ML20202B462
| ML20202B462 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/06/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9802120023 | |
| Download: ML20202B462 (39) | |
Text
q Q 'l ,
f ha Sar gealtg Lundy"*
hE Don K. Schopfer-Senior Vice President ;
312 209-6078 February 6,1998.
1 Project No. 9583100 Docket No. 50-423
- Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Actio,. Verification Program United States Nuclear Regulatory Commission
' Attention:- Document Control Desk i
Washington, D.C. 20555 I have ene.losed the following three (3) discrepancy reports (DRs) identified during our review -
activities for the ICAVP. These DRs are being distributed in accordance with the -
~ Communications Protocol, PI-MP3-01.
- DR No. DR-MP3-0989
. DR No. DR-MP3-0997 f DR No. DR-MP3-1020 j7
-It
' I have also enclosed the following one (1) DR that has been determined invalid. No action is '
required from Northeast Utilities for this DR. The basis for its invalid determha. ion is included on the document -
@l DR No. DR-MP3-0995 I have also enclosed the following seven (7) DRs for which the NU resolutions have been ri?mved and accepted by S&L.
DR No. DR-MP3-0005 DR No. DR-MP3-0053 DR No. DR-MP3-0499 s . . '
DR No. DR-MP3-0606 -
- U DR No. DR-MP3-0668 DR No. DR-MP3-0753 DR No. DR-MP3-0772 .L.
" ,{', ""' .]' 1}" g 9002120023 900206 PDR ADOCK 05000423 P PDR 55 East Monroe Stre Chicago. IL 60603-5780 USA + 312-269-2000
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United States Nuclear Regulatory Commission . February 6,1998 Document Control Desk Project No. 9583-100
- Page 2 I have also enclosed the four (4) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.
DR No. DR-MP3-0166 DR No. DR-MP3-0575:
DR No. DR-MP3-0705
- DR No. DR-MP3-0731 Please direct any questions to me at (312) 269-6078.
Yours very truly,
%XL D.' K. S opfer k SeniorVice President and ICAVP Manager DKS:spr
- Enclosures Copiesi E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council-J Fougere(1/1)NU nwe.vpwswom6=
i
s 4
4V Northeast Utilities ICAVP DR No. DR MP3 0949 Misistone unit 3 Discrepancy Report Review oreup: symem DRvAuo Review Element: Moencahon De ,,,,,,,,
Discopane: Mecherwoel Dwign O veo n -, Type: Lloaneing Document g
synesmerecese: NEW NRC signiacance level: 3 Date faxed to paJ-3 Dale Puteshed: 2mos pesarspency: Conclusion in SE EV 97-499 with respect to CR M3 97 3607 and specification 2280,000-582 Descripeson: Safety evaluation SE-EV 97-499 is provided as part of DCR MS-97094. The conclusion in the safety evaluation with respect to CR MS 97-3307 is inconsistent with the fill times determined in calculation US(B)-270, Revisions 5 and 6.
According to page 2 of safety evaluation SE EV-97-499, a reportability determination associated with CR M3-97 3607 corcluded that removal of the " time delay"in Emergency Operating Procedure EOP 35 ES-1,3 is not reportable. A time
- delay had been placed in the procedure to delay the closure of the 3RSS*MOV20A/B valves before diverting flow to the emergency core cooling system pumps by opening valves -
3RSS*MOV6837A/B. The purpose of the time delay was to purge air from the RSS piping during a small break loss of coolant accident without a containment depressurization -
actuation signal. The safety evaluation concludes that the time delay is not necessary because there is an inherent time delay of about 30 seconds in which valves 3RSS*MOV20A/B remain open before valves 3RSS*MOV8837A/B open. However, calculation US(B) 270, Revisions 5 and 6, show that more than 30 seconds is required to fill the RSS piping through the RSS
heat exchangers, considering the maximum fill time. Revisions 5 and 6 calculate the fill times for the RSS before and after installation of the flow restriction orifices via DCR M3-97045, respectively, Review Valid invalid Needed Date initiator: Femgold, D. J.
@ O O 2/196 IRC Chmn: Singh, Anand K
@ Q O 2/496 8 O O 2/s9e Date:
INVAUD:
Dete:
RESOLUTION Previously te%ntl*ad by ?!U? O Yee te) No Non Discrepent Cond6 tion?O Yee to) No Resolution Pend 6ng?O vos + No ResolutionUnresolved?O yee @ No initiator: (none)
VT Leed: Nort, Anthony A VT Mgt: Schopfer, Don K Printed 2/9/9811:51.06 AM Page 1 of 2
~
Northeast Utilities ICAVP DR No. DR44P34989 unustone unit 3 Discrepancy Report IRC Chmn: Singh, Anand K b O O Date:
SL Comments:
2M 11Sm M Page 2 of 2
t Northeast Utstles ICAVP DR No. DR MP3 4997
- Ministone Unit 3 - Discrepancy Report Review Group: System ._
DRVAUD Revlow Element: ModHIcstion Design pleelpiene: Mechaniost oesi'"
zi Type: Lloonaang Documert O va t'
s,--__ ^^ r R NEW g
NRC SignlAcJace level: 3 Date faxed to NU:
Date Pubilehed: 2/9/96 E- -i; e :y eval S3-EV 97-035 in DCR M3-97063 is inconsis'ent w/
ucN DM3-00,1463 97 & calc US(B)-361 Deeceipmen: Tne safety evaluation for DCR M3 97063, RSS Expansion Joint / Support Mocification, is S3-EV 97-035.
Page 3 of safety evaluation S3-EV-97-035 states, " Based on the existence of the orifices and based on calculation 03705-US(B).
361 (Rev 0), the effect on system flow due to the utliization of a smaller OD expansion joint liner is considered insignificant". A change in expansion joint liner OD is not shown in DCN DM3 1463-97 which provides the updated vendor infotmation for expansion joints 3RSS*EJ1 A-D and 3RSS*EJ2A-D, Furthermore, calculation US(B)-361 Revision 0 does not provide a basis for the flow resistance coefficient, (i.e., K-factor), used in the analysis for the expansion jo.nts. There* ore, the conclusion in the safety evaluation, (i.e., the effect of i system flow due to the smaller expansion joint liners is insig.tificant), cannot be -
confirmed.
Review Vand invoud Needed Date inittster: Feingold, D. J.
Q Q Q 2f396 VT Laod: Nerl, Anthony A O O O 2rs9e VT Mgr: Schophr, Don K G O O 2i+9e inc chmn: Singh, Anand K :"*Se Q O O .
Date:
INVALID:
Date:
RESOLUTION, previously idenessed by Nu? O Yes (S) No Non Diecrepent Condition?U vos (S) No ResolutionPending?O va @ No ResoluuonUnresolved?O va @ No Review AWah Not Acceptable Needed Date m ,. g VT Leed: Neri, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
SL Comments:
PrWed 2/9/9811:51:33 AM Pege1 of 1
l hh w,%
Northeast Utilities ICAVP DR No. DR MP31020 Millstone Unit 3 Discrepancy Report Review emup: System DR VALJD Review Element: System Design Diecipilme: Piping Design _
E-_ , ci Type: C*W g 8,_ ._: :! NEW NRC SignlAcance level: 3 Date FAlted k NU-Date Putdiohed: 2/W96 Descrepency: Effect of Fluid Transient induced header movements on 4' branch line not considered Descetption: In the process of r3 view'.ag the following documents, (1) 1!.179- NP(F)-X7923 ReV 2, CCN # 01,11 7-97 (2) 12179- NP(F)-X7925 Rev 2, CCN # 1 through CCN # 7 t art "C" and part "D"),9 23-97 we noted the following discrepancy:
L.
Header movements for the 12"line resulting from fluid transient
. loads, as analyzed in (2), have not been considered in the stress analysis of the decoupled 4* branch piping analyzed in (1),
Note:
Calculation (1) has been revised per modification DCR-M3-97045,Rev0 Review 'c Valid invalid Needed Data initiator: Patel, Ramesh.D
@ O 2/2/96 VT Leed: Nat, Anthony A @ Q Q 2/2S6 VT Mgr: Schopfw, Don K O O O 2/+se IRC Chmn: Sm Anand K @ Q 2/496
, Date:
INVAllo:
Date:
RESOLUTION:
Prev 6ously identleed by NU? O ves @ No Non Discrepent Condition?O Yes ? No ResoluoanFanding?O vee @ No ResolutionUnresolved?O vos @ No Review Acceptable Not WYh Needed Dele gngig,g, g VT Lead: Nat, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Singh, ArmW K g
Date:
SL Comments:
Printed 2/99611:5214 AM Page1 of 1
i fm iis%- .h- .my+.- - 4., .
9 Ww.-=-N g%w-4e+ s%-
Northeast Utmies ICAVP DR No. DRW34904 Ministorm unit 3 Discrepancy Report ,
Re w e,e.s: P,e ,w.e.e.o DR swauD Reviewow conesse Annan Procese Deserepeney Type: conome Aenen impiamernemen O vee ayesen#resses: N/A-g,.
