ML20247M043

Forwards Discrepancy Repts (Drs) Identified During Review Activities for Independent Corrective Action Verification Program.Drs Being Distributed IAW Communications Protocol, PI-MP3-01

ML20247M043
Person / Time
Site:	Millstone
Issue date:	05/20/1998
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9805260153
Download: ML20247M043 (62)

Text

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Don K. Schopfer Senior Vice President 312-269-6078 May 20,1998 Project No. 9583-100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed the following discrepancy reports (DRs) identified during our review activities for the ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.

I have enclosed the following eleven (11) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0039 DR No. DR-MP3-0851 DR No. DR-MP3-0226 DR No. DR-MP3-0929 DR No. DR-MP3-0497 DR No. DR-MP3-0996 DR No. DR-MP3-0598 DR No. DR-MP3-0999 DR No. DR-MP3-0697 DR No. DR-MP3-1088 DR No. DR-MP3-0713 I have also enclosed one (1) DR for which the NU resolution has been reviewed but not accepted. S&L comments on this resolution has been provided.

DR No. DR-MP3-0514

\

N 9805260153 9EOS2O kCO PDR ADOCK 05000423 p PDR 55 East Monroe Street

• Chicago, IL 60603-5780 USA 312-269-2000

. 1 United States Nuclear Regulatory Commission May 20,1998 Document Control Desk Project No. 9583-100 Page 2 Please direct any questions to me at (312) 269-6078.

Yours very truly,

%. p) t 1 D. K. Schopfer (

SeniorVice President and ICAVP Manager DKS:spr Enclosures Copies:

E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/1) Nuclear Energy Advisory Council J. Fougere (1/1) NU mnicavpkxan98WOS20-a. doc I

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.< l Northezt Utilities ICAVP DR N2. DR-MP3-0039 Millstone unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System Design I p

Discipline: P6 ping Design Discrepancy Type: Drawing Ow SystemProcess: sWP @) No NRC Sigmficance level: 4 Date faxed to NU:

Date Putgished: 9/11/97 D6screpancy: Upper Tier To Lower Tier Drawings Review For SWP in Diesel Generator Building

Description:

The Upper Tier to Lower Tier drawiligs review found the following drawing discrepancies between the P&lDs and the as built isometric drawings:

1. The following line number discrepancies were found on the drawings as noted:

On P&lD EM-133D Rev 23 versus isometric Cl-SWP-35S Sht 2 Rev 10:

3-SWP-010-264-3 (P&lD H-9) vs. 3-SWP-010-26-3 (ISO) 3-SWP-010-25-3 (P&lD H-9) vs. 3-SWP-010-264-3 (ISO) 3-SWP-010-26-3 (P&lD H-7) vs. unidentified (ISO) 3-SWP-010-40-3 (P&lD H-1) vs. 3-SWP-010-265-3 (ISO) 3-SWP-010-265-3 (P&lD H-1) vs. unidentified (ISO)

2. Cl-SWP-35S Sht 2 Rev 10 shows line 3-SWP-010-41-3 before j valve V-49 versus after V-49 on P&lD EM-133D Rev 23 (H-3).

3. E!6133D Rev 23 line 3-SWP-010-44-3 (J-1) is shown as 3- l SWP-010-266-3 on Cl-SWP-34 Sht 6 Rev 7. j

4. EM-133D Rev 23 line 3-SWP-010-25-3 (J-9) is shown as 3-  !

SWP-010-267-3 on Cl-SWP-34 Sht 6 Rev7.

5. No isometric drawings found for lines 3-SWP-008-416-3 and 3-SiNP-008-289-3.

Review Valid invalid Needed Date initiator: Road. J. W. B 0 0 Sr*S7 VT Lead: Nerl, Anthony A B D 0 Sr3/S7 VT Mgr: Schopfer, Don K O O O S'a/S7 1RC Chmn: Singh, Anand K B O O S/8/87 Date:

INVAUD:

Date: 5/19/98 RESOLUTION: 1st Response:

Disposition:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0039, do not represent discrepant conditions.

Item 1-4, the isometric, the P&lD and the Line Designation Table are all in agreement will each other and Section 4.4 of EDI 30255 which govems the development of these drawings.

I Printed 5/20/96 9:00:o4 AM Psge 1 of 3 t

. Northe:st Utilities ICAVP DR N2. DR-MP3-0039 Millstone Unit 3 Discrepancy Report item 5, the piping in question was provided by the Vendor with components 3EGS*E1 A / 2A and 3EGS*E1B / 2B (Diesel).

These lines can be found on Vendor Drawing 2447.300-241-150.

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

Conclusion:

NU has concluded that the issue: reported in Discrepancy Report, DR-MP3-0039, do not represent discrepant conditions.

The referenced drawings are in agreement with EDI 30255 which govems their development. Significance Level criteria do not apply here as this is not a discrepant condition.

2nd Response:

Disposition:

NU has concluded that the issues reported in DR-MP3-0039, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition -

which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of U3 Pt 20 deferral criteria.

ITEM 1: (a) This is a valid discrepancy: To enhance P&lD EM-133D, line number 3-SWP-010-26-3 will be added upstream of valve 3SWP*V16.(b) This is a valid discrepancy: To enhance isometric Cl-SWP-35S, line 3-SWP-010-264-3 continuation to Cl-SWP-25 will be revised to show the leader line for 3-SWP-010-264-3 above the floor line. (c) This item is NON.

DISCP' PANT: The isometric Cl-SWP-35S depicts line number 3-SW T-26-3 c the upstream side of valve 3SWP*V16, from Wile 3 SWP-OiO-264-3 and continues through the valve i until a new line number is depicted (3-SWP-008-239-3). The line I designation table also describes line 3-SWP-010-26-3, from line 3-SWP-010-264-3 to line 3-SWP-008-239-3. A new line number is only required if there was a change in size, schedule, temperature or pressure. This is not considered a discrepancy.(d) This is a valid discrepancy: To enhance isometric Cl-SWP-35S, line 3-SWP-010-265-3 continuation to Cl-SWP-40 will be revised to show the leader line for 3-SWP-010-265-3 above the floor line. (e) This is a valid discrepancy:

Line number 3-SWP-010-265 3 will be on depicted isometric Cl-SWP-35S as stated in item 1 (d) above.

ITEM 2: This is a valid discrepancy: To enhance P&lD EM-133D, line number 3-SWP-010-41-3 should be added upstream of valve 3SWP*V49.

ITEM 3: This is a valid discrepancy: To enhance isometric Cl-SWP-34 sh 6, line 3-SWP-010-266-3 continuation to Cl-SWP-44 will be revised to show the leader line for 3-SWP-010-266-3 above the floor line.

PrWed S/20/98 9 00:07 AM Page 2 of 3 L__.___ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ - . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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- Northe:st Utilities ICAVP DR N2. DR-MP3-0039 l

Millstone Unit 3 Discrepancy Report l

ITEM 4:This is a valid discrepancy: To enhance isometric Cl-SWP-34 sh 5, line 3-SWP-010-267-3 continuation to Cl-SWP-29 will be revised to show the leader line for 3-SWP-010-267-3 above the floor line.

l ITEM 5:NO DISCREPANCY, SEE SL COMMENT l DESCRIPTION.

Conclusion:

t NU has concluded that the issue reported in DR-MP3-0039, has identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets section 1.3.2.e of  ;

U3 PI 20 deferral criteria. CR M3-98-2170 was closed to Bin CR M3-98-0164 which will correct items 1,2,3, & 4 post startup.

Item 5 was agreed to be non-discrepant on the initial response to this DR, IRF M3-IRF-00331. (See S&L Comment Description)

There is no affect on License or Design Basis.

Previously identified by NU? O Yes (#) No Non Diecrepent Condithm?O Yes (8) No Resolution Pendmg?O ve. @ No Re.*tum uare.aved?O ve. @ No Review initiator: Tenwinkel, J. L VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/19/98 sL comments: 1st Response:

We have re-reviewed the line number discrepancies identified in items 1 thru 4 of this DR-MP3-0039 and remain convinced that j that the discrepancies between the P&lD and the isometric drawings exist as indicated.

We agree that item 5 is no longer a discrepancy, 2nd Response:

Based on NUs 2nd response, S&L agrees with the response and with NUs conclusion to retain this item as a valid Level 4 DR, notwithstanding the two sub-issues which NU has determined, and S&L agrees, to be non-discrepant as described in the response.

Printed 5/20/98 9:00:09 AM Page 3 of 3

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. NortheIt Utilities ICAVP DR N2. DR-MP3-0226 Millstone Unit 3 Discrepancy Report l l

l Review Group: Contguration DR RESOLUTION ACCEPTED Review Eiernent: system Installation p

Discipline: I & C Design Discrepancy Type: Installation implementaban Ow g

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System / Process: SWP NRC Significance level: 4 Date Faxed to NU:

Date Published: 12/14/97 Discrepancy: Instrument Mounting Ducription: Instrumentation mounting details are provided in vendor manuals and design drawings. The following discrepancies between design documents and the installation were noted during the system walkdown.

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l 1. Rosemount Vendor Manual 658-0028 require that instruments will be mounted level. Flow transmitter 3SWP-FT-59C is not installed level. Excessively out of level conditions may impact the accuracy of the flow transmitter causing mal-functions given the small pressure involved - this device l rneasures differential pressures in the range of inches of water. l l The difference in the elevation of the ports of this device resulting from the out-of-level condition could affect the ability of the instrument to accurately measure the pressure differential and, therefore, the flow in the pipe.

2. Helicoid /Ashcroft Vendor Manual 01M-226-002A requires that flush or wall-mounted gauges are to be installed by means of screws. Pressure indicators 3SWP-P1139A&B,140 A&B,141 A&B and 142 A&B are all mounted with only one of the three required mounting bolts / screws.

3. Mounting and corrosion / oxidation control requirements are set forth in Barton Manuals 01M-377-5A,01M-377.001B,01M-377.008A and Nu specifications SP-EE-212-D-3 (2.23-2.25)

NETM-22 (2.27 & 2.28). Improper instrument mounting and lack of corrosion / oxidation control can lead to premature device failure.

- Differential pressure transmitters mounting screws & star washers on 3SWP*PDIS 24A, B, C, D, and pressure transmitters 3SWP-PDIS 110A, B, C, D located in intake structure / pump house show significant signs of oxidation / corrosion. These instruments are exposed to a salt air atmosphere. The mounting screws, nuts and washers also may no longer meet seismic mounting and ASTM qualifications.

Instrument 3SWP-PDIS 1108 mounting screw does not have a star washer under screw head and no longer meets vendor mounting instructions.

Review Valid invalid Needed Date initiator: sarver, T. L 0 0 0 11/2s/97 VT Lead: Neri, Anthony A O O O 11'29/97 VT Mgr: schopfer. Don K O O O 2/se97 BRC Chmn: singh. Anand K O O O 2/8/97 Printed s/20/98 9:01:16 AM Page 1 of 3

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- N:rtheIt Utilitie3 ICAVP DR N2. DR-MP3-0226 Millstone Unit 3 Discrepancy Report Date:

INVAUD:

Dow: 5/19/98 RESOLUTION: FIRST NU RESPONSE:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0226, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0165 has been written to develop and track resolution of this item per RP-4.

Conclusion:

?".i aas concluded that Discrepancy Report, DR-MP3-0226, has K.entified a condition not previously discovered by NU which

.equires correction. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0165 has been written to develop and track resolution of this item per RP-4.

SECOND NU RESPONSE:

Disposition:

ltem i:

A field inspection indicates that the instrument is level. During perforniance of AWO M3-97-13056 the instrument was made level. No further corrective action is required.

Item 2:

AWO M3-98-06593 has been written in response to this item. It schedules work for the addition of bolts / screws for these instruments post start up.

Item 3:

Based on a walk down by the civil / structural design group completed on 5/6/98 the mounting screws, nuts and washes are acceptable and do meet the seismic mounting criteria, based on the smallload and minor amount of corrosion. The missing star  !

washer on 3SWP-PDIS110B does not provide a structural i function. AWO's M3-98-06595,06596,06597 and 06598 have been written in response to this item and schedule work to correct these issues.

l This discrepancy meets the criteria specified i- NRC letter

! B16901 and 17010. It has been screened per U3 PI-20 criteria Pnnted 5/20/98 9 01:19 AM Page 2 of 3

Northert Utilities ICAVP DR No. DR-MP3-0226 l

Millstone unit 3 Discrepancy Report and found to have no operability or deportability concems and meets the Unit 3 deferral cliteria. U3 PI 20 section 1.3.2 e defines the type of discrepancies which will be completed during the next refueling outage or later. Attachment 11 defines the ,

l type of issues which will be completed prior to startup. The intent of attachment 11 is to correct issues prior to startup that would inhibit operations from aligning the plant systems for safe operations in accordance with the design basis.

NU concludes that the assignment of priority 4 is correct and in accordance with U3 Pl 20 section 1.3.2 e.

Conclusion:

NU has concluded that the issues reported in DR-MP3-0226 have identified a CONFIRMED SIGNIFICANCE LEVEL 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. Item i has been corrected. The corrective action in CR M3-98-0165 will respond to and address items 2 and 3 post startup.

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Previously identified by NU? O Yes (9) No Non Discrepant condition?O Yes (G) No Resolution Pending?O ves @ No Resolution Unresolved?O yes @ No Review I Acceptable Not Acceptable Needed Date initiator: Johnson, Jay VT Lead: Nerl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: singh, Anand K Dde: 5/19/98 sL comments: S&L COMMENTS ON FIRST NU RESPONSE:

The corrective action is not apparent from the DR description or from CR M3-98-0185.

It is not apparent why maintenance to 3SWP*PDIS24A, B, C and I D can be deferred to after startup, in addition, it is not apparent if there are any two over one considerations evaluated for the non 1E devices.

S&L COMMENTS ON SECOND NU RESPONSE:

The NU response for items 1 and 3 is acceptable as stated.

For item 2, AWO M3-98-06593 has completed the installation of the missing bolts prior to startup, thereby resolvir.g any Seismic ll/l concems. This AWO has been provided to S&L as requested in the 5/18/98 telecon. Therefore, S&L finds the resolution of item 2 to be acceptable.

Printed 5/20/98 9.01:21 AM Page 3 of 3 i

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. Northert Utilitie3 ICAVP DR No. DR-MP3-0497 Millstone Unit 3 Discrepancy Roport Review Group: System DR resol UTION ACCEPTED Review Element: system Design Potential Operability issue Diecipline: Piping Design Q yeo Discrepancy Type: calculation System / Process: sWP

@ No NRC Significance level: NA Date faxed to NU:

Date Published: 10/26/97 Discrepancy: Integration time steps may be insufficient to capture peak hydraulic transient forces

Description:

In the process of reviewing the following documents, (i) Flow Transient Calculation No.12179-NP(B)-270-FA, Rev. 02 (ii) Flow Transient Calculation No.12179-NP(B)-271-FA, Rev. 04 we note the following:

Background and Discussion:

The hydraulic models of the piping networks addressed by (i) and (ii) consist of pipe segments from 3 ft. to 30 ft. In length.

Typical pressure wave velocities in water filled pipes range from 3000 to 4500 fps.

Calculation NP(B)-271-FA uses a pressure wave velocity of 2000 fps and validates this assumption based on field tests conducted on the circulating water system st the North Anna Station. (Ref.

6.19," Report on Hydraulic Transient Analysis and Related Circulating Water System Studies", North Anna 1&2, by SWEC, July,1979.) This calculation was requested for review under RFI 463, item 5.

The analytical integration time step used to establish the pressure force time histories on piping segments is 0.004 sec.

For pressure wave velocities of 2000 fps and 4000 fps, using a time step of 0.004 sec, results in the wave traveling a distance of 8 ft and 16 ft, respectively, during the time step. These distances are greater than numerous segments in the piping model.

Based on a review of the force time history plots, some segment forces hit peak (maximin.) values at adjacent (0.004 sec) time steps. This demonstrates that the pressure transient is very rapid and may occur or reach peak values at some time between the evaluated 0.004 see time step increments.

Discrepancy:

Based on a review of calculations (i) and (ii), we believe the evaluated integration time step of 0.004 sec may not capture the transient forces in some piping segments and under predict some peak forces. l The referont ad hinrth Annn calmdntinn neod in petnhfith the

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Printed 5/20/98 9:01:56 AM Page 1 of 8 1

P Northerst Utilitie3 ICAVP DR No. DR-MP3-0497 Millstone Unit 3 Discrepancy Report 2000 fps pressure wave speed could not be identified in the NU calculation data base.

