream voltage calculations for the battery chargers, inverters and 120VAC systems. On 1/15/97, ACR M3-97-0161 was initiated to document discrepancies identified during the design basis review of the MP3 Technical Specifications and supporting calculations. The ,

discrepancies documented in ACR M3-97-0161 relate to the 1 minimum design voltages for Class 1E heaters and the low .

voltage capability of the heaters to perform its design basis function. A formal root cause investigation was conducted which included the calculation discrepancies identified in both ACR M3- l 97-0119 and ACR M3-97-0161. The roct cause investigation provided corrective actions including: identify and analyze safety related equipment that could be affected by a deg,Wed vougs condition and determine the adequate relay settings to eliminate the identified deficiencies.

On 1/29/97, ACR M3-97-0161 Deportability Evaluation,

" Degraded Voltage and Equipment Heater," was approved. The Deportability Evaluation reviewed Calculation 3-92-103-191M3 and determined that with a loss of one train of heaters and a 12% reduced voltage, the CCP area temperature could be about 300F. This condition of 30*F for the CCP area was determined acceptable for continuos pump operation, based on input from Westinghouse letter NEU-92-566, dated 10/4/92. The deportability evaluation concluded that based on review of ventilation calculations, historic events, control room indication and system flexibility there is reasonable assurance that auxiliary building temperatures will be maintained within acceptable limits.

On, T/19/97, CCN 005 to Calculation 3-92-103-191M3, Rev.1 was approved. CCN 05 was developed in response to ACR M3-97-0119 corrective action plan to formalize the assumptions of ACR M3-97-0161 Deportability Evaluation. CCN 05 calculated CHS/CCP areas temperatures in winter when one heater train has failed and the other heater train is powered from the offsite 9 rid at 12% reduced voltage. CCN 05 calculated the minimum CCP area temperature as 29.6*F which is below the minimum value of 32*F as determined in PDCR MP3-92-103 and PDCR MP3-93-067. On 7/23/97, Calculation 97-ENG-01453M3,

" Vendor Calculation on Effects of Degraded Voltage on Safety Related Electric Heaters," Rev. O, was apporved. Calculation 97-ENG-01453M3 determined if the Class 1E heaters are able to perform their design basis functions under a degraded voltage condition and concluded that the heaters do not have a operability concem under degradcd voltage conditions and will perform their safety related function. Calculation 97 ENG-01453 evaluated the CCN-05 results and concluded that the 29.6'F condition is considered acceptable based on Westinghouse letter NEU-92 566, dated 10/4/92.

On 11/15/97, DCR 97030, Rev.1, " Unit 3 Degraded Grid Modifications was approved for implementation. DCR M3-030 was developed in response to ACR M3-97-0119 corrective action plan to restore the operability of the MP3 degraded grid voltage protection relays. As a result of DCR M3-030, a change to Calculation 3-92-103-191M3 is reauired to reflect the current Printed 5/19/981:56 44 PM Page 4 of 8

Northe:st Utilitie3 ICAVP DR N:. DR-MP3-0670 Millstone Unit 3 Discrepancy Report degraded voltage conditions.

On 1/15/98, CR M3-98-0224 was initiated to identify and provide a corrective action plan for the discrepancies noted in DR-MP3-0670. CR M3-98-0224 corrective action plan requires 1) a revision to Calculation 3-92-103-191M3 to reflect the current degraded voltage condition,2) an evaluation of Calculation 3-929103-191M3 results, and 3) based on the evaluation of the Calculation 3-929103-191M3 results, a revision to FSAR Section 9.4.3.1 and FSAR Appendix 38.

The following is a response to the 3 discrepancies identified in DR-MP3-0670:

1) The calculated (CCN 05 to Calculation 2-92-103-191M3) minimum temperature of 29.6*F in the CCP area was evaluated in the ACR M3-97-0161 Deportability Evaluation and Calculation 97-ENG-01453M3. The Deportability Evaluation reviewed Calculation 3-92-103-191M3 and determined that with a loss of one train of heaters and a 12% reduced voltage, the CCP area temperature will be about 30*F. This condition of 30*F for the CCP area was determined acceptable for continuous pump operation based on input from Westinghouse letter NEU-92-566, dated 10/4/92. The deportability evaluation concluded that based on review of ventilation calculations, historic events, control room indication and system flexibility there is reasonable assurance that auxiliary building temperatures will be maintained within acceptable limits. Calculation 97-ENG-01453 evaluated the CCN-05 results and concluded that the 29.6*F condition is considered acceptable based on Westinghouse letter NEU 566, dated 10/4/92.

In addition, CR M3-98-0224 corrective action requires a revision to calculation 3-92-103-191M3 to reflect the current degraded voltage conditions. Though CCN 05 calculates the CCP room temperature to be slightly below the Westinghouse evaluated temperature of 30*F, a preliminary change to calculation 3 103-191M3 indicates that the temperatures will be above 30*F.

The preliminary calculation is based on the corrective actions of ACR M3-97-0161 and ACR M3-97-0119. The corrective actions included raising the electrical voltage relay settings which will  !

increase the heater output.

Therefore, the discrepancy between the FSAR Section 9.4.3.1

)

minimum temperature of 32'F and CCN 05 minimum temperature of 29.6*F in the CCP area is considered a Significance Level 4.

2) CR M3-98-0224 corrective action requires a change to J l calculation 3-92103-191M3 to address the minimum l l temperatures in the MCC and rod control A/C booster pumps area. CR M3-98-0224 provides an evaluation of the minimum temperature conditions on the equipment in the MCC and rod ,

control A/C booster pumps area. The evaluation concluded that l the minimum temperatures will not effect the equipment in the area. Therefore. the need to establish a formal calculation for Pnnted 5/19/981:56:45 PM Page 5 of 8

1 Northert Utilities ICAVP DR No. DR-MP3-0670 Millstone Unit 3 Discrepancy Report the MCC & rod control A/C booster pumps area minimum l l temperature is considered a significance level 4. l l

3) CR M3-98-0224 corrective action requires an evaluation of  ;

Calculation 3-92-103-191M3 results. Based on the evaluation of j the Calculation 3-929103-191M3 results, FSAR Section 9.4.3.1 and FSAR Appendix 3B will be revised.

The calculated (CCN 05 to Calculation 2-92-103-191M3) minimum temperature of 29.6*F in the CCP area was evaluated in the ACR M3-97-0161 Deportability Evaluation. The i Deportability Evaluation reviewed Calculation 3-02-103-191M3 f and determined that with a loss of one train of heaters and a

, 12% reduced voltage, the CCP area temperature will be about 30*F. This condition of 30'F for the CCP area was determined acceptable for continuos pump operation based in Westinghouse letter NEU-92-566, dated 10/4/92. The deportability evaluation concluded that based on review of ventilation calculations, historic events, control room indication and system flexibility there is reasonable assurance that auxiliary building temperatures will be maintained within acceptable limits.

Therefore, the differing values between the FSAR Section 9.4.3.1 minimum temperature of 32*F and CCN 05 minimum temperature of 29.6'F in the CCP area is considered a Significance Level 4. A clarification to the Appendix 3B temperatures may be required following the evaluation of the ,

change to calculation 2-92-103-191M3. ]

Attachments:

CR M3-98-0224 l FSARCR 97-MP3-573 Second Response (M3-lRF-02124)

NU has concluded that Discrepancy Report DR-MP3-0670 has identified a condition not previously discovered by NU which requires correction.

1) Supply air is discharged southward and horizontally into the l room, , at the ceiling level, above the CCP pumps. The safety l related electric unit heaters, installed per PDCR MP3-93-067, are located on the north wall in front of these pumps, and on the l east and west walls adjacent to the pumps. The unit heaters are installed in such a way as to discharge heated air directly at the CCP pumps and associated controls, thus the equipment is located in the lower and warmer zone of a stratified air flow. Full entrainment of the outdoor air and heated indoor air takes place beyond the equipment. It is reasonable therefore to judge that the equipment and controls, along with instrumentation, will remain operable during the worst case conditions. The calculated worst case of room mixed airleaving temperature of 29.9 'F. (ref. CCN-7 to calc. 3-92-103-191M3) on a 0 'F. day when one train of heaters has failed and the remaining train is operating at 12% reduced voltage, is postulated to be an event of short duration. Millstone's experience relative to the Printed 5/19/961:56A6 PM Page 6 of 8

N:rthert Utilities ICAVP DR N2. DR-MP3-0670 Millstone unit 3 Discrepancy Report temperature in this area on cold winter days is consistent with the above stated judgment. Field inspection has verified that no instrumentation lines or components are located in the area of direct Impingement with cold air. Calculation 3-92-103-191M3 will be revised to address the impact of the worst case conditions on the CCP / Heat Exchanger equipment. Corrective action has been deferred to post start-up. Corrective action is being tracked by AR 98001049. A copy of the Action Request Report (A10) for AR 98001049 is attached.

Items 2 and 3 above appear to be identical statements. A copy of calculation 3-92-103-191M3, with CCN-6 and CCN-7, is attached.

System configuration conforms to MP3 design basis and licensing basis. NU, therefore, considers this issue Significance Level 4.

Attachments:

Calculation 3-92-103-191M3, Rev.1, CCN-6 and CCN-7 CCP-CHS Pump Area VentilationAction Request Report (A10) for AR 980001049 Previously identified by NU? O Yes (9) No Non Discrepant Condition?O Yes (s) N3 Resolution Pending?O ve. @ No Resolution Unresolved?O ve.

• No Review i Initiator: stout. M. D.

VT Land: Neri, Anthe:'y A I VT Mgr: schopfer. Don K 1RC Chmn: singh. Anand K Date:

B O O me '

5/15/98 SL Comments: Comments on First Response l

)

1) Westinghouse letter NEU-92-566 dated October 4,1992 only addresses operation of the charging / safety injection pumps at a 30*F ambient temperature. The letter does not address the CCP pumps, instruments, etc in the area that were evaluated for a 32*F temperature in PDCR MP3-92103 Mechanical Technical Review ME-3. Calculation 3-92-103-191-M3, CCN 5 on page 5 shows a supply air temperature of about 16'F to the CCP l pump / heat exchanger area and a 29.6'F air temperature leaving the CCP pump / heat exchanger area. The impact of below freezing conditions, especially in the areas near the supply air discharge to the room, needs to be addressed. The results of this evaluation are needed to establish the final significance level of the DR.

2) Results of calculation 3-92-103-191M3 revision are needed to establish the final significance level of the DR.

3) Results of calculation 3-92-103-191M3 revision are needed to determine the final significance level.

Response also needs to address effect of lower room temperature Printed 5/19/981:56 47 PM Page 7 of 8

Northert Utilities ICAVP DR Ns. DR-MP3-0670 Millstone Unit 3 Discrepancy Report on calculations, such as setpoint calculations, that used the 32*F room temperature as input.

Comments on Second Response The corrective action for CR M3-98-0224 resolves the technical issues.

The minimum temperature of 29.9'F does not meet the licensing basis minimum temperature of 32*F stated in the FSAR. This is considered to be a significance level 3 discrepancy.

The significance level of this DR is unresolved.

Supplemental Comments in a conference call on May 15,1998 NU agreed with the Level 3 classification of this DR. This resolves the open issue, I

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Pnnted 5/19/981:56:49 PM Page 8 of 8

Northert Utilitie3 ICAVP DR N2. DR-MP3-0717 Milistone Unit 3 Discrepancy Report Review Group: Programrnate DR RESOLUTION ACCEPTED Potential Operability issue Discipline: I & C Design Discrepancy Type: Procedure implementation Om System / Process: sWP g

NRC SigniAcance level: 4 Date faxed to NU:

Date Published: 12/20/97 Discrepancy: Setpoint changes without implementing documents.

Description:

Setpoint change calculation SP-3SWP-29, Rev. O, CCN 1 references E&DCR N-ME-02985 as the parent document, but E&DCR N-ME-02985 is stamped superseded by DCN DM3-S-1009-95. Setpoint changes cannot be implemented through the DCN process. Setpoint changes are implemented via Setpoint Change Records or Plant Design Change Records which are classfied as modifications (parent document); however, no implementing documentation (e.g. SCR, PDCR, DCR) was provided when requested from NU. Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisions (ops, annunciator, surveillance) are referenced or were provided when requested.

Setpoint change calculation SP-3SWP-25, Rev.1, CCN 1 references calculation 95-ENG-1177 M3, Rev. O as the parent document. Setpoint changes are implemented via Setpoint Change Records or Plant Design Change Records which are classfied as modifications; however, no modification is referenced. No implementing documentation (e.g. SCR, PDCR, DCR) was provided when requested from NU. Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisions (ops, annunciator, surveillance) are referenced or were provided when requested.

Setpoint change calculation SP-3SWP-25, Rev.1, revises a setpoint without a parent document. Setpoint changes are implemented via Setpoint Change Records or Plant Design Change Records which are classfied as modifications; however, no modification is referenced. No implementing documentation (e.g. SCR, PDCR, DCR) was provided when reouested from NU.

Additionally, no PDDS, MSI, MSL or MEPL database revisions or procedure revisons (ops, annunciator, surveillance) are referenced or were provided when requested.

Review Valid invalid Needed Date initiator: Dombrowski. Jim O O O 12/5/97 VT Lead: Ryan. Thomas J B O O $2/s/97 VT Mgr: schopfer, Don K B O O 12/11/97 IRC Chmn: singh, Anand K B O O 2iiero7 Date:

l INVALID:

Date: 5/19/98 RESOLUTION: Disposition:

Printed 5/19/981:57:52 PM Page 1 of 3

1 .

