ML20217K456
| ML20217K456 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/30/1998 |
| From: | Schopfer D SARGENT & LUNDY, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 9583-100, NUDOCS 9805010222 | |
| Download: ML20217K456 (97) | |
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Sar geMk Lundy"c YfIf Don K. Schopfer Senior %ce President 312 269-6078 April 30,1998 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 Regulaton Commission Attention: Document Control Desk Washington, D.C. 20555 Enclosed are discrepancy reports (DRs) identified during our review activities for the ICAVP, These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.
I have enclosed the following twenty-two (22) DRs for which the NU resolutions have been reviewed and accepted by S&L.
DR No. DR-MP3-0001 DR No. DR-MP3-0535 DR No. DR-MP3-0003 DR No. DR-MP3-0543 DR No. DR-MP3-0143 DR No. DR-MP3-0615 DR No. DR-MP3-0179 DR No. DR-MP3-0660 DR No. DR-MP3-0297 DR No. DR-MP3-0688 DR No. DR-MP3-0315 DR No. DR-MP3-0752 DR No. DR-MP3-0369 DR No. DR-MP3-0823 DR No. DR-MP3-0372 DR No. DR-MP3-0884 !
DR No. DR-MP3-0373 DR No. DR-MP3-0980 n
,U DR No. DR-MP3-0434 DR No. DR-MP3-1002 f 'l DR No. DR-MP3-0529 DR No. DR-MP3-1070 -f "'
9905010222 900430 PDR ADOCK 0:000423 P PDR 55 East Monroe Street + Chicago. IL 60603-5780 USA + 312-269-2000
1 I Inited States Nuclear Regulatory Commission April 30,1998 L ocument Control Desk - Project No. 9583-100 j Page 2 j 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-M.P3-0294 Please direct any questions to me at (312) 269-6078.
Yours very truly, DT _
~
D. K. Schopfer i Senior Vice President and ICAVP Manager DKS:spr Enclosures Copies:
E. Imbro (1/l) Deputy Director, ICAVP Oversight T. Concannon (1/l) Nuclear Energy Advisory Council J. Fougere (1/l) NU m:\icav}iarr\98M430-a doc i
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Northeast Utilities ICAVP DR N2. DR-MP3-0001 Millstone Unit 3 Discrepancy Report J Review Group: Programmetse DR RESOLUTION ACCEPTED PoterW'.al Operability issue Discipline: Other Discrepancy Type: Design Control Procedure g~
System / Process: N/A NRC Significance level: 3 Date faxed to NU:
Date Published: 7/8/97 Descrepancy: Consistency with Technical Specifications
Description:
We have reviewed Millstone Station Procedure DC 1, Rev. 5 (effective 3/3/97), titled " Administration of Procedures and Forms". Based on this review, we have noted the following discrepancies.
- 1. This procedure is not consistent with Technical Specification 6.8.3.c. This section of the technical specification requires, in the case of temporary, non-intent changes to procedures required by Technical Specification 6.8.1, that the change be approved by the Station Qualified Reviewer Program Manager or Nuclear Unit Director or Senior Vice President - Millstone Station within 14 days. Paragraph 1.6.3.a.4 of procedure DC 1 requires ,
that non-intent procedure changes be approved (including independent Review and Safety Evaluation Screening) by the Department Head, Responsible Individual, PORC or SORC within 14 days. These requirements are inconsistent with the i Technical Specification requirements.
- 2. Section 1.1 of procedure DC 1 has an obsolete quotation.
This section quotes Section 6.8.1 of the Technical Specifications as requiring procedures for Security Plan and Emergency Plan implementation. Amendment No.128 to the Technical Specifications, dated 4/24/96, deleted these requirements. This is an editorial discrepancy since these types of procedures are required by other regulations ttnd Millstone commitments, e.g.,
10 CFR 50, Appendix E, and Regulatory Guide 1.33.
Review Valid travalid Needed Date initiator: Sheppard, R. P. O O O 5/1 187 j
VT Lead: Ryan, Thornas J G O O 6/13'87 I VT Mgr: Schopfer, Don K Q O O S'30'S7 IRC Chmn: Singh, Anand K O O O 7/3'S7 Date:
INVALID:
Date: 4/28/98 RESOLUTION: Disposition:
Item 1:The Station Qualified Reviewer (SQR) Program has been implemented in accordance with Technical Specification 6.5.4.2.
Specification 6.5.4.5 directs that temporary revisions to procedures for which Qualified Reviewers are assigned be processed in accordance with Specification 6.5.4.2 in lieu of Specification 6.8.3. Specification 6.5.3.2.e provides for approval by the Responsible Manager for the functional group responsible Printed 4/30/98 3 45:12 PM Page 1 of 7
Northert Utilitie3 ICAVP DR No. DR-MP34001 Millstone Unit 3 Discrepancy Report for review of the technical content of the specific procedure. The statement " Station Qualified Reviewer Program Manager"in Specification 6.8.3.c is the same
- Responsible Manager" mentioned in Specification 6.5.4.2.e.
If a procedure change is required, (including the type described in Technical Specification Section 6.8.3.c), the owner department is responsible to perform the change. Each type of procedure change requires, at a minimum, an Independent Technical review, performed by a subject matter expert, and a review by the applicable Depertment Head to determine its applicability and correctness. Fer those Departments that have met the requirements to fully implement the SQR Program, and have been approved by their applicable Plant Operations Review Committee (PORC) or the Site Operations Review Committee (SORC), the Department head is authorized to sign for
" Approval" of the change in lieu of presenting it to the PORC or SORC for their review and approval.
The intent of Technical Specification 6.8.3.c is further defined in the transmittal letter B15309 which submitted the Proposed Technical Specification Change Request (PTSCR) to the i Nuclear Regulatory Commission on August 4,1995. The statements in the letter indicate that a manager will be appointed to approve the procedures "for that group." Key portions of the letter are quoted below:
" Description of Proposed Changes
... establishment of a station Qualified Reviewer Program (SORP) and the reassignment of certain procedure approvals to designated managers in lieu of approval by PORC/SORC."
"...Those procedures and programs that will go to the SQRP will be defined in writing and are anticipated to include those procedure changes that do not require a 10CFR50.59 evaluation... Procedures that can meet the SQRP definition will have a manager appointed who will have the authority to approve the procedures."
" Safety Assessment l
These proposed modifications will create a new SQRP which will permit the review of designated programs and procedures that !
are required by Technical Specification 6.5.1.6 and E.5.2.6 to be ;
performed by a SQR and approved by designated j managers....Those programs and procedures that would be j reviewed by a SQR in lieu of PORC/SORC will be designated in I writing by the Unit Director or the Senior Vice President - l Millstone Station. SQRs and managers who are authorized to l approve procedures will also be designated in writing by the Unit I Director or the Senior Vice President - Millstone Station.
Procedures which require a 10CFR50.59 evaluation will continue to require that a review be performed by PORC/SORC."
I implementation of the program is administered through Station Procedure DC-15. " Station Qualified Reviewer Procram." In Printed 4f30/96 3 45:16 PM Page 2 of 7
Northea:t Utilities ICAVP DR No. DR-MP3-0001 Millstone Unit 3 Discrepancy Report accordance with Section 1.6 of that procedure, the SQR Program will be implemented for a department only after the SQR candidates have been selected and approved, and the department has demonstrated that it can apply the program successfully and correctly.
Procedures DC-1 and DC-15 will be revised to state that a responsibility of the Department Head is to function as the
" Station Qualified Reviewer Program Manager" for approving non-intent changes. A copy of the draft change to DC-1 is attached. The change to DC-15 will be similar.
DR-MP3-0001, item 2: Revision 6 to DC 1 was started in June 1997 and the reference to the outdated Technical Specification was recognized during the Verification and Validation process.
Specifically, it was noted by a reviewer during the performance of a " Station Procedure Review" and provided as a comment for resolution. Subsequently, the paragraphs found in Revision 6 in Section 1.1 were rewritten to more clear 1y reflect that various regulations, standards, and commitments require the development of procedures. A copy of the draft change is attached.
Conclusion:
The Station Qualified Reviewer Program implements Technical Specification 6.5.4.2, with changes approved by the designated manager as stated in 6.8.4.2.e and as described in transmittal letter B15309 to the NRC. Clarification of the use of different titles will be included in the next revision to Station Procedures )
DC-1," Administration of Procedures and Forms" and DC-15, '
" Station Qualified Reviewer Program." The issue stated in item 2 of DR-MP3-0001 was identified during development of i Revision 6 to DC-1, which was initiated in June,1997, and will be included in that revision when issued. Condition Report M3-97-2069 will track these changes to completion.
2nd Response:
Disposition:
NU has concluded that DR-0001 has identified a condition not '
i previously discovered by NU which requires correction. The approved Corrective Action Plan for CR M3-97-2069 will correct these issues. Based on the administrative nature of these issues, NU has concluded that this a significance level 4 discrepancy. NU has concluded that the items identified in comments to IRF M3-IRF-00121 do not represent discrepant conditions.
These items are discussed below:
The term " Responsible Individual" is the generic title used to describe the management person assigned ownership of a particular document or series of documents.
PrWed 4/30/96 3 45:17 PM Page 3 of 7
Northert Utilities ICAVP DR No. DR-MP3 0001 Millstone Unit 3 Discrepancy Report Responsible Individuals are assigned as follows:
Department procedures have the ap(Schtse Department Head assigned as the Responsible Individual. e.g., the Unit 3 Operations Department Head (by title and name) is assigned as the Responsible Individual for each of the procedures belonging to the Unit 3 Operations Department.
Unit and Common Department procedures have a Department Head (from one of the departments that use the document) selected to act as the Responsible Individual.
Station procedures have a Department Head (usually the management person responsible for the program implemented by the Station procedure) selected to cct as the Responsible Individual.
In each of these situations, the Department Head / Responsible Individual is assigned as the " Station Qualified Reviewer Program Manager" for the implementation of the SQR Program (responsibilities defined in both DC 1, " Administration of Procedures and Forms," and DC 15, " Station Qualified Reviewer Program").
Their responsibility includes approval of the documents they are responsible for following the applicable Verification and Validation reviews and a recommendation for approval from an SQR approved independent Reviewer. Since, in all cases the review includes a review by an individual qualified as a Station Qualified Reviewer, this is not a discrepant condition.
There is no formal qualification process or training requirements for the position of Station Qualified Reviewer Program Department Head. Their responsibility includes approval of the documents they are responsible for following the applicable Verification and Validation reviews and a recommendation for approval from an SQR approved independent Reviewer. Since there is no formal qualification for the position of SQRP Manager, and his approval only follows the review by a qualified individual, item 4a does not represent a discrepant condition.
All" temporary changes" approved using the SQR Program requirements were processed in accordance with Technical Specification 6.5.1.7.a 6.5.2.7.a. 6.5.4.2,6.5.4.5, and 6.8.3.c.
Therefore no corrective action is required and no past temporary changes require additional approvals before startup. Item 4b does not represent a discrepant condition.
Conclusion:
NU has concluded that DR-0001 has identified a condition not previously discovered by NU which requires correction The approved Corrective Action Plan for CR M3-97-2069 will correct these issues.
Based on the administrative nature of these issues, NU has concluded that this a significance level 4 discrepancy.
NU has concluded that the items identified in comments to IRF Printed 4'30/98 3 45:18 PM Page 4 of 7 1
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Northerct Utilities ICAVP DR No. DR-MP3-0001 l Millstone Unit 3 Discrepancy Report
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M3-IRF-00121 do not represent discrepant conditions. ,
The Department Head / Responsible Individual is assigned as the
" Station Qualified Reviewer Program Manager" for the implementation of the SQR Program (responsibilities defined in both DC 1," Administration of Procedures and Forms," and DC 15, " Station Qualified Reviewer Program"). Their responsibility includes approval of the documents they are responsible for following the applicable Verification and Validation reviews and a recommendation for approval from an SQR approved independent Reviewer. The approval by the Department Head )
is based on a review by a qualified indMdual in all cases so additional qualification as the Station Qualified Review Program Manager is not necessary. 1 All " temporary changes" approved using the SQR Program requirements were processed in accordance with Technical ,
Specification 6.5.1.7.a,6.5.2.7.a,6.5.4.2,6.5.4.5, and 6.8.3.c. '
Therefore no corrective action is required and no past temporary changes require additional approvals before startup. This item j does not represent a discrepant condition.
Based upon the nature of the identified issues in this DR, NU has determined this to be a Severity Level 4 Discrepancy.
Supplement to 2nd Response: j Disposition: l l
NU has concluded that item #3 identified in comments to IRF M3-IRF-00121 represents a discrepant condition which requires correction.
The question is how do recommendations for items considered by PORC get transmitted to management as required by Tech.
Spec. section 6.5.1.7. This IRF is being sent after a review of Technical Specification Section 6 was conducted into the method of meeting the requirements of Technical Specification section 6.5.1.7. It was discovered that no formal written approval or disapproval of items considered by PORC under section 6.5.1.6a. was provided to the Unit 3 Unit Director as required by scetion 6.5.1.7a. CR M3-981247 was written and the approved corrective action plan will correct this issue. A !
signature block was added to the PORC Meeting Minutes Form for the Unit Director documenting approval of all recommendations of PORC. As a further enhancement, OA3 will be changed to include a requirement for the Unit Director Approval signature for all items considered by PORC under TS section 6.5.1.6a.
Notification to the Senior Vice President and CNO-Millstone, Vice President - Millstone Unit 3 and the Chairperson of the Nuclear Safety Assessment Board is assured by being on the 4 distribution of PORC Minutes as specified in OA3.
Item 4 was previously addressed in IRF 00421.
Pritted 4/30/98 3 45:19 PM Page 5 of 7
Northerct Utilities ICAVP DR N2. DR-MP3-0001 Millstone unit 3 Discrepancy Report Based on the administrative nature of this discrepancy, NU considers this to be a significance level 4.
Conclusion:
NU has concluded that item #3 identified in comments to IRF M3-IRF-00121 represents a discrepant condition which requires correction. No formal written approval or disapproval of items considered by PORC under Technical Specification section 6.5.1.6a. was provided to the Unit 3 Unit Director as required by section 6.5.1.7a. A signature block was added to the PORC Meeting Minutes Form the Unit Director documenting approval of all recommendations of PORC. The approved Corrective Action Plan for CR M3-98-1247 will provide a further procedure enhancement to OA3 to address these issues. Notification to the Senior Vice President and CNO- Millstone Unit 3 and the Chairperson of the Nuclear Safety Assessment Board is assured by being on distribution of PORC Minutes as specified in OA3.
Based on the administrative nature of this discrepancy, NU considers this discrepancy to be a significance level 4.
Attachments:
CR M3-98-1247 MP3 PORC Meeting Minutes Cover Sheet Previously identified by NU? O Yes (8) No Non Discrepent Corulition?O Yes (9) No ResolutionPending?O Yes @ No Re.oiution unre.oived?O Yo. @ No Review initiator: Sheppard, h. P.
VT Lead: Ryan. Thomas J VT Mgr: Schopfer. Don K IRC Chmn: Singh, Anand K Date: 4/28/98 SL Comments: Review of NU's 1st Response:
- 1. The resolution of part 2 of the discrepancy is acceptable.
- 2. The changes to procedure DC-1 stating that the Department Heads may function as SQRP Managers are acceptable.
- 3. No changes are proposed to paragrrph 1.6.3.a.4 of procedure DC-1. DC-1 needs to reflect the applicable procedure approval requirements in Technical Specifications 6.5.1.7.a,6.5.2.7.a, 6.5.4.2.e and 6.8.3.c. Thus, the identified discrepancy remains unresolved.
- 4. The response does not address the extent of condition as follows:
- a. Have these temporary, non-intent changes, which were reviewed by Qualified Reviewers, been approved by personnel whose qualifications meet that of a SQRP Manager, i.e., do the Printed 4W 3 45 21 PM Page 6 of 7
I Northert Utilitie3 ICAVP DR No. DR-MP3-0001 Millstone Unit 3 Discrepancy Report Responsible Individuals discussed in paragraph 1.6.3.a.4 of DC 1 meet the qualifications of this management position?
- b. If past changes have not been processed in accordance with Technical Specifications 6.5.1.7.a. 6.5.2.7.a. 6.5.4.2,6.5.4.5 and 6.8.3.c, what corrective action is proposed? Do any past temporary changes need additional approvals before start-up?
Review of 2nd Response and Supplement to 2nd Response:
- 1. We accept NU's response that there is no need to require additional approvals of past procedure changes.
- 2. Technical Specification 6.5.2.2 and Attachment 1 to Procedure OA-4 titled " Site Operations Review Committee" require the SORC Chairperson be the Senior Vice President - Millstone Station. Therefore, we conclude that with the change to the PORC Meeting Minutes Form to document the Unit 3 Unit Director approval of PORC recommendations, there is sufficient procedural guidance to comply with Technical Specification 6.8.3 conceming the approval of temporary procedure changes. The proposed change to procedure OA3 titled " Plant Operations review Committee" will reinforce the change to the PORC Meeting Minutes Form. These changes will assure Technical Specification compliance on a programmatic basis.
- 3. Based on a telecon, NU agrees that this discrepancy should be classified as Significance Level 3.
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Prtrned 4/3098 3.45:23 PM Page 7 of 7 l
Northert Utilities ICAVP DR NL DR-MP3-0003 Millstone Unit 3 Discrepancy Report Review Group: Programmate DR RESOLUTION ACCEPTED Discipline: Oth" Potential Operability lasue Discrepancy Type: Design Control Procedure O **
System / Process: N/A NRC Significance level: 4 Date faxed to NU:
Date Published: 7/17/97 Discrepancy: Environmental Screening
Description:
We have reviewed the following procedures as they relate to licensing documents: Design Control Manual (DCM), revision 05; Procedure NGP 4.03, revision 7 (effective 11/4/96), titled
" Changes and Revisions to Final Safety Analysis Reports";
Procedure NGP 4.04, revision 9 (effective 1/12/97), titled
" Review and Approval of Proposed Changes to Selected License Requirements"; and Procedure NGP 5.14, revision 11 (effective 4/1/96) titled "Non-Radiological Environmental reviews of Plant Design Change Records and Procedure Changes". Based on this review we have noted the following discrepancies.
- 1. Design changes such as new office buildings and warehouses are outside the scope of the DCM (reference Attachment 1-2 of the DCM). The above procedures do not require that these types of design changes or resulting changes to the Updated Final safety Analysis Report receive an environmental screening to ensure that they do not constitute an unreviewed environmental question as required by paragraph 2.C.2 of the Operating License and 10 CFR 51.90.
- 2. Procedure NGP 4.04 is intemally inconsistent. Section 4.3 of NGP 4.04 states that changes to the following documents constitute license amendments: 1) the Environmental Protection Plan (Millstone 3), when effects are significant enough to exceed the effects previously reviewed and accepted by the NRC for the particular system or type of operation involved, or 2) the Millstone 3 Environmental Protection Plan.
Review Valid invalid Needed Date initiator: sheppard. R. P.
O O O 7/7/S7 VT Lead: Ryan, Thomas J B O O 7/a/97 VT Mgr: schopfer, Don K O O O 7/10'87 IRC Chmn: singh. Anand K G O O 7/11/87 Date:
INVALID:
Date: 4/28/98 RESOLUTION: Disposition:
ltem 1 - Procedure OA-6, Site Facility Utilization, addresses changes outside the scope of the DCM and ensures that those changes not covered by the DCM have regulatory requirements identified on the Site Utilization Request form. The Site Utilization Request form must be approved by the Site Utilization Committee (SUC).
Pnnted 4/30/98 3:46:26 PM Page 1 of 4
Northent.t Utilitie3 ICAVP DR No. DR-MP3-0003 Millstone Unit 3 Discrepancy Report !
The SUC membership consists of the following:
Manager- Site Facilities Chairperson appointed by Manager-Site Facilities Supervisor- Site Facilities Secretary appointed by Manager-Site Facilities Unit 1 Representative Unit 2 Representative Unit 3 Representative Unit Services Representative Site Facilities Rep. NUSCo Land Planning and Management Rep.
NNECo Nuclear Services NNECo Generation Test Services Rep.
Rep. j NUSCo Nuclear Training Security Representative 1 Rep.
Station Fire Marshall Unit 1 Design Engineering Representative Specifically step 1.7.6 of OA-6 requires the Supervisor-Site Utilization to "Specify regulatory requirements in Review and Approval for Use, Modification, Installation, or Construction Section of Attachment 2, ' Site Utilization Request,' and recommend approval or disapproval."
OA-6 is the starting point for changes thought to be outside the scope of the DCM. Changes are either determined to be in the scope of the DCM or outside that scope. Those changes which are outside the scope of the DCM have all regulatory (Including environmental) requirements identified on the Site Utilization Request. The NUSCo Land Planning and Management Representative on the SUC is well aware of environmental regulatory requirements and has served on the SUC to ensure all land use issues are properly addressed.
Two enhancements have been made to OA-6. The first added steps to more clearly direct initiation of DCM changes for flood plan effects when any structure is erected.