NRC sioniseense invet: 4 Date faxed to NU:
Dese Puhashed: 2mse Deserepancy: Inconsistency between MP3 SER and revision to FSAR Deseripelen: Unresolved item report Closure Report (UIR 347) documents that the issue is a duplicate of that reported in ACR M3 96-0300, further stating in part that "FSARCR 96-MP3-50 had been approved by the Unit Director, thereby resolving this UIR."
The UlR 347 closure package also includes a cm of Memo -
MP3-DE 97 206 dated March 1,1997.
The memo documents that during the review prt, cess for FSARCR 96-MP3-59, a discrepency had been discovered between two different sections of the MP3 SER (Sections 6.3.1 and 6.2.2). The FSARCR was processed on the basis of consistency with section 6.2.2 of MP3 SER however, no evidence exists in the closure package to indicate that any corrective ad;ons were taken to resolve the identified discrepancy in the MP3 SER. With no action taken, section 6.3.1 of the MP3 SER remains inconsistent with the changes made in FSARCR 96-MP3-59 (Table 1.6-1) in addition to the discrepancy between the two MP3 SER sections identified in the aforementioned memo.
Review
'Vand inveed Noodse Data insbesor: Noeno, Mem 224s Q @ Q VT Lead: Ryan, Thomas J O G O asse VT Mgr: Schopfer, Don K Q Q Q IRC Clenn: Singh. Anand K ~
O O O Date: 2/5/96 INVAUD: Upon further review n was determined that the FSAR changes made by FSARCR 96 MP3 59 are correct and that the NRCs acceptance has been documented in the SER section 6.2.2.
While it might be prudent in this case (to avoid future confusion) for the Ucensee to advise the NRC that a discrepancy now exists between SER sections 6.2.2 and 6.3.1 so that the discrepancy could be resolved, such notification (whether performed or not) and subsequent resolution of the discrepancy between the two identified sections of the SER are not viewed as requirements within the scope of the ICAVP. Accordingly, this DR may be considered as invalid.
Dese:
REs0LUTioN.
Provtously identined I,y Nu? O vos @ No Non Discrepent Condition?Q vos @ No PM%PendHig?O vos @ No P a%uaresoeved70 vos @ No Review
^
.. , ----- - Not hap 8 N= Needed Date Printed 2W9e 1152:52 AM ' Page 1 o8 2
C 3 " D' ev-. e e.muy-w. p pmv Northeath Utilities ICAVP DR No. DR MP3-0965
- Ministone Unit 3 Discrepancy Report -
VT Lead: R Thomas J VT Mgr: Schopfer. Don K O g IRC Chmn: Singh, Anend K g
Date:
SL Commm',2s:
1 V
9 l
1 Printed 299611:5258 AM Page 2 of 2 I
i m s, g, - - . *
- Nwtheast Utmuss . ICAVP _ _ DR No. DRW36 Mestaw unit 3- Discrepancy Report :
n-iewer ,: Programmme oRResoumoNaccorre0 noview element: Change Process passayane: operemens DIsersponey Type: O 4 M & T Procedure g)y,, - ,
syssenWPressee: N/A g .
NRC alensionnes level: 4 Does faxed se NU:
Does Puteshed: 7457 asserspency: Intemal Procedure inconsistencies Deserspelen: This discrepancy relates to Millstone General Operating - ,
Procedure OP 3265, Rev.5 (effective 9/20/93), titled "EOP Change and Revision Process" which controls Emergency
- Operating Procedures (EOPs) and other EOP supporting procedures. This procedure is self contradidory in some fundamental requirements regarding the reviews required for :
procedure changes.
- 1. The procedure is intemally inconsistent regarr.ing the need for engineering reviews and safety evaluations for Atpoint : '
changes. Paragraph 2.2.13 of procedure OP 3265 states that an Intent change is,"a modification which alters method, scope, or safety of a procedure, Setpoint changes are considered intent changes." Further, notes 2 to paragraphs 4.3.2 and 4.3.3 state that setpoint changes do not require an engineering review or an ~
Integrated safety evaluation.
Contrary to the above procedure requirements, Attachment 1 to OP 3265 flow chart shows that all intent changes require an
. engineering review and an integrated safety evaluation.
- 2. The procedure is ambiguous conceming its necessity to verify and validate intent changes. The notes to paragraphs 4.3 and 4.3.6 of OP 3265 state that the EOP Coordinator decides whether procedure verification or validation is required and
- whether it will be full or partial. Thus, in+ent changes to procedures can be made without verifk .. or validation.
Contrary to the above procedural requirements, Attachment 1 to OP 3265 shows a procedure flowchart which indicates that all intent changes receive verification, validation, local validation, engineering review and integrated safety evaluation.
Rewsw venid inveed Needed Deie intilator: Shepperd. R. P.
O O O 6tsos7 VT Leed: Ryan, Thames J vr Mgr: Schopfer. Don K
@ Q Q 6<3o97 O O O aesoriri IRC Chrnn: Singh, Anand K Q O O 7'357 Date:
iNVAUD:
Date: 2/4/98 RESOLUTION. Dispocition:
CR M3-97-2071 has been initiated to track this issue. AR Printed 2/9461123:57 AM Page 1 or 3 l
r _. . _ _ _ _ _ _ _ _ _ _ _ _ _
Nottheast Utilities ICAVP DR No. DR44P3 0005 Millstone Unit 3 Discrepancy Report 97016328 was generated to coondinate activities associated with CR MS-97-2071. The corrective action for the CR is to correct .
the identified inconsistent wording. Millstone is currently revising OP 3265. Setpoln.s are govemed by Millstone calculation We 517 981 RE. Any setpoint changes made to an EOP will have first had to have gone through engineering reviews to change calculation '#3 517 981-RE.
Conclusion:
- 1) OP 3265 is currently in the revision process to clarify the review requirements for setpoint changes. 2) DC 2. Developing and Revising Millstone Procedures and Forms, Rev.1, change 2, Attachment 3 darifles that informational attachments will be referred to in notes. The flow chart referenced in DR-MP3-0005 is intended to be used as information only. The flow chart will not be removed but its use will be darified by referring to flowchart in a note.
2nd Response:
Disposition: NU has conduded that Sargent & Lundy comments to IRF-00114, (DR-MP3-0005 response), do not represent a discrepant condi'lon. OP 3265, EOP Network Procedure Revision Process, requires that the EOP Coordinator make dedslons regarding the types of reviews that are performed on
- emergency procedure modifications. The decisions made are based on knowledge of the change and experience with the process. Although OP 3265 allowed the use of the change proceu to alter EOP's it has not been used at Millstone 3. The unit has historically performed revisions to EOPs in lieu of changes. This was done because the EOP Coordinator chose to use the more rigorous revision process. Based on not choosing to use the change process, OP 3265 was revised to allow only revisions to be performed to EOP's.
Based on the above discussion, the S&L Comments are addressed as follows:
- a. Have intent changes to EOPs or EOP supporting procedures been made without verification and validation due to the inconsistency in procedure OP 3265?
No, alterations to the EOP procedures were done using the revision process which indudes verification and validation of each change. The EOP Coordinator chose this method as a more rigorous process ar.d OP 3265 has been revised to reflect this practice,
- b. If so, does this viclate the Unit 3 licensing basis and what corrective action is proposed?
Since the revision process was used in lieu of the change process, the licensing basis has bee.i preserved in this area so no corrective action is required.
- c. Based on the answers to these questions, do any Emergency Operatina Procedures or EOP supportina procedures need Printed 2fa9e 11M00 AM Page 2 or 3
Northeast UtilitiG. ICAVP DR No. DR MP3405 Misistone unit 3 Discrepancy Report additional reviews before start-up?
Based on the revision process being used in lieu of the change process, no additional reviews are required prior to startup.
Conclusion:
This IRF supplements IRF 00114. NU has concluded that Sargent & Lundy comments to IRF 00114, (DR-MP3-0005 response), do not represent a discrepant condMion. Although OP 3265 allowed the use of the change process to aner EOP's it has not been used at Mi!! stone 3. The unM has historically perfor"..<.J revisions to EOPs in lieu of changes. This was done becaus6 the EOP Coordinator chose to use the more rigorous revision process. Based on not choosing to use the change process, OP 3265 was revised to allow only revisions to be performed to EOP's.
Previously identined by Nu? O Yes @ No Non Descrepent Coneuen?Q. Yes (S) No PM%Peneng?O vos @ No ResolutionUnrosoevedtO vos G No Review Inluetor: Sheppard. R. P.
VT Lead: Ryan, Thomas J O N VT Mgr: Schopeer, Don K 1RC Chmn: Singh, Anand K Date: -2/4/96 sL commente:
/
PrWed25MI611:54:01 AM Page 3 or 3
Northeast Utinties ICAVP DR No. DR MP3 0053 Minstone unit 3 Discrepancy Report l ~
Rev6ew Group: Syelem DR REaOWTioN ACCEPTED Revlriw Element: System Design Diecipune: structures Deeyn
% pq %
Ducrepancy Type: Calculutbn Ow 8, ^ _ n -:8WP @ No NRC Signiacance level:4 Date FAXad to NU:
Date Putdiohed: 9/1147 Dioceepency: Pipe support calculation NP(F)-ZO198-405 discrepancy poecetpoen: Wehave reviewed Pipe Support Calculation NP(F)-ZO19B-405, Rev.7 and note the follow 6ng discrepancies:
- 1. On page 17. the Load factor should be 1.24 and not 0.41 based on Change Factor on page 1~..