Northe:st Utilities ICAVP DR No. DR-MP3-0717 Millstone Unit 3 Discrepancy Report NU has concluded that this issue reported in Discrepancy {

Report, DR-MP3-0717, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter 4 B16901 and 17010. It has been screened per attachment 11 of U3 PI 20 criteria and found to have no operability or deportability ,

concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. '

Setpoint calculation SP-3SWP-29 "3SWP*PV112A1, B1, A2, B2, i 3SWP*PV113A1, B1, A2, B2 Refrigerant Condenser Water Flow l

Control Valve Setpoint" Revision 0, Calculation Change Notice (CCN) 01, revised the modulating range from "110 to 150* PSIG to a range of *170 to 210" PSIG for these valves. The CCN states that E&DCR N-ME-02985 provides the technical l justification for revising the modulating range. However, this document has been superseded by DCN DM3-S-1009-95 and once superseded it can not be referenced as the basis document. The calculation should reference the applicable Valcor Engineering Corporation documentation and DCN DM3-00-0790-97. Which replaced the Freon - 12 actuator spring l packs for these valves with the applicable spring pack for a l l system using Freon - 22. NU considers this to be an l administrative activity that does not impact the design or licensing basis of any system.

i CR M3-98-2313 was closed to Bin CR M3-98-0138. Condition Report (CR) M3-98-0138 corrective actions will correct this level  ;

4 calculation deficiency post startup.

Calculation 95-ENG-1177M3

• Control Building Water Chiller Condenser (3HVK'CHL 1 A/B) Analysis", Revision 1, CCN 00, provided the basis for increasing the Service Water inlet i temperature from 75 oF to 81 oF which was then used as a 1 design input for setpoint calculation SP-3SWP-25 I "3SWP* TIC 35A, B Service Water inlet Temperature Control For Control Room Air Conditioning Water Chiller" Revision 1, CCN

01. These changes did not cause or result in a setpoint change.

However, setpoint calculation SP-3SWP-25 was revised to provide an operating band to enhance system performance and provide operations with flexibility to handle seasonal fluctuations.

This change was implemented by Setpoint Change Request (SCR) M3-95-031 in accordance with approved station procedures. Additionally, PDDS-98-0063 revised the Master Setpoint List (MSL) to reflect the operational band.

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

Conclusion:

NU has concluded that this issue reported in Discrepancy Report, DR-MP3-0717, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction.

This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and fcund to have no operability or deportability Printed 5/19981:57:55 PM Page 2 of 3 l

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i Northeist Utilities ICAVP DR N2. DR-MP3-0717 Millstone Unit 3 Discrepancy Report i i

ccoceins and meets section 1.3.2.0 of U3 PI 20 deferral criteria. I Condition Report M3-98-0138 corrective actions will correct the l calculation deficiency post startup. NU considers this to be an administrative activity that does not impact the design or licensing basis of any system.

Setpoint calculation SP-3SWP-25 was revised to provide an operating band to enhance system performance and provide operations with flexibility to handle seasonal fluctuations. This change was implemented by Setpoint Change Request M3 031 in accordance with approved station procedures.

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

Attachments: CR M3-98-2313 DCN DM3-00-0790-97 SCR M3-95-031 Previously identifled by NU? O Yes ($ No NonDiscrepantCondiuon?O Yes (@ No Resoludon Pending?O ves @ No Resolution Unresolved?O ves @ No Review

. ceptable Not Acceptable Needed Date Cam A VT Lead: Ryan, Thomas J VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/19/98 sL comments: NU's response is acceptable.

NU's response to Part 1 acknowledges the discrepancy in calculation SP-3SWP-29, Revision 0, Calculation Change Notice (CCN) 01 which failed to reference the applicable Valcor Engineering Corporation documentation and DCN DM3-00-0790-

97. NU has concluded that this issue is a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. NU will correct this discrepancy with Bin CR M3-98-0138 post startup.

The calculation revision is an administrative activity that does not impact the design or licensing basis of any system. In a conference call on May 18,1998, NU explained that DCN DM3-00-0790-97 and its associated MSEE replaced the Freon 12 valve actuator spring packs with Freon 22 valve actuator spring packs for valves 3SWP*PV112A1, B1, A2,82,3SWP*PV113A1, B1, A2, B2 to bring them in conformance with the original system design which was based on Freon 22 refrigerant. Therefore, a ,

Setpoint Change Requiest (or DCR) was not needed to make the setpoint change. i NU's response for Part 2 includes the Setpoint Change Request (SCR) M3-95-031 which implemented the setpoint change in accordance with approved station procedures and references PDDS-98-0063 which revised the Master Setpoint L!st (MSL) to i reflect the operational band. {

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Printed 5/19f981:57:57 PM Page 3 of 3 l

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Northeast Utilities ICAVP DR N3. DR-MP3-0724 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design Discrepancy Type: Component Data System / Process: HVX g

NRC Significance level: 4 Date faxed to NU:

Date Published: 12f21/97 '

Discrepancy: SLCRS and ABVS Filter Unit Backup Adsorbent Cooling Mechanism

Description:

During review of the supplementary leak collection and release sys'am (SLCRS) filter units 3HVR*FLT3A/B and auxiliary building ventilation system (ABVS) exhuast filter units 3HVR*FLT1 A/B a discrepancy was identified regarding backup adsorbent cooling.

FSAR Table 1.8-1, Reg. Guide 1.52, Rev. 2, Position C.3.k exception states " Exception is taken to the requirement of any cooling mechanism satisfying single-failure criteria because a backup mechanism is provided."

The backup cooling mechanism referred to in the Reg Guide exception was not found in the review of the system P& ids and physical drawings.

Review Valid invalid Needed Date Initiator: stout, M. D.

O O O 31/29/97 VT Lead: Neri, Anthony A B O O s t/2in7 VT Mer: schopfer, Don K O O O 52/5/97 IRC Chmn: singh. Anand K O O O 12/o/97 Date:

INVALID:

Date: 5/18/98 RESOLUTION: First Response NU has concluded that DR-MP3-0724 does not represent a discrepant condition. The backup adsorbent cooling mechanism employed at Millstone 3 is a water spray system. This method is consistent with Reg Guide 1.52 Section C.3.k. The water spray system shown on P&lD EM-146-C, rev.13 Fire Protection ( See Attachment ) performs the backup cooling function for filter units 3HVR*FLT1 A/B and 3HVR*FLT3A/B. Significance level criteria does not apply as this is not a discrepant condition.

Attachments:

1) P&lD EM-146-C-13 Second Resporise NU has concluded that Discrepancy Report DR-MP3-0724 has identified a condition not previously discovered by NU which requires correction.

Printed 5/19/981:58:20 PM Page 1 of 4

N:rthenct Utilities ICAVP DR N3. DR-MP3-0724 Millstone Unit 3 Discrepancy Report j Condition Report ( CR ) M3-98-0691 ( See Attached ) was written to address a series of issues related to SLCRS and ABVS which encompass the issue identified in DR-MP3-0724. Pursuant to discussions with S&L for clarification of the issue, the following ,

approach was developed to disposition DR-MP3-0724: I l

in lieu of a formal calculation, ERC (Engineering Record Correspondence) 25212-ER-98-0103 ( See Attached ), prepared q by SWEC, in conjunction with calculation 97-EBF-01955-M2 ( j See Attached ) and ICAVP Technical Review Note ( See 1 Attached ), establishes the maximum heat generation rate in the )

MP3 safety related ventilation filters from deposition of radioactive lodines following a Loss-Of-Coolant Accident. This ,

evaluation assumes that the maximum carbon temperature is j 250 'F, which is 50 'F below the minimum desorption j temperature of 300 *F,... and approximately 1/3 of the minimum j code required carbon ignition temperature of 572 'F. A formal I calculation is in preparation, which will validate the assumption of a 250 'F maximum temperature. The calculation will be completed before mode 2. Meanwhile, the results of the referenced evaluation demonstrate that NU is in compliance with i R. G.1.52. Since the heat load from radiodecay in the MP3 filter units is below that which would lead to autolgnition, there is no need for backup cooling.

Based on the information contained in ERC 25212-ER-98-0103, the ICAVP Technical Review Note, and calculation 97-EBF- ,

91955-M2, NU has concluded that the configuration of filter units 3HVR*FLT1 A/B and 3HVR*FLT3A/B are in compliance with R. G.1.52. The approved corrective action to CR-M3-98-0691 will develop a calculation to determine the heat load due to radioactive induced heat in the SLCRS and ABVS filter units.

Corrective action is being tracked by AR 98002864-03.

Based upon the preceding discussions, the LB / DB of MP3 is not impacted by this discrepancy therefore NU considers DR-MP3-0724 to be a level 4 discrepancy.

Attachments:

1. Condition Report M3-98-0691

2. Engineering Record of Correspondence No. 25212-ER 0103

3. ICAVP Technical Review Note

4. Calculation 97 EBF-01955-M2 Supplemental Response (M3-lRF-02343)

Per telephone conference on 5/7/98, corrective action for DR-MP3-0724 will be revised. This response supplements M3-lRF-02075.

NU has concluded that the issue reported in DR-MP3-0724 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Contrary to that previously stated in M3-IRF 02075, the formal calculation will be completed post startup. The results of Enoineerina Record of Correspondence Printed 5/19/981:58:24 PM Page 2 of 4

Northe:st Utilitie3 ICAVP DR N3. DR-MP3-0724 Millstone Unit 3 Discrepancy Report No. 25212-ER-98-0103 demonstrate that the heat load from radiodecay combined with air back leakage through isolation dampers in the MP3 filter units provide sufficient cooling to prevent auto-ignition. The ERC was independently reviewed and approved and is a Quality document. Redundancy of cooling mechanisms is not required since auto ign! tion issues arise from l a postulated filter fan failure, and as such, NU is in compilance with Reg. Guide 1.52.

Previously identined by NU? O Yes (9) No Non Discrepant Condition?Q Yes (9) No Resolution Pending?O Yes 9 No ResolutionUnresolved?O Yes @ No Review Inttletor: stout. M. D.

VT Lead: Neri, Anthony A VT Mgr: Schopfer. Don K BRC Chmn: singh, Anand K B O s's O O Date: 5/18/98 st Comments: Comments on First Response The FSAR exception to Reg. Guide 1.52, Rev. 2, position C.3.k implies that the backup cooling mechanism provided would be functional post-accident for adsorbent cooling. The fire protection system that provides the water for the water sprays is a non-safety system that can not be relied on to provide adsorbent cooling during post-accident conditions.

Related DRs that address adsorbent cooling and the classification of the fire protection piping / valves are DR-MP3-0588 and DR-MP3-0842 Comments on Second Response REFERENCES (1) Engineering Record Correspondence 25212-98-0103, Rev. O.

(2) Calc. 97 EBF-01955-M2, Rev. 0 (3) Calc. MP3LOCA94-01048-R3, Rev. 2 The methodology described in Reference 1 to estimate the MP3 SLCRS peak heat loading using the calculational parameters of MP2 has been reviewed and appears to be conservative.

However, the largest heat loading calculated in Reference 2, at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, may not be the peak value. The heat loading on the filter is a function of containment leakage and the radioactive decay of the various lodine isotopes 1-131 through l-135, among other things. Each isotope of iodine, having its own decay rate, has its own peak heat generation rate. It is the sum of the heat generation rates that determines the peak heat generation rate experienced by the filter. From an examination of the summary table shown on page 21 of Reference 2 it is not evident the heat loading at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is the peak. The time steps do not appear to be fine enough for this determination. More calculations are required at time points around suspected peaks to demonstrate a maximum..

Printed 5/19/981:58:25 PM Page 3 of 4

Northert Utilitie3 ICAVP DR N2. DR-MP3-0724 Millstone Unit 3 Discrepancy Report it is estimated that the cooling available due to leakage thru backdraft damper 3HVR*DMPF13A/B (33 cfm @ 12.5 iwg),

entering air temperature of approx 150 *F (120*F entering operating filter uait + temperature rise across heater +

temperature rise across operating exhaust fan), and a leaving air temperature of 300*F is on the order of 5000 Btu /hr for the SLCRS filter units. This is sufficiently greater than the 800 Btu /hr heat generation rate contained in reference 1 to coreclude that damper leakage w"I provide adequate airflow for adsorbent cooling for the SLCRS filter units. For the ABVS filter units, leakage thru damper 3HVR* MOD 28A/B would provide for ABVS filter unit adsorbent cooling.

i I

Base on the abcve, NU's second response, and CR M3-98-0691 corrective action plan this is considered to be a Level 4 discrepancy.

Comments on Supplemental Response No comments i l

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Printed 5/19/981:58:27 PM Page 4 of 4

Northert Utilitle: ICAVP DR N2. DR-MP3-0773 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED RW Ew. Nnge Wocess Potential Operability issue Discipline: I & c Design Discrepancy Type: Calculation Ow

% No

~

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

Date Published: 1/10/98 Discrepancy: Inconsistent setpoint change design input data

Description:

Setpoint calculation SP-3EGF-8, Rev2, calculates the low level setting for instruments 3EGF-LS29-1 A & B. The design input data used to determine the setting based upon the percent of span is different from the data used in the modification implementing document DCR-547. The proc as spanning differences results in two different calibrated voltage settings.