The second change added an Environmental Services section representative to the Site Utilization Committee. The Environmental Services group was formed onsite at Millstone in February of 1997 and the Manager-Environmental Services has been serving on the SUC since May of 1997 at his request. The procedure change formalized the position and added another level of review in addition to the current NUSCo Land Planning and Management Representative. The procedure change was handled via a change notice and was approved at the 7/23/97 SORC meeting. Another planned enhancement to the procedure is to add a clarification that states that changes to the EPP also effect the OL and that the DCM may be used as a guide for environmental screening criteria for changes. This is being tracked by AR97018600.
It has also been recognized that a greater awareness of environmental screenina requirements is needed throuah Printed 4/30/98 3 46:30 PM Page 2 of 4
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l N:rtherct Utilities ICAVP DR NA DR-MP3-0003 l
Millstone Unit 3 Discrepancy Report corrective actions associated with CR M3-97-1480 initiated 5/17/97 and ACR M3-96-0454 initiated 7/24/96 and assessments performed at the start of the CMP. As a result AR97011859 and AR96027594 are intended to improve awareness and performance of environmental screenings through training and a review of how the administrative procedures interface with each other.
Item 2 - This part of the DR refers to an apparent inconsistency within NGP 4.04 Rev. 9. Section 4.3 of the NGP lists those items which would require a License Amendment Request (LAR) to be initiated. Two of the conditions for which an LAR is required are as follows: item 4.3.4 lists, "A change in the EPP that could result in an increase in environmental effects significant enough to exceed the effects previously reviewed and evaluated by NRC for the particular system or type of operation involved" ; item 4.3.7 lists, " Changes to the Millstone 3 Environmental Protection Plan".
Step 4.3.7 could be interpreted as being inclusive of 4.3.4, however in discussions with Licensing, the intent of 4.3.7 is for direct changes to the Environmental Protection Plan whereas
)
4.3.4 was intended to address those effects on the EPP which could result indirectly because of a plant or operational change.
CR M3-97-2186 has been initiated to document and track this issue. This is a procedure enhancement only to clarify the wording to step 4.3.4.
Conclusion:
Item 1 The Millstone site depends on a combination of the Design Control Manual (for changes within the scope of that manual) and procedure OA-6, Site Facility Utilization, to ensure that the Environmental Protection Plan is adhered to for all power block and site changes.
For changes outside the scope of the DCM, the required environmental reviews for permits and effects on the OL are being perLined in accordance with OA-6, Site Facility Utilization. Based on your observations and as a result of l increased awareness of environmental screening issues, due to the establishment of the Environmental Services section onsite at Millstone, several enhancements have been made and more are planned to OA-6 to ensure that a high quality and consistent i review is completed on each and every occasion. This is being tracked by AR97018600.
Item 2 The DR points out the need to clarify a portion of NGP 4.04, Review and Approval of Proposed Changes to Selected License Requirements. This issue has been documented and will be tracked to completion on CR M3 2186.
Previously identified by NU? O Yes @ No Non Discrepent cond6 tion?U Yes @ No Resolution Pending?O Yee @ No Resolution Unresolved?O Ye. @ No Review Printed 4/3098 3 46:31 PM Page 3 of 4
3 Northert Utilities ICAVP DR No. DR-MP3 0003 Millstone unit 3 Discrepancy Report initiator: Shepperd, R. P.
VT Lead: Ryan, Thomas J VT Mgr: Schopfer, Don K IRC Chmn: Srgh, Anand K Date: 9/15/97 sL comments: The response as stated is acceptable. The DR had identified two discrepancies. The first part as it tumed out was previously identified, the second was not. Because the previously identified part of the discrepancy had a significance level of 3 and the unidentified part has a significance level of 4, the final discrepancy level has been changed to a 4.
Printed 4/3CV98 3M33 PM Page 4 of 4
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Northext Utilitie3 ICAVP DR N2. DR-MP3-0143 Millstone Unit 3 Discrepancy Report l I
Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Discipline: Mechanical Design Discrepancy Type: Licensing Document l System / Process: Rss @ No NRC Significance level: NA Date faked to NU:
Date Published: 11/2/97 Discrepancy: Inconsistency between FSAR Section 6.2.2.2 & Spec 2361.900-921 regarding thermal insulation
Description:
FSAR Section 6.2.2.2 states that encapsulated insulation inside i containment has inner and outer stainless steel jackets with {
minimum thicknesses of 0.010 and 0.018 inches, respectively.
However, General Thermal Insulation Specification 2361.900-921 Revision 2 states that the Jacketing minimum thickness is 0.010 inches, not addressing whether the Jacket is the inner or outerlayer.
Review Valid invalid Needed Date )
Initiator: Feingold, D. J. O O o' 7'S7 O i VT Lead: Neri, Anthony A B O O o'17/97
)
VT Mgr: schopfer, Don K O O O 1 720'S7 1
1RC Chmn: singh, Anand K O O O 'o'30'S7 j
D.i.:
INVALID: i Date: 4/27/98 RESOLUTION: - Northeast Utilities' Initial Response Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0143, does not represent a discrepant condition. {
During the 50.54(f) effort, each statement of fact in the FSAR was validated and verified. The subject statement in the FSAR was annotated and verified to be based upon specification 2361.900-345, Rev 1, Removable Thermal Insulation. The DR incorrectly identifies 2381.900-921, Rev 2, General Thermal Insulation, as the reference specification. The 345 specification confirms FSAR section 6.2.2.2 because it addresses the minimum thicknesses of the encapsulated insulation and includes equipment and piping inside containment. The i specification referenced in the DR does not apply to the equipment and piping inside containment. j 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-MP3-0143, does not represent a discrepant condition. The DR references the incorrect specification relative to the FSAR Printed 4/30/96 3 47A8 PM Page 1 of 3 J
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Northert Utilitie2 ICAVP DR No. DR-MP3-0143 Millstone Unit 3 Discrepancy Report statement. As indicated on the annotated section of FSAR section 6.2.2.2, the correct specification is 2361.900-345, Removable Thermal Insulation. This specification addresses the minimum thicknesses of the encapsulated insulation and includes equipment and piping inside containment.
Significance Level criteria do not apply here as this is not a discrepant condition.
- Northeast Utilities' Second Response Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0143, does not represent a discrepant condition.
The Line Designation Table is a controlled database which provides technical details of all piping systems throughout Millstone Unit 3. Included on this list, is the line insulation type designation. To interpret the type designation code, Design Engineering utilizes the Plant Design Data System (PDDS) for more detailed information regarding insulation classification.
Therefore, to properly determine the required pipe covering, one would first identify the line ID number and then, refer to the Line Designation Table to determine the insulation code associated with the line ID. The insulation code can then be determined using the PDDS users manual (attached) section 5.47 to identify the insulation characteristics. Finally, after identifying the insulation characteristics ( removable, encapsulated etc.), the design engineer can apply the appropriate specification (either specification 2361.900-345 for encapsulated insulation versus specification 2361.900-921 for general thermal insulation).
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0143, does not represent a discrepant condition.
The attached PDDS Users Manual and the Line Designation Table are the two documents required to properly identify the l line insulation requirements. After determining the insulation l requirements, one can then properly apply insulation l specifications 2361.900-345 and 2361.900-921.
l Significance Level Criteria do not apply as this is not a discrepant condition.
Previously identified by NU? O Yes ie) No Non Discrepant Condition?# Yes O No Resolution Pending?O yes @ No ResolutionUnresolved70 vos @ No Review initiator: Feingold, D. J.
VT Lead: Nert, Anthony A Pdnted 4/30/98 3-47:52 PM Page 2 of 3
Northert Utilities ICAVP DR No. DR-MP3-0143 Millstone Unit 3 Discrepancy Report VT Mgr: schopfer, Don K g g g _
mc chmn: singh, Anand K Date: 4/27/98 sLComments: - Comment on Northeast Utilities'Initia! Response Specification 2361.900-921, " General Thermal Insulation",
identifies the specification scope on page 13 as being applicable ,
to thermal insulation inside and outside the containment. l Specification 2361.900-345, " Removable Thermal Insulation",
identifies the specification scope on page 1-2 as being applicable to removable thermal insulation, required for piping and equipment operating at temperature in excess of 150 degrees Fahrenheit. Sections 2 and 3 of specification 2361.900-345 identify explicitly the piping and components to be insulated according to the specification. In contrast, specification 2361.900-921 identifies type of piping and components, inside and outside containment, to be insulated in accordance with the specification.
No documents are identifed, in the response to this Discrepancy Report, that provides assurance that piping and components inside containment are insulated using specification 2361.900-345 instead of specification 2361.900-921.
- Comment on Northeast Utilities' Second Response Sargent & Lundy finds Northeast Utilities'second response acceptable because an individual familiar with both design specifications 2361.900-921 and 2361.900-345 would generally select 1361.900-345 for design of removable insulation over 2361.900-921.
However, page 1-13 of specification 2361.900-921, Revision 2, contains a definition for removable insulation. This implies that specification 2361.900-921could be used for installation of remowble insulation in accordance with the PDDS Users' Manual, Section 5.47. The Users' Manual does not specify removable insulation as encapsulated. If this manual did define removable insulation as being encapsulated, then the obvious choice of specifcations would be 2361.900-345.
Consequently, Sargent & Lundy recommends that page 1-13 in specifcation 2361.900-921, defining removable insulation, be modified to reference specification 2361.900-345 as the appropriate specification to use for the specification of removable Insulation.
Printed 4/3098 3 47.55 PM Page 3 of 3
Northert Utilities ICAVP DR N2. DR-MP3-0179 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Elemord: system Design p
Discipline: Piping Des'gn Ow Discrepancy Type: Calculation fel No System / Process: sWP NRC Significance level: 4 Date faxed to NU:
Date Published: 9/19/97 Discrepancy: Vent / drain calculations do not reflect the latest header movements from piping analysis
Description:
In the process of reviewing the following calculations, (1) Calculation NO.12179-NP(F)-SWP-97-V224 Rev.1,10/4/85 (2) Calculation NO.12179-NP(F)-SWP-97-V225 Rev.1,10/3/85 (3) Calculation NO.12179-NP(F)-SWP-95-V222 Rev.1,10/2/85 (4) Calculation NO.12179-NP(F)-SWP-95-V223 Rev.1,10/2/85 (5) Calculation NO.12179-NP(B)-X1902 Rev. 5,6/29/95 we noted the following discrepancy :
Background:
Vent / drain calculations (1- 4) utilize header displacements and accelerations from revision 2 of the large bore piping analysis calculation (5) .
The current revision of the large bore piping calculation is revision 5. The piping has been re-analyzed and consequently, the header movements have been revised.
The large bore calculation does not address the effect of the revised piping header movements on vent / drain and root valve calculations (1- 4) .
Discrepancy:
Vent / drain and root valve piping support requirement calculations (1-4) have not been updated to incorporate the latest header displacements and accelerations Note:
These comments are based on a review of a sample of vent / drain support requirement calculations for the service water system. The same commerits may also be applicable to the other vent / drain calculations .
Review Valid invalid Needed Date initiator: Patel, Ramesh D 0 0 0 S/11/S7 VT Lead: Neri, Anthony A g Q O 9/11/97 VT Mgt: schopfer, Don K O O O 9/12/97 1RC Chmn: singh, Anand K B O O S'13/87 Date:
INVALID:
Pnnted 4/30/98 3 49-06 PM Page 1 of 3
Northert Utilitie3 ICAVP DR No. DR-MP3-0179 Millstone Unit 3 Discrepancy Report oste: 4/29/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report DR-MP3-0179 has identified a condition not previously discovered by NU which requires correction. Condition Report ( CR ) M3-97-3865 ( See Attached ) was written to provide the necessary corrective actions to resolve this issue. The corrective action outlined in Condition Report M3-97-3865 necessary to correct this issue is to update calculations 12179-NP(F)-SWP-97-V222,12179-NP(F)-
SWP-97-V223,12179-NP(F)-SWP-97-V224,12179-NP(F)-SWP-97-V225, and 12179-NP(P)-X1902 to include the latest header displacement / accelerations.
This corrective action has been completed.
i Note: DR-MP3-0179 states that this discrepant condition may also be applicable to other vent / drain calculations. The Generic Implications section of CR M3-97-3865 acknowledges this potential and addresses the issue as follows: This condition could exist on other Vent & Drain calculations when their associated large bore header calculations were revised.
Similarly, ( as in the case of the calculations referenced in this discrepancy report ) adequate margins exist to accommodate the potential for revised header movements. Therefore, this condition will be corrected if additional deficiencies are identified during further reviews.
Conclusion:
NU has concluded that Discrepancy Repoli DR-MP3-0179 has identified a condition not previously discovered by NU which requires correction. The corrective action necessary to resolve the issues detailed in DR-MP3-0179 will be implemented and tracked under the auspices of condition report M3-97-3865 ( Se Attached ). The corrective action outlined in Condition Repori M3-97-3865 necessary to correct this issue is to update calculations 12179-NP(F)-SWP-97-V222,12179-NP(F)-SWP V223,12179-NP(F) SWP-97-V224,12179-NP(F)-SWP-97-V225 and 12179-NP(P)-X1902 to include the latest header displacement / accelerations.
This corrective action has been completed.
Note: DR-MP3-0179 states that this discrepant condition may also be applicable to other vent / drain calculations. The Generic implications section of CR M3-97-3865 acknowledges this potential and addresses the issue as follows: This condition could exist on other Vent & Drain calculations when their associated large bore header calculations were revised.
Similarly, ( as in the case of the calculations referenced in this discrepancy report ) adequate margins exist to accommodate the potential for revised header movements. Therefore, this condition will be corrected if additional deficiencies are identified during further reviews.
Previously ident6 fled by NU7 O Yes i#> No Non Discrepant Condition?O Yes (#) No Resolution Pending70 ve. @ No Resoiution unre.oived70 ve. @ No Review Printed 4/3098 3 49 to PM Page 2 of 3
N::rthea:t Utilitie3 ICAVP DR N . DR-MP3-0179 Millstone Unit 3 Discrepancy Report InMietor: Patel, Ramesh.D VT Leed: Nerl, Anthony A VT Mgr: Schopfer, Don K 1RC Chmn: Singh, Anand K oste: 4/29/98 sL comments: The Vent / Drain and root valve piping support requirement calculations (1-4) have been revised. In these cases adequate margins exist to accomodate the revised header movements.
This generic condition could exist on other Vent & Drain calculations. Per CR M3-97-3865, this condition will be corrected if additional deficiencies are identified during further reviews.
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l Printed 4M 3 49:13 PM Page 3 of 3
N:rthea t Utilities ICAVP DR Nr. DR-MP3-0297 Miiistone Unit 3 Discrepancy Report i i
Review Group: system DR RESOLUTION ACCEPTED ReMW: S#em W PotentialOperability issue Discipline: Mechenk:al Design Discrepancy Type: Calculation Om System 9tocess: OsS @ No
~
NRC Significance level: 4 Date faxed to NU:
Date Published: 11/13/97 Discrepancy: Design Pressure in Calculation P(R)-1171 Ducription: A calculation is required to determine the basis of the QSS design pressures provided in the QSS line list. No QSS design pressure calcualtion was located in the NU calculation data base.
Calculation P(R)-1171, Rev.1 determines the Q5S operating pressures and temperatures. Calculation SDP-QSS-01358M3, Rev. 6 provides input for the QSS piping stress analysis. Neither of these calculations provide guidance on what design pressures should be identified in the QSS line list. ;
The calculations which provides the basis for the design I J
pressures identified in the QSS line list can not be located. I Review Valid invalid Needed Date initiator: Wakeland, J. F.
O O O 1o'3 /S7 '
VT Lead: Neri, Anthony A B O O 4'S7 VT Mgr: Schopfer. Don K O O O 5 /7/S7 IRC Chmn: singh, Anand K O ' '7/97 O O Date:
INVALID: 1 Date: 4/28/g8 RESOLUTION: -
FIRST RESPONSE:
DISPOSITION:
NU has concluded that DR-MP3-0297does not represent a discrepant condition. S&L DR-MP3-0297 identifies that Calculations P(R)-1171 and SDP-QSS-01385M3 determine operating pressures only for the QSS system and that no calculation exists which provides the bases for the design pressures identified in the OSS line list. This is an accurate description, however, this condition is not a discrepancy.
There is no requirement for a calculation to establish the design pressures listed in the Line Designation Table. Design pressures and temperatures were assigned during initial design of the plant based on experience and documented on FSK-27-128. If the assigned design conditions were found to be nonconservative when operating pressures and temperatures were determined for the Stress Data Package (SDP), the assigned design conditions were adjusted accordingly.
Printed 4/30/96 3.50:04 PM Page 1 of 5
Northert Utilities ICAVP DR N3. DR-MP3-0297 Millstone unit 3 Discrepancy Report Significance level criteria does not apply as this is not a discrepant condition.
CONCLUSION:
NU has concluded that Discrepancy Report DR-MP3-0297 does not represent a discrepant condition. There is no requirement for a calculation to establish the design pressures listed in the Line Designation Table. Design pressures and temperatures were assigned during initial design of the plant based on experience and documented on FSK-27-128. If the assigned design conditions were found to be nonconservative when operating pressures and temperatures were determined for the Stress Data Package (SDP), the assigned design conditions were adjusted accordingly. Significance level criteria does not apply as this is I not a discrepant condition.
l I
l SECOND RESPONSE:
DISPOSITION:
NU has concluded that DR-MP3-0297 has identified a condition not previously identified by NU which requires correction.
Condition report (CR) M3-98-1876 was written to provide the necessary actions to resolve DR-MP3-0297. Pursuant to teleconference with S&L for clairification of the issue, the following approach was developed to disposition DR-MP3-0297:
- 1. Review calculation P(R)-1171 to verify all appropriate upset l conditions are addressed. In addition, recalculate the pressure in the RWST test line based on pressure drop through the orifice and line losses rather than pump discharge pressure. Prepare a CCN to calculation P(R)-1171 to address the valve misposition errors and any other changes required.
- 2. Revise the Stress Data Package and revise the pipe stress analysis as required.
A review indicates that consideration of this system line up will not require a change to the design conditions. As such, the original QSS start up hydrotests will remain valid. This discrepant condition does not impact the MP3 LB/DB. NU considers DR-MP3-0297 to be a level 4 discrepancy. These corrective actions will be completed after MP3 startup.
CONCLUSION:
NU has concluded that Discrepancy Report DR-MP3-0297 has identified a condition not previously identified by NU which requires correction. Condition report (CR) M3-98-1876 was written to provide the necessary actions to resolve DR-MP3-PrWed N30/96 3.50:06 PM Page 2 of 5
1 l
N:sthe:st Utilitie3 ICAVP DR N2. DR-MP3-0297 Millstone Unit 3 Discrepancy Report 0297. Pursuant to teleconference with S&L for clairification of the issue, the following approach was developed to disposition DR-MP3-0297:
- 1. Review calculation P(R)-1171 to verify all appropriate upset conditions are addressed, in addition, recalculate the pressure in the RWST test line based on pressure drop through the orifice and line losses rather than pump discharge pressure. Prepare a CCN to calculation P(R)-1171 to address the valve misposition errors and any other changes required.
- 2. Revise the Stress Data Package and revise the pipe stress analysis as required.
t A review of P(R)-1171 indicates that consideration of this system line up will not require a change to the design conditions. As such, the original QSS start up hydrotests will remain valid. This discrepant condition does not impact the MP3 LB/DB. NU considers DR-MP3-0297 to be a level 4 discrepancy. These !
corrective actions will be completed after MP3 startup.
Previously identified by NU? U Yes @ No Non Discrepent condition?O Yes (#1 No Resolution Pending?O ve. @ No Resolution Unresolved?O ve. @ No j Review {
Acceptable Not Acceptable Needed Date l Initletor: Wakeland. J. F.
4g VT Lead: Neri, Anthony A g
VT Mgr: schopfer, Don K IRC Chmn: Singh, Anand K O O 'm O O O Date: 4/28/98 SL Comments:
FIRST RESPONSE:
Sargent & Lundy does not agree that piping design pressure requires no analytical basis.
The piping design pressure is the basis for the code hydrostatic test of the QSS piping pressure boundary. In NU's response,it was stated that if the design pressures assigned by FSK-27-12B were found to be non-conservative when operating pressures were determined for the stress data package (in P(R)-1187), that the design pressures on the line list were adjusted accordingly.
This raises the question of whether design pressures on the line list may have been changed after the code hydro tests. NU j needs to investigate the possibility that non-conservative piping !
design pressures could have been used as the basis for code ,
hydro tests. NU should report the results of this investigation in l the re-submittal of their response to this DR.
Because of the issue of potential non-conservative design pressures being used for the QSS piping hydro tests, Sargent &
Lundy cannot be certain that DR-MP3-0297 is a Level 4 issue.
Accordingly, it has been upgraded to a NRC Significance Level 3 issue.
Printed 4/30/98 3.50:11 PM Page 3 of 5
N:rthert Utilities ICAVP DR N2. DR-MP3-0297 Millstone Unit 3 Discrepancy Report SECOND RESPONSE:
As a result of a telephone conference with NU on 4-8-98, Sargent
& Lundy concurs that the terms " design pressure" and " maximum operating pressure" are interchangeable. The correct way of identifying the issue raised in DR-MP3-0297 is that Calculation P(R)-1171 does not include one of the possible design basis operating modes: Operation of a QSS pump at its shutoff head due to closure of one of the 3QSS*MOV34A/B valves or the incorrect installation of the specticle flange in the spray riser in the closed position.
