Text

Forwards Drs Identified During Review Activities for Independent C/A Verification Program,Sixteen Drs for Which Nu Resolutions Have Been Reviewed & Accepted by S&L
	ML20248A850
Person / Time
Site:	Millstone
Issue date:	05/28/1998
From:	Schopfer D; SARGENT & LUNDY, INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	9583-100, NUDOCS 9806010066
	Download: ML20248A850 (72)
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Senior Vice President 312-269-6078 May 28,1998 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 sixteen (16) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0029 DR No. DR-MP3-0944 DR No. DR-MP3-0035 DR No. DR-MP3-0984 DR No. DR-MP3-0081 DR No. DR-MP3-1009 DR No. DR-MP3-0161 DR No. DR-MP3-1011 ,

DR No. DR-MP3-0376 DR No. DR-MP3-1068 DR No. DR-MP3-0667 DR No. DR-MP3-1072 I

DR No. DR-MP3-0676 DR No. DR-MP3-1074 DR No. DR-MP3-0854 DR No. DR-MP3-1099

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9006010066 980528 /

PDR ADOCK 05000423 /JDo/

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$5 East Monroe Street

Chicago. IL 60603-5780 USA

312-269-2000

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l United States Nuclear Regulatory Commission May 28,1998 Document Control Desk Project No. 9583-100 Page 2 Please direct any questions to me at (312) 269-6078.

Yours very truly,

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

E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/1) Nuclear Energy Advisory Council 1 Fougere (1/1)NU m%evpkorr\98WOS28-a. doc 1

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1 ICAVP DR No. DR-MP3 0029 Northeast Utilities Milistone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p Discipline: Mechanical Design g Discrepancy Type: Calculation System / Process: SWP Om NRC Significance level: 3 Date faxed to NU:

Date Published: 9/11/97 Discrepancy: Service Water Pumphouse Ventilation Calculation Discrepancy

Description:

The following calculation were reviewed to verify that the correct heat load from the service water pump motors were used in determining the service water pump room ventilation requirements:

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

Circulating & Service Water Pump House Calculation P(B)-901 Rev. O, dated 12/14/83,3HVY*FN2A/2B Cycling Frequency Calculation P(B)-920 Rev. O, dated 12/14/83, Recommended Period of Operation of the Service Water Pumphouse Ventilation Recirculation Mode Calculation P(B)-925 Rev. O, dated 12/14/83, Service Water Pumphouse Ventilation Requirements The review identified the following discrepancies:

1) Calculation P-198 used 800 hp for calculating the heat loss from one service water pump motor. Plant Design Data System (PDDS) data for service water pump 3SWP*P1 A and 3SWP*P1B states that the motor rating is 600 hp with a brake HD requirement of 555 hp.Two pumps operate post-LOCA per FSAR section 9.2.1.2 while the calculation only considered one operating. This would result in higher than calculated heat loss to the pump room from the service water pump motors.

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

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

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

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

The discrepancy is assic ied a significance level 3 because the discrepancy may result in a higher Servive Water Pumphouse Printed 5/28/9810.1604 AM i of 6

I ICAVP DR No. DR-MP3-0029 Northeast Utilities Millstone Unit 3 Discrepancy Report required to support the SWP equipment operation.

Review Valid invalid Needed Date init6ator: stout. M. D. O O O S'd'87 VT Lead: Neri, Anthony A B O O S'd'S7 S'8'87 VT Mgr: schopfer, Don K O O O IRC Chmn: singh, Anand K 8 0 0 S'8'S7 Date:

INVAUD:

Date: 5/27/98 RESOLUTION: First Response:

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

The calculations will be revised to correct this condition.

Condition Report (CR) M3-97-3283 was written to provide the necessary corrective actions to resolve this issue. Based upon a preliminary Engineering Evaluation which considered the additional heat load from a second pump in conjunction with the lower BHP requirement, there exists a sufficient margin in the ventilation system to support the preliminary conclusion that the system will meet its design requirements. Once the calculation have been finalized a supplemented response will be provided confirming the results. NU concurs that until further analysis is completed and evaluated, this is a Significance Level 3 discrepancy.

Second Response:

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

NU reponse to DR-MP3-029 (M3-lRF-00418) that was previously submitted was based upon a preliminary Engineering Evaluation. This DR was retumed from S&L as "Pending" until "

completion and submittal of calculation and supplement" is presented. The corrective action specified in CR M3-97-3283 requires calculations P(B)-1118 and P(B)-901 to be completed by Sched. Ref. 06UO2.

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

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

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

Results presented in Calculation # SWP-01516M3 verify that the Printed 5/28/9610:16:04 AM Page 2 of 6 l

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ICAVP DR No. DR-MP3-0029 Northeast Utilities Millstone Unit 3 Discrepancy Report ventilation system has sufficient margin to account for two service water pump operation in the post LOCA configuration.

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

Attachments:

Calculation # SWP-01516M3, Tech. Eval. M3-EV-98-0038, OD # MP3-028-98, CR M3-97-3283 Third Response (M3-IRF-2150)

NU has concluded that items # 4 & 5 in" Comments on Second Response" to Discrepancy Report, DR-MP3-029, IRF-01965, have identified conditions not previously discovered by NU which required correction.

Item # 4. FSAR Section 9.4.8.1.1 will be revised to reflect the service water pump cubicle temperature at outdoor design temperature coincident with two pump operation in a post LOCA mode.

Item # 5. FSAR Appendix 3B will be revised to reflect the service water pump cubicle temperature excursion with the ventilation system in the winter alignment coincident with two pump operation in a post LOCA mode.

The corrective action plan for CR M3-98-1900 has been approved to ensure that the FSAR will be updated prior to Mode

2. By procedure, any change to a calculation requires a review of the FSAR to determine its impact. These items were identified midstream between completion of the calculation and doing a review to determine any FSAR impact.NU considers these two issues to be administrative in nature and Significance Level 4.

NU has concluded that items # 1,2,3, & 6, in

Comments on Second Response" to Discrepancy Report, DR-MP3-029, do not represent discrepant conditions.

Item # 1. Justification for assumption - The high velocity and the direction of the discharge of recirculation air towards the intake duct opening makes the assumption of mixing of makeup and recirculation air an appropriate assumption which has also been confirmed by observations made during field walkdowns associated with investigations related to this DR. The stratification assumption, taken in conjunction with the mixing assumption, adds conservatism to calculation by minimizing heat transmission through the floor and wall. The evaluation of system and equipment performance / operability is then based on the high temperature computed at the ceiling level even though 1 the equipment are located at the floor level. This is an added conservatism.

Printed 5/2W9810:16.05 AM Pa0e 3 of 6 L

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ICAVP DR N3. DR-MP3-0029 Northeast Utilities Millstone Unit 3 Discrepancy Report I

ltem # 2. Higher room temperatures - The rounding off (up or down) of NMA, MNE and MAE values to the nearest 5'Fis covered in FSARCR 97-MP3-295 and supported by Safety Evaluation S3-EV 97-16.

Item # 3. FSAR Section 9.4.0, as revised by FSARCR 97-MP3-295, no longer makes any reference to FSAR Table 2.3-1.

Item # 6. The review of set point calculations of the safety related instruments located in the service water pump cubicles shows that the higher ambient temperatures do not necessitate a change as detailed below:

l 3SWP*PS27A/B These are Model SB11AKR/TE10A52R ASCO pressure switches. The applicable setpoint calculation is SP-3SWP-16, Rev 1. The calculation includes a setpoint l

uncertainty for aging, temperature effect, and vibration including seismic DBE of i10% of adjustable operating range. ASCO l Qualification Report AOR 101083 specifies an allowable l instrument operating temperature tange of 0 to 150*F and an overall instrument uncertainty of i 10 % for the life of the unit.

lo changes are required to the instrument setpoint calculation.

3SWP*PDIS24A/B/C/D These are Model 224/580A-1 Barton differential pressure indicating switches . The applicable setpoint calculation is SP-3SWP-1, Rev 2. The calculation includes a total setpoint uncertainty value (including allowances for environmental influences) of i 10%. The Barton Product Bulletin )

for the 580 Series Nuclear Safety DP Indicating Switch specifies a maximum qualified service condition of 180*F. The bulletin also specifies a maximum LOCA instrument uncertainty of i 10%.No changes are required to the instrument setpoint calculation.

3HW*TS60A/B These are Model SA11 AKR/QD10A4R ASCO temperature switches. The applicable setpoint calculation is SP- ,

3HW-8, Rev 0. The temperature switch function is to start j 3HW*FN2A/B on a high service water pump cubicle {

temperature of 90*F and stop 3HW*FN2A/B on low service '

water pump cubicle temperature of 45'F. ASCO Qualification Report AQR 101083 specifies an allowable instrument operating temperature range of 0 to 150*F and an overallinstrument uncertainty of i 10 % for the life of the unit. Since temperature switch actuation will not be required at elevated temperatures above the 90*F setpoint, no change to the setpoint calculation is required.

TV only items related to cubicle mounted electrical equipment that were limiting in nature for the elevated temperatureswere i the thermel overtoad settings and the MCC rating. These items l are addressed in the Technical Evaluation (M3-EV 98-0038).

Significance Level criteria does r.ot apply to issues # 1,2,3,4, &

6, as these issues do not represent discrepant conditions.

However, the overall slanificance level of this DR remains a Printed 5/28/9610:16:05 AM Page 4 of 6 l

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Northeast Utilities ICAVP DR No. DRW34029 millstone Unit 3 Discrepancy Report level 4 as described in previous IRFs: M3 IRF-00418 & M3-IRF-01965 Supplement to IRF addressing issue discussed on 4/23/98 at 2:00 PM conference call:

The FSAR documents the temperature limits for the Service Water Pump cubicles with only one pump running. These limits remain correct for the one pump running condition which, by virtue of this DR, has been determined not to be the relevant number of pumps operating in the worst case condition. NU has, however, demonstrated via a revised calculation, the capability of the existing ventilation system without modifications or adjustments, to maintain the cubicle temperature within acceptable limits with 'he worst case required two pumps operating. Since the license basis of maintaining Service Water availability continues to be met by the existing condition when analyzed using the two (2) pump operating heat loading assumption, NU conciodes that this represents a Significance Level 4 discrepancy, involving an error in assumption with no impact on the overall result; i.e., the pump motors and other cubicle-installed equipment will not be presented with an unacceptable environmental conddion within which reliable operation is required.

Attachments:

FSARCR 97-MP3-295 CR M3-98-1900 M3-EV-98-0038 SE-EV 97-16 Previously tientified by NU7 O vos (9) No Non Discrepent Condition?O vos (8) No Resolution Pending?O ve. @ No Resolution Unresolved 70 ve. @ No Review Acceptable Not Acceptable Needed Date initiator: stout. M. D.

M7/98 VT Lead: Neri, Anthony A M7/96 VT Mgr: schopfer, Don K IRC Chrnn: singh, Anand K O M7/S8 B O O m7/Se Date: 5/27/98 sL connents: Comments on First Response:

Determination of final significance level is pending completion ano submittal of calculation and supplemental response from NU.

Comments on Second Response:

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

2. Calculation SWP-01516M3, Rev. O results show that the normal maximum average (NMA) of 85'F, maximum normal Printed M8/9610:16:05 AM Page s of 6

Northeast Utilities ICAVP DR N3. DR-MP3-0029 Millstone Unit 3 Discrepancy Report excursion of 110*F (MNE), and maximum abnormal excursion 120'F (MAE) shown in FSAR Appendix 3B are exceeded by 1*F during normal operation with one pump operating. Response does not evaluate the FSAR changes required to reflect the higher room temperatures.

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

4. Calculation SWP-01516M3, Rev. O results with 86*F outdoor air temperature and two service water pumps operating show that the maximum room temperature varies between 103*F at the floor and 119.8'F for the recirculation air. The maximum room i

temperature of 119.8'F exceeds the design temperature of 104*F stated in FSAR Section 9.4.8.1.1. NU's response should address what action is planned to correct the FSAR.

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

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

Comments on Third Response NU's correction action plan resolves the technical issues.

This is considered to be Level 3 discrepancies as the service water pump house ventilation system is not able to maintain the maximum temperature below that stated in FSAR Section 9.4.8.1.1 and FSAR Appendix 3B.

The significance level of this DR is the only issue unresolved. The significance level should be resolved by the NRC.

Additional Comments As directed by the NRC, the DR is being reissued as a confirmed Level 3 discrepancy.

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Northeast Utilities ICAVP DR No. DR-MP34036 Millstone Unit 3 Discrepancy Report Review Group: Opershons & Memtenance end Testing DR RESOLUTION ACCEPTED Review Element: Operehng Procedure D6ecipline: Opershons g

Discrepancy Type: Ucensing Document System /Procese: SWP O No

- NRC y we level: 3 Date Faxed to NU: I Date Putdished a/31/97 D6ecrepency: Not all Service Water heat exchan0ers are included in the surveillance procedure per LER 90-020-00

Description:

Licensing event report (LER) 90-020-00 dated July 16,1990 was issued as a result of both trains of Quench Spray and High Pressure Safety injection being inoperable due to a deficient surveillance procedure. The corrective action section of this LER stated in part. . . "To prevent the recurrence, the surveillance procedure covering all Service Water System heat exchangers has been changed. When the established limits for a heat exchan0er are exceeded the unit will be declared inoperable and the appropriate Technical Specification Limiting Condition of Operations Actions Statement entered". . .

Contrary to the above commitment, not all Service Water System heat exchangers are included in the applicable surveillance procedure. The applicable surveillance procedure is SP 3626.13, Service Water Heat Exchangers Fouling Determination, Rev 15, Change 1 with an effective date of April 1,1697. This procedure does not include any reference to or established limits for the following heat exchangers:

Containment Recirculation Heat Exchanger,3RSS*E1 A Containment Recirculation Heat Exchanger,3RSS*E1B Containment Recirculation Heat Exchanger,3RSS*E1C Containment Recirculation Heat Exchanger,3RSS*E1D Post Accident Sampling Sample Cooier,3 SSP-SCL3 Review Valid hvelld Needed Date initiator: spear, R. O O O ar22/97 VT Lead: Bees, Ken 0 0 0 a/22/97 VT Mgr: Schopfw, Don K O O O s/2ses7 NtC Chmn: Singh, Anand K O O O s/2ero7 Date:

INVAUD:

Date: 5/27/98 RESOLUTcN. Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0035, does not represent a discrepant condition.

Millstone Unit 3 has a history of mussel fouling o' the service water heat exchangers. Upgrades and corrective actions to address mussel fouling include: new hypochlorite metering pumps; weekly surveillance of active or filled heat exchan0erS (3626.13); scheouled preventative maintenance and inspection on heat exchangers per EN 31084 (revision 3 attached); and, Printed 5/26/96102124 AM PeGe 1 or 6 ;

Northeast Utilities ICAVP DR No. DR-MP3-0036 Millstone Unit 3 Discrepancy Report development of a Special Procedure (SPROC 96 3-07) to flush the RSS heat exchangers on a quarter 1y basis. In addition, prornpted by corrective actions for ACR 02994, permanent screens on the inlet of the RSS heat exchangers are scheduled to be installed during RFO6. Currently, during flushes these are installed, procedurally controlled and then removed.The corrective actions on LER 90-020-00 were intended to include the requirements of Generic Letter 89-13. GL 89-13 was issued to address safety related portions of the Service Water system.

Post Accident Sampling System sample cooler,3 SSP-SCL3, is not safety related nor is it QA. It does not fall under the requirements of GL 89-13. 3 SSP-SCL3 is kept in dry lay-up (i.e.

not filled) so it is not as susceptible to fouling.The RSS heat exchangers are not incbdfxl in 3626.13 for the following reasons:1. The service water side of the heat exchangers are kept in dry lay-up (i.e. not filled) during normal operating conditions. Fouling cannot occur in a dry system.2. The heat exchangers are surveilled for fouling during ESF / LOP testing each refueling (3646A.17 and 3646A.18 step 4.4.26.)3. The system is flow tested quarterly, and is completely flushed per SPROC 96-3-07.4. 3626.13 is a weekly surveillance. Significant bio-fouling of large bore upstream piping will not occur over a quarter, therefore, a quarter 1y inspection cycle is sufficient.

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

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0035, does not represent a discrepant condition.

Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and as such, does not fall under the requirements of GL 89-13. The RSS heat exchangers are surveilled and inspected under ESF / LOP Testing Surveillance (3646A.17 and 3646A.18 step 4.4.26.) and the regular quarteriy preventative maintenance schedule. Significance level criteria do not apply here as this is not a discrepant condition.

Revised Disposition and

Conclusion:

Disposition:

NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample coolcr is not safety-related and does not fall under the requirements of Generic Letter 89-13, additionally it is maintained in a dry lay-up condition. The RSS heat exchangers are kept in dry lay-up so they are not susceptible to fouling. The RSS heat exchangers are surveilled and inspected each refuel under ESF/ LOP Surveillance (3646A.17 and 3646A.18 step 4.4.26) and the regular quarterly preventative maintenance schedule to ensure no biofoulina exists in staanate lea pipina Printed s/28/9810:2124 AM Pa0e 2 or 6

Northeast Utilities ICAVP DR N3. DR-MP34035 Millstone Unit 3 Discrepancy Report upstream of the heat exchanger.

In their response to M3-IRF-00301, Sargent & Lundy noted that no determination is made after the RSS heat exchangers are flushed as to whether they are functional considering the amount of debris removed and if the periodicity of the flushes is appropriate. Sections 1.3.1 and 1.3.2 of EN31084, Operating Strategy For Service Water System At Millstone Unit 3, require the Containment Recirculation Spray Heat Exchangers to be flushed and inspected 4 times a year using SPROC 96-3-07.