This is a discrepant condition since the setpoint calculation is the supporting document referenced in the design change request.

Review Valid invalid Needed Date lattiator: Dombrowski, Jim B O O 12/22/97 VT Lead: Ryan, Thomas J B O O 12/22/97 VT Mgr: schopfer, Don K O O O 12/23/97 1RC Chmn: singh, Anand K B O O 52/31/97 Date:

INVALID:

Date: 5/19/98 RESOLUTION: Disposition:

NU has concluded that issue reported in DR-MP3-0773 has identified a NON-DISCREPANT condition.

During startup it was not recognized that the fuel oil density could fluctuate substantially between truck loads. These changes in fuel oil density caused the process fluid weight to fluctuate widely which manifested itself in a symptomatic shift in the switch setpoint, giving the appearance that the switch was misoperating, miscalibrated or the setpoint had shifted. However, when a calibration check was perfonned it would be within the acceptance criterion. This misleads individuals to believe that the span was incorrect for these switches that resulted in the issuance of several Design Change Requests (DCRs) (for example, DCRs 404, 547, etc.) to resolve this issue. This resulted in SP-3EGF-6, *3EGF-LS29A1 and B1, Fuel Oil Day Tank Low Level Alarm" setpoint calculation to be changed and revised several times. The cause of the symptomatic shift was identified and corrected by placing a truck load density acceptance criterion on new fuel oil deliveries and the setpoint revised to use the acceptance criteria midpoint density value.

The documents identified in this DR have been revised or superseded and are no longer used as design inputs. Calculation SP-3EGF-8 is currently on revision 4, Calculation Change Notice (CCN) 03. The Fuel Oil Day Tank Low Level switches 3EGF.

LS29A1 and B1 have been re-calibrated to reflect the new Pnnted s/19/901:58.50 PM Page 1 of 2

Northert Utilities ICAVP DR N2. DR-MP3-0773 Millstone Unit 3 Discrepancy Report setpoint sittings as a result of Adverse Condition Report (ACR)

M3-97-0486 dated February 12,1997. Therefore, DCR 547 does not represent a discrepant condition.

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

Conclusion:

NU has concluded that issue reported in DR-MP3-0773 has identified a NON-DISCREPANT condition. The documents identified in this DR have been revised or superseded and are no l longer used as design inputs. Calculation SP 3EGF-6 is currently  !

on revision 4, Calculation Change Notice (CCN) 03. The Fuel Oil Day Tank Low Level switches 3EGF-LS29A1 and B1 calibration loop folders have been revised and the switches recalibrates to ,

reflect the new setpoint.

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

Attachments: SP-3EGF-6, Rev. 4, CCN 03.

ACR M3-97-0486 Pts.viously klentified by NU? O Yes (9) No Non Discrepant condition?iG_) Yes O No Resolution Pending?O ve. @ No ResolutionUnresolved?O ves @ No Review initiator: Caruso A.

VT Lead: Ryan. Thomas J VT Mgt: schopfer, Don K '

1RC Chmn: singh, Anand K oste: 5/19/98 SL Comments: NU's response is acceptable.

NU's response acknowledges that the documents identified in this DR have been revised or superseded and are no longer used as design inputs. Calculation SP-3EGF-6 is cunently on revision 4, Calculation Change Notice (CCN) 03. The Fuel Oil Day Tank Low Level switches 3EGF-LS29A1 and B1 have been re-calibrated to reflect the new setpoint sittings as a result of Adverse Condition Report (ACR) M3-97-0486 dated February 12,1997.

In addition, Calculation SP-3EGF-6 Revision 4, Calculation Change Notice (CCN) 03 acknowledged that a field walkdown confirmed the elevation of the instrument to be accurate in the calculation.

Therefore, DCR-MP3-0773 does not represent a discrepant condition.

Printed 5/19/981:58 s4 PM Page 2 of 2

Northe:st Utilities ICAVP DR N2. DR-MP3-0833 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED ,

I '* "

Potential Operability lasue Diecipline: I & C Design Discrepancy Type: Calculation Ow SysterrWProcess: DGX (5)No NRC Significance level: 4 Date faxed to NU:

Date Published: 1/10/98 Discrepancy: Calculation methodology vs. RG 1.105 commitment for SP-3EGA-1,SP-3EGF-10,SP 3 EGO-4,5,8,12,SP-3EGS-12

Description:

The calculations described below document the vendor's process setpoint values but do not analyze the impact of instrument inaccuracy, calibration uncertainty, and instrument drift upon their respective Category 1 instruments. No bases for selecting instrument setpoint values is documented.

1. Calculation SP 3EGA-1 documents the setpoint for pressure switches 3EGA*PS28A1, A2, B1, and B2 that trigger an alarm on low air start header pressure for the Emergency Diesel's starting air reservoirs. ]

I

2. Calculation SP-3EGF-10 documents the setpoint for pressure switches 3EGF*PS38A and B that trigger an alarm and start the Emergency Diesel's respective Auxiliary Fuel Oil Pumps, 3EGF*P2A and B, on low fuel oil pressure.

3. Calculation SP-3 EGO-4 documents the setpoint for pressure )

switches 3 EGO *PS23A1, A2, A3, and B1, B2, B3 that trigger an 4 alarm and stop the respective Emergency Diesels on any two-out-of-three switch actuations on low lube oil pressure.

4. Calculation SP-3 EGO-5 documents the setpoint for pressure switches 3 EGO *PS21 A and B that trigger an alarm on low rocker arm lube oil pressure for the Emergency Diesels.

5. Calculation SP-3 EGO-8 documents the setpoint for pressure switches 3 EGO *PS24A and B that trigger an alarm on high crankcase pressure for the Emergency Diesels.

6. Calculation SP-3 EGO-12 documents the setpoint for level switches 3 EGO *LS40A and B that trigger an alarm on low lube oil reservoir level for the Emergency Diesels.

7. Calculation SP-3EGS-2 documents the setpoint for temperature switches 3EGS*TS30A and B that trigger an alarm on low Jacket water heater temperature for the Emergency Diesc's.

Review .

Valid invalid Needed Date I initiator: Reed. William. O O O 2/iae97 VT Lead: Nert, Anthony A B O O 2/19/97 VT Mgr: Schopfer, Don K B D 0 2/2297 1RC Chmn: singh, Anand K O O O $2/31/97 Dele:

mns ny_m.

Printed 5/19/981:59:23 PM Page 1 of 5

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Northext Utilitie3 ICAVP DR N2. DR-MP3-0833 Millstone Unit 3 Discrepancy Report  ;

m. . l I

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0833, has identified a condition previously discovered by NU which require ,

correction. Reg. Guide 1.105, Revision 1 (MP3's licensing basis), '

applies to protective instruments and alarms in systems important to safety. A system important to safety is defined as those systems that are necessary to ensure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe condition, or (3) the capability to prevent or mitigate the consequences of accidents that could further result in potential offsite exposures comparable to the guideline exposures of 10CFR Part 100, " Reactor Site Criteria". The Reg. Guide Position sections C1 through C6 provides further guidance indicating that the requirements of the Reg. Guide are to be applied in the development of setpoints with appropriate margins to account for expected uncertainties between the setpoint and the limiting safety settings com 'oed in the Technical Specifications. This provides clarification that c

• protective instruments and alarms in systems important to safety whose limiting safety settings for which we must maintain margin for uncertainty are listed in Technical Specifications.

Calculation of instrument uncertainties for MP3 is currently governed by a site wide standard specification, SP-ST-EE-286 l

" Guidelines for Calculating Instrument Uncertainties". This specification provides generic guidance on calculating instrument uncertainties, however it does not provide adequate detail for MP3 in identifying which instruments are required per the MP3 licensing commitments to have instrument uncertainties l included in their setpoints, Instead it relies upon the design basis 1 documents (MEPL program, and Specifications) to identify and  !

determine which instruments require inclusion of uncertainties l within their setpoints.

CR M3-97-1609, dated May 21,1997, was issued to document the results of a self-assessment conducted on the MP3 Setpoint Control Topical Area which identified the need to develop a Millstone Unit 3 specific instrument setpoint manual (or specification) to replace the generic SP-ST EE-286 specification.

Corrective actions fer this CR are in process and Specification SP-M3-IC-025 is in development which will provide guidacte for the preparation of safety system instrument setpoint and uncertainty calculations for MP3 in a manner that is clearly consistent with the intent of ISA S67.04, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants",

and requirements of Regulatory Guide 1.105, Rev.1,

" Instrument Setpoints for Safety.Related Systems". This administrative enhancement will ensure the appropriate application of uncertainties in the required setpoint calculation.

Due to misinterpretation of specification SP-ST-EE-286 requirements and discontinuities between the design base Printed 5/19/981:59:26 PM Page 2 of 5

Northert Utilities ICAVP DR No. DR-MP3-0833 l Millstone unit 3 Discrepancy Report l

documents there has been confusion as to which instruments require consideration of uncertainties in their setpoints. The original design philosophy identified those instruments that

! perform nuclear safety functions with an asterisk (*) in the instrument ID and denoted them as Category I. The MEPL program has evolved over the years in such a manner that it has departed from that original design philosophy in identifying Nuclear Safety Related equipment with an asterisk to identifying all QA Category I devices with an asterisk. For example, an instrument which is required to be QA Category I because it performs either a pressure boundary function or because of interrelationships with a Class IE circuit would have an asterisk in its ID. This led to an erroneous belief that those instruments required uncertainties to be applied even though they are not in systems important to safety per Reg. Guide 1.105 requirements.

CR M3-97-3083, dated September 12,1997, was issued to document these inconsistencies betweer the original instrument identification approach and the FSAR taba in identification of Category 1, non nuclear safety functional instrumentation.

Corrective actions for this CR have been identified. AR 97022871-02 issued SP-M3-ME-024 Rev. O, " Millstone Unit 3 Conventions for System Identifications, System Interfaces, and Equipment identification" as the MP3 controlling document for asterisk (*) coding. AR 97022871-01 will revises FSAR Section 3.2 to reflect use of the MEPL program to identify QA Category I equipment and MP3 Specification SP-M3-ME-024 as the controlling document for asterisk (*) coding of specific MP3 drawings. These changes are administrative in nature and do not impact the design or licensing basis of any system.

In regards to NETM-43 and NEAM-41:

NETM-43 " Preparation of Category I instrument Setpoint Calculations with Respect to the Requirements of NRC Regulatory Guide 1.105" established a uniform method for Stone l

& Webster Control System personnel to identify instruments that I require uncertainties to be included in their setpoints. Guidance ,

provided in section 4.0 " Criteria for Instrume it Setpoints" clearly I indicates that only instruments that have a technical specification i limit are to included uncertainties. This is to ensure that instrument drift and / or inaccuracies will not place the instrumant setpoint beyond the technical specification limit.

NEAM-41 " Processing of Calculations Millstone Nuclear Power Station - Unit 3," implements the requirements of NETM-43 by establishing a method for the preparation of calculations including setpoint calculations. NEAM-41 states in section 4 of attachment 4, that instrumentation uncertainties shall be incorporated into safety-related (QA Category i) setpoints. Both of these procedures are in agreement with the original design philosophy that the Reactor Protection Trip system and Engineered Safeguards Features Actuation systems setpoints have instrumentation uncertainties included in their setpoints.

NETM-43 and NEAM-41 are Stone & Webster procedures that Pdnted 5/19/981:5927 PM Page 3 of 5

Northert Utilities ICAVP DR N2. DR-MP3-0833 Millstone unit 3 Discrepancy Report were used for construction of MP3. They have not been reviewed and approved for use by the Plant Oversight Review Committee (PORC) as a NU procedure. Although the guidance provided by these procedures may still be followed if referenced as a design input document they however, can not be used as a stand alone procedure. Once the plant was tumed over to NU setpoint calculations were controlled in accordance with NU design control process (i.e., Setpolni Change Request, NGP's, PDCRs, Design Control Manual, etc.) that was in place at the time. Therefore, the Stone & Webster procedures are not '

applicable for the control of setpoints once NU took ownership of j the plant.

NU credits the design control process for controlling components that perform a protective function in systems imoortant to safety.

Specification SP-ST-ME-944, section 5.3.2 requires components that are being considered for use in a safety related application to be evaluated for its intended function. Part of this evaluation is to review or perform a MEPL determination to determine its required safety and qualification attributes.

Instruments identified in Discrepancy Report, DR-MP3-0833 were upgraded via the MEPL evaluation process. The MEPL determination for these components clearly identifies that these components perform a non-safety related function and were upgraded to QA Category 1 to maintain the plant licensing and I design basis associated with the separation requirements of Reg.  !

Guide 1.75 or to maintain a system pressure boundary. The l instruments identified do not perform a protective function in l systems important to safety per Reg. Guide 1.105 therefore, they I are not required by the design or licensing basis to include uncertainties within their setpoints.