- 2. On page 30 the dimension A should be 8.64* and not 8.34".
This is a math error.
- 3. Loads on page 35 utilized in the analysis of the base plate correspond to the loads on voided page 3 of ATT. "A". No justification is given for base plate loads used in the calculation.
Rev6ew vand invalid Needed Deh initiator: Patel, A.
Q Q Q 9/3/97 VTt.eed: Nat, Anthony A Q Q Q 9/3/97 VT Mgr: schoper, Don K Q Q Q WB/97 1Rc Counn: singh, Anand K Q Q Q 94/97 Dese:
INVAUD:
Date: 2/4/98 RESOL.UTION. NU has concluded that Discrepancy Report DR-MP3-0053, item 2 has identified a condition not previously discovered by NU which requires correction. Condtion Report (CR) M3-97-3210 was written to provide the necessary corrective actions to -
resolve this issue. The discrepancy in values reported in item 2 is insignificant with respect to the results of the calculation. NU has also concluded that items 1 and 3 do not represent discrepant conditions.
Response to item 1 The analysis addressed on page 17 references a load fac ir of 0.41, which is based on the load used in Revision 6 to the calculation. Revision 7 of the calculation was performed to address a load increase and qualifies the support via an evaluation on page 13 by applying a load factor of 1.24 to the results of the previous analysis. The STRUDL analysis from Revit;on 6, including page 17, must remain a part of the calculation in order to support the change factor approach applied to qualify the support. The load factor of 0.41 must be taken in the context of Revision 6 of the calculation which is provided for reference only. Therefore this is not a discrepant condition.
Printed 2/W9e 11:54A0 AM Pege 1 of 2 i
e = ' q.
Northeast Utilities ICAVP DR No. DR44P3-0053 Ministone unit 3 Discrepancy Report Resgnse to item 3 The etnier base plate qualification was based on a T: load of 21,836 used in Revision 5 of the calculation. The justirmation for the base plate qualification for the latest loads is provided on page 13 of Revision 7 which identifies lower loads than those used to qualify the plate in Revision 5, and states that no further
- calculation is required. Therefore this is not a discrepant condition.
Wt,m by Nut Uy (e) No nonoi.orepenacerU Yse (()No
-P.neng?O v. @ w. m unt.e.ev.et O v. @ w.
M.wiew Inte6stor: Patel,A. ' " " "
VT Lead: Nort, Anthony A O O =
VT Mgr: Schopfer, Don K O O m IRC Chmn: Shgh, Anand K Da8e: 2/4/98 st Comments:
s c
.f Printed 2&9611:54.52 AM Pe 2 of 2
l.
I' Northeast UWties ICAVP DR No. DR.MMM mastone Unit 3 Discrepancy Report moview oroup: syenem om Resot.UTloN ACCEPTED noview Eamment: syenem Deegn oiseine ne:ia e D=en o y, oleerepancy Type: Drewine s, _ _ ^ - n Ras gg NRc signiseense lowl: 4 Date faxed to NU:
Dele Puhashed: 11/24e7 r mii !nconsistent logic between drawings LGK 2711G and LSK. -
2711F,w/ resped 'o bypass alarms t . Logic Diagrams 12179-LSK 2711G, Revision 9 and 12179-LSK-2711F. Revision 9, show the, logic for the containmeist recirculation spray system bypassed alarm and the logic for the containment recirculation injed system bypassed alarm,-
respectively.
Notes to FSAR Figure 6.31 Identif) the emergency core cooling system (ECCS) modes of operatior, as " injection", ' Cold Leg Recirculation", and " Hot Leg Recirculation" No containment recirculation system (RSS) modes of operation are defined in the FSAR FSAR Section 6.2.2 and Notes to FSAR Figure 6.3-1 identify the RSS engineered safety features functions to be containment spray and recirculation of containment sump water through the reactor core for emergency core cooling.
Consequently, the alarm entitled, "Containmer,t Recirculation Inject System Bypassed",is confusing. The function of this alarm is to alert operators when a RSS train is unavailable for recirculation of the sump contents through the reactor core. A more appropriate alarm title might tee," Emergency Core Cooling Recirculation System Bypassed *,
Furtnermore, the logic for the containment recirculation inject system bypassed alarm shows that the alarm is annunciated for breaker to valve 3RSS*MOV20A open, regardles of the valve position. If valve 3RSS*MOV20A is closed, the RSS train is not bypassed for flow into the reactor core, regardless of the condition of the valve breaker. The logic for this alarm should be similar to the logic for the alarm entitled, 'Contalment Recirculation Spray System Bypassed", where the alarm is annunciated for a dual condition of 3RSS*MOV20A open and valve not fully opened. The only difference to the two alarms should be that in one case the logic is for valve is not fully closed ,
and in the other case the the logic is for valve is not fully open.
The logic for valve 3RSS*MOV23A on drawing 1217E-LSK 11F should be similar the logic for the same valve on drawing 12179-LSK-11G. The reasoning for this statement is the same as that applied for valve 3RSS*MOV20A.
Finally, this concem applies to parallel valves 3RSS*MOV238,C,0 and 3RSS*MOV208,C,D.
Review Valid invand Needed Date initiator: Famgold. D. J 8 O O 11/1' S7 VT Leed: Neri, Anthony A 11/17,97 UT Alee. *' Phai V Q Q Q 99f1*PN27
~ ~
Printed 2S9611:56:50 AM Page 1 of 3 m .
Northeast UtlNties ICAVP DR No. DR.MP3 0499 Ministorm unit 3 Discrepancy Report vi m r:o sonspeer, Don K "'17/'7 9 O O N4c Chmn: singh. Anand K O O O 11/2057 Date:
INVAUO:
Dese: 2)6/98 REaOumON: Disposition:
NU has concluded that the issue reported in Discrepancy Report.
DR-MP3-0499, does not represent a discrepant condition.
Item (1) Containment Recirculation has two functions. When the system is initiated, it is initially aligned to provide cooling water to the Containment Recirculation Spray Header. After a period of approximately thirty minutes, the RWST is depleted and the injection system is required to otdain sudion from the Containment Structure Sump. Therefore, the Recirculation system is partially realigned (by menudly closing 3RSSWOV20A, B, C or D and manually opening 3RSSWV8837A or B or 3RSSWV8808A or Q to provide cooling flow to the Recirculation injection System. The
" Containment Recirculation injedion System Bypassed" alarm provides indication of a problem within the specific portion of the RSS injection header and the common header to both the -
injection and spray header. The " Containment Recirculation Spray System Bypassed" alarm provides indication of a problem within the specific portion of the RSS spray header and the -
common header to both the spray and injection header, Consequently, the alarm " Containment Recirculation injecilon System Bypassed" alerts operators to RSS train unavailability, if received in conjunction with the " Containment Recirculation Spray System Bypassed
- alarm. If the common header to b0th the spray and injection header is bypassed both alarm windows are lit, The proposed alarm title, " Emergency Core Cooling Recirculation System Bypassed' would be too vague and non-directive in the specific function because ECCS is more then RSS and QSS.
Item (2) As stated in Part One, the Containment Recirculation System has two functions. The system is aligned, initially, to provide flow to the spray header. In preparation for this, 3RSSWOV20A, B, C, D and 3RSS*MOV23A, B, C, D are maintained in the open position. The alarm " Containment Recirculation Spray System Bypassed" has two logic inputs from the specified valves because the initial function of the RSS is to prnvide flow to the spray header, if the breaker is open and the valve is shut, this function will not be fulfilled. On the other hand, the alarm " Containment Recirculation inject System Bypassed" has only one logic input from the specified valves.
For injection function, the valve is required to be po: Honed by operator manor.1 action. Therefore, only power availability for this valve is used for the bypass indication. If the valve is open, the nrimarv funcfinn of RMM la still martnhlkhwi hut if the branirar im PrMted 2&9e 11:57:03 AM PeGe 2 of 3
__ _:S ~ _
Northeast Ututties ICAVP DR No. DRM99 Ministorw unit 3 - Discrepancy Report open, the availability of the injedion train is lost. The position of the valve is inconsequential with respect to injedion because the primary fundion is to provide cooling flow to the spray header.
Significance Level critona do not apply here es this is not a discrepent condition.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR MP3-0499, does not represent a discrepent condition.
Item (1) The Emergency Core Cooling System (ECCS) function include a number of systems and is too vague of a title to use, Containment Recirculation Spray System Bypassed and Containment Recirculation Injection System Bypassed provide a more descriptive titles for identifying system functions, item (2) The logic for " Containment Recirculation Spray System Bypassed" has two inputs while the logic for " Containment Recirculation injection System Bypassed" has one input and is consistent.
Significance Level criteria do not apply here as thir is not a discrepent condition.