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

8 O O 10/'S7 VT Lead: Neri, Anthony A B O O 10'15'87 VT Mgr: schopfer, Don K B O O 50/20/97 IRC Chmn: singh, Anand K B O O $ot21/97 Date:

INVALID:

Date: 5/19/98 RESOLUTION: First Response ID: M3-IRF-01774 Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0497, does not represent a discrepant condition. As noted in the DR, the chosen time step for the fluid transient analysis in 1) and li) is .004 seconds. This time step is considered appropriate for both calculations for the following reasons:

Two different Stone & Webster computer programs were used in calculations i) and li). Calculation i) is based on Stone & Webster computer code WATAIR (WATAIRO Code, ACSL modified version of ME-180 WATAIR) and uses a momentum force method of analysis. The position of the water and air segments within the piping model are tracked based on the driving pressure or boundary device, such as a pump, and the resisting pipe friction and elevation changes. The water columns or sections of water-filled piping are tracked as incompressible bodies separated by compressible volumes of gas. Forces result from the acceleration and momentum force differences between various fluid conditions as the fluid and gas pass through the piping system in response to valve actuation or pump start. The acceleration term is analogous to F1 = M

• a (Mass times acceleration) and the momentum term is analogous to the relationship F2 = rho *A*V"2 (density times Area times the velocity squared). These terms are combined when computing the unbalanced forces acting on each segment. Note that the pressure wave speed (C) is not a variable in the determination of pipe segment forces in the WATAIR computer program.

For segment loading the momentum term is usualty small and the acceleration term govems. The force on each segment due to the acceleration term varies according to the actual mass of fluid in that segment. Segment forces therefore vary or scale directly with the segment length. As an example, the segment lengths for Pump 1 A, Case 1* listed on page 13 of calculation i) located between MOV 102A and the pump suction vary from 3.021 feet to 31.672 feet. The corresponding peak force for each of the segments is given on page 23, illustrating the linear dependence of segment force on segment length. The time Printed s/2098 9 o2:00 AM Page 2 of 8

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• Northext Utilitie3 ICAVP DR NO. DR-MP3-0497 Millstone unit 3 Discrepancy Report history loading on each segment as determined by this method is applied in NUPIPE piping model. Thus, all segments are loaded as a result of the fluid transient event and the results do not depend on the pressure wave speed. NU has concluded that there is no discrepancy with regards to this calculation.

Calculation li) is based on Stone & Webster computer code WATHAM (ME-168, V02LO2, 83.347) which uses the Method-of-Characteristics in solving the fluid transient equations. This analytical method computes the pressures and flow responses accurately at the node points as determined by the time step selected. Thus, for a time step of 0.004 seconds and pressure wave speed of 2000 ft/sec, the flow responses will be accurate for 8 foot segment length and longer. The node point spacing used in this calculation is 10 feet. it is noteworthy that typical transients involving for example a pump restart or valve closure are not step functions. For example, the pump time to ramp up is 1.5 seconds in the present case (refer to page 71 of calc. ii)). In the case of column rejoining, the non-condensable gases (air) provide cushion and would be expected to slow the impact associated with columns rejoining. For such transients, a time step of 0.004 seconds used in li) is sufficient to capture the resulting peak transient forces. The segment forces for any segments less than the nodal span length for the particular analysis were computed using linear interpolation. The linear interpolation is considered to be acceptable for two reasons.

First, very short segments typically have relatively small forces acting on them which would not be controlling in a piping eva'uation since the short segment is adjacent to longer segments with larger imposed loads. Second, the linear interpolation of the pressure wave energy within the segment is considered to be a reasonable approximation of the actual unbalanced forces in these pipe segments for gap closure transients as the dominant force contribution is due to inertial effects. This was verified in a recent conversation between D. A.

Van Duyne and the WATHAM program author, Dr. J. S. Hsieh.

As before, the calculated force-time history is generated and applied to each piping segment regardless of its length (see piping segment lengths in Tables on pages 46-63 and forces on pages 100-188 of calculation ii) respectively)

Pressure Wave Speed:

Assuming no entrained air, pressure wave velocities in water filled pipes range from 3000 to 4500 fps. Calculation (ii) uses a i pressure wave velocity 2000 fps based on a conservative assumption that 0.1 percent of air content by volume is entrained

)

in the service water and a plot of pressure wave speed from Hydraulic Transients by Streeter and Wylie (see page 270 of calculation li)). Further evidence for this assumption includes I the reference to field tests conducted on the circulating water system at the North Anna Station (page 12, Ref. 6.19, " Report of Hydraulic Transient Analysis and Related Circulating Water System Studies," North Anna 1 & 2, by SWEC, July,1979) which reported wave speeds measured as beina approximately 1200 Printed 5/20/96 9:02:02 AM Page 3 of 8 i

N rtheast Utilities ICAVP DR No. DR-MP3-0497 Millstone Unit 3 Discrepancy Report fps. (This report was requested by S&L under RFI 463, item 5 and is attached). Water hammer field test performed on the MP3

, service water system during startup in November 1984 have i generally yielded measured forces that were significantly lower than those typically predicted by the fluid transient analysis.

Thus, NU believes that assumption of pressure wave speed of 2000 feet per second for the Long Island Sound water is reasonable and appropriate.

Conclusions:

Based on the discussion provided above, the chosen time step and the pressure wave speed of 2000 ft/sec is considered reasonable and appropriate for the service water transients analyzed by calculation ii). The pressure wave speed is not a variable in calculation 1). Segment forces were applied in all segments regardless of the length based on linear interpolation.

Thus, the condition identified by the DR is not considered discrepant. Significance Level criteria do not apply as this is not a discrepant condition.

Attachments: Ref. 6.19, " Report of Hydraulic Transient Analysis and Related Circulating Water System Studies," North Anna 1 &

2, by SWEC, July,1979)

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0497, does not represent a discrepant condition. The chosen time step accurately computes the forces at the node points for the transients under consideration. The piping segment loads are determined in proportion to the segment lengths. The results of the calculations are valid. Significance Level criteria does not apply here as this is not a discrepant condition.

Second Response ID: M3-IRF-02255 Disposition:

NU has concluded that this issue reported in DR-MPC I'C497 has identified a NON-DISCREPANT condition. Thepressure wave speed of 2,000 fps used in calculation 12179-NP(B)-271-FA was supported by the field test results performed at North Anna, and the waterhammer test results performed during startup of MP3 which measured significantly lower loads than predicted analytically. S&L stated that the MP3 startup tests would provide the most definitive basis for the use of 2,000 fps in the analysis.

These test reports were previously requested by S&L, but could not be located by NU (M3-IRF-00463 and M3-IRF-00764).

Further investigation has located the test reports, which are (1)

" Service Water System Hydraulic Test, Tests Conducted in November,1984 by Northeast Nuclear Energy Company and Stone and Webster Engineering Corporation", dated 1,21/85, and (2)" Service Water Svstem Hydraulic Transient Re-Test.

Printed 5/20/98 9:02:02 AM Page 4 of 8

Northert Utilities ICAVP DR N2. DR-MP3-0497 Millstone Unit 3 Discrepancy Report Tests Conducted in February,1985 by Northeast Nuclear Energy Company and Stone and Webster Engineering Corporation",

dated April,1985. They are provided as an attachment to this response.

The 1984 Test (item {1} above) showed that the predicted results .

were more conservative than the analytical results by a factor of l 1.5 to 3.7, for the vapor gap closing. The 1985 test (item {2}

above) validated the effectiveness of the system modifications made as a result of the first test, and demonstrated that the check valve closure loads were close to those predicted.

Therefore, these tests validate the appropriate nature of the assumptions utilized in the fluid transient calculations, including the 2000 fps wave speed.

Based on the above, the analysis performed in calculation 12179-NP(B)-271-FA is appropriate.

Significance Level criteria do not apply here as this is not a 1 discrepant condition.

I Attachments: Service Water System Hydraulic Test, dated 1/31/85 Service Water System Hydraulic Transient Re- l Test, NES-38558, dated May 16,1985

Conclusion:

NU has concluded that this issue reported in DR-MP3-00497 has identified a NON-DISCREPANT condition. The pressure wave speed of 2,000 fps used in calculation 12179-NP(B)-271 FA was supported by the field test results performed at North Anna, ar.d the waterhammer test results performed during startup of MP3 which measured significantly lower loads than predicted analytically. Further investigation has located the (attached) test reports dated 1/31/85 titled " Service Water System Hydraulic Transient Test and transmittal memorandum NES-38558 dated May 16,1985 titled " Service Water System Hydraulic Transient Re-Test.

The 1984 Test (item {1) above) showed that the predicted results were more conservative than the analytical results by a factor of 1.5 to 3.7, for the vapor gap closing. The 1985 test (item {2) above) validated the effectiveness of the system modifications made as a result of the first test, and demonstrated that the check valve closure loads were close to those predicted.

Therefore, these tests validate the appropriate nature of the assumptions utilized in the fluid transieat calculations, including the 2000 fps wave speed.

Based on the above, the analysis performed in calculation 12179-NP(B)-271-FA is appropriate.

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

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Northert Utilitica ICAVP DR No. DR-MP3-0497 Millstone unit 3 Discrepancy Report Resolution Pending?O ve. (e.) No Resolution Unresolved?O v. @ No Review initiator: Olson, P.R.

i VT Lead: Neri, Ardhony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Date: 5/19/98 l SL Comments: First Response l 10: M3-IRF-01774 S&L accepts NU's response regarding the analytical time steps used in the calculations subject to resolution of the assumed wave speed issue, which is further discussed below.

Pressure Wave Speed i

A pressure wave speed of 2000 fps is used in calculation 12179-NP(B)-271-FA. The following three reasons for using this value '

are provided in NU's response.

1. The 2000 fps value is based on the conservative assumption j that 0.1 percent of air content by volume is entrained in the i service water.

2. Field tests on a circulating water system (North Anna Station) demonstrated wave speeds of approximately 1200 fps in the discharge tunnel.

3. Water hammer field test performed on the MP3 service water system during start up in November 1984 have generally yielded measured forces that were significantly lower than those typically predicted by the fluid transient analysis.

S&L's comments on these responses are as follows;

1. The NU statement that 0.1 percent of air content by volume is conservative and entrained in the service water; A) is not ,

supported by any discussion as to the mechanisms contributing to )

the air entrainment condition and B) no basis is provided for the i

" conservatism" associated with the 0.1 air content by volume '

value.

2. Circulating water system field tests (North Anna Station) are reported to have demonstrated lower wave speeds. The report provided by NU," Report of Hydraulic Transient Analysis and Related Circulating Water System Studies," page 12, discusses the reasons for the test and possible mechanisms contributing to i air entrainment. These include the effects of the water boxes and

! uncertainties of wave speeds in large rectangular flow channels. It l also notes that the revised system logic and equipment, decreased the systems analytical sensitivity to the wave speed, even though wave speed is typically a significant factor in the magnitude of transient loading. Given the above considerations, Printed 5/20/98 902:05 AM Page 6 of 8

Northe:ct Utilitirs ICAVP DR No. DR-MP3-0497 Millstone Unit 3 Discrepancy Report NU should provide a clear basis as to how the circulating water system and test at North Anna is applicable to the Service Water system at MP3.

3. The results of the field tests at MP3 would provide the most definitive basis for the analytical application of the 2000 fps wave speed for the service water system. It is our understanding that two tests were performed in the past, the noted start up test in November 1984 and an April 1985 re-test. It was our understanding the re-test was done to investigate system response associated with the addition of new check valves and recommended changes to various valve positions and opening /

closing times. Therefore, in an attempt to review and compare the latest test results against the analysis, we previously requested the April 1985 re-test report in M3-RF1-00463 (item 4). NU's response in M3-IRF-00764 was that this report could not be located and was not available for shipment to S&L. In the absence of the test data, NU's statement that the test " generally yielded" lower forces from those " typically predicted" should be clarified and expanded upon. If this test or other tests on the MP3 service water system clearly demonstrated peak forces lower than those given by the analysis, then the use of the 2000 fps wave speed is justified. NU should provide a comparison of the test results with analytically computed values in order to validate the application of the 2000 fps wave speed.

Second Response ID: M3-IRF-02255 S&L has reviewed the following two additional documents provided by NU

1. Service Water System Hydraulic Test, dated 1/31/85

2. Service Water System Hydraulic Transient Re-Test, NES-38558, dated May 16,1985 in conjunction with the following previously provided documents

3. Calculation 12179-NP(B)-271-FA, Rev. 0

4. Calculation 12179-NP(B)-280-FA, Rev. O, Model - Data Comparison of Service Water System Hydraulic Transient Test for Vapor Gap Closure, (Voided Status)

Based on this review, we concur with NU's conclusion that the test data, provided by Service Water System Hydraulic Transient Re-Test, NES-38558, dated May 16,1985, yields loads which were close to those predicted. Since the measured test data compares favorably with the design capacity of pipe supports in the load path, the issues related to this DR are shown to not result in a discrepant condition.

It is noted that the design of the piping and pipe support system is based on the fluid hydraulic model of calculation NP(B)-271-FA which investigated the vapor gap closure transient based on an assumed 2000 fos wave speed. The Service Water System Printed 5/20/98 9:02:06 AM Page 7 of 8

l-l DR N2. DR-MP3-0497 Northea:t Utilities ICAVP Millstone Unit 3 Discrepancy Report Hydraulic Test, dated 1/31/85 and Service Water System Hydraulic Transient Re-Test, NES-38558, dated May 16,1985 demonstrates the following;

1) The significant vapor gap closure transient has been eliminated by the installation of the high point vent to the HVK heat exchangers. Therefore, the 2000 fps wave speed assumption is of reduced importance, and i

2) The pump trip check valve closure transient, which was never explicitly evaluated but clearly observed during the tests, is sensitive to system flow paths. Specifically, any potential system line up which would not allow flow to at least one CCS heat exchanger, may result in check valve closure transients greater than those for which the system is designed.

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+ I Northe:st Utilities ICAVP DR Ns. DR-MP3-0598 l Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: Modification Design Potential Operability issue Discipline Mechah %n Discrepancy Type: Installation implementation O vos j

! System / Process: sWP (e) No l NRC Significance level: NA Uete faxed to Nu:

Date Published: 1/10/98 )

Discrepancy: PDCR MP3-91-056 Did Not Adequately Address Breached Barrier nor Pump Assembly Requirements

Description:

PDCR MP3-91-056 was initiated to change the shaft and coupling materials on 3SWP*P1C from the original Monel 400 to Nitronic 50 for improved resistance to corrosion.

With respect to removal and reinstallation of pump intemal parts, no procedures were referenced to control this work. Drawings referenced in the package were not included with the package, and are designated in GRITS as vold, with later drawing revisions noted for each, and indicating that they are not available on aperture cards.

It should be noted that even though this PDCR was generated, no closeout documentation was included with the PDCR, and it therefore cannot be determined whether or not these activities I actually took place.

Review Valid invalid Needed Date initiator: Tenwinkel. J. L. O O O 12r22/97 VT Lead: Neri, Anthony A B O O 12r20/97 VT Mgr: schopfer, Don K G O O 2/23/97 IRC Clwnn: singh. Anand K B O O i2/31/97 Date:

INVALID:

Date: 5/19/98 l RESOLUTION: 1st Response:

Disposition:

NU has concluded that Discrepancy Report, DR-MP3-0598, has I identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.1701011 has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3.98-0513 has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR MP3-0598, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 Pl-20 criteria and found to have no operability or deportability Printed Sr20/98 9 03 03 AM Page 1 of 3

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Northzst Utilities ICAVP DR Nr. DR-MP3-0598 Millstone Unit 3 Discrepancy Report concems and meets the Unit 3 deferral criteria. CR M3-98-0513 has been written to develop and track resolution of this item per RP-4.

2nd Response:

Disposition:

NU has concluded that the issue reported in DR-MP3-598 has identified a NON DISCREPANT condition.

The first issue of the original discrepancy states that no procedures were referenced to control this work. Section 5.1 of the PDCR, " Design inputs and Detailed Design" states

" Attachment unnecessary due to design simplicity." Since this was a simple replacement of a component part, this work was controlled by the Work Order process which would have invoked the appropriate maintenance procedures for performing pump work.