NU considers the misinterpretation of specification SP-ST-EE-286 requirements and discontinuities between the design base documents to be a Significance Level 4 issue.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0833, has j identified a condition previously discovered by NU which

! requires correction. CR M3-97-3083 was issued to resolve conflicts between the present MEPL program requirements for identifying equipment as Category I and the original plant design process for designating instrumentation as Nuclear Safety Related. CR M3-97-1609 was issued to document the need to develop a Millstone 3 specific instrument setpoint, uncertainty and scaling specification which is under development and scheduled to be issued post startup. This document will replace Specification SP-ST-EE-286 for MP3 and as a unit specific specification will more accurately reflect the MP3 licensing basis for instrument setpoints. It will provide clear direction to the engineers to identify when the instrument requires instrument uncertainties to be applied. NU has concluded that Reg. Guide 1.105 requirements are not applicable to these devices ard therefore are not reauired to have instrument uncertainties Pnnted 5/19/961:59 28 PM Page 4 of 5

North 2ast Utilities ICAVP DR No. DR-MP3-0833 Millstone Unit 3 Discrepancy Report included in their setpoints. This is an administrative activity and will not impact the design basis of any system. Based on this NU l

considers this to be a Significance Level 4 issue.

Previously identified by NU? @ Yes U No Non Discrepent Condition?O Yes (e) No Resolution Pending?O ve. @ No Resolution Unresolved?O yes @ No Review initiator: DeMarco, J.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/18/98 SL Comments: jnstrument accuracy determination per RG 1.105, Rev.1:

Per a telecon among NU, NRC, and S&L on 5/18/98, this instrumentation was not required to be classified as Tech Spec, and did not require RG 1.105 error analysis. It was determined that the reason for the upgrade to Category 1 was based on the Diesel Generator Gageboards being fed from orange and purple power sources and that this instrumentation was not an input to Tech Spec or EOP steps.

==

Pr6nted 5/19/981:s9:29 PM Page 5 of 5

Northe:st Util; ties ICAVP DR N2. DR-MP3-0834 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: I & C Design Discrepancy Type: calculation Om Systern/ Process: DGX g

NRC Significance level: 4 Date faxed to NU:

Date Published: 1/10/98 D6screpancy: Non conservatism & calculation methodology vs. RG 1.105 commitment for SP-3EGS-6.

Description:

Calculation SP-3EGS-6 documents the setpoint for level switches 3EGS*LS34A and B that trigger an alarm on low expansion tank level for the Emergency Diesels. However, this calculation does not analyze the impact of instrument inaccuracy, calib.ation uncertainty, and instrument drift upon the Category 1 level switch setpoint. Additionally, the amount of water remaining in the expansion tanks at the low level setpoint was non conservatively calculated to be 178 gallons when, because of the tank's semi-elliptical heads, the remaining water .

volume may actually be less than 144 gallons.

Review l Valid invalid Needed Date InlHator: Reed, William.

O O O 2/19/97 VT Lead: Nerl. Anthony A S O O 12/1a/97 VT Mgr: schopfer, Don K B D 0 12/23/97 IRC Chmn: Singh, Anand K B O O 12/31/97 Date:

INVAUD:

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0834, has I identified a condition not previously discovered by NU which require correction. Reg. Guide 1.105, Revision 1 (MP3's licensing basis), applies to protective instruments and alarms in systems important to safety. A system important to safety is defined as those systems that are necessary to ensure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe condition, or (3) the capability to prevent or mitigate the consequences of accidents that could further result in potential offsite exposures comparable to the guideline exposures of 10CFR Part 100, Reactor Site Criteria". The Reg. Guide Position sections C1 through C6 provides fu ther guidance indicating that the requlrements of the Reg. Guide are to be applied in the development of setpoints with appropriate margins to account for expected uncertainties between the setpoint and the limiting safety settings contained in the Technical Specifications. This provides clarification that the protective instruments and alarms in systems important to safety whose limiting safety settings for which we must maintain maigin for uncertainty are listed in Technical Specifications.

Printed S/19/981:59:54 PM Page 1 of 7

N:rthext Utilities ICAVP DR No. DR-MP3-0834 Millstone Unit 3 Discrepancy Report Cuculation of instrument uncertainties for MP3 is currently govemed by a site wide standard specification, SP-ST-EE-286

" Guidelines for Calculating Instrument Uncertainties". This specification provides generic guidance on calculating instrument uncertainties, howeverit does not provide adequate detail for MP3 in identifying which instruments are required per the MP3 licensing commitments to have instrument uncertainties included in their setpoints. Instead it relies upon the design basis documents (MEPL program, and Specifications) to identify and determine which instruments require inclusion of uncertainties within their setpoints.

CR M3-971609, dated May 21,1997, was issued to document the results of a self-assessment conducted on the MP3 Setpoint Control Topical Area which identified the need to develop a Millstone Unit 3 specific instrument setpoint manual (or specification) to replace the generic SP-ST-EE-286 specification.

Corrective actions for this CR are in process and Specification SP-M3-IC-025 is in development which will provide guidance for the preparation of safety system instrument setpoint and uncertainty calculations for MP3 in a manner that is clearly consistent with the intent of ISA S67.04, "Setpoints for Nuclear Safety-Related instrumentation Used in Nuclear Power Plants",

and requirements of Regulatory Guide 1.105, Rev.1,

" instrument Setpoints for Safety-Related Systems". This administrative enhancement will ensure the appropriate application of uncertainties in the required setpoint calculation.

Due to misinterpretation of specification SP-ST-EE-286 requirements and discontinuities between the design base documents there has been confusion as to which instruments require consideration of uncertainties in their setpoints. The original design philosophy identified those instruments that perform nuclear safety functions with an asterisk (") in the instrument ID and denoted them as Category I. The MEPL program has evolved over the years in such a manner that it has departed from that original design philosophy in identifying Nuclear Safety Related equipment with an asterisk to identifying all QA Category I devices with an asterisk. For example, an instrument which is required to be QA Category I because it performs either a pressure boundary function or because of interrelationships with a Class IE circuit would have an asterisk in its ID. This led to an erroneous belief that those instruments required uncertainties to be applied even though they are not in systems important to safety per Reg. Guide 1.105 requirements.

CR M3-97-3083, dated September 12,1997, was issued to document these inconsistencies between the original instrument identification approach and the FSAR table in identification of Category 1, non nuclear safety functional instrumentation.

Corrective actions for this CR have been identified. AR 97022871-02 issued SP-M3-ME-024 Rev. O,

• Millstone Unit 3 Conventions for System Identifications, System Interfaces, and Equipment identification" as the MP3 controlling document for asterisk (*) coding. AR 97022871-01 will revises FSAR Section 3.2 to reflect use of the MEPL program to identify QA Cateaory l Printed S/19/981:s9 57 PM Page 2 of 7

Neithert Utilities ICAVP DR N2. DR-MP3-0834 Millstone Unit 3 Discrepancy Report l

l equipment and MP3 Specification SP-M3-ME-024 as the controlling document for asterisk (*) cotg of specific MP3 drawings. These changes are administre ve in nature and do not impact the design or licensing basis of any system.

In regards to NETM-43 and NEAM-41:

NETM-43

• Preparation of Category I instrument Setpoint Calculations with Respect to the Requirements of NRC Regulatory Guide 1.105" established a uniform method for Stone

& Webster Control System personnel to identify instruments that require uncertainties to be included in their setpoints. Guidance provided in section 4.0 " Criteria for Instrument Setpoints" clearly indicates that only instruments that have a technical specification limit are to included uncertainties. This is to ensure that instrument drift and / or inaccuracies will not place the instrument setpoint beyond the technical specification limit.

NEAM-41 " Processing of Calculations Millstone Nuclear Power Station - Unit 3," implements the requirements of NETM-43 by establishing a method for the preparation of calculations including setpoint calculations. NEAM-41 states in section 4 of attachment 4, that instrumentation uncertainties shall be incorporated into safety-related (QA Category I) setpoints. Both of these procedures are in agreement with the original design philosophy that the Reactor Protection Trip system and Engineered Safeguards Features Actuation systems setpoints have instrumentation uncertainties included in their setpoints.

NETM-43 and NEAM-41 are Stone & Webster procedures that were used for construction of MP3. They have not been reviewed and approved for use by the Plant Oversight Review Committee (PORC) as a NU procedure. Although the guidance provided by these procedures may still be followed if referenced as a design input document they however, can not be used as a stand alone procedure. Once the plant was turned over to NU setpoint calculations were controlled in accordance with NU design control process (i.e., Setpoint Change Request, NGP's, PDCRs, Design Control Manual, etc.) that was in place at the time. Therefore, the Stone & Webster procedures are not applicable for the control of setpoints once NU took ownership of the plant.

NU credits the design control process for controlling components that perform a protective function in systems important to safety.

Specification SP-ST-ME-944, section 5.3.2 requires components that are being considered for use in a safety related application to be evaluated for its intended function. Part of this evaluation is to review or perform a MEPL determination to determine its required safety and qualification attributes.

Instruments identified in Discrepancy Report, DR-MP3-0834 were upgraded via the MEPL evaluation process. The MEPL determination for these components clearly identifies that these components perform a non-safety related function and were uparaded to QA Cateaory 1 to maintain the plant licensina and l Pnnted 5/19/981:59 58 PM Page 3 of 7 '

DR N;. DR-MP3-0834 f Northert Utilities ICAVP

( Millstone Unit 3 Discrepancy Report design basis associated with the separation requirements of Reg.

Guide 1.75 or to maintain a system pressure boundary. The instruments identified do not perform a protective function in systems important to safety per Reg. Guide 1.105 therefos e, they l are not required by the design or licensing basis to include l uncertainties within their setpoints.

NU considers the misinterpretation of specification SP-ST-EE-286 requirements and discontinuities between the design base documents to be a Significance Level 4 issue.

i With respect to the non-conservative low water volume alarm:

Drawing 2447.300-241-076B shows that the ends on this tank are 42" OD x 1/4" min. ASME Flanged and Dished Heads, not semi-elliptical as stated in the DR.

From drawing 2447.300-241-076B and the material list the ID on this tank is then calculated to be ID = 42 in - 2 x 1/4 in = 41. 5 in The level switch setpoint is 33" below the level switch flange The level switch flange is 42" + 6" = 48" above the outside bottom of the tank.

The level switch flange is 41.75" + 6" = 47.75" above the inside bottom of the tank.

The level switch setpoint is 47.75"- 33" = 14.75" above the inside bottom of the tank.

Using data from Buffalo Tanks manual (copy attached) the SF (flange) dimension for this size head is 3".

When added to the tank cylinder length of 72" we can approximate this tank as a 78" long cylindrical tank with dished heads. (Note SP-3EGS-6 incorrectly used 92 in.)

Analyzing just the cylinder results in:

d (ID) = 41.5 in h = 14.75 in r = 20.75 in Volume of a Cylindrical Tank when tank is less than half full is given by:

V = KA (from page 53 of Machinery's Handbook,24 edition).

Tank Constant = K = C(r^2)L NOTE: Where C = liquid volume conversion factor, the exact value of which depends on the length and liquid volume units being used during measurement : 0.00433 gal /in3 or 7.48 gal /ft3.

K = 0.00433 gal /in3 x (20.75 in)^2 x 78 = 145.4182 gal Printed 5/19/961:59 59 PM Page 4 of 7

Northe:st Utilities ICAVP DR N2. DR-MP3-0834 Ministone unit 3 Discrepancy Report The ratio h/c is given as:

c = 2(( h ( d - h))^1/2 (from page 58 of Machinery's Handbook,24 edition)

= 2((14.75 in ( 41.5 in - 14.75 in))^1/2 = 39.727 in h/c = 14.75 In / 39.727 in = 0.3713 in From page 75 of Machinery's Handbook the Area is determined by using linearinterpolation as: i A = [(1.0105 - 0.9945) / (0.37337 - 0.36998)] * ( 0.3713 -

0.36998) + 0.9945 = 1.0007 V = KA = 145.4182 gal x 1.0007 = 145.52 gal I Therefore, the tank will not be drained in ( 30 days ( 145.52 gal remaining > 144 galleakage over 30 days).

This conservative approximation of volume exceeds the 144 gallons required to compensate for 30 days of systern leakage identified in the calculation. Therefore, if we were to consider the additional volume added by the dished portion of the heads we would have greater than 144 gallons and we are conservative.

The error identified in SP-3EGS-6 does not change the conclusion reached by SP-3EGS-6 or effect diesel operability.

NU has concluded this condition needs to be corrected and will revise calculation SP-3EGS-6 post startup. NU has further concluded based on the above that Discrepancy Report, DR-MP3-0834, is not a Significance Level 3 Discrepancy and should be downgraded to a Significance Level 4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0834, nas identified a condition not previo asly discovered by NU which requires correction. CR M3-97-3083 was issued to resolw conflicts between the present MEPL program requirements for identifying equipment as Category I and the original plant design process for designating instrumentation as Nuclear Safety Related. CR M3-97-1609 was issued to document the need to develop a Millstone 3 specific instrument setpoint, uncertainty and scaling specification which is under development and scheduled to be issued post startup. This document w!ll replace Specification SP-ST-EE-286 for MP3 and as a unit specific specification will more accurately reflect the MP3 !icensing basis for instrument setpoints. It will prov;de clear direction to the engineers to identify when the instrument requires instrument uncertainties to be applied. NU has concluded that Reg. Guide 1.105 requirements are not applicable to these devices and therefore are not required to have instrumer1 uncertainties included in their setpoints. This is an administrative activity and I will not impact the design basis of any system. Based on this NU 1 considers this to be a Significance Level 4 issue.