Pr .vioussy asenuand by Nut U Yes @ No NonDisc'.pentCandluon?@ Yes U No n.ema p.nmastO va @ No n amn var =*.stO va @=
n.wi Inistator: Femooid, D. J.
VT t.eed: Nwt, Anerny A VT Mgr: Schopfer, Don K iRn Chmn: singh, Anand K Date: 2/tW98 st comments
- The alarm entitled " Containment Recirculation inject System Bypassed
- is vague. However, the definition provided in the response shows no conflict between the two alarms,
' Containment Recirculation inject System Bypassed" and
" Containment Recirculation Spray System Bypassed". Therefore, assuming the alarm definitions are adequately addressed in operator training, no discrepancy exists.
Printed 25W9e 11:57;oS AM Page 3 of 3
~
Northeast Utilities ICAVP DR No. DR&36 uisistone unit 3- Discrepancy Report Movtow otoup: Piv ... ;~ DR RESOLUTION ACCEPTED Review Element: Corrective Acuan Procios Discrepancy Type: Correchve Action O va 8,u.T *N/A g
NRC signiacance level:4 Date FMed to NU:
Date Puldlehed: 11/1547 -
E - :i; inadaquate response for resolving the OIR 131 DesertPtica: The Millstone Unit 3's OlR131 ' Description of Unresolved item' block states the foltwing:
"The output voltage of each battery charger is automatically regulated in either float or recharging range to 0.5% of the setpoint voltage from an input voltage of 480V with a 10% '
variation.' The above statement is from the FSAR Sedion 8.3.2.1.2.1 dated April 1997.
The OIR's Discrepancy Closure Report " Background
- block states the following:
'OIR 131 questioned whether or not the station battery chargers were tested over the full range of the specified input voltages (480V 10% VAC), if not, consider performing the test during -
the battery charger testing.'
The OIR's Discrepancy Closure Report
- Conclusion
- block states the following:
"The station battery chargers were satisfactorily tested _over the full range of the specified input voltages at the factory in accordance with SPEC 260."
The SPEC 260 Battery Charger Tests were attached to the OIR 131's Discrepancy Closure Report. These tests confirm that the station battery chargers were tested over the full range of the specified input voltages (480V 10% VAC) and that the output was within 0.5% of the setpoint voltages of 528V (480V +10%),
480V (480V +0%) and 432V(480V-10%) at a DC output range of 132.1 VDC to 131.3 VDC.
The SPEC 260 Battery Charger Tests do not confirm that the station battery chargers will automatically regulate to 0.5%. ovm the full range of the specified input voltages (480V 10% VAC) for the following specific charger DC outputs as stated in the FSAR:
a) Battery float setting (See Note 1 below) b) Battery recharging (equalizing) setting (See Note 2 below)
Note 1: The battery float voltage is 135 VDC as noted in Calculations BAT 196-1241E3, Rev.1, BAT 2-96-1243E3, Rev.
1, BAT 3 96-12453E3, Rev. O and BAT 4-96-124BE3, Rev. O.
( This value may or may not be the same for the remaining Unit 3 batteries.)
Note 2: The battery recharging (equalizing) voltage setting was not discovered in documents examined but is expectert to be in the range of 137.4 to 140 VDC based on an equalizing value of
, ,o .m e e o . mu _, .n Printed 2/9/9611:57:43 AM '" " ~ ~ " "'~ F -"
PeGe 1 or 3
Northeast Utilities ICAVP DR No MPS6 uisistone Unit 3 Discrepancy Report n.wi VeH inveM Needed Date -
Inleiston Coruno. A. -
G 0 0 - 10/31'87 VT Lead: Ryan. Thomme J G O O 11'1/'7 VT Mgr: Schopfer Don K Q Q Q 11/6/97 InC Chmn: S6ngh. Anand K Q -0 0 11/117 4 Date:
INVAUD:
Dele: 2/5/98 nasoLUTioN: Disposition:
NU has concluded that the issues reported in Discrepancy Report DR MP 3-0606 do not represent discrepant conditions.
The FSAR states that the battery charger is automatically
- regulated in either the float or recharging range to .5% of the set point voltage from an input voltage of 480V with a 10%
variation. This statement is validated by the following information provided by C&D Batteries:
- 1. Technical data fumished by C&D Batteries Physical, Descriptive, & performance Data, Dec. 7,1978 Section
' Performance Data'
- a. Output voltage-range of adjustments: Float Voltage 120-135Vdc; Charging voltage 130145Vdc; c. Output voltage regulatinn- no load to full load; input voltage +/-10% V, +/-
5%Hz; % regulat!on at float setting +/ .5%, at equalizing -
setting +/ .5%.
- 2. C&D's "AutoReg Operathg Instructions' for the ARR Series Chargers, page RS42011/81 In the AutoReg charger, when the AC line supply is within the limits of 10% above or below the AC voltage rating on the nameplate, the chatger will maintain a steady DC output voltage within +/ .5% for any load from 0% ta 100%. "On the AutoReg charger, the float and equalize voltages can be adjusted within the range of 10% above .and below the nominal voltages, which are factory set.'
Maintaining a fioat charge at 135VDC and equalizing charge at 140VDC is within the limits provided by the manufacturer.
Significance level criteria do not apply as this is not a discrepant condition.
Condusion:
NU has concluded that the issues reported in Discrepancy Report DR-MP-3-0606 do not represent discrepant conditions.
The battery charger output voltages during float and equalizing charging aro wanin limits specified by the manufacturer.
Significance level criteria do not apply as this is not a discrepant condition.
Attachments:
- 1) Technical Data fumished by C&D Batteries Div, Dec 71978
- 2) C&D Batteries, AutoReg., Operating Instructions; 11/81 PdnteiC.,/Gl.,,,~, J by Nu? m no non macrgent mostmn7 Tes pagepgr3
Northeast Utilities ICAVP DR No. DR44P3 0606 Millstone Unit 3 Discrepancy Report
.t . - ,seenmase ey sur v vos ie; se son o.ecrepam conementte) Yes V No P"d% PeneinetO vos @ we P-%unre evoeto v.e @ w.
Review
% %g 'We Not aWh Needed Deee VT Lead: Ryan, Thomas J VT Mor: schop#er, con K O g O =
IRC Chmn: s@. Anand K - -
en _
- e: -
st,commwn: NU's response is acceptable.
Based upon receipt of a) C&D Battery technical data confirming the battery chargers' float range and recharger (equalizing) range. and b) NU's confirmation of the batteries' float setting of 135VDC and equalizing setting of 140VDC, it was concluded
. that the SPEC 260 Battery Charger Tests do confirm that the station battery chargers will automatically regulate to 0.5%. over the full range of the specified input voltages (480V i 10% VAC) for the specific charger DC outputs as stated in the FSAR.
This data was not available at the time of issuance of the DR, Consequently, the Discrepancy Report DR MP 3 0606 does not represent a discrepant condition.
Printed:.99611:57A8 AM Page 3 of 3
4.-.A, + + NW9 6' Northeast Utiittles ICAVP DR No. DR MP3 0444 uisistone unit 3 . Discrepancy Report Revtew Group: System L.. 'ON ACCEPTED Review Element: System Design ...
Diecipame: Mecherncei Dee"
ru . ;,- Type: rahnman O vee 8, ._ m HVX gg NRC Signiacance level: 4 Date faxed to NU:
Date Published: 12/8/97 E ~ x y: Calculation P(B)-900 Changing Pump and Component Cooling Pumps Area Ventilation System Desertption: Calculation P(B)-900 dated 4/9/84 determines the heat load and ventilation requirements for the charging pump and component
- cooling water pump areas ventilation system and the resulting room temperatures in the cubicles.
This calculation does not reflect the current system configuration and should be superceded by calculation 3-92103-191M3.
Rev6ew Valid invalid Needed Date laatietor: stout. M. D- G O O isti2/s7 VT Leed: Nat, Antnony A
' Q Q Q 11/18/97 VT Mer: Schopfer, Don K G O O 12tifo7 IRC Chmn: singh, Anand K G O O $2/4s7 Date:
INVALID:
Dese: 2/4/98 RESOLUTION. NU has conduded tha' Discrepancy Report DR MP3-0668 nas identified a condition previously discovered by NU which has been corrected.
Both calculations are valid. Calculation 3-92103-191M3 is the current calculation for the winter mode of operation. Calculation P(B)-900 was originally issued for both winter and summer modes of operation. Rev.1 to P(B) 900 was issued in response to UIR 1074, which identified inconsistencies in the design temperatures used. The revision also referenced calculation 3-92103-191M3 for w;nter mode of operation.
Attachments:
UIR 1074 and copy of 12179-900P(B), Rev.1 Condusion:
NU has conduded that Discrepancy Report DR-MP3-0668 has identified a condition previously discovered by NU which has been corrected. UIR 1074 recorded the inconsistencies In design temperatures used in calculation P(B)-900. Final disposition per AR 96033923 resulted in revision 1 to the calculation. The revision also darified the relationship between P(B)-900 and 3-92-103-191M3.