The second issue of the original discrepancy states that drawings referenced in the package were not included. No drawings are referenced in the PDCR proper; however, DCNs DM3-P-085-91 and DM3 P 095-91 are referenced in the PDCR. These two DCNs refer to drawings 2332.502-004-6F and 2332.502-004-9A.

These drawings correspond to NU number 25212-29004, sheets 6 and 9. Per GRITS, these DCNs were incorporated into the subsequent revision of the drawings (attached) indicated in the DCNs. [ Note: these drawings were subsequently voided by DCN DM3-S-0522-94 (attached). The applicable drawing for these pumps now is 25212-29004, sheet 10 (2332.502-004-010L).]

The last issue of the original discrepancy states that no closecut documentation was included with the PDCR. The attached copy of the PDCR indicates the PDCR was closed out 12/14/91.

Significance level criteria are not applicable as this is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in DR-MP3-598 has identified a NON DISCREPANT condition. The PDCR was performed I/a/w the Work Order process. Updating of associated drawings was accomplished via DCNs DM3-P-085-91 and DM3-P-095-91 and documented in GRITS. The PDCR was closed out 12/14/91.

Previously identifbed by NU? O Yes @ No Non Discrepant Condition?@) Yes O No Resolution Pending?O Yes @ No Resolution Unresolved?O Ye. @ No Review initiator: Tenwinkel, J. L.

VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K g gg O O O Date: 5/19/98 SL Comments: 1st Response:

Printed 5/20/98 9:o3:07 AM Page 2 of 3 l

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Northerst Utilities ICAVP DR N2. DR-MP3-0598 Millstone Unit 3 Discrepancy Report The NU disposition, including attachments, does not indicate corrective action to resolve the discrepancy. The DR Review Screen states only that the "PDCR is still in progress," even though the PDCR is over 6 years old.

2nd Reponse:

S&L concurs with NUs second response in light of additional attachments fumished with that response which indicate proper cotrol of the work process and closeout of the documentation.

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Printed 5/20/98 9:03.08 AM Page 3 of 3 l

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Northe:st Utilitica ICAVP DR N2. DR-MP3-0697 Millstone Unit 3 Discrepancy Report Review Group: Systern DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Component Data O yes g

System / Process: HVX "

NRC Significance level: 4 Date faxed to NU:

Date Published: 12/&97 ,

D6screpancy: ABVS and SLCRS Fire Dampers

Description:

During review of the auxiliary building ventilation system (ABVS) and supplementary leak collection and release system (SLCRS) fire dampers discrepancies regarding fire damper sizes were identified.

The sizes of the following fire dampers shown on specification 2170.430-565 data sheets do not match the available fire damper sizes shown on DCN DM3-01-1296-96 and DCN DM3 12986-96 (drawings 25212-29565 sh. 555 and 556):

3HVR*DMPF6 41"x17" with minimum of 2 sections 3HVR*DMPF7 41"x17"with minimum of 2 sections 3HVR*DMPF8 33"x21" 3HVR*DMPF18 50"x24"with minimum of 2 sections f 3HVR*DMPF23 54"x36" with minimum of 2 sections 3HVR*DMPF24 34"x36" with minimum of 2 sections 3HVR*DMPF25 54"x36"with minimum of 2 sections 3HVR*DMPF26 20"x10"with minimum of 2 sections 3HVR*DMPF29 15"x30" 3HVR*DMPF30 30"x30"with minimum of 2 sections 3HVR*DMPF31 10"x10"with minimum of 2 sections 3HVR*DMPF32 14"x12" with minimum of 2 sections 3HVR*DMPF44 15"x30" 3HVR*DMPF60 8"x5"with minimum of 2 sections 3HVR*DMPF61 9"x7" with minimum of 2 sections l 3HVR*DMPF62 10"x9" with minimum of 2 sections  ;

3HVR*DMPF64 8"x4"with minimum of 2 sections 1 The maximum UL rated single damper section size of 36"x36" shown on drawings 25212-29565 sh. 555 and 556 is exceeded for the following fire dampers 3HVR*DMPF10 48"x48" requires a minimum of 4 sections compared to 2 listed in data sheet 3HVR*DMPF12 48"x48" requires a minimum of 4 sections compared to 2 listed in data sheet.

l 3HVR*DMPF14 48"x48" requires a minimum of 4 sections l compared to 2 listed in data sheet.

3HVR*DMPF16 48"x48" requires a minimum of 4 sections compared to 2 listed in data sheet.

The sizes for the following fire dampers shown on the data sheets and in PMMS do not match 3HVR*DMPF17 38"x32"-vs- 50"x24" 3HVR*DMPF8 33"x21"-vs- 17"x42" Pnnted 5/20/98 9:03.42 AM Page 1 of 4

Northert Utilities ICAVP DR Ns. DR-MP3-0697 Millstone Unit 3 Discrepancy Report 3HVR*DMPF6 41"x17"-vs- 17"x42" Review Valid invalid Needed Date initiator: stout, M. D.

B 0 0 1 /21/97 VT Lead: Nerl. Anthony A B O O 1 /22/97 VT Mgr: schopfer, Don K O O O 12/1/97 BRC Chmn: singh, Anand K O O O 12/4ro7 Date:

INVALID:

Date: 5/19/98 REsOWTION: First Response NU has concluded that Discrepancy Report DR MP3-0697 has identified a condition not previously discovered by NU which requires correction.

The sizes given in the purchase specification data sheets for

• DMPF17; 8; 7; and 6 do not match the sizes given in PMMS for the same dampers. NU acknowledges this discrepancy. It should be noted that PMMS is not the MP3 design data base; PDDS is. The approved corrective action plan for CR M3 4572 will correct the PMMS errors post startup.

NU has concluded that the remaining two issues reported in Discrepancy Report DR MP3-0697 do not represent discrepant conditions.

The minimum 2 sections specified in the damper data sheets in 2170.430-565 for safety related fire dampers is intended to prevent the failure of one single fire damper section from impairing the safety function of the system. The specification approves two manufacturers for Cat i fire dampers; Air Balance Co. and Ruskin Mfg Co. Approved mfg. drawings 25212-29565, sh. 555 and 556 show that 4"x4"is the minimum available single size and 36"x36"is the largest available single size. It should be understood that the manufacturers, Air Balance Inc. and Ruskin had the option of fabricating the finished assemblies of fire campers from more than 2 single sections, and remain in compliance with the requirements of 2170.430-565.

The maximum UL rated single damper section size of 36" x 36" shown on drawings 25212-29565, sheets 555 and 556 is not exceeded by the sizes given for *DMPF10; 12; 14; and 16. Each of these is a 48" x 48" (overall) fire damper constructed from four (equal size) single damper sections. Although the purchase specification data sheets state that each of these dampers must be made from a minimum of 2 single damper sections, to meet the single failure criterion, the damner supplier may, for manufacturing or fabricating considerations, supply fire dampers made of more than 2 single sections and still comply with the requirements of 2170.430-565. In this case, Air Balance Inc.

specifies a maximum single section size of 36"x36", so a 48"x48" fire damper assembly must be made from more than 2 Printed 5/20/98 903:45 AM Page 2 of 4 I

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Northe:st Utilitie3 ICAVP DR N2. DR-MP3 0697 Millstone Unit 3 Discrepancy Report i

j sections..

l The errors found in PMMS do not affect licensing basis or design basis and have no technical significance with regard to periodic testing of safety related fire dampers. NU, therefore, considers this a Significance Level 4 issue.

Attachments:

CR M3-97-4572 with corrective action plan Second Response (M3-IRF-02113)

NU has concluded that the restated problem reponed in

, Discrepancy Report DR-MP3-0697 does not represent a l discrepant condition.

Dampers 3HVR*DMPF10,12,14, and 16 were purchased on P.O. number 12179-15335. This purchaso orderlists these l dampers as item numbers 13,15,17, and 19. The data sheets for each of these dampers state that they are made up of two

! minimum sections (item F), in accordance with the requirements l of specification 2170.430-565, however, the manufacturer's

! model number given for each of these units is 319ALV. The manufacturer's drawing attached to the purchase order displays l this model as a four section assembly. Copies of the data sheets l and the Air Balance Inc. drawing of the model 319ALV multi-

! section fire damper are attached.

1 l Tne information given in drawings 25212-29565, sh. 555 and 556 is generic to all the MP3 safety related fire dampers. Detailed information on each of these dampers can be found in the

[ purchase orders issued to the two approved vendors, Ruskin and Air Balance.

Configuration of the safety re!ated fire dampers is in accordance with the MP3 design basis and licensing basis. NU considers

this issue non-discrepant. NU's previous response stated in M3-l lRF-01205, concluded that the PMMS database was in error and I would be revised per the approved corrective action for CR M3-97-4572. NU, therefore, considers this issue Significance Level 4.

Attachments:

P.O. No.12179-15335, pages 9 through 13, and dwg. Mi-2566-2 Previously identified by NU? O Yes I*) No Non Discrepant Condition?O Yes @ No Resolution Psoding?O res @ No Resolution Unresolved?O yes @ No Review Acceptable Not Acceptable Needed Date inh Stg M D.

VT Lead: Neri. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh. Anand K oste: 5/19/98 SL Comments: Comments on First Response Printed 5/20/98 9:03 47 AM Page 3 of 4 t_________________________ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _

Northe c t Utilitie3 ICAVP DR N2. DR-MP3-0697 Millstone Unit 3 Discrepancy Report Dampers 3HVR*DMPF10,12,14, & 16 require a minimum of 4 sections inorder to meet the UL maximum section size limits.

Provide vendor submittal drawings or other documentation that confirms that these dampers were fabricated with 4 sections.

Drawings 25212-29565 sh. 555 and 556 and spec data sheets should be revised to reflect that the dampers require a minimum of 4 sections.

i NU's response did not adequately address the differences in damper sizes shown on the data sheets and drawings 25212- j 29565 sh. 555 and 556. Documentation on the damper sizes and number of sections fabricated and installed are needed.

Comments on Second Response Agree with NU's response that S&W PO 12179-15335 calls out Air Balance Model 319ALV for vertical fire dampers (3HVR*DMPF10,12,14, and 16) and that Air Balance drawing Ml-2566-2 shows a four section fire damper. Since these dampers l require 4 sections to meet maximum section size limits drawings 25212-29565 sh. 555 and 556 and specification data sheets should be revised to reflect that the dampers require a minimum of 4 sections. This is considered a Level 4 documentation  !

discrepancy, i l

NU's response did not address the differences in damper sizes I shown on the specification data sheets and DCN DM3-01 1296-96 (drawings 25212-29565 sh. 555 and 556). This is considered a Level 4 discrepancy.

Additional Comments Since Air Balance drawing Mi-2566-2 (S&W PO 12179-15335) I shows that 3HVR*DMPF10,12,14, and 16 are four section fire l dampers and the specification data sheets show the fire damper i sizes the lack of specific fire damper size and section information l in DCN DM3-01-1296-96 (drawings 25212-29565 sh. 555 and i l

556)is considered non-discrepant.

The purpose of DCN DM3-01-1236-96 was to create drawings of the Q fire dampers to maintain the vendor information in one place. The DCN provides vendor info regarding damper free area for standard duct sizes, pressure drop and leakage data based on damper free area and the number of mullions (sections) for standard duct sizes. The differences in the damper sizes shown on the specification data sheets and the standard damper sizes listed in the table in DCN DM3-01-1296-96 (drawings 25212-29565 sh. 555 and 556) are considered non-discrepant since the DCN does not identify specific fire damper.

This is considered a level 4 discrepancy based on the approved corrective action of CR M3-97-4572.

Pnnted SP20/98 9.0148 AM Page 4 of 4

Northe:st Utilities ICAVP DR No. DR-MP3-0713 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: systern Design Potential Operability issue Diecipline: Environrnnental Qualircation Discrepancy Type: Calculation Q y ,,

System / Process: Oss @ No NRC Sign!ficance level: NA Date faxed to NU:

Date Published: 12/21/97 Discrepancy: Equipment Qualification Discrepancy DesMption: EEQ-TRA-113.0, Rev.1, dated 1/14/1997 is the Electrical Equipment Qualification Test Report for Class IE General Electric (GE) Quench Spray Pump Motors (Plant I.D. No.

3OSS*P3A,B). It states on Sheet 2 of 7 that the GE test report GEK-42842 titled,

• Topical Report IEEE 323 Class IE Induction Motors, Horizontal Class B insult.ted, Model Numbers j SK821051CC, SK821054C26, SK828840C88", dated December l 1978 meets the requirements of DOR instead of R>G 1.89, Rev. J 1 and IEEE 323-1974.

This conclusion was bued on the fact that the motor qualification in the GE Topical Report was based on separate testing and operating experience which does not meet the requirements of IEEE 323-1974.

However, the Procurement Specification No. 2441.003-009, Rev.

2, page 1-17 of states that these pump motors should be environmentally quali'ied in accordance with IEEE 323-1974.

Also, Millstone FSAR Section 3.118.2.2 states that the, l

Environmental Qualification of all safety-related equipr,1ent shall J meet the requirements of IEEE 323-1974, the intent of NUREG-0588, and NRC 10CFR50.49.

Review Valid invalid Needed Date initiator: Yassin, s.

9 O O iii24/97 VT Lead: Neri, Anthony A B O O si29/97 VT Mgr: schopfer, Don K O O O 12/5/97 IRC Chmn: singh. Anand K B O O 12/9/97 Date:

INVALID:

Date: 5/19/98 RESOLUTION: NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition.

Environmentally qualified equipment must be type tested or analyzed to withstand the postulated environmental canditions expected during its service life including a design basis accident.

The task of comparing the results of a type test to installed conditions is a three part process. The first part is to validate the l te . report and summarize the results, second is to document

! generr.1 technical issues and aging calculation. The last step is to document the installed configuration and justify its similarity to the test configuration. The process by which each of these steps .

is accomplished is documented in the EEQ Progrom Manual in  !

Program Instructions 5.2,5.3, and 5.1 respectively. The Test '

Report Assessment (TRA) documents the process of assessing a qualification report. The process includes but is not limited to:

Pnnted 5/2G98 9.05:28 AM Page 1 of 5

1 Northert Utilitie3 ICAVP DR NA DR-MP3-0713 Millstone Unit 3 Discrepancy Report

• Defining the precise cor figuration of the tested items

• Listing all required environmental parameters recorded during the test j

• Identifying and resolving anomalies which could effect qualification

• Evaluating the test methods in accordance with IEEE 323 or DOR Guidelines )

• Specifying the performance characteristics of a component and i determining if they were demonstrated during the test

• Specifying the maintenance, replacement, installation and interfacing requirements identified in the test repcd  !

• Calculating the DBE 500 C Equivalent Life from test profile data j

• Calculating temperatures which correspond to a range of l qualiiied lives including the temperature associated with a 40 year qualified life The TRA, like a vendor supplied test report, is a general document unrelated to a specific plant but which may be used to support the qualification of equipment at Connecticut Yankee and Millstone 1,2 and 3.

The Equipment Qualification Record (EOR) documents the comparison of the plant installed equipment to the tested equipment evaluated in the TRA process or a DOR analysis. As a minimum the EQRs contain:

• Evidence that all pertinent environmental parameters, including the temperature profile, are properly enveloped

• A circuit loop drawing showing the actual installed configuration of the component being qualified and allinterfacing components within a harsh environmental zone

• Similarity analysis, performance analysis, periodic maintenance, equipment installation and equipment interface requirements to maintain qualification

• References of all source documents that provide input to the qualification process

• Procurement information for EQ purchase requisitions

• EQ maintenance requirements For 3QSS*P3A and 3QSS*P3B, EQR 113-0-1, contained in SP-M3-EE-353 (See DCN DM3-00-1833-97), qualifies GE motor model number SK828840C88 for application in a radiation harsh only environment. The EQR also provides justification that supports the qualification of these motors in their specific application to IEEE 323-1974, the intent of NUREG-0588 and NRC 10CFR50.49. The qualification of SQSS*P3A and SQSS*P3B are in full compliance with the FSAR statements in SAR Section 3.118.2.2. When the TRA and EQR are reviewed together with any calculations referenced in the applicable EQR, the entire EEQ evaluation can be seen and the basis for l

qualification conclusions evaluated.

