ML20237A636

Summary of 980612 Meeting W/Nneco & Parsons Power Group,Inc (Parsons) Re Issues Identified in Unit 2 Independent Corrective Action Verification Program (ICAVP) Discrepancy Rept 0364 (DR-0364).W/attendance List & Handout

ML20237A636
Person / Time
Site:	Millstone
Issue date:	07/14/1998
From:	John Nakoski NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9808140228
Download: ML20237A636 (63)

Text

I im July 14, 1998

',.l W.e *'

A0 LICENSEE:

North 2ast Nucl:ar Energy Company (NNECO)

FACILITY:

Millstone Nuclear Power Station, Unit 2

SUBJECT:

JUNE 12,1998, MEETING REGARDING SETPOINT DISCREPANCIES

~

4 l

DESCRIBED IN A MILLSTONE UNIT 2 INDEPENDENT CORRECTIVE ACTION l

VERIFICATION PROGRAM DISCREPANCY REPORT (DR-0364) 1 On June 12,1998, the staff of the Special Projects Office (SPO) of the Office of Nuclear Reactor Regulation met with representatives of Northeast Nuclear Energy Company (NNECO) and Parsons Power Group, Inc. (Parsons) to discuss issues identified in the Unit 2 Independent Corrective Action Verification Program (ICAVP) discrepancy report number 0364 (DRiO364).

)

Issues identified in DR-0364 related to discrepancies in the setpoint and loop uncertainty

{

analyses for the high pressure safety injection system. Parsons had identified over 200 issues 1

l it classified as discrepant in 13 broad categories.

NNECO provided a description of the activities it had in progress before DR-0364 was issued by Parsons related to setpoint and uncertainty analyses. NNECO indicated that it stopped its efforts to address concems with setpoints to assess the issues identified in DR-0364, and indicated that it would reinitiate the corrective actions taking into consideration the issues identified in DR-0364.

Based on the discussions during the meeting, the SPO staff indicated to both Parsons and NNECO that before proceeding down any specific path to tasolve the issues identified in DR-0364, a clearer understanding of the licensing bases for Unit 2 regarding setpoint methodology and practices was necessary. provides a list of meeting attendees. Enclosure 2 provides the handout used by NNECO during the meeting. Enclosure 3 provides gg OfbOSBW c-9 John A. Nakoski, ICAVP Program coordinator)

ICAVP Oversight Branch 5 g j

Special Projects Office 8 L

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Office of Nuc! ear Reactor Regulatid5 W

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Docket No. 50-336 E h W C i

Enclosures:

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July 14,'1998

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LICENSEE:

Northeast Nuclear Energy Company (NNECO)

FACILITV; Millstone Nuclear Power Station, Unit 2 S,UBJECT:

JUNE 12,1998, MEETING REGARDING SETPOINT DISCREPANCIES DESCRIBED IN A ff,lLLSTONE UNIT 2 INDEPENDENT CORRECTIVE ACTION j

VERIFICATION PROGRAM DISCREPANCY REPORT (DR-0364)

On June 12,1998, the staff of the Special Projects Office (SPO) of the Office of Nuclear Reactor Regulation met with representatives of Northeast Nuclear Energy Company (NNECO)

I and Parsons Power Group, Inc. (Parsons) to discuss issues identified in the Unit 2 Independent

(

Corrective Action Verification Program (ICAVP) discrepancy report number 0364 (DR-0364).

j issues identified in DR-0364 related to discrepancies in the setpoint and loop uncertainty analyses for the high pressure safety injection system. Parsons had identified over 200 issues it classified as discrepant in 13 broad categories.

NNECO provided a description of the activities it had in progress before DR-0364 was issued by Parsons related to setpoint and uncertainty analyses. NNECO indicated that it stopped its efforts to address concerns with setpoints to assess the issues identified in DR-0364, and I

indicated that it would reinitiate the corrective actions taking into consideration the issues identified in DR-0364.

I I

Based on the discussions during the meeting, the SPO staff indicated to both Parsons and NNECO that before proceeding down any specific path to resolve the issues identified in DR-0364, a clearer understanding of the licensing bases for Unit 2 regarding setpoint methodology and practices was necessary.

I provides a list of meeting attendees. Enclosure 2 provides the handout used by NNECO during the meeting. Enclosure 3 provides a copy of DR-0364.

c.)

hn A. Nakoski, ICAVP Program Coordinator

[Special Projects Office l

AVP Oversight Branch Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosures:

As stated (3) 1 cc w/encis: See next page

Millstone Nuclear Power Station Unit 2 cc:

Lillian M. Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Work Services Northeast Utilities Service Company Northe9st Utilities Service Company P. O. Box 270 P. O. Box 128 Hartford, CT 06141-0270 Waterford, CT 06385 i

Mr. John Buckingham -

Ernest C. Hadley, Esquire' Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 New Britain, CT 06051 Mr. John F. Streeter Mr. Kevin T. A. McCarthy, Director Recovery Officer - Nuclear Oversight Monitoring and Radiation Division Northeast Utilities Service Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 Mr. David B. Amerine Regional Administrator, Region i Vice Prasident - Human Services U.S. Nuclear Regulatory Commission Northeast Utilities Service Company 475 Allendale Road P. O. Box 128 King of Prussia, PA 19406 Waterford, CT 06385 First Selectmen Mr. Allan Johanson, Assistant Director Town of Waterford Office of Policy and Management Hall of Records Policy Development and Planning 200 Boston Post Road Division Waterford, CT 06385 450 Capitol Avenue - MS# 52ERN P. O. Box 341441 Mr. Wayne D. Lanning Hartford, CT 06134-1441 Deputy Director of Inspections Special Projects Office Mr. M. H. Brothers 475 Allendale Road Vice President - Operations King of Prussia, PA 19406-1415 Northeast Nuclear Energy Company P.O. Box 128 Charles Brinkman, Manager Waterford, CT 06385 Washington Nuclear Operations ABB Combustion Engineering Mr. J. A. Price 12300 Twinbrook Pkwy, Suite 330 Director - Unit 2

.Rockville, MD 20852 Northeast Nuclear Energy Company P.O. Box 128 Senior Resident inspector Waterford, CT 06385 Millstone Nuclear Power Station c/o U.S. Nuclear Regulatory Commission

.P.O. Box 513 Niantic, CT 06357 l

Millstone Nuclear Power Station '

Unit 2 cc:

Mr. B. D. Kenyon (Acting)

Attorney Nicholas J. Scobbo, Jr.

Chief Nucler Officer-Millstone Ferriter, Scobbo, Caruso, Rodophele, PC Northeast Nuclear Energy Company 1 Beacon Street,11th Floor P.O. Box 128 Boston, MA 02108 Waterford, CT 06385 Mr. J. P. McElwain Citizens Regulatory Commission Recovery Officer-Millstone Unit 2 ATTN: Ms. Susan Perry Luxton Northeast Nuclear Energy Company 180 Great Neck Road P. O. Box 128 Waterford, CT 06385 Waterford, Connecticut 06385 Deborah Katz, President Mr. M. L. Bowling Citizens Awareness Network Recovery Officer - Technical Services P. O. Box 83 Northeast Nuclear Energy Company Shelburne Falls, MA 03170 P. O. Box 128 Waterford, CT 06385 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building Capitol Avenue Hartford, CT 06106 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone - ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 Mr. Daniel L. Curry

~

Project Director Parsons Power Group Inc.

2675 Morgantown Road Reading, PA 19607 l

Mr. Don Schopfer l

Verification Team Manager l

Sargent & Lundy 55 E. Monroe Street l

Chicago,IL 60603

LIST OF ATTENDE5S Millstone Unit 2 -lCAVP Status June 12,1998 - 10:40 a.m.

NAME ORGANIZATION POSITION Eugene Imbro NRC Deputy Director, ICAVP Oversight, SPO, NRR Ralph Architzel NRC Millstone Unit 2 Team Leader, SPO, NRR John Nakoski NRC ICAVP Program Coordinator, SPO, NRR Rich V.cintyre NRC Lead Inspector, Millstone Unit 2 Dan Curry Parsons Project Director Eric Blocher Parsons Deputry Director Rich Glaviano Parsons Tier 2 Lead John Hilbish Parsons Regulatory Lead Ron Smith Parsons Tier i Lead (Acting)

Kenneth Mayers Parsons Tier 1 I&C Setpoints Raymond Necci NU Director, Configuration Management Plan Steve Brinkman NU Director-Unit 2 Engineering Joe Fougere NU Manager, ICAVP Michael Ahern NU Unit 2 Design Engineen.

• inager Ravi Joshi NU Regulatory Compliance Manager

- C. F. Cristallo Jr.

NU I&C Engineer, Unit 2 Design Engineering Kenneth W. Fox

.NU l&C Engineer, Unit 2 Design Engineering Greg Tardif hiU Unit 2 ICAVP Kenneth Hogeland NU Senior Engineer - Nuclear Oversight Kelly Gilligan NU Nuclear Communications l

Paul Collette ABB-CE Manager, l&C Howard Shamro ABB-CE Engineering, I&C George Berntsen ABB-CE Engineering, l&C Tom Quigley Hurst Consulting, Inc.

Unit 2 Design Engineering Craig White SWEC ICAVP Support John Markowicz NEAC Vice Chairman Josepth H. Besade CRC Member of the public

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PARSONS POWER GROUP INC.

2675 Morgantow n Road. Reading. PA 19607 ICAVP MILLSTONE UNIT 2

("""~2"""*"""~'"

DISCREPANCY REPORT DR NUMBER: DR-0364 DR TITLE: Discrepancies in Setpoint and Loop Uncertainty Analyses for HPSI REVISION: 0 ISSUE DATE: 02/20/98 ORIGINATING GROUP: Tier 1 SIGNIFICANCE LEVEL: 3 DISCREPANCY L

REFERENCES:

i A. CALCULATIONS 1.

92-030-1259E2 Rev. O, CN-1 " Millstone 2 - Refueling Water Storage Tank Level Setpoint f-Analysis" 2.

92-030-1260E2 Rev. O, CN-1 " Millstone 2 - Pressurizer Pressure Setpoint Analysis" l

3.

92-030-1269E2 Rev. O,

" Millstone 2 - Containment Pressure Setpoint Analysis" 4.

93-039-1132E2, Rev. O, CN-1 " Millstone 2 - Pressurizer Pressure Transmitters Dria Analysis" l

5.

93-039-1147E2, Rev. O,

" Millstone 2 - Foxboro Spec 200 Modules Dria Analysis" i

6.

93-039-1148E2, Rev. O,

" Millstone 2 - Containment Pressure Transmitters Drift Analysis" 7,

93-039-1149E2, Rev. O,

" Millstone 2 - Refucling Water Storage Tank Level Transmitters Dria Analysis" 8.

93-039-1165E2 Rev. O,

" Millstone 2 - Containment Pressure Wide Range Drin Analysis" 9.

93-039-1214E2, Rev. O,

" Millstone 2 - Control Room Indicators & Recorder Dria Analysis"

10. 93-039-1239E2, Rev. O,

" Millstone 2 - Dixson Indicator Model B 101 Dria Analysis" I1. PA 78-771-418GE Rev. O,

' Millstone 2 - Containment Pressure Wide Range PAM Indication" l

12. PA 78-771-424GE Rev. O, "Mi'htone 2 - Pressurizer Pressure ESAS Input" l

13. PA 78-771-426GE Rev. O,

" Millstone 2 - Containment Pressure Control Room Indication" l

14. PA 78-771-435GE Rev. O,

" Millstone 2 - Containment Pressure ESAS Input"

15. PA 78-771-436GE Rev. O,

" Millstone 2 - Containment Pressure Control Room Recorder"

16. PA 78-771-439GE Rev. O,

" Millstone 2 - Pressurizer Pressure Control Room Indication"

17. PA XX-XXX-0573GE Rev.1, CN-1 " Millstone 2 - Pressurizer Pressure Loop Accuracy Calculation"

18. PA XX-XXX-0965GE Rev.1, " Millstone 2 - Conbtinment Pressure Loop Accuracy Calculation"

19. PA XX-XXX-1006GE Rev. O, " Millstone 2 - HPSI Flow Loop Accuracy Calculation"

20. PA XX-XXX-1042GE Rev.1&2, " Millstone 2 - Refueling Water Storage Tank Level Loop Accuracy Calculation"

21. PA XX-XXX-1128GE Rev. O. " Millstone 2 - HPSI Discharge Pressure Loop Accuracy Calculation" 7

l DR o364. DOC f

Page 1 of 41 D elosure 3

l uvubxuwltw;mc1y

22. 2-ENG-031 Rev. O,

" Millstone 2 - Lo-Lo Level Alarm and SRAS Actuation Setpoint for RWST"

23. S 01357-S2 Rev. O,

" Millstone 2 - Minimum Time to Sump Recirculation Actuation i

Signal"

)

)

24. ID20-2 Rev. O,

" Millstone 2 - RWST SRAS Actuation"

)

25. TSCR-2-32-77-45GM Rev. O,

" Millstone 2 - RWST Volume" j

26. 92-030-1254E2 Rev. O,

" Millstone 2 - Steam Generator Level Setpoint Analysis" l

27. PA XX-XXX-0963 Rev.1,

" Millstone 2 - Steam Generator Level Loop Accuracy Calculation"

28. 93-039-1135E2 Rev. O,

" Millstone 2 - Steam Generator Level Drift Analysis"

29. 93-039-1249E2 Rev.1, CN-1 " Millstone 2 - Steam Generator Level Calibration Calculation"

)

l

30. 90-032-0436E2 Rev. O,

" Millstone 2 - Condensate Storage Tank Level Setpoint Analysis"

] 31. 90-032-0293E2 Rev.1,

" Millstone 2 - Condensate Storade Tank Level Loop Accuracy Calculation" I

32. 006-AS91-C-003 Rev. 00, "MP 2 Replacement Steam Generator Project: One to One l

Comparison of Original SG & Replacement SG for a MSLB l

Containment Response Analysis (ABB)"

33. E-5272-595-006 Rev.1,

" Millstone 2 - Cycle-10 Loss of Feedwater Analysis" B. INDUSTRY STANDARDS

1. IEEE 279-1971 Criteria for Protection Systems for Nuclear Power Generating Stations

2. IEEE 344-1975 Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations

3. GDC Criterion 13 AEC General Design Criteria for Nuclear Power Plants - Criterion 13

-Instmmentation and Control

4. GDC Criterion 20 AEC General Design Criteria for Nuclear Power Plants - Criterion 20

- Protection System Functions

5. GDC Criterion 21 AEC General Design Criteria for Nuclear Power Plants - Criterion 21

- Protection System Reliability and Testability

6. GDC Criterion 22 AEC General Design Criteria for Nuclear Power Plants - Criterion 22

-Protection System Independence

7. GDC Criterion 29 AEC General Design Criteria for Nuclear Power Plants - Criterion 21

- Protection Against Anticipated Operational Occurrences

8. IEEE 344-1971 Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations

9. AShE XI ASME Boiler and Pressure Vessel Code

10. IE Bulletin 79-1.

NRC Bulletin

11. INPO SER 27-93 INPO Significant Event Report (SER)

C. SURVEILI.ANCE PROCEDURES

1. IC 2418C Pressurizer Pressure Instrument Calibration

2. IC 2429A Safety Related Instrument Calibration - Operating

3. IC 2429E Condensate Storage Tank Level Calibration l

4. SP 2402B Pressurizer Pressure Calibration

{

l

5. SP 2402D Steam Generator Level Calibration f

6. SP 2402M Functional Test of Steam Gen. Level and Auto Aux. FW Init. Logic

7. SP 2402N Auxiliary Feedwater Flow Indication Calibration DR-0364. DOC Page 2 of 41

vuunummu R SP_2402Q ATWS Setpoint Functional Test

9. SP 2402S Auto Aux. Feedwater Calibration and Functional Test

10. SP 2403D Containment Pressure Calibration

11. SP 2403E RWST Level Calibration

12. SP 2403M RWST Level Functional Test D. METHODOLOGIES (1) Methodology - Looo Uncertaint_v (a.) SP-ST-EE-286 Guidelines For Calculating Instrument Uncertainties (Revisions 1989 -

1995):

(b.) SP-M2-EE-0003 Guidelines For Impact Evaluation of 24 Month Fuel Cycle on Technical Specification Surveillance for Millstone Unit 2 (Revision 0,1994)

(2) Methodology - Setooints (Safety Systems).