Frequency of performing the flushes is tracked automatically by PMMS and AWO's are issued when the need for flushes becomes due. Permanent inlet debris screens have been installed in the inlet of each heat exchanger (DCR M3-97111).

Inlet heat exchanger screens are used since the service water side of the heat exchangers are kept in dry lay-up (i.e. not filled) during normal operating conditions. Fouling cannot occur in a dry system. EN31084 requires a formal assessment (Attachment 4 of the procedure) of the amount of captured mussels on the inlet screens relative to the heat exchanger performance. If the f'ush criteria for foreign material is exceeded, a Condition Report must be issued (per RP-4) which in tum will require an operability assessment to be performed.

Thus, the effectiveness of the flushing and the frequency of flushes is assessed by the System Engineer using this method.

As stated in the MP3 Service Water System Heat Exchanger Performance Monitoring Program, heat transfer surveillance or performance testing of the RSS heat exchangers is not required.

The RSS system configuration precludes inducing a heat load across the heat exchangers such that meaningful test data can be obtained. However, the RSS heat exchangers are inspected regularly as described above.

CR M3-98-1693 evaluated the additional issue raised by S&L conceming micro-fouling inspection criteria contained in EN 31084, rev. 3. Micro-fouling inspection criteria is considered to be important since the heat transfer capability of each RSS heat exchanger cannot be verified by performing a test due to the unique system configuration of the RSS. Each RSS heat exchanger is flushed and inspected at least 3 times a year as required by EN 31084. Following each flush of the heat exchanger (per SDROC 96-3-07), which utilizes service water, the heat exchanger is then isolated and completely filled with demineralized water in accordance with OP 3326, section 4.7.

After filling, the heat exchanger is drained and then restored to the RSS system in dry lay-up. Formation of any scale or other micro-fouling condition / deposit is thus signifmantly minimized by the combination of flushing with service water and then filling and draining with demineralized water, Furthermore, the piping configuration for RSS is such that no s!gnificant heat load can be applied (or has ever been applied) across the heat exchanger 1 tubes, consequently there is no heat mechanism present for developing scale. However, to ensure the ability of each RSS heat exchanger to perform its safety fundion as designed, the visual inspection requirements in EN 31084 will be enhanced (A/R 98008002-01) to include (1) reviewino previous inspection !

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ICAVP DR N2. DR-MP3-0035 Northeast Utilities Millstone Unit 3 Discrepancy Report results prior to performing each inspection so that any changes can be readily identified and (2) bullets to advise inspector to inspect in accordance with ASME OM-S/G-1994, part 21.

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

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and Generic Letter 89-13 therefore does not apply. The RSS heat exchangers are surveilled and inspected for micro-fouling each refueling per ESF/ LOP Testing Surveillance (3646A.17 and 3646A.18) and quarterly per SPROC 96-3-07. Any foreign material removed from the RSS heat exchanger inlet screens is evaluated in accordance with EN 31084 for any effect on the performance of the heat exchangers. Prior to being placed in dry lay-up during normal plant operations, each RSS heat exchanger is visually inspected for micro-fouling after the service water flush and then filled with demineralized water and drained.

The fouling inspection of EN 31084 will be enhanced (A/R 98008002-01) to require review of the previous inspection results prior to performing the next inspection and trending the inspection results to evaluate the heat exchanger condition.

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

l NU's revised response:

Disposition:

NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not safety-related and does not fall under the requirements of Generic Letter 89-13. The RSS heat exchangers are kept in dry lay-up so they are not susceptible to fouling. The RSS heat exchangos are surveilled and inspected each refuel under ESF/ LOP Testing Surveillance (3646A.17 and 3646A.18 step 4.4.26) and the regular quarterly preventative maintenance schedule.

In their response to M3-IRF-00301, Sargent & Lundy noted that no determination is made after the RSS heat exchangers are I flushed as to whether they are functional considering the amount ;

of debris removed and if the periodicity of the flushes is l appropriate. Sections 1.3.1 and 1.3.2 of EN31084 Operating Strategy For Service Water System At Millstone Unit 3, require the Containment Recirculation Heat Exchangers to be flushed and inspected 4 times a year using SPROC 96-3-07. Frequency of performing the flushes is tracked automatically by PMMS and AWO's are issued when the need for flushes becomes due.

Permanent inlet debris screens have been installed in the inlet of Printed 5/28/9610:21:25 AM Page 4 of 6 j

Nertheast Utilities ICAVP DR Nr. DR-MP3-0035 Millstone Unit 3 Discrepancy Report each heat exchanger (DCR M3-97111). Inlet heat exchanger screens are used since the service water side of the heat exchangers are kept in dry lay-up (i.e. not filled) during normal operating conditions. Fouling cannot occur in a dry system.

EN31084 requires a formal assessment (Attachment 4 of the procedure) of the amount of captured mussels on the inlet screens relative to the heat exchanger performance. If the flush criteria for foreign material is exceeded, a Condition Report must be issued (per RP-4) which in tum will iequire an operability assessment to be performed. Thus, the effectiveness of the flushing and the frequency of flushes is assessed by the System Engineer using this method.

As stated in the MP3 Service Water System Heat Exchanger Performance Monitoring Program, surveillance or performance testing of the RSS heat exchangers is not required. The RSS system configuration precludes inducing a heat load across the heat exchangers such that meaningful test data can be obtained.

Hewever, the RSS heat exchangers are inspected regularly as described above.

CR M3-98-1693 evaluated the additional issue raised by S&L conceming micro-fouling inspection criteria contained in EN 31084, rev. 3, and concluded additional inspection criteria are not required. Micro-fouling inspection criteria is considered to be important by S&L since the heat transfer capability of each RSS heat exchanger cannot be verified by performing a test due to the unique system configuration of the RSS. However, each RSS heat exchanger is flushed and inspected at least 3 times a year as required by EN 31084. Following each flush of the heat exchanger (per SPROC 96-3-07), which utilizes service water, the heat exchanger is then isolated and completely filled with demineralized water in accordance with OP 3326, section 4.7.

After filling, the heat exchanger is drained and then restored to the RSS system in dry lay-up. Formation of any scale or other micro-fouling condition / deposit is thus significantly minimized by the combination of flushing with service water and then filling and draining with demineralized water. Furthermore, the piping configuration for RSS is such that no significant heat load is applied (or has ever been applied) across the heat exchanger tubes, consequently there is no heat mechanism present for developing scale. Hence additional micro-fouling criteria is not warranted. Significance Level Criteria does not apply as this is not a discrepant condition.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0035 does not represent a discrepant condition. Surveillance Procedure 3626.13 surveils all service water heat exchangers except for the ,

PASS sample cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and Generic Letter 89-13 therefore does not apply. The RSS heat exchangers are surveilled and inspected each refueling per ESF/ LOP Testing Surveillance (3646A.17 and 3646A.18) and quarterly tested per SPROC 96-3-07. Any foreign material removed from the RSS heat exchanger inlet screens is evaluated in accordance with EN 31084 for any effect on the Printed 5/28/9810:2125 AM Pape 5 or 6

l Northeast Utilities ICAVP DR Ns. DR-MP3-0035 Millstone unit 3 Discrepancy Report performance of the heat exchangers. Inspection for micro-fouling is also performed. Significance Criteria does not apply as this is not a discrepant condition.

Previously identified by NU7 O Yes f8) No Non D6screpant Condition?O Yes (*) No ResolutionPending70 Yes @ No Re.aiution unre.oevedro Y @ No Rev6ew initiator: spear, R.

VT Lead: Bass, Ken VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/26/98 SL Comments: S&L concurs that the additional information provided by NU is adequate to resolve this issue. The additional information provided in AR No. 98008002 indicating that EN 31084 will be revised to include the requirement to note fouling / condition indications during visual inspections and to include the guidance provided in the ASME OM-S/G-1994 Standard, Part 21 Section C9.1 for visual inspection technique will resolve this issue. S&L does consider this to be a level 3 discrepancy. This determination is based on the information contained in M3-IRF-02279 when NU stated that EN 31084 will be enhanced to include reviewing previous inspection results prior to perform each inspection (trending) so that any changes can be readily identified and to advise the inspector to inspect in accordance with the referenced OM Standard and the commitment made in the referenced AR. Both of these actions were taken after the ICAVP discovery date.

S&L understands that NU has agreed to further revise the Basis document of EN 31084 to state the inspection of the Containment Recirculation Heat Exchangers described in EN 31084 provide the compliance with GL 89-13.

l 1

Printed 5/268810:2125 AM Page 6 of 6

Northeast Utilities ICAVP DR N3. DR-MP3-0081 Millstorm Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Elemord: System Design Diecipline: P6 ping Design Discrepancy Type: calculetkm Ow g

System / Process: RSS ~

NRC Significance level: 4 Date faxed to NU:

Date Published: W29/97 06.crepancy: Incorrect operating temperature used in stress analysis.

Description:

In the process of reviewing the following pipe stress calculations for the Recirculation Spray System, (i) Calculation No.12179-SDP-RSS-01361M3 Rev. 4, dated 5/29/97 (ii) Calculation No.12179-NS(B)-X7902 Rev.1, dated 9/3/96 (iii) Calculation No.12179-NS(B) X7903 Rev.1, dated 9/3/96 (iv) Calculation No.12179-NS(B)-X7904 Rev. 2, dated 9/3/96 (v) Calculation No.12179-NS(B)-X7905 Rev.1, dated 9/3/96 (vi) Calculation No.12179-US(B)-353 Rev. O, dated 4/23/97 we noted the following discrepancy:

Background:

Based on the stress data package (i), under operating condition 7 the operating process temperature for lines 3-RSS-010-5-2 and 3-RSS-010-10-2 is 257 deg F. The corresponding pressure in these lines is 150 psig. This is an Emergency & Faulted condition which is described as follows ' Containment Recirculation Pumps take suction from the Containment Recirculation Sump and discharge to the spray headers. A failure of one train of service water cooling to the Containment Recirc Coolers 3RSS*E1 A& C results in the affected RSS train (E1 A, C) discharging hot sump water (257 deg F) to the ring headers and the unaffected RSS train (E18, D) discharging cooled sump water to the headers'. The two RSS lines are analyzed in calculations X7903 and X7905.

Since a failure of either train of service water (A or B) needs to be considered, the same operating condition of 257 deg F, and 150 psig needs to be considered for lines 3-RSS-010-20-2 and 3-RSS-010 9-2. These two lines are analyzed in calculations X7902 and X7904.

The four pipe stress analysis calculations (ii) to (v), utilize a maximum operating temperature of 245 deg F. This represents the maximum containment recirc piping temperature, as calculated in (vi).

1 Discrepancy:

The pipe stress calculations utilize Rev. 3 of the stress data l package, and have not been updated to reflect the latest revision

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Northeast Utilities ICAVP DR N3. DR-MP3 0081 Millstone Unit 3 Discrepancy Report discrepancy between the 257 deg F defined in the stress data package (i) and the 245 deg F defined in references (ii) thru (vi).

Review Valid Invalid Needed Date initiator: singh, R. O O O s/2aro7 VT Lead: Neri, Anthony A B O O ar2ars7 VT Mgr: schoprer, Don K B D 0 s/22/97 1RC Chmn: singh, Anand K B O O e/2s/97 Date:

WVAuo:

Data: 5/27/98 RESOLUTION: First Response ID: M3-IRF-00293 Disposition:

NU has concluded that Discrepancy Report DR-MP3-0081 does not represent a discrepant condition. Although pipe stress calculations 12179-NS(B) X7902, X7903, X7904, and X7905 all reference Revision 3 of the RSS Stress Data Package, allwere revised as a result of the increased RSS pipe fluid temperatures, as stated in the ' Basic Analytical Data Summary' page contained in each calculation (see attached, page 21 of calculation NP(B)-

X7902).

These calculations also state, under' Changes to Existing Calculation-Operating Conditions', how the criteria for maximizing stresses and support loads were developed (see attached pages 12 and 13 of the sample calculation), Details explain that the two worst case postulated LOCA combinations developed by the Nuclear Technologies Group were used in the calculations. The worst case scenarios did not require the 257'F temperature, but required evaluation for temperatures of 230*F and 245'F, based on time phasing of containment structure movements. Revision 4 of SDP-RSS-01361M3 also states that re-analysis of the piping system was in progress during review and update of the SDP (See attached page 5 of the SDP).

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-0081 does not represent a discrepant condition. Pipe stress calculations 12179-NS(B)-X7902, X7903, X7904, and X7905 were worked in parallel with the RSS stress data package, with the result that the calculations did not reference Revision 4 of the RSS SDP. The pipe stress calculations, as issued, correctly account for the latest increase in RSS temperature which is now defined in Revision 4 of the RSS SDP, Second Response Response ID: M3 - IRF -01963 Pitnled 5/28/9610:21:53 AM Page 2 or 8

DR NO. DR-MP3-0081 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Disposition:

NU has concluded that the issue reported in DR-MP3-0081 has identified a condition not previously discovered by NU which requires correction. CR M3-98-1998 has been initiated to address this issue. The issue of utilizing the proper revision of the SDP is not a discrepant condition.

Although pipe stress calculations 12179-NP(B)-X7902, X7903, X7904, and X7905 all reference Revision 3 of the RSS Stress Data Package, all were revised as a result of the increased RSS pipe fluid temperatures, as stated in the ' Basic Analytical Data Summary' page contained in each calculation (see attached, page 21 of calculation NP(B)-X7902).

These calculations also state, under ' Changes to Existing Calculation-Operating Conditions', how the criteria for maximizing stresses and support loads were des eloped (see attached pages 12 and 13 of the sample calculations). Details explain that the two worst case postulated LOCA combinations developed by the Nuclear Technologies Group were used in the calcu;ations. The worst case scenarios did not require the 257 'F temperature, but required evaluation for temperatures of 230 'F and 245 'F, based on time phasing of containment structure movements. Revision 4 of SDP-RSS-01361M3 also states that re-analyzes of the piping system was in progress during review and update of the SDP (See attached page 5 of the SDP).

Regarding the S&L comment subsequent to NU's initial response that the current stress analysis calculations do not address the discrepancy between the 230 'F and 245 'F cases analyzed in the stress calculation and the 257 'F case identified in the SDP, the following explanation is provided. Calculations 03705-US(B)-

352 and 353 analyze a family of accident scenarios for RSS piping inside containment to determine the bounding conditions for pipe stress and support loading. The 230 'F and 245 *F cases are based on detailed analysis of worst case accident scenarios crediting delay time for RSS system initiation. These calculations demonstrate that the ambient temperature effects on the piping are more severe than the fluid temperatures resulting from a loss of SWP.

The 257 'F piping temperature specified in the SDP due to the loss of SWP in one train is based on calculation 12179-US(B)-

322 which determines the maximum sump water temperature for worst case accident scenarios. The 257 'F temperature is conservative for piping analysis since it occurs early in the accident scenario prior to RSS initiation (i.e. prior to system flow). At the time of RSS initiation, the calculation d Wrmines a sump temperature of 250 'F. However, this 250 'F case is a result of minimum ESF such that the sump temperature is maximized due to the loss of one train of QSS. This scenario involves a single failure which is independent of the loss of SWP case. The sump temperatures resulting from the loss of SWP case are lower due to the cooling effect of two operating QSS pumps. The temperatures calculated during fluid flow conditions for the loss of SWP case are bounded by the pipino Printed 5f28S810:21:s4 AM Pege 3 of 8 l

l

~

ICAVP DR No. DR-MP3-0081 Northeast Utilities Millstone Unit 3 Discrepancy Report temperatures reached due to ambient conditions prior to RSS flow initiation. Therefore, the more realbtic temperatures calculated in 03705-US(B)-352 and 353 are utilized in the piping analysis. The SDP calculation will be revised accordingly to address the apparent discrepancy.

Based on the administrative nature of this issue and the fact that the conclusions of the calculation remain unchanged, Significance Level of 4 is appropriate.

Conclusion:

NU has concluded that the issue reported in Revised Discrepancy Report DR-MP3-0081 has identified a condition not previously discovered by NU which requires correction. The maximum operating temperatureof 257F provided in the stress data package,12179-SDP-RSS-01361M3, rev. 4, is not consistent with the operating temperatures used in the stress analysis calculations. The approved corrective action plan for CR M3-98-1998 will revise after startup the stress data package to clarify the maximum temperature resulting from the loss of SWP post LOCA and will also revise calculation 03705-NP(B)-

003 to clear 1y document the bases for the 230F and 245F temperatures used in the stress analyses. Based on the fact that the conclusions of the stress analyses remain unchanged, the Significance Level is concluded to be Level 4.

Attachments:

CR M3-98-1998 with approved corrective action plan Calculation 12179-NP(B)-X7902 pages 12,13,14 and 21 Stress Data Package SDP-RSS-01361M3 page 5 Third Response Response ID: M3 - IRF - 02356

Background:

Sargent & Lundy has requested, by telecon, clarification of why the maximum containment sump temperature of 257F was not used in the inside containment RSS piping stress analyses when this temperature is identified in the SDP as the maximum temperature.

Disposition:

NU has concluded this issue reported in DR-MP3-081 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Previously the stress calculations assumed that the ambient temperature conditions caused by DBA events enveloped the uncooled fluid conditions for the purpose of developing the most limiting pipe stress and support loading. In general, this is the case since the ambient temperature exceeds the worst case sump temperature once RSS flow is initiated. An Engineering study calculation (03705-NP(B)-003. rev. O. CCN 2. attached) demonstrates that.