Sargent & Lundy also agrees, based on the 4-8-98 telephone conference, that any adjustments that may have been made to the original system design pressures were completed prior to the initial QSS system hydrotests. Thus the code hydrotests are consistent with the piping design pressures identified in the line list. I The increase in maximum operating pressure due to QSS pump shutoff head is not a major contributor to QSS piping system stress levels. Discussions with the ICAVP piping review team members confirm that changes to the SDP will not affect the conclusions of the QSS piping stress analyses. Sargent & Luncy concludes that the maximum operating pressure due to QSS pump shutoff head is less than the pressures currently identifieo in the line list, so the code hydrotests and wall thinkness calculations use valid values for design pressure. According to the ICAVP reviewers evaluation, the maximum shutoff head in the lowest segment of the QSS process piping will produce a )
maximum operating pressure of 169 psig. This is less than the J design pressure of 175 psig identified in the line list. Therefore, Sargent & Lundy agrees that the discrepancy of omitting the maximum operating pressure case for the system is a level 4 i discrepancy and that revision of P(R)-1171, SDP-QSS-01358M3 and any affected QSS piping stress analyses may be deferred until after Unit 3 restart.
Sargent & Lundy concurs that the issues raised in DR-MP3-0297 will be addressed by CR M3-98-1876.
The ICAVP reviewers evaluation of maximum OSS operating pressure is provided below:
The RWST is 59'-0" tall with its base at 24'-6" (EM-111M, Rev. 9),
so the maximum RWST level is Elevation 83'-6" (This exceeds the high-high level alarm setpoint identified in 3-ENG-167, Rev.
0). The low point in the process lines on the discharge side of the QSS pumps, which could be subject to pump shutoff head, is the i bottom of lines 3-QSS-008-31 and 33, at El. 23'-2" (23'-6"-
1/2x7.981", per EP-79H, Rev 9). The design QSS pump shutoff head is approximately 329' (for a 17" impeller per 2214.602-040-Printed 4'3098 3 50:13 PM Page 4 of 5
Northemt Utilitie3 ICAVP DR N3. DR-MP3-0297 Millstone Unit 3 Discrepancy Report 012, Rev. A). The maximum pressure in a process line on the discharge side of the QSS pumps is (83'-6"- 23'-2" + 329')(62.426 lb/ft3 /144 in2/ft2), or 169 psig. According to the line list, the design pressure for process lines on the discharge side of the !
QSS pumps is 175 psig.
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i Printed 4/3G98 3.50:14 PM Page 5 of 5
N:rthent Utilitie3 ICAVP DR N3. DR-MP3-0315 uliistone unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potentia rability issue Discrepancy Type: Component Data SystervVProcess: HVX Ow NRC Significance level: 4 Date faxed to NU:
Date Published: 10/10/97 Discrepancy: SLCRS HEPA Filter Airflow Rating and Pressure Drop
Description:
During review of the component data for the Supplementary Leak Collection and Release System (SLCRS) filter units, 3HVR*FLT3A/38, a discrepancy regarding the design airflow and clean pressure drop for the HEPA filters was identified.
Specification 2170.430-065 specifies an airflow of 8,500 cfm for i the SLCRS filter unit.
Vendor drawing 2170.430-065-022 shows an airflow of 8,500 cfm for the SLCRS filter unit and that there are 6 HEPA filters in the l unit. I FSAR Section 6.2.3.3 and Table 6.2-63 states that the SLCRS filter unit airflow is 8,500 cfm FSAR Table 6.5-1 states that the SLCRS filter unit airflow is 9,500 cfm and that there are 6 HEPA filters in the unit.
Piping & Instrumentation Diagram EM-148E shows a 9,500 cfm airflow for the SLCRS filter units FSAR Table 1.8-1, Regulatory Guide 1.52, paragraph C.3.d clarification states that the HEPA filters will be subjected to velocities recommended by the HEPA filter manufacturer which exceeds ANSI N509-1976 Section 4.3.1 requirements. l Specification 2170.430-065 identifies a 1500 cfm rated airflow for the HEPA filter which corresponds to a 9,000 cfm maximum airflow for the unit. i FSAR Table 6.2-63 states that the clean HEPA filter pressure drop is 1.0 inches of water gauge (iwg). Specification 2170.430-065 and vendor drawing 2170.430-065-022 state that the clean pressure drop is 1.15 iwg. At the 9,500 cfm airflow shown on the P&lD the clean pressure drop will be higher due to increase in airflow above the rating conditions for the filter.
Review Valid invalid Needed Date initiator: stout, M. D.
O O O 9/24/97 VT Lead: Neri, Anthony A O O O 9/2s/97 VT Mgr: schopfer, Don K O O O o/1/97 IRC Chmn: singh, Anand K O O O 10/3'87 Date:
INVALID:
Printed 4/30/98 3.51:37 PM Page 1 of 3
N:rthert Utilitie3 ICAVP DR Ns. DR-MP3-0315 Millstone unit 3 Discrepancy Report Date: 4/24/98 REsOLtmON: First Response:
NU has concluded that Discrepancy Report, DR-MP3-0315, has identified a condition previously discovered by NU which requires correction. This discrepancy was previously documented in OIR 159 and CR M3 97 2371 (approved corrective action plan attached). FSARCR 97-MP3-468 was initiated 7/30/97 to begin corrective actions. Not all corrective actions have been completed at this time but are required to be complete prior to restart. Corrective actions will be processed and tracked by AR 97018713 and will ensure that the FSAR is reviewed against the Equipment Specification, Operator Instruction Manual (OlM) (2170.430-065) and calculations and revised as necessary. The AR has been modified to ensure that the items related to this DR are addressed. There is reasonable assurance that the engineering evaluation of the required changes will not impact plant operation. NU concurs with the significance level of this DR.
Second Response:
NU has concluded that Discrepancy Report DR-MP3-0315 has identified a condition not previously discovered by NU for which corrective action has been taken.
NU wrote CR-M3-97-2371 to address issues conceming the flow rates through the HEPA filters, but the corrective action did not specifically address Table 1.8-1. AR 97018713-02 was added to track completion of corrective action. This action assignment will correct the FSAR Table 1.8-1 to explain the actual vs.
nominal HEPA filter air flow rates.This revision will not change design basis or licensing basis. NU, therefore, considers this issue Significance Level 4.
Attachments:
CR-M3-97-2371 AR 97018713-02 Third Response (M3-IRF-0224)
NU Engineering Evaluation M3-EV 970303, SLCRS High Efficiency Particuate Air (HEPA) Filters for MP3 Filtration Unit 3HVR*FLT3A/B , (copy attached), provides the documentation to justify higher than rated HEPA air flow in the SLCRS filter units.
This issue does not change or impact design / licensing basis. As stated in M3-IRF-01953, NU considers this issue to be Significance Level 4. l l
Attachment:
Engineering Evaluation M3-EV-970303, Rev. O SLCRS High Efficiency Particulate Air (HEPA) Filters for MP3 Filtration Unit 3HVR*FLT3A/B Previously identifled by NU7 O Yes (9) No Non Discrepent condition?O Yes f9) No l
Printed 4f30/98 3.51:41 PM Page 2 of 3 '
}
l Northerct Utilitie3 ICAVP DR N1 DR-MP3-0315 Millstone Unit 3 Discrepancy Report Resolution Pendmg?O Yes it) No Resolution Unresolved?( ) Yes (R) No Review 1 initiator: stout, M. D.
- VT Lead: Neri, Ardhony A O **
VT Mgr: Schopfer, Don K O ** l IRC Chmn: singh, Anand K Date: 4/24/98 SL Comments: Comment on First Response:
Disagree with NU's response that this is a condition previously identified by NU. AR 96009041-01 Closure request (attached to the response) states that the capacity of the filter unit is 10,000 ,
cfm. The 10,000 cfm capacity applies to the charcoal adsorber section in the filter unit. The maximum system airflow that the {j HEPA filters are rated for is 9,000 cfm (6 filters at 1,500 cfm I each). )
{
NU's response did not address the FSAR Table 1.8-1 discrepancy l identified in the DR regarding exceeding the HEPA filter manufacturer's maximum recommended velocity.
Comment on Second Response:
Resolution pending completion of correction action for CR M3 2371 regarding vendor qualified airflow rating for HEPA filter.
NU is requested to provide vendor documentation accepting the higher than rated filter airflow.
Comment on Third Response Engineering Evaluation M3-EB-970303, Revision 0 attached to l NU's response provides justification for higher than rated HEPA l filter airflow. The FSAR Table 1.8-1 revision regarding actual-vs- nominal airflow noted in the corrective action plan for CR M3-97-2371 is considered to be a 1.evel 4 discrepancy. l l
l l
Printed 4/3o98 3 51:43 PM Page 3 of 3
i N:rthe:ct Utilities ICAVP DR N2. DR-MP3-0369 Millstone Unit 3 Discrepancy Report Review Group: systern DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Electrical Design Discrepancy Type: Component Date Om l g l System / Process: Rss ~
NRC Significance level: 4 Date faxed to NU:
Date Published: 11/2/97 Discrepancy: Design Document Discepncies Resulting from RSS Valve Operator Replacements
Description:
Motor operated valves 3RSS*MOV20A, 3RSS*MOV208, 3RSS*MOV20C, and 3RSS*MOV20D were changed from the horsepower of 0.125 showa in the original purchase Specification 2362.200-164 Add.1 to 0.33 horsepower. Not all of the design documents reflect the latest changes.
The AC Motor Evaluation Checklist, Limitorque EEQ Walkdown Checklist, motor overload test record, and molded case circuit '
breaker test record sheets (pages 9 through 24 in Attacnment 3) of Calculation 89-094-120E3 (Rev. O, CCN 4) have not been revised to reflect the changes in horsepower, motor torque, full load curTent, and locked rotor current to valves 3RSS*MOV20A,
{
3RSS*MOV208,3RSS*MOV20C, and 3RSS*MOV20D, even 1 though these valves were replaced in 1985. The latest change notice (CCN #4) still reflects these pages as valid (i.e., they are not noted as being void nor is there a sta!ement that they will be replaced in the future). Both PDDS and PMMS refer to the replacement valves as being provided by Specification 2362.200-164 Add.1 (same as the originally purchased valves), but this specification still references the horsepower, full load current, locked rotor current, and torque of the originally purchased {
valves even though the vendor drawings reflect the horsepower i of the replacement valves (0.33 HP). PDDS has not been revised to reflect the change in the valves' horsepower, full load current, and locked rotor current. The vendor drawiags reference the old torque value (2 ft-Ibs) and different full load and locked rotor currents than the calculation or PMMG.
Calculation NL-038 (Rev. 2, CCN 6) references the old motor (0.13 horsepower and 3.15 locked rotor amperes). These documents should be revised to reflect the latest motor data.
Review Valid invalid Needed (late initiator: Kandall. D. J. O O O io/ ca7 VT Lead: Neri, Anthony A O O O 1o/27/97 VT Mgr: schopfer, Don K O O O tor 2c/97 lRC Chmn: singh, Anand K O O O $o/30S7 Date:
INVAUD: 1 Date: 4/21/98 RESOLUTION: Disposition:
)
NU has concluded that Discrepancy Report, DR-MP3-0369, has identified a condition not previously discovered by NU which j Printed 4/30/98 3 52:23 PM Page 1 of 3 l l
Northert Utilities ICAVP DR N3. DR-MP3-0369 Miiistone unit 3 Discrepancy Report 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 reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. Bin CR M3-98-0163 corrective actions will correct the calculations, drawings, PDDS, PMMS and specification, post startup.
The issues identified by the DR are; Calc 89-094-120E3 has been superseded by the MOV Electrical calculation MOV9810-01542E3.The associated pages of calc 89-094-120E3 are contained in the MOV calc and they have been partially corrected. Calculation MOV MOV9810-01542E3 will be revised to update the values as per the DR post startup.
Specification 2362.200-164 will be revised to correct the rating of 3RSS*MOV20A-D to 0.33HP post startup.
The vendor drawings are being updated under the current MOV program as part of DCR M3-97004. The vendor drawings are being revised by the corrective actions of CR M3-98-0965 in response to DR-MP3-0543 which identified the incorrect values for other MOV's.
Calculation NL-038 will be revised to correct the ratings of 3RSS*MOV20A-D to 0.33HP post startup The PDDS and PMMS data bases will be corrected to reflect these changes post startup.
CR M3-98-1697 was closed to CR M3-98-0163. The corrective actions in CR M3-98-0163 will correct these issues post startup.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0369, 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 attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 Pl 20 deferral criteria. Bin CR M3-98-0163 corrective actions will correct the calculations, drawings, PDDS, PMMS and specification, post startup. l Previously identified by Nur U vos @ No Non Discrepent condition?U vee @ No l ResolutionPending70 vos @ No Resoiutionuareeoived70 vos @ No Review initiator: Kendall, D. J.
- N
- VT Lead: Nerl. Anthony A O O em VT Mgr: schopfer, Don K O O em IRC Chmn: singh. Anand K Printed 4'3098 3:52.27 PM Page 2 of 3
Nartheret Utilities ICAVP DR Ns. DR-MP3-0369 Millstone Unit 3 Discrepancy Report SL Comments:
1 1
Printed 4/30/98 3.52:29 PM Page 3 of 3
N:rthert Utilities ICAVP DR N3. DR-MP3 0372 Millstorm Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Potential Operability issue Discipl6ne: Electrical Design Discrepancy Type: Component Data Ow System / Process: RsS g
NRC Significance level: 4 Date faxed to NU:
Date Published: 11/2/97 Discrepancy: Stroke Time Discrepancies for RSS Motor Operated Valves
Description:
Motor operated valves 3RSS*MV8837A,3RSS*MV8837B, 3RSS*MV8838A, and 3RSS*MV88388 have stroke times which are not consistent between Calculation NM-027 Rev. 2 /
purchase Specification 2280.050-676 (Rev.1) and motor operated valve Calculations 89-094-332E3 (Rev. O, CCN 2) / 89-094-112E3 (Rev. O, CCN 2). Calculation NM-027 Rev. 2 and Specification 2280.050-676 have stroke times of 10 seconds but i Calculations 89-094-332E3 and 89-094-112E3 have stroke times I which have been revised in CCN 2 to 12 seconds. Since these calculations consider longer stroke times than Calculation NM-027, their results are conservative.
Calculation NM-027 is the goveming calculation for stroke times i because the thermal overload setting Calculations 89-094-112E3 {
and 89-094 332E3 reference NM-027 as their input source for stroke time. The stroke times for 3RSS*MV8837A, 3RSS*MV88378,3RSS*MV8838A, and 3RSS*MV88388 are shown in Calculations 89-094-112E3 and 89-094-332E3 as 10 seconds in the installed condition and 12 seconds for the proposed valve replacement. Although the 12 second stroke time is shown in Calculations 89-094112E3 and 89-094-332E3 as an input from Calculation NM-027 Rev.1, a review of NM-027 Rev. 2 shows that the stroke time is still 10 seconds. Therefore, Calculations 89-094-112E3 and 89-094-332E3 do not agree with the value of stroke time used in Calculation NM-027 nor do they reference the latest revision (Rev. 2) of Calculation NM-027.
Review Valid invalid Needed Date I initiator: Kendall, D. J. O O O 10/15/S7 VT Leed: Nerl. Anthony A O O O 1o/27/97 VT Mgr: Schopfer, Don K O O O o/2a/97 IRc Chmn: Singh. Anand K O O O 10/3057 Date:
INVALlO:
Date: 4/24/98 RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0372, 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 attachment 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 Pi 20 deferral criteria.
Pdnted N3o&8 3:53:01 PM Page 1 of 3
l Northen t Utilities ICAVP DR No. DR-MP3-0372 M:listone Unit 3 Discrepancy Report Calculation NM-027, Table 1 (listed in item 1) lists the specification stroke time as 10 seconds. The new stroke time (per DCN DM3-00-1176-97) is 30.25 seconds. The stroke time discrepancy listed for calculation NM-027 is still within the allowable specification stroke time of 60 seconds. CR M3 )
2026 was closed to CR M3-98-0138. The corrective actions in i Bin CR M3-98-0138 will correct this issue post startup.
There is no affect on License or Design Basis.
NU has concluded that Discrepancy Report, DR MP3-0372, has identified a condition previously discovered by NU which requires correction.
Item 1:
Specification 2280.050-676: The specification is being changed as part of DCN DM3-00-1176-97," Actuator Modifications for valves 3RSS*MV8837NB and 3RSS*MV8838A/B". The stem and gear replacement changes the calculated stroke time from 10.08 seconds to 30.25 seconds. The changes to the specification are contained within the DCN. DCN DM3-00-1176-97 is part of DCR M3-97004, Generic MOV modifications. DCR M3-97004 was initiated by EWA M3-95338, Generic MOV modifications, in response to GL89-10.
Calculations 89-094-113E3 and 89-094-332E3: These calculations have been superseded by MOV electrical calculation, MOV8910-01542E3 Rev. O. The new calculation lists the stroke time for 3RSS*MV8837A/B and i 3RSS*MV8838A/B as 30.25 seconds. The new MOV electrical calculation was initiated as part of the MOV GL89-10 program.
]
Item 2:
Calculations 89-094-113E3 and 89-094-332E3 have been superseded by calculation MOV8910-01542. The new calculation makes no references to calculation NM-027. The new MOV electrical calculation was initiated as part of the MOV GL89-10 program.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0372, has l identified a condition not previously discovered by NU which I requires correction. This discrepancy meets the criteria specified l'1 NRC letter B16901 and 17010. It has been screened per l attachment 11 of U3 PI-20 criteria and found to have no l operability or reportability concems and meets section 1.3.2.e of l U3 Pl 20 deferral criteria. Calculation NM-027, Table 1 (listed in l ltem 1) lists the specification stroke time as 10 seconds. The stroke time discrepancy listed for calculation NM-027 is still within the allowable specification stroke time of 60 seconds. CR M3-98-2026 has been closed to CR M3-98-0138 which will correct the stroke time discrepancy post startup. There is no ,
PrWed 4/30/98 3 53:06 PM Page 2 of 3 i
1 N:rtheact Utilities ICAVP DR No. DR-MP3-0372 Millstone Unit 3 Discrepancy Report affect on 1.icense or Design Basis.
NU has concluded that Discrepancy Report, DR-MP3-0372, has identified a condition previously discovered by NU which requires correction.
Item 1:
Specification 2280.050-676: The specification is being changed as part of DCN DM3-00-1176-97, " Actuator Modifications for valves 3RSS*MV8837A/B and 3RSS*MV8838A/B". DCN DM3-00-1176-97 is part of DCR M3-97004, Generic MOV modifications. DCR M3-97004 was initiated by EWA M3-95338, Generic MOV modifications, in response to GL89-10.
1 Calculations 89-094-113E3 and 89-094-332E3: These {
calculations have been superseded by MOV electrical calculation, MOV8910-01542E3 Rev. O.
I Item 2: l Calculations 89-094113E3 and 89-094-332E3 have been superseded by calculation MOV8910-01542. The new calculation makes no references to calculation NM-027.
Previously identified by NU? O Yes (S) No Non Discrepent Condition?O Yes (S) No Resolution Pending?O ve. @ No ResolutionUnresolved?O yes @ u.
Review initiator: Feingold, D. J.
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K ,
Date:
sL Comments:
i l
Printed N30/96 3.53:08 PM Page 3 of 3 I
Northrert Utilities ICAVP DR No. DR-MP3-0373 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: system Design Potential Operability lasue Discipline: Mechanical Design Discrepancy Type: Calculation Qy, systemProcess: Oss @ No NRC Significance level: 4 Date faxed to NU:
Date Published: 11/22/97 Discrepancy: Calculation US(B)-295
Description:
The purpose of US(B)-295, Rev. 5/CCN 1 is to determine the minimum RWST drawdown levels and drawdown times. The calculation provides the design basis for the low-low RWST switchover level setpoint.
Eight discrepancies were identified in Calculation US(B)-295 I (see DR-MP3-0266 for discrepancy in FSAR and in Calculation US(B)-295):
- 1. Level-to-volume-to-drawdown time conversions are all accurate to four significant figures except tank volume at 57.88 ft (which should be 1,177,599 gal rather than 1,180,127 gal) and volume at 58.33 ft (which should be 1,192,937 gal rather than 1,194,444 gal). [p.6A] These quantities are off by no more that 0.2% (about 1.5 inches) and are for non-safety-related parameters, so they do not affect the validity of the calculation.
- 2. The high-high level setpoint is given as 58.33 ft in US(B)-295, but is actually 58.40 ft in 3-ENG-167, Rev. 0 [p. 68] The high level setpoint is given as 57.58 ft in US(B)-295, but is actually 58.15 ft in 3-ENG-167 (p. 6B]. These quantitles are off by no more that 7 inches, and are for non-safety-related parameters which are not used in the computation of any of the drawdown times or drawdown levels, so the validity of the calculation is not I affected.
- 3. According to Calculation 3451B03-1232E3, the instrument l setpoint inaccuracy / drift for the low-low level setpoint is +25.92 l in, -28.28 in. Calculation US(B)-295 uses +/-24 inches (pp. 6a, Bb,6c,6d,7a,10, and p. 5 of CCN 1) for determining drawdown levels and drawdown times. This discrepancy has a significant l effect on calculated drawdown times.