(a.) SP-EE-315 Guidelines For Calculating Setpoints For Safety Systems (Revisions 1991 -

1995)-

(b.) SP-IC-019 Millstone Unit 2 I&C Setpoints (Revision 0,12/12/97)

E. OTHER REFERENCES (1) Discrepancy Report 60127 "RPS Analytical Limit Violation with Existing Setpoint Due to Steam Generator Narrow Range Low Level Tap Span" (2) 1 Discrepancy Report 60128 " Missing Seismic Analysis in Setpoint Analyses for ESAS, RPS &

Safety-Related Loops" (3) Discrepancy Report #-0129 "Non-Conservative Drift Evaluations" (4) - Discrepancy Repon #-0130 " Incorrect Value Used for Measurement & Test Equipment

. (M&TE) Term in Calculations" (5) Discrepancy Repon 00171 " CST Maximum Water Temperature" (6) Discrepancy Repon #-0279 " Comparison ofMinimum "As-Left" Values for Degraded Voltage Trip with Plant Technical Specification Requirements"

.(7) Discrepancy Report 60464 "Setpoint for SIAS on High Containment Pressure Not Consistent with Technical Specification or FSAR" (8) EOP # 2540, "FunctionalRecovery"-

(9). EOP # 2532,"LOCA"

~

l.

(10)' EOP # 2534," Steam Generator Tube Rupture L

(11) EOP # 2536," Excess Steam Demand" (12) EOP # 2537," Loss ofFeedwater" (13) EOP # 2528,"Electncal Emergency" (14). EOP # 2530," Station Blackout" (15) Discrepancy Report #-0402 " Conflict Between I&C Procedure SP 2402B for Pressurizer Pressure Loops P-l?2A,B,C,D and Supporting Calculations - PA XX-XXX-0573-GE and 92-030-1260E2" DR 0364. DOC Page 3 of 41 o -

DISCREPANCY I

IL OVERVIEW:

{

A review of the Calculations referenced above revealed certain discrepancies in many different areas. The following are a list ofDiscrepancies that have been categorized into two areas. The First Area is a listing of the Major Discrepancies (Level 3) against the Calculations listed in Reference A, the overall Setpoint Program and the Interface that will impact a setpoint/ accuracy calculation's conclusion or results. The Second Area is for Minor Discrepancies (Level 4). These l

Discrepancies were further categorized into general "Typer" of Discrepancies as follows:

Type ABD - As Built Discrepancy Type AD - Assumption Discrepancy Type AL - Analytical Limit Discrepancy Type CD - Calibration Discrepancy Type DD - Drift Discrepancy Type DDD - Design Document Discrepancy Type DID - Design input Discrepancy Type DOD - Design Output Discrepan :y Type EED - Environmental Effect Discrepancy Type FD - Functional Discrepancy Type M - Miscellaneous Discrepancy Type MD - Methodology Discrepancy q

Type PED - Process Effect Discrepancy Type PRD - Process Range Discrepancy IIL DISCUSSION OF DISCREPANCIES:

Generic Calculation Related Discrepancies (1) Level 3 Twe DD Discrepancy

[See Reference A.27, Calcula: ion PA XY-XXX-0963GE]

INPO SER 27-93 was issued to prevent the use of a method for calibrating transmitters where the transmitters are cycled up and down three times before recording "As-Found" data. Cycling the transmitters before recording the "As-Found" data skews the results in a non-conservative manner and is not valid method for verifying " Drift" This practice was utilized by Northeast Utilities as well as some other plants. The values used to calculate the extended " Drift" interval

~

accuracies uses data from an era that includes this practice. Therefore, the 30 month drift values are all incorrect and can not be relied upon as overly conservative or even conservative l

values for any interval including the 18 month

• 25% (22% month) used at Millstone.

l l

A. Steam Generator Narrow Ranee Level Calculation Related Discrepancies l

l (2) Level 3 Twe PED Discrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Downcomer Effects need to be addressed and added to the Narrow Range Steam Generator Level Setpoint Calculation.

DR-0364. DOC Page 4 of 41 1

-.____________________________u

DISCREPANCY (3) Level 3 Tspe PED Discrepancy

[See Reference A.27, Calculation PA H-XH-0963GE]

Carryunder Effects are not addressed in the Setpoint Analysis for steam generator level, Carryunder Effects are considered zero for water levels at 44 inches or more above the bottom of the primary separator return cylinder. For levels less than 44 inches above the bottom of the primary separator return cylinder the Canyunder Effects increase linearly until the water level drops below 14 inches above the bottom of the primary separator return cylinder. Below this level, a 1% uncertainty is normally used which is less than actual test results for the Millstone Primary Separator test concluded. The 1% uncenainty is based on these test results and the fact that a natural phase separator exists and the separator return flow migrates to the Downcomer, thus reducing the Carrytmder Effects.

(4) Level 3 Tvoe AL Discrepancy

[See Reference A32, Calculation 006-AS91-C-003]

The Main Steam Line Break Safety Analysis uses 168.348 inches as the Steam Generator Narrow Range Level Tap Span Measurement. ABB CE states in the calculation that the old CE Steam Generator's tap spans are 183.156 inches.

(5) Level 3 Tvoe AL Discrepancy (See Reference A33, Calculation E-5272-595-006]

The Loss of Feedwater Event Safety Analysis uses 184 inches or more as the Steam Ge terator Narrow Range Level Tap Span Measurement.

(6) Level 3 Tvoe AL Discrepancy

[See Reference B10, IE Bulletin 79-21]

Millstone committed via response to IE Bulletin 79-21 Item (2) and Item (4) that, "The effect of post-accident temperatures on the indicatedwater levelrelative to the actualwater level,for both steam generator andpressuri:er, is shown graphically in attachment 2. An instrument error of* 3% must be addedto these curves." This

• 3% uncertainty has not been found in the Steam Generator Narrow Range Level Calculations or EOPs as presented in Attachment 2 of the response to the IE Bulletin 79-21 Item (4). Note that EOP # 2540,2532,2534, 2536, 2537, 2528 and 2530 were reviewed for this response. (See References I.E.8, I.E.9, I.E.10, I.E.11, I.E.12, I.E.13 & I.E.14 respectively.)

92-030-1254 Rev. O, " Millstone 2 - Steam Generator Narrow Rance Level Setpoint Analysis Calculation" (7) Level 3 Tspe DDDDiscrepancy

[See Reference A.26, Calculation 92-030-1251]

The Summary in Section 6.0 is auoted as follows:

"The present values of trip serpoint and allowable valuefor the RPS trip in the Technical Specifications are not satisfactory andmust be changed. 7he present trip valuefor AFW initiation in the TechnicalSpecifications is satisfactory. The present allowable valuefor AFW initiation in the TechnicalSpecifications is not satisfactory and must be changed."

There is no UIR for this situation. This is not conservative and the 30 month drift response is not applicable, because the new 30 month drift value may be less conservative than the old 22%

month drift term.

DR-0364. DOC Page 5 of 41

DISCREPANCY (8) Level 3 hve DID Discrepancy

~

[See Reference A.26, Calculation 92-030-1254]

Section 2.1 lists the " Design Inputs" as "Not Applicable" This is misleading, and it appears

~

that the " References"in Section 2.2 are consideied the " Design Inputs" Inputs are not clearly identified throughout the calculation.

(9) Level 3 Tvve DID Discrepancy

[See Reference A.26, Calculation 92-030-1254]

The M&TE Allowance (MTE & MTE3) for the Fluke Digital Multimeter are shown as 2

0.39% Span on the Referenced Calculation (Ref. 2.2.2) and 0.38% Span on this calculation.

(l0) Level.3 hye DID Discrepancy

[See Reference A.26, Calculation 92-030-1254]

The M&TE Allowance (MTE ) uses only the Fluke Digital Multimeter according to this 3

calculation, but a Translation (Transmitter Simulator) is used as well (* 0.24% Span).

(l1) Level 3 hye DIDDiscrepancy

[See Reference A.26, Calculation 92-030-1254]

The RPS Loop Acceptance Criteria in Section 5.8 states, "The acceptance criteria of the calibration procedure should be at least as restrictive as the values.". These values are "As-Left and "As-Found" calculated values to support the setpoint calculation. Therefore, this 3

calculation is not valid if the calibration procedure has less conservative numbers. The calibration procedure SP 2402D uses

• 0.16 mAdc for the " Acceptance Criteria", which is greater than

• 0.15 mAdc used in the calculation. Also, note that in Section 5.9 "As-Left" is identified as "AF" instead of"AL".

(l2) Level 3 hye DIDDiscrepancy

[See Reference A.26, Calculation 92-030-1254]

The Summary in Section 6.0 states, "... It is reconunended that loop as-left criteria in the surveillance procedure be set considerably more restrictive than those above.". As shown in Section 5.8 the "As-Left" values in the procedure are greater than these, therefore they are not more restrictive.

(l3) Level 4 hpeMDiscrepancy

[See Reference A.26, Calculation 92-030-1254]

The Manufacturer's Make and Model Number are not provided for the Transmitter (Xmtr).

PA XX-XXX-0963GE Rev.1, " Millstone 2 - Steam Generator Narrow Range Level Loop Accuracy Calculation" I

(l4) Level 3 TvoeDIDDiscrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Section 2.1 lists the " Design Inputs" as "None". This is misleading, and it appears that the

" References" in Section 2.2 are considered the " Design Inputs". Inputs are not clearly identified throughout the calculation.

(l5) Level 4 hveMDiscrepancy 1

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Reference 2.2.15 lists PA 92-030-1249E2 as the Steam Generator Narrow Range Level Calibration calculation, but 93-039-1249E2 is the correct reference.

DR-0364. DOC Page 6 of 41

= =-

DISCREPANCY (16) Level 3 Tvoe DID Discrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

l Assumptions are made but are not explained in enough detail to allow their use. An example is ~

t Assumption 3.3,"In Section 4.5, a sensor temperature effect ofi 0.5% is assumed." Another example is Assumption 3.6. The containment temperature is considered to vary 30 *F from 105 F to 135 F.

(l7) Level 4 TpeMDiscrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

In Section 4.17 Reference 2.2.13 is listed twice, but both should be 2.2.11.

(l8) Level 3 hye EED Discrepancy (See Reference A.27, Calculation PA H-XXX-0963GE]

Section 5.4 " Post-Accident Conditions RPS Input (l" 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)" states, "The function of the RPS for these variables is completed a few seconds into an accident. Therefore no error calculations are performed.". This ignores a Small Break LOCA and has no referenced basis for making this " ASSUMPTION". This is incorrect. Other scenarios can affect this trip.

(l9) Level 3 Tvpe DID Discrepancy

[See Reference A.27, Calculation PA H-HX-0963GE]

l Appendix A calculates the Process Measurement Accuracy (PMA) term as a minus (-) 8.4%. It is stated, "This is conservative, because high containment temperatures andhigh steam pressures will not occur simultaneously (also, the negative bias is not importantfor an actuation on decreasinglevel)." This doesn't seem to correlate. An example is as follows:

Note that a Feedwater Line Break or a Small Break LOCA in containment could effect the j

Reference Leg Temperatures. Effectively, the density in the Reference Leg decreases as I

Temperature increases effectively reducing the pressure on the Reference Leg side of the transmitter also known as the upper tap (From applying PV = nRT). The Lower Tap will still have approximately the same pressure applied to the transmitter. Therefore, the Lower Tap pressure minus the (Reduced) Upper Tap Pressure will be larger than if the Upper Tap Pressure had not been reduced by the Reference Leg Heat-up. As a result the indicated levelis really higher than the actual level and therefore is a " BIAS" that needs to be included. This is not accounted forin this calculation.

(20) Level 3 Tvve AL Discrepancy (See Reference A.27, Calculation PA H-) OOC-0963GE]

Analytical Limits have no documented Design Basis ties t ; the Safety Analysis values used.

(21) Level 3 Twe DID Discrepancy

[See Reference A.27, Calculation PA H-XXX-0963GE]

The steam generator level is measured by subtracting two masses, one from the top of the generator and the other from a lower point on the generator to calculate the approximate water level versus steam breakpoint level. When calculating this level among a homogeneous mixture of 890 Psia and 550 'F water, wet steam, dry steam boundaries accounts for some additional uncerta' ties. These are normally covered in the Safety Analysis calculations. The lower tap m

location, below the Main Feedwater (MFW) inlet nozzle, adds additional uncertainties that are not covered by the Safety Analysis. The relatively cold MFW is denser than the heated water in the Steam Generator, and therefore contributes an additional uncertainty. This is normally referred to as a Downcomer effect and this needs to be included.

(22) Level 3 Tvoe DID Discrepancy (See Reference A.27. Calculation PA XX-XXX-0963GEJ DR-0364. DOC Page 7 of 41

DISCREPANCY Instrument accuracy inputs are not tied to controlled Documents or Technical Manuals. The EQ Binder file correlation to the I&C Calculations need to be addressed for Accuracy (At lea Harsh Environment accuracy).

(23) Level 3.hpe DlQ Discrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Variations in field installation elevations between multiple channel instmments are not considered.

(24) Level 3 Tsve DIDDiscrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Setting Tolerances are not considered in the Loop Accuracy Calculations.

(25) Level 3 Tvve DID Discrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

"As Found" and "As Len" allowances considered in the Loop Accuracy Calculations do not reflect the allowances specified in the Surveillance Procedures.

(26) [evel3 Tspe MD Discrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

Seismic Analysis evaluations missing (See Reference E.1, DR# 0128).

(27) Level 3 TvoeMDDiscrepancy

[See Reference A.27, Calculation PA XX-XH-0963GE]

Drin Evaluation incorrectly considered in the DriR Calculations (See Reference E.3, DR#

0129).

(28) Level 3 TspeMDDiscrepancy

[See Reference A.27, Calculation PA XX-XXX-0963GE]

M&TE Evaluation incorrectly considered in the Loop Accuracy Calculations (See Reference E.4, DR# 0130).