The calculation error identified does not chanae the conclusion Pnnted 5/19/98 2:00:00 PM Page 5 of 7

Northee:t Utilities ICAVP DR N3. DR-MP3-0834 Millstone Unit 3 Discrepancy Report reached by SP-3EGS-6 or effect the diesel licensing or design basis. The approved correction plan for CR M3-98-0306 will revise calculation SP-3EGS-6 post startup. Based on this NU considers this to be a Significance Level 4 issue.

Prev 6ously identined by NU? O Yes (*) No Non Discrepent Condition?O Yes (*) No Resolution Pending?O ve. C*)No Resolution Unresolved?O ve. @)No Review Acceptable Not Acceptable Needed Date initiator: DeMarco, J VT Lead: Nort, Anthony A B O O 5' 8'S8 VT Mgr: schopfer, Don K O 5/1S'88 IRC Chmn: Singh, Anand K B O O 5/1S'S8 O O O Date: 5/18/98 SL Comments:

A. Instrument accuracy determination per RG 1.105, Rev.1:

Per a telecon among NU, NRC, and S&L on 5/18/98, this instrumentation was not required to be classified as Tech Spec, and did not require RG 1.105 error analysis.

B. EDG Jacket Water Coolant Expansion Tank Level Switch:

1. Considering the straight cylinder only (i.e. without the flanged and dished heads), drawing 2447.300-241-076B shows the tank cylinder length to be 72" with no tolerances given on the drawing.

The assumption that the 72" cylinder length of either, or both, expansion tanks is the "as-built" dimension is not conservative.

2. The data from the Buffalo Tanks manual shows the SF (straight flange) dimensions listed in the table to be the maximum values. The footnote associated with this column of data specifies the SF minimum dimension to be 1.5" in all cases and that SF may be any value between the maximum and the minimum. The assumption that the SF dimension on either, or both, expansion tanks is the maximum is not conservative.

3. Using the 72" cylinder length and the 1.5" SF dimension (2 ends) yields an overall straight cylinder length of 75" which, in tum, yields a tank volume of only 139.9 gallons at the level switch setpoint of 33" below the: instrument standpipe flange. This volume is less than the raquired 144 gallons; however, at the existing process setpoint value of 33" below the istrument standpipe flange, the additional water in the dished heads of each tank may provide the needed 4.1 gallons.

4. The process setpoint value that corresponds to the " bottom of the level glass" criterion specified by the EDG vendor is 32" below the instrument standpipe flange, rather than 33". The portion of the sight glass through which water is visible is 22" long; the 24" length is the distance between the centerlines of the top and bottom tank connections for the sight glass. Setting the level switch to the lowest visible level in the sight glass yields the Printed 5/19/98 2:00:01 PM Page 6 of ?

l Northert Utilitie3 ICAVP DR N2. DR-MP3-0834 Millstone unit 3 Discrepancy Report 4 32" process setpoint value. At the 32" setpoint, the remaining l tank volume in the 75" cylindrical (only) portion of the tank is  ;

approximately 152.9 gallons. )

5. It is prudent that a level switch setpoint (instrument setpoint) value be chosen such that the switch actuates on, or before, the remaining volume in the tank decreases to the specified, design process value of 144 gallons. An instrument accuracy calculation consistent with the guidance provided in RG 1.105, Rev.1, should be performed to determine, with reasonable assurance, that the resultant setpoint provides for switch actuation no later than the process design value.

i

6. The revision of the setpoint value should be determined before startup; however, this is not a requirement. This portion of the DR is a Significance Level 4, since it was determined that the reason for the upgrade to Category 1 was based on the Diesel Generator l Gageboards being fed from orange and purple power sources and that this instrumentation was not an input to Tech Spec or EOP steps.

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Printed 5/19/98 2:00:02 PM Page 7 of 7

N:rthna:t Utilities ICAVP DR No. DR-MP3-0839 Millstone unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p

Discipline: Operations Discrepancy Type: corrective Actior- Om System / Process: HVX g

NRc Significance level: NA Date faxed to NU:

Date Published: 1/22/90 Discrepancy: Commitment Record System is not updated effectively.

Descripuon: S&L reviewed commitments that were made to the Nuclear Regulatory Commission (NRC) in 1984 and 1985. The "date of last change" to the commitment records was May 1997. The commitment records reference letters to the NRC that are either unrelated or incomplete.

Commitment Record (CR) 24576 requires verification of the system flow rate versus pressure drop during plant operation.

The CR notes that in a letter to the NRC dated July 13,1984, that "(1) the system flow rate and pressure drop will be verified at least once every 18 months and (2) the system fans are fixed-speed fans and the system flow rates against pressure drops will be verified during plant operation using the certified fan curves".

The CR references NRC letter A04258. Letter A04258 cfiscusses Emergency Operating Procedures and the Control Room Design Review. This reference is not correct and the NU response to corrective actions in the Commitment Record System can not be verified.

Commitment Record 23439 and NU letter B12516 state "that all QA Category I fire dampers requiring closure under system flow will be tested in place for closure under design flow conditions.

Any dampers which fall this test will be evaluated on a case-by-case basis to determine the best course of corrective action and modified accordingly". This letter was considered to be the final report but is incomplete with respect to stating if specific corrective actions were taken.

These commitment records were reviewed in May 1997 and are unacceptable, These are not isolated examples of concerns with the Commitment Record System. S&L consider this to be a discrepancy.

Review Valid invalid Needed Date initiator: Pleniewicz, R.

O O O 12/22/97 VT Lead: Bass, Ken 8 O O $2/24/97 VT Mgt: schopfer, Don K O O O sis 2/98 IRC Chmn: Singh. Anand K O O O 1' 7/98 Date:

INVALID:

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0839, has identified a NON-DISCREPANT condition.

Printed f/19/98 2:00:25 PM Page 1 of 4

3 Northe:st Utilities ICAVP DR NJ. DR-MP3-0839 Millstone Unit 3 Discrepancy Report The first item referenced in the DR Commitment Record 24576 involves an apparent misunderstanding of the how the List program retrieves documents. It is true that Commitment Record 24576 does reference cotrap file number A04258. It also references List No. CV480001. If the number A04258 is entered into List to search for correspondence you will get two hits as described in the DR. One document refers to Emergency Operating Procedures and the other document refers to the i Control Room Design Review. However, when the subject "ESF '

Atmosphere Cleanup Systems" is queried, the document that comes up is NUREG 1031 (CV480001) which is exactly what we are looking for. The cotrap number is a letter file number unrelated to any List designation. If the number CV480001 is entered into List in the following manner < TITLE cv480001>, the correct document will also come up. This does not represent a discrepant condition.

The second specific item listed on DR-MP3-0839 refers to Commitment Record 23439 and NU letter B12516. It is true that the letter states that any failures would be evaluated on a case by case basis and that the letter was considered a final report with respect to stating if specific corrective actions were taken.

This letter was written in February of 1985 during the Startup and Testing program before commercial operation. Without having completed all testing activities no comprehensive report could have been issued at the time the referred to letter was written which would have addressed every damper and any associated problems. Consequently, there is no discrepancy in evaluating each failure or problem on a case by case basis. This was a logical decision made during the Test and Startup program.

Further, as identified in M3-lRF-00543, those dampers wh;ch had problems closing against flow and which were modified have been identified. This does not relate to any concems over the Commitment Tracking system.

The 50.54f pro,, ram established historical commitment validation with the implementation of Pl 6, " Licensing Reviews". PI 6 provides instructions for identifying commitments through a review of docketed correspondence. Instructions are also provided for the validation of identified commitments and the verification and documentation of their status.

Effective February,1998, thc Licensing Basis Transition Plan has been developed and approved to integrate evolving station process improvements with LB restoration and achieve a transitioned and maintainable LB. The plan contains three parts :

(A.) it describes the recent improvements to the station infrastructure for managing the LB on a going forward basis, and describec additional actions to complete process changes; (B.)

the plan also provides status of CMP deliverables specific to the Unit 3 LB restoration and LB compliance, and those transition actions to reach closure of these projects, (C.) the plan provides a road map to the Station LB and department owners, as well as LB controls.

Implementation of the plan is in progress and includes the followina:

Pnnted 5/15998 2:00:29 PM Page 2 of 4

N::rtherst Utilities ICAVP DR No. DR-MP3-0839 Millstone unit 3 Discrepancy Report 1.) Achieving a smooth transition of each of the RAC 06 Regulatory Commitment identification and Verification Projects into Regulatory Affairs.

2.) Consolidating (or establishing) AITTS assignments, and completion dales for each of the tasks approved within this plan for FSAR, TS, TRM fcc LB transition activities.

3.) Aligning resources to close restart LB issues for Unit 3.

Regulatory Commitment Management Program (RCMP)

Specific to commitments, the current and going forward Commitment tracking is being controlled by procedure RAC 06, Rev.0(attached). RAC 06 establishes the Regulatory Commitment Management Program which consolidates and upgrades existing procedures related to regulatory commitments and integrates into one location all the many organizational actions and interfaces needed to make, implement and change regulatory commitments. The actions and interfaces of the RCMP have been organized into eight distinct elements:

defining, dispositioning, implementing, tracking, maintaining, linking, changing, reporting and monitoring. Each element is described in RAC 06, as well as the entire process for handling commitments. Commitment management has been thoroughly reviewed and significantly strengthened with the implementation of RAC 06 and the baseline reviews performed in the 50.54f effort. There is reasonable assurance, based on the CMP activities, that past commitments have been identified and properly implemented; and going forward, that NU has implemented an effective program which will ensure commitments are identified, tracked, closed and reported property.

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-MP3-0839, has identified a NON-DISCREPANT condition.

The two specific examples noted in the DR do not represent discrepant conditions. In the one case familiarity with the List program as well as the Regulatory Commitment Database (RCD) and practice would have aided the user in finding the desired document. The second item refers to a statement in a response letter to an inspection which took place during the plant star'up and testing program. The decision that individual damper failures would be addressed on a case by case basis was reasonable and acceptable considering when it was made during the startup program. In general, Commitments have been identified and validated as part of the CMP program. The new RAC 06 procedure ensures that going forward, there is a consistent and consolidated program for identifying, validating, statusing and tracking new and existing commitments.

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

Pnnted s/1&S8 2.00:29 PM Page 3 of 4

Northear.t Utilities ICAVP DR Ns. DR-MP3-0839 Millstone unit 3 Discrepancy Report Previously identified by NU? O yes (e) No Non Discrepent Condition? e ves O No Resolution Pend 6ng?O yes @ No ResolutionUnresolved?O vos @ No Review A optable Not Acceptable Needed Date ,

gg,gy. S r, R.

VT Lead: Bass, Ken O O =

VT Mgr: Sctgfer, Don K IRC Chmn: Singh, Anand K Dete: 5/18/98 SL Commerds:

l I

Printed 5/19/98 2:00.31 PM Page 4 of 4

1 Northe st Utilitiea ICAVP DR N3. DR-MP3-0888 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element: Change Process {

p D6scipline: I & C Design Om l Discrepancy Type: corrective Action g System / Process: sWP NRC Significance level: NA Date faxed to NU.

I Date Puthshed 2/5/98 i D6screpen:y: inadequate Adverse Condition Report significance level.

DescripHon: Adverse Condition Report (ACR) M3-96-0357 documents an l inadequate description in Licensing Event Report (LER) 96-005-000. The original concem, identified by Vertical Slice Review Team item #506, was written to address a design noncompliance l created by Bypass Jumper 3-90-20. This ACR was incorrectly categorized as level a "D." The ACR documents that the LER did not report the design basis violation associated with the bypass

)

l Jumper. Such an omission from an LER warrants a significance level higher than level "D." This document should be categorized I at the same level as the original problem. A significance classification higher than level "D" would have resulted in a re- i review of the entire investigation. This investigation would l

address the lack of sufficient discussion regarding violation of l the plant's design basis documents (DBD) and assessed the

! completeness of the LER's revision. According to NUREG-1022, errors in an LER must be corrected in a revised report, and this revised report must be a stand alone document. Since the original disposition determined that the condition created by Bypass Jumper 3-90-20 was reportable, and the result of an inadequate safety evaluation, the subsequent disposition revising the LER should have re-reviewed the original Root Cause I

Analysis and other supplemental investigations to determine the adequacy of this revision. Additionally, the ACR's Corrective I Action Plan stated that there is additional discussion being added

! to the causal factors determination and corrective action; I howtver, this revision is inconsistent with RP-4's requirements for dispositioning level"D" ACRs. Level"D" ACRs do not require a causal factor determination.

Review Valid invalid Needed Date l

Initiator: Dombrowsid. Jim O O O 1/27/98 l

VT Lead: Ryan, Thomas J B O O /27/98 1/29/98 VT Mgr: schopfer, Don K O O O )

O_

l 2/2/98 IRC Chmn: singh, Anand K O O

( Date:

INVALID:

Date: 5/19/98 l RESOLUTION: Disposition:

NU has concluded that the issues reported in DR-MP3-0888 have identified a NON-DISCREPANT condition.