Previously identleed by NU? (9) vee O No Non D6ecrepent Cond4 tion?O Yee t#1 No PM% Ponding?O v.e @ No R ui n unr sv.d? O vos @ No Review Printed 2SSe 11:58:23 AM Page 1 of 2
'rrup Ms4x *u$. *A Northeast Utmuss ICAVP M No MW36 umstone Unit 3 Discrepancy Report inmistor . Stout M. D.
VT Lead: M Anthony A O O O N VT Mort Schopfer.Om K wic chmn: Shgh, Anand K O- O Does: 2/4/98 at commenes: Agree with NU's response that this was a discrepancy previously identified by NU.
Printed 2/W9611:56:27 AM Page 2 of 2
- - - - _---- --- - - = - - - -
Northeast Utimies ICAVP DR No. DR MP3-0668 Ministone Unit 3 Discrepancy Report Revtow Group: System DR RESOLUTloN ACCEPTED Review Element: System De@
'"~*"**" O vee Descrepancy Type: ceiculation s, _ T, =* HvX g
NRC s' _2 z - -2 levet:4 Date faxed to NU-Date Pubilshed: 12/8/97 re- + Calculation P(B)-900 Charging Pump and Component Cooling Pumps Area Ventilation System r= . Calculation P(B)-900 dated 4/9/84 determines the heat load and ventilation requirements for the chargin0 pump and component cooling water pump areas ventilation system and the resulting room temperatures in the cubicles.
This calculation does not reflect the current system configuration and should be superceded by calculation 3-92-103-191M3.
Revtew vand inve d Needed Date initiator: stwt M. D. O O O tiri2/s7 VT Lead: Nort, Anthony A 8 O O tiriais7 VT Mgr: 0chopfer, Den K 8 O O 12 ties 7 1Rc chmn: Segh, Anand K G O O 12/4/s7 Date:
INVALID:
m: 34M d REsOLUTloN. NU has concluded that Discrepancy Report DRGP3-0668 has identified a condition previously discovered by NU which has been corrected.
Both calculations are valid. Calculation 3-92-103-191M3 is the current calculation for the winter mode of operation. Calculation P(B)-900 was originally issued for both winter and summer modes of operation. Rev.1 to P(B)-900 was issued in response to UlR-1074, which identified inconsistencies in the design .
temperatures used. The revis6n also referenced calculation 3-92-103-191M3 for winter mode of operation.
Attachments:
UIR 1074 and copy of 12179-900P(B), Rev.1
Conclusion:
NU has concluded that Discrepancy Report DR-MP3-0668 has identified a condition previously discovered by NU which has been corrected. UIR 1074 recorded the inconsistencies in design temperatures used in calculation P(B)-900. Final disposition per AR 96033923 resulted in revision 1 to the calculation. The revision also clarified the relationship between P(B)-900 and 3-92-103-191M3.
Previously identtfled by NU7 T Yee () No Non Discrepent Condition?Q Yee @ No rep.ndine?O vos @ No ResoMion Unresolved?O vee @ No Review Printed 2/9/9e 11:s8:38 AM Pege 1 of 2
4.___ -.
- . . . . . . . . . ~ .
Northeast Utsties ICAVP DR No. DR MP3-0444 L Millstone unit 3 Discrepancy Report
% ,.m u D. ^~Ya NW ^~+^ Needed Date O O O N VT Land: Nui, Anmeny A VT Mgr Schopfer, Don K O O =
Ntc Chmn: S4, Anand K Date: 2/4/98 sLcm Agree with NU's response that this was a discrepancy previously
. identified by NU.
Printed 2S9611:56:42 AM Page 2 of 2 l
Northeast Utilities ICAVP DR No. DR MP34783
- Miiistone Unit 3 Discrepancy Report Review Group: System DR RESO4071oN ACCEPTED Review Element: ModWloshon Design 06scapane: Mahnw Dm%n E . :i Type: Instemation implementshon O vm S, J. - HVX gg WRC Signiacance level: 4 Date faxed to NU:
Date Putdlehed: 12/2097 r , i; PCDE MP3-90-076 Test Requirements DescriP men: During review of modification PCDE MP3-90-076 a discrepancy regarding the post modification testing requirements was idenufled.
The modification added a bracket to limit the travel of backdraft damper 3HVR*DMPB130 at the disharge of SLCRS fan 3HVRTN128. The PDCE required retest of SLCRS fan 3HVRTN12A airflow. The PDCE did not address retasting SLCRS fan 3HVRTN128 to verify that adjustment of 3HVR*DMPB138 did not reduce fan airflow below design requirements. PDCR MP3-91 124 was issued to make additional modifications to damper 3HVR*DMPB138 to increase fan 3HVRTN12B airflow.
Review vand invelld Needed Date inllister: stout, M. D.
@_ O O $2iner vT i ed: Nui,AnihonyA B O O $2SS7 VT Mgr: Schopeer, Don K G O O 2/15/97 utc ctenn: Singh. Anand K 8 O O 12 tiers 7 Dide:
INVAUD:-
c Date: 2/6/98 REBot.UTION' NU has concluded that the issue reported In Discrepancy Report DR MP3 0753 does not represent a discrepant condition.
The retest performed for PDCE 3 90-076 was deficient in not including a flow test of 3HVRTN128.
The retest of t% modification was a flow test on 3HVRTN12A to verify adequate flow and was completed on 6/29/90. The retest should also have verified that 3HVRTN128 flow was not adversely affected by the modification. However it was felt that previous testing had verified adequate flow for 3HVRTN12B with the same damper position required by the n;Mification. The subsequent Technical Specification surveillance test for fan 3HVRTN128 failed due to low flow on 7/16/90. PIR 390-116 documented this failure. During the PIR investigation, a flow test was performed on fan 3HVRTN12A, which also failed due to low flow. The corrective action for the PIR was to change the Technical Specification low flow acceptance criteria from 8550 scfm to 7600 r.cfm for the SLCRs fans.
The bracket installed on backdraft damper 3HVR*DMPB138 via PDCE 3-90-076 was removed in July 1991 via PDCR MP3 Printed 2/9/9612o1:00 PM Page 1 or 2
\ - - - - -
Northeast Utilities ICAVP M No MMP34753 a
Milistone Unit 3 Discrepancy Report 124.
NU, therefore, aoncludes that even though PDCE MP3-90-076 failed to require a flow test of 3HVR*FN12B the fan has been frequently flow tested in accordanca with Tech. Spec.
surveillance requirements. Note too that the determination of modification retests has been strengthened per subsequent revisions to the Desi0n Control Manual, which will significantly decrease the possibility of a reoccurence. Furthermore, PIR 390-116 documented fan failure and corrective action, which was completed prior to 1/1/96.
Significance Level Criteria do not apply o this is not a ,
discrepant condition.
Attachments:
PIR 390-116 Previously identined by NU? @ Yes Q No Non Diecrepent Condition?Q Yes @ No ResoludonPending?O vos @) No Resolutionunresolved?O vos @) No Rev6ew initiator: Stout, M. D.
VT Leed: Nort Anthony A B O O =
VT Mor: Schopfer, Don K IRC Chmn: Singh, Anand K Date: 2/6/98 bL connente: Agree with NU's response that subsequent surveillence testing discovered the low altflow condition.
Based on NU's response, which confirms that the retest performed for PDCE 3-90-076 was deficient in not including a flow test of 3HVR*FN128, this is considered to be a discrepant condition with respect to past modification practices.
The DR has been reclassified as a discrepancy previously.
identified by NU.
4 y Printed 2/W9612:o1:13 PM Page 2 of 2
4 Normeest UWWe7 BCAVP DR No. DR.MP84na umekme Unit :- ' Discrepancy Report nweswerog: Pressamme tut neeoumtwaccerfs0 newesw esamese: conunw Aenen Presses Dissipanet Meehentel Des **
bloempeney Typer Consene Aseen O vee systemipvenees: Wx gg (sec signeamenseloves: 4_ o,n, pan gi w:
Date Pubilshed: 12/3097
. -J Closure of Design Defloient,y Report (DDR 1027)
Deseripelen: DDR 1027 documented a conoom wth the ventilation design for the Charging and Component sooling Water Pump areas. The -
= potential exists for croco contamination (from charging pump areas to component cooling pump areas) due to a roolroulation flow path. This flow path was part of the ortDinal plant doelen.
DDR 1027 was closed to PMR 3 84028. Page 7 of PMR 3 88 -
026 Indicates that with regard to DDR 1027,
- this has not been a problem to date and potential solutions vote evaluated and '
rejected due to high cout'...
Pa0e 8 s f PMR S-48-026 is a memo (datad July 26,1994) from a radiation protection supervisor to MP3 Desion stating that based on reviuw of summaries contained in PDCRs MP3-86 000 and MP3-06-028 *with regard to ALARA conoems with disbursement of radicadivity with the air flow pettoms, I do not one this as a problem at Miltblone 3.*
While the recirculation flow path was part of ori0inal plant detien, there are some inconsistencies in system description betwoon the doelen, SER, and cunent FSAR. In addalon, closure of the DDR did not addreas compliance with system desion/ licensing requirements.