B. Containment Pressure Calculation Related Discreonncies (29) Level 3 Tvoe ALDiscrepancy The Containment Pressure Setpoint Analysis doesn't evaluate the trip for SIAS with respect to a Reactor Trip on Containment Pressure. The Containment Pressure trip for SIAS is malated in the Setpoint Calculation as 5 4.85 Psig and the Surveillance Procedure uses 3.85 Psig as the setpoint. This may cause a SIAS before the Reactor Trip. A minimum term should be calculated for the Analytical Limit based on preventing a Reactor Trip aner a SIAS trip based on Containment Pressure.

(30) Level 3 Tspe DIDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

Section 2.1 lists the " Design Inputs" as "Not Applicable". This is misleading, and it appears that the " References"in Section 2.2 are considered the " Design Inputs". Inputs are not clearly I

identified throughout the calculation.

(3l) Level 3 Tspe AL Discrepancy (See Reference A.3. Calculation 92-030-12691 DR 0364. DOC Page 8 of 41 j

DISCREPANCY A memo attached to the Setpoint Analysis identifies the Analytical Limit for Containment Pressure - High as 5.83 Psig. This Analytical Limit Memo is not a design document. yet it is referenced as a design input.

(32) Level 3 TypeMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The Rack Drift (RD) term and Rack Accuracy (RCA) term are missing from section 5.1.

(33) Level 3 Twe DID Discrepancy

[See Reference A.3, Calculation 92-030-1269]

The M&TE used in section 4.3 for MTEidoesn't include the Transmitter Simulator Uncertainty.

t (34) Level 3 Type DIDDiscrepancy

[&c Reference A.3, Calculation 92-030-1269]

The Surveillance Procedure uses an allowable tolerance of

• 1.5 % for "As Found" & "As Left" allowances yet the Setpoint Calculation only allows 1.09% maximum for "As Found" and

• 0.97% for "As Left".

(35) Level 4 Tvoe DIDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The effects of the 2500 resistor are not included in this calculation and should be included l

either here or in the Loop Accuracy calculation. Note that the Calculation considers this to be

• 0.1% accurate, but the Surveillance Procedure doesn't test the input resistor.

-(36) Level 4 Tvoe FD Discrepancy

[See Reference A.3, Calculation 92-030-1269]

The calibrated span of the Containment Pressure transmitters are calibrated from 60 to 0 Psig to support the actual Plant requirements. The setpoint of 4.75 psig does not agree with good engineering practices for having setpoints be at least 15% from the end points of the calibrated span of the transmitter.

^ (37) Level 3 Tvoe DOD Discrepancy

[See Reference A.3, Calculation 92-030-1269]

FSAR Section Setooint Allowable Value Uncertainty i

Table 14.8.2-4 (ESAS-MSLB)

$ 5.83 Psig N/A Included j

!~

Section 6.3 (ESAS-SIAS)

= 4.75 Psig N/A N/A L

Setpoint Calc (ESAS Trip)

$ 4.80 Psig 5 5.06 Psig

• 1.03 Psi l

L These do not agree.

l (See Discrepancy Report # 464, Reference I.E.7.)

(38) Level 3 Tvoe ALDiscrepancy

- [See Reference A.3, Calculation 92-030-1269]

The Containment Pressure Setpoint Analysis Calculation has a setpoint value (SIAS $ 4.8 1

PSIG) that does not match the UFSAR value (SIAS = /. 75 PSIG). The Surveillance Procedure (SP 2403D) for Containment Pressure and its Calibration Data Sheet (SP 2403D-1) value

[SIAS = 3.80 psig

• 1.5% (* 0.90 psi)] do not match the UFSAR value (SIAS = 4.75 PSIG). It appears that the ES AS setpoint will exceed the Analytical Limit if Accident uncertainty effects are included (Small Break LOCA) as presently installed.

(39) Level 3 Tvoe DID Discrepancy (See Reference A.3. Calculation 92-030-1269]

l t-DR-0364. DOC.

Page 9 of 41 i

uvu m ;u n u m w g The Setpoint and Loop Uncertainty calculations incorrectly calculate the overall"As Left" tolerance as a 0.97% Span or a 0.582 psi, because the Surveillance Procedure's Calibration Sctting Tolerance ("As Left" tolerance) is 1.5% Span or 0.90 psi. Note, that the Setpoint' and Loop Uncertainty calculations incorrectly calculate the overall"As Found" tolerance as 1.09% Span or

• 0.654 psi which is still less than the Surveillance Procedure's Calibration Setting Tolerance ("As Left" tolerance) of* 1.5% Span or

• 0.90 psi. The actual setpoint results are not reasonable since they are so close to a span endpoint.

(40) Level 3 hpe DID Discrepancy

[See Reference A.3, Calculation 92-030-1269]

Reference Setooint Allowable Value Uncertainty Tech Spec Table 2.2-1 (SIAS ESAS) 5 4.75 Psig 5 5.24 Psig N/A Tech Spec Table 3.3-4 (SLAS ESAS)

= 4,75 Psig 5 5.20 Psig N/A Setpoint Calculation (ESAS Trip) 5 4.80 Psig 5 5.06 Psig

• l.03 Psi Procedure - SP2404B (Trip ESAS)

= 3.50 Psig N/A

• 0.90 Psi FSAR Sect 6.3 (SIAS ESAS) 5 4.75 Psig N/A N/A FS AR Table 14.8.2-4 (Trip ESAS) 5 5.83 Psig N/A Included These do not agree. The SIAS setpoint per the Technical Specification Table 3.3-4 does not allow a setpoint below or above 4.75 Psig and the setpoint is set at 3.50 Psig. This is not necessarily conservative for this particular trip. An analysis was not performed on the lower limit of the Containment Pressure setpoint for SIAS to assure that the Reactor Trip on Containment Pressure would be initiated first, before safety injection is initiated.

(Also, See Reference I.E.7, Discrepancy Report # 0464.)

(41) Level 3 hpe EEDiscrepancy (See Reference A.3, Calculation 92-030-1269]

The Setpoint Analysis Calculation evaluations ate system calculations / analyses and do not reflect the current plant configuration. It appears that the ES AS setpoint will exceed the Analytical Limit if Accident uncenainty effects are included as presently installed. (Small Break LOCA).

(42) [evel3 hveMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The M&TE Terms Used in Calculations for Instrument Loop Uncertainties are not calculated properly. The M&TE have the same Uncertainties as any other instrument, and these effects are discussed in ISA-RP67.04 Part II dated 1994 and ISA SSI.1 dated 1979. The M&TE Reference Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8) is not an Effect, but is used as the M&TE's Span which is used by each Effect.

The M&TE overall Accuracy Term (MTE)is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (1.) Calibration Effects, (2.) Calibration Standard Effects, (3.) Temperature Effects, (4.) Drift Effects, (5.) Readability / Resolution Effects, (6.) Power Supply Effects, other (g.) Miscellaneous Effects, and Mso (h.) Incorrect Spans were used for some of the M&TE.

(See Reference E.4, Discrepancy Report # 0130)

(43) Level 3 TypeMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE and the Rack's MUTE DR-0364. DOC Page 10 of 4 t

(

c l

uvuaunte ccv need to be considized. This needs to be addressed.

(44) Level 3 hpe DID Discrepancy

[See Reference A.3, Calculation 92-030-1269]

The Loop Accuracy calculation is missing the Setting Accuracy Tolerance for both the Sensor and the Rack Drift values are speculative. Some margin may exist there since they were calculated for 30 months instead of the 22% months currently required in the Technical Specifications. (See Reference E.4, Discrepancy Report DR# 0130)

(45) Level 3 hpe DIDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

Seismic Effects per GDC 21 states that RPS/ESAS equipment must be able to wi'thstand a Seismic Event and still maintain its Design Function. This doesn't mean concurrent events, but does mean that the RPS/ESAS equipment will not be disabled. Additionally, an OBE may not include a re-calibration, so it >.:ds to be addressed in the Loop Uncertainty as a minimum.

(See Reference E.2, Discrepancy Repon DR# 0128)

(46) Level 3 hveMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

1 Accident Analysis values are not cddressed properly, Accident conditions do apply and need to be addressed or added.

(47) Level 3 hve DID Discrepancy

[See Reference A.3, Calculation 92-030-1269]

An uncertainty or bias term was not calculated for the gauge pressure transmitter for Barometric Pressure Effects. The gauge pressure effects include ambient pressure effects due to the actual ambient pressure at the transmitter. Therefore, Barometric Pressure Effects / Gauge Pressure Effects should be addressed with at least an " Assumption".

(48) Level 3 hyeMDDiscrepancy

[See Reference A.3, Calculation 92 030-1269]

The PAM calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(49) Level 3 Rye ADDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's Methodology for calculating PAM environment inaccuracies. Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process Measurement Allowances (PMA) and the Control Room Indicator's Readability Error (RDIND).

(50) Level 3 hveMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The Control Room Indication (PAM) calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(51) Level 3 hveMQDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, IS A and Millstone's Methodology for calculating PAM environment inaccuracies. Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process Measurement l

DR-0364. DOC Page 11 of 41 Y

l

DISCREPANCY Allowances (PMA) and the Control Room Indicator's Readability Error (RDIND).

(52) Level 3 TsveMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The Control Room Indication (PAM) calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(53) Level 3 Tsve ADDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

There are no " Assumptions" referenced in this calculation, but " Assumptions" are made to perform this calculation and they would result in similar results. The Assumptions' listed are missing and insufficient to logically apply the methods of the EPRI, IS A and Millstone's Methodology for calculating Accident Environment ESAS inputs environment inaccuracies.

Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, and Process Measurement Allowances (PMA).

(54) Level 3 TspeMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

The PAM calculation does not address process conditions and effects that are n.icable but aren't included in the calculation. Installation offsets, Psig transmitter ambient pressure considerations dring an accident, and IR effects are some of the missing effects. The PAM Calculation does not include the uncertainty due to readability of the indicator. Rack Temperature Effects and Drift are missing from this calculation (55) Level 3 Tsve ADDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

There are no " Assumptions" referenced in this calculation, but " Assumptions" are made to perform this calculation and they would result in similar results. The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's Methodology for calculating Accident Environment ESAS inputs environment inaccuracies.

Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process Measurement Allowances (PMA) and the Control Room Recorder's Readability Error (RDIND).

(56) Level 3 TsveMDDiscrepancy

[See Reference A.3, Calculation 92-030-1269]

This calculation incorrectly addresses Drift that reduces the overall Operating Margin. (See Reference E.3, DR#-0129 on Drift Analysis.)

(57) Level 3 TrpeMDDiscrepancy (See Reference A.3, Cakulation 92-030-1269]

This calculation incorrectly addresses Drift that revises a Design Input to the Setpoint Analysis and Loop Uncertainty Calculations. (See Reference E.3, DR#-0129 on Drift Analysis.)

PA XX-XXX-0965GE Rev.1, " Millstone 2 - Containment Pressure Loop Accuracy Calculation" (58) Level 3 7'speMDDiscrepancy

[See Reference A.18, Calculation PA XX-XXX-0965GE]

The M&TE Terms Used in Calculations for Instmment Loop Uncertainties are not calculated properly. The M&TE have the same Uncertainties as any other instrument, and these effects are discussed in ISA-RP67.04 Part II dated 1994 and ISA S51.1 dated 1979. The M&TE DR-0364. DOC Page 12 of 41

L%1CLiM W35CT Reference Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8)is not an Effect, but is used as the M&TE's Span which is used by each Effect.

The M&TE overall Accuracy Term (MTE) is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (1.) Calibration Effects, (2.) Calibration Standard Effects, (3.) Temperature Effects, (4.) Drift Effects, (5.) Readability / Resolution Effects, (6.) Power Supply Effects, other (7.) Miscellaneous Effects, and also (8.) Incorrect Spans were used for some of the M&TE. (See Discrepancy Report DR# 0129)

(59) Level 3 Tsve MD Discrepancy

[See Reference A.18, Calculation PA XX-XXX-0965GE]

Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE and the Rack's M&TE need to be considered. This needs to be addressed.

(60) Level 3 TypeMDDiscrepancy

[See Reference A.18, Calculation PA H-HX-0965GE]

The Loop Accuracy calculation is missing the Setting Accuracy Tolerance for both the Sensor and the Rack. Drift values are speculative at best. Some margin may be there since they were calculated for 30 months instead of the 22% months currently required in the Technical Specifications. (See Discrepancy Report DR# 0130)

(61) Level 3 Tvoe DID Discrepancy

[See Reference A.18, Calculation PA XX-XH-0965GE]

Seismic Effects per GDC 21 states that RPS/ESAS equipment must be able to withstand a Seismic, vent and still maintain its Design Function. This doesn't mean concurrent events, but does mean that the RPS/ESAS equipment will not be disabled. Additionally, an OBE may not include a re-calibration, so it must be included in the Loop Uncertainty as a minimum. (See Discrepancy Report DR# 0128)

(62) Level 3 TsveMDDiscrepancy

[See Reference A.18, Calculation PA H-XXX-0965GE]

Accident Analysis values are not addressed properly and Accident conditions do apply and need to be added or addressed.

(63) Level 3 Tvoe DID Discrepancy

[See Reference A.18, Calculation PA XX-XH-0965GE]

An uncertainty or bias term was not calculated for the gauge pressure transmitter for Barometric Pressure Effects. The gauge pressure effects include ambient pressure effects due to the actual ambient pressure at the transmitter. Therefore, Barometric Pressure Effects / Gauge Pressure Effects should be addressed with at least an " Assumption" PA 78-771-418GE Rev. O, " Millstone 2 - Containment Pressure Wide Range PAM Indication" (64) Level 3 Tsve MD Discrepancy

[See Reference A.11, Calcination PA 78-771-418GE]

The PAM calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

l (65) Level 3 Tvoe AD Discrepancy

[See Reference A.11, Calculation PA 78-771-418GE]

l The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's Methodology for calculating PAM environment inaccuracies. Some items I

l DR-0364. DOC Page 13 of 41

DISCREPANCY missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process Measurement m

Allowances (PMA) and the Control Room Indicator's Readability Error (RDIND).

PA 78-771-426GE Rev. O," Millstone 2 - Containment Pressure Control Room Indication" (66) Level 3 Tyve PED Discrepancy

[See Reference A.13, Calculation PA 78-771-426GE]

The Control Room Indication (PAM) calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(67) Level 3 Tyne._dD Discrepancy

[See Reference A.13, Calculation PA 78-771-426GE]

The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, IS A and Millstone's Methodology for calculating PAM environment inaccuracies. Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process Measurement Allowances (PMA) and the Control Room Indicator's Readability Error (RDIND).

PA 78-771-435GE Rev. O, " Millstone 2 - Containment Pressure ESAS Input" (68) Level 3 TspeMDDiscrepancy

[See Reference A.]4, Calculation PA 78-771-435GE]

The Control Room Indication (PAM) calculation does not address process conditions and effects that are applicable to the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(69) Level 3 TvveMDDiscrepancy

[See Reference A.]4, Calculation PA 78-771-435GE]

There are no " Assumptions" referenced in this calculation, but " Assumptions" are made to perform this calculation and they would result in similar results. The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's Methodology for calculating Accident Environment ESAS inputs environment inaccuracies.

Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, and Process Measurement Allowances (PMA).