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

2nd NU Response:

Disposition:

Pnnted 5/20/98 9:05:31 AM Page 2 of 5

Northe:st Utilities ICAVP DR NO. DR-MP3-0713 Millstone Unit 3 Discrepancy Report NU has concluded it'at the issue reported in Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition. TRAs (Test Report Assessments) are non-plant specific assessments of Vendor test reports. TRA-113.0 Rev.1 is an assessment of GE Report GEK-42842 dated December 1978.

Although this report was generated to qualify GE motors for Millstone Unit 3, the TRA review / assessment of this report was not prepared with Millstone Unit 3 in mind. This is reflected in the TRA statement on page 3 of 7," Contrary to GE's statement regarding the qualification to IEEE-323-1974 and 344-1974 on I

page iv of Ref. 5.1, engineering analysis based on separate testing and operational experience as presented in this GE Topical Report, satisfies the requiremen's of the DOR Guidelines and does not meet IEEE-323-74 requirements".

It is incumbent upon the specific plant EEQ engineer to accept the assessment, supplement the assessment, or reject the assessment, when preparing the EQR (Equipment Qualification Record) for plant specific qualification documentation. In this particular case, the plant specific EEQ engineer did not accept the TRA supposition that the GE qualification was not to IEEE-323-1974 for the following reasons:

1. It was determined that the preparer of the TRA undertook too strict an interpretation of IEEE-323-74 in that section 5 of IEEE-323-74 states *lt is preferred that the demonstration [of qualification) be done by type tests on actual equipment".

2. IEEE 323-74 also states in section 5.1 "When size or other practical requirements limit or preclude type tests, this part of the demonstration may be completed by methods described in Sections 5.2,5.3, and 5.4". These sections are Operating Experience, Qualification by Analysis, and Combined Qualification respectively. Under section 5.4, Combined Qualification, the following is stated which supports GE's claim to satisfying IEEE-323-74 qualification,

• Partial type tests with '

extrapolation or analysis, operating experience with extrapolation or analysis, and type test supplemented with tests of components and analysis are examples of the use of combined qualification",

in this regard, the EQR determined that these conditions were satisfied.

3. The QSS motors are 500 HP 4 KV motors which means that they are rather large in size and therefore meet the size criteria to preclude sequential type testing. The GE Report addresses radiation-resistance with test results from a typical 460 volt form wound insulated coil and individual material radiation threshold doses. The GE Report addresses thermallife based on AIEE

1. 511 (predecessor to IEEE 275) and AIEE #1F (predecessor to IEEE #101) testing of motorettes. Operating experience (as well  ;

as Weibull Failure Data in Section IV Motor Life Data) is also j presented in the GE Report. These partial type test and analyses in conjunction with operating experience satisfy the IEEE 323-74 criteria for qualification and are addressed as such Pnnted s/20/98 9.05:32 AM Page 3 of s I

Nnrthenct Utiliti2s ICAVP DR No. DR-MP3-0713 Millstone Unit 3 Discrepancy Report in the EQ Summary portion of the EQR and hence the EQR statement "A sufficient test documentation collected in GEK-42842 adequately demonstrates the capability of the subject pump motors to meet their performance specifications under normal and accident environmental conditions, and supports the qualification of these motors in their specific application to IEEE 323-74."

4. The NUREG 0588 position on qualification is stated in sections:

2.1 (1) which states " Qualification methods should conform to the requirements defined in IEEE Std. 323-1974" 2.1 (2) which states "In general, the staff will not accept analysis in lieu of test data unless (a) testing of the component is impractical due to size limitations, and (b) partial type test data is provided to support the analytical assumptions and conclusions reached" and 2.1 (4) which states " actual type testing is preferred....However, analysis or operating history, or any applicable combination thereof, coupled with partial type test data may t;e found acceptable, subject to the applicability and detail of information provided".

Ir, summary, it is EQR 113-0-1 Rev. O that provides the ultimate state of qualification for the Millstone 3 GE QSS pump motors and not TRA 113.0 Rev.1. Based en the above discussion, the GE QSS pump motors are qualified in accordance with IEEE Std. 323-74 and NUREG 0588 guidelines. O Significance level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0713, does not represent a discrepant condition. TRAs (Test Report Assessments) are non-plant specific assessments of Vendor test reports.

The TRA must be reviewed for applicability. In the case of TRA-113.0 Rev.1, the Mir; tone 3 EEQ engineer did not accept the TRA supposition thst the GE qualification was not to IEEE-323-1974 as detailed M the disposition section of this IRF.

It is EQR 113-0-1 Rev. O that provides the ultimate state of qualification for the Millstone 3 GE QSS pump motors and not TRA 113.0 Rev.1. Based on the discussion provided in the

':isposition section of this IRF, the GE QSS pump motors are qualified in accordance with IEEE Std. 323-74 and NUREG 0588 guidelines.

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

Previously identified by NU? O Yes f @ No Non Discrepant Condition? % Yes O No Printed 5/2098 9.o5:33 AM Pag;# 4 of 5

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Norther:t Utilities ICAVP DR N2. DR-MP3-0713 1 Millstone Unit 3 Discrepancy Report Resolution Pending?C Yes (*) No Resolution Unresolved?O Yes (*) No Review e e Date initiator: Yassin, s.  ;

VT Lead: Neri, Anthony A O O mm VT Mgr: schopfer, Don K O Sm 4 1RC Chmn: Singh, Anand K Date: 5/19/98 SL Comments: The Class 1E General Electric (GE) Quench Spray Pump Motors I.D. No. 3OSS*P3A/B and Model No. SK828840C88 are located <

in EQ Zone ES-02 in the ESF Building which is Harsh, Radiation only area. f l

)

in the NU response, M3-IRF-01231, and SP-M3-EE-353, Appendix II, Rev. O it is stated that these GE motors are environmentally qualified to IEEE 323-1974 requirements.

However, the NU document EEQ-TRA-113.0, Rev.1 dated 1/14/1997, Section 1.0 Page 3 of 7 states the following with regard to GE motors 3OSS*P3A/B (Model No. SK828840C88): "

" Contrary to GE's statement regarding the qualification to IEEE 323-1974 and 344-1974 on page iv of Ref. 5.1 ( GEK-42842," Topical Report IEEE 323 Class IE Induction Motors, Horizontal Class B insulated, Model Numbers SK821051C40, SK821054C26, SK828840C88"), the engineering analysis based on separate testing and operating experience, as presented in this j GE Topical Report, satisfies the requirements of the DOR '

Guidelines and does not meet IEEE 323-74 requirements."

On the other hand, the NU EQR 113-0-1, Rev. 0 (page 1 of 5) states that " A sufficient test documentation collected in GEK.

42842 adequately demonstrates the capability of the subject pump motors to meet their performance specifications under normal and accident environmental conditions, and supports the qualification of these motors in their specific application to IEEE 323-1974."

Please explain the difference between NU TRA-113.0, Rev.1 and NU EQR 113-0-1, Rev. O.

SS.L Comments on NU's 2nd Response:

NU's second response is acceptable.

Pnnted s/20/98 9 05.35 AM Page 5 of 5

Northe st Utilities ICAVP DR NO. DR-MP3-0851 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Poter,tial Operability issue Discipline: Mechanical Design Discrepancy Type: Installation imp %mentatior, Ow g

System / Process: SWP ~

NRC Significance level: NA Date faxed to NU:

Date Published: 1/22/98 Discrepancy: PDCR 3-94-090 Implementation and Test Requirement Discrepancies

Description:

PDCR 3-94 090, which involved replacement of several pipe spools, in some cases with spools of the same [CaNi lined]

material and in some cases with different [Monu] material, was reviewed and the following discrepancies noted.

1. The mod package lists two work orders [AWOS] under the

" Implementation and Testing" Section - AWO M3-94-19304 and AWO M3-93-06860. However, AWO M3-94-19304 could not be found in PMMS and therefore could not be verified to have controlled the work tctivities as required by PDCR 3-94-090.

AWO M3-96-06860 mdicated that it controlled portions of the work per ASME Section XI Repair / Replacement, and indicated that it [AWO M3-96-06860] was a " continuation of AWO M3 19304," which coula not be located. NU, in response to a request for this item, indicated that it "could not be found in Nuclear Plant Records and is therefore unavailable." [See IRF M3-IRF-01193.]

2. Under the " Retest Requirements" section of PDCR 3-94-090 Procedure EN 31603 "ASME XI ISI System Pressure Tests" is listed as the procedure to be used to conduct the hydrotest upon completion of the modification. However, work order AWO M3-9604810 [found in PMMS) indicated that it was a " retest of M3-94-19304" (which could not be located - see above] but instead listed Procedure EN 31090 " Elevated Pressure Test" as the goveming procedure. Procedure EN 31603 indicates that it is applicable for testing at " normal operating pressures" while Procedure EN 31090 indicates that it is applicable for " testing components at elevated pressures." The mod package documentation was insufficient to determine which procedure was appropriate.

Review Valid invalid Needed Date initiator: Tenwinke8. J. L. 8 O O 12/19/97 VT Lead: Neri, Anthony A B O O 12/19/97 VT Mgr: Schopfer, Don K B O O 2/23/97 IRC Chmn: Singh, Anand K B O O 1'17/98 Date:

INVALIO:

Daie: 5/19/98 RESOLUTION ist Response:

Disposition:

Printed 5/20/98 9.06:05 AM Page 1 of 3

Northerst Utilities ICAVP DR N2. DR-MP3-0851 f Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report, DR-MP3-0851, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 It has been screened per U3 PI-20 criteria and found to have no operability or deportability concems and meets the Unit 3 deferral criteria. CR M3-98-0655 )

has been written to develop and track resolution of this item per RP-4.

Conclusion:

NU has concluded that Discrepancy Report, DR-MP3-0851, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and.17010 it has been screened per U3 PI-20 criteria and found to have no operability or deportability concerns and meets the Unit 3 deferral criteria. CR M3-98-0655 has been written to develop and track resolution of this item per RP-4.

2nd Response:

Disposition:

NU has concluded that the issues reported in DR-MP3-0851 have identified NON-DISCREPANT conditions. The first issue is that AWO M3-94-19304 could not be found in PMMS and, therefore, was not available for review. AWO M3-94-19304 was located and is attached. The second issue is that the PDCR stated that the spool pieces would be shop hydro-tested per ASME 111 and procedure EN 31063. whereas AWO M3-96-04810 stated the retest was done in accordance with EN 31090. At the time the PDCR was written, procedure EN 31090 dio not exist.

All hydrostatic testing was done 1/a/w EN 31063. The test procedures of EN 31063 were subsequently split into two procedures- EN 31063 and EN 31090. I Section 1.2 of EN 31063 (attached) states procedure EN 31090 is to be used for ASME XI hydrostatic pressure tests. Section ,

1.2 of EN 31090 (attached) states that it should be utilized for l ASME XI Repair / Replacement Hydrostatic Tests and ASME Ill Hydrostatic Tests (and several others); therefore procedure EN l 31090 was appropriate. l l

Conclusion:

NU has concluded that the issues reported in DR-MP3-0851 l have identified NON-DISCREPANT conditions. AWO M3 l 19304 (attached) controlled the work activities for PDCR 3 94 l 0909, and EN 31090 is the correct procedure for ASME Section XI hydrostatic test.

Previously identified by NU? O yes (*) No Non Discrepant Condition? *) Yes O No Resolution Pending?O yes @ No Resoludon Unresolved?O ves @ No Rt 'iew initiator: Tenwinkel, J. L l 5/19/98 Pnnted 5/20/96 9:06-09 AM Page 2 of 3 i

Northert Utilities ICAVP DR ND. DR-MP3-0851  !

Millstone Unit 3 Discrepancy Report l VT Lead: Neri, Anthony A B O O M*

VT Mgr: schopfer, Don K NtC Chmn: singh, Anand K oste: 5/19/98 SL Comments: 1st response:

With regard to the NU Disposition provided in response to the DR, S&L disagrees that this item meets the screening criteria for deferral, because it cannot be currently shown from the documentation provided and reviewed that the replaced piping segments [in the SW retum lines from the "B" Diesel Generator Coolers) were installed and tested to appropriate controlled procedures prior to retuming the system to service. Therefore operability is not assured. NU has agreed in their Disposition that the item requires correction. Please provide details relative to

{

NUs plan to correct this discrepancy. This should be provided prior to startup or justification fumished to support deferral.

[In reviewing this disposition it was also nott.d that there is a typographical error in item 2 of the original DR Description prepared by S&L - the ASME Section XI System Pressure Test procedure referenced as EN 31603 should read EN 31063.]

2nd Response:

Based on the additional information fumished by NU in their 2nd response, S&L concurs with NU that this no longer represents a discrepant condition.

Pnnted 5/2o/98 9:06:10 AM Page 3 of 3

Northe:st Utilitie3 ICAVP DR Nr. DR-MP3-0929 Millstone Unit 3 Discrepancy Report Review Group: Conrguration DR RESOLUTION ACCEPTED Review Element: System Instanaten Discioline: Electrical Design Discrepancy Type: Installation linfL, c,-ston Om g-System / Process: HVX NRC Significance level: 4 Date faxed to NU:

Date Published: 1/18/98 Discrepancy: Tray Supports not in accordance with design documents.

Ducripuon: The following anomalies were identified between the as installed field conditions and the referenced design documents during system reviews and walkdowns.

1. Field condition of support A303-005 (Reference drawing EE - l 34GA - Rev. 4) has a lighting fixture attachment on the bottom tray shelf near the SE vertical leg. No open document reviewed for this drawing discusses this.

2. Field condition of support A308-012 (Reference drawing EE -

34GA - Rev. 4) has an item "W" strut attached to the bottom tray shelf that is used to support lighting fixtures and cable outlets.

No open document reviewed discusses this.

3. Support A310-018 (Reference drawing EE -34GA - Rev. 4) has a tube steel brace attached to the north leg that runs to the ceiling. No open document reviewed discusses this. (The brace l installed is similar to that shown on A311.)  !

4. Support A316-052 (Reference drawing EE -34GB - Rev 3) has an item "W" strut attached to the bottom tray shelf that spans north and south to support lighting fixtures and components. Not discussed in documents.

5. Support A317A-056 (Reference drawing EE -34GB - Rev. 3) has conduit 3CX104PJ (11/2") attached via conduit support MA-884. No open document reviewed discusses this addition.

6. Support A325-035 (Reference drawing EE -34GC - Rev. 4) has item "W" strut attached which is used to support lighting fixture and an emergency light fixture. Also, there are two unused sections of 15/8" x 13/16" strut (B-line type B-52 strut) that are 4" long that attach to the NW vertical leg, one of which has rope tied to it. No open documents reviewed discuss these items.

7. Support A336-016 (Reference drawing EE -34GD - Rev. 4) has a ceiling brace attached to the south leg that is not shown on the support detail drawing. Also, there is an item "W" strut attached to the bottom tray snelf that is used to support lighting fixtures. No open documents reviewed discuss these items.

8. Support A344A-068 (Reference drawing EE -34GE - Rev.1) has an item "W" strut attached to the bottom tray shelf ,

spanning N-S, that is used to support lighting fixtures. Also, a cantilever of 3/4" conduit used to support emergency lights is p , attachedto the bottom-tray-che!f member-No4>peadggr 6

l l

Northert Utilitie3 ICAVP DR N . DR-MP3 0929 Millstone Unit 3 Discrepancy Report reviewed discuss these items.

l 9. The fittings / connections for the intemal diagonal "X" bracing 1 that was removed by F-E-40516 were not removed in the field I (Reference drawing EE -34GE - Rev.1).

10. Support A404-011 (Reference drawing EE -34GF - Rev. 3) has seven horizontal N-S members that span to adjacent supports that are used to route several vertical conduits. Three of these are idenlified as MA-80, MA-81 and MA-82. None of the open documents for this drawing discuss such a major addition and nothing is shown on the drawing.

11. Conduits 3CL925NC and 3CL925ND are attached to the fourth member (from the bottom). No open document discussed this addition to support A404-011 (Reference drawing EE -

34GF - Rev. 3).

12. Support A404-011 (Reference drawing EE -34GF - Rev. 3) has an item "W" strut attached to the bottom tray shelf member that is used to support lighting fixtures. No open document reviewed discusses this.

13. Support A435-046 (Reference drawing EE -34GJ - Rev, 1)has four members attached to outer side of east vertical leg that are supporting vertical conduit runs. No open documents reviewed discuss this.