Prtnted 5/28/9610:21:54 AM Page 4 of 8

Northeast Utilities ICAVP DR No. DR-MP3-0081 Millstone Unit 3 Discrepancy Report considering all the appropriate boundary conditions (containment pressure and liner temperature), the ambient condition bounds the uncooled flow condition with the exception of the ring headers.The maximum temperature condition in the ring headers is govemed by the DBA ambient temperature. However, the ring headers were reanalyzed to address a variety of interface conditions unique to the ring headers (i.e. uncooled flow meeting cooled flow in each ring header) to demonstrate the integrity of the piping and pipe supports. Design basis calculation revisions /CCNs (attached) were performed for the cooled /uncooled fluid conditions in the ring headers only and for the associated sixteen structural anchors. The balance of the supports in the ring headers (non-anchors) were not si0nificantly affected by the cooled /uncooled fluid conditions and are therefore addressed within the associated stress calculations.

The Engineering Study Calculation addresses the balance of the commodities which are not affected by the cooled /uncooled flow consideration, including the riser stress problems. The revised calculations demonstrate that the RSS piping meets design basis criteria for DBA events. No modifications were required due to this reanalysis. The approved corrective action plan for CR M3-98-1998 will revise after startup the stress data package to ciarify the maximum temperature to be used in the stress analyses.

Since the conclusions of the stress analyses remain unchanged, the Significance Level is concluded to be Level 4.

Note: The calculations noted as being attached have been shipped from the Stone & Webster office in Boston to Sargent &

Lundy to expedite their review and can be identified either by the packing slip referencing both DR-MP3-0081 and M3-IRF-02356 or by the transmittal number: M3-TRA-00306.

Conclusion:

NU has concluded this issue reported in DR-MP3-081 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. The maximum temperature of 257F provided in the stress data package for RSS is not the maximum temperature to be used in the stress calculations. The attached calculations provide clarification as to the maximum temperature to be used. The corrective action plan for CR M3-98-1998 will revise after startup the stress data package to clarify the maximum temperature post LOCA. Since the conclusions of the stress analyses remain unchanged, the Significance Level is l concluded to be Level 4.

Attachments:

Engineering Study Calc. 03705-NP(B)-003 R0 C2 Large Bore Stress 12179-NP(B)-X7918 R1 C2 Large Bore Stress 12179-NP(B)-X7912 R1 C2 Pipe Support Calc. 12179-NP(F)-ZO79C-079 R3 C2 Pipe Support Calc. 12179-NP(F)-Z079C-089 R2 C2 Pipe Support Calc. 12179-NP(F)-Z0790-090 R3 C2 Pipe Support Calc. 12179-NP(F)-Z079C-093 R2 C3 Pipe Support Calc. 12179-NP(F)-Z.079C-094 R1 C3 ;

4 Pnnted s/28/9610.21:s4 AM Page 5 of 8

Northeast Utilities ICAVP DR Nr. DR-MP3-0081 Millstone Unit 3 Discrepancy Report Pipe Support Calc. 12179-NP(F)-Z079C-097 R3 C4 Pipe Support Calc. 12179-NP(F)-Z079C-098 R3 C4 Pipe Support Calc. 12179-NP(F)-Z079C-101 R1 C4 Pipe Support Calc. 12179-NP(F)-Z079C-102 R1 C3 Pipe Support Calc. 12179-NP(F)-Z079C-105 R3 C2 Pipe Support Calc. 12179-NP(F)-2079C-108 R4 C2 Pipe Support Calc. 12179-NP(F)-Z079C-109 R1 C3 Pipe Support Calc. 12179-NP(F)-Z079C-112 R3 C2 Pipe Support Calc. 12179-NP(F)-Z079C-113 R4 C2 l Pipe Support Calc. 12179-NP(F)-ZO79C-116 R1 C3 Pipe Support Calc. 12179-NP(F)-2079C-117 R1 C3 Insert Plate Calc. 12179-SEO-V1.006 R3 C1 Insert Plate Calc. 12179-SEO-V1.007 R3 C1 Insert Plate Calc. 12179-SEO-V1.011 R2 C1 Insert Plate Calc. 12179-SEO-V1.093 R1 C1 Insert Picte Calc. 12179-SEO-V1.095 R1 C1 Previously identified by NU? O Yes (9) No Non D6screpent condition?U Yes @) No Resolution Pending?O Ye. @ No Re=ueion unree*ed70 ves @ No Review initletor: Prakash, A.

VT Lead: Nerl, Anthony A :

VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date: 5/27/98 i st. comments: First Response:

NU's disposition states that the discrepancy report does not represent a discrepant condition because the calculation adequately explains how the criteria for maximizing stresses and support loads were developed, and the two worst case postulated LOCA combinations deve;oped by the Nuclear Technologies Group (NTG) are utilized.

According to page 13 of the calculation, the finalized LOCA l scenarios, as developed by the NTG, are documented in {

calculation 03705-US(B)-353. The two worst postulated LOCA l scenario combinations (P02 and P24) were transmitted by NTG to the piping analysis group. Corresponding pipe temperatures for these two cases are 230F and 245F.

At issue is the fact that the Stress Data Package (SDP) specifies a maximum operating temperature of 257F for the subject piping.

The disposition states that 'the worst case scenarios did not .

require the 257F temperature, but required evaluation for I temperatures of 230F and 245F based on time phasing of I

containment structure movements'. This statement !s not substantiated by calculation 03705-US(B)-353. None of the scenarios considered in the calculation lead to a pipe temperature of 257F. This is because the spray water outlet temperature of the recirculation spray hest exchanger RSHX [TDV300] as a function of time in all scenarios considered is taken to be cooled sump water from the RSHX. The scenario leading to the 257F l

temperature corresponds to the RSHX discharging hot sump j Printed 5/28/96 to:21:s4 AM Page 6 of 8 I

Northeast Utilities ICAVP DR No. DR-MP3-0081 i Millstone Unit 3 Discrepancy Repor+

water due to a failure of one train of service water cooling. This scenario is not considered by calculation 03705-US(B)-353.

The SDP specifies the 257F temperature for operating condition 7A/B. Condition 7 addresses one-half of the RSS coolers discharging hot, and one-half of the coolers discharging cooled sump water to the spray headers. The operating temperature for the spray header receiving cooled water is taken from calculation US(B)-353, as noted in Notes 1 and 3 of the SDP. The operating temperature for the spray header receiving hot sump water is 257F. Although the source for the 257F is not provided in the SDP, the SDP does reference calculation US(B)-322 (Ref. 7a).

This calculation states that 'if the heat exchanger fails, then the piping of the recirculation spray system will be exposed to water at the temperature of the water on the floor', and provides the maximum temperature of the water on the floor as 256.9F.

According to the SDP: 'The SDP provides the system specification information required to perform the code piping stress analysis and therefore represents a design input document for the pipe stress calculation. The SDP forms the basis for the input to the structural analysis of safety related piping systems and mechanical components. The SDP is reviewed for consistency with design basis assumptions regarding flowpath, single failure postulation, and operator action'.

The discrepant condition is that the maximum operating temperature provided in the SDP, a design input to the stress analysis calculation, is not consistent with the operating temperature used in the stress analysis calculations. Either the SDP should be revised to reflect the logic delineated in the stress analysis calculations, or the stress calculations should address the discrepancy. The current stress analysis calcult;tions do not address the identified discrepancy.

Second Response (Telecon):

S&L requested clarification of why the maximum containment sump temperature of 257F was not used in the inside containment RSS piping stress analyses when this temperature is identified in the SDP as the maximum temperature.

Third Response:

Based on a review of the revised calculations, we concur with NU on the following:

- the RSS piping meets design basis criteria for DBA events

- the approved corrective action plan CR M3-98-1998 to revise, after startup, the stress data package to ciarify the maximum temperature used in stress analyses

- the conclusions of the stress analyses are unchanced, and the Pdnted 5/28/981021:s4 AM Page 7 of 8

i

DR N3. DR-MP3-0081 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Significance Level can be changed to Level 4 l

l j

For the sake of darifying the documentation, the following '

suggestions are noted:

- Several support summaries attached to the pipe support calculations do not include the SSEA loads. The loads are, however, included in the computed load combinations. The support numbers are,3RSS-1-PSA93,94,97,98,109,11?. & 113.

- Calculation NP(B)-003 states that "a representative RSS riser stress calculation X7905 was selected for all riser qualifications since it is very similar in overall piping configuration and support arrangement as the other RSS riser problems". The discussion should be expanded to address why the X7903 problem, the benchmark problem used before,is not used in this CCN evaluation. Of significance is the fact that the stainless steel grades in these two cases are different, and have different code allowable stresses.

- Static anchor displacements resulting from the design conditions being anlyzed are based on structural stiffness for a completely cracked concrete model of the containment. This, and its implications for the conclusion should be addressed in the calculation.

- For supports, RSS-1-PSA079 & 089, the welded attachment calculation (PILUG) output has a weming " max beta = 0.874, results require confirmation", Confirmation of the results should be dispositioned in the calculations.

l l

Printed s/28/9810:21:54 AM Page 6 of 6

ICAVP DR N . DR-MP3 4161 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: Operatens & Maintenance and Testing DR RESOLUTION ACCEPTED Rev6ew Element: Operatng Procedure p ,

Discipline: Operatson.

Om Discrepancy Type: 0 & M & T Procedure g Systerr#rocess: SWP NRC Significance level: NA Date Faxed to NU:

Date Published: 9/22/97 Dmcrepancy: Flood Proti 5: a Procedures and Technical Specification Requirements Discrepancy Descript6on: Tech. Spec. section 3.7.6, Flood Protection, Limiting Condition for Operation (LCO), states that flood protection shall be provided for the service water pump cubicles and components when the water level exceeds 13 feet Mean Sea Level, USGS datum, at the Unit 3 intake structure. This LCO is applicable at all times.

The associated action statement is "With the water level at 13 feet above Mean Sea Level, USGS datum, at the Unit 3 intake structure, shut the watertight doors of both service water pump cubicles within 15 minutes."

The surveillance requirements associated with the flood protection LCO are:

1. Measurement at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the water level is below elevation 8 feet above Sea Level, USGS datum.

2. Measurement at least once por 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when the water level is equal to or above elevation 8 feet above Mean Sea Level, USGS datum.

The following listed procedures implement the flood protection requirement:

SP3665.1 Rev. 5, Flood Level Determination OPS Form 3665.1 1 Rev. 5, Flood Level Determination AOP 3569 Rev.10, Severe Weather Conditions SP 3670.2 Rev. 8, Tech Spec Related PEO Rounds (Mode 1-4)

OPS Form 3670.2-6 Rev. 7, Shift Outside PEO Tech Rounds (Mode 1-4) l SP 3672.3 Rev. 4, Tech Spec Related PEO Rounds (Mode 5/6)

OPS Form 3672.3-3 Rev. 4, Shiftly Outside PEO Tech Spec Rounds (Mode 5/6)

Three flood protection requirement discrepancies were identified.

1. No procedural guidance exists that describes the flood l protection program actions to be taken when the water level is determined to be equal to or greater that 13 feet above mean sea level, USGS datum as documented in OPS Form 3665.1-1 Rev. 5. Section 7, Summary of changes, of SP3665.1 Rev. 5, Flood Level Determination , identifies one of the changes made in revision 5 of this procedure as " References to the actions taken if water level exceeds 13 feet have been removed. These actions are dealt with in EOP 3569, Severe Weather

('nndit innc* Prnewdura FOP '1LrAQ Ravarm Wanthar f'nnditlnne Printed 5/28/9610:22:15 AM Page 1 of 5 1

t L _ -- - _ _ - _ _ _ _ _

ICAVP DR No. DR-MP3-0161 Northeast Utilities Millstone Unit 3 Discrepancy Report does not exist. This was confirmed by referencing Unit 3 Emergency Operating Procedures Index,2500 Procedure Index, Rev.141 dated 5/20/97. Procedure AOP 3569 Rev.10, Severe Weather Conditions, does exist and may be the correct reference rather than EOP 3569. This AOP does not adequately identify the Tech Spec required actions to be taken if the water level reach:s or exceeds 13 feet.

The performance requirements identified in the Tech. Specs are not adequately translated into the referenced operating / surveillance procedures.

2. Page 2 of Procedure SP3665.1 Rev. 5, Flood Level Detenrunation, states in the box identified as Basis Information, "This monitoring is required every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months even if the watestight doors and the normal sump drains are closed. No exemption is provided in T/S 4.7.6.b which would allow ctution of monitoring". Page 3 of the same procedure states in the box identified as CAUTION, "With sea level approaching 13 feet above mean sea level weather conditions may warrant entering T/S 3.7.6 LCO and discontinue surveillance until conditions ,

allow". These statements are in direct conflict. j Page 5, Step 5 of Procedure AOP 3569 Rev.10 required the operator to

Monitor sea water level at the intake structure houriy until wino speed exceeds 50 mph." This step is not consistent ;

with OPS Form 3665.1-1 Flood Level Determination which requires that the water levelis recorded every two hours. If the operator ceases io monitor the sea level when the winds exceed 50 mph the required Tech Spec t. surveillance that is described in SP 3665.1 Flood Level Determination and OPS Form 3665.1-1 l Flood Level Determination may be missed if the water level is l high during high wind conditions.

l These procedures appear to be contradictory and may preclude the service water system from being monitored in accordance with the Technical Specification during high winds and/or ;

flooding conditions. !

3. Tech. Spec. section 3.7.6, Flood Protection, requires i determination of water level referenced to *Mean Sea Level, l USGS datum, at the Unit 3 intake structure. We were unable to determina from the documentation provided, what type instrument was used to determine the mean sea level, specifically where the instrumentation is located, or how the 4 instmmentation is calibrated and referenced to the USGS datum.

Review Valid invahd Needed Date initiator: spear, R. 8 O O S'57/87 ;

VT Lead: Bess, Ken 0 0 0 S/17/S7 l

( VT Mgr: Schopfer, Don K Q Q Q 9/18/97 IRC Chmn: Singh. Anand K O O O et18/97 Date:

INVALIO:

Printed 5/26/9610:22:16 AM Page 2 or 5 f

t- _ w

ICAVP DR No. DR-MP3 0161 Northeast Utilities Millstone Unit 3 Discrepancy Report D 5/26/98 RESOLUTu: Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0161, identified multiple conditions. Items 1 and 3 of the DR do not represent discrepant conditions. Item 2 was an apparent discrepant issue previously identified by NU which did not require correction.

1. SP 3665.1 is entered when it is identified that Long Island Sound levelis Dreater than eight feet above mean sea level. SP

365.1 has proceduial guidance for actions that should be taken when the intake is threatened by rising sea level. Upon notification from CONVEX of a hurricane advisory, AOP 3569 is nntered. Steps 5,6 and 7 of AOP 3569 are the procedure steps that implement the actions of Tech Spec 3.7.6. These actions are taken prior to level exceeding 13 feet.The reference to EOP 3569, Severe Weather Conditions, exists only in the Basis Document of SP 3665.1 and not in the procedure itself. A procedure Feedback Form, DC1 Att.10, was submitted to the procedures group to reference the correr:t procedure, AOP 3569.

2. CR M3-97-1613 was written 5/23/97 to document the inconsistency between AOP 3569 and Tech Spec 3.7.6 requirements of monitoring sea level. The investigation determined that the condition was not adverse. SP 3665.1 Implements the surveillance requirements of Tech Spec 3.7.6 to ensure that the appropriate action statement is met when conditions require it. Further, AOP 3569 provides guidance to refer to Tech Spec 3.7.6 for applicability and monitor sea level hourly until wind speed exceeds 50 mph. Subsequent steps perform the actions of Tech Spec 3.7.6. At the Shift Manager's discretion or when winds exceed 50 mph, monitoring can be suspended by entering the action statement and verifying the watertight doors and sump drains are closed. This would be the logical course of action to ensure personnel and plant safety.

The basis information in SP 3665.1 is referring to only performing the actions of the Tech Spec. That alone does not exempt us from performing the surveillance requirements. In order to suspend the surveillance requirement, the action must be taken and the Tech Spec entered, as indicated in the caution. A Feedback Fonn, DC 1 Att.10, has been submitted to the procedure group to clarify the intent of the basis information.

3. The instrument used to check sea level is a level reference (tidemeter) in one foot increments mounted on the side of the intake foundation. The tidemeter is installed with respect to intake area grade. Grade at the intake was determined during initial construction surveys to be 14.5 feet. Mean sea level was also determined during initial construction and benchmarks placed and monitored per SP CE 223, Movement Monitoring Program and documented on FSK-12179-G-029. Surveyed markings were placed on the wall where the tidemeter is hung with appropriate tolerances and uncertainties. Replacement tidemeters are hung corresponding to the surveyed marks. The intent of the tidemeter is to give the operator an estimate of tide /

PrWed W26/9810:22:16 AM Paes 3 of 5

Northeast Utilities ICAVP DR No. DR-MP3-4161 Millstone Unit 3 Discrepancy Report wave level. It is not calibrated to incremental tolerances, since it is intended that the operator be ablo to make a determination of sea level from a distance. Significance level criteria do not apply as this is not a discrepant condition

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0161, does not represent a discrepant condition. AOP 3569 steps 5,6 and 7 are the procedure steps that implement the actions of Tech Spec 3.7.6 and are taken prior to level exceeding 13 feet. The apparent discrepancies in AOP 3569, SP 3665.1, and Tech Spec 3.7.6 were previously identified by NU and documented in CR M3-97-1613. The CR resolution, however, determined that there was not a discrepancy as the action for the Tech Spec would be taken in accordance with AOP 3569 and the LCO entered. Once this is done, surveillance requirements are not applicable. The instrument used to determine sea level is a level reference (tidemeter) hung at the intake. During initial plant construction, surveyed markings were placed in the location of the tidemeter to ensure it was hung properly. Significance level criteria do not apply as this is not a discrepant condition.