- 1. The cutterd FSAR discuseos a winter mode of operation wherein the recirculation flow path is in service to maintain a minimum area temperature. The r9oirculation flow path (when in svrvloe) is contrary to another d Aement in the FSAR ( page 9.4,15) which states 'onos air is drawn from a building space, it is eMher discharged to the atmosphe:s through the ventilation vont or diverted to the auxiliary buildin0 flhretion units, prior to reicase through the ventilation vent.'
- 2. Since the charging pumps handle primary coolard, the potential for higher airbome contamination exists relative to the Componord C@ing Pump area. Therefore, the toolrculation flow path (when in selv6ce) is contrary to Nem No,7 on FSAR pa0e
-- ?
12.3.17 which states ' sir flow within the auxiliary, waste disposal, y and fuel buildinos dortn0 normel operation is from areas of lower
> - to hi0her potential airbome contamination and then to monitored Verds.....'
- 3. The recirculation flow path (when in servloe) is contrary to MP3 SER pa0e 9 32 which states ' control of airbome activity is socomplished by exhausting air supplied to clean areas throu0h 0
the potentially contaminated areas. The h itCum is processed by the flReted exhaust system. The remaining air supplied to clean areas is exhausted by the unfiltered exhaust system.'
Preens ates12m 24 PM Pese 1 or 4
9 Q,' -
GM'M -
Northeaet utsties ICAVP DR Nm DR.44P84m
, umetone Unit 3 Discrepancy Reprxt 4.The recirculat6on flowpeth (when in sesvice) would constitute piant operation contrary to Nem No.12 on FSAR page 9.417 anytime the Charging pump ureas are more contaminated than the Component Cooling Pump Ara 46.
- 5. Closure " the DDR appearoa to rely in p,..t on sooumulated operational exportence and existing low contam6nat60n data (memo shown as page 8 of PMR S-88-026 referenced above) without :ckr-c. t $+reit of the higher potential for contamination that exists in the Charging pump aroes compared to ihe Component Cooling Pump areas and the associated flowpath desagrWioensing requirerpents whidiwould apply (eg.
FSAR and SER Moms documented in hems 1 through 4 above),
nwiew VeH tweed Nessed Date inam : N n.. m Q .O O **
VT Leed: Ryan, Themes J G O O 12/11/e7 VT Mgrt schopfer, Den K Q Q Q 12/11/97 sec chmn: singh, AnemiK O O O $2/isor two:
sWAUD:
Date: 2/4/98 ftEs0LUT1oN: Diepoogion NU has concluded that Discrepancy Report DR MP3 0772 has Identified a condition not previously discovered by NU which ha6 boon conected. CR MS 97 3161 was written to address the wording used in FSAR sect 6on 9.4.3. Tho conective adion to this CR resulted in FSAR CR No. 97 MPS 590.
The discrepant items are addretted as follows: ,
item 1. FSAR CR MPb 97 590 revises the referenced statement on FSAR page 9.418 to take exception for the winter mode of operation, item 2. FSAR CR MP3-97 590 revises the referenced statement on FSAR page 12.317 to add the qualifier ' typically *,
item 3. and item 4. FSAR CR MP3 97 590 revises the referenced statement on FSAR page 9.417 to add the quellfier
' typically *,
I Item 5, Acknowledgement of the potential for air flow from an area of higher contamination to an area of lower contamination during the winter (recirculation) mode of operation has been addressed by FSAR CR MP3 97 590. NU has determined that the "... potential accident consequences of this design are -i
- Insignificant and were discusssa and resolved with the NRC. It was noted that this is not an ideal normal operating ALARA design, but is acceptable for a number of reasons. However, aa noted by the NRC, it is not consistent with the general gnod predice ALARA design principle on air flow as quoted in the FSAR.* (CR No. MS-97 3161 meanesotam sseu esse 2 or 4
_ _ _ _m
i :.- L :. : - :
DR h on.aspum Northeast Utilities ICAVP
- Melistorm un8t 3 Discrepancy Report (Note
- CR MS 97 3161 was written in response to NRC ICAVP ;
Out of Scope inspection Request No. 237, This disotopency, i discovered by the NRC, perellels this S&L Disotopency Report.
Acconl6nply. NU concurs that this is a disorspency not previously .
L dieoovered by NU which requires correction.) _
Because the corrective action to CR No. '%97 3161 does not chenpo the deelen or l6 censing basis, NL . ,nsiders this leaue a Sionificanos Level 4.
Conclusion NU has concluded that Disoropency Report DR-MP3-0772 has i identiflod a condition not previously discovered by NU which has been corrected. An approved corredive action plan per CR MS-97 3161 resulted in revisions to the MP3 FSAR per FSAR CR 97 MP3 590. Because the corrective action did not result in any change to system design basis or licensing basis, NU considers th!s irsue a Sionificanoe Level 4.
p, ,m aa.dornur u y=
- u. m on ,.mc.nem ru v. e n.
n wa p.amaerO v. @ u. n =6. man var =*.drO va @ N.
n.m.
Inst.6.n N.mtv., M.rk G O O N vit d: Ry.n. Thom.s J VT Men s.h pe.r. D.n K e O O =
inc chun: s#gh. An.nd K _
Det : 2/4/08 -l st.c ,en.ne.: l A conference call was held on 2/4/98 between S&L, NU and the _ ;
NRC regarding this DR. During the call NU faxed FSARCR MP3-97 590 including safety evaluation. Based on our review of this further information provided and in particular, the safety j evaluation, S&L does not have any additional technical conoem and agrees w6th "'- 'valtion that the issue should be
- characterized as sigr,.. ,,ance level 4 since the recirculation path
, was part of the original design reviewed and accepted by the i
NRC. !
l L ' In addition, the inue was discussed between the DR initiator and Stephen Tingen of the NRC. Mr. Tingen was involved in the l
, NRCs finding of the FSAR inoodsistency with the HVAC design !
b (noted in NRC Inspedion report 50-423/97 206) and he provided i some back0round on specific issues of concem which the NRC i had dieniaead and resolved with the Licensee in this matter.
These issues related to assessing potential dose effeds to control room personnel, eccess to the aux.bidg, during an accident and assessment of imped to offsite dose (eg. part 100 limits), Mr. '
Tingen indicated that these concems/ questions had been
. satisfactorily addressed by the Licensee. With regard to the NRC specif!c issues dieammad above. S&L has no concem and considers that these issues have been satisfadorily addressed in i the safety evaluation for FSARCR MP3-97 590 which was faxed l Prtnt.d 199s 12.o3.30 PM P.g. 3 or 4
,-- -~ ,. , . - - . - . . - . -__-. . . - _ . - . . , - , - , . - . - - -
- --~w .-. . . -
Norttwst U Weies ICAVP DR Nr. DR 44PWM Milletou ure s. Discrepancy Report to us today.
PrWed 249s G 03 M N g4g 4
Northeast UWWes ICAVP DR Nm DRM169 umstone Unit 3 Discrepancy Report
~
n w ,: 3, e,. on ns.oumow nameTuo nev6ew elemme: syenwn Design ,,,,,,, ,,,,,
insemane: i a e o-.en o y, Disempancy Type: %% f@ Ni s, _ 7 9 nWP Nne signinoenee level: 4 Date faxed b Nu:
Oste Pubhehed: 1W1M7 F . -r; Calculation SP 35WP.1 methodology vs. RG1,105 commitment i omerwown The purpose of calculation SP 38WP 1, Rev. 2 is to determine differential pressure setpoird for switches 38WP*PDl824A,8,C,D giving start permissiive to 38WP*8TRI A.8,C,D strainer motors.
During the review of Calculation SP 3SWP 1, the following was discovered:
- 1. Per objective sodion of the calculation, the w::ulation has been performed to compensate for the instrument channel inaccuracy as per the requirements of Reg. Guide 1.105. The Reg. Guide endorses ISA 67.041962, 'Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Plants", Various components identified in this document that need to be considered for calculating the setpoint uncertainty e.g.,
calibratin uncertainty, measuring and test equipment uncertainty, calibration tolerance, seismic event impact etc. have not been addressed, nev6ew Vehd invehd Needed Date Inalatori H6nes, R. O O O *S**7 VT Leed: Nat, Anthony A Q Q Q 1&147 vi uen schepe.r. o*a k O O O 15 27 InC Chmn: Singh. Anand K O O O $517 oste:
INVAUD:
Dese: 2/3/98 nesOLuTloN: D{gposition; NU has concluded that the issue reported in Discrepancy Report, DR MP3-0166, does not represent a discrepant condition,The quellfication program and performance specifications for the Barton differential pressure swnches were not available when this calculation was performed. Calculation SP.3SWP 1 revision was issued as requiring confirmation. - The calculation revision assumed an encompassing inaccuracy for the differential pressure switch instrument of & 10% of Full Scale which was provided by the vendor. This encompassing inaccuracy ensured that the established instrument setpoint wculd be conservative once the final performance specifications were rece;ved. After the vendor test report data was received the calculation confirmation wat performed and it was determined that no revisions to the calculation were required. This was documented via interoffice Correspondence dated 910-65. While it is not clearty stated in the interoffice Correspondence that all inaccuracies, both instrument and non-instrument related, were Pnreed 29se 12:0402 PM Page 1 or 3
Northeast Umme. ICAVP- DR No. DMP841M Mastone Unit 3 Discrepancy Report
~'
reviewed and accounted for, it is soeumed that the engineer who completed the confirmation effort took all inaccursul6s into
(- acoor based upon the input assumptions that refetonood RG I 1.105,avision 1 offocuve in 1985.MHistone Un4 3 licensing basis uses Reg. Guide 1,105 revision 1 for setpoints.Significanoe Level ontoria do not apply hors as this is not a discrepent condN6on. Attachments: Calmiation SP SSWP 1 with Interofflos Concepondanos 91045.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR MPS 0168, does not reprosort a discrepent condition. The calculation was in accordance to Regulatory Guide 1.105 revision 1, the Millstone Unit 3 licensing basis. Significance Level criteria do not apply here as this is not a discreparW condition.