14. Support A435-046 (Reference drawing EE -34GJ - Rev.1) has two "AV" members attached to the inside of the vertical legs (one on each leg) that span north to A435-045. These members support four 2" conduits that run to panel 3RCS-PNL50 (one ID#

is 3CL170NQ). No open documents reviewed discuss this addition.

15. Support A435-046 (Reference drawing EE -34GJ - Rev.1) has an item "W" strut attached to the bottom tray shelf member that supports lighting fixtures. No open document reviewed discusses this. ,

16. Support A440-056 (Reference drawing EE -34GJ - Rev.1) has a horizontal strut member installed above the brace member I addeci by F-E-35951. This second member supports 2" conduit 3CK146NA. No open document discusses this.

17. Support A440-056 (Reference drawing EE -34GJ - Rev.1) has an item "W" strut attached to the bottom tray shelf member. ,

This is used to support a lighting fixture. No open document j review discusses this. )

18. Support A153C-013 (Reference drawing EE -34GR - Rev. 5) is used to support two 1 1/2" conduits (3CL201PA3 and 3CL201PA4).No open document reviewed discussed the addition of these conduits.

19. Support A164-038 (Reference drawino EE -34GS - Rev. 4)

Printed 5/20/98 9.06:4s AM Page 2 of 6

O Northert Utilitie3 ICAVP DR N2. DR-MP3-0929 Millstone Unit 3 Discrepancy Report has a lighting fixture attached near the N-W leg. No open document reviewed discusses this. Also, a flex hose / tubing run is attached to this support.

20. Support A174A-051 (Reference drawing EE -34G1 - Rev. 6) has item "BQ" strut labeled AB-8376 attached to bottom tray shelf member that is used to support a flex hose / tubing run.

TSO2 lists conduit 3CX931BA (see F-E-33584) as attaching to this conduit support - not correct by field walkdown. Per F-E, conduit should be attached to verticalleg, not added horizontally. No open document reviewed addresses this.

21. F-E-33584 routes conduit 3CC932NH and lists support A174A-051 elevation 34'-6" as an attachment point. Field installation of this conduit is at elevation 35'-10" where A174A does not have any horizontal member. F-E is incorrect. Conduit spans 8'-0" which is acceptable without support at A174A-051 (Reference drawing EE -34GT - Rev. 6).

22. Support A181-061 (Reference drawing EE -34GT - Rev. 6) is used to support conduit 3CX208NY, No open document addresses this.

l

23. The detail drawing for support A198-016 (Reference drawing

]

EE -34GT - Rev. 6) shows a " dummy" member installed at j elevation 39'-6". No member is installed in field. No open document discusses this.

24. Support A205-031 (Reference drawing EE -34GU - Rev. Tj l has three "AV" members attached to the south vertical leg that are used to route eleven conduits (e.g.,4"-3CX227NJ). No open documents reviewed discuss this addition.

25. The horizontal item "W" addressed by F-E-24126 to be added to support A209A-002 (Reference drawing EE -34GU -

Rev. 7) could not be found by the field walkdown. ,

l

26. Support A211-065 (Reference drawing EE GU - Rev. 7) has an attachment for a lighting fixture support on the bottom tray shelf member. No open document reviewed addresses this.

27. Support A216-020 (Reference drawing EE -34GU - Rev. 7) is used to attach a flex hose coaxial cable that exits and re-enters a cable tray. No open document reviewed addresses this attachment. Typical for support A221-014 (Reference drawing EE -34GV - Rev. 6).

l 28. TSO2 lists support A1010-006 as a support for tray 3TC1030. The installed tray is routed horizontally on members l

i associated with sections 5-5,6-6,7-7,8-8 and 42-42 and is a vertical run on members associated with section 9-9. The riser supports are attached to members. The total number of tray attachment points is 11. TSO2 lists nine supports: A55-001, A66-002, A77-003, A88-004, A99-005, A1010-006, A1515-011 and A1616-012 associated with drawing EE-34DS and A11-010 associated with drawina EE-34MJ. A11-010 is not identified on Printed 5/20/96 9:06:45 AM Page 3 of 6

\

Northext Utilitie3 ICAVP DR No. DR-MP3-0929 Millstone Unit 3 Discrepancy Report drawing EE-34MJ, but section 42-42 of DS is shown on MJ.

Sections 15-15 and 16-16 are assumed to be what TSO2 identifies as A1515-011 and A1616-012, yet these sections of EE-34DS and EE-34MK have no role in supporting tray 3TC1030. Support numbers in TSO2 cannot be directly found on referenced drawings - only found by inference. (Reference drawings EE MK - Rev. 3, EE DS - Rev. 4, EE MJ -

Rev. 3)

29. Cable tray 3TC163N does not have any supports listed in TSO2. Field walkdown located tray in position shown on drawing EE -34DS - Rev. 4 (C-5) where a member spans between sections 8-8 and 9-9 at elevation 37'-9" The tray is attached to this member and then routes down and north through a wall penetration. One support should be listed for tray.

30. Cable tray 3TC166N is routed horizontally at elevation 5'-0".

It does not route vertically from this level-tray is then 3TC161N. Five supports for tray STC166N are members at the bottom of section views 5-5,6-6,7-7,8-8 and 9 that are shown on drawing EE-34MK. No part of this route is referred to drawing EE-34MJ, and also, no part of drawing EE-34MJ shows anything identified as A12-028. (Reference drawings EE -34MJ -

Rev. 3. EE -34DS - Rev. 4) l

31. Cable tray 3TX1060 is shown on section 2-2 on drawing EE-34DS and is routed horizontally on horizontal members associated with section views 11-11,12-12,13-13,14-14 and 15-15 which are shown as details on drawing EE-34ML. The tray is also routed vertically on two members shown at elevation 13*-6" and 19"-6" on drawing EE 34DS. These members are detailed in section view 43-43, which is shown on drawing EE-34MJ Rev.

3. No member is identified as A22-024 on any drawing. Tray 3TX1060 is attached at seven points in the field, which matched drawing EE-34DS Rev. 4 information.

32. An addition to cable tray 3TC2070 was made by F-E-22975 in which a horizontal cable tiay was installed and supported by j four new hangers. A250, A254 and A255 types are shown in sketches in the F-E, but no location plan changes were made to l show an individual number for each support. Two type A250's were installed and found by field walkdown, but no determination - of which one is A250-072 - could be made based on the documents available.

33. An addition to cable tray 3TK2080 was made on the 66 elevation but no open document reviewed provided any I documentation for this addition. As such, no support type A252 drawing was found, nor can any support be located with the identification of A252-077 as installed on the tray section. i I

34. TSO2 indicates tray 3TC139P has a support numbered I Support A33-040. No drawing lists a support with A33-040. l

35. A 1/2" conduit is attached to the upper portion of the north vertical lea of support A310-018 (Reference drawina EE -34GA -

Pnnted b"20SS 9 oB 46 AM Page 4 of 6

1 l

l

(

Northe~t Utilitie3 ICAVP DR N3. DR-MP3-0929 l Millstone Unit 3 Discrepancy Report Rev. 4) and also makes an attachment to the steel structure shown in section view 10-10 on EE-34DS Rev. 4 and EE-34MK Rev. 3. The lighting conduit addition is not addressed in any I open document reviewed for these drawings.

Review j Valid invalid Needed Date l Initiator: sarver, T. L O O O 1/2/98 j VT Lead: Neri, Anthony A B D 0 1/5'S8 i VT Mgr: schopfer, Don K B O O ii12/98 BRC Chmn: singh, Anand K O O O sii4/98 Date:

INVALID:

Date: 5/19/98 RESOLUTION: NU has concluded that Discrepancy Report, DR-MP3-0503, has identified a condition not previously discovered by NU which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or deportability ,

concems and meets the Unit 3 deferral criteria. CR M3-98-0513 has been written to develop and track resolution of this item per ]

)

RP-4. j SECOND RESPONSE:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-0929, ha e identified CONFlRMED SIGNIFICANCE LEVEL 4 conditions which require correction.

However, the following specific item requested in the S&L Follow-up to DR 929 are non-discrepant. Item 5 Conduit support MA-884 was approved by E & DCR no. F-E-28594 and the support was approved by comparison to Calc. no.12179-SEO-BE-52.1296.

Item 10,11,13,14, and 16 Conduit supports for the MCC and Rod Control Rooms at elevation 45'-6" of the Auxiliary Building were addressed in E & DCR no. F-E-19618. This E & DCR addresses Non-Safety Related conduits installed over Non-Safety Related equipment and installed without conduit support log drawings. These installations are acceptable as is. Item 18 Conduit 3CL201PA3 is supported by suppport no. AB-8717 and is justified by a Conduit Support Log drawing no. 25212-34011 sh. AB8717, and the Cable Raceway Program for cable tray support no. DY-A153C-013. Conduit 3CL201PA4 is support no. AB-8726 and is justified by a Conduit Support Log drawing no. 25212-34011 sh. AB8726, and the Cable Raceway Program for cable tray support no. DY-A153C-013. Item 22 Conduit 3CX208NY is supported by support no. AB-1860 and is justified by a Conduit Support Log drawing no. 25212-34011 sh. AB1860, and Calc. no.12179-SEO-BE-52.143. Item 24 Conduit supports for elevation 43'-6* of the Auxiliary Building were addressed inE

& DCR no. F-E-6286. This E & DCR addresses conduit supports in Non-Category 1 areas / rooms within Catergory 1 buildings being exempt from the requirements of seismic supports, and r installed without conduit support log drawings. These installations are acceptable as is. item 25 Horizontal item "W" is Printed 570/96 9 06:48 AM Page 5 of 6

Northext Utilities ICAVP DR No. DR-MP3-0929 Millstone Unit 3 Discrepancy Report conduit support no. AB-3445 and is justified by a Conduit Support Log drawing no. 25212-34011 sh. AB3445, for 3' diameter conduit no. 3CC202PW.Per field walkdown on 5-6-98 the Horizontal item "W" is properly installed for support no. AB-3445. Item 33 Cable tray is properly installed and properly supported per E & DCR no. F-E-36210. There are no additions to the cable tray. Cable tray supports are shown in E & DCR no.

F-E36210.The remaining issues associated with DR 929 have been approved for binning in accordance with the responses provided in M3-IRF 1864.

- Previously identified by NU? O Yes is) No Non Discrepent Condition?O Yes (p) No Resolution Pending?O Yes @ No Resolution Unresolved?O Yes (#1 No Review Acceptable Not Acceptable Needed Date M N VT Lead: Neri. Anthony A VT Mgr: schopfer, Dor' K IRC Chmn: singh, Anand K Date: 5/19/98 SL Comments: Adequacy of the supports for the revised configurations and/or additional loads needs to be verified prior to start-up for the DR items numbered 5,10,11,13,14,16,18,22.24,25 and 33.

SECOND RESPONSE:

S & L concurs with NU's disposition based on the review of the reference documentation including E & DCR no. F-E-28594.

I l

Printed 5/20/98 9:06:50 AM Page 6 of 6 l

!- Northert Utilities ICAVP DR N2. DR-MP3-0996 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: Calculation System / Process: NEW NRC Significance level: 4 Date faxed to NU:

Date Published: 2/7/90 Discrepancy: Revision of Calculation US(B)-1187 for DCRs M3-97042 and 97045

Description:

The purpose of Calculation US(B)-1187, Rev. 2 is te determine operating RSS pressure and temperatures for input into the stress data package, SDP-RSS-01361M3, Rev. 5.

The Stress Data Package Plant Conditions Checklist, pp.13-19 of US(B)-1187, contains incorrect and outdated information. l These are editorial errors which could cause confusion over which system design information is correct:

1. Calculation P(R)-883 is referenced in several places for maximum RSS pressure, but this calculation was statused superseded on 7 30-97. The correct reference is P(R)-1186, Rev. 2. P(R)-1186 identifies to maximum RSS pump discharge pressure as 300.1 psig, not 304.3 psia (289.6 psig).

1

2. RSS Pump start time delays are identified as 290 and 300 seconds, but, according to LSK-24-9.4A, Rev. 9, the time

[ delays are 650 and 660 seconds.

3. The procedure for manually operating RSS for the ECCS recirculation after a postulated small break LOCA without a CDA should not require MOV20A/B be closed before RSS pump start because this would air-bind the ECCS pumps

- as discussed in DR-MP3-989.

Review Valid invalid Needed Date initiator: Wakeland. J. F. B 0 0 1/31/98 VT Lead: Neri, Anthony A O O O 2/2/98 VT Mgt: Schopfer, Don K Q O O 2/2/98 IRC Chmn: singh, Anand K B O O 2/3/98 Date:

INVALID:

Date: 5/19/98 RESOLUTION: DISPOSITION:

! NU has concluded that DR-MP3-0996 has identified a confirmed significance level 4 condition which requires correction. This discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems and meets the deferal criteria of section 1.3.2.e of U3 PI-20.

Printed 5/20/98 9:07:22 AM Page 1 of 4

Northe:st Utilities ICAVP DR N3. DR-MP3-0996 Millstone Unit 3 Discrepancy Report CR M3-98-2287 was closed to Bin CR M3-98-0138. The corrective action plan for Bin CR M3-98-0138 will correct the following items post startup:

ITEM 1: This is a valid discrepancy. The RSS System Design Condition (SDP-RSS-01361M3, Rev. 5, dated 10-15-97; see pertinent pages 1 & 18 attached) presently specifies a design pressure of 275 psig for RSS pump discharge.

Calculation P(R)-1186, Rev. 2 (see pages 1 & 8 attached),

specifies a system operating pressure (not system design pressure) for the RSS pump discharge of 300.1 psig. Calculation P(R)-1187, Rev. 2 (see pages 1 & 15 attached) specifies a value of 289.6 psig (ref. calc. P(R)-883).

In accordance with Supplement 4 of NUREG 1031 and ASME Section ill, Subsection NC-3612.3,1971 Edition, up to and including Summer 1973 addendum, the design pressure of 275 psig for the RSS pump discharge as presently shown in the Stress Data Package (SDP) can be exceeded for a short period.

The operating pressure for this short period is 300.1 psig. The pressure term does not have a large magnitude when compared to the allowable for Equation 8. An operating pressure of 300.1 psig is acceptable since the maximum stress for the design pressure of 275 psig is 3458 psi (i.e., calculated by ASME Ill Equation 8) and is well below the S-value Allowable which is 17,080 psi as demonstrated in SWEC calculation 12179-NP(F)-

X7923, Rev. 2, page 108 (attached) for discharge piping form 3RSS*P1 A. Stress analysis of the other lines results in similar margins relative to ASME Code allowables. The slight increase in pressure from 275 psig to 300.1 psig does not result in exceeding the S-value allowable.

A CCN to calc. P(R)-1186 shall be performed to state the design pressure is 275 psig and change the present wording from

" system design pressure" to " system operating pressure" (see l page 8 attached). l I

Calculation P(R)-1187 and SDP-RSS-01361M3 will be reviewed and updated as required to incorporate the peak pressure case from calculation P(R)-1186.

ITEM 2: This is a valid discrepancy. The RSS pump delay time of 650 seconds for 3RSS*P1A & 1B and 660 seconds for 3RSS*P1C

• 1D delay time are the correct values to use in calc.

P(R)-1187. A CCN to calculation P(R)-1187 will change the present values of 290 and 300 seconds for RSS pump delay times to 650 and 660 seconds, respectively.

ITEM 3: This is a valid discrepancy. The Stress Data Package Plant Conditions Checklist (see P(R)-1187, page 17 attached),

Plant Condition, Emergency Condition 1, shall be changed to indicate that 3RSS*MOV20A & B are open. The position of these valves is addressed in the response to DR-MP3-0989, IRF M3-IRF01815.

I Printed 5/20f96 9.o7:25 AM Page 2 of 4

I Northert Utilities ICAVP DR N;. DR-MP3-0996 Millstone Unit 3 Discrepancy Report CONCLUSION:

NU has concluded that DR-MP3-0996 has identified a confirmed significance level 4 condition which requires correction. This j discrepancy meets the criteria specified in NRC letter B16901 and 17010. It has been screened per attachment 11 of U3 PI-20 criteria and found to have no operability or deportability concems l and meets the deferal criteria of section 1.3.2.e of U3 PI-20. CR M3-98-2287 was closed to Bin CR M3-98-0138 which will correct items 1,2 and 3 post startup. There is no effect on the License or Design Basis.