The inadequacy of Bypass Jumper 3-90-20 was originally l documented on 3/21/96 via ACR 10795. ACR 10795 was Pnnted 5/19/98 2:01:04 PM Page 1 of 3 i

Northe:st utilitie3 ICAVP DR N2. DR-MP3-0888 Millstone Unit 3 Discrepancy Report assigned a significance level"C" which required an Apparent Causal Factors determination in accordance with RP-4 Rev.1, which was in effect at that time. The corrective actions developed for ACR 10795 provided immediate and long-term resolution for the adverse condition including the removal of the bypass jumper and the installation of a permanent plant modification in accordance with the design change process. In addition to ACR 10795, LER 96-005-00 was issued on 4/19/96 to document this condition. l Subsequently, on 7/2/96, ACR M3-96-0357 was initiated to identify shortcomings in the response included in LER 96-005-

00. As a result, a supplemental response, LER 96-005-01, was submitted to address the issues not repotted in the initial LER response. The corrective actions for ACR 10795 and ACR M3 l i

0357 have adequately addressed the technical and regulatory issues related to Bypass Jumper 3-90-20.

I The discrepancy identified by S&L pertains to the significance  !

level "D" assigned to ACR M3-96-0357. The adverse condition {

described in ACR M3-96-0357 pertained to the omission of a )

reference to Design Basis Documentation information in LER 96- (

005-00. The ACR was assigned a significance level "D" by the l Management Review Team (MRT) in accordance with RP-4 )

Rev.2 which was in effect at that time (7/2/96). Although the )

original ACR 10795, which identified the technical inadequacy of  !

the Bypass Jumperwas assigned a significance level"C", ACR M3-96-0357 was assigned a significance level *D", based on MRT's evaluation of the adverse condition as described in the ACR. Each of the ACRs were evaluated individually and assigned a significance level based on the extent of the condition described in the ACR. RP-4 did not require MRT to assign a significance level based upon the significance level of a l previously issued ACR, whether it was a related issue or not. As l a result, this issue is considered not discrepant. l S&L indicates that the corrective action plan for ACR M3 0357 stated that additional discussion would be added to the causal factors determination and corrective actions, was not in i accordance with RP-4, which did not require Level D ACRs to l

perform a causal factors determination. Level D ACRs did not require a causal factors determination, However, the corrective action for ACR M3-96-0357 was referring to the causal factors and corrective action sections of the revised LER response, not the actual ACR investigation. As a result, this issue is considered not discrepant.

Additionally, the Millstone Corrective Actions Program was significantly upgraded in February of 1997 following the performance of QAS Audit QAS-96-4108, dated June 19,1996, and the Corrective Action Plans for ACR-13318 and CR M3 0111. The governing procedure, RP-4, provides specific guidance to the Management Review Teams on the significance level classification of Condition Reports (CRs). Specifically relating to the subject matter of this DR, RP-4 ensures that all CRs which are determined to describe a condition which is fVinted s/19/96 2:01:07 PM Page 2 of 3

North:ast Utilities ICAVP DR No. DR-MP3-0888 Millstone Unit 3 Discrepancy Report reportable are assigned the highest significance level of 1.

Significance level criteria do not apply as these issues are non-discrepant.

Conclusion:

NU has cr- uded that the issues reported in DR-MP3-0888 have ide; afied a NON-DISCREPANT condition. ACRs 10795 and M3-96-0357 were each evaluated individually and assigned significance levels based on the significance of the specific condition described on each respective ACR. No requirement existed to assign a significance level based on the significance level of a previously issued ACR. The corrective actions for ACR M3-96-0357 refers to a revision to the causal factors determination of the supplemental LER response, not the actual ACR investigation as described by S&L. Significance level criteria do not apply as these issues are non-discrepant.

Attachments: ACR 10795 ACR M3-96-0357 LER 96-005-00 LER 96-005-01 Previously identified by NU? O Yes (G) No Non Discrepant Condition?f8) Yes O No Resolution Pending?O ve. Ce)No Resoiution unresoived?O ves Ce) No Review initiator: Caruso, A.

VT Lead: Ryan. Thornas J VT Mgr: schopfer Don K IRC Chmn: singh, Anand K Date: 5/19/98 st Comments: NU's response is acceptable.

Based on ACR M3-96-0357's corrective action and LER 96-005-01 (attachrrents), NU has re-reviewed and upgraded the "Cause of Event " and the Analysis of Event" to accurately describe the plant condition.

In addition, the Millstone Corrective Actions Procram was significantly upgraded in February of 1997. The goveming procedure, RP-4, provides specific guidance to the Management Review Teams on the significance level classification of Condition Reports (CRs). Specifically relating to the subject matter of this DR, RP-4, Millstone Corrective Aciions Program, now ensures that a!! CRs which are determined to describe a condition which is reportable are assigned the highest significance level of 1.

DR-MP3-0888 can be considered non-discrepant.

Printed s/19G8 2:01:08 PM Page 3 of 3

Northe st Utilitiss ICAVP DR No. DR-MP3-1004 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Maintenance Discrepancy Type: Der.lgn Control Procedure Om SystenVProcess: DGX g

NRC Significance level: 4 Date faxed to NU:

Date Published: 2/5/98 Discrepancy: Adequate information was not provided to verify updating of parts and materials.

Description:

Adequate documentation was not provided that could be used to verify the changes to materials, parts, or components. Various PDCR's included changing the material of piping or tubing or updating a part or component. We were unable to verify that 5 these changes were incorporated in a controlled document which would insure that the revised configuration would be maintained during subsequent maintenance activities.

This is considered a generic programmatic discrepancy.

A partial listing of PDCR's that included changes to material or parts which could not be verified includes:

PDCR 3-96573 PDCR 3-85-025 PDCR 3-86-126 PDCR 3-86-135 PDCE 3-87-057 PDCR 3-87 076 PDCR 3-90-234 PDCR 3-91-022 PDCR 3-91024 PDCR 3-93-220 PDCR 3-94-094 PDCR 3-91-056 PDCR 3-91 152 PDCR 3-92-024 PDCR 3-93-067 PDCR 3-94-111 PDCR 3-96-557 PDCR 3-96-076 PDCR 3-86-153 PDCR 3-89-032 PDCR 3-90-010 PDCR 3-90-235 PDCR 3-92-043 PDCR 3-93-043 PDCR 3-03-056 PDCR 3-93-075 PDCR 3-94-040 PDCR 3-94-065 PDCR 3-96-056 PDCR 3-96-078 Revsew Valid invalid Needed Date initiator: Sr> ear. R. 1/28/98 Printed 5/19/98 2.01:38 PM Page 1 of 3

Northe:st Utilities ICAVP DR N2. DR-MP3-1004 Millstone Unit 3 Discrepancy Report instestor; spear, R. /2mie O O O VT Leed: Bass, Ken O O O /28/9e VT Mgr: Schopfer, Don K Q O O 1/29/98 IRC Chmn: Singh, Anand K O O O 2/2/98 Date:

INVAllD:

Date: 5/18/98 RESOLUTION: Disposition; NU has concluded that this issue reported in DR MP3-1004 has identified a CONFlRMED SIGNIFICANCE LEVEL 4 condition which requires correction. The lack of incorporation of changes to materials, parts, or components into PMMS has been addressed extensively in the approved corrective action plan for CR M3-98-0407. The approved corrective action plan for CR M3-98-0407 investigated not only the design procedures but also the procedures associated with work control and procurement activities to ensure process mapping would accurately capture all activities and procedures. From the process mapping findings, changes will be implemented ')y the end of 1998. In addition, personnel training and familiarization will be performed to ensure future compliance with procedures.

The PMMS data base component ID's were reviewed for completeness during the system reviews performed by the CMP Project. These 50.54f System Readiness Reviews have been forwarded previously by transmittal number 3 o n January 10, 1997. Over 4000 component ID's have been added to the database since these reviews were completed. Non-safety related components are not included in the data base unless they require specific maintenance. Also, those sub-components which do not receive specific maintenance are not listed individually.

Conclusion:

NU has concluded that this issue reported in DR-MP3-1004 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. The approved corrective action plan for CR M3-98-0407 addresses the lack of incorporation of materials parts, or components into the PMMS Program both procedurally and culturally. Both procedural changes and more training of personnel will be done to ensure an effective PMMS Program exists. The data base was also reviewed to ensure accurate information exists and can be used for maintenance and design activities.

Previously identined by NU? O Yes (8) No Non Discrepant Condition?O Yes @ No ResolutionPending?O v s (6) No Resoiuiion unr.soived?O ves @ No Review Initiator: spear, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/18/98 Pnnted 5/19/98 2:01 A2 PM Page 2 of 3

l 1

l I l Northeast Utilities ICAVP DR N3. DR-M73-1004 l Millstone unit 3 Discrepancy Report sL Comments: Sargent & Lundy raised numerous questions regarding the control of spare parts in the performance of corrective and preventive maintenance. Control of spare parts appeared to be an issue in i routine maintenance situations, but was even more of a concem l to us 9fter installation of system modifications. These concems were raised in several Discrepancy Reports in addition to this one, all were categorized as Level 4.

NU has demonstrated that adequate control has been in place in the past to assure that proper spare parts have been installed in maintained equipment. Successful closure of the DRs demonstrates that this is not a Design or Licensing Basis issue.

However, Sargent and Lundy makes the following observations regarding the spare parts issues as they relate to maintenance practices. The past and current methods for controlling spare parts in the maintenance of components was and is a highly man-power intensive effort. This is because of the unreliability of the coding and identification of spare parts in the current electronic maintenance and material control system, PMMS. Because of the high degree of uncertainty as to the correctness of the parts identified, a planner is required to research back to a certified and approved design basis document when specifying parts for each job order planned. This is an extremely time consuming undertaking to assure that the most recent and approved design basis document is located. This labor intensive practice drastically increases planning time. This is of particular concem since the same amount of planning time is expended on repetitive preventive maintenance tasks as well as non-repetitive corrective maintenance tasks. The process also relies heavily on information passed from planner to planner as new information is identified. This information is not contained in procedures or any other written medium. This is often referred to as " tribal knowledge." This type of knowledge is not readily transferable and is often not retrievable. It relies heavily on the day to day performance of individuals rather than on a proven process.

While NU has successfully demonstrated to our satisfaction that these methods have not resulted in application errors of spare parts to date, as maintenance activities increase through unit restart and power operation, these methods may result in an increased potential for error. Through their responses to various DRs, NU has identified changes that are in process for identification and qualification of the spare parts inventory. These changes, both short term and long term, should improve the process and result in a reliable delivery of spare parts with less burden on the planning staff. '

Printed 5/19/98 2:01:44 PM Page 3 of 3

N rthert Utilities ICAVP DR No. DR-MP3-1011 Millstone Unit 3 Discrepancy Report Review Group: Operations & Maintenance and Testing DR RESOLUTION ACCEPTED Discipline: Mechanical Design Potential Operability issue Discrepancy Type: Design Control Procedure g

SystenVProcess: DGX NRC Significance level: 3 Date faxed to NU:

Date Published: 3/598 Discrepancy: Unreviewed Safety Questions Conceming the MP-3 Emergency Diesel Generators

Description:

Modification 3-91-196 (MOD) was reviewed and issued by NU's PORC on 12/4/91. The PDCR package was completed and submitted to Nuclear Records on 8/15/92. The need for the modification was that the fuel oil sample point was down stream 5 of the strainers that remove particulate of 200-mesh size or larger from the fuel oil. Consequently, the strainers could affect the sample particulate analysis. The purpose of the modification is to permanently remove the strainer elements from strainer housings 3EGF*STR1C and 3EGF*STR1D (one of two on each Diesel) allowing for a more representative sample of sediment in the fuel oil.

The design requirements for the Emergency Diesel Fuel Oil System, in part, are as stated below:

Section 9.5.4.1 of the FSAR, ' Design Bases', states that the design bases for the EGF shall be:

1. In accordance with Regulatory Guide 1.137, for fuel oil systems design, fuel oit quality, and tests.

2. In accordance with General Design Criterion 17, for the capability cf the fuel oil system to meet independence and redundancy criteria.

The removal of one of the strainers from each Diesel, removes the reaundancy which is required in the two fuel oil transfer systems on each Diesel. This item is also described in MP3's FSAR, Section 9.5.4.2 System Description, which states: *Each flow path consists of a fuel oil storage tank, two 100 percent capacity fuel oil transfer pumps and strainers, a day tank, and piping to each respective diesel engine..

Regulatory Guide 1.137, Section C, ' Regulatory Position states',

• 1. The requirements for the design of fuel-oil systems for diesel generators that provide standby electrical power for a nuclear power plant that are included in ANSI N195-1976, ' Fuel Oil Systems for Standby Diesel-Generators,' provide a method acceptable to the NRC staff for complying with the pertinent requirements of General Design Criterion 17.. "

ANSI N195-1976, Section 6.3, ' Strainers', states: "A strainer shall be provided for each engine. The mesh of the strainers shall be as required to prevent overloading of the engine fuel filter. The strainer shall be of duplex design".

The original design of the EDG Fuel Oil System is also in non-rnmnfinnra with ANRt N1Q8L1Q7A which rannirpe riunfav Printed 5/19/96 2:24:22 PM Page 1 of 4

Northext Utilities ICAVP DR N2. DR-MP3-1011 Millstone unit 3 Discrepancy Report Strainers. A single Y-type strainer is installed in each Fuel Oil Subsystem instead of the Duplex Strainers.

Table 1.8-1 of MNPS-3 FSAR states that NU will comply with Reg. Guide 1.137 except for the cited clarifications and exceptions. The only exception taken, is that MP-3 has 3-day storage tanks for each Diesel, instead of the required 7-day tanks.