Reavised Response:

Disposition:

NU has concluded that the issue reported in DR-MP3-00161 has identified a NON DISCREPANT condition. Surveillance Procedure (SP) 3665.1 is entered when it is identified that Long Island Sound level is greater than eight feet above mean sea level. Upon notification of a hurricane advisory, AOP 3569 is entued. Step 7 of AOP 3569 requires that the appropriate doors are closed thereby implementing the actions of Tech Spec 3.7.6. These actions are taken prior to the sea level exceeding 13 feet.

As an enhancement to SP 3665.1, procedure and form change request SP 3665.1, revision No. 5, change No.1 (attached) has baen issued which states "With sea level approaching 13 feet above mean sea level weather co.1ditions may warrant entering T/S 3.7.6 LCO and discontinue surveillance until conditions allow".

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

Conclusion:

NU has concluded that the issue reported in DR-MP3-00161 has identified a NON DISCREPANT condition. Surveillance Procedure (SP) 3665.1 is entered when it is identified that Long Island Sound level is greater than eight feet above mean sea level. Upon notification of a hurricane advisory, AOP 3569 is entered. Step 7 of AOP 3569 requires that the appropriate doors are closed thereby implementing the actions of Tech Spec 3.7.6. These actions are taken prior to the sea level exceeding 13 feet.

Printed 5/2MI610 22:16 AM . Page 4 of 5 i

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ICAVP DR No. DR-MP3-0161 Northeast Utilities Millstone Unit 3 Discrepancy Report As an enhancement to SP 3665.1, procedure and form change request SP 3665.1, revision No. 5, change No.1 (attached) has been issued which states *With sea level approaching 13 feet above mean sea level weather conditions may warrant entering T/S 3.7.0 LCO and discontinue surveillance until conditions allow".

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

Previously klerdi6ed by NU7 O Yes (e) No Non r%crepent Condit6on?fG) Yes O No Resoiution Pending70 ve. @ No R iutiaa uor. ev.470 Y,. @ No Review I Acceptable Not M=;^ "- Needed Date VT Leed: Bass, Ken ~

VT Mgr: Schopfer, Don K IRC Chmn: Singh. Anand K Date: 5/26/98 SL Comments: S&L accepts NU's response based on the additional information provided in M3-IRF-02331 and concurs that this is not a discrepant item. Revision No. 5, Change No.1 to SP 3665.1 and associated Form referenced the Technical Specification and proveds adequate guidance for entering the LCO when the sea level approached 13 feet.

S&L determined that there is an incorrect reference to a procedure in SP 3665.1 Rev. 5. Section 7,

SUMMARY

OF CHANGES, states " Reference to the actions taken of water level exceeds 13 feet have been removed. These actions are dealt with in EOP 3569, Severe Weather Conditions. We believe that the reference should to be AOP not EOP 3569.

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ICAVP DR No. DR-MP3-0376 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: Operatons & Maintenance and Testing DR RESOLUTION ACCEPTED Review Element: Corrective Acton Process p Discipline: Other Om Discrepancy Type: Corrective Acton g System / Process: sWP NRC Significance level: NA Date faxed to NU:

Date Published: 10/1tV97 Discrepancy: inadequate documentation to verify commitment Close-out.

Description:

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

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

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

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

The following discrepancy was noted:

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

Review l

valid invaild W Date O O 1 '1S'87 initiator: spear, R. O VT Lead: Bass, Ken O O O 1 21'87 viugr: schopfer, Don K B D 0 12/i/97 IRC Chmn: singh, Anand K G O O 12/3/97 Date: 11/19/97 Printed SQtV9610:23:05 AIF'- Page 1 of 3

ICAVP DR No. DR-MP3-0376 Northeast Utilities Millstone Unit 3 Discrepancy Report HTY MLJLI.

Date: 5/26/98 RESOLUTION: Disposition:

NU has concluded that this issue reported in DR-MP3-0370 has identified a NON-DISCREPANT condition. The noted condition is the lack of adequate documentation to complete the independent verification of the Generic Letter 89-13 Service Water submittal to the NRC. The initial submittal made on January 25,1990, indicated for item V of the GL that the Operating, Emergency, and Maintenance procedures were under review and the review wouki be completed by the end of the next refueling outage. Training was addressed generically for all three Millstone units. A fnliowing NRC submittal on May 31, 1991, stated the activities related to item V were accomplished during the 1991 reSeling outage. Subsequent to these submittals being made to the NRC, a complete formal program for compliance to Generic Letter 89-13 has been developed and instituted. The information contained in the previous NRC submittals has now been augmented considerably. NRC review and inspection of compliance of the program to the requirements of Generic Letter 89-13 is being addressed by SIL ltem 36 prior to startup. Significance Level Criteria do not apply as this is not a discrepant condition.

The Millstone Unit 3 GL 89-13 Service Water System Heat Exchanger Performance Monitoring Program Manual has been forwarded to Sargent & Lundy as an attachment to M3-IRF-01949 in response to DR-MP3-0035.

Conclusion:

NU has concluded that this issue reported in DR-MP3-0376 has identified a NON-DISCREPANT condition.

The information previously submitted to the NRC in January, 1990, and May,1991, for compliance to item V of Generic Letter 89-13 has been augmented consklerably by the development and institution of a complete formal program in January,1998, for compliance to GL 89-13 requirements. SIL ltem 36 addressec compliance of the program to the requirements of GL 89-13. Significance Level Criteria do not apply as this is not a discrepant condition.

Prev 6ously klent6 fled by Nu? O Yes r#) No Non D6screpent corwstt6on?(e) Yes O No Resolution Pending?O vee Ce) No Renoiutionunresoev.d70 v.s @ No l

Review Acceptoble Not Mar 8 Ale Needed Dete g i g , spew,R.

VT Leed: Bess. Ken VT Mgr: Schopfw, Dr. K IRC Chmn: Singh. Ana.1d K Date: 5/26/98 sL comments: NU's response did not provide adequate information to determine specific procedures that were reviewed as part of the GL 69-16 Printed 5? Wee 102376 AM PeGe 2of 3 l

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i ICAVP DR N3. DR-MP3-0376 Northeast Utilities Millstone unn 3 Discrepancy Report implementation. S&L's review of operating and maintenance pr >cedures verified that NU's periodic review process was effective. Based on this review, S&L considers NU's response adequate and acceptable, f

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Prtreed 5/28/9610:2305 APA page 3 of 3

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ICAVP DR N2. DR-MP3-0667 Northeast Utilities Millstone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Elemoed: System Design Poterdial Oper@ lasue Discipline: Mechenical Design O vee D6screpancy Type: Calculebon e No SystemProcess: HVX l NRC Significance level: 3 Date faxed to NU:

! Date Putd6ehed: 12/8/97 D6screpancy: Calculation P(B)-1130 Temporary Ventilation for CCP Pump Area D*ecripuon: Calculation P(B)-1130 Rev. O calculates the heat load and ventilation requirements for temporary ventilation in the component cooling water (CCP) rumps area due to a loss of primary ventilation resulting from a fire on El 43'-6" or EL 66'-6" in the auxiliary building. During review of the calculation the following discrepancies were identified:

1) Calculation P(B)-900 is used as the source for the intemsi heat loads. The MCC and misc. electrical equipment heat loads used in P(B)-1130 are lower than those found in P(B)-900.

2) Calculation uses a supply air temperature of 86*F in sizing the temporary fan but does not provide a basis for using this value.

3) Calculation selects a temporary fan but does not provide a basis for the fan pressure rating selected.

Rev6ew Val 6d tavai6d Needed Date initbtor: Stout. M. D. 8 O O til 2/97 VT Leed: Neri, Anthony A B 0 0 55' 8'S7 VT Mgr: schopfer, Don K O O O 2/ii97 IRC Chmn: Singh, Anand K O O O 12/4/97 Date:

INVALID:

Date: 5/27/98 RESOLUTION: First Response (M3-IRF *302)

NU has determined that the issue reported on Discrepancy Report DR-MP3-0667 does not represent a discrepant condition.

1. The heat loads of calculation P(C)-1130 have been extracted from calculation P(B)-900, and augmented by inputs from SGCS Calculation 95-052. However, these calculations represent diverse plant conditions and their total heat load values are not comparable. CCN-1 to P(B)-1130 evaluates the effect of higher j temperatures than those considered in the original calculation and concludes that the additional heat load is within design limits.

Calculation P(B)-900 covers normal and accident plant operating conditions with both the component cooling water system (CCP) and the charging pump system in operation.

Calculation P(B)-1130 determines the capacity of the portable fans which are reserved for use in the event of a fire in fire area Printed s/28/9810:33.12 AM Pope 1 of 6

ICAVP DR No. DR-MP3 0667 Northeast Utilities Ministone unit 3 Discrepancy Report AB-1 to cool the CCP area assuming the operation of CCP equipment only. This condition is postulated to arise due to the loss of the ventilation system by a fire at elevation 66'-6" or by a fire on the south side of the fire sprinkler curtain that separates the charging pumps area from the CCP area. This scenario is described in Appendix R Compliance Report.

2. Per FSAR Section 9.4.0, 86*F is the outdoor summer design temperature used for ventilation equipment sizing at Millstone I Unit 3. According to the 1973 ASHRAE Handbook of Fundamentals, this 86*F outdoor temper 6ture value will be exceeded for 21/2 % of the summer hours every summer on a statistical basis. Concurrent with the outdoor temperature excursions beyond 86*F, there will be indoor temperature excursions of almost the same magnitude beyond the indoor l design of 110*F.

3. The fan is used in a free delivery application, therefore a pressure loss calculation is not necessary. It is installed in the frame of door A-24-2 in the Northwest comer of CCP area and the single panel Northeast door A-24-9 is opened to let the air out. The specified 1/8" i.w.g. fan static head thus provides a margin of safety.

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

Second Response (M3-IRF-01922)

NU has concluded that item 1 of the follow-up issues on Discrepancy Report DR-MP3-0667 has identified a condition not previously discovered by NU which requires correction. CCN-02 for Calc. P(B)-1130, Rev. 00, was issued as a result of the approved corrective actions associated with CR-M3-98-1231 to revise the results to be consistent with the data in the latest revision of associated calculations P(B)-900,3-92-103-191M3, and 92-LOE 189E3.

As requested, a copy of CCN-01 to calculation P(B)-1130 is attached. This CCN addresses the impact on the Temporary Ventilation System, which serves the Component Cooling Pump

& Heat Exchanger area during loss of primary ventilation, of higher temperatures of CCP piping caused by Safety Grade Cold Shutdown operation, the revised electrical heat loads from Calc P(B)-900, and operation with a single CCP pump.

Additional heat loads from piping (t,'l,800 Bluh), utilized in CCN-01 to P(B) 1130, were taken from CCN-01 (copy attached) to Calculation P(B)-900, Rev.1. CCN-01 to Calc P(B)-1130 is being revised / updated by CCN-02 to P(B)-1130 to utilize data from Rev.1 of P(B)-900, including CCN-01.

1. The electrical equipment loads in P(B)-1130 Rev. O, were originally taken from calculation P(B)-900. Rev. O, with the discrepancies as noted in the DR. Page 6 of the current Revision of Calculation P(B)-900, (Rev.1, copy attached).shows the Normal Condition heat load from electrical Printed 5/2al0610:3312 AM Page 2 or 6

ICAVP DR No. DR-MP3-0667 Northeast Utilities Millstone unit 3 Discrepancy Report equipment and lighting for the Componer.1 Cooling Pump &

Heat Exchanger area as 95,660 Btu /Hr. This heat load, which is based on electricalload inputs from Electrical Calculation No.

92-LOE-189E3, Rev. O, was taken from Calculadon No. 3 103-191M3, Rev.1.

Calculation SGCS95-052 is referenced in CCN-01 to Calculation P(B)-900, Rev.1, and was used to obtain the expected rise in temperature of the CCP system.

The revisions to calculation P(B)-1130 will not change the calculation's conclusions that the temporary ventilation fans have sufficient capacity to perform their function.

Therefore NU concludes that design basis / licensing basis are not affected and this issue is considered as Significance Level 4.

NU has concluded that the follow-up issres identified in items 2

& 3 of DR-MP3-0667 do not represent a discrepant conditions.

2. Per Procedure OP 3314J, Rev. 4, Change 3, (copy attached), the outside stairwell door, A 241,in the northwest comer, door A-24-9, in the northeast comer, and the outer door of the HP trailer (outside of door A-24-9) are blocked open, while the inside stairwell door in the northwest comer, A-24-2, is removed and fans 3HVR FN18A/B (as shown in Calc. P(B)-

1130) are installed in the door frame, directing air to the outside. Outdoor air is thus drawn in through doorway A 24-9, via the HP trailer, in the northeast comer of the Aux. Bldg., and exhausted through doors A-24 -2 and A-24 -1, in the northwest corner. Reference Section 4.1 and 4.2 of OP 3314J for installation and operation of the fans.

3. In accordance with standard industry practice in the selection of fans for free blow applications, these units were selected from Buffalo Forge Co. Breezo Model Catalog , each meeting the following specifications: 5393 CFM @ 1/8" WG; 1140 RPM, 3/4 HP Motor, 220 VAC Single Phase. No ductwork, either upstream or downstream, is attached to these fans. The pressure losses associated with the air intake and discharge through the building are negligible. Tests for Fans 18A & B, included in Technical Evaluation No. M3-EV 98-0030, Rev. O, indicates that the fans were functionally verified to meet their design requirements.

Attachments:

CR-M3-98-1231 with approved corrective action CCN-01 to Calculation P(B)-1130, Rev. O CCN-02 to Calculation P(B)-1130, Rev. O Calculation P(B)-900, Rev.1 CCN-01 to Calc P(B)-900, Rev.1 Procedure OP 3314J, Rev. 4, Change 3 Technical Evaluation M3-EV-98-0030, Rev.0 Supplemental Response (M3-IRF-2260)

The followina information is provided to S&L supplemer. tina NU's Printed 5/26/9810:33.12 AM Pa0e 3 of 6

ICAVP DR No. DR-MP3-0667 Northeast Utilities Millstone Unit 3 Discrepancy Report response to DR-MP3-0667 as stated in M3-IRF-01922:

During an NRC BTP 9.5-1 compliance inspection at MP3, no records could be located that confirmed flow testing of fans 3HVR-FN18A/18B. CR M3-97-3182 was initiated on 9/19/97 to provide the corrective actions. As part of the corrective actions for CR M3-97 3182, steps were added to OP 3314J, Rev. 4, to block open door A-24-9 in the Northeast comer of EL. 24'-6" the Auxiliary Building and a door of the RCA access point trailer, to provide a flow path for the fans. The faas are installed in door A-24-2 in the Northwest comer of EL. 24'-4," the Auxiliary Building.

Outdoor at is thus drawn in through doorwry A-24-9, via the RCA access point trailer, in the northeast cc mer of the Aux.

E,dg., and exhausted through doors A-24-2 ,nd A 24-1 (outer stairwell door), in the northwest comer. The procedure chan0e was approved 1/28/98, and the flow test pcrformed on 2/3/98.

This supplemental information to the it;ow-up issue identified as item 2 of DR-MP3-0667, which was concluded not to represent a discrepant condition.

Attachments:

CR-M3-97-3182 with approved corrective action plan Procedure OP 3314J, Rev. 4 Supplemental Response (M3-lRF-2336)

NU has concluded that the issues reported in DR-MP3-00667 has identified CONFIRMED SIGNIFICANCE LEVEL 4 conditions which have been corrected. During an NRC BTP 9.5-1 compliance inspection at MP3, no records could be located that confirmed flow testing of fans 3HVR-FN18A/188. CR M3 3182 was initiated on 9/19/97 to provide the corrective actions.

As part of the corrective actions for CR M3-97-3182, Change No.

3 to OP 3314J, Rev. 4 was issued to add steps to block open door A-24-9 in the Northeast comer of EL. 24'-6" the Auxiliary Building and a door of the RCA access point trailer, to provide a flow path for the fans. The fans are installed in door A-24-2 in the Northwest comer of EL. 24'-6" the Auxiliary Building. Change No. 3 to OP 3314J, Rev. 4 was approved 1/28/98. Chan0e No. 3 to OP 3314J, Rev. 4, which added steps for blocidng open door A-24-9 in the Northeast comer of EL. 24'-6" of the Auxiliary Building and a door of the RCA access point trailer, to ensure a flow path for fans 3HVR-FN18A/188, was initiated and approved after 5/27/98, the date of completion of discovery of the CMP process. This is supplemental information to item 2 of the follow-up issues of DR-MP3-0667. See M3-lRF-1922 and M3-IRF-2260 for additionalinformation.

NU has concluded that although opening the auxiliary building and RCA access point trailer doors to allow supply air to enter the building was not previously proceduralized (Ref. procedure OP 3314J), it is considered that based on operator experience, the fact that the Technical Support Center (TSC) will be in operation and manned with experienced engineers and operators, and the time required to install the temporary ventilation fans. a reasonable assumption would be that the PrNed 5/26/961o:33.12 AM Page 4 of 6 l

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ICAVP DR No. DR-MP3 0667 Northeast Utilities Millstone unit 3 Discrepancy Report doors would be opened to allow cooling air flow to the area even in the absence of specific procedural guidance. NU, therefore, considers this issue to be Significance Level 4.