- 4. The telephone memo of 3-26-74 (Attachment 3 to US(B)-295) should not be referenced as the basis for completing the manual switchover of ECCS suction from the RWST to the containment sump within 10 minutes [pp. 6D,6E,6F,6G,8, and 9].
Westinghouse letter NEU 1016 (to SWEC, dated 3-27-74) is the proper reference for the 10 minute manual switchover time (in accordance with Calculation 357P). There is a basis for the 10 minute manual switchover time, so this discrepancy does not affect the validity of the calculation.
- 5. No basis is given for the assumption that operators would secure an RHS pump that failed to automatically trip on low-low RWST level within the first 2 minutes of manual ECCS suction P W N m o8PM
=t Eb' 5F = d 'T f d= " t d b=C =F a
Northext Utilities ICAVP DR N3. DR-MP3-0373 Millstone Unit 3 Discrepancy Report to manually trip an RHS pump needs to be resolved to verify the validity of the RWST switchover level (and the RHS pump trip / low-low level alarm setpoint), the minimum RWST switchover level of 18.90 ft (see DR-MP3-0266), and the minimum RWST drawdown time from the m!nimum level at the termiitation of ECCS suction switchover to the top of the ECCS suction.
- 6. US(B)-295 identifies hydraulic calculations US(B)-245, Rev. O and US(B)-312, Rev. O as the source for maximum QSS, HHSI and LHSI flows [p. 7]. Pump flows in these two hydraulic calculations are presented as a set of supply curves (flow as a function of RWST-to-RPV Dp or RWST-to-containment Dp) for the LOCTIC containment pressurization analysis. There is no discussion of how these supply curves were interpreted to obtain ,
maximum pump flow for RWST drawdown. There is no l constancy on how this was done. HHSI flows for the minimum I and maximum ESF cases are taken for a Dp of -23.4 psi, while I LHS! flows for the minimum and maximum ESF cases are taken for a Dp of -7.92 psi. P(R)-1096, Rev. O should have been used as the source of maximum QSS flow because it finds the supply curves for undegraded pumps, whereas US(B)-312 finds the supply curves for degraded pumps. The issue of what are the l correct flows needs to be resolved in order to verify all of the i minimum RWST drawdown levels, the switchover level (and the RHS pump trip / low-low level alarm setpoint), and all of the minimum RWST drawdown times.
- 7. CCN 1 to US(B)-295 references P(R)-1062 as the basis for changing the maximum QSS flow from 5000 to 5200 gpm for one-pump operation, and from 6000 to 6500 gpm for two-pump operation. P(R)-1062 does not contain this input. The correct reference is P(R)-1096 (See DR-MP3-0440). The issue of what are the correct QSS flows needs to be resolved in order to verify all of the minimum RWST drawdown levels, the switchover level (and the RHS pump trip / low-low level alarm setpoint), and all of !
the minimum RWST drawdown times. j
- 8. CCN 1 to US(B)-295 references US(B)-245, Rev. O as the basis for changing the maximum RHS flow from 4850 to 5100 gpm for one-pump operation, and from 9700 to 10200 gpm for two-pump operation. As discussed above, US(B)-245 does not contain any specific numbers for maximum pump flow. It provides a series of different RHS flows as a function of RWST-to-RPV Dp. US(B)-245 had previously been cited as the basis for the 4850 and 9700 gpm maximum RHS flows. The lack of documented basis RHS pump flow needs to be resolved to verify the validity of the RWST switchoverlevel (and the RHS pump trip!!ow-low level alarm setpoint), the minimum RWST switchover level of 18.90 ft (see DR-MP3-0266), and the minimum RWST drawdown time from the minimum level at the termination of ECCS suction switchover to the top of the ECCS suction.
Calculation US(B)-295 should be revised to resolve discrepancies 3. 5. 6. 7 and 8.
Printed N3Gr98 3:5413 PM Page 2 of 7
Northen t Utilitie3 ICAVP DR No. DR MP3-0373 Millstone Unit .1 Discrepancy Report Review Valid invalid Needed Date initiator: Wakeland, J. F.
O O O 1'1 '87 l
VT Lc.ed: Nwi, Anthony A O O O 5 '197 (
VT Mgr: schopfer, Don K O 5 4/97 O O ptC Chmn: singh, Anand K O O O 1$/18S7 Date:
INVALID:
Date: 4/27/98 RESOLUTION:
FIRST RESPONSE:
DISPOSITION: I NU has concluded that Discrepancy Report, DR-MP3-0373, has identified a condition previously discovered and corrected by NU.
Calculation US(B)-295, revised for ongoing plant modifications, incorporates the required changes for the eight (8) items identified in DR MP3-0373. No further corrective action is required.
Revised RWST drawdown rates and switchover levels were initiated by the corrective action of ACR M3-96-0499, dated 8/1/96. CR M3-97-3298, dated 9/29/97 was issued to correct '
calculation US(B)-295 to include maximum safeguards flow rates as changed by ongoing modification DCR M3-96-077, issued 5/10/97. Calculation US(B)-295, Revision 6 incorporated changes relating to DR ltems 3,6,7 (portion related to flow rates) & 8. These conditions are considered previously discovered.
UIR 1068, dated 10/28/96 and ACR M3-96-1218 identified issues on operator response times credited in safety analyses.
Resolution of associated memo NE-98-SAB-023, addresses DR item 5 as included in US(B)-295, Revision 7. This condition is
@nsidered previously discovered.
DR item 7 identified a reference listing an incorrect calculation number but which utilized the correct values. This typo was subsequently identified and corrected in the Revision 7 review process. DR items 1,2, & 4 and the listing of calculation P(R)-
1062 instead of P(R)-1096 on the reference list do not affect results but have been incorporated within calculation US(B)-295, Revision 7.
Specifically, the eight items are currently addressed in calculation US(B)-295, Revision 7 as follows:
- 1. The ID of the RWST is 59'-0"(Drawing 12179-EP-111G).
Therefore, the cross-sectional area, or volume of water per unit tank height (gal /ft) is 20451.5 gal /ft. All values have been corrected based on this conversion.
Pnnted 4/30/98 3.s4:15 PM Page 3 of 7
1 I
I Northert Utilities ICAVP DR No. DR-MP3 0373 i Millstone Unit 3 Discrepancy Report
- 2. The high level setpoint of 58.15 ft and the high-high level setpoint of 58.40 ft is utilized.
- 3. The uncertainty in the RWST empty level set point is +12.7/-
13.8 in. These values are added to the vortex suppressor height of 28 in. to obtain a QSS pump trip setpoint height of 28 + 12.7 =
40.7 in. (3.39 ft) with a maximum QSS pump trip height of 40.7 +
13.8 = 54.5 in. (4.54 ft). However, the +25.9/-28.3 in, uncertainty referred to in the DR is applied, in the reference, to the low-low level (RHS pump auto-trip) setpoint about a nominal value of 305 in. (25.4 ft).
- 4. The time allotted to fully achieve switchover is increased from 10 to 25 minutes. The basis for 25 minutes is timed test data j taken from 9/19/96 to 10/18/96 in response to UlR 1068 and referenced in memo NE-98-SAB-023,
- 5. The time allotted for securing an RHS pump which fails to trip on the low-low level (RHS pump auto-trip) signal is increased from 2 to 5 minutes. Basis for 5 minutes is timed test data taken from 9/10/96 to 10/18/96 in response to UIR 1068 and ACR M3-96-1218 as referenced in memo NE-98-SAB-023. The most conservative assumptions lead to a minimum RWST level of 11.82 ft when switchover of the ECCS pumps is completed.
- 6. All pumps are assumed to operate continuously at conservatively high flow rates. The assumed flow rates are based on flow rate changes per modification DCR M3-96-077 issued 5/10/97.
- 7. The reference for the QSS pump flow rates is correctly stated as Calculation 12179-P(R)-1096. The relation to pump flow is addressed in item 6 above.
- 8. The reference for the one-pump RHS flow rate is Calculation 12170-US(B)-294-5 and the reference for the two-pump RHS flow rate is Westinghouse Letter No. FSSE/CWBS-1200, 2/20/90. I CONCLUSION:
NU has concluded that Discrepancy Report, DR-MP3-0373, has L identified a condition previously discovered and corrected by NU. Calculation US(B) 295, revised for ongoing plant modifications, incorporates the required changes for the eight (8) items identified in DR-MP3-0373. No further corrective action is required.
SECOND RESPONSE:
PrWed 4/3o98 3 5418 PM Page 4 of 7 l
Northe:st Utilitie3 ICAVP DR No. DR-MP3-0373 Millstone Unit 3 Discrepancy Report DISPOSITION:
NU has concluded that Discrepancy Report, DR-MP3-0373, has identified conditions not previously discovered by NU.
Corrective action has been completed with the issuing of revision 7 of US(B)-295, and CR M3-98-2066 (attached) was written to document the corrective action for those items which were not prediscovered (items 1,2,6,7 and 8). Items 6,7 and 8 should be Significance Level 4 for the following reasons:
ltem # 6 - (level 4) This item is similar to items #7 and #8. The flowrate discrepancies noted for QSS, LHSI and HHSI pumps I are against rev. 5 of the calculation. These discrepancies were updated and carried overinto CCN 1 to revision 5 of this calculation. Therefore, this item is enveloped by item #7 for QSS pump flowrates and item #8 for LHSI / HHSI flowrates and need not be responded to separately. See responses to items #7 and #8.
Item # 7 - (level 4) The value used for QSS pump flowrate in the calculation was correct. The reference for the value was discrepant. Results of the calculation are unaffected.
Additionally, DR MP3-0440 already identified this issue.
Item # 8 - (level 4) Flowrate values for LHSI (i.e. RHS) and HHSI (i.e., CHS and SlH) pumps were validated in revision 7 of calculation US(B)-295 using more useful references, Westinghouse letter FSSE/CWBS-1200 (attached). The discrepancies between the values used can be seen in the following table:
LHSI (RHS) 1 pump: 5100 gpm (Revision 5, CCN 1) .
1 pump: 5500 gpm (Revision 7) i (7.8% increase}
2 pumps: 10,200 gpm (Revision 5, CCN 1) 2 pumps: 10,027 gpm (Revision 7)
(1.7% decrease}
HHS1 (CHS + SlH) 1 pump: (560 + 670) = 1230 gpm (Revision 5 CCN 1) 1 pump: (560 + 675) = 1235 gpm (Revision 7)
(0.4% increase}
2 pumps: (820 + 890) = 1710 gpm (Revision 5, CCN 1) 2 pumps: (876.1 + 830.7) = 1707 gpm (Revision 7)
(0.17% decrease}
Net Change: 1.87% decrease in total pump flowrate when both trains are assumed operating, and an 8.2% increase in total pump flowrate when only one train is operating. Since both trains operating still provides the highest total flowrate (i.e., more conservative), the total flowrate reduces from 18,410 Opm to 18,234 gpm:
Pmted 4/30/98 3 s419 PM Page 5 of 7
Northert Utilitie3 ICAVP DR N2. DR-MP3-0373 Millstone unit 3 Discrepancy Report Total flowrate = (2) CHS + (2) SlH + (2) QSS + (2) RHS Total flowrate = 876.1 + 830.7 + 6500 + 10027 = 18,234
Conclusion:
The results of calculation US(B)-295 rev. 5 CCN 1 would not have been affected by the flowrate deficiencies noted in this DR. The maximum total pump flowrate would have decreased from 18,410 gpm to 18,234 gpm thereby increasing the minimum time to reach the switchover setpoint. Therefore, the error in pump flowrate would not have degraded switchover times / levels. NU believes that items 6,7 and 8 in Discrepancy Report, DR-MP3-0373, should be considered as Significance Level 4 issues because the errors, now corrected, were in the conservative direction. As such, they did not ha te any adverse l affect on the design basis of the RSS system.
CONCLUSIONS:
NU has concluded that Discrepancy Report, DR-MP3-0373, has identified conditions not previously discovered by NU.
Corrective action has been completed with the issuing of revision 7 of US(B)-295, and CR M3-98-2066 (attached) was written to document the corrective action for those items which were not prediscovered (items i,2,6,7 and 8). NU believes that items 6, 7 and 8 in Discrepancy Report, DR-MP3-0373, should be considered as Significance Level 4 issues because the errors, now corrected, were in the conservative direction. As such, they did not have any adverse affect on the design basis of the RSS system. NU concludes that Discrepancy Report, DR-MP3-0373, is a Significance Level 4.
Previously identified by NU7 O Yes @) No Non Diecrepant Condition?U vee (9) No Resolution Pendeng70 vee @ No Renoiution unrea*.d70 vee @ No Review initiator: Wakeland, J. F.
VT Lead: Nert. Anthony A VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K Dm: 4/27/98 SL comments:
FIRST RESPONSE:
Sargent & Lundy doas not agree that all of the issues identified in DR-MP3-0373 were previously discovered by NU. ACR M3 0499, initiated 11-6-93, identified DR-MP3-0373 item 3. ACR M3-96-1218, initiated 12-3 96, identified DR-MP3-0583 items 4 and
- 5. DR-MP3-0373 itemn 6,7 and 8 were identified by NU in CR-97-3298, iriitiated 9-29 97, but this is after the 5-27-97 cutoff date for the QSS/RSS ICAVP review. Level 4 items 1 and 2 were not identitid by NU.
Sargent & Lundy's ICAVP review of calculation US(B)-295, Rev.
7 concluded that NU resolved all 8 discrepant conditions Printed 4/30/98 3 s4 20 PM Pege 6 of 7
Northert Utilities ICAVP DR No. DR-MP3-0373 l Millstone Unit 3 Discrepancy Report f identified in DR-MP3-0373.
Sargent & Lundy has determined that items 6, 7 and 8 were level 3 discrepancies, so the NRC Significance Level should remain level 3.
SECOND RESPONSE:
NU's second response has resolved all of the comments S&L made on NU's first response to DR-MP3-0373. Therefore Sargent & Lundy concurs that DR-MP3-0373, items #1,2,6,7, and 8 are level 4 discrepant conditions which require corrective action. Sargent & Lundy also concurs that Rev 7 to US(B)-295 corrected all of these discrepancies.
l l
I Pmted 4/30GB 3 54 22 PM Page 7 of 7 a
Northert Utilitie3 ICAVP DR Na. DR-MP3-0434 uiiistone unit 3 Discrepancy Report
\
(
Review Group: Programmate DR RESOLUTION ACCEPTED Review Element: Corrective Action Process p ,
Discipline: Operation.
Discrepancy Type: Corrective Acton Om System / Process: Oss g 1 NRC Significance level: 3 Date Faxed to NU:
Date Published: 12/7/97 Discrepancy: Conclusions Documented in Technical and Reportability Evaluations for ACR No. 012327 Ducription: Discussion:
The subject ACR was written to document that the TSP baskets were found with a volume at less than the fill line that specifies the minimum Technical Specification volume per surveillance l procedure SP 3606.10. The Reportability Evaluation relies '
entirely on a Technical Evaluation MP3-TS-96-210 and it was determined that the issue is not reportable. The following observations form the basis for this discrepancy report:
The evaluation documents that the baskets were initially filled to the " full line" during RF05 and that there has been " expected settling", although the amount of settling
- expected"is not mentioned. The conclusion is made that "since there are no signs of leakage around the baskets, the total mass is still in place, and the baskets are still capable of perforrning its l function". j
- 1. We disagree (based on the documentation pmvided in the ACR and Technical Evaluation /Reportability Evaluation) that lack of " signs of leakage" is sufficient basis to conclude that the
" total mass is still in place and the baskets are still capable of performing its function". The analysis lacks the necessary confirmation that the initial charge (mass) of TSP was in fact adequate for meeting the functional requirements. This could be done by review of past records (also not mentioned). Had the settling been correctly anticipated, the initial fill would have been greater to prevent encountering this situation where settling has now occurred to the point that the minimum Technical Specification volume (fill line) is not met. This oversight is sufficient to warrant verification that the correct mass was initially charged.
- 2. With regard to the corrective action for ACR 012327 which was to add more TSP, Safety Evaluations MP3-94-135 Rev.1(Mech 1MatlChem.) and ISE/MP3-94-054 Rev.1 which are contained in PDCR MP3-94-135 state in part that a maximum pH of about 11.0 will occur ...and a pH of less than 10.5 would be achieved after about 18 minutes . ISE/MP3-94-054 Rev.1 further concludes that "the transient pH behavior does not adversely affect metals, coatings and elastomers in the Containment and the performance of safety functions is not affected." This statement is based on the conclusions documented in Safety Evaluation MP3-94-135. As noted in Safety Evaluation MP3-94-135, *the important time periods to be munhintad nra thnen dactrihad nhnum when nH ic nutcido nf tha Printed 4f30/98 3.58 A1 PM Page 1 of 9
Northert Utilities ICAVP DR N2. DR-MP3-0434 Millstone Unit 3 Discrepancy Report qualified conditions (i.e. ...pH above 10.5), and when the low pressure injection pH is higher than before."
- a. Eased on NU's conclusion in ACR 012327 documentation that the original required mass was still in place, and subsequent addition of TSP to 1/2 inch above the fill line (from the as-found level which was below the fill line), the new greater mass of TSP should be considerd for its potential impact on the peak pH which would be achieved in a DBA requiring recirculation spray.
Such consideration is prudent to ensure that conclusions reached in the safety evaluations remain valid after addition of TSP.
- b. In addition, while periodic makeup of TSP due to compaction or settling was contemplated in the modification (MP3-94-135),
the safety evaluations for the mod do not indicate if the maximum calculated pH (and resultant conclusion of acceptability) included consideration of the additional mass which would be added periodically to account for settling.
- c. With regard to the maximum pH which was evaluated to be acceptable in the safety evaluations, it is not clear what initial boron concentration was assumed. It is noted that the maximun tech spec boron concentration of 2900 ppm was used to conservatively define the minmum amount of TSP which would raise pH to greater than or equal to 7.1, however use of the maximum allowable tech spec RWST concentration would not be conservative when evaluating the maximum pH for acceptability.
- 3. In conjunction with items 1 and 2 above, NU should re-evaluate the reportability and significance level of this ACR.
Although the condition was discovered in Mode 5 when the TSP baskets function is not required to be operable, all 12 TSP baskets were initially specified as INOP by the Shift Supervisor.
Then a technical evaluation and reportability evaluation took place. The need to perform these evaluations ( aimed at ensuring that safety functions would be met when operability is questioned or questionable and at determining resultant reportability) Justifies an initial higher significance (eg. at least level C) especially if there was reason to suspect (and no evidence is provided to the contrary) that the unanalyzed condition could have existed in an operating mode where the TSP baskets were required to be operable.
Review Valid invalid Needed Date initiator: Navarro, Mark O O O ir20/97 VT Lead: Ryan ThornasJ O O O 11/24/97 VT Mgr: schopfer, Don K O O O 12/i/97 IRc Chmn: singh, Anand K O O O 2ra/97 D*: 11/19/97 lNVA LID:
Date: 4/27/98 RESOLUTION: Disposition Printed 4/30/98 3:58 46 PM PaBe 2 of 9 6
N:rthe:st Utilities ICAVP DR No. DR-MP3-0434 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report DR-MP3-0434 has identified a condition not previously discovered by NU which requires correction. NU has concluded that Discrepancy Report DR MP3-0434 identifies three concems, one that has not been previously discovered by NU which requires correction, and two that do not represent discrepant conditions. NU concurs with the significance level 3 assigned by Sargent & Lundy for the discrepant condition. Each of these concems is discussed in detail below.
NU has concluded that item 2 identified in Discrepancy Report DR-MP3-0434, relative to the lack of consideration regarding the potential impact of adding one and one-half inches of TSP on the i maximum transient pH, is a condition not previously discovered by NU which requires correction. The corrective actions associated with ACR 12327 focused on ensuring compliance with Technical Specification LCO 4.5.5; the minimum required volume of 974 cubic feet of TSP, was satisfied. The corrective actions for ACR 12327 filled the baskets one-half inch above the fillline in anticipation of any future settlement. The corrective actions were accomplished without considering the impact of this additional TSP on the maximum transient pH. CR M3-98-0459 was written on 1-28-98 as a result of DR-MP3-0434 to address this condition and to develop corrective actions. The investigation of CR M3-98-0459 found the impact of the ;
additional mass of TSP on the maximum transient pH was negligible; however, this determination was based on a calculation that included a mathematical error and a nonconservative assumption. CR M3-98-1517 was written on 3-19-98 to reevaluate the impact of the additional TSP on the maximum transient containment sump pH to ensure the conclusions reached in Safety Evaluations MP3-94-135, Revision 1, and ISE/MP3-94-054, Revision 1, remain valid. AR 98005945 02 was generated as part of the approved corrective action plan for CR M3-98-1517 to track the issuance of a revision to Calculation US(B)-350 to document the increase in mass resulting from the addition of TSP to the TSP baskets.