PA 78-771-436GE Rev. O, " Millstone 2 - Containment Pressure Control Room Recorder" (70) Level 3 Tvve MD Discrepancy

[See Reference A.15, Calculation PA 78-771-436GE]

The PAM calculation do not address process conditions and effects that are applicable but aren't included in the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects. The PAM Calculation does not include the uncertainty due to readability of the indicator. Rack Temperature Effects and Drift are missing from this calculation.

(71) Level 3 7'vpe MD Discrepancy i

[See Reference A.15, Calculation PA 78-771-436GE]

There are no " Assumptions" referenced in this calculation, but " Assumptions" are made to perform this calculation and they would result in similar results. The Assumptions listed are issing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's own e

.ethodology for calculating Accident Environment ESAS inputs environment inaccuracies.

Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Process DR-0364. DOC Page n of4I l

1 l

DISCREPANCY Measurement Allowances (PMA) and the Control Room Recorder's Readability Error (RDIND)..

93-039-1148E2, Rev. 0, " Millstone 2 - Containment Pressure Transmitters Drift Analysis"

}

(72) Level 3 TweMDDiscrepancy

[See Reference A.6, Calculation 93-039-1148E2]

This calculation incorrectly addresses Drift that reduces the overall operating Margin. (See DR-0129 on Drift Analysis.)

93-039-1165E2 Rev. O, " Millstone 2 - Containment Pressure Wide Range DriYt Analysis" (73) Level 3 TweMDDiscrepancy

[See Reference A.8, Cal:ulation 93-039-1165E2]

This calculation addresses Drift but not in a manner that is correct and this revises a Design l

Input to the Setpoint Analysis and Loop Uncenainty Calculations. (See DR-0129 on Drift I

Analysis.)

C. HPSI Flow. Pressure. Discharne Pressure Calculation Related Discrepancies PA XX-XXX-1006GE Rev. O, " Millstone 2 - HPSI Flow Loop Accuracy Calculation" (74) Level 3 TvveMDDiscrepancy

[See Reference A.21, Calculation PA XX-XXX-1006GE]

The Loop Accuracy calculation is missing the Setting Accuracy Tolerance for both the Sensor t

and the Rack. They do not do a 3 Up 3 Down calibration (or even a 10 up 10 down), but a cne up and no down. Hysteresis is definitely not verified. (See ISA-RP67.04 Pan II dated 1994 and ISA S51.1 dated 1979)

I (75) Level 3 Tvve DIDDiscrepancy

[See Reference A.21, Calculation PA XX-)C0(-1006GE]

Orifice Plate sources of error when measuring flow (dP) include eccentricity, plate flatness, gasket projections into the pipe, wear or damage to the square edge, reverse installation, lack of piping smoothness and actual distances and locations of other piping bends, reducers and valves or restrictors. Check valves upstream of the orifice plates, lift guided disc type, which according to CRANE's Flow ofFluids. offers approximately twice the flow resistance of a fully open Globe valve. The required straight runs for Globe valves are given by ASME Standards (i.e. - ASME MFC-3M-1984) but are not given for Check valves. Both Globe and Check valves are similar in construction and flow patterns, but the lift type check valve offers substantially more resistance to flow than a wide open Globe valve it would be reasonable to assume that the minimum straight run of pipe required is at least equal to that of a Globe valve and most likely up to twice the distance. Consequently, the HPSI Flow Orifice installations are discrepant with the latest ASME recommendations and the 1971 version Flow Meters as well, 1984 version requires 25 Pipe Diameters and the 1971 version requires 16 Pipe Diameters and l-15 is stated in the calculation as the installed distance. These items are not addressed in this calculation.

l (76) Level 3 Tvve DIDDiscrepancy

'[See Reference A.21, Calculation PA XX-XXX-1006GE]

A bias term is missing for not meeting the straight piping mn requirements upstream of the flow orifice. The straight piping run req'uirements upstream of the flow orifice are stated as meeting l

DR-0364. DOC Page 15 of 41

DISCREPANCY requirements in the calculation (15 D), yet don't meet the requirements per Isolation drawings and field verifications. Note that a Lifi Check valve is used in the line upstream of the flow orifice which requires an even greater distance (25 D) for straight pipe runs. According to installation ISOs the straight run criteria is not met.

(77) Level 3 7'speDIDDiscrepancy

[See Reference A.21 Calculation PA XX-XXX-1006GE]

The Process Measurement Accuracy (PMA) states that LPSI flow orifices are designed for water at 200 F and that the HPSI orifice uses RWST water between 50 to 100 F and therefor more dense than LPSI. So the LPSI orifice design conditions are used since the HPSI design conditions can't be found. Millstone Unit 2 Calculation N-PEC-24 dated 1/5/72 fitled " Safety Injection Systems Delivery Curves" provides the HPSI Flow Orifice data.

(78) Level 3 Tspe DID Discrepancy

[See Reference A.21, Calculation PA H-XXX-1006GE]

This calculation states in section 4.1 (PMA) that the "A search of Nuclear Records failed to produce a manufacturer's orifice calculation for HPSI flow." No data is provided in this calculation to show the Beta or Orifice diameter. Therefore, the required straight upstream runs ofpipe can not be determined. Note also the fact that a check valve upstream of the Orifice Plate is not addressed either.

(79) Level 3 TsveDIDDiscrepancy

[See Reference A.21, Calculation PA H-XH-1006GE]

A bias term for the Primary Element Accuracy (PEA).;f 2% for an Orifice was assumed based on Chilton's Handbook and not verified. It is uncle ir why this would be assumed and not, either field verified or verified with the vendor of the Orifice plate. Orifice plates can be removed to assure proper installation, wear and usually nameplate data can be obtained.

(80) Level 3 Tsve FD Discrepancy

[See Reference A.21, Calculation PA H-HX-1006GE]

The square root extraction is provided by a programmable read only memory (PROM) within the indicator and according to the calculation the error is negligible for the PROM. This seems highly unlikely as there is an algorithm needed to convert voltagelcurrent to a span value which would include some losses.

(81) Level 3 TsveDODDiscrepancy

[See Reference A.21, Calculation PA XX-XXX-1006GE]

The control room indication's total loop uncertainty is calculated as 3.27% Span (@ 300

{

GPM) to

• 5.03% Span (@ 100 GPM) which includes the linear addition of a 2.0% Primary Element Allowance (PEA). This results in a measurable total loop uncertainty of* 1.27% Span

{

(@ 300 GPM) to

• 3.03% Span (@ 100 GPM) but the Surveillance Procedure IC2429A allows l

• 2.0% Span for the full span. The indicator's accuracy in the calculation is 0.39% Span

)

which is less than the apparent 2.0% allowance in Surveillance Procedure IC2429A.

l (82) Level 3 Tsve DIDDiscrepancy

[See Reference A.21, Calculation PA H-XXX-1006GE]

The Drift Effects error is not included for the Dixson Indicator in this calculation. A separate Drift evaluation exists that identifies what the plant drift is for the Dixson Indicator.

(Calculation 93-039-01239E2 r. O uses

• 0.64% Span)

(83) Level 3 TypeMDiscrepancy DR-0364. DOC Page 16 of 41 l

J

DISCREPANCY

[See Reference A.21, Calculation PA XX-XXX-1006GE]

Static Pressure Effect is calculated and stated to be 0.5% span due to a static pressure!

1600 psi and a transmitter rated to 1.5% span for a 6000 psi static pressure. This doesn't appear to be accurate, since a later specification for the same instrument specifies the static pressure of a transmitter rated to 1.5% span for a 3000 psi static pressure. If the latest specification is correct, then 0.5% span is not conservative (-0.8% span). This needs to be addressed.

(84) Level 4 hp_eDl_ Discrepancy

[See Reference A.21, Calculation PA H-XXX-1006GE]

The Overall Computer's Accuracy (OCA) doesn't calculate an uncertainty but the Surveillance Procedure IC2429A allows 20.0 GPM Span ( 6.67% Span).

(85) Level 3 TvoeMDDiscrepancy

[See Rejkrence A.21, Calculation PA XX-XXX-1006GE]

The M&TE Terms Used in Calculations for Instrument Loop Uncertainties are not calculated properly. The M&TE have the same Uncertainties as any other instrument, and these effects are discussed in ISA-RP67.04 Part II dated 1994 and ISA S51.1 dated 1979. The M&TE

{

Reference Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8) is not an Effect, but is used as the M&TE's Span which is used by each Effect.

The M&F overall Accurecy Term (MTE)is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (a.) Calibration Effects, (b.) Calibration I

Standard Effects, (c.) Temperature Effects, (d.) Drift Effects, (e.) Readability / Resolution Effects, (f.) Power Supply Effects, other (g.) Miscellaneous Effects, and also (h.) Incorrect Spans were used for some of the M&TE. These concerns are described below:

(See Discrepancy Report DR# 0129)

(86) Level 3 Tvoe MD Discrepancy (See Reference A.21, Calculation PA H-XH-1006GE]

Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE (Sensor) and the Rack's M&TE need to be considered. This needs to be addressed.

(87) Level 3 Tvoe CDDiscrepancy

[See Reference A.21, Calculation PA XX-XXX-1006GE]

l The Metrology Lab referenced in the calculation in section 4.10 did not specify the ranges to be

~

used. M&TE with ranges of 700 "H2O and 50 rnA can not be used adequately to measure the end points of 700 "H2O and 50 mA respectively. The Surveillance Procedure IC2429A specifies a Wallace & Tiernan pressure gauge with a span of 0 to 830 inches of H2O b used.

(88) Level 4 Tvoe DIDDiscrepancy

\\

[See Reference A.21, Calculation PA XX-XXX-1006GE]

The Attachments do not clearly convey the accuracy or necessary information as implied by this calculation without outside intervention. Specifically model numbers are not shown in enough detail or in the same format as the calculation's attachments.

(89) Level 4 Tvoe ADDiscrepancy

[See Reference A.21, Calculation PA H-XXX-1006GE]

There are no " Assumptions" referenced in this calculation, in Section 3.0 " Assumptions", but

" Assumptions" are made to perform this calculation and need to be identified.

(90) Level 3 Tvoe FD Discrepancy

[See Reference A.21, Calculation PA H-XXX-1006GE]

The Post-Accident Conditions (prior to SRAS) are considered as Normal Conditions, but the DR-0364. DOC Page 17 of 4 t t

I l

I

DISCREPANCY after SRAS Post-Accident Conditions are stated as a condition where the equipment is not qualified to function.

(9l) Level 3 7\\veFDDiscrepancy

[See Reference A.21, Calculation PA XX-XXX-1006GE]

Appropriate margins are not used for the inoication loop uncertainty, since it conflicts in a non-conservative manner with the actual allowances in Surveillance Procedure IC2429A it need be addressed.

PA XX-XXX-1128GE Rev. O, " Millstone 2 - HPSI Discharee Pressure Loop Accuracy Calculation" (92) Level 3 hve DOD Discrepancy

[See Reference A.21, Calculation PA XX-XXX-1128GE]

The control room indication's total loop uncertainty is calculated as

• 1.3% Span (* 22.75 psi) but the Surveillance Procedure IC2429A allows 2.0% Span (* 35 psi).

(93) Level 3 hye DID Discrepancy i

[See Reference A.21, Calctdation PA XX-XXX-1128GE]

The Drift Effects error is not included for the Dixson Indicator in this calculation. A separate Drift evaluation exists that identifies what the plant drift is for the Dixson Indicator.

(Calculation 93-039-01239E2 r. 0 uses

• 0.64% span)

(94) Level 4 hveMDiscrepancy (See Reference A.21, Calculation PA XX-XXX-1128GE]

The range for PT-30lX is listed as 15 to 1765 psig on the nameplate of the transmitter, yet 0 to 1750 psig is used in the calculation and in the Surveillance Procedure IC2429A.

l (95) Level 3 hveEEDDiscrepancy

[See Reference A.21, Calculation PA 20C-XYX-1128GE]

Sensor Temperature Effects are specified for a temperature variation of 20*F for the transmitter location in this calculation. The room variation is much greater than 20 F for the temperature differential from the rooms minimum temperature to the rooms peak temperature.

(96) Level 4 Type DOD Discrepancy

[See Reference A.21, Calculation PA XX-XDC-1128GE]

The Overall Computer's Accuracy (OCA) has an uncertainty calculated as

• 0.1% Span (*

0.175 psi) but the Surveillance Procedure IC2429A allows

• 0.5% Span (t 8.7 psi).

(97) Level 3 hyeMDDiscrepancy

[See Reference A.21, Calculation PA XX-XXX-1128GE]

The M&TE Terms Used in Calculations for Instrument Loop Uncertainties are not calculated properly. The M&TE have the same Uncenainties as any other instrument, and these effects are discussed in ISA-RP67.04 Pan II dated 1994 and ISA S51.1 dated 1979. The M&TE Reference Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8) is not an Effect, but is used as the M&TE's Span which is used by each Effect. The M&TE overall Accuracy Term (MTE)is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (1.) Calibration Effects, (2.) Calibration Standard Effects, (3.) Temperature Effects, (4.) Drift Effects, (5.) Readability / Resolution Effects, (6.)

Power Supply Effects, (7.) Miscellaneous Effects, and also (8.) Incorrect Spans were used for some of the M&TE. These concerns are described in Discrepancy Report DR# 0129.

l DR 0364. DOC Page 18 of 41 l

l o___________-__

DISCREPANCY (98) Level 3 hpe MD Discrepancy

[See Reference A.21, Calculation PA H-XXX-1128GE]

<Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE (Sensor) and the

~

Rack's M&TE need to be considered. This needs to be addressed.

(99) Level 3 hpe DID Discrepancy

[See Reference A.21, Calculation PA XX-XXX-Il28GE]

The Sensor M&TE uses only a Heise Pressure Gauge for calculating the MTE term used in section 4.10, but the Transmitter (Sensor) uses both a Heise and a DMM to perform its calibration per Surveillance Procedure IC2429A. The DMM needs to be added.

(l00) Level 4 hpe AD Discrepancy

[See Reference A.21, Calculation PA XX-XXX-1128GE]

There are no " Assumptions" referenced in this calculation, in Section 3.0 " Assumptions", but

" Assumptions" are made to perform this calculation and need to be identified.

(10l) Level 3 hpe FD Discrepancy

[See Reference A.21, Calculation PA XX-XXX-1128GE]

The Post-Accident Conditions (prior to SRAS) are considered as Normal Conditions, but the after SRAS Post-Accident Conditions are stated as a condition where the equipment is not qualified to function.

(102) Level 3 hpe DOD Discrepancy

[Sce Reference A.21, Calculation PA XX-XXX-1128GE]

Appropriate margins are not used for the indication loop uncertainty since it conflicts in a non-conservative manner with the actual allowances in Surveillance Procedure IC2429A. Also, the issue over when the loop needs to function need to be addressed. The Technical Specification Bases 3/4.1.2 require the pump discharge pressure to be greater than or equal to 1125 psig. Its is not clear if this is nominal number or a value requiring uncertainties to be applied.

D. CST Level Calculation Related Discrepancies Calculation # 90-032-0293E2, MP2 Condensate Storace Tank (CST) Level Loon Accuracy I 5280,I,5282,I,5489 (l03) Level 3 7\\pe DID Discrepancy CST Level pulls a vacuuin when draining. A vacuum Breaker is installed to prevent the vacuum created in the tank due to pumping down the water from exceeding approximately- 0.3 osi which is approximately 6 to 9 inches oflevel. Note that the Differential Pressure gauge thinks the level is lower than it is inside the tank due to the less dense water at - 0.3 osi (vacuum).