Pre *<~'Jsly identined by Nu? O Yes (G) No Non D6screpent Condition?O Yes (G) No Resolution Pending?O Yee @ No l'.eoolut6onUnresolved?O Yee @ No Revi Initiator: stout. M. D.

VT Lead: Neri. Anthony A VT Mgr: schopfer, Don K gg IRC chmn: sy, Anand K wa S O O Date: $/27/98 SL Commente: Comments on First Response NU is requested to provide a copy of CCN-1 to P(B) 1130 which is required to complete the review of NU's response.

1) Electrical Heat Loads NU's response does not adequately address the differences in the electrical equipment, cable, and lighting heat Sains used in calculations P(B)-1130 and P(B)-900.

'ihe electrical equipment loads in calculation P(B) 1130 are lighting at 25,600 Btu /hr, MCC and misc. electrical equipment at 14,450 Blu/hr and cables at 4,200 Btu /hr for a total of 44,250 Btu /hr.

The eluctrical equipment loads in calculation P(B)-900 are motor control centers at 13,200 Btu /hr, miscellaneous electrical equipment at 8,450 Btu /hr, cable loads at 4,200 Blu/hr, and lighting at 25,600 Blu/hr for a total of 51,450 Btu /hr.

Inaddition calculation 3-92-103-191M3 has a different value for normal condition electrical loads. The electrical equipment loads shown on page 15 of calculation 3-92-103-191M3 for normal operation is 95,660 Blu/hr and was based on calculation 92-LOE-189E3.

NU's response indicates that the heat loads of calculation P(B)-

1130 were augmented by inputs from SGCS Calculation 95-052.

Describe what information from 95-052 was used and address why it was not documented in calculation P(B)-1130.

2) Supply Air Temperature ,

Agree with NU's response that the design summer outdoor air temperature is 86*F.

Per NU's response the temporary faras draw air from the northwest stairwell at door A-24-2 and discharges to the elevation 24'-6" in the auxiliary building. The air is relieved to outdoors thru door A-24-9. Provide the basis for assuming that the temperature of the air drawn from the stairwell is the same as the outdoor air temperature.

Printed 5f28/9610:33:1.9 AM Page 5 of 6

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[ DR No. DR-MP3-0667 Northeast Utilities ICAVP Ministone Unit s Discrepancy Report Note that System Operating Procedure OP 3314J, Rev. 4

' Auxiliary Building Emergency Ventilation and Exhaust' describes using the temporary fans at door A-24-2 as exhaust fans but does not address what door (s) are opened to allow outside air into the area for cooling.

3) Fan Pressure While the fan is not connected to ductwork, there are still pressure losses associated with the air intake into the auxiliary I building and outlet from the auxiliary building. These losses should be addressed 'n the calculation.

Comments on Second and Supplemental Responses Agree with NU's response for items 1 and 3.

Agree that Procedure OP 3314J Rev. 4, Change No. 3, dated 1/28/98 addresses the outdoor air intake path of item 2. As the need to change the procedure was identified after the CMP completion date this is considered to be a Level 3 discrepancy.

FPER Soction 8.5 states that portable ventilation is provided to cool the CCP pumps should all auxiliary building ventilation be lost. Failure to open a door to provide an outside air intake path for the temporary fans does not agree with the FPER and would have resulted in the area temperature being higher than that determined in calculation P@)-1130. Disagree with NU's response that it is reasoriable to rely on operator action not contained in the procedure to the open doors needed to provide an outside air intake path at the time the temporary fans are installed.

The significance level of this DR is unresolved.

Additional Comments As directed by the NRC, the DR is being reissued as a confirmed Level 3 discrer.ancy.

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Printed 5/2fV9810.33:13 AM Pape 6 of 6

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DR No. DR-MP3 4676 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: system installation Discipline: Other Om Discrepancy Type: Installeta implementate gg System / Process: HVX NRC Significance level: 4 Date faxed to NU:

Dele Published: 12f7/97 Discrepancy: Walkdown Discrepancies of HVX and SLCRS

Description:

The following discrepancy items were found during the walkdown of the ducting and mechanical equipment of the HVX and SLCRS:

1. Flow elements 3HVR*FE88A and 3HVR*FE888 have no NU labels.

2. Instrument line 3HVR-PDIS157A has an additional support (first support from the filter 3HVR*FLT3A) that is not shown on drawing EK-512123 Rev 2.

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3. Support DSA1139 shown on drawing BZ-545-48 Rev3 has an additionallateral pipe restraint attached to one of the vertical legs of the support that is not shown on the drawing or its unincorporated DCNs.

4. Damper 3HVR*DMPB5B has no NU label. !

5. Dampers 3HVR*DMPB6A and 3HVR*DMPF23 have no visible NU labels.

6. Dampers 3HVR*DMPBSA and 3HVR*DMPF22 have no visible NU labels.

7. Part of duct next to dampers 3GWS*AOD78A/B is not insulated (2 hr fire rated) as called for on drawing EB-45L Rev13.

8. Dampers 3HVR*DMPS,3HVR* MOD 45B2 and 3HVR* MOD 45B1 have no NU labels visible.

9. Flow element 3HVR*FES2B tabel reads *FE88A.

10. Damper 3HVR* MOD 50C2 has no mfg. label visible.

Review Valid invalid Needed Date initiator: Reed, J. W. O O O 11'14/97

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VT Lead: Neri, Anthony A B O O 1/1S'S7 12/iis7 1

VT Mgr: schopfer. Don K O O O RC Chmn: singh, Anand K O O O 1273/97 Dete:

INVALID:

Date: 5/27/98 RESOLUTION: First Response (M3-IRF-02174)

Pnnted 5/28/9610.23 57 AM Page 1 or 4 I

ICAVP DR N . DR-MP3 4676 Northeast Utilities Millstone Unit 3 Discrepancy Report NU has concluded that the issues reported in DR-MP3-0676 have identified CONFIRMED SIGNIFICANCE LEVEL 4 conditions which require correction, items 1,4,5,6,7,8,9 and 10 meet the criteria specified in NRC letter B16901 and 17010.

They have been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meet section 1.3.2.e of U3 Pl 20 deferral criteria.

NU has concluded that the issues reported in items 1,7,8,9 and 10 of DR-MP3-0676, have identified conditions which require correction. A discussion of each issue follows:

Item 1 is valid,3HVR*FE88A and 3HVR*FE88B do not have NU labels installed.

Item 7 is valid, drawing EB-45L does indicate the section of duct in question should be insulated with 2 hr. fire rated insulation.

However, the plan drawing EB-45H does not indicate the section to be insulated. The P&lD drawing EM-148E also does not indicate the section to be insulated. NU acknowledges that the duct should be insulated with at least a 1 hr. fire wrap. (DCN DM3-00-0855-97 reduces the required insulation on this section of duct to 1 hr. fire rated) but that it remains operable without it because the damper supports are fire protected and the duct itself is capable of withstanding a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fire. For information, an old E&DCR F-B-39542, for both EB-45H and 45L, shows this small section of 16" x 12" duct insulated.

Item 8 is valid, damper 3HVR*DMP5 has no label, however dampers 3HVR* MOD 45BL & 3HVR* MOD 45B2 do have labels installed.

Item 9 is valid,3HVR*FE528 has a manufacturers tag with the incorrect identification (3HVR*FE88A) and should be corrected.

Item 10 is valid, however damper 3HVR* MOD 50C2 has no manufacturers tag, but does have an NU label.

NU has concluded that issues 4 and 5 reported in DR-MP3-0676 have identified a PREVIOUSLY IDENT!FIED condition, item 4 is valid, however damper 3HVR*DMPB5B has no label.

This conition was pre-discovered by Pt 24 walkdowns and identified on UIR 2582 (attached) section E.4.

Item 5 is valid, however damper 3HVR*DMPB6A has no label.

This condition was pre-discovered by Pl 24 walkdowns and identified on UIR 2582 section E.5. Damper 3HVR*DMPF23 has no label and was not rediscovered.

Item 6 is valid, however damper 3HVR*DMPB5A has no label.

This condition was pre-discovered by Pl 24 walkdowns and identified on UIR 2582 section E.3. Damper 3HVR*DMPR22 has no label and was not rediscovered.

None of the eauipment identified in items 1.4.5.0.8.9 and 10 is Page 2 of 4 Prirded s/28/9610:23:57 AM

l ICAVP DR No. DR-MP3-0676 Northeast Utilities Millstone Unit 3 Discrepancy Report operated by Plant Operators, so the missing labels will not impact plant operation. The missing duct insulation, item 7, does not affect operability because the duct has a one hour fire rating itself. Therefore the installation of the insulation may be deferred until post startup.

For items 1,4,5,6,7,8,9, and 10 the missing labels and insulation will be installed post startup. CR M3-98-2312 was closed to BIN CR M3-98-0165. The corrective actions for CR M3-98-0165 will install these labels and the duct insulation.

NU has concluded that the issues reported in items 2 and 3 of Discrepancy Report, DR-MP3-0676, have identified NON-DISCREPANT conditions. A discussion of each issue follows.

Item 2 is not valid, the instrument line for 3HVR-PDIS157A has a total of 6 supports from the filter 3HVR*FLT3A to the per.etration in the floor. This is in agreement with EK-512123 rev 2. This is not considered a discrepancy, item 3 is not valid, this is an additional pipe support attached to support DSA1139. This support is detailed en E&DCR N-CS-03528 pages 17 & 81. This E&DCR is posted against the DSA support drawing no. 20212-22642/1139. This is not considered a discrepancy.

Attachments:

CR M3-98-2312 UIR 2582 Supplemental Response (M3-IRF-02357)

NU has concluded that this issue reported in DR-MP3-0676 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. Pursuant to discussions with S&L for clarification of the issue, NU submits the following additional information:

The unwrapped duct identified in DR-MP3-0676 represents a condition that is inconsistent with the configuration of the SCLRS ductwork as depicted on drawing EB-45L. This inconsistency does NOT represent a departure from the MP3 LB

/ DB since the licensing commitment made in the FPER page B-21, Position C5.a.(4 ), is strictly adhered to as deccribed in the NU Response C.S.a. ( 4 ) [ See Attachment A for a graphical representation of the duct in q'uestion and its relation to the required configuration as described in Position C.S.a.( 4 )]. The unwrapped duct in question is outside of the LB / DB commitment space. Additionally, as stated in the deportability determination of condition report M3-98-1651 ( See Attached ),

the unwrapped duct poses no operability or safety concem.

Action request 98006344 will track all work activities necessary to ensure consistency between the FPER, the SLCRS duct work, the drawings, and the plants procedures. AWO M3-98-06394 will contrnt the work activities necessary to install the fire wrap en the unwrapped duct.

Pnnted 5/289610:23.57 AM Page 3 of 4 l

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ICAVP DR No. DR-MP3-0676 Northeast Utilities Millstone Unit 3 Discrepancy Report NU considers DR-MP3-0676 to be a valid level 4 discrepancy.

These corrective actions will be completed after MP3 startup.

Attachments:

1. Attachrnent A: Graphicalillustration of discrepant condition

2. Condition Report M3-98-1651 Previouely identifled by NU7 O Yes rG) No Non Discrepent Condition?Q Yee (9) No Resolution Pending70 Yee @ No Reedutionunreedved70 Yee @ No Review initictor: stout, M. D.

VT Lead: Neri, Anthony A VT Mgr: schopfar, Don K IRC Chmn: singh, Anand K Date: 5/27/98 SL Comments: Agree with NU that items #2 and #3 are non-discrepant.

Agree with NU that missing labels for 3HVR*DMPB58, 3HVR*DMPBSA and #HVR*DMPB6A were previously identified by NU.

Agree with NU that items #1,5,6,7,8,9, and 10 are level 4 discrepancies.

1 Printed 5/2tV961023:57 AM Pa0e 4 of 4

ICAVP DR No. DR-MP3-0854 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design p Discipline: I & C Design Om Discrepancy Type: Licensing Document g" SystenVProcess: DGX NRC significance level: 4 Date faxed to NU:

Date Published: 1/18/98 D6screpancy: FPER Figure 7-1.4 contains incorrect instrument numbers Ducription: FPER Figure 7-1.4, Amendment 14 dated July 1985 depicts level indicating switches *LIS26A, B and LIS27A, B. The function of these switches is to start /stop the Fuel Oil Transfer Pumps 3EGF*P1 A,B,C,D, respectively.

These numbered switches do not appear on P&lD EM-117A 10, Emergency Generator Fuel Oil System. They also do not have an associated loop diagram, nor do they appear in the Logic Diagram LSK-8-9A, Rev. 9, Emergency Generator Fuel, which depicts the control logic for the above pumps. These components do not appear in PMMS or PDDS. These switches were procured at one time under Spec. 2424.210-377. There are vendor drawings for these switches in GRITS under the specification. A review of eMMS history did not identify any work orders (AWOs) for these switches. Based on other information in the history files, the wrong model numbers required for the switches were received and the switches retumed to the vendor.

Switches 3EGF*LS40A, B and 3EGF*LS41 A,B were purchased under Spec 377 with subsequent installation of these new switches. These new switches were placed in service on June l 15,1985. The functions of the new switches is the same as the old ones. These switches are depicted on P&lD EM-117A-10.

Their corresponding Logic Diagram is LSK-8-9A, Rev. 9. Their associated Loop Diagrams are 3EGF-040A, Rev.3; 3EGF-0408, l

Rev. 4; 3EGF-041 A, Rev. 4; and 3EGF-041B, Rev.5. These l

j new switches do not appear in PMMS or PDDS.

FPER Figure 7.1-4 should be revised to indicated these new switch numbers.

Review Valid invalid Needed Date initiator: Launi, C. M. O O 18S8 O

VT Lead: Neri, Anthony A B O O 5'8/S8 VT Mgr: schopfer, Don K B D D 1/12/98

/ d/S8 IRC Chmn: s6ngh, Anand K O O O Date:

INVALID:

Date: 5/26/98 RESOLUTION: Disposition

NU has concluded that this issue reported in Discrepancy Report DR-MP3-0854 has identified a CONFIRMED SIGNIFICANCE Printed 5/28/9810:24:22 AM Page 1 of 2 l

ICAVP DR N2. DR-MP3-0854 Northeast Utilities Millstone Unit 3 Discrepancy Report LEVEL 4 which requires correction. This discrepancy meeis the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. CR M3-98-2314 has been written to revise FPER Figure 7.1-4 to indicate the new switch numbers.The P&lD EM-117A-10 and the Logic Diagram LSK 9A are correct and show levelindicating switches 3EGF*LS40A, B and 3EGF*LS41 A,B not *LIS26A, B and LIS27A. The switches 3EGF*LS40A, B and 3EGF*LS41 A,B are in PMMS and PDDS as well as being on the Safe Shutdown Equipment List (SSEL) correctly.CR M3-98-2314 was closed to Bin CR M3-98-0167.

The corrective Actions of CR M3-98-0167 will correct the FPER Figure post startup. There is no affect on License of Design Basis.

Conclusion:

NU has concluded that this issue reported in Discrepancy Report DR-MP3-0854 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 which requires correction. This discrepancy meets the criteria specifitsd in NRC letter B16901 and 17010. It has been i screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. CR M3-98-2314 has been {

I written to revise FPER Figure 7.1-4 to indicate the new switch I numbers.CR M3-98-2314 was closed to Bin CR M3-98-0167.

The corrective Actions of CR M3-98-0167 will correct the FPER I Figure post startup. There is no affect on License of Design Basis.

Previously identified by NU7 O Yes @ No Non D6screpent Condition?O Yes @ No i

Resolut6onPending?O va @ No naamionunraav.d70 va @ No Review initiator: Tenwinkel, J. L.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Dete: 5/26/98 SL Comments: No comments.

I Printed 5/28/9610:24r AM Page 2 of 2 l

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ICAVP DR No. DR MP34944 Northeast Utilities Mmstone Unit 3 Discrepancy Report l Review Group: Operatens & Meirdenance and Test ng DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p g Discipline: Operatons Ow Discrepancy Type: Corr $ctive Acton gg Systemerocess: DGX NRC Significance level: 4 Date faxed to NU:

Date Published: 1/25/98 I

Discreancy: Procedure revisions do not prevent recurrance of event reported j in LER 89-015-00 Descripuon: A review of the requirement described in REQ-MP3-DGX-0289 was unable to determine how tha corrective actions prevent the .

operating error described in LER 89-015-00 from recurring under similar circumstances. LER 89-015-00 reports a failure te assure that the "A" Emergency Diesel Generator and its associated "A" Train 4160/480 VAC Emergency Busses were fully operational prior to removing the "B" Emergency Diesel Generator from service. This is a discrepancy.

OP Form 3672.1-2 is performed daily but only confirms that the bus is energized. There is no provision for the operator to record the bus load or to compare it against a limiting value based on the power source. Therefore, OP Form 3672.1-2 would not prevent recurrence.

i OP 3344A describes the necessary steps to manipulate the power source to the 480v load centers with precautions but there is nothing that informs subsequent shifts that there is ar inusual i electrical line-up that limits the load carrying capabilities of the j bus. Therefore, the operator does not have the necessary j information available to make the correct decision regarding !

I operability issues of the opposite emerDency diesel generator.

Therefore, OP 3344A would not prevent recurrence.

This procedure also requires removing the A " CAR" Fan from service if bus 32S is being supplied through a cross-tie. ;

However, the portion of OP 3344A that retums bus 32S to its normal supply does not mention retuming the A " CAR" Fan to an operational condition.