Additionally, this revision will provide a discussion of the affects of the maximum transient pH. This AR will be completed after startup based on the justification, included within NU Memo MP-DE-96-0511, dated 7-16-96, for the acceptability of limited exposures of epoxy coatings to a pH as high as 13.9. No field modifications are required. The investigation of the discrepancy included under item 2 also identified that FSARCR 97-MP3-451 had incorporated a EQ pH range of 4.4 to 11.0 into FSAR Section 3.11B and Appendix 38. The FSARCR utilized Safety Evaluations MP3-94-135, Revision 1, ISE/MP3-94-054, Revision 1, and the Radiological Safety Evaluation / Significant Hazards Consideration For MP3 PTSCR 3-16-94, PTSCR 3-29-94 and PDCR 3-94-135, Revision 1, as the basis for the change. Safety Evaluation MP3-94-135, Revision 1, indicates under
- Malfunctions Evaluated" that the pH will be about 11 at the outset and will remain above 10.5 for 3-8 minutes until mixing occurs. A reference is made to Stone and Webster Letter SRE-MP3-9402 dated 11-15-94. This letter states the maximum Pnnted 4/30/98 3 58 48 PM Page 3 of 9
Northext Utilities ICAVP DR No. DR-MP3 0434 Millstone Unit 3 Discrepancy Report recirculation spray pH was evaluated informally and was not documented in a QA Category I calculation since it was outside of the scope of work. The letter further indicates that calculations found the outer recirculation spray suctions in the i sump could be pumping solution with a pH above 11 for several minutes after the pumps start which is acceptable due to the short term nature of the transient. The letter also states that if they assume 100% of the spray water is drawn from the vicinity of the TSP baskets, which maximizes the initial spray pH as well as the TSP mixing, the initial spray is somewhat greater than 11 ,
and it remains above 10.5 for approximately 5 minutes. This discrepancy was also included in CR M3-98-0459 for further investigation and the development of corrective actions. AR 98002149 04 was generated as part of the approved corrective action plan for CR M3-98-0459 to track a revision to the FSAR to I indicate that the maximum anticipated pH for the initial minutes )
of the transient is approximately 11. FSARCR 98-MP3-39 was j approved on 3/12/98 to complete this corrective action. I I
NU has concluded that item 1 identified in Discrepancy Report DR-MP3-0434, relative to the lack of necessary confirmation that the initial charge of TSP was in fact adequate for meeting the j functional requirements, does not represent a discrepant i condition. NU did confirm, during the investigation of '
ACR 12327 that the TSP baskets had been filled to the fill line.
NU Memo MP3-TS-96-210, dated May 2,1996, states that when the TSP baskets were initially filled during RFOS, they were only filled up to the fill line. This statement was based on the investigator's review of the completed AWO which not only confirmed the initial charge was to the fill line but also showed that the baskets were not filled above the fill line in anticipation of any settlement. This memo was referenced in the Reportability Evaluation for ACR 12327 as the evaluation that determined that the settling of the TSP since the initial fill in RFO5 had not reduced the mass of TSP available. As indicated in the bases for Technical Specification 3/4.5.5, the required amount of TSP to maintain the containment sump pH above 7.0 i is based on mass, however, a required volume is specified, rather than mass, since it is not feasible to weigh the entire amount of TSP in containment. The minimum required volume is based on the manufactured density of TSP. The Technical Specification bases acknowledges that TSP has a tendency to agglomerate from high humidity in the containment building thereby, resulting in an increase in density and a decrease in volume. The bases concludes that estimating the minimum volume of TSP in containment is conservative with respect to achieving a minimum required pH. It should be noted that the location of the fillline, as de19rmined by calculation 3-93-038-0108203, Revision 1, assures a minimum volume of 975 cubic feet is provided when the TSP baskets are filled to the fill line.
NU has concluded that item 3 identified in Discrepancy Report DR-MP3-0434, relative to the significance level assigned to ACR 12327 and whether the reportability evaluation for ACR 12327 reached the proper conclusion, does not represent a discrepant condition. The reportability determination performed for CR M3-Printed 4/30/98 3:58 49 PM Page 4 of 9
Northert Utilities ICAVP DR No. DR-MP3-0434 Millstone Unit 3 Discrepancy Report 98-0459 (attached) reviewed the bases for the original I reportability evaluation performed for ACR 12327 and confirmed the 'non-reportable' conclusion was valid.
Regarding the significance level of ACR 12327, procedures RP 4, Revision 1, and NGP 2.40, Revision 1, were utilized to determine the significance level as they were in affect at the time the ACR was written. RP 4, Revision 1, refers to NGP 2.40 as the Significance Level Model to be used in the ACR process.
Utilizing the criteria included in NGP 2.40, Revision 1, ACR 12327 was correctly assigned Significance Level D. This significance level is supported by the initiator's assessment that there were no visible signs of leakage and that the condition was believed to have resulted from settlement which had been anticipated (
Reference:
Bases for Technical Specification 4.5.5). As there was no loss of TSP mass, the safety function would still have been fulfilled. This determination was later confirmed via the Reportability Evaluation for ACR 12327.
Conclusion NU has concluded that Discrepancy Report DR-MP3-0434 has identified a condition not previously discovered by NU which requires correction. NU has concluded that Discrepancy Report DR-MP3-0434 identifies three concems, one that has not been previously discovered by NU which requires correction, and two that do not represent discrepant conditions. NU concurs with the significance level 3 assigned by Sargent & Lundy for the discrepant condition.
NU has concluded item 2 identified in Discrepancy Report DR-MP3-0434, relative to the lack of consideration regarding the potentialimpact of adding an inch and a half of TSP on the maximum transient pH, is a condition not previously discovered by NU which requires correction. CRs M3-98-0459 and M3 1517 were written to investigate the impact of adding TSP on the maximum transient containment sump pH and to develop corrective action. AR 98005945 02 was generated as part of the approved corrective action plan for CR M3-98-1517 to track the issuance of a revision to Calculation US(B)-350 documenting the increase in mass resulting from the addition of TSP.
Additionally, the revision to this calculation will provide a discussion of the affects of the maximum transient pH. This AR will be completed after startup based on the justificathn, included within NU Memo MP-DE-96-0511, dated 7-16-98, for limited exposures of epoxy coatings to pH's as high as 13.9. No field modifications are required. The investigation of the ,
discrepancy included under item 2 identified that FSARCR 97- l MP3-451 had incorporated a EQ pH range of 4.4 to 11.0 into FSAR Section 3.118 and Appendix 3B, although the referenced safety evaluations indicate the transient pH will be about 11 and the document that supported the referenced safety evaluations indicates that a pH of greater than 11 may be experienced for a short duration. This discrepancy was included in CR M3 0459 for further investigation and the development of corrective actions. AR 98002149 04 was aenerated as part of the approved Printed 4'30@6 3.58.50 PM Page 5 or 9
N:rthert Utilities ICAVP DR N2. DR-MP3 0434 Millstone unit 3 Discrepancy Report .
I corrective action plan for CR M3-98-0459 to track a revision to I the FSAR to indicate that the maximum anticipated pH for the initial minutes of the transient is approximately 11. FSARCR 98-l J
MP3-39 was approved on 3/12/98 to complete this corrective action. NU has concluded items 1 and 3, identified in Discrepancy Report DR-MP3-0434, do not represent discrepant ,
conditions. Regarding item 1. NU confirmed during the I investigation of ACR 12327 that the i TSP baskets had been filled initially to the fill line and documented this in NU Memo MP3-TS-96-210, dated May 2, 1996. Regarding item 3, the reportability determination j performed for CR M3-98-009 j reviewed the bases for the original reportability evaluation performed for ACR 12327 and confirmed the 'non-reportable' conclusion was valid. Additionally, the significance level D assigned to ACR 12327 was reviewed u' y NU and determined to be correct based on the criteria contained in NGP 2.40, Revision 1, which was in affect at the time the ACR was written. This significance level is supported by the initiator's assessment that thers were no visible signs of leakage ar,d that the condition was believed to have resulted from settlement which had been anticipated (
Reference:
Bases for Technical Specification 4.5.5). As there was no loss of TSP mass, the safety function would still have been fulfilled. This determination was later confirmed via the Reportability Evaluation for ACR 12327. ] -
NU's second Disposition l
I NU has concluded that item 2 of the original Discrepancy Report DR-MP3-0434 has ideatified a condition not previously discovered by NU which requires correction. Sargent and Lundy has provided additional information related to the previous disposition for item 2 in the original DR. The new concerns are addressed below:
In regards to Sargent and Lundy's first two concems, NU has sufficient evidence to demonstrate that the results of the planned revision to calculation US(B)-350 will not adversely impact any SSCs important to safety. NU Memo MP-DE 96-0511, dated 7-16-96, provided justification for limited exposures of epoxy I coatings to pH's as high as 13.9, thereby, assuring compliance l with the design basis requirement for material compatibility for those components most likely to be affected by a higher transient pH. This determination served as the basis for deferring the revision to calculation US(B)-350 until after startup.
However, in light of Sargent and Lundy's concems and in lieu of providing additionaljustification to support the performance of the calculation revision after startup, NU agrees to complete the revision prior to startup. A CR Change Form for CR M3-98-1517 has been initiated and approved to change AR 98005945-02 from post startup to Mode 2.
In regards to Sargent and Lundy's third concem, the Design Control Manual (DCM), Revision 6, Change 5, Chapter 5, requires a review of calculation revisions and new calculations to Pnnted 4/30/98 3:58.51 PM Page 6 of 9
Northelt Utilities ICAVP DR No. DR-MP3-0434 Millstone Unit 3 Discrepancy Report i
determine if the results impact the unit LB/DB. Chapter 5 of the '
DCM also requires the initiation of a CR if the results of the review indicate a potential deficiency in the Unit LB/DB.
Additionally, the DCM requires the performance of a 10CFR50.59 screening for new calculations and calculation revisions unless the calculation is done in support of a parent process which will provide the 10CFR50.59 screening. Prior to startup, the results of the 10CFR50.59 screening performed for this calculation revision will be utilized to determine the need for NRC review.
It should be noted that the NRC safety evaluation for License i Amendment 115, attached to NRC Letter to NU, dated 05-26-95, l evaluated the change in containment sump pH control from l several aspects. The NRC review ensured the maximum I transient pH is not detrimental to the EQ components inside containment and that the ultimate containment sump pH is greater than 7.0 to prevent the reevolution of iodine and to provide greater assurance that no stress corrosion cracking will occur. When discussing their review of NU's calculation in Section 2.2 of the SER, the NRC is referring to the NU calculation that verified the ultimate sump pH would be greater than or equal to 7.1. Section 2.2 of the SER states that NU calculated that 974 cubic feet of TSP would ensure the ultimate containment sump pH will be equal to or higher than 7.1 and notes the conservatism provided by assuming a quench spray boric acid concentration of 2000 ppm. This section of the SER states that the NRC reviewed NU's calculations and performed its own independent verification and the results of this evaluation showed that control of the containment sump pH by TSP will prevent reevolution of iodine during operation of the containment sprays in the recirculation mode and will not cause the components in the containment to corrode. The planned revision to calculation US(B)-350 will evaluate the impact of additional TSP mass on the maximum transient pH. As additional TSP mass is conservative with respect to achieving a minimum pH, the revision will not effect the previous results reviewed by the NRC that show the ultimate sump pH will be greater than or equal to 7.1.
NU has concluded that the significance level of the discrepant condition associated with DR-MP3-0434 remains a level 3.
NU's Second
Conclusion:
NU has concluded that item 2 of the original Discrepancy Report DR-MP3-0434 has identified a condition not previously discovered by NU which requires correction. Regarding Sargent and Lundy's first two concems, NU agrees to revise calculation US(B)-350 prior to startup. A CR Change Form for AR 98005945-02 has been initiated and approved to change the scheduled completion to Mode 2.
Regarding Sargent and Lundy's third concem, the revision to calculation US(B)-350 will be reviewed in accordance with Chapter 5 of the DCM to determine if the results impact the unit Pnnted 4/30/98 3.58 52 PM Page 7 of 9
N::rthea:t Utilities ICAVP DR N3. DR-MP3-0434 l Millstone unit 3 Discrepancy Report LB/DB. If the results of this review indicate a potential deficiency l In the Unit LB/DB, a new CR will be initiated as required by the DCM. The revision to calculation US(B)-350 will also receive a 10CFR50.59 screening as required by the DCM. Prior to startup, j the results of the 10CFR50.59 screening will be utilized to '
determine the need for NRC review.
NU has concluded that the significance level of the discrepant condition associated with DR-MP3-0434 remains a level 3.
Previously identified by NU? O Yes (8) No Non Discrepant Condition?O Yes (9) No ResolutionPendingtO va @ No Re.aution unre.aved?O va @ No j Review Acceptable Not Acceptabie Needed Date initiator: Navarro, Mark gg VT Lead: Ryan, Thomas J gg VT Mgr: schopfer, Don K IRc Chmn: singh, Anand K O O **
g g ggjgg Date: 4/27/98 sL Comments: S&L comments to NU's first response:
l Sargent & Lundy concurs with NU's dispositions for items 1 and 3 of this DR. We do not agree with NU's disposition for item 2 as discussed below:
- 1. NU has indicated that the AR which was issued to track j revision of the calculation US(B)-350 will be completed after i startup based on the justification included within NU Memo MP-DE-96-0511 dated 7-16-96. Since the results and impacts of NU's l I
revised calculation are not yet known, the calculation revision {
(including NU's review / acceptance of results) should be completed before startup to ensure no unacceptable impact on SSCs important to safety, nor impact on the changes described in j FSARCR 98-MP3-39.
]
1
- 2. In addition, NU's reportability determination which was j performed for CR M3-98-0459 states under item No. 2
" Evaluations into the maximum transient pH following a large break LOCA are on-going, however, there are presently no calculational results which confirm that the unit would be outside its design basis during or after a DBE. If future calculation (s) determine otherwise, a new condition report and reportability evaluation will be initiated". A similar statement is made with respect to NU's on-gning " engineering evaluations to investigate less severe DBE's to confirm both maximum transient pH and ultimate pH are within design basis". Since NU agrees that the issue needs resolution and a calculation revision is required, we do not agree that this design basis issue can be deferred until after startup.
l
- 3. Moreover, the NRC has documented in their safety evaluation I related to amendment No.115 to MP3 facility operating license NPF-49 (section 2.2) that "the staff reviewed the licensee's calculations and performed its own independent verification."
Accordingly, the results of NU's revised cale may require NRC Printed 4/30/98 3:58:s4 PM Page 8 of 9 ,
N:stheret Utilities ICAVP DR No. DR-MP3-0434 Millstone Unit 3 Discrepancy Report review.
S&L comments to NU's second response:
NU's second response is acceptable.
l l
l l
l Printed #30/98 3 58 56 PM Page 9 of 9
1 Northert Utilitie3 ICAVP DR No. DR-MP3-0629 Millstone unit a Discrepancy Report j Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design g ,
Discipline: Mechanical Design Discrepancy Type: Calculaten Ow I SystemProcess: Rss (Sl No
~
NRC Signincance level: NA Date faxed to NU:
Date Publisind: 12/7/97 )
Discrepancy: Calculation US(B)-316
Description:
The purpose of Calculation US(B)-316, Rev. O is to:
- 1. estimate the quantity of insulation that is removed and shredded as a result of jet impingement from a high energy line break (HELB) j
- 2. determine the resulting pressure drop from said insulation being distributed across the RSS sump intake screens. The additional pressure drop across the sump screens is considered in the Net Positive Suction Head (NPSH) analysis for the RSS pumps.
Two discrepancies were identified in Calculation US(B)-316:
- 1. US(B)-316 assumes the sump screens are fully submerged, even though Calculation US(B)-326, Rev.1 concludes that the screens are only partially submerged during a significant portion of the postulated DBA event. The head loss due to the screen blockage on page 21 of US(B)-316, DH = 68.3 U 1.7911.07, (Reference 2 of US(B)-316, NUREG-0897, Rev.1) uses an insulation thickness, t, and an approach velocity, U, based on a fully-submerged net screen area of 244.2 ft2 (Reference 9, Calculation US(B)-303, Rev. 0). Using the wetted screen area of !
partially submerged screens would result in a larger insulation thickness, t, since the insulation thickness is determined by dividing the volume of shredded insulation by the effective (wetted) screen area. The larger approach velocity and the larger j insulation thickness result in a higher head loss.
- 2. Justification for not using the more conservative (higher) approach velocities listed on page 12 of US(B)-303 (Reference 9 of US(B)-316) is not provided. The higher approach velocities on page 12 of US(B)-303 are due to further area reduction to account for open areas of the screen based on Attachment 2 of US(B)-303.
A revision to Calculation US(B)-316 to evaluate the above discrepancies should be performed.
Review Valid invalid Needed Date initiator: Wakeland. J. F. O O O "/4'87 VT Lead: Nerl. Anthony A B O O 11/18/97 VT Mgr: Schopfer, Don K O O O 12/1/97 1RC Chmn: singh. Anand K O O O $2ra/97 Date:
Printed 4/30/98 3:59.53 PM p.g. 1 of 4
1 1
Northert Utilities ICAVP DR No. DR-MP3 4529 Millstone Unit 3 Discrepancy Report INV AL.RJ; Date: 4/28/98 RESOLUTION:
FIRST RESPONSE: ,
i DISPOSITION:
i NU has concluded that Discrepancy Report, DR-MP3-0529, has I identified a condition previously discovered and corrected by {
NU. Revised containment sump hydraulic analysis was initiated I in part by the corrective action of ACR M3-96-0620, dated 8/21/96. Calculation US(B)-326 hydraulic analysis along with !
calculations US(B)-303 and US(B)-316 referenced in the DR are j superseded by new RSS suction hydraulic calculation US(B)-
)
362, Rev 0 dated 11/9/97. The Passport calculation tracking i system is in the process of being revised to reflect this changed l status. The two items stated in the DR are evaluated in the new l calculation as follows:
Item 1 of DR identifies submergence level of the containment j sump screens and its effect on head loss. Previous calculation l US(B)-316 assumed full submergence of the screens. The level in the sump is now calculated as a function of time as indicated }
in Table 8 of calculation US(B)-302. Actual head loss vs.
containment sump level is thus modeled.
Item 2 required a justification for utilized approach velocities as relating to screen net area. Calculation US(B)-316 did not decrease effective flow area thru screens to account for wire mesh area although previous referenced calculation US(B)-305, l also superseded by calculation US(B)-362, utilized higher I approach velocities. Assumption 19 and associated justification I included in Appendix C of calculation US(B)-362 identifies the l negligible effect on head loss to the RSS pumps from wire mesh screens.
l CONCLUSION-l NU has concluded that Discrepancy Report, DR-MP3-0529, has identified a condition previously discovered and corrected by NU. Calculation US(B)-318 is superseded by calculation US(B)- l 362, Rev 0 dated 11/9/97. The two items identified in the DR are evaluated in the new calculation for Containment Recirculation System (RSS) suction hydraulic analysis, US(B)-
362.
SECOND RESPONSE:
DISPOSITION:
NU still concludes that Discrepancy Report, DR-MP3-0529, has Pnnted 4/30@8 3:59 57 PM Page 2 of 4
Northea:t Utilities ICAVP DR No. DR-MP3 0629 Millstone Unit 3 Discrepancy Report identified conditions previously discovered and corrected by NU.
Calculation US(B)-316 revision 0 was reviewed on 1/29/97 (see l attached Calculation Review Checklist). NU agrees that the two issues raised in DR-MP3-0529 regarding calculation US(B)-316 were not specifically addressed in the review. However, the conclusions of the review indicate that the calculation contained discrepancies associated with ACR M3-97-0620, but a detailed review of the calculational methodology and results was not required because the calculation would become obsolete upon revision to calculation US(B)-326. The review referenced ACR M3-97-0620 as the w ce document recommending Calculation l
US(B)-326 be revise C ster it became US(B)-362 ) to become the RSS pump design oasis NPSH calculation, ultimately superseding or voiding all other RSS pump NPSH calculations.
Therefore, specific corrective actions against calculation US(B)-
316 were not necessary and would not be recognized. No new ACRs and no new corrective action was required as a result of the review, because adequate measures were already being taken.
l Although calculation US(B(-326 was being revised, additional CRs were generated against it to address additional concems that were being uncovered. Item 2 of this DR was addressed on j 12/20/96 by CR M3-96-1441 (attached), which raised the issue of the need to evaluate the sump approach velocity. Item 1 was addressed on 2/4/97 by CR M3-97-0409 (attached), which identified that the water level would be below the screens (vortex ,
suppression grating) and that Calculation US(B)-326 should be l revised using a different screen blocking methodology. None of these condition descriptions exactly match the issues identified in the Discrepancy Report. However, the corrective actions that resulted from these CRs did correct all the issues raised in the Discrepancy Report, and these results were issued in US(B)-362 (previously numbered 326) simultaneously with the release date of the DR. Based on this information, NU concludes that the issues raised in Discrepancy Report, MP3-0529, have been previously identified and corrected by NU.
CONCLUSION:
1 NU still concludes that Discrepancy Report, DR-MP3-0529, has identified conditions previously discovered and wrcected by NU.
Three Corrective Action Reports were written pior to the cut-off date for pre-identification. These did identify the issues in sufficient detail to ensure that when the replacement calculation was completed it had corrected each of the errors identified by Sargent & Lundy. Based on this, NU concludes that the issues identified in Discrepancy Report, DR-MP3-0529, were previously identified by NU.
Previously identined by NU? fel Yes O No Non Discrepent Condition?O Yes (#> No Resolution Pending?O ve. tilNo Resolution unresolved?O ve. (W) No Review Printed 4/30/98 3:59.58 PM Page 3 of 4
N:rtherct Utilities ICAVP DR N . DR-MP3-0529 Millstone Unit 3 Discrepancy Report l 1
Initiator: Wakeland, J. F.