(l04) Level 4 Tvoe DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

l This calculation assumed a condensate storage tank maximum water temperature of 93 F, and i

referenced Tank Specification 7604-C-43 as the design input. The Piping Class Summary 7604-MS-1 listed the temperature as 100 F. Therefore, in the 11/20/97 conference call Millstone was asked the basis for using 93 'F. They responded on 11/25/97 that they did not have a documented basis and that a DR should be written. DR- 0171 has been written to cover this S m.

DR-0364. DOC Page 19 of 41 I

L------------________-.._________________-.

DISCREPANCY (l05) Level 3 Tsve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Page 23 references calculation PA-XX-XXX-573-GE, Rev. O, as design input for a 0.4%

MTE allowance. The referenced calculation is now at Rev.1, and uses a value of 0.75% for MTE allowance and the Parent Calculation was not revised.

(l06) Level 3 Tvve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Page 24 references calculation PA-XX-XXX-948-GE, Rev. O, as design input for a 2.5%

allowance for Overall Indicator Accuracy (OAI) for the GE 180 indicator (LI-5282-1). The referenced calculation is now at revision I and no longer covers a GE 180 indicator. However, page 62 of calculation 90-032-293-E2 is a data sheet on the GE 180 indicator. This data sheet lists reference accuracy of the GE 180 indicator as i 1.5% FS and repeatability as 2.0% FS which when combined by SRSS methodology yields 2.5%. In addition, uncertainty due to drift, power supply effect, and temperature effect must be considered. Therefore, the OAI for the indicator is non-conservative and does not conform to design input.

(107) Level 3 Type MD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Page 34 references a letter from ITT Barton (pages 53 and 54 of calculation) as the basis for 0.0 allowance for sensor drift for LIS-5489 (Barton 288A). ISA Standard 67.04 defines drift as change over time. The letter stated that Barton defines drin as " mechanical wear," which is included within the instrument's accuracy specification. To use this 0.0 as a value for Sensor Drift is a misapplication of the design input. Standard drift, as change over time, should be determined for use in computing Total Probable Error (TPE) for the indicator and the alarm.

Drift can be determined via statistical analysis of calibration data on Barton 288A.

(108) Level 3 Tyne DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Page 36 states that the only indicator accuracy component not already included in is resolution (readability of the indicator) and thus lists the overall indicator accuracy (OIA) as 0.5%.

However, pages 60 and 61 of the calculation are from ITT Barton Product Bulletin 288A/289A-4. This bulletin lists pointer (indicator pointer) accuracy as 2% and pointer repeatability as 0.5%. OIA for the indicator is non-conservative and does not agree with the design input.

(109) Level 4 Tyve AD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Page 7, assumption 2, states tl.at temperature effect on transmitter sensing lines is negligible, and provides no basis. Our alternate computation shows that their assumption is correct, but a basis should have been given. Assumption 7 states that the accuracy of switch LC-5280 is assumed to be 2% without providing anyjustification as to the basis.

j (l10) Level 4 Tvve DID Discrepancy l

[See Reference A.31, Calculation 90-032-0293E2]

l On page 23, RD3, rack drift for a N-2AP+ ALM +AR and N-2AI-12V module in combination was assumed to be the same (0.5%) as for a N-2AI-I2V and N-2AO-VAI module in combination, though reference accuracy was for the first set was 1.0% while reference accuracy for the second set was only 0.25%. No basis was given for the drift assumption, and the value used may be non-conservative.

(l11) Level 3 Type AD Discrepancy DR-0364. DOC Page 20 of 41 I

DISCREPANCY I

[See Reference A.31, Calculation 90-032-0293E2]

On page 41, RCA (including drift and temperature effect, and all other errors) for the pneumatic alarm module is assumed to be 2.0%. No basis is given for the value. A statistical analysis of -

j calibration data from past calibrations of Custom Components Model 6864G1 switches could be used to determined drift and possibly temperature effect if calibrations were done in different seasons.

(ll2) Level 3 Tvve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

\\

Calculated uncertainty is added to the required level to establish required setpoints. This f

calculation adds 2.5% for operator response time. It refers to an internal company memo from Ed Foster to Bill Quinton for the 2.5% number. No basis is given in the memo or calculation as to how the 2.5% figure was calculated. No other margin is used.

(l13) Level 3 hpe MD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

T'.e terminology of Westinghouse Setpoint Methodology is used in this calculation, but the

' terms are combined per IS A RP67.04 methodology. Allowance for calibration tolerance (sometimes called setting tolerance), used per ISA RP67.04 methodology, was not included.

Westinghouse Setpoint Methodology compensates for not using this term. SD, SMTE, and SCA are summed and RCA, RMTE, RSCA, and RD are summed before squaring for use in the square root of the sum of squares equation. This results in a larger allowance than if each term were squared and used in the square root of the sum of squares equation independently, and is done since Westinghouse Methodology considers that these parameters may be interactive. ISA RP67.04, paragraph 6.2.6.2 step c, third method, allows this sununing together before squaring for use in the square root of the sum of squares equation as an acceptable alternative to including a calibration tolerance allowance. ISA RP67.04, paragraph 6.2.6.2, steps b and d, define other methods which would allow exclusion of a calibration tolerance term in the uncertainty computation. Review of the subject calculation does not indicate that these steps have been applied. Therefore, the calibration tolerance term should have been applied, and the method used for the accuracy calculation was non-conservative and not acceptable.

(114) Level 3 hpe MD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

ISA RP67.04 states uncertainties associated with seismic effects due to a safe shutdown or operating basis (OBE) earthquake are included (by an SE term). Millstone states that all instruments to be used after a SSE with be extensively re-evaluated (our assumption is that they would be at least checked to be within calibration values) before use. No uncertainty is allowed for post OBE seismic uncertainty. Typically, no uncertainty is assumed unless the OBE is at least of % SSE magnitude. Therefore, Instruments that must function after an OBE should include an SE term for a seismic event of at least % SSE magnitude.

(?.15) Level 3 hpe DOD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

l FSAR section 10.4.5.3/page 10.4.7 states that at operational low level, volume available in the i

CST is 150,000 gallons. Based on non-conservatism in the way the setpoint is calculated and established, the water level could possibly reach a lower level.

(l16) Level 3 Type FD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Operational procedures. Technical Specification Sections 3.7.1.3, and FSAR section 10.4.5.3 f

DR-0M4. DOC Page 21 of 41 l

1

DISCREPANCY t

require that minimum volume of the Condensate Storage Tank be no lower than 150,000 for modes I,2, and 3. Actions required by the Technical Specification are a) restore the water vohime to within the limit or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or b) Demonstrate

• operability of thefirewater. system as a backup supply to the auxiliaryfeedwater pumps and restore the condensate storage tank water volume to within its limits within 7 days or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

()17) Level 3 Tsve ALDiscrepancy

[See Reference A.31, Calculation 90-032-0293E2]

With the setpoint for 150,000 gallons established non-conservatively, the plant could be below the limit without knowing that the LCO condition should be entered.

+

(118) Level 3 Tsve ABDDiscrepancy (See Reference A.31, Calculation 90-032-0293E2]

Design inputs documenting elevation of centerline ofinstmments, low-low alarm level, and allowance for operator response time for minimum volume alarm are based on Inter Office memos. Many design inputs are based on superseded calculations. Although these calculations may not have been superseded when this calculation was prepared, some have changes which impact this calculation.

(119) Level 4 Tsve DlD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Maximum temperature for the condensate storage tank water was listed as 93 'F by the calculation. A question on this was responded to by Millstone on 11/25/97, that they did not have a documented basis and that a DR should be written. DR- 0171 has been written to cover this item.

(120)Le. vel 3 Tsve CDDiscrepancy

[See Reference A.31, Calculation 90-032-0293E2]

The setpoints associated with loop L-5282 were found to be documented in Condensate Storage Tank Level calibration procedure IC2429E. However, a computer search of all Millstone Unit 2 Basis Procedures did not find any calibration procedures which documented

{

the setpoints of the Low-Low Level Alarm (loop L-5489) or of the Minimum Alarm Setpoint

{

(loop L-5280). The Minimum Alarm Setpoint (loop L-5280)is a Technical Specification (section 3.7.1.3) required value.

(l21) Level 3 Tspe DOD Discrepancy i

l

[See Reference A.31, Calculation 90-032-0293E2]

\\

Alarm Response Procedure ARP 2590D shows the nominal value of these setpoints and not the actual calibrated values which have corrections for pmcess and instruments inaccuracies.

However, pages 49D and 49C of the procedures each have a note which is in conflict with the calculation. The note states, "Due to pressure variations in the CST, indicated level may vary from actual level. CST minimum and low-low level alarm instmments are calibrated to i

compensate conservatively for fluctuating tank pressure assuming the loss of I breather valve.

This is not the case for indication instruments and normal high and low level alarms, which ace calibrated for normal pressures and normally high operating level, due to needed accuracy of level indication under normal conditions."

I (l22) Level 3 Tvoe CD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

The calculation allows for pressure variations due to loss of 2 breather valves (-5.0 INWC to

+9.0 INWC). Also, the calculation does include this inaccuracy in establishing normal high and DR-0364. DOC Page 22 of 41 I

)

DISCREPANCY low level alarm setpoints associated with loop (L-5282). These inaccuracies are also included in computations for indication uncertainty, but would not figure into calibration of the indicators.

~

(l23) Level 3 Type _l10D Discrepancy e

[See Reference A.31, Calculation 90-032-0293E2]

EOP Procedure 2537, Rev.12 was reviewed to determine how uncertainty for the indication as computed from this calculations for loop L-5282 was applied in initiating operator response.

No allowances were included for instrument or process uncertainties as analyzed in the calculation. A 3% uncertainty was added to the CST minimum level requirement (from S3% to 56%)', but this does not match the value for uncenainty as determined in the calettlation.

(l24) Level 3 hpe FD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

After an OBE seismic event, the minimum CST inventory required by Technical Specification section 3.7.1.3 would still be required. Post seismic uncertainty due to an OBE of % SSE magnitude (typical) has not been considered. Though not a setpoint, the indicated value for this level via loop L-5282 indicator (PAM) also has not considered this uncertainty.

(l25) Level 3 hye DIDDiscrepancy

[See Reference A.31, Calculation 90-032-0293E2]

L-5280, L-5282, L-5489, Rev. 01, and 90-032-436-E2, Rev. O, Condensate Storage Tank (CST) Minimum Alarm Set Point Calculation (L5280), Rev. O, were reviewed for compliance I

with accepted industry standards, and found to be non-conservative.

I The terminology of Westinghouse Setpoint Methodology is used in this calculation, but the terms are combined per ISA RP67.04 methodology. Allowance for calibration tolerance (sometimes called setting tolerance), used per ISA RP67.04 methodology, was not included.

Westinghouse Setpoint Methodology compensates for not using this term. SD, SMTE, and SCA are summed and RCA, RMTE, RSCA, and RD are summed before squaring for use in the square root of the sum of squares equation. This results in a larger allowance than if each term were squared and used in the square root of the sum of squares equation independently, and is done since Westinghouse Methodology considers that these parameters may be interactive. IS A RP67.04, paragraph 6.2.6.2 step c, third method, allows this summing together before squaring for use in the square root of the sum of squares equation as an acceptable alternative to including a calibration tolerance allowance. ISA RP67.04, paragraph 6.2.6.2, steps b and d, define other methods which would allow exclusion of a calibration tolerance term in the uncertainty computation. Review of the subject calculation does not indicate that these steps have been applied. Therefore, the calibration tolerance term should have been applied, and the method used for the accuracy calculation was non-conservative and not acceptable.

(l26) Level 3 hye MD Discrepancy (See Reference A.31, Calculation 90-032-0293E2]

ISA RP67.04 states uncertainties associated with seismic effects due to a safe shutdown (SSEl t

or operating basis (OBE) eanhquake are accounted for (by an SE term). Millstone states that all instruments to be used after a SSE with be extensively re-evaluated (our assumption is that they would be at least checked to be within calibration values) before use. No uncenainty is allowe'. for post OBE seismic uncertainty. Typically, no uncenainty is assumed unless the OBE is at least of % SSE magnitude. Therefore, Instruments that must function after an OBE should l

I DR-0364. DOC Page 23 of 41

!L____-_____

uvuswamNay I

include an SE term for e seismic event of at least % SSE magnitude.

(l27) Level 3 T pe MD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

The methodology of SP-EE-315, Rev. I was not followed in establishing the setpoint. TA: was not calculated. Perhaps monthly surveillance are not done on this loop. If this is the case, the RCA and RD (if any) must be included in the TA: computation, or else the results will be non-conservative. They were not included in TA: here. Instead, RD and RTE are broken out of RCA, and RD is not used at all.

(l28) Level 3 Tspe MD Discrepancy

[See Reference A.31, Calcula: ion 90-032-0293E2]

If TA is not computed and used in establishing the setpoint, tai must equal TPE as computed 2

in calculation 90-032-293-E2, Rev.1 (with corrections as noted on review) and it doesn't.

(l29) Level 3 Tsve MD Discrepancy l

[See Reference A.31, Calculation 90-032-0293E2]

l No value was analyzed for ISA 67.04 drift defined as " change over time" for LIS-5489 Alarm (Barton 288A) because a Barton specialist defined drift as " mechanical wear." This is considered a non-conservative assumption. Statistical analysis of or a check with other utilities to obtain drift data on the Barton 288A should have been used to determine change over time.

{

(l30) Level 3 T ve DID Discrepancy

[Se<. Reference A.31, Calculation 90-032-0293E2]

Drift (RD3) for (N-2AP-ALM-AR and N-2AO-VAI) modules in combination was considered i

the same as ( RDI) for (N-2AI-ILV and N-2AO-VAI) modules in combination, though other accuracy parameters were much larger for the former. No basis was given for the assumption.

(l31) Level 3 Tsve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Several memos and letters are used as design input to provide instmment centerline elevation, process temperatures and pressures, analyticallimits, operator response time values, etc. Two party sign offis required for walk down data. Issued drawings or specifications should be referenced for temperature and pressure values. Calculations or basis documents should be referenced for analytical or process limits, such as CST Low and Low-Low level alarm.

(l32) Level 3 Tsve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Several calculations are referenced that are at later revisions than referenced. Though these calculations were issued later than the subject calculation, their changes should have keyed revision of the subject calculation. Examples are PA XX-XX-573GE Rev.1, which changed the value of MTE uncertainty from that used in Rev. O and incorporated into the subject calculation, and PA XX-XX-948, Rev.1, which no longer has the data on a GE 180 indicator that was used in the subject calculation.

l (l33) Level 3 Tsve DID Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Vendor documents showing instrument uncertainty was not always thoroughly analyzed. As an example, the calculation uses 2.5% from another calculation as OIA for a GE 180 indicator, but Page 62 of calculation 90-032-293-E2 is a data sheet on the GE 180 indicator. This data sheet lists reference accuracy of the 180 indicator as 1.5% FS and repeatability as i 2.0% FS which when combined by SRSS methodology yields 2.5%. In addition, uncertainty due to drift, DR-0364. DOC Page 24 of 41 i

l

uvum.u w s tGV power supply effect, and temperature effect must be considered in Overall Indicator Accuracy 1

l (01A).