Commitment Record 17554 commits to " Issue a new procedure to delineate the Electrical Plant Line-up conditions . .

The review was unable to determine from the Validation Text what new procedure was issued. Instead, it appears that an existing procedure was revised.

Review Valid invalid Needed Date initiator: Tamlyn, Tom O O O 1'18'S8 VT Lead: Bass,Kan 9 O O '18'S8 VT Mgr: schopfer, Don K O O O si20sse IRC Chmn: singh, Anand K O O O ir2iise Dele:

INVALID:

l l

Printed 5f26/9810:24:40 AM Pape1 of 3

Northeast Utilities ICAVP DR No. DR-MP3 0944 Millstone Unit 3 Discrepancy Report Dde: $/26/98 RESOLUTION: Disposition:

NU has concluded that the issue reported in DR-MP3-00944 has identified a NON-DlSCREPANT condition.

Section 4.4, " Cross-Tying 480 Volt Load Centers", and Section 4.5,

Restoring Cross-Tied 480 Volt Load Centers

of Procedure OP 3344A Rev.11, are sufficient to prevent the operating error described in LER 89-015-00 from recurring under similar circumstances. These steps contain the appropriate instructions and cautions to address the root and contributing causes of the event, as identified in the LER. In addition, logs, shift tumovers, and red TAGS provide additional mechanisms to prevent said operating error. Operations uses Section 4.4 to cross lie the 480 volt load centers. The first step,4.4.1 requires the operator to refer to the Technical Specifications (T/S) and determine the applicable LCO actions. Step 4.4.1 identifies the applicable T/S including 3.8.3.2. This addresses the root cause identified in the LER, by providing procedural guidance to ensure that all T/S requirements are being met. Applicable T/S LCOs and abnormal electrical alignments are logged by the operating shift and carried forward as part of the Shift Tumover process (OP 3260 Conduct of Operations). The shift log and tumover report would be reviewed should an EDG subsequently be determined to be Inoperable. This review is specifically performed to determine if additional T/S LCOs now apply because of the EDG Inoperability.

OPS Form 3872.12 is used to perform T/S Surveillance, and is not intended to address LER 89-015-00.

Restoration of the cross tied 480 volt load centers, by subsequent shifts, will be by procedure OP 3344A Section 4.5.

Steps 4.5.1 through 4.5.9 restore the load centN to the normal alignment. Step 4.5.10 allows loads removed fNm serv!ce in section 4.4 to be restored, for example the A

CAR

fan. In addition, the procedure for cross tying the 480 voit load centers requires the use of TAGS in order to prevent operation of the component while the bus is cross tied. These TAGS document why the breakers are racked oui, and can be considered to be another mechanism to inform operators of an unusual electrical line-up that limits the load carrying capabilities o' a bus.

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

Conclusion:

NU has concluded that the issue reported in DR-MP3-00944 has identified a NON-DISCREPANT condition.

Section 4.4, " Cross-Tying 480 Volt Load Centers", and Section 4.5, " Restoring Cross-Tied 480 Volt Load Centers

of Procedure OP 3344A Rev.11, are sufficient to prevent the operating error described in LER 89-015-00 from recurring under similar circumstances. These steps contain the appropriate instructions and cautions to address the root and contributing causes of the event, as identified in the LER. In addition, logs, shift tumovers, and red TAGS provide additional mechanisms to prevent said operating error.

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

MDy nur ' vos ~ no mm --- = n. --r'

. vn p,,, yg;, 3

ICAVP DR No. DR MP3-0944 Northeast Utilities Millstone Unit 3 Discrepancy Report Preveously kierdified by NU? U Yes iej No Non Descrepent Conditum7U Yes @ No ResolutkmPending?O va @ No Re.auikm unre.av.d?O va @m Review initiator: Speer, R.

VT Lead: Bass, Ken VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/26/98 st Comments: S&L concurs that the identified correctives are sufficient to prevent a reoccurrence of the operating error described in LER 89-015-00. OP 3344A was revised to contain the appropriate instructions and cautions to address the root and contribution causes of the event. This revision to OP 3344A was identified as revision 11 in NU's response dated May 2,1998 and has an effective date of November 131997 which is after the ICAVP discovery date. Therefore, S&L considers this to be a level 4 discrepancy.

Printed Gr28/961024.so AM Page 3 of 3

ICAVP DR Nr. DR MP3-0984 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: Modircaten Design Discipline: Mechancal Design Om D6screpency Type: Calculaten gg SystemfProcess: DGX NRC Significance level: NA Date faxed to NU:

Date Published ti2Sf9e D6screpency: Seismic test reports for equipment installed by plant modifications are not available for review.

Descripuon: The seismic test reports listed below are identified in the associated PDCRs as the basis for the seismic qualification of the equipment installed by plant modifications. These reports were requested on Request For Information M3-RF1-00827.

ICAVP Response Form M3-IRF-01312 provided the purchase documentation (purchase orders, certificates of compliance, etc.)

for the subject equipment; however, the seismic test reports were not available. Therefore, the seismic test reports can not be reviewed for compliance to the seismic requirements of the applications identified in the PDCRs.

Modification No.: PDCR# MP3-86-334 Equipment: GE Model 12SFF31 A1 A Relays Location: Panels 3EGS*PNLA/B Test Report No.: GE Report No. MIL 82-12 Modification No.: PDCR# MP3-87-025 Equipment: GE Model No.12PVD99AB001 A Relays Location: 4KV Switchgear Test Report No.: NTS Report No. 22650-87N Modification No.: PDCRW MP3-94-006 Equipment: Westinghouse V46D47T45C Transformer Location: Panels 3EGS*PNLA/B Test Report No.: NTS Report No. 60318-94N Review Valid invalid Needed Date O 1'18'88 initiator: Johnson, Jay G O sitatoe VT Lead: Neri, Anthony A O O O VT Mgr: Schopfer, Don K O O O si2o/98 tr22/se IRC Chmn: singh, Anand K O O O Date:

INVALID:

Date: 5/27/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report DR-MP3-0984 does not represent a discrepant condition. The previously provided Purchase Orders and Certificates of Compliance togeth3r with . . . contains a detailed seismic review (Attachment 2 of the PDCR) which provides engineering justification for the use of the replacement relays. The review references GE Report No. MIL 82-012, but the report itself is not included in the modification packa08. nor is it required to be.

The Purchase Orders and the Certificate of Compliance Prtnted 5/2eSe 10.25:10 AM ,

Page 1 of 3 1

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ICAVP DR No. DR-MP3-0984 Northeast Utilities Millr. tone Unit 3 Discrepancy Report previously provided to S&L document that the replacement relays meet the samu criteria as the original components.

Therefore, there is no discrepant condition.

PDCR# MP3-87-025 pertains to Resistance Temperature Detectors, not the referenced GE relays. Therefore there is no discrepant condition identified.

PDCR# MP3-94-006 which replaced transformers in 3EGS*PNLA/B contains a detailed seismic qualification review (Nc. SQR3-94-0014) which provides engineering justification for the use of the replacement transforTners. The review references NTS Report No. 60318-94N, Rev. 0 (P.O. 952131) but the report itself is not included in the modification package, nor is it required to be. The Purchase Orders and Certificates of Compliance previously provided to S&L document that the replacement transformers meet the same criteria as the original components. Therefore, there is no discrepant condition.

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

Previously identified by NU7 O Yes @ No Non Discrepent Condition 7@ Yes O No Resolution Pending?O ve. @ No Re.oiution unre.oived70 Ye. @ No Review initiator: Johnson, Jay VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: sinDh, Anand K Date: $/27/98 SL Comments: S&L COMMENTS ON FIRST NU RESPONSE:

PDCRs MP3-86-334 and MP3-94-006:

Although h may not be required that the seismic report be included in the modification package, it is not possible for S&L to verify that the seismic review contained in the PDCR is correct without it, if the engineer used the report in his seismic review of the PDCR then it should be made available to S&L for verification.

PDCR MP3-87-025:

Rereview of the PDCR provided to S&L for verification indicates that it does pertain to GE relays. If other information is available showing that the subject change affects RTDs instead then this should be made available to S&L for verification.

S&L COMMENTS ON SUBSEQUENT NU RESPONSE VIA TELECON:

Subsequent to fuilher discussions with NU via telecon, NU confirmed that PDCR MP3-87-025 does pertain to the subject GE PVD relays. In addition, NU provided adequate documentation on all of the subject test reports identified in this discrepancy; Printed 5/28/9010:25.10 AM Page 2 or 3

ICAVP DR No. DR-MP3-0984 Northeast Utilities Wilstone unk 3 Discrepancy Report therefore, this is a non-discrepant condition.

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Printed 5/28/9810:25:11 AM Page 3 of 3 l

DR NO. DR-MP3-1009 Northeast Utilities ICAVP Millstone Unit 3 Discrepancy Report Rev6ew Group: Programmata DR RESOLUTK)N ACCEPTED Review Element: CorrectNo Action Proceso p g Diecipl6ne:I & C Design O veo Discrepancy Type: CorrectNe Action iiin TeL. g System /Proceso: sWP NRC Significance level: 4 Date faxed to NU:

Date Putnished: 2/7/98 J D6screpancy: Inadequate implementation Documentation f

Description:

Unresolved item Report (UIR) 432 Closure Reg' Jest documents that an " engineering review" (Material Equipment Parts List (MEPL) evaluation MP3-CD-1071) was performed to disposition Non-Conformance Report (NCR) 395-065; however, this

" engineering review" (MEPL evaluation MP3-CD-1071) was not included in the UlR 432 closure package.

Review Valid invalid Needed Date

'30S8 ininetor: Dombrowsid, Jim O O O VT Lead: Ryan, Thomas J B O O 1'30'S8 2/2/9e VT Mg : schopfer, Don K O O O O 2/ase IRC Chmn: singh, Anand K O O Date:

INVAUD:

Date: 5/27/98 RESOLUTION:

NLJs First Response NU has concluded that Discrepancy Report, DR-MP3-1009, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-1143 has been written to develop and track resolution of this item per RP-4.

NU's Second Response

Background:

S & L's Considers the NU response stated in M2-IRF-01914 to Discrepancy Report DR-MP3-1009 unacceptable. S & L restates the discrepancy as follows:

This ACR was identified as a " Start-up" document. Unless a specific reason acceptably dispositions this ACR as to why ,

verification of completion will be delayed till after plant start-up, f this DR resolution is unacceptable. ]

l Disposition:

NU has concluded that the issue reported in DR-MP3-01009 has identified a NON-DISCREPANT ccndition.Further investigation Printed 5/28/9e to:2s:30 AM Page 1 of 4

ICAVP DR No. DR-MP3-1009 Northeast Utilities Millstone Unit 3 Discrepancy Report has determined that the closure package is adequate. NCR 3 0065 identified and resolved the condition tracked by UIR 432, and is contained in the UIR 432 Closure Package. MEPL MP3-CD-1071 is referenced by NCR 3-95-0065, but is not considered part of the NCR. MEPL MP3-CD-1071 is being provided.

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

Conclusion:

NU has concluded that the issue reported in DR-MP3-01009 has identified a NON-DISCREPANT condition.Further investigation has determined that the closure package is adequate. NCR 3 0065 identified and resolved the condition tracked by UIR 432, and is contained in the UIR 432 Closure Package. MdPL MP3-CD-1071 is referenced by NCR 3-95-0065, but is not considered part of the NCR. MEPL MP3-CD-1071 is being provided.

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

Attachments: ONCR 3-95-00650 DMEPL MP3-CD-1071 NU's Supplemental Response:

Disposition: l NU has concluded that this issue reported in DR-MP3-01009 has identified a CONFlRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. This item meets the deferral criteria of section 1.3.2.e of U3 PI-20.

CR M3-98-1143 has been written to correct the original item post l startup. CR M3-98-1143 has been closed to BIN CR M3 0135. CR M3-98-2631 has been written to identify that the disposition of NCR 395-065 does not clearly state the bases for the decision, and to correct this post startup.

MEPL evaluation MP3-CD-1071 identified several instruments installed on the Service Water system that were designated as nonQA but were connected to the system through common 1 tubing with safety related instruments. The concem was that a postulated failure of the nonQA instrument to maintain its system pressure boundary could render the safety related instrument as ]

unable to perform their safety function. The original NCR disposition indicated that the instruments would be upgraded to QA, UIR 432 documented this action as startup related, however a subsequent ADMIN Disposition declared the condition as non-discrepant based upon engineering review but did not provide any basis for that disposition. UIR 432 was closed based upon the ADMIN disposition on the NCR.

l The installation program implemented at MP3 established two installation categories. Group A installations were those instruments connected to safety related procer 5 pipina or Prtnted 5/28/9810:25.31 AM Pa08 2 of 4

I ICAVP DR No. DR-MP31009 Northeast Utilities Millstone Unit 3 Discrepancy Report equipment regardless of whether or not the instrument performed a safety related function. Group B installations connect non-safety related instrumentation to non-safety related processes.

Group A installations are designated as safety class 2 QA, seismic, and meet the design and material requirements of ASME lit, subsection NC. The original procurement specifications for instruments such as those identified in the MEPL purchased instruments as either QA Cat 1 or QA Cat 2 under the Stone & Webster QA program. The seismic acceptability or qualification of the instruments was documented via a qualification test report through the procurement specification or the instruments were evaluated for seismic pressure boundary integrity through calculation by the engineering department. The seismic acceptability of the instruments is not based upon the QA, or nonQA, MEPL designation established for the purposes of future procurement and replacement of the instruments but is instead based upon l how the instruments will be installed in the plant, i.e., as Group A. Therefore, the ADMIN Disposition of NCR 395-065 is correct and the UlR is not a startup related issue however the basis for the NCR disposition does not adequately document the above described installation basis and will be corrected

Conclusion:

NU has concluded that this issue reported in DR-MP3-01009 has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. This item meets the deferral criteria of section 1.3.2.e of U3 PI-20.

CR M3-98-1143 has been written to correct the original item post startup. CR M3-98-1143 has been closed to BIN CR M3 0135. CR M3-98-2631 has been written to identify that the disposition of NCR 395-065 does not clearly state the bases for the decision, and to correct this post startup.

Attachments:0CR M3-98-2631 Previously identined by Nu? O Yes (G) No Non Discrepent Condition?O vos @) No ResolutionPending7O ves @ No Resolutionunresolved70 vos @ No Review initiator: Sheppard, R. P.

O O mm VT Lead: Ryan, Thomes J VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Dete: S/1gl98 sL Comments:

S&L's Comments to NU's First Response This ACR was identified as a " Start-up" document. Unless a specific reason acceptably dispositions this ACR as to why Printed s/2tV9810:25:31 AM PeDe 3 of 4

ICAVP DR No. DR-MP3-1009 Northeast Utilities milistone unit 3 Discrepancy Report verification of completion will be delayed till after plant start-up, this DR resolution is unacceptable.

S&L's Comments te NU's Second Response NU's Response is unacceptable.

NU has not provided a copy of the " engineering review" documentation as noted in the NCR 395-065 ADMIN Disposition.

This " engineering review" provided the justification that the non-conforming conditions were determined not to be valid; consequently, justifying the NCR closure as Adtnin and not requireing any field changes. This " engineering review" was requested in this DR but not received .

f!U has not indentified what actions they intend to take after startup per CR M3-98-1143. Note: CR M3-98-1143 references

" Historical Record Cleanup".

i Printed 5/2tV9810:25:31 AM Page 4 of 4 L

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Northeast Utilities ICAVP DR N@. DR-MP3-1011 g Millstone Unit 3 Discrepancy Report Review Group: Operatsons & Maintenance and Testing DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design g

Disceep ecy Type: Des 6gn Control Procedure SystemProcess: DGX NRC signlAcance level: 3 Date faxed to NU:

Date Published: 3/5/96 D6screpancy: Unreviewed Safety Questions Conceming the MP-3 Emergency Diesel Generators

Description:

Modification 3-91-196 (MOD) was reviewed and issued by NU's PORC on 12/4/91. The PDCR package was completed and '

submitted to Nuclear Records on 8/15/92. The need for the modification was that the fuel oil sample point was down stream of the strainers that remove particulate of 200-mesh size or larger from the fuel oil. Consequently, the strainers could affect the sample r~*:culate analysis. The purpose of the modification is to pem a . ..uy remove the strainer elements from strainer a housings 3EGF*STR1C and 3EGF*STR1D (one of two on each Diesel) allowing for a more representative 9 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:

l 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 of the fuel oil system to meet independence and redundancy criteria.

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

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

l. The requirements for the design of full-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-rnmntinnen with ANRI N10r wiQ7A which rannirac rhinlow Pnnted 528/961025:48 AM Page 1 of 4

Northeast Utilities ICAVP DR No. DR-MP3-1011 Millstone unit 3 Discrepancy Report Strainers. A single Y-type strainer is installed in each Fuel Oil l 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 l storage tanks for each Diesel, instead of the required 7-day )

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

'concem' from NU's Nuclear Safety Engineering group. The 50.54f EDG Review Team questioned the technicaljustification for this MOD and whether or not it could result in a potential reduction in reliability. The conclusion of this ACR was that the strainers should remain removed, because "There is also less risk of an EDG failure with the cartridges removed than with l 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 u have only looked at the 'C' and 'D' strainers being used during the Fuel Oil Sample Surveillance. No evaluation of tha long term effects of operating with the unstrained oil pump was performed. Further, no analysis was performed to determine the effects on sludge carry-over or its effect on the engine fuel filters as the tank levels diminish. This review should have included an analysis of the 10% minimum level allowed in the Fuel Oil Storage Tanks and some minimal level in the Day Tanks when operated in manual utilizing operators. NU did not take into account that the unstrained pumps 'C' and 'D' are also the ones which have dual electrical feeds, making them the more reliable Feel Oil Transfer Sub-Systems during a LOP event .