- VT Lead: Nerl, Anthony A O O **
VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K Date: 4/27/96 SL Comments:
FIRST RESPONSE:
Sargent & Lundy does not agree that ACR M3-90-0620 identified the two issues raised in DR-MP3-0529 regarding calculation US(B)-316. While similar technicalissues are identified in ACR M3-96-0620, this ACR addresses only calculations US(B)-326, US(B)-265, P(R)-1115 and P(R)-1131. None of the corrective actions of AR 96028931 identified in the corrective action plan for ACR M3-96-0620 involve US(B)-316. Therefore Sargent & Lundy concludes that DR-MP3-0529 is a condition not previously discovered by NU.
The discrepancies identified in items 1 and 2 of DR-MP3-0529 result in an underestimate of debris loading on the RSS sump screens. Sargent & Lundy needs a more specific basis to conclude that the error in debris loading would not have i significantly degraded RSS NPSHa prior to modificaiton M3- l 97045. Therefore the NRC Significance Level remains level 3. 1 The Sargent & Lund ICVAP review of US(B) 362, Rev. O concluded that the discrepancies identified in DR-MP3-0529 have been resolved in the current RSS sump design.
SECOND RESPONSE:
A CMP review of US(B)-316, Rev. O was completed on 1-27-97 (prior to the ICAVP cutoff date of 5-27-97). The CMP calculation review checklist concluded that the issues raised in ACR-M3 0620 also apply to US(B)-316. Therefore Sargent & Lundy concurs that the issues raised in DR-MP3-0529 are not discrepant conditions because they are previously discovered conditions.
Pnnted 4/30/96 4.00:00 PM Page 4 of 4
i I
Northert Utilities ICAVP DR No. DR-MP3-0636 Millstone Unit 3 Discrepancy Report Review Group: Systern DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: CalculatKm Om g~
Syste.WProcess: Oss NRC Significance level: 4 Date faxed to NU:
Date Published: 11/2497 l Discrepancy: Calculation P(R)-931 l Ducription: Calculation P(R)-931 (Rev. 0) determines the insulation requirements for the RWST and the QSS piping located outside.
The insulation requirements are based on the heat loss in the winter and the heat gain in the summer. The water temperature in the RWST is maintained between 40 'F and 50 'F.
1
- 1. The heat transfer surface for the RWST is underestimated.
The surface of the RWST is modeled as a cylinder with a flat top. However, the top of the RWST is domed resulting in a larger heat transfer surface than is modeled. The convection coefficient used is for a horizontal surface. The larger surface area would result in a larger temperature change. The calculation does not take credit for the thermal conductivity of the metal shell nor does it take credit for the insulating value of .
the air in the dome. The calculation assumes the tank is I completely full up to the 24" vent line. It is unclear if these items would offset the increased surface area of the RW" top.
- 2. The calculated summer heat gain from the RWST Recirculation Pump (Page 9) is overestimated. The heat gain is the difference between the actual and ideal power output (work) of the pump. The work of the pump is converted from horsepower to Blu/hr by multiplying by 2545. Twenty-five Hp is equivalent to 63,600 Btu /hr. The calculation determines the heat gain to be 66,170 Blu/hr. Since the heat increase is for the summer and the larger value was used in the calculation, this is conservative.
- 3. The ideal pump power calculated is 88 Hp. The a::tual power is calculated by dividing ideal power by the pump efficiency.
The ideal pump power used in the equation was 87 Hp. The intemal energy increase is the difference between the actual and the ideal power output and this difference is insignificant.
- 4. The calculation determines the temperature change for various insulation thickness. The calculation for the piping (Page
- 13) determines the thermal resistance due to the pipe as 0.0076. The resistance is 0.0027. This is small compared to the resistance due to the insulation and has an insignificant affect on the results.
- 5. The summary of results indicates that the summer heat gain is 135,000 Blu/hr (Page 3). The calculation determines the summer heat gain to be 150,000 Blu/hr (Page 10).
Review Valid invalid Needed Date taaelmae l arvm! f5 11/11 po7 Printed 4/30@8 4:11:47 PM Page 1 of 3
Northenrt Utilitie3 ICAVP DR N . DR-MP3-0635 Millstone Unit 3 Discrepancy Report initiator: Langel,D. ' '1 87 O O O VT Lead: Nort, Anthony A O O O '1/1 /S7 VT Mgr: schopfer Don K O O O 1/17/97 IRC Chrnn: singh, Anand K O O O iir2arg7 Date:
INVALID:
Date: 4/21/98 RESOLUTION: Disposition:
NU has concluded that items 4 and 5 of Discrepancy Report DR-MP3-0535 have identified conditions not previously identified by NU which require correction.
- 4. The typographical error for the thermal resistance of 0.0027 is insignificant and does not affect the results of the calculation. l The cooling rate of 12*F per hour will change to 12.42*F per hour for 1 inch of insulation and from 6.7'F per hour to 6.71*F per hour for 2 inches of insulation. This error will be corrected per the approved corrective action for CR M3-98-1093.
Corrective action will be completed post startup.
- 5. The summary of 135,000 BTUH on pages 3 and 14 was a carry over from calculation 422P, which was the predecessor oi calculation 931P(R), Calculation 422P is superseded by calculation 931P(R). The 135,000 BTUH is considered an administrative error and should be 150,000 as stated on page
- 10. This error will be corrected per the approved corrective action for CR M3-98-1093. Corrective action will be completed post startup.
NU has concluded that the issues reported in items 1,2, and 3 do not represent a discrepant condition.
- 1. The increase in RWST surface area for the tank head is an additional 200 sq. ft. The result of this is insignificant; a quick mathematical check indicates that heat transfer changes by less than 1%. The shell is assumed to be an ideal conductor (i.e. the temperature of the wateris the temperature of the shell) and is conservative. Not taking into account the insulating value of the j airin the dome is also conservative. l
- 2. The heat gain from the pump, 66,170 BTUH, was calculated j using 26 HP, not 25. The 26 HP was derived from: 113 - 87 = '
26, which was derived from using the conservative values (We =
87.85 was rounded down to 87 and Wa = W/eff = 87.85/0.78 =
112.56 rounded to 113). Since the values used were conservative, corrections to actual values will not significantly .
change the results of the calculation, and will have no effect on I safe operation of the system. l
- 3. The explanation given in item 2, above, applies also to this item.
P Ncte he RWST syCt m h2c nc! & "' 2ny s gn nt 50 PM PW3
Northert Utilities ICAVP DR No. DR-MP3-0635 Millstone Unit 3 Discrepancy Report problems coping with high or low outdoor temperatures during operations. Failure to maintain the temperature of the RWST results in a plant shutdown, per Tech Spec requirement 4.5.4.b. RWST temperature is verified at twenty-four hour intervals.
Conclusion:
NU has concluded that items 4 and 5 of Discrepancy Report DR-MP3-0535 have identified conditions not previously identified by {
NU which require correction. The approved correction plan for CR-MP3-98-1093 will revise calculation P(R)-931 to correct the errors on pages 3 and 13, as identified in DR items 4 and 5.
NU considers the remaining items non-discrepant, since values used were conservative and the suggested changes would have j negligible effects on the results. Corrective action will be i completed post startup. {
Previously identified by NU7 O Yes (8) No Non Discrepent Condition?O Yes fG) No Resolution Pending70 Yo. @)No Reeoiution unre.oived70 Ye. @) No Review l int .sr: Langel, D.
VT Leed: Neri, Anthony A l
VT Mgr: Schopfer, Don K f
IRC Chmn: Singh, Anand K Dete: I SL Comments:
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Printed 4/30/98 4:11:53 PM Page 3 of 3
Northea:t Utilities ICAVP DR No. DR-MP3-0643 Millstone Unit 3 Discrepancy Report Review Group: Configuration DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: Electncal Design Discrepancy Type: Draw 6ng SystemProcess: Rss g~
j t
NRC Significance level: 4 Date faxed to NU:
Date Published: 11/2/97 Discrepancy: Vendor Drawing Data Error
Description:
Vendor drawing 2362.200-164-043. Rev. B erroneously shows the horse power, full load and lock rotor current for the 2 ft-Ib operator to be the same as the 5 ft-ib operator. The 2 ft-Ib l
operators are used on valves 3RSS*MOV23A through D. This drawing also indicates the motor speed to be 1800 rpm; nameplate indicates 1700 rpm.
Review Valid invalid Needed Date initiator: Server, T. L.
O O O So/1S'87 VT Lead: Nort, Anthony A O O )
VT Mgr: Schopfer, Don K O 1o/27/97 O O O o/28/97 IRc Chmn: singh, Anand K O O O 10/3o/S7 i
Date: -
INVAUD:
Date: 4/21/98 l RESOLUTION: Disposition:
(
NU has concluded that the issue reported in Discrepancy Report, j DR-MP3-0543, has identified a condition not previously discovered by NU which requires correction.
The FLA, LRA, HP & RPM characteristics for all the valves on the vendor drawing 25212-29164-043 were reviewed against the following documents /information to identify all potential discrepancies:
- 1) The EEQ walkdown data taken from the motor nameplates,
- 2) One Line Drawings,
- 3) SP-EE-342 (Opal Database), !
- 4) SP-EE-346 (fuse Control Spec.),
- 5) SP-M3-EE 321 (Setpoint Spec.),
- 6) Calculation NL-025,
- 7) Calculation NL-033,
- 8) PDDS Database,
- 9) PMMS Database.
The results showed that some of FLA, LRA, HP ratings need to be updated for 3RSS*MOV23A through D,3RSS*MOV20A through D, and 30SS*MOV34A&B on various documents (i.e.
vendor drawing's 2362.200-164-002, Spec. SP-EE 342, spec SP-EE-346, and the PDDS Database). The RPM for all 20 motors needs to be changed from 1800 to 1700 on vendor drawing's 2362.200-164-002,004, & 043. The required changes are document updates only, there is no field work required by the i results of this review. Condition Report (CR) M3-98-0965 was written to provide the necessary corrective actions to resolve Printed 4/30/964:01:19 PM Page 1 of 2
N:rthert Utilitie3 ICAVP DR No. DR-MP3-0543 Millstone Unit 3 Discrepancy Report these issues. Post startup, the approved Corrective Action Plaa for CR M3-98-0965 (attached) will initiate a comprehensive review of all changes (specifications, calculations, databases and drawings) made as part of the GL89-10 MOV effort and ensure that they are documented correctly.
Conclusion:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0543, has identified a condition not previously discovered by NU which requires correction.
Condition Report (CR) M3-98-0965 was written to provide the necessary correction actions to resolve these issues. Post startup, the approved Corrective Action Plan for CR M3-98-0965 (attached) will initiate a comprehensive review of all changes (specifications, calculations, databases and drawings) made as part of the GL89-10 MOV effort and make sure that they are documented correctly.
Previously klentifled by Nur O ve. ft) No Non Discrepent Condition?O ve. f8) No Re.olution Pending?O ve. @ No R..oiution unre.olv.d70 ve. @ No Review initiator: Warner, l.
VT Lead: Neri, Anthony A O O **
VT Mgr: Schopfer, Don K IRC Chmn: Singh, Anand K Date:
sL Comments:
Pnnted 4/30G8 4-01:23 PM Page 2 of 2
N:rthea:t Utilities ICAVP DR N . DR-MP3-0615 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Potential Operability issue Discipline: Mechanical Design Discrepancy Type: corrective Action g
SysterrVProcess: Rss "
NRC Signincance level: NA Date faxed to NU:
Date Published: 11/2497 D6screpancy: Inconsistency within specification SP-ME-784 with respect to location of elastomeric seat.
Description:
in letter B09878 to the Nuclear Regulatory Commission, dated May 15,1991, Northeast Utilities committed to change the design of containment isolation valves 3RSS*MOV23A,B,C,D to prevent them from failing their local leak rate tests. This is documented in Northeast Utilities' Pl6 commitment record 19690.
The subject valves are butterfly valves. In the original design, an elastomeric seat was installed on the valve body. Letter B09878 documents that the root cause of the valve failure is seat separation from the valve body. Accordingly, the letter recommends that the new valve design locate the elastomeric seat on the valve disc instead of the valve body.
PDCR 93-015 implemented the change by installing new valves with elastomeric seats on the valve body instead of on the disc.
According to PDCR 93-015, the design of the new valves are specified in specification SP-ME-784 Revision 2. On page til of the specification, the valve discs are identified as having rubber on the edges. But on page 17, the disc is said to be machined to ease entry of the disc into the seat. The two statements in specification SP-ME-784 are inconsistent; therefore, the installed configuration cannot be confirmed.
Review Valid invalid Needed Date .
Initiator: Feingold. D. J. G O O 11/11S7 VT Lead: Neri, Anthony A G O O 1/12/97 VT Mgr: Schopfer, Don K G O O 'il 7/87 IRC Chmn: Singh. Anand K Q Q Q 11/20/97 Date:
INVALID:
Date: 4/23/98 RESOLUTION: Initial Northeast Utilities Response -
Disposition:
NU has concluded that DR-MP3-0615 does not represent a discrepant condition. Specification SP-ME-784 is a purchase specification providing a general description of the desired valve ,
design for bid and purchase only. The detailed design of the l valve seat is documented on drawings 2362.200-164-109 and j 2362.200-164-110 (Transmittal 51, dated 07/07/97). As documented on drawing 2362.200-164-109, the valve seat is Pnnted 4/30/98 4 02:17 PM Page 1 of 4
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I Northert Utilitie3 ICAVP DR No. DR-MP3-0615 Millstone Unit 3 Discrepancy Report constructed of hard rubber type E.P.T.. The disc is machined in l such a way that it does not interfere with the interaction of the valve seat and the rubber seating ring. Therefore, there is no contradiction in specification SP-ME-784. The seat configuration as illustrated in the afore mentioned drawings are consistent with the commitment made in B09878.
Significance level criteria does not apply as this is not a discrepant condition.
Conclusion:
NU has concluded that Discrepancy Report DR MP3-0615 does not represent a discrepant condition. As detailed in the disposition, the detailed design of the valve seat is documented on drawings 2362.200-164-109 and 2362.200-164-110 (Transmittal 51, dated 07/07/97). As documented on drawing 2362.200-164-109, the valve seat is constructed of hard rubber type E.P.T. The disc is machined in such a way that it does not interfere with the interaction of the valve seat and the rubber ,
seating ring. Therefore, there is no contradiction in specification l SP-ME-784. The seat configuration as illustrated in the afore ,
mentioned drawings are consistent with the commitment made in 1 I
B09878.
l Significance level criterla does not apply as this is not a .
discrepant condition.
Second Northeast Utilities Response Disposition:
NU has concluded that DR-MP3-0615 does not represent a discrepant condition. Specification SP-ME-784 is a purchase specification providing a general description of the desired valve design for bid and purchase only. The detailed design of the valve seat is documented on drawings 2362.200-164-109 and 2362.200-164-110 (Transmittal 51, dated 07/07/97). As documented on drawing 2362.200-164-109, the valve seat is constructed of hard rubber type E.P.T.. The disc is machined in such a way that it does not interfere with the interaction of the valve seat and the rubber seating ring. Therefore, there is no contradiction in specification SP-ME-784. The seat configuration as illustrated in the afore mentioned drawings are consistent with the commitment made in B09878.
Pursuant to teleconference with S&L on 4/17/98, the following supplemental information is provided to bring this issue to closure:
Northeast Utilities agrees that the sentence on page 17 was transferred from the original Stone & Webster specification 2362.200-164. It was not deleted from the new purchase specification SP-ME-784 because it was felt to also be Phnted 4f30/98 4:02:21 PM Page 2 of 4
1 N rthert Utilities ICAVP DR Nr. DR-MP3-0615 Millstone Unit 3 Discrepancy Report applicable to the new valve and seat design. Specifically, the valve disc must be contoured in such a way as to not interfere with the disc and seat ring entry into the metallic valve seating surface on the valve body, in addition, the disc must be contoured in such a way as to not interfere or cut into the elastomeric seating ring mounted to the outer edge of the disc itself.
Significance level criteria does not apply as this is not a discrepant condition.
Conclusion:
NU has concluded that Discrepancy Report DR-MP3-0615 does not represent a discrepant condition. As detailed in the disposition, the detailed design of the valve seat is documented on drawings 2362.200-164-109 and 2362.200-164-110 (Transmittal 51, dated 07/07/97). As documented on drawing 2362.200-164-109, the valve seat is constructed of hard rubber type E.P.T. The disc is machined in such a way that it does not interfere with the interaction of the valve seat and the rubber seating ring. Therefore, there is no contradiction in specification l
SP-ME-784. The seat configuration as illustrated in the afore mentioned drawings are consistent with the commitment made in B09878.
Pursuant to teleconference with S&L on 4/17/98, the following supplemental information is provided to bring this issue to closure:
Northeast Utilities agrees that the sentence on page 17 was transferred from the original Stone & Webster specification 2362.200-164. It was not deleted from the new purchase specification SP-ME-784 because it was felt to also be applicable to the new valve and seat design. Specifically, the valve disc must be contoured in such a way as to not interfere with the disc and seat ring entry into the metallic valve seating surface on the valve body, in addition, the disc must be contoured in such a way as to not interfere or cut into the elastomeric seating ring mounted to the outer edge of the disc 4 itself.
l)
Significance level criteria does not apply as this is not a discrepant condition. ]
1 Previously identined by NU? O Yes @ No Non Discrepant Condition? 8) Yes () No l l
Resolution Pendmg?O ve. @) No Resolution Unresolved?O ve. <@ No l Review E
- initiator: Feingold, D. J.
VT Lead: Neri, Anthony A VT Mgr: schopfer. Don K IRC Chmn: singh, Anand K Detc 4/23/98 Pnnted 4/30/98 4:02:23 PM Page 3 of 4 l
Northua:t Utilities ICAVP DR No. DR-MP3-0615 Millstone Unit 3 Discrepancy Report l
st comments: - Comments On Initial Northeast Utilities Response -- j l
Page 17 states that the disc is to be machined to ease entry of the disc into the seat. This infers that the edge of the disc is machined such that it can easily enter the elastomeric seat. If the ;
elastomeric seat is on the disc, then the disc cannot move to engage the elastomeric seat.
)
The statement on page 17 of specification SP-ME-784 is identical j to a statement on page B125 of specification 2362.200-164 for the original butterfly valves with the elastomeric seat on the valve body. Therefore, the statement appears to have been missed when creating specification SP-ME-784 from specification 2362.200-164.
The replacement butterfly valves appear to be designed in j accordance with the commitment in letter 809878; however, the i design specification is misleading and in conflict with drawings 2362.200-164-109 and 2362.200-164-110.
1
- Comments On Second Northeast Utiities Response - I Sargent & Lundy finds Northeast Utilities'second response acceptable, l
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Northert Utilitie3 ICAVP DR Ns. DR-MP3-0660 Millstone Unit 3 Discrepancy Report Review Group: system DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanecal Design Discrepancy Type: Calculation System / Process: HVX l
NRC Significance level: 4 Date faxed to NU-Date Published: 12/8/97 Discrepancy: Emergency Generator Enclosure Maximum Temperature Calculation
Description:
During review of calculation P(B)-953, Rev. 2 ' Emergency Generator Enclosure Ventilation' a discrepancy in the determination of the room temperature was identified.
The results of the calculation show that at the extreme maximum outside air temperature of 103*F the temperature in the silencer room is 121*F. This is higher than the 120*F maximum temperature stated in FSAR Section 9.4.6.1.
The calculation uses an airflow rate of 120,000 cfm and an air density of 0.075 lb/ cubic feet in calculating the temperature rise between the supply air and exhaust air in the room. At the design outside air temperature of 86*Fdb/75'Fwb the density of air is 0.0708 lb/ cubic feet. Since the supply fans are a constant volume device the 0.075 lb/ cubic feet air density used under estimates the temperature rise in the room by 1) approximately 6% at the design outside air temperature of 86'Fdb/75'Fwb, and
- 2) by approximately 9% at the extreme maximum outside air temperature of 103*Fdb.
Review Valid invalid Needed Date initiator: stout, M. D. O O O 11/22/97 VT Lead: Neri, Anthony A B O 11/22/97 VT Mgr: schopfer, Don K B O O $2/i/97 IRC Chmn: singh, Anand K O O O 12/4s7 Date:
INVALID:
Date: 4/27/98 RESOLUTION: First Response NU has concluded that Discrepancy Report DR-MP3-0660 has identified a condition not previously discovered by NU which requires correction.
The reference to the maximum outdoor temperature of 103'F and the resulting 121'F as the maximum indoor temperture was made in the calculation to establish a tie with the temperature values of the environmental zones that appearin Appendix 3B to section 3.11 of the FSAR. It now appeare that making that reference was a mistake as it has no benefit and only leads to confusion. It is, therefore, proposed to delete the maximum temperature values given for the silencer room and the enclosure as a single zone from the calculation. In any case, the Printed 4/3098 4:02:58 PM Page 1 of 5
Northecst Utilities ICAVP DR No. DR-MP3-0660 Millstone Unit 3 Discrepancy Report operability of the emergency diesel generator is not in question, since the maximum diesel generator room temperature is conservatively estimated at 117.2*F when the outdoor temperature is 103*F whereas the specified maximum temperature in specification 2447.300-241 (E-241), Emergency Diesel Generators, is 120*F. The concept of operability due to temperature does not apply to the silencer.