(l34) Level 3 Tspe DOD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

Based on methodology and non-conservative assumptions used in this calculation the PAM level indicator total probable error, TPE% %, uncertaintyis estimated to ta -0.84%, +

0.69% of full span more than documented by the calculation. The PAM level Recorder total probable error, TPEn.., uncertainty is estimated to be -0.93%, + 0.78% of full span more than documented by the calculation.

]

(l35) Level 3 Trye DOD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

l LIS-5489 Alarm total probable error, TPE,um, uncertainty is estimated to be -0.66%, +

f 0.52% of full span which is more than calculated in the calculation.

l If the maximum temperature is higher than 93 F, the water will be less dense at maximum l

temperature than considered in the calculation and the result will be a slightly larger magnitude negative bias process error (the water level will be higher than the instrumentation reads). The -

0.461 % span uncenainty (span is from 22,645 to 250,000 gallons or 21 to 331 INWC for L-5282)is computed in the calculation assuming 93 F. Assuming that the maximum temperature j

is 100 *F as per Piping Class Sununary 7604-MS-1, this process error is - 0.597 % span.

Then, instead of-1.976, + 3.092, the bias uncertainty is - 2.112, + 3.092.

(l36) Level 3 Tsve Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

L-5280 Alarm (T/S Minimum Volume), TPE.uo, uncertainty is estimated to be -0.19 %, +

0.04 % (not significant) of fU: span more than documented in the calculation.

(l37)Leve13 Type MD Discrepancy

[See Reference A.31, Calculation 90-032-0293E2]

None of the above TPEs include post OBE seismic uncertainty since no device specific data is i

available upon which to base an estimate. A small additional TPE increase due to post seismic uncertainty resulting from an OBE of % SSE magnitude could be expected.

l Calculation # 90-032-0436E2, MP2 Condensate Storaee Tank (CST) Minimum Alarm Set Point Calculation L-5280,1 5282,I 5489 l

(l38) Level 3 Trpe DID Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

The methodology of SP-EE-315, Rev. I was not followed in establishing the setpoint. TA2 was not calculated. Perhaps monthly surveillance are not done on this loop. If this is the case, the RCA and RD (if any) must be included in the TA: computation, or else the results will be non-conservative. They were not included in TA here. Not all the relevant data from calculation i

90-032-436-E2, Rev.1, such an allowance for operator response time, is used in establishing l

CST Minimum Tech Spec Volume Alarm Set Point.

(l39) Level 3 Tsp _e.ADDiscrepancy

[See Reference A.30, Calculation 90-032-0436E2]

On pages 7 and 9, values for RCA, drift (RD) and temperature effect (RTE) for the Custom Components Model 6864G1 switch module are assumed. No basis is given for the value used; thus, it cannot be considered reliable. A statistical analysis of calibration data from past l

DR-0364. DOC Page 25 of 41 E..___.__.--

wusmunuwEV calibrations of Custom Components Model 6864G1 switches could be used to determined drift

~

and possibly temperature effect ifcalibrations were done in different seasons. Likewise, an analysis of"as good as can be achieved""as left" values for Model 6864G1 switches could be '

reasonably used for RCA.

(l40) Level 3 hve DOD Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Calculation 90-032-436-E2, Rev. O, disagrees with 90-032-436-E2, Rev.1, and does not consider operator response time.

(l41) Level 3 hpe AL Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

FSAR section 10.4.5.3/page 10.4.7 states that at operational low level, volume available in the CST is 150,000 gallons. Based on non-conservatism in the way the setpoint is calculated and established, the water level could possibly reach a lower level.

(l42) Level 3 Type FD Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Operational procedures, Technical Specification Sections 3.7.1.3, and FSAR section 10.4.5.3 require that minimum volume of the Condensate Storage Tank be no lower than 150,000 for modes 1, 2, and 3. Actions required by the Tech Spec are a) restore the water volume to within the limit or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or b) Demonstrate opes ability of the firewater system as a backup supply to the auxiliaryfeedwaterpumps andrestore the condensate storage tank water volume to within its limits within 7 days or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(l43) Level 3 hye AiDiscrepancy

[See Reference A.30, Calculation 90-032-0436E2]

With the setpoint for 150,000 gallons established non-conservatively, the plant could be below the limit without knowing that the LCO condition should be entered.

(144) Level 3 hve ADDiscrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Some assumptions are not reasonable and normal. Values for RCA, drift (RD) and temperature effect (RTE) for the Custom Components Model 6864G1 switch module are assumed. No basis is given for the value used. Additionally, some values brought forward from calculation 90-032-436-E2, Rev.1, are based on questionable assumptions.

(l45) Level 3 hye FD Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

\\

Calculation 90-032-436-E2, Rev.1 was the primary design input. It would have been expected to be reasonable and reliable, but did not prove so. Even so, not all the relevant data from l

calculation 90-032-436-E2, Rev.1, such an allowance for operator response time, is used in establishing CST Minimum Tech Spec. Volume Alarm Set Point.

(l46) Level 3 hve MD Discrepancy l

l

[See Reference A.30, Calculation 90-032-0436E2]

This calculation does not follow the methodology of SP-EE-315, Rev.1 in calculating CST Minimum Tech Spec Volume Alarm Set Point. Instead of using setpoint = Allowable value +

allowance 2, the calculation uses setpoint = analytical limit + allowance (in this case, allowance used was allowance 1 only).

(147) Level 3_ Type DOD Discrepancy DR 0364. DOC Page 26 of /t I

L---.----------.---------

uvtatremar

~

[See Reference A.30, Calculation 90-032-0436E2l EOP Procedure 2537, Rev.12, shows 3% uncertainty added to the CST minimum level requirement (from 53% to 56%), but this is less than the value for uncertainty as determined in' the calculation for the alarm. It is expected that the L-5282 Indicator would be used in the EOP. As noted above, a computer search of all Millstone Unit 2 Basis Procedures did not find any calibration procedures which documented the setpoints ofloop L-5280.

(IC-2429E " CST Level Calibration " does contain the Servoint for L-5280J (l48)L.evel3 Twe MD Discrepancy (See Reference A.30, Calculation 90-032-0436E2]

After an OBE seismic event, the minimum CST inventory required by Tech Spec section 3.7.1.3 would still be required. Post seismic uncertainty due to an OBE of % SSE magnitude (typical) has not been considered.

(l49)[evel4 Tspe DID Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Calculation 90-032-436-E2, Rev.1 assumed a condensate storage tank maximum water temperatt. e of 93*F, and referenced Tank Specification 7604-C-43 as the design input. The Piping Class Summary 7604-MS-1 listed the temperature as 10) F. Therefore, in the 11/20/97, 2:00 p.m. conference call Millstone was asked the basis for using 93 F. They responded on 11/25/97 that they did not have a documented basis and that a DR should be written. Effect of discrepancy: If the maximum temperature is higher than 93 "F, the water will be less dense at maximum temperature than considered in the calculation and the result will be a slightly larger magnitude negative bias process error (the water level will be higher than the instrumentation reads). As an example, -0.461 % span uncertainty (span is from 22,645 to 250,000 gallons or 21 to 331 INWC for L-5282) is computed in the calculation assuming 93 *F. If the maximum temperature is 100 *F as per Piping Class Summary 7604-MS-1, this process error would be -

0.597 % span. Thus, there could about 309 gallons more of water in the tank due to this discrepancy than used in the calculation in establishing the high alarm setpoint (L-5282). (See Reference E.8, DR# 0171 " CST Maximum Water Temperature")

(l50)[evel3 Twe DODDiscrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Most uncertainty values used in this calculation were brought forward from 90-032-293-E2, Rev. 01. However, the 2.5% additional volume added to the setpoint for operator response time in 90-032-293-E2, Rev. 01 was not used here. No explanation is given, so absence of this

'2.5% is considered an error in this calculation.

(l51) Level 3 T1pe DOD Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

L-5280 Alarm (T/S Minimum Volume), setpoint is estimated to be too low by (10.44 - 10.10) psi = 0.34 psi. This equates to 2.83 % span or 6026 gallons. The 2.83% includes the 2.5%

(5353 gallons) for operator response time included in calculation 90-032-293-E2, Rev. 01, but not included here.

l (l52) Level 3 Tspe DOD Discrepancy

[See Reference A.30, Calculation 90-032-0436E2]

Technical Specifications section 3.7.1.3 requires that the Condensate Storage Tank shall be operable with a minimum of 150,000 gallons in modes 1,2, and 3. With the non-conservatism in the subject calculations, it is possible for the level to go below 150,000 gallons without this condition being detected. Once the level is detected below 150,000 gallons. Technical DR-0364. DOC Page 27 of 41

!L-

DISCREPANCY Specifications allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to either restore the level to 150,000 gallons or demonstrate operability of the fire water system as a backup supply to the auxiliary feed pumps and to restore the condensate storage tank water volume to within its limits within 7 days. Note that without the allowance of 2.5% (5353 gallons) for cperator response time which was included in calculation 90-032-293-E2, Rev. 01, but not included in 90-032-436-E2, Rev. O, the setpoint is only around.33% or 703 gallons low. However, since 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are allowed in the Technical Specifications to restore the level to the minimum required volume, this allowance has little significance. Without this operator response time allowance but considering the other non-conservatism in the calculations, about 149,300 gallons would be available should the minimum volume setpoint be reached. Although it is possible that the Condensate Storage Tank water level could go below the 150,000 gallons Technical Specifications minimum requirement and be outside its design basis, it is thought that since the discrepancy,is relatively small, the system could still perform its design function. Also, the fire water system is a backup supply to the auxiliary feed pumps.

E. Pressurizer Pressure Calculation Related Discrepancies 92-030-1260E2 Rev. O, " Millstone 2 - Pressurizer Pressure Setpoint Analysis",

(l53) Level 4 hpe DID Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

Section 2.1 lists the " Design Inputs" as "None". This is misleading, and it appears that the

" References" in Section 2.2 are considered the " Design Inputs". Inputs are not clearly identified throughout the calculation.

(l54) Level 3 hpe DIDDiscrepancy

[See Reference A.2, Calculation 92-030-1260E2]

A memo attached to the Setpoint Analysis identifies the Analytical Limit for Pressurizer Pressure - Low as 1578 Psia and for Pressurizer Pressure - High as 2422 Psia. This Analytical Limit Memo is not a design document, yet it is referenced as a design input.

(l55) Level 3 hyeMDDiscrepancy 1

[See Reference A.2, Calculation 92-030-1260E2]

The Rack Drift (RD) term and Rack Accuracy (RCA) term are missing from section 5.1.

(l56) Level 3 hpe CDDiscrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The M&TE used in section 4.3 for MTE doesn't include the Transmitter Simulator 3

Uncenainty.

(

(l57) Level 3 hpe DOD Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The Surveillance Procedure uses an allowable tolerance of* 1.5 % for "As Found" & "As Left" allowances yet the Setpoint Calculation only allows 1.06%.

(l58) Level 3 hye DID Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The effects of the 2500 resistor are not included in this calculation and should be included either here or in th Loop Accuracy calculation. Note that the Calculation considers this to be

• 0.1% accurate, but the Surveillance Procedure uses an allowable tolerance of* 3.0 % for the l

DR-0364. DOC Page 28 of 41

DISCREPANCY input resistor. (See Reference I.E.15, DR# 402.)

(l59) Level 3 hve AL Discrepancy

[See Reference A.2. Calculation 92-030-1260E2]

The Pressurizer Pressure Setpoint Analysis Calculation conflicts or differs from other plant settings and requirements. The operating margins are greater than 6 Psi offdue only to a Psig transmitter versus a Psia transmitter installation offsets. It appears that the ESAS setpoint will exceed the Analytical Limit when Accident uncertainty effects are included (as presently installed).

(l60) Level 3 hve AL Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The results of this calculation for the Pressurizer Pressure Setpoint Analysis are not reasonable, nor accurate. In fact even the calculated results show the setpoint beyond the calculated Allowable Value, which by definition can't be correct. Also, it appears that the ESAS setpoint will exceed the Analytical Limit if Accident uncertainty effects are included as presently installed.

Reference Setnoint Eauivalent Setnoint Uncertainty UFSAR Table 14.1.5-4 (SLB ESAS)

> 1606.3 Psig

> 1600 Psia

-22 Psi Setpoint Calculation (ESAS Trip) 1620 Psig

> 1601 Psia

+22.6 Psi SP2404B (Trip ESAS) 1620 Psig 1613.7 Psia FS AR Sect 6.3 (SIAS ESAS) 1591.3 Psia

> 1585 Psig FSAR Sect 7.3.2.2 (a.) (Trip ESAS)

> 1606.3 Psig

> 1600 Psia FSAR Sect 7.3.2.13 shows the range as 1500 PSI _A to 2500 PSI _A instead of the 1500 PSIG to 2500 PSIG that was used.

(l61) Level 3 hpe MD Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The Setpoint Analysis Calculation evaluations are system calculations / analyses and do not reflect the current plant configuration. The calibrated span of the Pressurizer Pressure transmitters are calibra:ed from 1000 to 2500 Psig to support the actual Plant requirements of 1000 to 2500 Psia. The Pressurizer Pressure transmitters are gauge pressure transmitters (1000 to 2500 Psig) but without compensation become Absolute readings in Psia (1000 to 2500 Psia) on the RPS & ESAS Trip Bistables and also the Control Room Indication.

(l62) Level 3 hye Abu Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

The Setpoint Analysis is based on the input from the Loop Uncertainty Calculation where the value for a 46 foot column of water below the tap being the installed configuration of the transmitter. This causes a considerable offset to be accounted for in the Setpoint Analysis. The transmitter is actually between 46 feet and 49 feet for the Pressurizer Pressure transmitters.

This difference was not evaluated.

l 1

(l63) Level 3 hpe DOD Discrepancy

)

[See Reference A.2, Calculation 92-030-1260E2]

Calculation W2-517-301-RE Revision 0, "MP-2 Measurement Uncenainties" dated 3/3/82 calculates a loop uncenainty for Pressurizer Pressure (P-102 Loop) as

• 19.4% Span for 18 L

l months (22% Month Maximum) as a basis for the

• 22 Psi used for the Reload Analysis.

DR-0364. DOC Page 29 of 41

DISCREPANL (

Calculation W2-517-357-RE Revision 0,"MP-2 Reanalysis of Measurement Uncertainties" dated 4/15/83 calculates a loop uncertainty for Pressurizer Pressure (P-102 Loop) as 20.2%,

Span for 18 months (22% Month Maximum) as a basis for the 22 Psi used for the Reload Analysis.

This calculation 92-030-1260E2 Rev. O, " Millstone 2 - Pressurizer Pressure Setpoint Analysis" dated 7/23/95 calculates a loop uncertainty for ESAS Pressurizer Pressure (P-102 Loop) as

+22.6% Span -12.2% Span for 24 months (30 Month Maximum) as a basis for the

• 22 Psi used for the Reload Analysis. Note that the uncertainty for RPS Pressurizer Pressure (P-102 Loop) as +22.5% Span -12.1% Span for 24 months (30 Month Maximum) as a basis for the

• 22 Psi used for the Reload Analysis.