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

Each pump has sufficient capacity to fill both day tanks with both emergency generators running, since the fuel consumption at rated load and speed for one emergency generator is 6.16 gpm." This implies that if one Fuel Oil Storage Tank were inoperable, then both EDG's would be feed from one tenk. 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 canceming 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 PrWed 5/2H6 to:25A0 AM Page 2 of 4

ICAVP DR No. DR-MP3-1011 Northeast Utilities Millstone Unit 3 Discrepancy Report and strainers, a day tank, and piping to each respective diesel engine." l

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 al;0nment. 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, boed on NU's response, the DR's NRC Significance Level could escalate.

Revnew Valid invalid Needed Date initialor: Ungeran. R. O O O 2r24eee O 2r2sso VT Lead: Bass, Ken O O VT Mgt: Schopfer. Don K g g Q 2/26/90 BRC Chmn: Singh, Anand K O O O 3/2/98 Date:

INVALID:

Date: 5/26/98 RESOLUTION: Disposition:

Northeast Utilities RP4-2 CR Change Form (attached), revised the corrective action plan for CR M3-96-1373 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 discharDe lines. The justification for this difference from the ANSI standard is supported by the MP3 procedures which assure that the oit 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.

l

Conclusion:

Northeast Utilities RP4-2 CR Change Form (attached), revised Pnnled 6/2&96 to 25 40 AM Page 3 of 4 l

Northeast Utilities ICAVP DR N2. DR-MP3-1011 Millstone Unit 3 Discrepancy Report the corrective action plan for CR M3-98-1373 to revise FSAR Section 9.5.4 as required to clearly describe the configuration of the strainers in the transfer pump discharge lines, revise FSAR Table 1.8-1 to identify the differences between MP3 DG fuel oil 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 klentifled by NU? O Yes te) No Non D6screpent Condition?O vos (9) No Resolution Pending?O ve. @ No Reso!Jion Unresolved 70 vos @ No Review Acceptable Not Ar' afd*Ma Needed Date W S R.

VT Lead: Bees, Ken VT Mgr: Schopfer. Don K IRC Chmn: singh, Anend K Date: 5/26/98 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.

S&L has reviewed the FSAR/ Safety Evaluation and the FSAR Change Request describeJ in the response and determined that it addresses all the necessary topics. NU's response to this Discrepancy Report is complete and acceptable.

NU concurred that this is a Level 3 Discrepancy during telephone conference calls. l l

I Printed 5/28/9610:25 40 AM Page 4 of 4

Northeast Utilities ICAVP DR No. DR-MP3-1068 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential OperatWity issue Discipline: Mechan 6 cal Design Om Discrepancy Type: Procedure implementation g System / Process: NEW NRC Significance level: NA Date Faxed to NU:

Date Putsshed: 2/28/98

(

Discrepancy: Incomplete documentation implementing changes to Specification SP-ME-570 Ducription: In the process of reviewing modification DCR M3-97063 and associated DCN-00-1122-97 the following is noted.

l DCN-00-1122-97 states on page 3 under the topic Specification i Changes Required,

" Add snubber mark nos. 3-RSS-4-PSSP459 and 3-RSS PSSP460 to the snubber list, Appendix U of Specification SP-ME-570."

Based on a review of the subject DCN, no change paper incorporating the changes to Appendix U of Specification SP-ME-570 could be identified.

In addition, the subject DCN also identifies the addition of other new pipe supports and the deletion of one support. It is believed these cases should be reflected by changes to the listing of pipe supports contained in Appendix M of Specification SP-ME-570.

The subject DCN does not mention this potential change to the specification or include any change paper to reflect its implementation.

Discrepancy:

DCN DM3-00-1122-97 does not provide change paper to implement the noted changes to specification SP-ME-570 Appendix U and does not identify or implement potential changes to Appendix M of the same specification.

Review Valid invalid Needed Date Instaator: Otton, P.R.

8 O O 2/2o/98 VT Lead: Nei, Anthony A B O O 2/21/96 VT Mgr: schopfer. Don K B O O 2/21rse IRC Chmn: Singh, Anand K B D 0 2 2s/9s Date:

INVALID:

Date: 5/27/98 RESOLLmON Response ID: M3-IRF-02231 Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1068, does not represent a discrepant condition. DCN DM3-00-1122-97 lists SP ME-570 as an affected document to Printed s/28/9610:26:1s AM Page 1 of 2

ICAVP DR No. DR-MP3-1068 Northeast Utilities Millstone Unit 3 Discrepancy Report add the new snubbers. DCN DM3-05-1122-97 (attached) was issued to supplement DM3-00-1122-97 to add all the pertinent information conceming the new snubbers. Additionally, no update to Appendix 'M' of SP-ME 570 is required as no interface seismic supports were affected. This Appendix to the specif; cation is for seismic supports on Class 4 lines which are credited, not to list all seismic supports in general.

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

Attachments:1) DCN DM3-05-1122-97

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0987, does not represent a discrepant condition. The update to Appendix 'U' SP-ME-570 is included in DCN DM3-05-1122-97 and there is no update required to Appendix 'M' of SP-ME-570.

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

Previously identined by NU7 O Yes (#) No Non D6screpant Condition 7(8) Yes O No Resolution Pending70 Yo. (*J No Re.oiution unre.oived70 Yo. (*J No Review initiator: Olson, P.R.

VT Leed: Nerl, Anthony A VT Mgr: schopfer, Don K IRC Chmn: skigh, Anand K Date: 5/27/98 SL Comments: S&L agrees with NU's response that the required update for Appendix U to SP-ME-570 (originally missing in DCN DM3 1122-97) was identified by NU during the modification process and corrected in the subsequent DCN revision, DM3-05-1122-97.

It is noted however, that Rev. 05 of this DCN was not initially provided by NU with the review package for DCR M3-97063.

Also, based on further review, we agree ' hat Appendix M of SP-ME 570 does require an update Editorial correction: The last sentence in the paragraph above is corrected to read as follows, Also, based on further review, we agree that Appendix M of S 2-ME-570 does not require an update.

Printed sr2tW9810:26.16 AM Page 2 of 2

Northeast Utilities ICAVA DR No. DR-MP3-1072 Miiistone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION AOCEPTED Review Element: Corrective Acton Process p

Dieciplins: Mechanical Design Discrepancy Type: CorrectNe Action implementation Om SystenVProcess: SWP NRC Significance level: 4 Date faxed to NU:

Date Putsshed: 3/12/96 Discrepancy: ACR M3-96-0653 Corrective Action inconsistent with Corrective Action Plan Ducription: ACR M3-96-0653 identified the potential for the Chlorine Pit Access Enclosure to flood and submerDe both the SWP Train A and B isolation valves to CW Pump Lube Water

[3SWP*MOV115A/B] without operator knowledge, since the only indication of flooding in the area is via level switch 3SWP-LS153 which is non safety related. The ACR also indicated that the room is only infrequently accessed. The recommended action included placing the area on rounds, performing surveillance on the level switch, and/or upgrading the switch [to safety related).

The possibility was also raised of performing analyses to demonstrate that SWP could function satisfactorily without isolating the lube water to the CW Pumps.

The Corrective Action Plan indicated that " preliminary evaluations have determined that a moderate energy line break of the 30" SWP lines in the access enclosure would flood the isolation valves in less than 30 minutes" and that "if 3SWP*MOV115A/B were disabled due to flooding, sufficient service water flow to vital loads during design basis conditions would still be available."

The Corrective Action Plan called for the following activities as a result:

1. Formally update the service water analysis to demonstrate that sufficient service water is available to vital loads during design basis conditions with flow to the CW pumps not isolated, and

2. Evaluate removing 3SWP*MOV115A/B from " active valve" sistus and the GL 89-10 MOV Program.

Section 7 of the Corrective Action Plan further states:

"The criteria employed by MP3 flood studies is the availability of 30 minutes of operator time, following detection by a safety related instrument, to isolate the leak before affecting safety related equipment. Revising the service water flow analysis to demonstrate isolating service water flow to the cire water pumps during design basis conditions is not required will remove the active safety function of 3SWP*MOV115A/B."

l All of the above are tracked under Tracking Assignmment #

96029368-02.

In lian nf thm rnrradium ndinne timerrihart nhnum a cD chnnna Printed 5/289610:26.31 AM Page"1 or 7 l

Northeast Utilities ICAVP DR N2. DR-MP3-1072 Millstone unit 3 Discrepancy Report Form was initiated. Section 7 of this form, " Justification" states:

"The amount of flow that would be lost if valves 3SWP*MOV115A/B were unable to close due to flooding would be unacceptable. Calculations have shown up to an 11%

decrease in flow to SW heat exchangers would occur. Instead of accepting condition, ensure leve! switch 3SWP-LS153 will operate to prevent flooding condition from occuring prior to a design basis condition."

In tum, a CR Action Closeout Form was completed, indicating that the amount of flow loss would be unacceptable if the MOV115 valves did not isolate when required, and stated that a

" Preventive Maintenance Change Form had been initiated to ensure the level switch 3SWP-LS153 is checked for proper operation on an annual basis."

This action is not adequate from the fchowing perspectives:

1. As stated in the ACR Corrective Action Plan, the MP3 flooding study methodology assumes 30 minutes of operator time, after detection by a safety related instrument, to take action to isolate the break before affecting safety related equipment in this case there is no safety related instrument to provide the notification.

2. Even if the switch were upgraded to safety related, it could not provide adequate waming to the operator based on the NU analysis that the room would flood in less than 30 minutes.

3. Since the l solation valves for both SWP divisions are located in the same room, the potential exists for degrading both divisions due to failure from a single event - the flooding of the room.

4. While it is not included in the scope of the ACR lt is also noted that the two air operated safety related isolation valves

[3SWP*AOV25A/B, one for each division] for isolation of the non safety related chlorination dilution water are also located in the same SW access enclosure and subject to the same flooding conditions as the MOV115A/B valves. [See also DR-MP3-0998.]

5. In addition to the flooding concems, as identified in Items 3 and 4 above, the requirement for physical separation of the two redundant SWP divisions is not satisfied as a result of the two instances of Train A and Train B isolation valves being located in

- the same room - i.e. the SWP access enclosure.

Review Valid invaad Needed Date initiator: Tonwinkel, J. L 8 O O sose VT Lead: Neri, Anthony A O O O 3/4S8 VT Mgr: schopfer, Don K O O O 3'5Se IRC Chmn: singh, Anand K G O O 3'iva8 Date:

INVAUD:

Printed 5/28/9810:26:31 AM PeGe 2 of 7 i

)

i N:rtheast Utilities ICAVP DR N3. DR-MP3-1072 Millstone Unit 3 Discrepancy Report Date: 5/27/98 RESOLUTION: 1st responsC Disposition:

NU has concluded that Discrepancy Report, DR-MP3-1072, has identified a condition not previously discovered by NUwhich requires correction.

The corrective actions associated with ACR M3-96-0653 correctly reported that sufficient service water flow would be available to the RSS heat exchangers following a service water pipe rupture (MELB) in the chlorination pit, with floodg of the pit, and associated failure (open) of the service waa valves 3SWP*MOV115A&B. A CR change form (attached) was subsequently processed that revised the evaluation to indicate that there would not be sufficient service water flow to the RSS heat exchangers (11% deficit) should valves 3SWP*MOV115A&B fail to close.

Both of the evaluations can be torrect, depending on the initiating accident. FSAR section 3.1.1.3," Applications of Single Failure Criteria" clearly states that a LOCA/CDA and a single active failure can be postulated in the near term (<24 hrs.)

However, a LOCA with a single " passive" failure (MELB) ccnnot be postulated until the long term (>24 hrs.). Consequently, it was correct to describe the scenario of a service water MELB (3SWP*MOV115A&B failed open - no LOCA/CDA) with sufficient service water flow (no RSS heat exchanger flow required). It was also correct to postulate a LOCA/CDA with associated closure of 3SWP*MOV115A&B, thereby assuring adequate service water flow to the RSS heat exchangers (no SWP MELB).

As depicted in the DR scenario, a service water MELB, with concurrent failure (open) of valves 3SWP*MOV115A&B does not prevent the service wa9r system from delivering design flow to the service water components. A LOCA/CDA, coincident with service water MELB, is not c *near term" design basis accident per FSAR Single Failure Criteria described in section 3.1.1.3.

Service water calculation 97-41, accident scenario 2, (attached) provides the basis for 3SWP*MOV115A&B failure (open) with subsequent CWP line break.

Because flooding calculation,12179-P(N-1072R does not specifically address the MOVs and flooding in the service water chlorination pit, enhancements will be made to the calculation.

The flooding concems needs to be updated to document the acceptability of the 3SWP*MOV115A&B valves remaining open during a service water MELB in the chlorination access pit enclosure. These are the corrective actions of CR M3-98-1253 and will be completed after re-start. Since these changes do not effect the ability of the system to fulfillits safety function, NU does not consider this to be a level 3 discrepant condition.

Therefore, NU recommends downgrading this DR to a level 4 discrepant condition based on the lack of a supporting evaluation Prtnted 5/2&9610:20:32 AM Page 3 or 7

ICAVP DR N2. DR-MP3-1072 Northeast Utilities Millstone Unit 3 Discrepancy Report in the current Flooding Hazard Analysis.

The DR con an surrounding the flooding time versus the j operator response time becomes irrelevant when isolation of valves 3SWP MOV115A and B are no longer necessary. The chlorination pit level switch,3SWP-LS153 will continue to be maintained in good working order by way of the previous corrective actions of ACR M3-96-0653 which provides an annual preventive maintenance activity. The function of the level switch w;ll serve as an indication of a flooding event. As described above, timely operator actions are not critical during the mitigation of a design basis accident. The level switch will remain as a non-safety related component since immediate operator actions are not required to mitigate a DBA in order to maintain design consistency with the rest of the plant.

The affect of flooding on the two air operated isolation valves, 3SWP*AOV25A/B is not a concem since these valves fall closed (reference DR# M3-DRT-0998 (M3-IRF-01725)). The double valves provide positive isolation between one train of the service water system and the non-safety relN chlorination system.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-1072, has identified a condition not previously discovered by NUwhich requires correction.

Based on the scenario of an assumed service water moderate energy crack, a concurrent CDA is not required to be postulated.

Therefore the RSS heat exchangers will present no load upon the system since no CDA would occur. With the 3SWP*MOV115A&B valves unisolated, adequate flow will still be maintained to the safety related heat exchangers.

The approved corrective action plan for CR M3-98-1253 will ensure the following:

1. Update the flooding calculation 12179-P(R)-1072R to indicate why flooding in the service water chlorine pit is not of any consequence to the service water system. This action is being tracked under A/R 98004879-04 and is scheduled to be completed following re-start.

2. Develop a formal design input regarding the acceptability of l 3SWP*MOV115A&B remaining open during a service water MELB in the service water chlorine pit. This action is being tracked under A/R 98004879-01 and is scheduled to be l completed following re-start.

l Since this DR requires multiple failures for the concems to be valid, veisus the single failure criteria in the determination of credible events as stipulated in the Millstone Licensing basis, NU does not consider the effects of a flooding event to be a discrepant condition. NU does consider the lack of a supporting evaluation within the Floodina Hazard Analysis to be a Prtneed 5/26S810:26:32 AM Page 4 or 7

1 ICAVP DR Ns. DR-MP3-1072 l Northeast Utilities :

Millstone Unit 3 Discrepancy Report l 1

discrepant condition. Since these changes do not effect the ability of the system to fulfill its safety function, NU does not consider this to be a level 3 discrepant condition. Therefore, NU recommends downgrading this DR to a level 4 discrepant condition. The approved corrective action plan will revise the Flooding Hazard Analysis post startup.

2nd response:

As a result of telecons with S&L, NU pmvided the following revised response:

Disposition:

NU has concluded that the issues reported in DR-MP3-1072, have identif;ed a CONFIRMED SIGNIFICANCE LEVEL 4 CONDITION.

ACR M3-96-0653 makes some incorrect statements conceming the design basis of Millstone 3 systems used for evaluating the effects of postulated line breaks in non safety related systems.

The response to this DR is being revised to acknowledge that although the results of the corrective action plan to ACR M3 0653 will be unchanged, some of the statements conceming the design basis for postulating rnoderate energy cracks and breaks are incorrect.

To demonstrate that high energy and moderate energy systems are in compliance with GDC 4, a review is performed to the criteria specified in NRC BTP's ASB 3-1 and MEB 3-1. These BTP's provide guidelines for postulating piping failures. These failures are considered to be initiating events during normal plant operation and are not assumed to occur concurrently with a design basis accident. In accordance with ASB 3-1, a single active failure as well as Nures which are direct consequences of the initiating event are also to be assumed. As a result of this postulated failure, direct consequences and single failure, the functional capability of essential systems and components should be maintained in cases where operator action is required to mitigate the consequences of the postulated line break in order to protect the capability of safe plant shutdowr., an appropriate operator response time is assumed, and CAT I detection is required.

As stated in FSAR Section 31.1.3, systems required to mitigate the consequences of Chapter 15 accidents are designed to tolerate a single active failure in addition to the incident which requires their function. The infrequent incident or limiting fault identified here is NOT considered concurrently with the postulated piping failures described above which demonstrate plant conformance to GDC 4.