Regarding the second issue of the DR, it is common practice to use standard air density and to not use density correction factors in HVAC calculations when the temperature changes are not very large and the inputs are so grossly overestimated (the margin in the estimated waste heat from the diesel engine alone given by the vendor in attachment A to the calculation is in the order of 40%, or,16% of total room load) . Nevertheless, using the density correction factors of the DR, the room temperatures at outdoor design temperature and outdoor maximum temperature change from 100.2*F to 100.6*F and from 117.2*F to 118.5'F, respectively. The indoor temperature of 100.6*F is still in compilance with the revised FSAR statement. The indoor maximum temperature of 118.5'F still does not affect operability. The 118.5'F is, however, overestimated because of the simple rerating of the Dt by the density correction factors. A rigorous recalculation is expected to result in a temperature not much different than 117'F since a higher room temperature will reduce the heat gains into the room and increase transmission losses to the outside.
The approved corrective action plan to CR M3-97-4788 requires re-evaluation of the temperature values for the silencer room, and a re-evaluatbn of the air density correction factors effect on indoor room temperatures. The assignment is being tracked by AR 97030723-02. Since the silencers are in separate rooms and are not affected by temperature and the operability of the diesel generator *.s not in question, completion of corrective action has been deferred to post startup.
Because this issue has no effect on licensing basis / design basis, NU considers this a Significance Level 4.
Attachments:
CR No. M3-97-4788 with approved corrective action plan.
Second Response (M3-IRF-02040)
NU has concluded that the follow-up issues reported in DR-MP3-0660 has identified a condition not previously discovered by NU which requires cortection.
- 1) Regarding density correction fcciors, Assumption 6 on page l 10 of Calc 953P(B), Rev. 2, states ".. Ventilation air in the normal HVAC temperature rangem treated on a volumetric basis wnhout correction for deas:ip.ariation. There is no significant error resulting from this...'. Px the corrective actions of CR M3-97-4788, CCN-01 to Calc 953P(B), Rev. 2, has t'een issued to ndd a statement to the body of the calculation to clarify the use
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Printed 4/30/98 4:03:02 PM Page 2 of 5
Northext Utilitie3 ICAVP DR N2. DR-MP3-0660 Millstone Unit 3 Discrepancy Report i of standard air density, without a correction factor. In addition, a statemer,i was added to the cale per CCN-01 conceming the conservative nature of the vendors estimate of engine heat rejected to the room.
- 2) The temperature in the silencer enclosure has no impact on the equipment installed there. The temperature in the silencer enclosure, as shown on Calc 953P(B), can reach 121F. The only temperature sensitive equipment in each of the two silencer enclosures is a lighting transformer. The two transformers in question,3 LAD *EXL10 and LAD *EXL2P, are qualified to 135F, as shown in Specification No. 2421.500-608, Rev.1.
3,4) The DG Silencer Enclosure is not considered part of Zone DG-01, as described in FSAR Section 9.4.5.1, and Appendix 3B.
It is a structure on the roof of the Diec,el Enclosure, open to atmosphere on both ends, and sees ventilation exhaust flow from the DG enclosure.
Per the approved corrective actions of CR M3-97-4788, CCN-01 to Calc 953P(B), Rev. 2 has been issued to clarify the temperatures in the Silencer Enclosure.
As the transformers are qualified for the expected temperatures, and the CCN will not change the results of the calculation, this is considered by NU to be Significance Level 4.
In addition, the design temperature of the emergency generator enclosure, as defined in FSAR Section 9.4.6.1, APP. 3B, was changed from 120F to 104F, via FSARCR 97-MP3-295. This '
FSARCR was issued to correct inconsistencies in designation and definitions of the related concepts of ventilation indoor design temperature, NMA (Normal Maximum Average), MNE (Maximum Normal Excursion), and MAE (Maximum Abnormal Excursion). As shown in CCN-02 to Calc P(B)-1118, Rev. O, 120F represents the MAE of Zone DG-01 (Emergency Diesel Enclosure.)
During the investigation of the issues raised in DR-0660, the following was discovered:
The specification calls for the transformers to be qualified to a temperature range of 50 - 135F, greater than the 121F max
{
which the area will experience. However, the nameplate on the l transformers states the maximum ambient temperature as 130F, '
which also exceeds the maximum area temperature of 121F, as
{
calculated in 953P(B), Rev. 02. The PDDS Data Sheets state .
that these transformers are in Zone DG-01. Review of the l purchase Specification,2421.500-608, shows these transformers as being in the Emergency Generator Enclosure - EL. 24'-6",
Zone DG-6FGUO. CR M3-98-1861 was issued to develop I corrective actions associated with these issues. The approved j corrective action will resolve documentation discrepancies in the i boundaried of FSAR Environmental Zone DG-01 as shown in Appendix 3B of the FSAR, and the designation of the FSAR Zone for the transformers in PDDS and the Purchase
, Specification, and difference.= in it e transformers' qualifiv on l temperature, between that shown in the Purchase Specification Printed 4/30/96 4 03:03 PM Page 3 of 5 1
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Northert Utilities ICAVP DR No. DR-MP3-0660 Millstone unit 3 Discrepancy Report and the one on the devices' nameplates. Design Engineering will generate the required administrative DCNs and database updates to resolve the discrepancies discovered by this CR. This is a documentation update only, and will be completed after restart.
Attachments:
CR M3-97-4788 CR M3-98-1861 CCN-01 to Calc 953P(B), Rev. 2 Specification 2421.500-608 (partial)
CCN-02 to Calc P(B)-1118 FSARCR 97-MP3-295 Previously klentified by NU7 O Yes (*) No Non Discrepent Condition?U Yes (*) No Resolution Pending70 vos @ No Re.oiution unre.oived70 vos @ No Review initiator: Stout, M. D. ~
VT Lead: Neri, Anthony A VT Mgr: Schopfer, Don K g
IRC Chmn: Singh. Anand K Date:
O 4/27/98 SL Comments: Comments on First Response Agree that correcting the air density used in the calculation has a small impact (-0.5'F) on resulting room temperature and that based on information in Attachment A to calculation P(B)-953, Rev. 2 that diesel engine heat loss values are conservative. This should be addressed in the calculation.
Assumption 5 in calculation P(B)-953, Rev. 2 states that a purpose of the calculation is to determine the temperature in the vicinity of the isolation transformer, which is at the upstream end of the silencer. The function of this component and the impact of slightly higher temperatures would have needs to be addressed in NU's response.
FSAR Section 9.4.6.1 Design Basis item 3. states that the emergency generator enclosure maximum indoor air temperature is 120*F. As the silencer room is inside the enclosure building, the 120'F maximum temperature stated in the FSAR is applicable to the maximum temperature in the silencer room.
The approved corrective action for CR M3-97-4788 states i
- Evaluate the reference to the temperature values for the silencer room and delete if appropriate. Evaluate the effect of air density correction factors on the indoor room temperature and revise calculation as required. (Ref. calc. P(B)-953, rev. 2)". The corrective action does not address the discrepancy between the calculated temperatures in the silencer room and 120*F maximum temperature stated in the FSAR.
Comments on Second Response l
Printed 4/30/98 4:03:05 PM p, g {
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N:rthe=t Utilities ICAVP DR No. DR-MP3-0660 Millstone unit 3 Discrepancy Report This is considered to be a Level 4 documentation discrepancy.
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N:rthert Utilities ICAVP DR N2. DR MP3-0688 Millstone unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Discipline: Mechanical Design y qg Discrepancy Type: Calculation O vee SystemProcess: DGX @) No NRC Significance level: 4 Date faxed to NU:
Date Published: 12/20/97 D6screpancy: Discrepancies in Calculation 3-92-102-263-M3/Rev. O, CCN 1
Description:
Review of the calculation " Emergency Diesel Starting Air System Design Pressure and Temperature", calc. no. 3-92-102-263-M3, Rev 0, Calculation Change Notice no.1 resulted in the following discrepancies:
- 1. This calculation is classified "Non-QA" on the Calculation Change Notice No.1, page 1, box 7, and "non QA" and seismic qualification basis "N/A" on page 1 of the calculation. However, among components included in the scope of the calculation are Air Receiver Tank 3EGA*TK1 A,1B,2A,2B (classified QA Cat.1 component) and safety related piping (lines with line sequential numbers 1,3,5,11,13,15).
- 2. The model used to calculate air temperature at the air compressor discharge (page 9 of the calculation) yields temperatures below those provided by the Emergency Diesel Generator supplier via the Colt Industries letter " Contract 206072 Millstone 3 Quincy Air Compressor", dated April 5,1983, and attached to calculation P(T)-1042, Rev. (blank) as Attachment
- 2. The Colt industries letter states that if the compressor tums 900 rpm, the air discharge temperature at 450 psi will be approximately 585 degrees F, and at 425 psi approximately 575 degrees F. (This information was used in calculation P(T)-1042 to define operating temperatures at limiting compressor discharge pressures.) The model used in this calculation yields air temperature of 570 degrees F at 450 psig and 584.5 degrees F at 500 psig. In comparison to the vendor provided data, the temperature calculated in this calculation appears non conservative.
- 3. The calculation states that the aftercooler design pressure is 500 psig per "Aftercooler Heat Exchanger Spec. Sheet",
Appendix E, Specification 12179-2520.300-730, Add.1, dated 3/21/85. The Aftercooler Heat Exchanger Spec Sheet could not be found in the referenced purchase specification. However, the purchase specification, Attachment 2 does specify the air cooled aftercooler process side design pressure at 450 psig.
- 4. Calculation states that "The whole EGA system is using pipe Class 301, Spec SP-ME-572... Class 301 piping is suitable for 555 psig up to 600 degrees F temperature.
Conclusion:
Piping is OK for 500 psig." The P&lD's EM-116B-25 and EM-116D-5 show a class change within the dryer package between the aftercooler (CL 602), condensate separator (CL 151), prefilters (CL 602), and the dryer (CL 151). Per Spec. SP-ME-572 piping Class 151 is good for 275 psig at 100 degrees F, and 150 psig at p pg 500 degrecc F, ;;c"tetow the cc!ce!ct!On iden'Tcd opergt[81 of s
N rthert Utilitie3 ICAVP DR No. DR-MP3-0688 Millstone Unit 3 Discrepancy Report pressure and the design pressure.
Review Valid invalid Needed Date initiator: oberen4Bojan. O O O ir21/97 VT Lead: Nerl. Anthony A O O O i r24/97 VT Mgr: schopfer, Don K O O O 12ii/97 1RC Chmn: singh, Anand K O O O $2/16/97 D.t.:
INVALID:
Date: 4/29/98 RESOLUTION: First Disposition:
NU has concluded that issues 1 and 4 reported in Discrepancy Report, DR-MP3-0688, have identified conditions not previously j discovered by NU which require correction. An issue by issue J
discussion follows.
L The approved corrective action plan in CR M3-98-0140 will be completed post startup to revise calculation 3-92-102-263-M3 to {
l identify it as QA CAT 1. It will also revise the designation of EGA l pipe class from 151 to 301 on P&lD EM1168 and EM116D to l reflect the material provided by the vendor. There is no impact {
on the licensing or design basis since the calculation was independently reviewed as required for CAT 1 calculations and the installed material is identical (A106Gr B. Sch 80) for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4.
NU has concluded that issues 2 and 3 of Discrepancy Report, DR-MP3-0688, do not represent discrepant conditions. The Colt Industry letter provides " approximate" temperatures for various discharge pressures and compressor speed. The method for calculating compressor discharge temperatures uses several conservative assumptions and room temperatures specific to Millstone and is deemed acceptable. The after coolers were replaced by DCN DN3-S-1269-93 with models rated for 500 psig. There is no requirement to revise a superseded purchasing specification. Significance Level criteria do not apply here as this is not a discrepant condition.
Conclusion:
NU has concluded that issues 1 and 4 reported in Discrepancy Report, DR-MP3-0688 have identified conditions not previously discovered by NU which require correction. Issues 1 and 4 will be corrected by the approved corrective action plan in CR M3 0140 to revise the calculation and the P&lD. These actions will be completed post startup. There is no impact on the licensing or design basis since the calculation was independently reviewed as required for CAT 1 calculations and the installed material is identical for either pipe class. Therefore NU has concluded that this discrepancy is a Significance Level 4. NU has concluded that issues 2 and 3 of Discrepancy Report, DR MP3-0688, do not represent discrepant conditions. Issue 2 is considered non discrepant since it uses an acceptable method of calculating Printed 4/3098 4:03-41 PM Page 2 or 5
Northext Utilities ICAVP DR No. DR-MP3-0688 Millstone Unit 3 Discrepancy Report compressor discharge temperatures while the vendor provided approximate information. issue 3 requires no correction since the aftercoolers have been replaced by models rated for 500 psig by DM3-S-1269-93. Significance Level criteria do not apply for issues 2 and 3 since these are not discrepant conditions.
Second Disposition:
NU has concluded that the issue reported in item 2 of Discrepancy Report, DR-MP3-0688, has identified a condition not previously discovered by NU which requires correction. The approved correct w action plan for CR M3-98-0140 (attached) has been modified to revise calculation 3-92-102-263-M3 post startup to be identified as a QA Cat 1 calculation and to revise or delete assumption number 2 and revise the body of the calculation as required.
Per our discussion with the vendor and the information provided attachment 1, the assumption that the Intercooler temperature approach to ambient temperature is 50 'F is not conservative as stated in assumption number 2 of the current calculation. By revising the methodology to calculate the discharge air temperature using less conservative thermodynamic equations ,
for polytropic compression in lieu of isentropic compression and revising assumption number 1 to state that the compressors interstage pressure is 54 psig (attachment 1) and assumption number 2 to state that the Intercooler temperature approach to ambient temperature will De selected as 100 'F (Using 100 'F is conservatively higher than the 157 'F - 70 *F = 88 'F stated in attachment 1), it can be shown (attachment 2) that the maximum temperature will equal 588.6 *F which is less than the 600 *F design temperature.
Based on our review it is determined that the conclusion will not be affected by the revision to this calculation. As such, there is no effect on the license or design basis. Therefore, NU has concluded this to be a Significance Level 4 issue.
Conclusion:
NU has concluded that the issue reported in item 2 of Discrepancy Report, DR-MP3-0688, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-0140 (attached) has been modified to revise calculation 3-92-102-263-M3 post startup to be identified as a QA Cat 1 calculation and to revise or delete assumption number 2 and revise the body of the calculation as required. Per our discussion with the vendor and the information provided by attachment 1, attachment 2 shows that the conclusion will not be affected by the revision to this calculation. As such, there is no effect on tne license or design basis. Therefore, NU has concluded this to be a Significance Level 4 issue.
Additional information to the second disposition:
Northeast Utilities contacted Coltec industries to request l additional supporting information. Per the attached record of telephone conversation. Coltec provided information that Printed 4/3098 4.03.43 PM Page 3 of s 4
1
\
I Northea2t Utilitie3 ICAVP DR N . DR-MP3-0688 Millstone unit 3 Discrepancy Report confirms:
(a) That the temperature of the airleaving the intercooler approaches the ambient by 88 to 90 *F, in all cases reviewed.
Ici the case of 120 *F ambient, the approacF. is 90 'F which is less that the 100 'F previously assumed.
I (b) That the HP stage discharge temperature is 543 'F which is '
less than the 588 *F conservatively calculated by NU. ,
The Summary of Results of the calculation are therefore unaffected. As such, there is no effect on the license or design basis. Therefore, NU has concluded this DR to be a
- CONFIRMED DISCREPANT" Significance Level 4 issue.
Conclusion:
Northeast Utilities contacted Coltec Industries. Per the attached record of telephone conversation, at a 120 'F inlet temperature, the discharge air temperature would be 543 'F". This discharge temperature is below the design temperature of 600 *F confirming the results of the calculation that for the design pressure increase, the design temperature will remain unchanged. The conclusions of the calculation are therefore unaffected. As sucis, there is no effect on the license or design basis. Therefore NU has concluded this DR to be a
" CONFIRMED DISCREPANT" Significance Level 4 issue.
Previously idenUned by NU? O Yes (e) No Non Discrepant Condition?O Yes W) No Resolution Pending?O ve. @ No Resolution Unresolved?O v.. @ No Review Acceptable Not Acceptable Needed Date M Oh@
VT Lead: Neri, Anthony A VT Mgr: schopfer, Don K 1RC Chmn: singh, Anand K O O Date: 4/28/98 sL Comments: S&L comment for first disposition:
S&L agrees with the disposition for the first discrepancy.
S&L will require additional information to determine adequacy of the NU disposition for the second discrepancy regarding the determination of air compressor air discharge temperature. While S&L agrees that the model of isentropic compression is conservative for this calculation and accepts the interstage pressure model, the assumption that the intercooler temperature approach to ambient temperature will not exceed 50 degrees F needs to be substantiated with design information, and so documented in the calculation. Piease identify such approach temperature supporting information.
S&L agrees with the disposition for the third discrepancy. As shown on the revised data sheet for air cooled aftercooler (page 60 of DCN DM3-S-1269-93) the design pressure for the aftercooler process side was revised to 500 psig. This is a non-discrepant condition.
Printed 4/30/98 4 03 44 PM Page 4 of 5
1 N:rtherct Utilities ICAVP DR No. DR-MP3-0688 Millstone unit 3 Discrepancy Report Regarding the fourth discrepancy S&L agrees that the condensate separator and dryer pipe material and wall thickness (per dwg.
2520.300-730-004C, Sh.100 of DCN DM3-S-1269-93) meet the pipe Class 301 requirements. S&L agrees with the NU disposition for this discrepancy, that is that the P&lD should be appropriately corrected.
S&L comment on the second NU disposition:
Based on the additional vendor information provided with the disposition in the NU response no. M3-IRF-02242, S&L agrees that the design temperature for the starting air system downstream of the air compressor is conservatively set at 600 degrees F. S&L also agrees that the calculation no. 3-92-102-263-M3 should be revised per corrective action plan for CR M3 0140, as modified. As shown by NU, the calculation changes will not adversely impact the results of the calculation. This, combined with the previous disposition of other items of the DR, demonstrates that the discrepancies described in this DR will have no effect on the system design or licensing basis.
Therefore, the Significance Level for this DR has been lowered to Level 4. S&L also agrees that the corrective action can be deferred.
Pnnted 4/30/96 4:03.46 PM Page 5 of s
Northea:t Utilities ICAVP DR N1 DR-MP3-0752 Millstone Unit 3 Discrepancy Report Review Group: Prey ,vineic DR RESOLUTION ACCEPTED Review Element. Corrective Action Process Discipline: I & C Design Discrepancy Type: Corrective Action System / Process: sWP g
NRC Significance level: 4 Date faxed to NU:
Date Published: 1/1098 Discrepancy: Resolution not addressing root cause.
Description:
DDR 207 identifies an air entrainment problem with instruments 3SWP-PDIS 24A-D and PDIS 110A-D. The resolution indicates that no discrepancy exists and each time the pump is to be started, an instrument maintenence technician should vent the line prior to pump start ensurin0 air or gases are not trapped in the sensing lines. Per ASME PTC 19.21964 and ISA-S6701-1979, industry practice recommends for liquid filled systems that instrumentation be located below the process line and sensing lines slope up from the instrumentation to the process ensuring that any air or gas shall be continuously vented preventing entrainment. The resolution does not address compliance with the previously mentioned standards nor the feasibility of resloping the instrument sensing lines.
Review Val 6d invalid Needed Date initiator: Dombrowsid. Jim G O O 12/is/97 VT Leed: Ryan, Thomme J G O O 12/is/97 VT Mgr: schopter. Don K G O O 2/23/97 IRC Chmn: Singh, Anand K G O O 12/31/97 Date:
INVALID:
Date: 4/29/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0752, does not represent a discrepant condition.
Service Water System strainer back flush differential pressure control switches (3SWP*PDIS 24A-D) and alarm switches (PDIS 110A-D) are installed in accordance with Specification 2472.800-943 " Instrumentation installation, Piping, and Tubing, Safety Class 2, ANSI Code B31.1, Class 4' requirements. This specification implements ASME and ISA requirements and industry recommended practices where practical. Installation of these switches is shown on drawings 12179-BK-16D-64-3 and 12179-BK-16D-65-3 respectively. A field verification of the installation was performed that confirmed the sensing lines slope downward from the process towards the instrument and have at least the minimum line slope of one half inch per foot. To accommodate mounting of the valve manifold and instrument a short vertical (up) section of sensing line is connected to the bottom of the valve manifold and continues upward between the valve manifold and the switch. This arrangement is in accordance with both the installation specification and the Pnnled 4/30/98 4 04:27 PM Page1 or 3
4 Northert Utilitiea ICAVP DR NA DR-MP3-0752 Millstone Unit 3 Discrepancy Report i
drawing for this application.