Previously identified by NU7 O Yes @ No Non Discrepant Condition?Q Yes (#) No Resolution Pendmg?O Yes @ No Re.oiution unre.oived70 ve. @ No Review initiator: Wakeland, J. F.

VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: singh, Anand K Dete: 5/19/98 sL comments: Sargent & Lundy concludes that CR M3-98-2287 and CR M3 l 0588 (with the CR change to CR M3-98-0588) will correct the I discrepancies identified in DR-MP3-0996.

Significance Level 4 Items # 2 and #3 are minor documentation errors that do not affect the RSS system design basis (and will be corrected by CR M3-98-2287).

Item #1 is a mis-statement in the Stress Data Package Plant Conditions Checklist of the maximum operating pressure. This error occured because one possible operating mode was not considered. This new operating mode, RSS pump operating at shutoff head, may occur during 4.0.5P testing or during a postulated accident only if a valve malfunctions or is mispositioned. This valve malfunction or mispositioning event would produce an RSS pump discharge pressure of approximately 300 psig, y hich is only about 9% greater than the 275 psig RSS piping design pressure (from the line list). Sargent

& Lundy concurs that such a valve mispositioning event would be of the short duration forwhic% the ASME Code permits the stress allowables to be exceeded. Because these stress levels are allowed, piping stress analyses, which use 275 psig as the maximum RSS pump discharge pressure, do not need to be re-evaluated. Even if stress allowables were exceeded for increased pressures of this new operating mode, the RSS system would still be within its licensing and design basis. Therefore item

1. 1 is a level 4 discrepancy.

The statement on maximum RSS pressure in the Stress Data Package Plant Conditions needs to be corrected (and will be by CR M3-98-2287), but it is not used as input to the stress analysis.

Other statements on the maximum RSS operating pressure made in Calculations P(R)-1186, P(R)-1187 and SDP-RSS-01361M3 Printed S/20/98 9 07:27 AM Page 3 of 4

North 2a::t Utilitias ICAVP DR No. DR-MP3-0996 Millstone Unit 3 Discrepancy Report need to be revised (and will be corrected by CR M3-98-0588, with the CR change to CR M3-98-0588).

Item #1 of DR-MP3-0999, written against SDP-RSS-01361M3, Rev. 5, and item #3 of DR-MP3-0454, written against P(R) 1186, Rev.1/CCN 2 address the issue of RSS pump shutoff head identified in item #1 of DR-MP3-0996. The pump shutoff head issue should not have had redundant coverage among the discrepancy reports. To resole this radundancy, item #3 of DR-MP3-0454 was closed to item #1 of DR-MP3-999 and Item #1 of DR-MP3-0999 was closed to item #1 DR-MP3-0996. Thus the issue of RSS pump shutoff head operation in Calculations P(R)-

1186, P(R)-1187, and SDP-RSS-01361M3 are all addressed by item #1 of DR-MP3-0996. CR M3-98-2287,intiated 2-4-98, and the CR Change against CR M3-98-0588, initiated 5-14-98 address the revisions which are required of Calculations P(R)-1186, P(R)-

1187, and SDP-RSS-01361M3.

Sargent & Lundy concludes corrective actions to resolve the discrepancies identified in DR-MP3-0996 are in place, the discrepancies are significance Level 4 issues, and their resolution may be deferred until after Unit 3 restart.

Printed 5/20/98 9:07:28 AM Page 4 of 4

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l N:rthea:t Utilities ICAVP DR Nr. DR-MP3-0999 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Diu:repancy Type: Calculation Om System / Process: NEW g

NRC Significance level: NA Date faxed to NU:

Date Published: 2/5/98 Discrepancy: Revision of Calculation SDP-RSS-01361M3 for DCRs M3-97042 and 97045

Description:

The purpose of Calculation SDP-RSS-01381M3, Rev. 5 is to provide a line-by-line listing of RSS operating pressures and temperatures for each mode of system operation in a foimat which can be used as input to the piping stress ana'ysis. The operating pressures and temperatures are determ'ned in Calculation P(R)-1187, Rev. 2.

Four discrepancies were identified in Calculation SDP-RSS-1361M3, Rev. 5:

1. (p.18) The design pressures and temperatures do not reflect those computed in P(R)-1186, Rev. 2. Design pressure at pump suction should be 49 psig, design pressure at pump discharge should be 300 psig, design pressure at containment isolation valves MOV*20A/B/C/D should be 283 psig, design pressure at Si crosstie valves MOV*8837NB & 8838NB should be 285 psig, and design temperature should be 260F throughout the entire spray circuit.

l

2. (pp.19-21) There is no source for the 39 psig operating pressure for suction piping in Operating Condition 1. This parameter is not computed in P(R)-1187, Rev. 2.

3. (pp. 20-21) The operating pressures in pump suction piping for the Operating Condition 3,3RSS*P1 A test mode, agree with values computed in P(R)-1187, Rev. 2, but contradict the 50 psig value computed in US(B)-1186, Rev. 2.

4. (pp. 20,21,25, and 26) The operating pressures in pump dewatering lines 3-RSS-150-43,51,84, and 87 are identified as equal to those for the pump suction piping even though these lines are located nearly 17*-2" below the suction piping (an ,

elevation difference which corresponds to as much as 7.4 psid). I Review Valid Invalid Needed Date initiator: Wakeland, J. F.

O O O s/24/98 VT Lead: Neri, Anthony A B O O s/29/98 VT Mgr: schopfer, Don K O O O s/29/98 IRC Chmn: singn, Anand K O O O 2/2/98 Date:

INVALID:

Date: 5/19/98 RESOLUTION:

Pnnted 5/20/98 9:08:27 AM Page 1 of 6

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(- Northezt Utilities Millstone Unit 3 ICAVP DR N . DR-MP3-0999 Discrepancy Report FIRST RESPONSE:

DISPOSITION:

NU has concluded that DR-MP3-0999 does not represent a discrepant condition. The disposition to each issue raised in DR-MP3-099 is addressed individually as follows:

Issue 1: The design pressures and temperatures in the SDP are a summary provided for information only. The design basis location of design pressure and temperature conditions for the system are contained in the line designation table. P(R)-1186 calculated maximum operating conditions. As the existing suction design pressure is 60 psig no change is required.

j Discharge design pressure is 275 psig to the 3RSS*MOV20s and i 225 psig beyond the 20 series valves. The reference to 300 psia j for Case 1 in calculation P(R)-1186 is relevent only for upset conditions and is not a normal operating design parameter. The design temperature for all the lines above is being increased to j 260F in DCR M3-96-054. Therefore, this is not a discrepant  !

condition. I Issue 2: The Condition 1 Operating Pressure for the suction piping is computed on Page 9 of P(R)-1187. Therefore, this is ]

t not a discrepant condition.

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Issue 3: It is the purpose of the SDP to determine the bounding i conditions for stress analysis. The difference between the value l for the RSS pump Operating Condition 3 pump suction pressure reported in SDP-RSS-01361M3 and P(R)-1186 is the difference between bounding conditions and normal operating conditions.

l As the values used in SDP RSS-01361M3 exceed those considered in P(R)-1186, this is not a discrepant condition.

issue 4: The justification for the operating pressures in pump dewatering lines 3-RSS-150-43,51,84 and 87 being equal to those for the pump suction piping can be found in the General Note on page 16 of calculation SDP-RSS-01361M3 which states:

"All 2 inch and smaller ASME Class 2 and 3 ANSI B31.1 and all 1 inch and smaller ASME Code Class 1 piping shall normally be l analyzed using design conditions as provided in the SDP -

System Design Conditions Table. The lines shall be designed using the provisions of Project Procedure NETM-24 and NEAM-110." Employing this practice ensures that all lines can meet the bounding pressure. Threrefore this is not a discrepant condition.

CONCLUSION:

NU has concluded that DR-MP3-0999 does not represent a discrepant condition. As detailed in the disposition, each of the four questions is bounded by the values in the Stress Data Package for the system which inherently incorporates margin from the operating conditions.

Pnnted S'20/98 9 o8:30 AM Page 2 of 6

Northert Utilities ICAVP DR NO. DR-MP3-0999 Millstone Unit 3 Discrepancy Report Significance level criteria do not apply as this is not a discrepant condition.

SECOND RESPONSE:

DISPOSITION:

NU has concluded that the issues reported in DR-MP3-0999 have identified NON-DISCREPANT conditions. Item 1: The ASME 111 Code requires the design pressure of a system to equal or exceed the worst case normal plant operating condition for the system. When preparing the initial design calculation of a system, design pressure is often based on a conservative condition of a system;i.e. operating at pump shutoff head.

A system will only operate at pump shutoff conditions due to equipment failure or inadvertent valve positioning. Calculation P(R)-1187," Documentation of Operating Temperatures and Pressures Used as input to SDP-RSS," properly identifies pump shutoff head as an upset condition in Operating Condition 3.

The upset condition is also discussed in the original Licensing basis of Millstone 3 (Supplement 4 of the SER, Page 17-5).

Calculation P(R)-1187 does not identify any normal operating conditions which exceed the present design conditions, therefore, no revision to the design pressures is required. I Calculation P(R)-1186," Containment Recirculation System )

Design Pressuresfremperatures," has been identified by S&L as 1 discrepant in a number of DRs. CR M3-98-0588 has been initiated to identify and track the discrepant activities. As the discrepant condition exists in calculation P(R)-1186, which was identified elsewhere rather than in SDP-RSS-01361M3, we do not consider this calculation to be discrepant per this DR.

Item 4: Due to it's small size, the piping for these lines was analyzed to the design conditions of the suction piping.The calculated maximum suction piping pressure is 49 psig [ P(R)-

1186]. If you allow for the elevation pressure differential of 7.4 l

psi, the calculated maximum pressure of the dewatering lines (49 psig + 7.4 psi = 56.4 psig )is less than the design pressure of the suction piping (60 psig). The design pressure remains at 60 psig and the analysis of these lines has not changed. As such, NU does not believe this item is discrepant.

1 CONCLUSION:

NU has concluded that the issues reported in DR-MP3-0999 have identified NON-DISCREPANT conditions. Item 1: The ASME Ill Code requires the design pressure of a system to equal or exceed the worst case normal plant operating condition for the system. When preparing the initial design calculation of a system, design pressure is often based on a conservative j condition of a system: 1.e. operatino at pump shutoff head.

Printed S/20/96 9 08:31 AM Page 3 of 6 L__________________________

Wst Utilitie3 ICAVP DR No. DR-MP3-0999 Millstone Unit 3 Discrepancy Report A system wid only operate at pump shutoff conditions due to equipment failure or inadvertent valve positioning. Calculation P(R) 1187," Documentation of Operating Temperatures and Pressures Used as input to SDP-RSS," properly identifies pump shutoff head as an upset condition in Operating Condition 3.

The upset condition is also discussed in the original Licensing basis of Millstone 3 (Supplement 4 of the SER, Page 17 5).

Calculation P(R)-1187 does not identify any normal operating conditions which exceed the present design conditions, therefore, no revision to the design pressures is required.

Calculation P(R)-1186," Containment Recirculation System Design Pressures / Temperatures," has Deen identified by S&L as discrepant in a number of DRs. CR M3-98-0588 has been initiated to identify and track the discrepant activities. As the discrepant condition exists in calculation P(R)-1186, which was identified elsewhere rather than in SDP-RSS-01361M3, we do not consider this calculation to be discrepant per this DR.

Item 4: Due to it's small size, the piping for these lines was analyzed to the design conditions of the suction piping.The calculated maximum suction piping pressure is 49 psig [ P(R)-

1186]. If you allow for the elevation pressure differential of 7.4 psi, the calculated maximum pressure of the dewatering lines (49 psig + 7.4 psi = 56.4 psig )is less than the design pressure of the suction piping (60 psig). The design pressure remains at 60 psig ano the analysis of these lines has not changed. As such, NU does not believe this item is discrepant.

Previously identified by NU? O ves (#) No Non Discrepant Condition?(9) Yes Q No Resolution Pending?O ves @ No Resolution Unresolved?O ves @ no 5

Review Acceptable Not Acceptable Needed Date initiator: Wakeland, J. F.

VT Lead: Neri, Anthony A O SIS'98 VT Mgr: schopfer, Don K O S1S'S8 IRC Chmn: singh. Anand K O O O st1S/S8 O O O Date: 5/19/98 sL Comments:

FIRST RESPONSE:

Item 1: Sargent & Lundy concludes that this is a discrepant condition. The ASME code requires that nuclear class 2 piping stresses be analyzed for the greater of maximum operating pressure or design pressure. A change in design pressure to account for the possibilty of RSS pump shutoff head, introduces a 25 psi increase in design pressure. This corresponds to a 0.3 ksi increase in the stress in the RSS discharge line (up to the MOV 20 valves): 0.3 ksi = (25 psi /1000 ksi/ psi)(10.02 in) / [2 (0.365 in)). Pressure stresses are used for the sustained load, and the occaisional and emergency load cases. For these cases, the ASME code does not include temperature stresses. Therefore, it is the engineering judgement of the ICVAP reviewer that correcting the RSS design pressure in the stress data package Pnnted 5/20/98 9.08:33 AM Page 4 of 6

Northe st Utilitie3 ICAVP DR N:. DR-MP3-0999 Millstone Unit 3 Discrepancy Report would not significantly reduce the margin in piping stress.

Sargent & Lundy consideres this to be a level 4 discrepancy which may be corrected after Unit 3 restart.

Item 2: Sargent & Lundy agrees that this is not a discrepant condition. The basis for using 39 psig for the operating RSS suction pressure is provided on p. 9 of US(B)-1187, Rev. 2.

Item 3: Sargent & Lundy agrees that this is not a discrepant condition. The pressure identified in P(R)-1187, Rev. 2 and in SDP-RSS-01361M3, Rev. 5 bound the value used identified in P(R)-1186.

Item 4: Sargent & Lcndy concludes that this is a discrepant condition. However, the 7.4 psi error in estimating the pressure in RSS pump dewatering lines 3-RSS-150-43, 51,84 and 87 is not a significant contributor to stress levels in these lines. Therefore Sargent & Lundy consideres this to be a level 4 discrepancy which may corrected after Unit 3 restart.

SECOND RESPONSE:

Sargent & Lundy agrees that item #4 of DR-MP3-0999 is not a discreper ? condition because the design pressure of 60 psig, which '.n. sed as the basis for hydrotesting and for the limiting stress analysis, envelopes the drain line pressure that was identified.

Since is was already agreed that items #2 and #3 are non discrepant conditions, all of the issues raised in DR-MP3-0999 are non discrepant conditions.

Item #1 of DR-MP3-0999, written against SDP-RSS-01361M3, Rev. 5, addresses the same issue that has already been addressed in item #3 of DR-MP3-0454, written against P(R)-

1186, Rev.1/CCN 2 and item #1 of DR-MP3-0996, written against P(R)-1187, Rev. 2. The issue is that the operating pressures generated by RSS pump shutoff head are not indentified in the design basis mechanical calculations. CR M3-98-2287, intiated 2-4-98, and the CR Change against CR M3 0588, initiated 5-14-98 address the revisions which are required  ;

of Calculations P(R)-1186, P(R)-1187, and SDP-RSS-01361M3.  !

i The pump shutoff head issue should not have had redundant coverage among the discrepancy reports. This discrepancy will l be covered only by item #1 of DR-MP3-0996. Item #1 of DR-l MP3-0999 is considered to be closed to item #1 DR-MP3-0996.

(it should be noted that item #3 of DR MP3-0454 was considered to be clused to item #1 of DR-MP3-999. Now it should be considered to be closed to item #1 of DR-MP3-996).

Based on this consolidation, Sargent & Lundy does not consider i DR-MP3-0999 to be a discrepancy. '

Printed 5/20/96 9:08.34 AM Page 5 of 6

Nsrther;t Utilities ICAVP DR No. DR-MP3-0999 Millstone Unit 3 Discrepancy Report l

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Prtnted 5/20/98 9:08:35 AM Page 6 o' 6 l

. NortheIt Utilities ICAVP DR N . DR-MP3-1088 Millstone Unit 3 Discrepancy Report Review Group: Programmetc DR RESOLUTION ACCEPTED Reh Eht Cmm W Pm Potential Operabliity lasue Discipline: I & C Design Ow Discrepancy Type: Corrective Action imp 6ementation System / Process: DGX gg NRC Significance level: NA Date faxed to NU:

Date Published: 3/30/98 D6screpancy: Insufficient documentation for post startup closure of instrument qualification issue.