ACR M3-96-0653 This ACR was written to identify that if there was a postulated j pipe rupture in the intake Structure Access Enclosure the seal

! water supply valves to the circulating water pumps.

I Printed 5/28S610:26:32 AM Page 517

Northeast Utilities ICAVP DR Ns. DR-MP3-1072 Millstone Unit 3 Discrepancy Report 3SWP*MOV115A&B could become submerged without operator knowledge since flood detection is only provided with a non QA level switch. The ACR further concludes that this could result in a failure in both trains of the service water system. Section 7 of the ACR corrective action plan states that ..."The criteria employed by MP3 ficod studies is the availability of 30 minutes of operator time, following flood detection by a safety related instrument, to isolate the leak before affecting safety related equipment." For appncation to the piping arrangement which is the subject of the ACR, this statement is not applicable. A postulated failure of any line within the access enclosure could ficod the entire room and cause the valves 3SWP*MOV115A&B to fail such that they remain open. This is postulated under the stipulations of ASB 3-1 and MEB 3-1. In accordance with these BTP's, the plant is assumed to be in a normal operational mode.

For this case , service water system calculations confirm that adequate service water flow will continue to the system components. Inoperability of these valves will also not prevent normal, safe shutdown of the plant. It is for these reasons that no operator action is required within a specified time period to terminate the flood. If allowed to 90 undetected, the flood will not disallow a normal safe plant shutdown. Based upon this, a nonsafety related level switch for flood detection is acceptable.

This " hazards" review of the system does not require the assumption of a design basis accident. Therefore the safety related functions of the service water system are unaffected by this postulated piping failure and resulting flood. The valves are designed to close in the event of a DBA in order to provide isolation of the non safety portion of the service water system. A MELB in the non safety portion of the SWP system is not required to be postulated concurrently with the DBA event.

CR M3-98-1253 was previously Generated to update the flooding analysis as documented in MS-IRF-01941. CR M3-98-2628 has been generated to document the fact that there is incorrect information in CR M3-96-0653. This CR was generated for trending and documentation purposes only. No additional corrective actions will be taken for this historical condition. The incorrect information in ACR M3-96-0653 is the discrepant condition identified.

Conclusion:

NU has concluded that the issues reported in DR-MP3-1072, have identified a CONFIRMED SIGNIFICANCE LEVEL 4 l CONDITION.

A postulated failure of any line within the racess enclosure could flood the entire room and cause the valves 3SWP*MOV115A&B to fail such that they remain open. This is postulated under the stipulations of ASB 3-1 and MEB 3-1. In accordance with these BTP's, the plant is assumed to be in a normal l operational mode. For this case , service water system

! calculations confinn that adequate service water flow will l continue to the system components. Inoperability of these Pnnled 5f28/9610:26:32 AM Page 6 or 7

~

Northeast Utilities ICAVP DR N . DR-MP3-1072 Millstone unit 3 Discrepancy Report valves will also not prevent normal, safe shutdowr> of the plant.

It is for these reasons that no operator action is required within a specified time period to terminate the flood. If allowed to go undetected, the flood will not disallow a normal safe plant shutdown. Based upon this, a nonsafety related level switch for flood detection is acceptable.

The " hazards" review of the system does not require the assumption of a design basis accident. Therefore the safety related functions of the service water system are unaffected by this postulated piping failure and resulting flood. The valves are designed to close in the event of a DBA in order to provide isolation of the non safety portion of the service water system. A MELB in the non safety portion of the SWP system is not required to be postulated concurrently with the DBA event.

CR M3-98-1253 was previously generated to update the flooding analysis as documented in M3-IRF-01941. CR M3-98-2628 has been generated to document the fact that there is incorrect information in CR M3-96-0653. This CR was generated for trending and documentation purposes only. No additional corrective actions will be taken for this historical condition. The incorrect information in ACR M3-96-0653 is the discrepant condition identified.

Previously identifled by NU7 O Yes (G) No Non D6screpent Condition?O Yes (8) No Resolution Pend 6ng?O ve. (*) No Resolution Unresolved?O ve. O No Review initiator: Tenwinkel. J. L VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K Date: 5/27/98 sL comments: Based on the revised response provided by NU after discussions via telecon, S&L is in agreement with NUs response and that this item be downgraded from Level 3 to Level 4.

l l Printed 5/26/9810-26:33 AM Page 7 of 7 l

l 4

DR N3. DR-MP3-1074 Northeast Utilities ICAVP Milistone unit 3 Discrepancy Report Review Group: Operatens & Meirtenance and Testing DR RESOLUTION ACCEPTED Review Element: Corrective Action Process Discipl6ne Other Discrepancy Type: Corrective Action trnplernentaten g SysterrWProcess: sWP NRC Significance level: 4 Date faxed to NU:

Date Putdiohed: 3/598 Discrepancy: Inadequate implementation cf Service Water System testing corrective action.

Description:

Item 2 of Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment, requires that a test program be conducted to verify the heat transfer capability of all safety-related heat exchanges cooled by service water.

The Generic Letter states that the initial frequency of testing should be at least once each fuel cycle, but after three tests the best frequency for testing should be determined to provide assurance that the equipment will perform the intended safety func' ions.

Unresolved issue Report (UIR) # 515, GL 89-13 Heat Exchanger Testing documents that heat exchanger testing was not being accomplished as required by the Generic Letter. The corrective action for this UIR includes developing a " position on heat exchanger testing schedule."

A review c(the UIR corrective action implementation determined that the heat exchanger testing program is inadequate and does not meet the intent of Generic Letter 89-13. The testing schedule does not include all safety related heat exchangers cooled by service water. The action tracking items do not assure that each safety related service water heat exchanger will be tested at least once each fuel cycle for the next three cycles.

Peview Valid invalid Needed Date initiator: spear, R. S 0 0 2r2stoe VT Lead: Bass, Ken 0 0 0 2*S8 VT Mgr: schopfer, Don K O O O ar2 roe IRC Chrnn: singh, Anand K G O O ar2ree Date:

INVALID:

Date: 5/27/98 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR #515 corrective action (AR96008622-

01) required the development of a firm and accelerated schedule for completing the Generic Letter 89-13 service water system heat exchanger tests and evaluations of the test data. Both '

AR96008622-01 and AR97000669-02 tracked the development of the MP3 Service Water Heat Exchanger Performance Monitoring Program which formalize the commitment to Generic Letter 89-13 requirements and to provide the programmatic .

Printed 5/28/9e 10:27:35 AM Page 1 of 5 l

Northeast Utilities ICAVP DR N3. DR-MP3-1074 Millstone Unit 3 Discrepancy Report means to schedule the testing of heat exchangers and to evaluate the test results. The discrepant Final Disposition of UlR l

515 will be corrected after startup by the approved corrective action plan for CR M3-98-1279 to reference the performance monitoring program which provides the requested heat exchanger testing schedule and commitment to GL 89-13.The Significance Level is concluded to be Level 4 since there is no impact on MP3 DB or LB or plant equipment.

Conclusion:

NU has concluded that Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR 515 Closure Request Final Disposition will be corrected after startup by the approved corrective action plan of CR M3-98-1279 to reference the MP3 GL 89-13 Service Water System Heat Exchanger Performance Monitoring Program which implements the requirements of Generic Letter 89-13 and provides testing schedules. The Significance Levelis concluded to be Level 4 since there is no impact on MP3 LB or DB or plant equipment.

Revised response received 4/23/98:

Disposition:

NU has concluded that the new issue reported in Revised Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. The heat exchanger testing fiequency stated in the conclusion to UIR 515 deviates from the testing requirements contained in Generic Letter 89-13.13 are included in the licensing bases. This Discrepancy Report and NU's conclusion establish that the Heat Exchanger Testing program is not being accomplished as required by the Generic Letter and therefore does not meet the licensing bases. The criteria for determining the relative discrepancy significance level establishes that if a discrepancy -

does not meet its licensing and design bases but the system is capable of performing its intended function, it is a level 3 discrepancy. After discussion and agreement with the NRC Inspection Team, clarification of the responses to Generic Letter 89-13 is required prior to start-up. AR 97030287-08 requires preparation of a NRC submittal formally proposing the change in heat exchanger testing frequency from the requirements of Generic Letter 89-13.

The submittal is to be made prior to start-up. The proposed testing frequency is consistent with the Generic Letter 89-13 recommendations for initial test frequencies. The retest and cleaning schedules will be based upon the initial testing results.

The maximum period between tests is five years once a retest frequency is established. In addition the conclusion of UIR 515 will be revised accordingly after startup by the approved corrective action plan for CR M3-98-1279. Testing of individual groupings of MP3 SW heat exchangers in the program will be tracked by the following AR's:

97019658 3EGS*E1 A/E2A 97019660 3EGS*E1B/E2B Printed 5/28S31027.35 AM Pa0e 2 of 5 I

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Northeast Utilities ICAVP DR No. DR-MP3-1074 Millstone Unit 3 Discrepancy Report Discrepancy Report DR-MP3-1074 has identified a condition not previously discovered by NU which requires correction. UIR 515 l Closure Request will be revised as required by the approved corrective action plan for CR M3-98-1279 after startup to reference the MP3 GL 89-13 service Water System Heat Exchanger Performance Monitoring Program testing requirements for the SW heat exchangers. The change in testing requirements will be contained in a submittal to the NRC which will made prior to startup. The Significance Level for DR-MP3-1074 is concluded to be Level 4 since LB and DB are met.

l Previously identif6ed by NU? O Yes (G) No Non Discrepent condit6on?Q Yes @ No Resolutkm Pending?O yes @ No Reeoeunionunresoeved?O vee @ No Review Acceptable Not V' Needed Deie initiator: speer, R.

VT Lead: Biss, Ken O O O se27/ss VT Mgr: schopfer, Don K B O O sr27/9e IRC Chmn: singh, Anand K B O O st27ise O O O Date: 5/26/98 sL comments: S&L concurs with NU's resolution and conclusion for Discrepancy Report DR-MP3-1074 but does not concur that the Significance Level is Level 4 as proposed by NU. The requirements of Generic Letter (GL) 89-13 are included in the licensing bases. This Discrepancy Report and NU's conclusion establish that the Heat Exchanger Testing program is not being accomplished as required by the Generic Letter and therefore does not meet the licensing bases. The criteria for determining the relative discrepancy significance level establishes that if a discrepancy does not meet its licensing and design bases but the system is capabie of performing its intended function, it is a level 3 discrepancy.

Additional S&L Comments:

NU has not provide enough additional information to resolve this issue. S&L has determined that the intent of GL 89-13 is that all safety related heat exchangers be tested on a regular basis.

Section two of GL 89-13 states that initial testing frequency should be at least once per cycle, but after 3 tests the frequency my be adjusted. This listing of SW heat exchangers included in the latest response does not include the Containment Recirculation Coolers (3RSS*E1A-D). GL 89-13 does not provide for excluding safety related heat exchangers when an adequate heat load can not be applied to the heat exchanger. As stated previously, implementation of GL 89-13 is a licensing basis issue and as such this is a Level 3 Discrepancy.

Further S&L Comments S&L concurs that the additional information provided by NU is adequate to resolve this issue. The additional information provided in NU's May 6 letter to the US Nuclear Regulatory Commission (NRC), Letter No. B17205 provided adequate information such that S&L concludes that NU's response is Printed s/28/9810:27:35 AM Pope 4 of 5

ICAVP DR N2. DR-MP31074 Northeast Utilities Millstone Unit 3 Discrepancy Report j acceptable. This letter clarifies NU's commitment to develop a i program for testing Millstone Unit No. 3 Service Water Heat I exchangers ad defined in GL 89-13. This program consists of baseline testing, a periodic retest program and additional actions to assess heat exchanger performance. This additional information combined with S&L's review of the inspection procedures provided enough information for S&L to concur with NU's response and the corrective actions described in the referenced documents.

S&L concurs with downgrading this u. crepancy to a Level 4 discrepancy based on the additionst documentation provided and the telephone conferences.

S&L understands that NU has agreed to further revise the Basis document of EN 31084 to state the inspection of the Containment Recirculation Heat Exchangers described in EN 31084 provides the compliance with GL 89-13.

Printed Sr289610:27:36 AM Page 5 of 5 R

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. ICAVP DR No. DR-MP3-1099 Northeast Utilities Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design g Discrepancy Type: Calculation O No system / Process: DGX NRC Significance level: 4 Date faxed to NU:

Date Published: N2N96 D6screpancy: Diesel generator seismic qualification report does not address all components supplied.

DescripHon: The following equipment was supplied under Spec. No. 2447.300-241. The seismic qualification report for the equipment supplied under this specification does not include any documentation of the adequacy of these items.

(1) 3EGS*H2A/B Generator Space Heater The seismic qualification report for this space heater was ,

requested on M3-RF1-855 and M3-RF1-873. The response (

provided on M3-IRF-02117 states that these heaters are an integral part of thu generator stator, that there is no specific qualification for the heaters and that this equipment is seismically insensitive. The section of the Colt Industries report for the diesel generator skid pertaining to the generator was i

forwarded as part of the response. This report does address the generator stator; however, no justification is provided for the qualification of the space heater. j (2) 3EGD*EJ1 A/B/C/D and 3EGD*EJ2A/B/C/D Exhaust and Air Supply Nozzle Expansion Joints The qualification report for these expansion joints was requested )

on M3-RF1-855 and M3-RFi-873. The response provided on M3-IP.F-02117 states that these bellows expansion joints are part of the diesel generator qualification. However, these expansion joints are not mentioned in the qualification report for the diesel generator *..

(3) 3 ENS *RES-GNA/B Neutral Ground Resistor The seismic qualification report and equipment mounting calculation for this component was requested on M3-RFl-858 and M3-RFI 873. The response provided on M3-lRF-02117 states that this item is qualified by Colt, the diesel generator supplier. However; the Colt qualification report does not address this component. Also, no calculation is available for the mounting of this component to floor.

Review Valid invaild Needed Date O * *S8 inineior: aonn.on a.y G O VT Lead: Neri, Anthony A g O g N15S8 O *18/S8 VT Mgt: schopfer, Don K G O 1RC Chmn: singh. Anand K B O O *'7/98 Date:

AMLF.it in.

Printed 5/28/9610:43.48 AM ' ' ~ Page 1 of 3

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ICAVP DR No. DR-MP31099 Northeast Utilitieo Miliston Unit 3 Discrepancy Report Date: 5/27/98 RESOI.UTION: Disposition:

NU has concluded that Discrepancy Report, DR-MP3-1099, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-2126 will improve the seismic qualification documentation for 3EGS*H2A/B,3EGD*EJ1 A/1B/1D/2A/28/2D, and 3 ENS *RES-GNA/B. The improved documentation will provide more specific details of the basis for seismic qualification of these componenta.

Seismic qualification evidence exists for each of the three components, however, the evidence for these three componentr.

is somewhat less detailed than that for other components. The Colt industries seismic qualification report package (#206072) provides varying details of seismic qualification documentation.

The cover page states that items for which no specific seismic analysis or test are shown are those items which, in normal operation, are subjected to forces and loads much greater than those imposed by a seismic disturbance and which, experience has shown, have substantial margin of safety."

3EGS*H2A/B relies on the general qualification for the stator contained in the Colt Industries seismic qw!ification report package (#206072). This component is a space heater mounted integrally inside the stator. The expansion joints, i I

3EGD*EJ1 A/1B/1D/2A/28/2D rely on the Colt's general qualification for skid mounted piping as supplemented by SWEC piping analysis. 3 ENS *RES-GNA/B relies on General Electric )

qualification report 73LSP-1 which was not immediately i retrievable in a search of plant records. This equipment was among the eariiest purchases during the original design (~1977),

and the apparent cause is the difference in viewpoint of an acceptable level of documentation between current practice and that held twenty years ago, items 1 and 2 of DR-MP3-1099 were not provided with specific component seismic qualification documentation at the time of )

purchase. Since they had been designed for more severe {

conditions, it was not considered necessary to provide detailed component specific seismic qualification documentation item 3 was provided with seismic qualification by General Electric, the supplier of the neutral ground resistor to Colt. This qualification could not be located in the course of a preliminary search. CR M3-98-2126 has been written, and its corrective action plan will provide the missing documentation fo' lowing Unit 3 restart. NU concludes that the diesel generator is seismically qualified , and that it continues to meet its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-1099, has Prtnted 5r28/9610:43 48 AM Page 2 of 3

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ICAVP DR N3. DR-MP3-1099 Northert Utilities Millstone Unit 3 Discrepancy Report identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-2126 will improve the seismic qualification docu,centation for the components in question. These actions will be completed fellowing restart of Unit 3. In the case of items 1 and 2 no detailed component specific seismic qualification was provided because Colt generally qualified these cornponents based on the operating forces exceeding the expected seismic forces. NU will improve documentation by providing more specific details for the basis for seismic qualification of these components. For item 3, the seismic qualification was not provided by Colt, but was instead supplied by General Electric. This documentation has not been located yet. As part of the corrective action plan, the necessary documentation will be located or regenerated, post restart, to satisfy the requirement. The improved documentation will provide more specific details of the basis for seismic qualification of these components. NU concludes that the diesel generator is seismically qualified, and that it continues to meet its design basis. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.

Prev 6ously idenuned by NU? O Yes @ No Non D6screpent Condition?O Yes @ No Resolution Pending?O ve. @ No Re.oiuiioa unre.olved70 ve. @) No Rev6ew Initiator: Johnson, Jay VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Clwnn: singh, Anand K Date:

SL Comments:

Printed Sr28/9810:43-48 AM Page 3 of 3

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