It should also be noted that ACR M3-96-0240 was written to track a ' Difference in Professional Opinion (DPO), due to a

'concem' from NU's Nuclear Safety Engineering group. The 50.54f EDG Review Team questioned the technicaljustification for this MOD and whether or not it could result in a potential reduction in reliabihty. The conclusion of this ACR was that the strainers should remain removed, because *There is also less risk of an EDG failure with the cartridges removed than with them installed". No basis for this assumption is included in the ACR.

The Safety Evaluation performed by NU determined that NO Unreviewed Safety Question (USQ) exists. However, ICAVP believes that this Safety Evaluation is deficient. This is due to the fact that NU's Safety Evaluation appears to have only looked at the 'C' and 'D' strainers being used during the Fuel Oil Sample Surveillance. No evaluation of the long term effects of operating with the unstrained oil pump was performed. Further, no analysis was performed to determine the effects on sludge cany-over or its effect on the engine fuel filters as the tank levels diminish. This review should have included an analysis of the 10% minimum level allowed in the Fuel Oil Storage Tanks and some minimal level in the Day Tanks when operated in manual utilizing operators. NU did not take into account that the unstrained pumps 'C' and 'D' are also the ones which have dual electrical feeds, making them the more reliable Fuel Oil ,

Transfer Sub-Systems during a LOP event .

NU's FSAR Section 9.5.4.2, ' System Description', item 2 states:

• Each pump has sufficient capacity to fill both day tanks with 1 both emergency generators running, since the fuel consumption j at rated load and speed for one emergency generator is 6.16 gpm." This implies that if one Fuel Oil Storage Tank were inoperable, then both EDG's would be feed from one tank. This means that the operable storage tank would be filled on approximately a daily bases, without any provision for settling time. Worst case would be with an unstrained pump in-service.

The FSAR does not adequately address that any exceptions to the design requirements was taken for the MOD (see Table 1.8-1 of NU's FSAR). It should be noted that the language conceming the MOD in Sections 8 and 9 of the FSAR is ambiguous and not all required parts of the FSAR reflect the MOD. These include, in part:

1. FSAR, Section 9.5.4.2:"Each flow path consists of a fuel oil storaae tank. two 100 percent capacity fuel oil transfer pumps Pnnted 5/19/98 2:24:25 PM Page 2 of 4

l N:rthert Utilities ICAVP DR Ns. DR-MP3-1011 Millstone Unit 3 Discrepancy Report l

and strainers, a day tank, and piping to each respective diesel engine."

j 2. FSAR, Section 9.5.4.2, item 6: "A duplex fuel oil strainer is provided for each diesel generator by the manufacturer."

3. FSAR, Section 9.5.4.3: As a result of the redundancy incorporated in the system design, the EGF system provides its minimum required safety function under any one of the following conditions: . . loss of off-site power coincident with maintenance outage or failure of one emergency generator fuel oil transfer pump associated with each emergency generator; and loss of off-site power coincident with maintenance outage or failure of either emergency generator fuel oil storage tank.

It is not clear that the pumps without strainers installed are still in their 'as designed' system alignment. By NU's admission (ACR M3-96-0240), this means that the unstrained pump may start before the normal lead pump and deliver unstrained oil for a prolonged period of time.

From the available information, the ICAVP Team could not determine if the MOD design of the EDG Fuel Oil System would definitely result in both EDG's being inoperable. Thus, a NRC Significance Level of 3 is assigned. However, based on NU's response, the DR's NRC Significance Level could escalate.

Review Valid invalid Needed Date Initiator: Ungeran, R. B 0 0 2/24/98 VT Lead: Bass, Ken 5 0 0 2/25/98 VT Mgr: schopfer, Don K G O 2/26/98 IRC Chrnn: singh, Anand K 8 O O 3/2/98 Date:

INVALID:

Date: 5/15/98 RESOLUTION: Disposition:

Northeast Utilities RP4-2 CR Change Form (attached), revised the corrective action plan for CR M3-98-1373 as follows:" Revise FSAR Table 1.8-1 to identify the differences between MP3 DG fuel oil piping strainer design and section 6.3 of ANSI N195-1976. Revise FSAR Section 9.5.4 as required to clearly describe the configuration of the strainers in the transfer pump discharge i lines. The justification for this difference from the ANSI standard ,

j is supported by the MP3 procedures which assure that the oil quality stored exceeds the standards recommended by the diesel manufacturer. The justification should include discussion of the following points: (1) Sampling of the oil received; (2) Condition of the storage tank; (3) Condition of the fuel oil piping; (4)

Methodology of the sampling (specifically draining the dead leg of the sample line prior to taking the sample." NU has concluded this DR to be a " CONFIRMED DISCREPANT" Significance Level 4 issue.

Conclusion:

Northeast Utilities RP4-2 CR Change Form (attached), revised Printed 5/19/98 2:24:27 PM Page 3 of 4

North:ast Utilili:s ICAVP DR No. DR-MP31011 Millstone Unit 3 Discrepancy Report the corrective action plan for CR M3-96-1373 to revise FSAR Section 9.5.4 as required to clearly describe the configuration of the strainers in the transfer pump discharge lines, revise FSAR Table 1.8-1 to identify the differences between MP3 DG fuel oil piping strainer design and section 6.3 of ANSI N195-1976 and to provide the justification for this difference from the ANSI standard. NU has concluded this DR to be a

• CONFIRMED DISCREPANT

• Significance Level 4 issue.

Previously identified by NU? O Yes (G) No Non Discrepant Condition?O Yes (G) No Resolution Pending?IS) Yes O No Resolution Unresolved?O Yes @ No Review initiator: spear, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/15/98 SL Comments: S&L concurs with revised corrective action plan for CR M3 1373 as described in the discrepancy response. S&L considers the item as pending resolution until we have reviewed the FSAR /

Safety Evaluation described in the response.

Pnnted 5/19/98 2.24.29 PM Page 4 of 4

Northe st Utilities ICAVP DR N3. DR-MP3-1049 Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Corrective Acton Process Diecipl6ne: I & C Desgn Discrepancy Type: Corrective Action ;mp;.nwani, System / Process: NEW g  !

NRC Sign 6ficaru:e level: 4 Date faxed to NU:

Date Published: 2/23/98 Discrepancy: Inadequate technical closure of UIR 2451

Description:

UlR 2451 reported: "various instruments are CAT 1 and the associated set point calculations are QA CAT 2"; the UIR specifically lists Emergency Diesel Generator (DGX) System instrument setpoint calculations SP-3 EGO-1 Rev 0, SP-3EGS-1 Rev 0, SP-3EGS-4 Rev 1, SP-3EGS-5 Rev 1, and SP-3EGS-7

)

Rev 1. Resolution of this UIR was tracked via A/R 97018724-01 which, as of 9/6/97, stated: "MMOD M3-97511 has been l completed that has corrected all these calculations."

A review of the latest versions of these setpoint calculations revealed that they were re-labeled " CAT 1" but the calculation methodology itself was not upgraded to meet the requirements of l RG 1.105 Rev.1 as committed to by NU. The latest versions of l

these calculations fail to analyze the impact of instrument inaccuracy, calibration uncertainty, and instrument drift upon their respective instrument setpoint values.

Review I Valid Invalid Needed Date )

initiator: Reed, William.

O O O 2/13/98 VT Lead: Neri, Anthony A B O O 2/i3/98 VT Mgr: schopfer, Don K O O O 2/5a/98 IRC Chmn: singh, Anand K O O O 2/19/98 Date:

INVALID:

Date: 5/18/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0833, has )

identified a condition previously discovered by NU which l' requires correction. Reg. Guide 1.105, Revision 1 (MP3's licensing basis), applies to protective instruments and alarms in j systems important to safety. A system important to safety is  ;

defined as those systems that are necessary to ensure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe condition, or (3) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guideline exposures of 10CFR l Part 100, " Reactor Site Criteria". The Reg. Guide Position i sections C1 through C6 provides further guidance indicating that the requirements of the Reg. Guide are to be applied in the development of setpoints with appropriate margins to account for expected uncertainties between the setDoint and the limiting safety settings contained in the Technical Specifications. This i

provides clarification that the protective instruments and alarms Printed 5/19/98 2:02:33 PM Page 1 of 4

Northe:st Utilities ICAVP DR N2. DR-MP3-1049 Millstone Unit 3 Discrepancy Report in systems important to safety whose limiting safety settings for which we must maintain margin for uncertainty are listed in Technical Specifications.

Calculation of instrument uncertainties for MP3 is currently govemed by a site wide standard specification, SP-ST-EE 286

" Guidelines for Calculating instrument Uncertainties". This specification provides generic guidance on calculating instrument uncertainties, however it does not provide specific detail as to identifying which instruments are required per the MP3 licensing commitments to have instrument uncertainties included in their setpoints. Instead it relies upon the design basis documents (MEPL program, and Specifications) to identify and determine which instruments require inclusion of uncertainties within their setpoints.

CR M3-97-1609, dated May 21,1997, was issued to document the results of a self-assessment conducted on the MP3 Setpoint Control Topical Area which identified the need to develop a Millstone Unit 3 specific instrument setpoint manual (or specification) to replace the generic SP-ST EE-286 specification.

Corrective actions for this CR are in process and Specification SP-M3-IC-025 is in development which will provide guidance for the preparation of safety system instrument setpoint and uncertainty calculations for MP3 in a manner that is clearly consistent with the intent of ISA S67.04, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants",

and requirements of Regulatory Guide 1.105, Rev.1,

" Instrument Setpoints for Safety-Related Systems". This administrative enhancement will ensure the appropriate application of uncertainties in the required setpoint calculation.

Due to misinterpretation of specification SP-ST-EE-286 requirements and discontinuities between the design base documents there has been confusion as to which instruments require consideration of uncertainties in their setpoirits. The original design philosophy identified those instruments that perform nuclear safety functions with an asterisk (*) in the instrument ID and denoted them as Category 1. The MEPL program has evolved over the years in such a manner that it has departed from that original design philosophy in identifying Nuclear Safety Related equipment with an asterisk to identifying all QA Category I devices with an asterisk. For example, an instrument which is required to be QA Category I because it performs either a pressure boundary function or because of interrelationships with a Class IE circuit would have an asterisk in its ID. This led to an erroneous belief that those instruments required uncertainties to be applied even though they are not in systems important to safety per Reg. Guide 1.105 requirements.

CR M3-97-3083, dated September 12,1997, was issued to document these inconsistencies between the original instrument identificati3n approach and the FSAR table in identification of Category 1, non nuclear safety functional instrumentation.

Corrective actions for this CR have been identified. AR 97022871-02 issued SP-M3-ME-024 Rev. O. " Millstone Unit 3 Printed 3/19/98 2:02:36 PM Page 2 of 4 l

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N:rthert Utilition ICAVP DR N3. DR-MP3-1049 Millstone Unit 3 Discrepancy Report l

Conventions for System Identifications, System Interfaces, and Equip-ment identification" as the MP3 controlling document for asterisk (*) coding. AR 97022871-01 will revise FSAR Section 3.2 to reflect use of the MEPL program to identify QA Category I equipment and MP3 Specification SP-M3-ME-024 as the controlling document for asterisk (*) coding of specific MP3 drawings. These changes are administrative in nature and do not impact the design or licensing basis of any system.

NU credits the design control process for controlling components that perform a protective function in systems important to safety.

Specification SP-ST-ME-944, section 5.3.2 requires components that are being considered for use in a safety related applicat!on to be evaluated for its intended function. Part of this evaluation is to review or perform a MEPL determination to determine its required safety and qualification attributes.

Instruments identified in Discrepancy Report, DR-MP3-1049 were upgraded via the MEPL evaluation process. The MEPL determination for these components clearly identifies that these components perform a non-safety related function and were upgraded to QA Category 1 to maintain the plant licensing and design basis associated with the separation requirements of Reg.

Guide 1.75 or to maintain a system pressure boundary. The instruments identified do not perform a protective function in systems important to safety per Reg. Guide 1.105 therefore, they are not required by the design or licensing basis to include uncertainties within their setpoints.

UIR 2451 reported: "various instruments are CAT 1 and the associated set point calculations are QA CAT 2"; the UIR

" Recommended Disposition Details" suggested upgrading the calculations to QA CAT 1. The concem identified in this UIR has been adequately addressed by revising the affected calculation to match the device classification. The device classification "QA CAT I" by itself does not dictate the applicability of Reg. Guide 1.105 setpoint calculation methodology that is to be utilized.

Applicability is based upon the instrument safety function as elucidated above and not strictly based upon the device classification.

NU has concluded that Reg. Guide 1.105 requirements are not applicable to these devices and therefore are not required to have instrument uncertainties included in their setpoints. This is an administrative activity and will not impact the design basis of any system. Based on th;s NU considers this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0833, has identified a condition previously discovered by NU which requires correction. CR M3-97-3083 was issued to resolve conflicts between the present MEPL program requirements for identifying equipment as Category I and the original plant design process for desianatina instrumentation as Nuclear Safety Pdnted 5/19/98 2:02:36 PM Page 3 of 4 l

i Northert Utilitie3 ICAVP DR N2. DR-MP3-1049 Millstone Unit 3 Discrepancy Report Related. CR M3-97-1609 was issued to document the need to develop a Millstone 3 specific instrument setpoint, uncertainty and scaling specification which is under development and scheduled to be issued post startup. This document will replace Specification SP-ST-EE-286 for MP3 and as a unit specific specification will more accurately reflect the MP3 licensing basis for instrument setpoints. It will provide clear direction to the engineers to identify when the instrument requires instrument uncertainties to be applied. NU has concluded that Reg. Guide 1.105 requirements are not applicable to these devices and therefore are not required to have instrument uncertainties included in their setpoints. This is an administrative activity and will not impact the design basis of any system. Based on this NU considers this to be a Significance Level 4 issue.