Description:

CR M3-97-1444 addresses the operating temperature range of the Emergency Generator Load Sequencer (EGLS). IEEE 279 requires conditions which render the EGLS inoperable be statused in the Control Room. The vendor's O&M manual documents the equipment's operating temperature range as 75

+/- 5 deg. F. The instrument rack room's normal temperature is documented in the purchase specification as 75 +/- 5 deg F.

Setpoint Calculation SP-3HVC-8 documents the rack room's temperature setpoint as 75 deg. F; however, actual rack room temperature measurements vary around 68.7 deg. F. Without an approved design change, the HVAC's temperature controller setpoint was change to 65 deg. F by operation's initiated EWR#

3-94-00128 that was approved but not released. The UFSAR documents the rack room's temperature range as 70 deg. F to 80 deg. F; however, Calculation No. P(B)-0954, titled " Temperature rise in the Control Building during temporary loss of air conditioning" and Calculation No. 88-032-090GF, titled " Station Blackout Transient Room Temperature Analysis for the Instrument Rack Room at MP3' documents that room temperature can be higher than 80 deg. F. The Tech. Spec.

documents that rack room's equipment can be declared operable as long as the rack room temperature is below 95 deg. F. The EGLS Qualification Test Report No. 2404.01 documents the equipment's minimum / maximum test teniperatures as 70 deg. F and 95 deg. F. however, if the Tech. Spec.'s rack room temperature limit of 95 deg. F is exceeded, the required action is to record the temperature and duration for EQ purposes. No minimum temperature alarm or required action is provided for the instrument rack room.

Corrective action requests ARs 97011511-01,02, & 03 and 97011973-01 are scheduled for completion after start-up.

Justification for scheduling the completion and closure of these action requests, associated with CR M3-97-1444, is based on a EGLS critical subcomponent operating temperature range analysis and critical subcomponent comparison, between the EGLS and similar equipment supplied by Westinghouse. The critical subcomponent operating temperature range analysis is based on the specified operating temperature range for each manufacturer's subcomponent inside the EGLS. The comparasion is based on similarity of critical subcomponents in a piece of equipment supplied by Westinghouse that was qualified with a greater minimum / maximum testing temperature range, as documented in test report WCAP-8687. None of this data was submitted with the review package. The following infom1ation is nopded in r'nnfirm nnernhilifv nf the Ff"l1 A-Printed 5/20/98 9.09.05 AM Page 1 of 6

Northsatt Utilitiss ICAVP DR No. DR-MP3-1088 Millstone Unit 3 Discrepancy Report

-EGLS critical subcomponent list and associated operating temperature range data,

-critical subcomponent list for the Westinghouse supplied equipment used in the EGLS comparison and qualification report WACP-8687.

Review Valid invalid Needed Date initiator: Dombrowski, Jim B O O 3/25/98 VT Lead: Rycn, Thomas J B O O 3/25/98 VT Mgr: Schopfer, Don K O O O 3/25/98 IRC Chmn: singh, Anand K O O O 3/27/98 Date:

INVALID:

Date: 5/19/98 RESOLUTION:

NU's First Response Disposition:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1088, does not represent a discrepant condition. The following information is being provided as requested to confirm operability of the EGLS:

The following information is provided as requested per the DR.

1. EGLS critical subcomponent list and associated operating temperature range data:

OSubcomponento 00perating Temp. OReference0 Range 0 Lambda power 0-10 'C to 71 *C OVendor Manual supply LRS-54 OIM-427 Lambda power 0-10 *C to 71 'C OVendor Manual supply LRS-56 OIM-427 Agastat control 00 *C to 60 'C OVendor Manual relays GP series OlM-427 Motorola MHTL 0-30 'C to 75 *C OVendor Manual Integrated Circuits OIM-427 MC660 Series Sprague integrated 00 'C to 70 *C OVendor Circuits series OlM-427 ULN-2000A Motorola MDTL 00 *C to 75 *C OVendor Manual Integrated Circuits OlM-427 Pnnted 5/2G98 9:09 09 AM Page 2 of 6

Northe:st Utilities ICAVP DR Nc. DR-MP3-1068 Millstone Unit a Discrepancy Report

2. Critical subcomponent list for the Westinghouse supplied equipment used in the EGLS comparison and quclaication report WCAP-8687:

Westinghouse SSFS (Solid State Protection System) equipment was used as a similar equipment to EGLS. The critical subcomponent list is provided below;

a. Motorola MHTL Integrated Circuits MC660 Series

b. Basler Electric Co. Power supply, part Nos. 90 73700-101, 90 735300-101, 90 73900-101, 90 74000-101

c. Relays, Midtext Inc. part Nos.156-14T300 (120vac),156-14C300 (24vdc),156-14D200 (48vdc) d. Relays, Potter &

Brumfield rotary type MDR Series Significar.ce Level criteria do not apply here as this is not a discrepant condition.

Conclusion:

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1088, does not represent a discrepant condition. The requested information is beir.g provided within the disposition. Significance Level criteria do not apply here as this is not a discrepant condition.

Attachment:

None NU's Second Response

Background:

l S&L considers the NU response stated in M3-IRF-02216 to l Discrepancy Report DR-MP3-1088, unacceptable. S&L restates the discrepancy in DR-MP3-1088 as follows:

With the exception of the Motorola MHTL Intergrated Circuit ,

Series MC600 Series component, the critical subcomponen'- M l the EGLS equipment and the Westinghouse SSPS ea%> ment are not identical; consequently, the asssessment that the minimum / maximum temperatures for the Westinghouse SSPS i equipment as documented in the test report WCAP-8687 is applicable to the EGLS equipment is not valid. (Note: The WCAP-8687 test report was not provided as an attachment to the DR.)

Disposition:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1088 has identified a NON-DISCREPANT condition. The following information is being pravided to confirm the operability of the EGLS in the Instrument Rack Room.

NU provided the reqpested Emergency Generator Load Sequencer (EGLS) critical subcomponents equipment list and their Vendor Manual (OIM-427) specified operating temperature ranaes in the oriainal MS-DRT -01088(NUL M3-IRF-02216 Printed 5/2o/98 9:09:10 AM Page 3 of 6 i

i Northent Utilitie3 ICAVP DR N). DR-MP3-1088 Millstone Unit 3 Discrepancy Report response. The EGLS uses similar type critical subcomponents compared to the Westinghouse Sohd State Protection System -

(SSPS) equipment with the except> ,

• Te Motorola MHTL Integrated Circuits where both use the MC600 series. Both systems are located in cabinets in the instrument Rack Room, a designated mild environment. NU has concluded that a j technical assessment of the EGLS critical subcomponents has confirmed operability of the EGLS at 68 *F by reviewing the Vitro Laboratories, EGLS Qualification Report No. 2404.01 (attached),

Vendor Manual OIM-427 components minimum / maximum temperature ranges (previously provided), component type, and a comparison of similar type components / conditions used in the SSPS. The Instrument Rack Room temperature setpoint was lowered to 68 'F by Operations to minimize cycling the Instrument Rack Room HVAC System. NU considers the Instrument Rack Room temperature of two degrees below the mininum 70 *F test value stated in the EGLS Qualification Report No. 2404.01 to be inconsequential to EGLS operation thus justifying corrective action scheduling for CR M3-97-1444 until after start-up.

The critical subcomponents installed in the EGLS equipment are a similar type of industrial grade components and their operating temperature ranges are also similar to the Westinghouse SSPS components even though they are not identical components. For example, the relays used in EGLS equipment are not. identical to the relays used in the SSPS equipment, however they are similar type of relays (electro-mechanical type, general purpose industrial grade). Same is true for the power supply units. Both pieces of equipment use the same type of Motorola MH1L Integrated Circuits which is the essential part of the equipment.

Therefore, the comparison is considered reasonable and valid to i l

support the equipment operating temperature range conditions for similar component types within the SSPS equipment in addition to the operating temperature range data of the critical subcomponents in the EGLS equipment itself.

As previously reported, the normal / abnormal Instrument Rack Room nominal temperature of 70 'F to 80 'F and the Technical Specification maximum temperature limit of 95 'F are within the specified operating temperature ranges [0

• C to 60 *C (32 'F to 140 'F)] of the critical subcomponents in the EGLS.

The EGLS Qualification Report No. 2401.01, Dated 12/2/83, demonstrated EGLS operability from 70*F to 95'F. However, the individual specified critical subcomponent operating temperature ranges exceed the QuaEfication Report test limits.

The SSPS EQ Test Report, WCAP 8687, Normal and Abnormal Temperature And Humidity Testing Report (attached) performed testing from 40*F to 124'F. These temperature limits are within the specified EGLS critical subcomponent operating temperature range of 32 'F to 140 'F.

The EGLS has a design feature to automatically self test the circuitry during normal operation. Any failure detected by this testing would be alarmed in the control room. The EGLS System operability is therefore continuously monitored by the Printed 5/20/98 9 09:11 AM Page 4 cJ 6 l

N:rthert LMilitie3 ICAVP DR N3. DR-MP3-1088 Millstone Unit 3 Discrepancy Report auto test feature and alarmed in the control room in compliance with IEEE 279 requirement.

In regards to the updating / justifying the EGLS EQ documentation, there are no further EQ component requirements for EGLS sine,e the equipment is located in a mild environment.

The vendor of EGLS equipment no longer provides services for the EGLS equipment.

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

Conclusion:

NU has concluded that the issues reported in Discrepancy Report, DR-MP3-1088 has identified a NON-DlSCREPANT condition. NU has concluded that a technical assessment of the EGLS critical subcomponents has confirmed operability of the EGLS by reviewing the Vitro Laboratories, EGLS Qualification Report No. 2404.01 (attached), Vendor Manual OIM-427 components minimum / maximum temperature ranges (previously provided), component type, and a comparison of similar type components / conditions used in the SSPS.

The requested Westinghouse Equipment Qualification Test Report, Two Train Solid State Protection System, (Normal and Abnormal Temperature and Humidity Testing), WCAP-8687, Rev. 2 is attached. NU emphasizes that the attached WCAP-8687 is considered Westinghouse proprietary and should be handled as agreed to under the NU / S&L ICAVP proprietary agreement.

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

Attachments:

WCAP-8687, Supp. 2-E16A, Westinghouse Equipment Qualification Test Report, Two Train 000 Solid State Protection System (normal and abnormal temperature and humidity testing), Rev.2 OOVitro Laboratories, Qualification Report No. 2404.01, Emergency Generator Loading Sequencer, ODMillstone Nuclear Power Station, Unit 3, Dated: December 2,1983 Note: The requested Westinghouse Equipment Qualification Test Report, Two Train Solid State Protection System, (Normal and Abnormal Temperature and Humidity Te: sting), WCAP-8887, Rev. 2 is attached. NU emphasizes that the attached WCAP-8687 is considered Westinghouse proprietary and should be handled as agreed to under the NU / S&L ICAVP proprietary agreement.

Previously identified by NU7 O Ye. (G) No Non Discrepant Condition?ie) Yes O No Resolution Pending?O ve. @ uo se.oiution unre.oived?O ve. @ wo l Review Acceptable Not Acceptable Needed Date 5/19/98 Pnnted 5/20/98 9:o9:12 AM Page 5 of 6

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N:rthert Utilition ICAVP DR No. DR-MP3-1088 Millstone Unit 3 Discrepancy Report VT Lead: Ryan, Thomas J B O O **

l VT Mgr: schopfer, Don K O M*

mc chmn: singh, Anand K l

Daw: 5/19/98 SL Comments:

S&L's Comments on NU's First Response l

NU's response is unacceptable.

With the exception of the Motorola MHTL Intergrated Circuit Series MC600 Series component, the critical subcomponents in the EGLS equipment and the Westinghouse SSPS equipment are not identical; consequently, the asssessment that the minimum / maximum temperatures for the Westinghouse SSPS equipment as documented in the test report WCAP-8687 is applicable to the EGLS equipment is not valid. (Note: The WCAP-8687 test report was not provided as an attachment to the DR.)

The following information is needed to comfirm operability of the EGLS:

An EQ calculation / amended EQ report with engineering anaysis justifying that the EGLS can operate within the temperure limits that the instrument Rack Room is subjected to during nomal /

abnormal conditions.

If operability of the EGLS cannot be comfirmed, NU is to state how they are meeting the IEEE 279 requirement that the an inoperable EGLS is statused in the Control Room.

S&L's Comments on NU's Second Response NU's response is acceptable.

NU's Second Response has resolved the following concems:

1) The EGLS has a desigt. faature to automatically self test the circuitry during normal operadon. Any failure detected by this testing would be alarmed h the control room. The EGLS System operability is therefore continuously monitored by the auto test ,

feature and alarmed in the control room in compliance with IEEE l 279 requirement.

2) Based on the test reports (attachments), we are in agreement with NU's conclusion that a technical assessment cf the EGLS critical subcomponents has confirmed operability of the EGLS at 68 *F by reviewing the Vitro Laboratories, EGLS Qualification Report No. 2404.01. Based on the operability assessmer.t of the EGLS at 68 'F, we concur with NU's desision to schedule the CR M3-97-1444 corrective action after start-up. .

l DR-MP3-1088 can be considered to be non-discrepant. l Pnnted 6 558 9:09:14 AM Page 6 of 6 j

l* Northe:st Utilitie3 ICAVP DR N2. DR-MP3-0514 l Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION l'. EJECTED Review Element: System Design p

Discipline: Mechanical Design g Discrepancy Type: Test Requirements System / Process: HVX NRC Significance level: 3 Date faxed to NU:

! Date Publishwi: 11/13/97 Discrepancy: Containment Enclosure Building Nagative Pressure DescripHon: During review of the Supplementary Leak Collection and Release System (SLCRS) a discrepancy in the negative pressure required to be maintained in the Auxiliary Building at elevation 24'-6" was identified.

SER Section 6.2.3 states that the capacity of the SLCRS is sufficient to reduce and maintain a pressure of -0.25 in, water gauge throughout the eaclosure building and contiguous buildings within 1 min after the accident, assuming wind velocity of 22 mph.

FSAR Section 6.2.3.3 states that the negative pressure is measured at Auxiliary Building 24 6 elevation and maintained per Technical Specifications at greater than or equal to 0.4 inches water gauge after a design accident (DBA). The 0.4 inch water gauge (iwg) negative pressure is measured at the Auxiliary Building 24-6 elevation in order to ensure a negative pressure in all areas inside the secondary containment boundary under most onsite meteorological conditions.

Drawing EM-25-12 shows the high point of the containment structure enclosure as elevation 186'-2 3/4".

Calculation 92-071-339M3 Rev. O and change number 001 determine correction factors to account for the difference in pressere at the test location, elevation 112'-0" (top of SLCRS suction ductwork) and elevation 106'-2 3/4" (top of enclosure building) caused by differences in air temperature inside and outside the containment enclosure building. The 0.4 iwg negative differential pressure in FSAR Section 6.2.3.3 is the differential pressure at elevation 24'-6" needed inorder to maintain a 0.25 iwg negative differential pressure at elevation 112'-0" with O'F outside air temperature and 50*F containment enclosure building temperature. To maintain a 0.25 iwg negative differential pressure at the top of the containment enclosure building at these temperatures a 0.51 iwg negative differential pressure is needed at elevation 24'-6".

The calculation also contains a table that provides the required negative differential pressure at elevation 24'-6" for various indoor and outdoor air temperatures. For cases with the indoor air temperature lower than the outdoor air temperature, the l required te:;t differential pressure at elevation 24'-6" is less than -

l 0.25 iwg which does not meet the requirement that all areas are I maintained at a -0.25 iwg differential pressure.