7;r 1;idonaAnd by NUf Q Yes @ No NonDisorspentconmuen?U vas @ No ,
ResehmenPenenet O v. @ Ne mesenmaiunradadrO vos @ N. .
Review inalmen Hnho. R.
VTLass: Nett. Anthony A vi u ne senspier, oen K Inc counni sDgh, Anand K D -
O =
O O ones: 2/3/98 st.cawnenes: The assumed 110% of Full Scale (FS) Inaccuracy in the calculation SP 38WP 1, Rey, is non conservative for the following reasons:
- 1. Report no. RS 580A 9, dated 12/22/83 thlod " Class 1E Qualification Test Program and Results for ITT Barton Models 580A, 581 A, and 583A Differential Pressure Switches" identifies the following:
An inaccuracy value of 110% of FS with a repeatability valu.e of 11% of FS for the Seismic effect on setpoint scouracy (refer to sheet 3 of 16 of document RS X759 7),
An inaccuracy valt.e of 110% of FS with a repeatability value of 11% of FL for the Radiation effect on the setpoint accuracy (refer to page 2 of 12 of document R3-580A 7). Siru , the switch is located in the mild area CWO1 (CW/SW Purt.p House) this inaccuracy is not applicable for this calculation.
An inaccuracy value of 110% of FS with a repeatability value of 11% of FS for the LOCA effed on the setpoint accuracy (refer to j page 40 of document RS-580A 9). Since the switch is located in the mild area CW01 (CW/SW Pump House) this inaccuracy is not applicable for this calculation.
Since the inaccuracy value used in tua calculation is equal to the error due to seismic setpoint drift value it is not in conservative dirodion. Errors due to repeatability (since Pt repeatability is not independent of inaccuracy value), calibration uncertainty, measuring and test equipment (M&TE), calibration inaccuracy should be considered in the calculation. The assumed M&TE enor should be verified or should be controlled by the use of known instrument inaccuracy in the calibration procedure.
- 2. Abovementioned switch inecouracies are in agreement with the Prweed 299e 12:04 08 PM Pope 2 or 3
Northeast Uuudes ICAVP M No. M&MM umstone urm 3 Discrepancy Report ITT corporst60n produd butiotin 680A senes .1.1994 edition titled
" Nuclear Safety DP Indicating Switch".
Based upon above discussion if all of the uncertainties identified above are accounted for the total error value will be muse than 10% fl0ure identified in the calculation, u
! s ', Y d \?&
Printed 2,1W9612.04 07 PM Page 3 of 3
~ . - _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _
m _
- q. t- we . ..e*---=g,e Northeast Umme. ICAVP DR No. DRW3478 Mastone Ur* 3 Discrepancy Report Review Group: system OR REtoLUTION MJECTED Review Element: 8relem Dest im
,,,,,,,, m O ves
- Oteerepeney Types compwed outs e,_
g g, 7 Hvx W SI RieseReelevel:
O 4 Date faxed to NU:
Date PuWiehed: 11/165#
oneerepancy: Auxiliuy Building Filter Unit Charcoal Adsorber Face Velocit/
P'. During review of the auxiliary building ventilation system (ABV8)
. exhaust filter units 3HVR*FLT1 A/1B a discrepancy regarding the ,
face velocity, residence time, and emciency was idenufled. j FSAR Table 1.81 Regulatory Gunde 1.52 Rev. 2 position C.3.1 ;
. exception states that the dwell time for the minimum 2 inches of I the carbon adsorber unit is 0.21 sec. All filters use a 4-inch thick l charcoal bed. Testing of the charcoal is based on a maximum l face velocity of 46 fpm.
FSAR Table 1.81 Regulatory Guide 1.52. Rev. 2 position C.6.a exception states that the activated carbon adsorber section has a -
4 inch bed and operating face velocity of 47 fpm (0.43 sec residence time). Table 2 of RG 1.52, Rev. 2 assigns a 95%
decontamination efficiency for edivated carbon sample having a methyl lodida penetration of less than 1%. It will be verified that within 31 days after removal, a 4 inch laboratory sample from the installed sample canisters will demonstrate a removal emciency of 99% for methyl iodide when tested in accordance with ANP N5101980.
FSAR Suction 9.4.3.2 states that the charcoal adsorber is
- designed for a 0.21 secono dwell time per 2 inch depth for gases at a flow velocity of 47 fpm. Four-inch depth of charcoal is provided. The impregnated charcoal is capable of removing in excess of 99 percent of methyliodide and 99.5% of elemental g lodhe.
Technical Spection Section 4.7.9 requires that a laboratory analysis of a representative carbon sample meets the laboratory testing criteria of Regulatory Poshion C.6.a of Regulatory Guide 1.52. Revision 2, for a methyl lodido penetration of less than 0.17de.
7 Specification 2170.430-065 Charcoal Adsorber Cells Desi0n and Construction section states that the auxiliary building filters have a face velocity of 46 fpm and a minimum residence time of ;
0.22 sec. per 2 in of bed thichness. The bed depth shall be a i nominal 4 in. thhinnJ.
The laboratory test acceptance criteria shown in FSAR Table 1.8-1 and Technical Specification Section 4.7.9 do not agree with each other.
Review Val 6d invalid Needed Date
-- --- w u n_ moim Pnnled 2AWJe 12:0691 PM Page 1 or 3 y- ,. ,, w -o --w-n.-v., _w., - , , . . ,r- - - -,,,-w,-.,mw.w, . . ,~,,,
Natheast Umwes ICAVP DR k DRMP84878 mustaw unit 3 Discrepancy Report i instaten sieut.M.D. Q Q Q tQt21M VT 4.aed: Neri, Anthony A O O O i ' *'7 VT Men schopfer, Den K O O O i t *'7 sec counn: singh, Anane K O O O 15'15/'7 Date:
mauo:
Date: 2/3/94 ;
lussoluta: NU has concluded that Discrepency Report, DR MP3-0575, has Identified a condition previously discovered by NU which requires correction. The first question of this DR, toisting to the
- velocity of the air entering the filters is addressed in complete detail in UlR 1005. The UIR Closure Request details the changes required to corred those Noms that are the subject of the DR. FSARCR 97-MP3 531 Implements those chan0es. The corredive actions are in procoes and w6ll be completed prior to i startup.The second question re'ates to the offioloney and the test acceptance criteria for charcoal. The FSAR and the Tech Specs are consistent with the Reg. Guide 1.52 Table 2. A rating of 99%
efficiency is assi0ned when a sample tests to <0.175%
, penetration. The FSAR discusses the efficiency retina of 99% of methyliodide and 99.5% of the elemerellodine. Tech Specs specifies the testing method and acceptance criteria. Field work is not required.
Attachments:
Technical Spedfication Surveillance Requirement 4.7.9 UIR1005 Closure Request Engineerino Evaluation MS-EV 970224 Rev 0 FSARCR 97 MP3 531 Spedfication 2170.430-066, Spedal Filter Assemblies, pa0e 121 Regulatory Guide 1.52 pa0es 1.52 6 and 1.52 7 '
~
=/- ?;leonesed by Nu? Q Yes @ No Non F- 7conmuon?Q Yes @ No RoseblonPenshng?O vos @ No M % Unteeolvedt O vos @ No Review Intiteter: Stout, M. o.
VT Land: Nort. Anthony A VT Mgn Schopfer, Don K IRC Chmn: Singh, Anand K Date: 2/3/98 st.conenents: A0ree with NU's response that the charcoal adsorber face velocity discrepancy wss previously identified by NU.
Disagree however with NU's response regarding the charcoal laboratory test acceptance criteria. The 1% methyl lodide penetration stated in the FSAR is assigned a 9S% offidency in Table 2 of RG 1.52. The 0.175% methyllodide penetration stated in the Technical Specification is assigned a 99% efficiency in Table 2 of RG 1.52. Therefore, the Technical Spedfication and FSAR acceptance criteria do not agree. This is considered a ;
Level 4 discrepency as the Technical Spedfication acceptance criteria is more stringent than that identified in the FSAR.