All three calculations are still valid yet reflect different values for the same loop instruments.

This is a Discrepancy, and note that the +22 Psi is exceeded.

(164) Level 3 Twe FD Discrepancy

[See Reference A.2, Calculation 92-030-1260E2]

All of the Safety-Related Functions for the Pressurizer Pressure loops need to be addressed.

The PORV setting and the TM/LP value (the TM/LP fixed value included) were not evaluated for the overall loop uncenainty which includes the offset effects. This is a significant Discrepancy.

PA XX-XXX-0573GE Rev.1, " Millstone 2 - Pressurizer Pressure Loop Accuracy Calculation" (l65) Level 3 Tvoe MD Discrepancy

[See Reference A.17, Calculation PA XX-)CfX-0573GE]

The M&TE Terms Used in Calculations for Instmment Loop Uncertainties are not calculated properly. The M&TE have the same Uncertainties as any other instmment, and these effects are discussed in ISA-RP67.04 Part II dated 1994 and ISA SSI.1 dated 1979. The M&TE Reference Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8) is not an Effect, but is used as the M&TE's Span which is used by each Effect.

The M&TE overall Accuracy Term (MTE) is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (a.) Calibration Effects, (b.) Calibration Standard Effects, (c.) Temperature Effects, (d.) Drift Effects, (e.) Readability /Resclution Effects, (f.) Power Supply Effects, other (g.) Miscellaneous Effects, and also (h.) Incorrect Spans were used for some of the M&TE. These concerns are described below:

(See Discrepancy Report DR# 0129)

(l66) Level 3 Tvoe MD Discrepancy

[See Reference A.17, Calculation PA XX-XXX-0573GE]

Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE and the Rack's M&TE need to be considered. This needs to be addressed.

(167) Level 3 Tvve MD Discrepancy (See Reference A.17, Calculation PA XX-XXX-0573GE]

. The Loop Accuracy calculation is missing the Setting Accuracy Tolerance for both the Sensor and the Rack.

(l68) Level 3 Tvoe DID Discrepancy DR-0364. DOC Page 30 of 41 L-----_ _

DISCREPANCY

[See Reference A.17, Calculation PA XX-XXX-0373GE]

In Section 4.15 of this calculation concerning the Computer Accuracy (OCA) reads as follows:

"At the time this calculation was prepared, a new ICCM was under procurement. Accuracy of, the r;w ICCM will be provided by the vendor."

No UlR was referenced or found to document this missing uncertainty.

)

(l69) Level 3 Tsve DD Discrepancy I

[See Reference A.17, Calculation PA XX-XXX-0573GE]

Drift values are speculative at best. Some margin may be there since they were calculated for

{

30 months instead of the 22% months currently required in the Technical Specifications. (See Discrepancy Report DR# 0130)

(170) Level 3 Tspe DID Discrepancy

[See Reference A.17, Calculation PA XX-XXX-0573GE]

A bias term was calculated due to the height of the water column for the pressure transmitter

(

(46 feet from tap). The actual span heights in the field vary based on Millstone drawings.

1 (Example - PT-102C is located at over 48% feet below the tap.) Therefore, 46 feet is not accurate and should be addressed with at least an " Assumption".

(l71) Level 3 Tsve MD Discrepancy

[See Reference A.17, Calculation PA 20C-XXX-0573GE]

The bias term calculated is really not a bias but an " Offset". Therefore, it is always present. If an " Offset"is treated as a " Bias" then the Bias needs to be described as always present and affecting both the (+)TPE and the (-)TPE. (TPE is Total Probable Error.)

(172) Level 3 Tsve ADDiscrepancy

[See Reference A.17, Calculation PA XX-)CDC-0573GE]

Static Pressure Effect is not calculated and stated to be zero. This doesn't appear to be accurate. Rosemount and Barton Pressure transmitters have a static pressure effects when at pressures of> 1000 psi and the Pressurizer is normally at 2250 psi. This needs to be addressed.

(173) Level 3 TsveMDDiscrepancy

[See Reference A.17, Calculation PA XX-XXX-0573GE]

Seismic Effects per GDC 21 states that RPS/ESAS equipment must be able to withstand a Seismic Event and still maintain its Design Function. This doesn't mean concurrent events, but does mean that the RPS/ESAS equipment will not be disabled. Additionally, an OBE may not include a re-calibration, so it must be included in the Loop Uncenainty as a minimum. (See Discrepancy Repon DR# 0128)

(174) Level 3 Tspe FD Discrepancy (See Reference A.17, Calculation PA XX-X)DC-0573GE]

Accident Analysis values are not addressed properly and Accident conditions do apply and need to be addressed or added.

93-039-1132E2, Rev. O, " Millstone 2 - Pressurizer Pressure Transmitters Drift Analysis" (l75) Level 3 Tspe DD Discrepancy

[See Reference A.4, Calculation 93-039-1132E2]

This calculation addresses Drift but not in a manner that is correct. This revises a Design Input to the Setpoint Analysis and Loop Uncertainty Calculations. This reduces the overall operating Margin. (See DR-0129 on Drift Analysis.)

(176) Level 3 Type DDD Discrepancy DR-0364. DOC Page 31 of 41

{

l

DISCREPANCY

[See Reference A.4, Calculation 93-039-1132E2]

Calculation W2-517-301-RE Revision 0,"MP-2 Measurement Uncertainties" dated 3/3/82 calcult.tes an uncertainty for dria based on actual field calibration data ("As Found") from 4/17/79 to 9/13/80 as

• 1.0% Span for 18 months (22% Month Maximum) based on a deviation l

l of-0.775% Span for PT-1028 (Foxboro El1GM Transmitter).

Calculation W2-517-357-RE Revision 0,"MP-2 Reanalysis ofMeasurement Uncertainties" dated 4/15/83 calculates an uncertainty for drin based on the same actual field calibration data

("As Found") but from 4/17/79 to 8/26/80 as

• 1.75% Span for 18 months (22% Month Maximum) based on a deviation of +1.475% Span for PT-102B (Foxboro El1GM

, Transmitter).

This calculation 93-039-1132E2, Rev. O, " Millstone 2 - Pressurizer Pressure Transmitters Drift Analysis" dated 7/23/95 calculates an uncertainty for dria based on the same transmitters but from 1/21/88 to 12/18/92 as

• 0.41% Span for 24 months (30 Month Maximum) based on a standard deviation analysis for P Z-102 A, B, C, & D (Foxboro El 1GM Transmitter).

All three calculations are still valid yet reflect different values for the same instmments.

PA 78-771-424GE Rey, 0, " Millstone 2 - Pressurizer Pressure ESAS Input.

(l77) Level 4 hpe DID Discrepancy

[See Reference A.12, Calculation PA 78-771-424GE]

There are no " Design Inputs" referenced in this calculation, but input parameters are used and i

are somewhat reasonable. " Design Inputs" are needed, and need to be referenced.

(l78) Level 3 hve DID Discrepancy

~

[Sce Reference A.12, Calculation PA 78-771-424GE]

Rack Temperature Effects and Dria are missing from this calculation.

(179) Level 3 hye PED Discrepancy (See Reference A.12, Calculation PA 78-771-424GE]

The Accident Environment ESAS inputs calculation do not address process conditions and i

effects that are applicable but aren't included in the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects.

(180) Level 3 hpe AD Discrepancy

[See Reference A.12, Calculation PA 78-771-424GE]

There are no " Assumptions" referenced in this calculation, but " Assumptions" are made to perform this calculation and they would result in similar results. The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's own Methodology for calculating Accident Environment ES AS inputs environment inaccuracies.

Some items missing are the " Ambient / Accident Temperature" Effects, Dria Effects, and l

Process Measurement Allowances (PMA).

)

I PA 78-771-439GE Rev. O, " Millstone 2 - Pressurizer Pressure Control Room Indication" (l81) Level 3 hye DID Discrepancy (See Reference A.16. Calculation PA 78-771-439GEJ DR-0364. DOC Page 32 of 41

f DISCREPANCY l

The PAM calculation do not address process conditions and effects that are applicable but aren't included in the calculation. Installation offsets, Psig transmitter ambient pressure considerations during an accident, and IR effects are some of the missing effects. The PAM Calculation does not include the uncertainty due to readability of the indicator. Rack Temperature Effects and Drift are missing from this calculation.

(l82) Level 3 hve AD Discrepancy

[See Reference A.16, Calculation PA 78-771-439GE]

The Assumptions listed are missing and insufficient to logically apply the methods of the EPRI, ISA and Millstone's own Methodology for calculating PAM environment inaccuracies. Some items missing are the " Ambient / Accident Temperature" Effects, Drift Effects, Prdcess

(

l Measurement Allowances (PMA) and the Control Room Recorder's Readability Error l

(RDIND).

1 F. RWST Level Calculation # 92-030-1259E2Related Discrepaneles (l83) Level 4 Tvoe DID Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

Section 2.1 lists the " Design Inputs" as "Not Applicable" This is misleading, and it appears that the " References" in Section 2.2 are considered the " Design Inputs". Inputs are not clearly j

identified throughout the calculation.

l (l84) Level 3 hye DIDDiscrepancy

[See Reference A.1, Calculation 92-030-1259E2]

\\

A memo attached to the Setpoint Analysis identifies the "High" Analytical Limit for RWST Level

{

SRAS trip as 66 inches and the " Low" Analytical Limit for pump NPSH as " Exists". This Analytical Limit Memo is not a design document, yet it is referenced as a design input. The calculation has a footnote that addresses the " Low" Analytical Limit for NPSH as not of concern because of the elevation of the RWST relative to the safety injection pumps.

(l85) Level 3 hveMDDiscrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The Rack Drift (RD) term and Rack Accuracy (RCA) term are missing from section 5.1.

(l86) Level 3 hpe FD Discrepancy l

{

[See Reference A.1, Calculation 92-030-1259E2]

\\

The M&TE used in section 4.3 for MTE3 doesn't include the Transmitter Simulator Uncertainty.

I (187) Level 3 hpe DOD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The Surveillance Procedure uses an allowable Loop tolerance of 9.0 Inches H O for"As 2

Found" & "As Left" allowances yet the Setpoint Calculation states that the 0.28 mAdc for

" Loop As Found" &

• 0.26 mAdc " Loop As Left" allowances which are only 7.46 Inches H2O I

for"As Found" &

• 6.93 Inches H2O for"As Left" and not conservative. Note that the calculation tabulates milli-amps together of two different ranges 10 to 50 mAdc and 4 to 20 l

mAdc and this is misleading, confusing and not documented.

l l

(188) Level 3 hve DOD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The effects of the 2500 resistor are not included in this calculation and should be included either here or in the Loop Accuracy calculation. Note that the Calculation considers this to be

• 0.1%

DR-0364. DOC Page 33 of 41

DISCREPANCY accurate and negligible, but the Pressurizer Pressure Surveillance Procedure uses an allowable tolerance of 3.0 % for the input resistor that is not tested in this Surveillance Procedure.

(l89) Level 3 Tsve DOD Discrepancy

[See Reference A.I. Calculation 92-030-1259E2]

The RWST Setpoint Analysis Calculation (92-030-1259E2) calculated a setpoint value (SRAS 5 55.1 Inches H2O above the tank bottom or < 49.1 Inches H O above the discharge pipe) that 2

does not match the UFSAR value (SRAS = 4 FT - Section 7.3.2.2.f or SRAS = 4 FT i 18 Inc

- Section 6.2.3.1) which has no reference point given for the setpoint. The Technical Specification value (SRAS = 4 FT

• 9 Inches - TS Table 3.3.4) which has a reference point given as above the tank bottom, and the RWST Surveillance Procedure SP 2403E and SP2403M (SRAS = 41.8 Inches H2O) value do not agree with the RWST Setpoint Ana:ysis Calculation.

(l90) Level 3 Tspe DOD Discrepancy (See Reference A.1, Calcrdation 92-030-1259E2]

The RWST is used for different scenarios but they are not addressed in this calculation. The RWST is used in a Large Break LOCA, Small Break LOCA, and provides equal amounts of makeup water for sub-cooled and saturated Steam Generator Tube Rupture (SGTR) recovery methods for Low-Low Level ESAS trips, High Level alarm to prevent Overflow, and Low Level to alarm Minimum Technical Specification levels. These all need to be addressed in this calculation. Note that calculation S-01228S2 rev. O," Millstone 2 Emergency Operating Procedure Setpoint Documentation" identifies an EOP required operator action based on 6%

level for a low value which is right at the 0% calibration point which may never be read with uncertainties included.

(l91) Level 3 Tspe DOD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The Technical Specification Section 3.5.4 requires a 370,00 GALLON volume between the low level alarm and the RWST Level SRAS set point which should be the basis for the Setpoint Analysis. The existing setpoint does not necessarily maintain a 370,00 GALLON volume and it is not even addressed as part of this calculation. The RWST calculation's required purpose should be addressed. There are many conflicting calculations and values that need to be clarified from a process viewpoint for an accurate setpoint analysis. Other effects that indicate errors, differences, and missing information which would include vortex effects at low levels of the RWST need to be addressed with at least an Assumption.

(l92) Level 3 Tsve DOD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

Note, that the RWST Level Setpoint and Loop Uncertainty calculations calculate the overall "As Len" tolerance as

• 4.2 "H 0, but the RWST Level Surveillance Procedure's Calibration Setting 2

Tolerance ("As Len" tolerance) allows up to

• 9.0 "H20. Note, that the Setpoint and Loop Uncertainty calculations calculate the overall "As Found" tolerance as

• 2.06% Span or

• 9.06 "H2O (SRSS of 1.94% for the transmitter & 0.69% for the Rack) which is corresponds with the Surveillance Procedure's Calibration Setting Tolerance ("As Found" tolerance) of

• 9.0 "H20.

(l93) Level 3 Tspe MD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

Note that an M&TE term is added to the "As Len" value as a measurable error in the Setpoint l

Analysis calculation, but this is a conservative allowance. There would be no problem with this except that the "As Found" tolerance needs to address the M&TE term and the "As Len" M&TE 1

term also. Neither M&TE term is accounted for in the "As Found" tolerance.

l DR-0364. DOC Page 34 of 41

DISCREPANCY (l94) Level 3 7\\ve DOD Discrepancy x-

[See Reference A.1, Calculation 92-030-1259E2]

Note, that the actual setpoint set in the plant is 41.8 Inches from the top of the discharge pipe, which has no record or basis for its exact setting. While the value set is less than the setpoint analyzed in the Setpoint Analysis and within the bounds of the UFSAR and Technical Specification, it appears to have extra margin for the SRAS ESAS trip. Per our telecon with Millstone, the basis for the exact setting does not exist or wasn't found, for choosing a setting of exactly 41.8 Inches for the SRAS ESAS trip. No 50.59 Evaluation or Modification was provided to account for the plant's setting. This is a Discrepancy in the Process for implementing the setpoint.

(l95) Level 3 Twe FD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The ES AS setpoint Low-Low RWST Level Automatic trip is not analyzed for NPSH or to assure air doesn't get into the line.