! l Pnnted 5/2098 9 03:55 AM ' iage 1 of 8

I.

l Northe:st Utdities ICAVP DR N3. DR-MP3-0514 l Millstone Unit 3 Discrepancy Report I pressure distribution around the containment enclosure building.  ;

Review Valid invalid Needed Date Initiator: st:st, M. D. '

O O O o/17/87 VT Lead: Neri, Anthony A B O O 11/1/87 VT Mgt: Schopfer, Don K B O O $ 1'6'87 BRC Chmn: singh, Anand K B O O 11/7/87 Date:

INVALID:

Date: 5/13/98 RESOLUTION: First Response

{

NU has concluded that the issue reported in Discrepancy Report, j DR-MP3-0514, does not represent a discrepant condition. j Proposed Technical Specification Change Request 3-30-93 contains a letter to the NRC dated 11/4/93 which recommends the changes to the Tech Specs and states in part on page B 3/4 6-7 paragraph 3/4.6.6.1:

"In order to ensure a negative pressure in all areas inside the secondary containment boundary under most meteorological conditions, the negative pressure acceptance criteria at the measured location is 0.4 iwg. It is recognized that there will be an occasional meteorological condition urider which slightly positive pressure may exist at some localized portions of the boundary.. " {

On 12/8/93 the NRC issued Amendment 87 along with its Safety Evaluation approving the changes to the Tech Specs. This would supersede any prior statements found in SER section S.2.3.

Furthermore, there are no piping and electrical penetrations above elevation 69'-9" in the containment liner (Reference CTMT pipe penetration drawing 12179-EP-121 A 10 and EP-121B-8.) Therefore, if a leak did occur, it would be below the

{

SLCRS duct suction. 1 CCN 001 to Calculation 92-071-339-M3 provided the independent calculation to establish the minimum negative pressure required by the SLCRS test at elevation 24* A" to render  !

minimum negative pressure of 0.25 iwg at elevation 112'-0" (top of SLCRS suction dJCt. reference drawing EB-15M.) This is the  ;

basis that the NRC accepted. The Tables in the calculation on pages 10 and 11 are based on the 186'-2 3/4" elevation.

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

1 Second Response (M3-IRF-1954) l NU has concluded that Discrepancy Report DR-MP3-0514, item l 1d, has identified a condition not previously discovered by NU Printed 5/20/98 9:09:59 AM Page 2 of 8 i

N:rthent Utilitie3 ICAVP DR No. DR-MP3-0614 Millstone Unit 3 Discrepancy Report which requires correction.

(id) Fire Stops and Seals are govemed by the EM-60 series drawings in conjunction with specification SP-GD-001. The flex.

seal referred to is en architectural cosmetic feature. The "Rodofoam"(compressible material) was all removed, but the drawings referenced were not updated. The approved corrective action to CR-M3-98-0772 will revise the affected drawings. The affected documents are not operations critical.

(1) (General) Bypass Jumper 3-03-170 provided for the installation of two tubing penetrations to measure differential pressure acrcss the Containment Enclosure. The Bypass Jumper was made a permanent modification. DCN DM3-S-1254-95 (copy attached) details location and installation of the permanent pressure taps.

(1a) The Hydrogen Recombiner Bldg is not within the SLCRS boundary. Its common wall with the Containment Enclosure acts as a boundary for SLCRS. Differential pressure was measured in the MSVB which is drawn down via the Enclosure Bldg. ,

therefore the MSVB differential pressure readings provide conservative indication of the Enclosure Bldg. differential pressure. This is not a discrepancy.

(1b) Same as above.

(1c) The measurement location was selected to eliminate the effect of wind velocity on the actual DP measurement. During testing, the door to the extemal environment was opened to ensure the high side tap was reflective of extemal pressure.

This is considered to be a more reliable approach to measuring the DP as it eliminates any dynamic effect by wind pattems at the measurement location. Ref. drawing no. 25212-2/196-00001 (12179-EB-35B) Ventilation and Air Conditioning Service Building Sh. 2. This is not a discrepancy.

(2) The drawings referenced correctly show that the duct is blanked off and the sample room dampers normally closed.

Although the staternent that the bleriked off duct is not consistent with the statement in tne 11/4/93 submittal, the degree to which the NRC relied on this information is judged to be low. The SER for Amendment 87 makes no reference to the paragraph on page 14 of the 11/4/93 submittal, but places emphasis on the NRC review of the test data used by NNECo to justify the measurement location. The SER also acknowledges that only parts of the contiguous spaces listed are included in the SLCRS boundary (ref. page 5, use of term " partially"). This implies that at some level in the supporting discussion surrounding the issuanco of this amendment that the extent to which the spaces were included in the SLCRS boundary area was discussed and clarified. While the discussion in the text of page 14 is inaccurate to some degree, it is judged to have been insignKicant or immaterial to the NRC approval of the amendment. The normally closed sample room dampers are accep_t_able because this room is outside the SLCRS boundary.

Printed 5/20S6 9:10:00 AM Page 3 of 8

I*

Northe st Utilities ICAVP DR N . DR-MP3-0514 Millstone Unit 3 Discrepancy Report This is not a discrepancy.

(3) This concem was addressed in the 11/4/93 submittal in that an analysis was performed to determine the joint probability of occurrence of wind and temperature conditions which could cause a reduction in the required building DP. NNECo i addressed this as a low probability condition in paragraph 3 on {

l page 15 of the 11/4/93 submittal. The NRC reviewed NNECo's  !

l basis and accepted it in the Amendment 87 SER. This is not a j discrepancy.

(4) The NNECo evaluation of IEN-88-76 was based on the joint probability of occurrence of the atmospheric conditio's rather than the discreet frequencies. The NRC reviewed the NNECo logic and accepted it explicitly in the SER. The approved corrective action to CR-M3-98-0772 will retrieve this analysis for confirmatory review. Justification for the "<2% time" is detailed in Calculation XX-XXX-115RA, Rev. O. A copy is attached for '

your information. This is not a discrepancy.

(5.1 & 5.2) The -0.51 iwg DP value cited would be required if the design were based on achieving a minimum of -0.25 iwg DP under all conditions. As noted in the 11/4/93 submittal, the proposed acceptance value of -0.4 iwg was not intended to bound all conditions.

(5.3) The extreme environmental conditions described in IEN 88-76 were addressed through the joint probability evaluation previously discussed and excluded on the basis that they  ;

occurred <2% of the time. (See attached calculation XX-XXX-115RA, Rev. 0) This is not a discrepancy.

The test rig locations listed on the Test Rig Location Diagram in  !

IST 3-93-045 are explained on the attachment titled Test Rig Locations IST 3-93-045. (This is in response to S&L's request per NU/S&L telecon 3/25/98).

Licensing basis / design basis not affected by the discrepant conditions. NU considers the discrepant item 1d to be Significance Level 4. The corrective action will be completed post startup.

I Attachments:

CR-M3-98-0772 with approved corrective action plan Calculation XX-XXX-115RA, Rev. O DCN DM3-S-1254-95 Test Rig Locations IST 3-93-045 l Supplemental Response (M3-IRF-2322) l This response supplements M3-IRF-01954. At a meeting held on 4/14,'98 at Millstone, S&L requested additional information conceming the SLCRS Verification Test.

A copy of MP3 Surveillance Procedure SP 36141.3, Rev. 9, is attached to this transmission. Ste:> 4.1.5.b is an instruction to Pmted 5/20/98 9:10:01 AM Page 4 of 8

• Nsrthecst Utilitiss ICAVP DR No. DR-MP3-0514 Millstone Unit 3 Discrepancy Report block open 'at least one side of the Servico Building east corridor north door (S-24-20)".

To supplement information provided in M3-IRF-01954, a copy of MP3 Surveillance Procedure SP 36141.3, Rev. 9, is attached to this transmission. Also, IST 3-93-046 was the last test performed in which multiple measuring points were used. The difference between the MSVB and the AB (PDiT212) readings (0.05) is insignificant. Both areas met the required negative pressure at 40 seconds and both areas were significantly more negative than 0.40" WG at 120 seconds.

Attachments:

SP 36141.3 Supplementary Leak Collection and Release System Negative Pressure Verification Pr;rviously identified by NU? O Yes @ No Non Discrepant Condition?U Yes (9) No Resolution Pending70 Yes @ No Resoiution unresoived7@ Yes O No Review initiator: stout, M. D. * * **

• VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh. Anand K oste: 5/13/98 sL Comments: Comments on First Response NU responso does not fully address the issues identified in the discrepancy report.

1) NU Letter 814669 dated November 4,1993, which transmitted the proposed technical specification change request for the supplementary leak collection and release system, provides a discussion for using a single point pressure measurement location. The argument was that there is a large open area between the various buildings and provides a table of the area of the openings. Looking at the areas provided in the letter it would seem that a single measurement locatiors is reasonable.

However, when the physical details for the 4" shake space between the containment structure and the surrounding buildings, IST 3-93-045 test results, and IST 3-93-046 test results are reviewed it is not obvious that a single point pressure measurement at elevation 24'-6"is representative of the pressure for the whole structure.

a) IST 3-93-045 conducted on 10/24/943 measured differential pressures in the auxiliary building, ESF Building, and main steam valve building (per Attachment 1 Test Rig Locations). Differential pressures where not measured in the hydrogen recombiner building and the containment enclosure during the drawdown test.

b) IST 3-93-046 conducted on 10/27/93 measured differential pressures in the auxiliary building, ESF building, and main steam valve building (per Attachment 1 Test Rig Locations). Differential pressures where not measured in the hydrogen recombiner Printed 5/20/98 9.10:03 AM Page 5 of 8

I-l 0

Northert Utilitie3 ICAVP DR N . DR-MP3-0514 Millstone Unit 3 Discrepancy Report building and containment enclosure during the drawdown test.

l c) The auxilary building elevation 24'-6" general area measurement records the differential pressure between the

( '

auxiliary building and the service building. Depending on the relative pressure of the service building to the outside, the actual auxiliary building differential pressure with respect to outside could be different than that read on 3HVR-PDIT212.

d) Drawing EA-1S-1 section 5-5 shows a flex seal in the shake space between the ESF building and Containment Stucture.

Drawing EA-42A-17 ioes not show the flex seal. There were no i open change docuri ents posted against drawing EA-1S that l removed the flex seal. In addition section 70-70 on drawing EC- )

32E-5 shows compressible material installed in the shcke space near the removable slabs on the ESF Building Roof. If the flex ]

seal at the bottom of the containment enclosure shown on EA-1S- t 1 or the compressible material shown on EC-32E-5 is installed, the ESF building does not appear to directly communicate with the containment enclosure.

2) NU Letter B14669 dated November A,1993, page 14, states that there is a SLCRS duct connection for exhausting from the hydrogen recombiner building. Both P&lD EM-148E-12 and duct drawing EB-72A-6 show the exhaust duct openings blanked off and that damper 3HVR*DMP60 in the duct that exhausts from the sample room is normally closed. Therefore, there would be no direct SLCRS exhaust from the hydrogen recombiner building l during secondasy containment drawdown as implied in the letter. I

3) As shown on P&lD EM-148E-12 and duct drawing EB-15M-10, ,

SLCRS uhausts 6430 cfm from the containment enclosure at l one location between columns C & D (auxiliary building side of I the containment enclosure). Not all of the containment penetrations, shown on drawing EP-121 A 10 and EP-121B-8, are located in the same area (quadrant) as the SLCRS exhaust opening in the containment enclosure. For example, the penetrations into the hydrogen recombiner building are on the opposite side of the enclosure. As the radius of the containment structure is ~75' exhausting from only one location does not 1 ensure that leakage into the containment enclosure space is i exhausted by SLCRS if th; mal or wind effects cause the pressure differential to be less than .25 iwg in portions of the containment enciasure.

4) NU Letter B14669 dated November 4,1993, page 15, indicated that the combination of low outdoor temperatures and moderate wind speeds would occur less that 2% of the time. Based on FSAR Table 2.3-15, the 33-foot wind speed is between 4 - 12 mph 60.8% of the year and between 13 - 18 mph 18.77% of the year. Considering the containment structure as a cylinder, wind effects result in the pressure on the outside surface of the

' enclosure to vary significantly. With a 18 mph wind, the outside surface pressure for the con 91nment enclosure varies from +0.15 iwg (O' ezimuth) to 0.18 iwg (90' azimuth). A -0.25 iwg differential pressure readina at O' azimuth would result in a +0.09 Printed 5/20/96 9:10:04 AM Page 6 of 8

(.

O Northe:st Utilitie3 ICAVP DR N2. DR-MP3-0514 Millstone Unit 3 Discrepancy Report iwg differential at 90' azimuth. A -0.40 iwg differential pressure reading at O' azimuth would result in a -0.06 iwg differential at 90' azimuth. Neglecting thermal effects that occur in the winter, using a single measurement location could result in portions of the secondary containment not meeting the differential pressure requirement of .25 iwg (outlined in IE-IN 88-76) m. re frequently than the 2% of the time stated in the letter.

5) Using an outdoor air temperature of 0*F and indoor air temperature of 50*F (ref, calc 92-071339-M3, CCN 001, pg 6) the differential pressure required at el 24'-6" to maintain the differential pressure at the top of the containment enclosure at -

0.25 iwg is -0.51 iwg (ref. calc 92-071-339-M3, pg 10). The .40 iwg differential at el 24'-6" would maintain a .25 iwg differential with an outside air temperature of 20*F and an inside air temperature of 50*F. Note however, that based on New London, CT ASHRAE weather data, outside air temperatures are below 20'F more than 2% of the winter months. Therefore, to account for thermal effects only, the differential pressure at elevation 24'-

6" should be -0.51 iwg not -0.40 iwg.

This is considered a descrepant condition due to the following:

1. The -0.40 iwg Differential pressure at elevation 24'-6" does not maintain the top of the containment enclosure at a .25 iwg differential pressure when thermal effects described in NRC Information Notice No. 88-76 are accounted for.

2. The differential pressure at elevation 24'-6" in the auxiliary building has not been established as representative of the pressure in the containment enclosure and hydrogen recombiner building based on information received from NU.

3. The required differential pressure to offset normal wind effects on the containment enclosure has not been addressed.

Comments on Second and Supplemental Responses NU's response resolves comments #1 and 3 above. NU's response does not resolve comment #2 regarding the differential pressure measurement location.

1. The differential pressure is measured between the auxiliary building el 24'-6" and the service building. NU's response indicates that the service building door to the outside is opened during testing. This requirement was not contained in surveillance procedure SP36141.3 " Supplemental Leak Collection and Release System Negatnre Pressure Verification" until 4/2/98 when Change 3 issued. This is considered a discrepant condition as tests performed prior to 4/2/98 may have been influenced by the service building pressure relative to the outside.

2. The differential pressure measurement location does not bound the differential pressure in the main steam valve building in all cases. The B-train winter mode test results for IST 3-93-036 show the MSVB differential pressure as beina 0.05 iwa less than that Printed 5/20r98 9:16:13 AM Page 7 of 8

I, O DR N2. DR-MP3-0514 Northext Uti!! ties ICAVP Millstone Unit 3 Discrepancy Report measured in the auxiliary building. The results of the May 30, 1995 Train B SLCRS Negative Pressure Verification show a differential pressure at elevation 24'-6" in the Auxiliary Building of -0.425 iwg at 120 seconds and -0.45 iwg at 200 seconds.

Adjusting for the 0.05 iwg offset in the MSVB, the secondary containment differential pressure is -0.375 iwg at 120 seconds and -0.40 iwg at 200 seconds which does not meet the acceptance criteria of -0.40 iwg within 120 seconds. The results of the May 30,1995 Train A SLCRS Negative Pressure Verification show a differential pressure at elevation 24'-6" in the Auxiliary Building (3HVR-PDl210) of -0.475 iwg at 120 seconds and -0.475 iwg at 200 seconds. The B-train results for IST 390-014 run #3 shows the MSVB 0.35 iwg ( .11 - ( .46)) less than the auxiliary building. The A-train results on run #1 show the MSVB 0.09 iwg (-

.41 - ( .5)) less than the auxiliary building. Therefore, using differential pressure measured at elevation 24'6" of the auxiliary building does not ensure that all areas of the secondary containment are drawn down to negative pressure within 120 seconds after an accident as stated in FSAR Section 6.2.3.3.

3. The measurement location between the auxiliary building and service building (northwest comer) on elevation 24'6"is influenced by the t,narging pump room ventilation system (fans 3HVR*FN13A/B and 3HVR*FN14A/B). In the winter mode, air is supplied to the component cooling pump area and exhausted through the charging pump rooms. In the summer mode, air is supplied and exhausted from the component cooling pump area (ref. drawing EB-45C-13). The net exhaust airflow in this area influences the differential pressure measured and may mask an lower differential pressure in the containmerit enclosure during drawdown testing.

This DR is unresolved.

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l Printed 5/20/98 9:16:13 ATA Page 8 of 8

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