Printed 229s 12.06 06 PM Paes 2 of 3
~ 1
- j i
,e- =-=-n,m.wa,ma, ,l Northeast utsties ICAVP DR No. DRws.4575 l l
Nm unit s Discrepancy Report e
Printed 2/MI612.06'07 PM p ,,,3 ,, 3
l Netheast Utlittles ICAVP DR No. DRW34M Milletone Unit 3 Discrepancy Report Reveew oreup: syenom DR Ms0LUTioN REJaCTEo Revtow teament: system Damien D6ecipene: m Desi'"
F . -i Type
- Cempenerd Does O vee
@) No s,. 1 . - HV5 NRc alsneseenseimi: 4 Date faxed to Nu:
Does Puhilshed: 12/as7
~
Deseressacy: Remote Instrumentation and Alarms for ESF Filter Systems Descetpelen: During the review of supplementary leak colledion and release system (SLCRS) filter units 3HVRTLT3A/B and auxiliary building ventilation system (A8VS) filter units 3HVRYLT1 A/B discrepancies regarding the remote Instrumentation and alarms required by ANSI N5091976 were identified.
FSAR Table 3.21 states that the ESF filter trains satisfy the requirements of ANSI N509 ANSI N5091976 Section 4.8.2 requires that the following items be provided at a central control room instrument panel:
Air temperature upstream of adsorbers Calibrated volumetric flow Indicator and recorder High/ low airflow alarms Ar shown on P&lDs EM 148A 24 and EM 148E 12:
High terinerature upstream of the adsorbers is not monitored A calibrated volumetric flow indicator and recorder is not provided High airflow alarms are not provided nevtew Vehd invahd Needed De8e inleiston Stout, M. D. O O O tir22sr v7 L.ed: N.n.Arenony^ O O O m22sr !
VT Men Schopfw, Don K O O O $ 287 IRC Chmn: S% Anand K Q Q Q 12/497 Date:
DNAUD:
Date: 2/2/98 nasolutioN: NU has determined that the issue reported in Discrepancy Report DR MP3-0705 does not represent a discrepent condition.
As stated in FSAR section 3.2.1, Table 3.21 specifies the seismic requirements for the components on that list, and that the applicable code is ANSI N509. Although this reference does not apply to the monitoring, alarming, and recording of flow
_ rates, the subjed is addressad in FSAR Table 1.61 "NRC Regulatory Guides" (R.G. No.1.52, section 6.5.1.2, paragraph C.2.g. as ammended by FSAR CR 97 MP3105), "The filter trains are not instrumented to monitor, alarm and record flow rates in the contml room. Flow through the filters are verified on a monthly basit..... ... .*
Prtreed 249s 12:06.47 PM Page 1 or 2
.-n. -
Nwtheast Ummes IOAVP DR No. DR4P34M notorm ut* 3 Discrepancy Report ,
i
- We have temperature alarms upstream and downstream of the .
adsod4rs. The upstream alarms are shown downstream of the heaters and alarm at VP1 in the control room. The downstream l alarms are shown on the downstream side of the adsortier bank ,
but are phys 6cally located on the downstream supports for the adsortier banks. These alarms go to the fire protsdion consolo ,
in the control room. The standard does not state that the upstream temperature alarm must be immediately upstream of the adsortier bank, so we are in full compliance on this issue. ,
- Significance Level Crtleria do not apply since this is not a !
ditoropent Condition. !
Provtounty teenmand by Nut V Yes T No Nonoleerepentcondmes*Q Yes @ No neestualenrenenetO vos @ we nosetuaanuar.eeh.dtO ves @ No 4 noview initiseen stout,M 0, vi t.and: Nort. Arweny A O O O m VT Men schapser. Don K .
Inc chnm: sagh, Anand K O -
- j. Date: 2/2/98 st.cenenente: Additionalinformation is requ6 red to complete review of NU's t'
response to DR MP3-0705.
1, FSAR CR 97 MP3105 was not identified as a pending FSAR
+
change in the listing transmitted with MS-IRF 00141 nor was it included with NU's DR response. NU is requested to provide a copy of this FSAR CR.
- 2. Agree that FSAR Table 6.51 states that filter units are in partial compliance with Reg. Guide 1.52 Rev. 2, paragraph C.2.g ,
and refers to FSAR Section 6.5.9.5 which states that flow indicators and recorders are not necessary. However, FSAR Tcble 1.81 which addsesses compliance with Reg. Guides does -
not take exception to paragraph C.2.g. FSAR Table 1.81 should be revised to include this exception
- 3. Agree that FSAR Table 3.21 specifies the seismic requirements for the components in the tabl3. Per FSAR Section 3.2.5, the table prov! des a concise compliation of the safety classes, codes, and design classifications of the strudures, systems, and components in Table 3.21 that are QA Category 1.
- This implies that the ESF filter units meet the requirements of ANSI N5091976. Therefore, exceptions to ANSI N5091976 should be identified and justified in the FSAR.
4
- 4. The temperature switches / alarms shown downfitream of the heaters are associated with the heater thermal overionds. This does not satisfy the ANSI N509 requirement to monitor the air temperature upstream of the adsortiers. This should be identified as an exception to ANSI N5091976 requirements in the FSAR.
PrWed 290s 1205.s1 PM Pese 2 or 2
Northeast Usities ICAVP DR N6. DR4P34731 Wiletone Unit 3 Discrepancy Report moview eroep: system on nasousfloN RsJECTRO noview element: system Dog Dissipane: Mecherocal Dee'"
obsereparey Type: DrenW O vee eyemenWPresses: HVX
-gg NRC Signiseenee level: 4 Date FAsad to NU:
Date Piddished: 12/2007 oleeresency: Charging Pump and Componert Cooling Water Pump Area Ventilation Winter Mode Damper Positions Desertpelma: During review of the charging pump and component cool 6ng water pump area ventilation system a discrepancy regarding the outside airflow during winter mode of operation was identified, Note 17 on PalD EM 148A 24 states that during winter mode of operation dampers 3HVR*DMP4 and 3HVR*DMP32 are set to approximately the 50% open position. The note does not identify the minimum outside airflow required for stable operation of exhaust fans 3HVRYN6A/B nor the maximum outside airflow sliowed in order to mairdain minimum room temperatures.
As shown in calculation S 92103191M3, Rev.1 (CCNs 1 thru 5) the amount of outside air drawn in by supply fans 3HVRTN14A/B directly effeds the ability of the system to maintain the minimum room design temperatures.
Based on the abovs, winter mode design airflows are not refloded on P&lD EM 148A & EM 1488, movbew vest inveed Needed Date inittster: stout M. D- 0 O O iniie7 VT Lead: Neri, Arthony A O O O $2me7 VT Men schos wer, Don K O O O 12/1157 inc ch: Singh, Anand K O O O $2tiss7 Date:
elWALE:
Date: 2/2/96 natoLUTioN: NU has determined that the issue reported in Discrepancy Report DR MP3-0731 does not represent a d;screpant condition.
Balancing dampers 3HVR*DMP4 and 3HVR*DMP32 were positioned to meet the flow requirements of PDCR MP3 93-014 for winter and summer conditions. Once the desired flow rates were ottained, the damper quadrants were painted and markeo as
- Summer
- or Winter
- positions. Changing from winter to summer is as simple as placing the damper quadrant handle to the desired position. The requirements specified in PDCR MP3-93-014 and verified by retest for the winter condition was a minimum flow of 15,500 cfm to 3HVRTN6A/B and a maximum outside air flew into fan 3HVRTN14A/B of 17,000 cim. It is not necessary to reflect this information on the P&lD.The ratio of outdoor air to indoor (recirculated) air does not change the volume of air moved by fans 3HVRTN14A/B, so stable Prtnted 249812.06.17 PM Page 1 of 2
4
- ' ' ' ' u=.w. e aw,m Northeast utiMes ICAVP DR No. DRWS 4731 Ministerm unit 3 - Discrepancy Report operation of the fans is not compromised by switching from summer to w6nter mode of operation.
The EEQ temperature ranges in the Charging Pump and CCP cubicios are monMored and excursions adivate alarms in the Control Room. There is no automatic control system goveming altflow eMher in terms of volutte or temperature.
For the above stated reasons, NU has determined that there is no value in putting airflow volumes on the P&lD, Sigidf6cance Level Criteria do not apply since this is not a discrepent condition.
Provtously ideneland try Nut V Vee @ No NonDeseropontCcadmienfU Yes @ No Reentuelen PendinerO von @ us casowienun,seeevedrO vos @ we Review Inteister 84eut, M. o. '
VT Lead: Nort, Anthony A O O O m -
vy me n se, con K O O O m sec counn: sinsh, Anand K Oste: 2/2/98 at cenenente: Agree with NU's response that PDCR MP3 93-014 identifies the mininum and maximum " Winter" mode outside airflows.
However, P&lD EM 148815 shows an aliflow of 20,000 cfm at retum air damper 3HVR*DMP4 which impl6es that when dampers 3HVR*DMP4 and 3HVR*DMP32 are repositioned for winter mode that the outside airflow is 7,00* cim An outside airflow of 7,000 cfm is below the minimum required for stable operation of far,s 3HVRTN6A/5. The PalD should be revised to correct the ,
drawing discrepancy.
The significance level has been revised to a Level 4 discrepancy.
Pftnted 2.99s 12.08.21 PM Page 2 or 2 i I
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