(196) Level 3 hve ABDDiscrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The Setpoint Analysis Calculation evaluations are system calculations / analyses and do not reflect the current plant configuration. The processes used in the plant are not analyzed to assure the safe operation of the plant. The RWST is used in a Large Break LOCA, Small Break LOCA, and provides equal amounts of makeup water for sub-cooled and saturated Steam Generator Tube Rupture (SGTR) recovery methods for Low-Low Level ESAS trips, High Level alarm to prevent Overflow, and Low Level to alarm Minimum Technical Specification levels. These all need to be addressed in this calculation. Note that calculation S-01228S2 rev. O, " Millstone 2 Emergency Operating Procedure Setpoint Documentation" identifies an EOP required operator action based on 6% level for a low value which is right at the 0% calibration point which may never be read with uncertainties included.

(197) Level 3 hpe FD Discrepancy

[See Reference A.1, Calculation 92-030-1259E2]

The Operator Action point is too low and is not analyzed to include loop uncertainties. There is a concern that the RWST will be dry and allow air into the lines. Note, that vortex flow errors could be a problem on the low-low level setpoint and operator action points. It appears that vortex breakers are installed in the tank along with a screen cover, and this may reduce the error of vortex effects. This still needs to be addressed because of the lowest levels have the largest effects.

93-039-1149E2, Rev. O, " Millstone 2 - Refueline WaterStorace Tank Level Transmitters Drift Analysis" (l98) Level 3 hve DID Discrepancy

[See Reference A.7. Calculation 93-039-1149E2]

This calculation addresses Drift but not in a manner that is correct and this revises a Design Input i

to the Setpoint Analysis and Loop Uncertainty Calculations. (See DR#-0129 on Drift Analysis.)

l PA XX-XXX-1042GE Rev.1, " Millstone 2 - Refueline Water Storace Tank Level Loop Accuracy Calculation" l

(l99) Level 3 hpe ABDDiscrepancy

\\

(See Reference A.20, Calculation PA XX-XXX-1042GE]

DR-0364. DOC Page 35 of 41

DISCREPANCY A bias term (PMA) needs to be calculated due to the height of the water column for the pressur[

transmitter (2% inches below the tap). The calculation and the Calibration Procedure stipulate that the transmitter is located either at the tap or 4 inches above the tap for either a 2% inch or 6% inch disparity.

(200) Level 3 Tspe DID Discrepancy

[See Reference A.20, Calculation PA XX-XXX-1042GE]

In the RWST Level calculation section 4.15, it is stated that the Overall Computer Accuracy

[OCA)is assumed to be 0.1%. Yet, the Calculation for Pressurizer Pressure (PA XX-XXX-1042GE) states the vendor will provide the accuracy term in the future and 0% was used. Note that the RWST Surveillance Procedure (I&C Form 2403E-1) uses a tolerance allowance acceptance of the Overall Computer Accuracy [OCA] of* 0.5% which is 5 times greater than the RWST calculation. Also, the RWST Surveillance Procedure (SP 2403E, Attachment 2) uses a tolerance allowance for acceptance of the Overall Computer Accuracy [OCA] of* 2.0%.

(201) Level 3 Tspe ABDDiscrepancy

[See Reference A.20, Calculation PA XX-XXX-1042GE]

The span specified on Figure 1 of the RWST Level calculation is shown as 0 to 425"H 0. The 2

actual span shown in the calibration procedure is -l8 to 422 "H2O or (440" H2O). The 440" H O 2

span is also used in the Setpoint Analysis Calculation # 92-030-1259E2 Rev. O.

(202) Level 3 Trpe MD Discrepancy

[See Reference A.20, Calcination PA XX-XXX-1042GE]

The M&TE Terms Used in Calculations for Instrument Loop Uncertainties are not calculated properly. The M&TE have the same Uncertainties as any other instrument, and these effects are discussed in ISA-RP67.04 Part II dated 1994 and ISA S51.1 dated 1979. The M&TE Refere Accuracy Effects do not include the seven (1 through 7) Effects listed below. Item (8) is not an Effect, but is used as the M&TE's Span which is used by each Effect.

The M&TE overall Accuracy Term (MTE)is calculated using only the M&TE's Reference Accuracy Effects. The M&TE Terms are missing the (1.) Calibration Effects, (2.) Calibration Standard Effects, (3.) Temperature Effects, (4.) Drift Effects, (5.) Readability / Resolution Effects, (6.) Power Supply Effects, other (7.) Miscellaneous Effects, and also (8.) Incorrect Spans were used for some of the M&TE. These concerns are described below:

(See Discrepancy Report DR# 0129)

(203) Level 3 Tsye MD Discrepancy

[See Reference A.20, Calculation PA EXXX-1042GE]

Only 1 M&TE Term is used in section 5.1, but the Transmitter's M&TE and the Rack's M&TE need to be considered. This needs to be addressed or clarified. Ifsection 4.10 meant to envelope both cases then say so, and show that it does.

(204) Level 3 Tspe ABDDiscrepancy

[See Reference A.20, Calculation PA XX-XXX-1042GE]

Reference UIRH 2130 states that an instrument walkdown of the RWSTLevel transmitters, per the PI-07 Review, measured the transmitters at 3 inches belcw the tap, yet Parson 's walkdown rneasured the transmitters at 2% inches above the tap. A location above the tap definitely affects the uncertainty and must be accountedfor in the calcination..

(205) Level 3 Tspe CD Discrepancy Reference UIRH 2130 states that an instrument transmitters are calibrated only once in an increasing direction. This does not include Setting Tolerance (Hysteresis or Linearity either) and needs to be included (See DR# 0129)

DR-0364. DOC Page 36 of 41

DISCREPANCY (206) Level 3 Tspe DID Discrepancy (See Reference A.20, Calculation PA XX-XXX-1012GE]

The Maximum Boric Acid concentration was previously given in an earlier revisions of the Technical Specification's LCO as 2400 ppm. This LCO was subsequently removed but the Technical Specification Bases (3/4.5.2 & 3/4.5.3) still reflects a maximum concentration of 2400 ppm. Currently a minimum concentration of 1720 ppm is in the Technical Specification's LCO Section 3.1.2.8. These maximum and minimum concentrations ofBoric Acid need to be analyzed along with the maximum and minimum temperatures of the RWST to calculate the density variation for the borated water. The calculation assumes a 1.01 factor for density effects but does not verify its correctness.

2-ENG-031 Rev. O, " Millstone 2 - Lo-Lo Level Alarm and SRAS Actuation Setpoint for RWST" (207) Level 3 Tvoe FD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

This calculation does not address instrument loop uncertainties or plant process conditions and it needs to include or address uncertainties.

(208) Level 3 Tspe FD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

The tank's wall thickness was not addressed by this calculation.

(209) Level 3 Tvoe DOD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

The SRAS point is referenced to the bottom of the tank or top of the drain which revised the existing 30 inch setpoint to 48 inches

• 9 inches, but doesn't use a volume of 421,000 gallons or 370,000 gallons. The Technical Specification volume is 370,000 gallons and this calculations uses setpoints of 48 inches

• 9 inches and a Technical Specification value of48* 18 inches as the required setpoint value. (See Calculations TSCR-2-32-77-45GM & ID20-2.)

(210)Leve13 Tspe ADDiscrepancy

[See Reference A.22, Calculation 2-ENG-031]

There are no " Assumptions" listed and but the tank's wall thickness or loop uncertainties aren't addressed. This is not a valid Assumption. Other assumptions exist but are not documented such as a new trip point for SRAS (48

• 18 inches) and a measurable tank level span of 440 inches.

(211) Level 3 Tvoe FD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

The Low Level Alarm of 94% is addressed as 34 feet 6 inches or 414 inches above the top of the discharge pipe, but no loop uncertainties are applied to this setpoint. (Note this was 32 feet 6 inches above tank bottom before being changed by this calculation)

(212) Level 3 Tspe FD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

The instrument loop uncertainties must be included in any evaluation concerning the function of instrumentation to perform a safety-related action. Ncte, both the Low Level Alarm (94%) and the Low-Low Level SRAS trip point (9.55% or 42 inches above the top of the discharge pipe) loop uncertainties need to be addressed together to account for the Technical Specification limit of RWST Volume. All the functions of the RWST were not addressed or verified to function properly within acceptable margins.

(213) Level 3 Type FD Discrepancy DR-0364. DOC Page 37 of 41

DISCREPANCY

\\

[See Referene A.22, Calculation 2-ENG-031]

l This calculation is somewhat like a lot of things that were evaluated in the time frame of 1979.

l The diameter ofin: tank and the instruments overall uncertainty at least should have been mentioned along with all of the functions required of this tank.

(214) Level 3 Tspe DDD Discrepancy

[See Reference A.22, Calculation 2-ENG-031]

Other values are listed in the UFSAR today for the volume required 'n the RWST other than 48 i

inches 18 inches, like 421,000 or 370,000 gallons.

S-01357-S2 Rev. O, " Millstone 2 - Minimum Time to Sump Recirculation Actuation Signal", (Millstone via UIR #2926 identified that the assumed time to SRAS in Chapter 14 is l

longer than actual calculated values.)

(215) Level 3 Tspe FD Discrepancy

[See Reference A.23 Calculation S-01357-52]

This calculation does not address all instrument loop uncertainties or plant process conditions and it should.

(216) Level 3 Tvve FDDiscrepancy

[See Reference A.23, Calculation S-01357-S2]

The tanks wall thickness were addressed as uniform thickness by this calculation.

(217) Level 3 Tspe DODDiscryincy

[See Reference A.23, Calculation S-01357-52]

The SRAS point is referenced to the bottom of the tank but should be to the top of the drain since the usable volume of 453,907 gallons,421,000 gallons or 370,000 gallons. The 370,000 gallons is presented.

(218) Level 3 Tvoe FD Discrepancy

[See Reference A.23, Calculation S-01357-52]

The calculation uses t,he nominal setpoint of 48 inches + 18 inches as the required setpoint value for the Low-Low SRAS trip point, but doesn't include an uncertainty for the Low alarm point of 94%. (See Calculations TSCR-2-32-77-45GM,1D20-2 & 2-ENG-031.)

(This was identified by Millstone via UIR #2926. The assumed time to SRAS in Chapter 14 is longer than actual calculated values of two (2) 30 second intervals.)

(219) Level 3 Tspe ADDiscrepancy (See Reference A.23, Calculation S-01357-S2]

The diameter of the tank and the instruments' overall uncertainty at least should have been mentioned along with all of the functions required of this tank.

{

(220) Level 3 Tspe FD Discrepancy t

[See Reference A.23, Calculation S-01357-52]

The Low Level alann is calculated to be 94% and the Low-Low level SRAS trip is set at 48 inches above the bottom of the tank. These values are not properly addressed although they may

(

end up being conservatively acceptable. All the functions of the RWST were not addressed or l

verifica to function properly and within acceptable margins. (SRAS, NPSH, Air in line, or Low l

Level Alarm interface with Low-Low Level Trip.)

i I

1D20-2 Rev. O, " Millstone 2 - RWST SRAS Actuation"

_ (221) Level 3 Type FD Discrepancy DR-0364. DOC Page 38 of 41

wumismNar

[See Reference A.24 Calculation ID20-2]

This calculation does not address instrument loop uncenainties or plant process conditions and it '

needs to include uncertainties. This calculation verifies the Level at which SRAS is initiat instrument loop uncertainties need to be included in any evaluation concerning the function of instrumentation to perform a safety-related action.

(222) Level 3 Tsve DOD Discrepancy (See Reference A.24, Calculation 1D20-2]

The point is referenced to the bottom of the tank or top of the drain but it is a minimum water level volume of 421,000 gallons is presented, whereas the Technical Specifica: ion minimum water level volume is 370,000 gallons. Note SRAS is calculated to initiate at 2 feet 6 inches, which is a 1 foot margin from an empty tank to the discharge pipe level. Other calculations use diffe' rent numbers instead of 421,000 gallons. (See TSCR-2-32-77-45GM & 2-ENG-031.)

(223) Level 3 Tspe AD Discrepancy -

[See Reference A.24, Calculation 1D20-2]

There are no " Assumptions" listed and but the tank's wall thickness or loop uncertainties aren't addressed. This is not a valid Assumption. Other assumptions exist but are not documented.

(224) Level 3 Tsve AD Discrepancy

[See Reference A.24, Calculation 1D20-2]

This calculation is somewhat like a lot of things that were evaluated in the time frame of 1973.

j Again, the diameter of the tank and the instruments overall uncertainty at least should have been j

mentioned along with all of the functions required of tids tank.

l (225) Level! Tsve DOD Discrepancy l

[See Reference A.24, Calculation 1D20-2]

Other values are listed in the UFSAR today for the volume required in the RWST other than 421,000 gallons (@ 32.6 feet).

l TSCR-2-32-77-45GM Rev. O, " Millstone 2 - RWST Volume" (226) Level 3 Tspe FD Discrepancy (See Reference A.25, Calculation TSCR-2-32-77-45GM]

This calculation does not address instrument loop uncertainties or plant process conditions and it needs to include uncertainties. The instmment loop uncertainties must be included in any evaluation concerning the function or' instrumentation to perform a safety-related action.

(227) Level 3 Tsve FD Discrepancy (See Reference A.25, Calculation TSCR-2-32-77-45GM]

The tanks wall thickness was not completely addressed, but was presented by the calculation's reviewer without a reviewer.

(228) Level 3 Tspe DOD Discrepancy

[See Reference A.25, Calculation TSCR-2-32-77-45GM]

The SRAS Level trip point of 5% feet above the tank bottom and 370,000 gallons is presented as the Technical Specification volume required. Other calculations use different numbers instead of 370,000 gallons and the actual plant low-low level trip setpoint is 41.8 inches above the top of ti.e discharge pipe or 47.8 inches above the tank bottom.

(229) Level 3 Tspe DOD Discrepancy

[Sre Reference A.25, Calculation TSCR-2-32-77-45GM]

Note the Low Level alarm point is presently set at 34 feet 7 inches above the tank bottom per this DR-0364. DOC Page 39 of 41

uvusstaunwKcv

~

calculation but the installed setpoint is 35.01 feet.

(230) Level 3 Twe AD Discrepancy

[See Reference A.25, Calculation TSCR-2-32-77-45GM]

There is one " Assumption" listed and it states that the tank's wall thickness doesn't need to be

{

addressed. This is not a valid Assumption. Other assumptions exist but are not documented.

(231) Level 3 Twe AD Discrepancy

[See Reference A.25, Calculation TSCR-2-32-77-45GM]

{

This calculation is somewhat like a lot of things that were evaluated in this time frame of 1977.

l Again, the diameter of the tank and the instmments overall uncertainty at least should have been mentioned along with all of the functions required of this tank.

)

1 1

I l

1 I

l DR-0364. DOC Page 40 of 41

-mmrew u (232) Level 3 Tvve DOD Discrepancy

[See Reference A.25, Calculation TSCR-2-32-77-45GM]

Other values are listed in the UFS AR today for the volume required in the RWST.

']?. A L L==

Ravm

} L. Thomas Tier 1 02/20/98 Originator Group Date EVALUATION

@ BASIS VALID D BASIS INVALID - CLOSED 0 PREVIOUSLY IDENTI M,J. Akin Group Lead Date

/-

REVIEW AND APPROVAL Cm SL Reviewed: E.A. Blocher

/Ja+rf f Deputy Project Director Date Approved: D.L. Curry Project Director Date DR-0364. DOC Page 41 of41