Previously identified by Nu? (*) Yes O No Non Discrepant Condition?O Yes (8) No Resolution Pending?O Ya @ No Roosution unre.oived?O va @ No Review Acceptable Not Acceptable Needed Date VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/18/98 sL comments: Clarification: NU's response references DR-MP3-0833 which is virtually identical to DR-MP3-1049 except for the calculations referenced.

Instrument accuracy determination per RG 1.105, Rev.1:

Per a telecon among NU, NRC, and S&L on 5/18/98, this instrumentation was not required to be classified as Tech Spec, and did not require RG 1.105 error analysis. It was determined that the reason for the upgrade to Category 1 was based on the Diesel Generator Gageboards being fed from orange and purple power sources and that this instrumentation was not an input to Tech Spec or EOP steps.

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Northert Utilitie3 ICAVP DR Nr. DR-MP31067 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: I & C Design Discrepancy Type: Design Control Procedure g

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

Date Published: 3/14/98 i Discrepancy: FSAR specified accuracy for the containment does not match Westinghouse supplied basis calculation

Description:

Per FSAR section 7.3.1.2 (page 7.3-61) required containment j pressure signal accuracy for a steam break protection is +/- 1.8 1 percent of full scale.

I Per Table 3-32 on page 66 of WCAP-14353, dated July,1995, l titled " Westinghouse Setpoint Methodology for Indication, Control and Protection Systems for Millstone Nuclear Power Station Unit 3,24 month fuel cycle evaluation", the main control board indication (normal environment) channel statistical allowance for the containment pressure it.dication is 4.0% of full scale. Since, the part of the signal of interest is control part, the indication accuracy portion can be discounted from the 4 percent accuracy figure.

]

Even after discounting for uncertainties for readability (1% FS),

and drift components for sensor drift (1% FS), rack drift (2% FS) from 30 months to 24 months, the channel allowance is higher than +/-1.8% specified in the FSAR. j Review l Valid invalid Needed Date initiator: Hindia, R.

8 O O 3/3/98 1 VT Lead: Neri. Anthony A B O O 3/d'S8

)

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

IRC Chmn: singh Anand K B O O 3' o'S8 l

Date:

INVALID:

Date: 5/14/98 RESOLUTION: Disposition: NU has concluded that the issue reported in Discrepancy Report DR-MP3-1057 has identified a NON-DISCREPANT condition. FSARCR 97-MP3-284 revised the entire text of section 7.3.1.2.6 " Minimum Performance Requirements." The value in question, " Containment Pressure Signal +/-1.8 percent of full scale" which used to be in FSAR section 7.3.1.2.6, is no longer present in the FSAR. Section 7.3.1.2.6 now states ". .. instrument channel uncertainty components are tabulated in Technical Specifications Table 3.3-  ;

4." i Tech. Spec Table 3.3-4 provides trip setpoints and allowable values used for bistable calibration and surveillance tests. It does not specify instrument channel uncertainty values, it should be noted that the DR states that WCAP-14353 lists a Printed 5/19/98 2:03.01 PM Page 1 of 2

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Northe:st Utilitien ICAVP DR No. DR-MP3-1067 Millstone Unit 3 Discrepancy Report l

value of 4.0% of " full scale." The WCAP actually states the channel uncertainty as 4.0% of " span." Additionally, WCAP-14353 is not the appropriate reference for the instrument channel uncertainty associated with the Containment High Pressure trip.

WCAP 10991, Rev. 3 " Westinghouse Setpoint Methodology for Protection Systems Millstone Nuclear Power Station Unit 3"is correct reference. PTSCR 3-30-97 (*24 Month Fuel Cycle") will update Table 3.3-4 to conform with the latest revision, WCAP 10991,Rev.5.

Ccaclusion: NU has concluded that the issue reported in Discrepancy Report DR-MP3-1057 has identified a NON-DISCREPANT condition. The cited value from the FSAR was deleted by FSARCR 97 MP3-284. ESFAS trip setpoints and allowable values for bistable calibration and surveillance testing are tabulated in Tech. Spec. Table 3.3-4 Previously klentified t>y NU7 U Yes (G) No Non Discrepant Condition?(8) Yes Q No Resolution Pending?O Y.s @ No R.soiuiion unresoived70 Yes @ No Review initiator: Hindia. R.

VT Lead: Nerl. Anthony A VT Mgr: schopfer, Don K O O me IRC Chmn: singh, Anand K Date: 5/13/98 st Comments: The Tech. Spec. table 3.3-4 in its present form is not in agreement with WCAP-10991. However, per the disposition provided PTSCR 3-30-07 will update Table 3.3-4 to conform with the latest WCAP 10991, Rev. 5.

Based on these facts the dispostion provided is aceptable.

Pnnted 5/19/90 2:03:05 PM Page 2 of 2

Northeast Utilitie3 ICAVP DR N2. DR-MP3-1094 Millstone Unit 3 Discrepancy Report Review Group: System Dr.etESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation SystemProcess: NEW g l NRC Significance level: 4 Date faxed to NU:

Date Published: 4 9/98 Discrepancy: Modeling of Air Conditioning Unite in Calculation T-01528-S3

Description:

Durl:ig review of calculation T-0. 528-S3, Rev. 0

• Evaluation of ECCS Passive Failure in RSS Puig Cubicle" discrepancies regarding the modeling of the sensible ano sateni ooling l capacity of the air conditioning units were identified.

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

2) The results of the GOTHIC model show that the room temperatures are approx 120*F and 100 %RH. At this condition the capacity of the cooling coils is significantly higher than rated conditions. Calculation should address the ability of the air conditioning units (3HVQ* ACUS 2A/B) to operate with this loading.

Review Valid invalid Needed Date initiator: stout, M. D. O O O + 'S8 l' VT Lead: Neri, Anthony A B O O 4,/98 VT Mgr: schopfer, Don K O O O 43S8 IRC Chmn: singh, Anand K O O O **S8 ,

1 Date:

INVALID:

Date: 5/13/98 RESOLUTION: First Response (M3-IRF-2140) i NU has concluded that Discrepancy Report DR-MP3-1094 has identified a condition not previously discovered by NU which requires correction. Condition Report (CR) M3-98-1851 (See Attached) was written to provide the necessary corrective action to resolve this issue. The corrective action to correct this issue is to revise calculation T-01528-S3 to correct the assumed inlet air conditions as specified in DR-MP3-1094. The conclusion reached in calculation T-01528-S3 will not change. This discrepant condition does not impact the MP3 LB / DB. NU Printed 5/19/98 2:03.31 PM Page 1 of 2

Northext Utilities ICAVP DR N2. DR MP3-1094 Millstone Unit 3 Discrepancy Report considers DR-MP3-1094 to be a level 4 discrepancy.

This corrective action will be completed post MP3 restart.

Attachments:

Condition Repo,t M3-98-1851 Supplemental Response (M3-lRF-2341)

In a telephone conference on 5/1/98, S&L requested additional evidence supporting NU's conclusion on DR-MP3-1094, stated in M3-IRF-02140.

NU has concluded that the issue reported in DR-MP3-1094 has identified a CONFIRMED SIGN!FICANCE LEVEL 4 discrepancy, which has been corrected.

Corrective action for CR M3-98-1851 to revise calculation T-01528-S3 has been completed. A copy of the revised calculation is attached to this transmission. The conclusion remains that the peak area room temperatures ara bounded without credit for air conditioning units 3HVQ* ACUS 2A/B.

Attachments:

Calculation T-01528-S3, Rev.1 Previously identified by NU7 O Yes (9) No Non Discrepant Condition?O Yes (9) No Resolution Pending?O ve. @ No Re oiunonunre.oived70 ves @ No Review initiator: Stout, M. D, <

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/13/98 st Comments: Based on the results of Calculation T-01528-S3, Rev.1 agree that this is a level 4 discrepancy l

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Northext Utilitie3 ICAVP DR NA DR-MP3-1096 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED RevW Element: CorrectNe Action Process p

Discipline: Mechanical Design Discrepancy Type: CorrectNo Action implementation Om System / Process: DGX g

NRC Significance level: NA Date faxed to NU:

Date Published: 416/98 Discrepancy: ASME Section XI Classification of EDG Fuel Oil System

Description:

CR M3-97-1596, dealing with the Section XI classification of Emergency Diesel-Generator (EDG) auxiliary systems, was closed to CR M3-97 2546. One of the issues described in CR M3-97-2546 was that the Inservice Inspection (ISI) Program Manual required a visual VT-2 examination of the Class 3 portions of the Emergency Diesel Fuel Oil System (EGF) System whereas the old FSAR Table 6.6-2 did not show any Class 3 requirements for this system.

FSAR-MP3-472 was issued to correct the FSAR regarding the classification of these EDG auxiliary systems. New Section 6.6.1 states that new Table 6.6-1 lists the Class 2 and 3 systems to be included in the ISI Program. The new Table 6.6-1 does not list the EGF System as an ASME Section XI ISI System.

Thus, the corrective action for CR M3-97-2546 does not appear to be implemented. If the intention was to delete the EGF System from the ISI Program, this would contradict the commitment to Regulatory Guide 1.137, Revision 1, dated October,1979 in Sections 1.8 and 9.5.4.1 of the FSAR (see Regulatory Position C.1.e and paragraph 7.3 of ANSI N195-1976).

Review Valid invalid Needed Date initiator: sheppard, R. P. G O *S'S8 O

VT Lead: Ryan, Thomas J G O ue/98 O

VT Mgr: schopfer, Don K G O O *1o/98 IRC Chmn: singh, Anand K 6 0 0 *11/S8 Date:

INVALID:

Date: 5/19/98 RESOLUTION Disposition:

NU has concluded that Discrepancy Report DR-MP3-1096 does not identify a discrepant condition. FSAR CR FSAR MP3-472 l was issued to revise FSAR section 6.6.1 to identify systems i required for the Inservice inspection Program based upon the l

classifications of components in Regulatory Guide 1.26. Section B of Regulatory Guide 1.26 states in part "Other systems not covered by this guide, such as instrument and service air, diesel engine and its generators and auxiliary support systems, diesel fuel, . " Thus, the new FSAR Table 6.6-1 does not list the EGF System as an ASME Section XI ISI System. However, the EGF System was added as an augmented inservice pressure test to Printed 5/19/98 2:03.57 PM Page 1 of 3

h l N:rtherst Utilities ICAVP DR N3. DR-MP3-1096 Ministone Unit 3 Discrepancy Report the Inservice inspection Program as required by section C.1.e of Regulatory Guide 1.137, Fuel-Oil Systems For Standby Diesel Generators. FSAR Table 1.8-1 provides the commitment to Regulatory Guide 1.137. Therefore, FSAR Table 6.6-1 is l technically correct by not including the EGF System while the inservice inspection program has augmented requirements to test the EGF System. The approved corrective action plan for CR M3-97-2546 has been implemented correctly. Significance l Level Criteria does not apply as there is no discrepancy.

Conclusion:

NU has concluded that Discrepancy Report DR-MP31096 does not represent a discrepant condition. The corrective action plan for CR M3-97 2546 has been implemented correctly. Regulatory Guide 1.26 specifically exempts the EGF System from its classifications. Thus, inclusion of the EGF System into FSAR Table 6.6-1 is not required. However, the ISI Program includes augmented inspection requirements for the EGF System based upon the requirements of Regulatory Guide 1.137. Significance Level Criteria do not apply as no discrepancy exists.

Previously identified by NU? U ves (9) No Non Discrepent Condition?@ ves O No Resolution Pending?O vos @ No Re.osution unre.oived70 ves @ No Review initiator: sheppard, R. P.

VT Lead: Ryan, Thomas J VT Mgr: schopter, Don K IRC Chmn: singh, Anand K Date: 5/19/98 SL Comments: The classification of the Emergency Diesel Fuel Oil System has been changed from Safety Class 3, and hence ASME Section XI Class 3, to an augmented ISI system. The inservice testing, maintenance and modification of this system, however, is still generally being performed in accordance with ASME Section XI requirements.

Per telecon and fax NU provided evidence that the EGF transfer pumps and check valves are still part of the IST Program. NU also advised that the EGF system would be maintained as an ASME Section 111 Class 3 system. NU stated in the telecon that Repair / Replacement Plans will be developed for repair, replacements and modifications to the EGF system and that the Authorized Nuclear Inservice Inspector would be given the opportunity to review these activities. NIS-2 Code Data Reports will not be used.

Based on the above, S&L agrees that the safety concern i described in this Discrepancy Report is addressed, and the issue can be considered non-discrepant. ,

l We recommend NU discuss with the NRC whether the EGF system should be classified as a ASME Section XI Class 3 system. Since the scope of procedure WC-3 titled "ASME Printed 5/19/96 2:04:00 PM Page 2 of 3

Northert Utilities ICAVP DR No. DR-MP3-1096 Millstone Unit 3 Discrepancy Report Section XI Repair & Replacement Program" is currently limited to Safety Class 1,2 and 3 items, component supports, and Class MC components identified in the Unit specific inservice inspection Plan, we also recommend that NU verify that the Repair / Replacement Plans for the EGF system are procedurally controlled.

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