)
The air entrapment problem is not directly associated with the 3SWP*PDIS 24A-D and PDIS 110A-D installation, instead, it is >
associated with the process being measured because 1) the Service Water is a highly oxygenated pmcess fluid and 2) ;
gasses can readily come out of solution due to the constant j
pressure and vacuum fluctuations across the strainer. The gas that comes out of solution between the process connection and the point where the impulse lines bend up to meet the valve manifold will vent back into the process. However, gasses that come out of solution between the valve manifold and the switch will become entrapped within the switch. This cannot be
(
prevented without creating a crud trap within the switches. The '
instruments are periodically vented as part of their calibration and maintenance activities which is adequate for these installations. NU considers the recommended disposition of Design Deficiency Report (DDR) 207 to be appropriate and plant operation over the past decade has proven this to be an acceptable resolution to this startup DDR. Considering the above,3SWP*PDIS 24A-D and PDIS 110A-D switches are installed in accordance with MP3 instrument installation program, applicable codes, standards and industry recommended practices. Therefore, Design Deficiency Report (DDR) 207 was appropriately dispositioned.
Significance Level criteria do not apply here as this is not a discrepant condition.
Conclusion:
I NU has concluded that the issue reported in Discrepancy Report, i DR MP3-0752, does not represent a discrepant condition. NU considers the disposition of Design Deficiency Report (DDR) 207 to be appropriate and that the differential pressure switches
, 3SWP*PDIS 24A-D and PD!S 110A-D are installed in accordance with MP3 instrumentation installation program, applicable codes, standards and industry recommended practices.
Significance Level criteria do not apply here as this is not a discrepant condition.
j
. Attachments: DDR-207 Previously identined by NU7 Q Yes (#) No Non Discrepant Cond6 Hon 7s) Yes O No Resolut6on Pending70 va @ No Raoiuuan unr..oiv.d70 ve. @ No Review initiator: Caruso, A.
Acceptable Not Acceptable Needed Date VT Leed: Ryan, Thomas J O O =
VT Mgr: Schopfer, Don K O O =
IRC Chmn: singh, Anand K Date: 4/29/98 Printed 4/30/98 4.o4:32 PM Page 2 of 3
Northe=t Utilities ICAVP DR N2. DR-MP3-0752 Millstone Unit 3 Discrepancy Report SL Comments: NU's response is acceptable.
NU's disposition acknowledges that the Service Water System strainer back flush differential pressure control switches (3SWP'PDIS 24A D) and alarm switches (PDIS 110A-D) are installed in accordance with Specification 2472.800-943
" Instrumentation Installation, Piping, and Tubing, Safety Class 2, ANSI Code 831.1, Class 4" requirements. NU's disposition also acknowledges that Specification 2472.800-943 implements ASME and ISA requirements and industry recommended practices where practical.
Consequently, we concur that the DR-MP3-0752 is not discrepant.
Printed 4/30/98 4-04.34 PM Page 3 of 3
NortheTt Utilities ICAVP DR Na, DR-MP3 0823 Milistone Unit 3 Discrepancy Report l l
Review Group: system DR RESOLUTION ACCEPTED I Review Element: system Design p
Discipline: Mechanical Design Discrepancy Type: Drawing Om System / Process: DGX g {
NRC Significance level: 4 Date faxed to NU: l Date Published: 1/10S8 Discrepancy: P&lD EM-117A Rev.10, Emergency Generator Fuel Oil i System, Review of piping line sizes.
I Ducription: Piping size calculations were not found. This would be the type j of calculation that addressed fluid velocity and pressure drop over the expected range of operation. The transfer pump calculation P(B)-0799 indirectly verifies the main pipe header to the day tanks, but the balance of the piping has not been l addressed.
{
Of particular concem is the gravity drain line from each day tank to it's respective AC or DC fuel oil pump. Since the line flows by gravity, it must be sized for maximum flow rates and with minimal pressure loss.
Review Valid invalid Needed Date initiator: Russ. Earl.
VT Lead: Neri, Anthony A O O O 12/19/97 O O O 12/19/97 VT Mgr: schopfer, Don K O O O 2/23/97 IRC Chmn: singh, Anand K O O O 12/3i/97 Date:
INVALID:
l l
Date: 4/29/98 RESOLUTION: First disposition:
NU has concluded that DR-MP3-0823 does not represent a j discrepant condition. The piping from the Day tank was installed j by the AE and was sized to be compatible with the suction connections to the vendor supplied, skid mounted fuel oil pumps .
(See Attached Dwg 2447.300-241-005). Design pressures and temperatures for the piping system are supported by calculation P(T)-1019 ( See Attached ). The diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) and surveillence procedure SP 3646A.1/2 at least every 31 days.
The operability testing along with the calculations confirms the adequacy of the DG fuel oil piping system. Additionally,it ;
should be noted that the fuel oil pumps on the diesels are DC I and engine driven. There is no AC powered fuel oil pump as l stated in the S&L DR.
Significance level criteria does not apply as this is not a i discrepant condition.
Conclusion:
NU has concluded that Discrepancy Report DR-MP3-0823 does r.ot represent a discrepant condition. The piping frem the Day tank was installed by the AE and was sized to be compatible with the suction connections to the vendor supplied, skid mounted Pnnted 4/30/98 4:05:16 PM Page 1 of 4
N:rthert Utilities ICAVP DR N . DR-MP3-0823 Millstone Unit 3 Discrepancy Report fuel oil pumps (See Attached Dwg 2447.300-241-005). Design pressures and temperatures for the piping system are supported by calculation P(T)-1019 ( See Attached ). The diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) ,
and surveillence procedure SP 3646A.1/2 at least every 31 days. 1 Additionally, it should be noted that the fuel oil pumps on the diesels are DC and engine driven. There is no AC powered fuel oil pump as stated in the S&L DR. The operability testing along with the calculations confirms the adequacy of the DG fuel oil piping system.
Significance level criteria does not apply as this is not a discrepant condition.
Second disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0823, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-2082 (attached) will prepare and issue a calculation prior to unit 3 start up to document that the net positive suction head available (NPSHA) to the Engine Driven and DC Motor Driven Fuel Pumps is equal to or greater than the net positive suction head required (NPSHR). Our review of this discrepancy determined the following: The Fuel Oil Day Tank is correctly located at the elevation above the pump (11 feet) prescribed by the vendor. The 1 inch suction piping in question is only 25 feet long with (4) 5" diameter bends. Based on a required flow of 6.16 gpm, the velocity is about 3 feet per second and the head loss is less than 1 foot thereby providing a NPSHA of about 10 feet. The diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) ,
and surveillance procedure SP 3646A.1/2 at least every 31 1 days. As such there is no effect on the license or design bcsis, therefore NU has concluded this to be a Significance Level 4 issue.
Conclusion:
I NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0823, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-2082 (attached) will prepare and issue a calculation prior to unit 3 start up to document that the net positive suction head available (NPSHA) to the Engine Driven and DC Motor Driven Fuel Pumps is equal to or greater than the net positive suction head required (NPSHR). Our review of this discrepancy determined that the Fuel Oil Day Tank is located per the vendor requirements and the diesels are operability tested in accordance with the Tech Specs (4.8.1.1.2a) and surveillance procedure SP 3646A.1/2 at least every 31 days. As such there is no effect on the license or design basis, therefore NU has concluded this to be a Significance Level 4 issue.
Previously identified by Nu? O Yes (G) No Non Discrepant condition?U Yes W) No Resolution Pendeng?O ve. @ No Re.oiution unre.oived?O ve. @ No Review Printed 4/30/98 4:05:20 PM Page 2 of 4
N:rthert Utilities ICAVP DR No. DR-MP3-0823 Millstone Unit 3 Discrepancy Report Acceptande Not areapdaNa Needed Date initnetor: obersnel.Boien. de"S8 VT Lead: Nort, Anthony A O O O VT Mor: schoprer, Don K B O O 4r898 IRC Chmn: singh, Anand K O O O draSe O O O Date: 4/29/98 sL comments: S&L comments on the first NU disposition:
The basic concem in this Discrepancy Report is that there do not appear to be calculations for the fuel oil piping system that address pipe fluid flow velocity and pressure drop and a review of the pipe size information as shown on the P&lD's appears to show some inconsistencies in system design.
The comment is made that the piping from the day tank was sized to be compatible with the suction connections on the vendor supplied skid mounted fuel oil pumps. Reference is made to an attached drawing, Dwg 2447.300-241-005, which was reviewed and shows that the skid mounted connections are 1 1/2 inches in size. The gravity pipeline to these connections is sized at 1 inch, requiring a pipe reducer to make the connection. The diesel vendor drawing does not require 1 inch piping, however, the day tank vendor's drawing does show a 1 inch connection for this gravity fuel oil pipe.
To put this in perspective, the fuil oil transfer system begins at the 35,340 gat storage tank in wh ch the 40 gpm transfer pumps are mounted. These pumps have a 3 inch discharge connection which is reduced to 1 1/2 inches ind then piped to the day tank.
From the day tank, the 1 inch 9 avity line feeds into the 1 1/2 inch piping connections the DG skid which in tum feed into the engine-driven and DC driven fuel oil pumps through 1 1/2 inch vendor supplied skid-mounted piping. The gravity feed 1 inch pipe is not under the same pressure as the other piping systems. It is possible that the engine-driven and DC driven fuel oil pumps are overcoming the flow resistance in the gravity pipeline instead of having the fluid delivered to their inlet connections at essentially atmospheric pressure. The 1 inch gravity line is the smallest pipe between the storage tank and the fuel oil pumps.
To compare with other pipe sizes, the vendor drawing also shows that the fuel oil pressure retum header connection is 1 1/2 inch, which is also fitted with a 1 inch pipe and routed back into the day tank. Also, the gravity drain line from the day tank drip pan into plant drainage is sized at 3 inch.
Regarding the NU reference to calculation P(T)-1019, the system design pressures and temperatures are not an issue in this DR.
This is addressed in DR-MP3-0840.
The operability of the diesels during the relatively short test periods may not be a sufficient assurance that the pump suction is appropriately designed and may mask potential consequences of an inadequate available Net Positive Suction Head on the pump itself over a long post accident period of diesel operation.
A piping size / pump NPSH calculation would alleviate such Printed 4/30/9e 4.05.23 PM Page 3 of 4 l
l N:rthe:ct Utilities ICAVP DR N . DR-MP3-0823 Millstone Unit 3 Discrepancy Report j concems. j l Regarding the NU reference to the fact that there is no AC powered fuel oil pump, we agree and regret the error in describing the pumps.
S&L comments on the NU second disposition: l S&L agrees with the NU commitment via the corrective action plan for CR M3-98-2082 to prepare and issue prior to Unit 3 startup a net positive suction head calculation to document that the NPSH available to the fuel pumps is equal to or greater than the NPSH required. In addition, S&L agrees with NU evaluation that the vendor fuel oil day tank elevation requirement relative to the Diesel Generator skid bottom elevation is met, and that the potential difference in piping pressure loss between 1 inch and 1 1/2 inch suction line for the given piping configuration and at the nominal flow rate is about i ft of fluid head. Based on this evaluation, S&L believes that the pump NPSH requirements are i very likely met. This is supported by the history of diesel operability tests as required by Technical Specifications.
Because of this, and considering the NU commitment to prepare and issue an NPSH calculation prior to startup, S&L agrees to reduce the Significance Level for this DR to Level 4.
i l
l l
Pmted 4/30/96 4 05:25 PM Page 4 of 4
N:rthe2t Utilities ICAVP DR Ns. DR-MP3-0884 Millstone Unit 3 Discrepancy Report Review Group: Programmatic DR RESOLUTION ACCEPTED Review Element. Corrective Action Process Diecipline: Operstbn.
Discrepancy Type: Corrective Action implementation Ow g~
System / Process: SWP NRC Significance level: NA Date faxed to NU:
Date Published: 1/10/96 D6screpancy: Incomplete Closure of Unresolved Item Report (UIR 1414)
Description:
In conjunction with UIR 1414, the Discrepancy item Closure Package (DICP) has been reviewed.
Only the first two Recommended Dispositions sre addressed in the DICP. The recommendation for Design Engineering to Generate MMOD to correct Ops Form / Procedure designations, as applicable has not been addressed.
Note: It is recognized that changes to OPS Form / Procedure designations may not be needed to address the specific issue documented on this UIR, however, if no changes are needed, this should be documented with justification in the DICP since it is clearly indicated as a recommended disposition on the UIR which has been reviewed / approved by the EP/PVRT and UPM.
As an example, another recommended disposition was for Design Engineering to generate a DCN to correct P&lD, as applicable. The DICP documentation clearly indicates that the P&lD was reviewed and determined to be correct, so the issue is property closed with regard to potential impact to P&lDs (eg. no impact) and the recommended disposition shown on the UlR was properly addressed.
Review Valid invalid Needed Date initiator: Navarro, Mark 8 0 0 2/23/97 VT Lead: Ryan, Thomas J B O O 12/23/97 VT Mgr: schopfer, Don K O O O 12r2st97 IRC Chmn: Singh, Anand K O O O 12/31/97 D.te:
INVALID:
Date: 4/30/98 RESOLUTION: Disposition Project Instruction PI 14 section 1.3 Preparation and Processing of Unresolved item Reports (UIR) describes the preparation of an UlR. The guidelines to complete UIR block #3 (Recommended Disposition Details) includes: " provide the proposed disposition and references or basis required to support the disposition." A template for block #3 was developed by the group doing the P&lD walkdown to provide consistent I recommendations. This template included the following items: !
Des. Eng. PERFORM MEPL review and IDENTIFY correct safety designation for affected equipment. System Eng.
GENERATE label request to correct field condition, as l applicable. Design Eng. GENERATE DCN to correct P&lD, as Printed N3098 4 06.07 PM Page 1 of 3 i
j
i N::rtherst Utilitie3 ICAVP DR Ns. DR-MP3-0884 Millstone Unit 3 Discrepancy Report applicable. Design Eng. GENERATE MMOD to correct Ops Form / Procedure designations, as applicable.This template was used on 58 UIRs to provide guidance if an issue was identified. It was never intended to require all items to be completed. PI 20 provides guidelines for completing non-ACR assignment forms, that is the Discrepancy item Closure Package (DICP). This guideline only requires identified actions to be listed, if an action such as " GENERATE MMOD to correct Ops Form / Procedure designations, as applicable" is not identified it does not have to be listed. The Expert Panel has reviewed the UIR through the Pl 14/20 process and concurred with the disposition or required actions. Therefore, UIR 1414 DICP is complete. Significance l Level criteria do not apply here as this is not a discrepant condition.
I Conclusion PI 20 guideline only requires identified actions to be listed.
Therefore, UIR 1414 DICP is complete. Significance Level criteria do not apply here as this is not a discrepant condition.
NU's second Disposition NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0884, does not represent a discrepant condition.The final disposition of UIR 1414 provided several options to be instituted as deemed necessary by Design Engineering Department. A/R 97007860 was written to allow Design l Engineering to perform MEPL evaluation, generation of a label '
request, DCN, MMOD as required. Therefore it was the judgment of Design Engineering to perform only the actions deemed necessary. The disposition should not have to list actions not taken if they were not considered applicable. The Expert Panel has reviewed the UIR Closure Request Report (DCIP) as a " stand alone" document and has concluded that the disposition adequately addressed the issues. The DCIP package includes UIR 1414 as part of the support documentation.
Adequate references exist between the UIR Closure Request Report and the UIR to ensure proper understanding of the actions taken in the closure of UlR 1414. Therefore NU does not consider this to be a discrepant condition.
NU's second Conclusion NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0884, does not represent a discrepant condition. NU has concluded that the disposition to UlR Closure Request Report was correct as written based on the flexibility provided in the UIR disposition. The wording, 'as required", indicates that any or all of the prescribed actions can be performed.
Therefore, the UIR Closure Request Report disposition only performed and documented the necessary actions. Although the DCIP is considered a " stand alone" document, the DCIP is comprised of the CRR and the UlR. Adequate references between both of these documents exist to gain an understanding of the disposition. therefore NU does not consider this to be a Printed 4/30/98 4:06:11 PM Page 2 of 3
N:rthett Utilitie3 ICAVP DR N2. DR MP3 0884 Millstone Unit 3 Discrepancy Report discrepant condition.
Previously idenufled by NU? U vos @ No Non Discrapent Condluon?(e) vos U No Resolution Pending?O ve. @ wo Re.oiuuan unre.aved?O ve. @ wo Review initiator: Neverro, Mark VT Lead: Ryan. Thomas J VT Mgt: schopfer, Don K IRC Chmn: singh. Anand K oste: 4/30/98 SL Comments: S&L comments to NU's first response:
The response provided is not acceptable. The response indicates that documentation is not required in the Closure Request Report for generic actions listed in the final disposition of the UIR if there was no action required since "PI 20 only requires identified actions to be listed" and that the Expert Panel has review the UIR through the Pl 14/20 process and concurred with the disposition or required actions". Contrary to the above, 1
- 1. Attachment 6 of PI 20 states that "the disposition listed on the i closure request shall contain a discussion on the related findings I and stated solutions". This should include at least a statement that ar. MMOD to correct OPS Form / Procedure designations", as indicated in the UIR final disposition, was not required. In addition,
- 2. Pi-20 Note states that "the DICP should be viewed as a stand alone document. An outside reviewer should have enough information within the DICP to fully answer all potential questions regarding issue background and resolution.
As pointed out in the DR, there was no required action to correct P&lDs and this was proper 1y documented in the Closure Request Disposition. A similar statement in the Disposition should have beei documented for the Licensee's conclusion that "MMOD to co'rrect OPS Form / Procedure designations was also not required."
S&Ls comments to NU's second response:
S&L continues to believe that documenting that approved final disposition actions were not needed plays an important part in ensuring that all required corrective actions have been completed regardless of wording that states such actions are "as applicable". NU's response however, is accepted based on NU's confirmation that an MMOD to correct OPS Form / procedure designations to address UIR 1414 was not required.
Printed 4/3090 4.06:13 FM Page 3 of 3
Northe st Utilities ICAVP DR N2. DR-MP3-0980 l Millstone Unit 3 Discrepancy Report Review Group: Accident Mdigston DR RESOLUTION ACCEPTED Review Element: Operating Procedure Discipline: Operah Discrepency Type: Procedure implementation O vee System / Process: N/A g
NRC Significance level: NA Date faxed to NU: 1 Date Published: 1/25/98 Discrepancy: Inconsistency in Translation of Design into EOPs Deectlption:
References:
EOP 35 E-3. " Steam Generator Tube Rupture", Rev.13, Effective 10/3/95 l UIR 1061, Reanalysis of Offsite Dose from a SG Tube Rupture Accident for Chapter 15 of the FSAR The ICAVP has reviewed the reference EOP as part of the verification of plant characteristics important to ensure that safety analysis assumptions are appropriately implemented and maintained in accordance with the MP3 FSAR Chapter 15 accident analysis. As part of that review the following discrepancies were noted.
- 1) The E-3 procedure cites a 46-minute time for completion of the actions necessary to complete plant cooldown to cease the tube rupture break flow and terminate the release. It is cited in the purpose of the procedure and indicated as consistent with the FSAR. The ICAVP team notes that the FSAR cites a 30-minute time period for this action and the associated offsite release assessment uses the 30-minute time for the release duration.
- 2) The FSAR indicates that the operator controls the ruptured steam generator at the steam Generator relief valve setting. The E-3 procedure directs the operator to control the ruptured steam generator at a pressure of 60 psi below the relief velve setting.
This inconsistency could cause an under prediction of the release from the RCS to the steam generator.
NU has identified in UIR 1061 that the affected safety analyses for the steam generator tube rupture need to be updated.
However, the assumptions and EOP inconsistencies identified above should be reviewed and factored into the safety analyses and, if determined to be appropriate, coordinated with EOP revisions.
Review Valid invalid Needed Date initiator: Bennett, L A. 1' 8/98 G O O VT Lead: Raheja, Raj D G O O 1' S/98 Vr Mgr: Schopfer, Don K O G O 1/20/98 1RC Chmn: singh, Anand K G O ti22/98 O
Date:
INVALID:
Date: 4/27/98 Printed 4/30/98 4.07::lul4#LUTION: Page 1 of 5
Northert Utilitie3 ICAVP DR No. DR-MP3-0980 Millstone Unit 3 Discrepancy Report RESOLUTION: Disposition:
NU has concluded that Discrepancy Report, DR-MP3-0980, has identified a condition previously discovered by NU which requires correction. PART 1- The Standard Review Plan Section 15.6.3 gives no guidance for the assumptions of plant performance in determining the mass releases to the environment. As such, the analysis methodology applied in the 1970's and early 1980's typically made an arbitrary assumption that the primary to secondary leak flow would be terminated in 30 minutes and no single failure was applied. This is what was used for developing the original Millstone Unit 3 FSAR analysis and is still documented in the FSAR.
In the licensing of Millstone Unit 3, the NRC challenged the arbitrary assumption of 30 minutes for termination of the primary to secondary leak and required the postulation of a single failure. This was requested for all the post-TMl Near Term Operating License (NTOL) plants. The NTOL utilities got together and formed a subgroup of the Westinghouse Owners Group (WOG) to respond to this question. In 1985, Millstone Unit 3 was allowed to startup pending resolution of the question through the WOG.
This created the dilemma of what to do with the content of Section 15.6.3 of the FSAR. The analysis in the FSAR was never approved by the NRC because of the open question.
However, there was no approved analysis that could be used to replace it. It was decided to leave the FSAR as is until resolution of the SGTR question. During that time new evaluations and analyses consistent with the WOG evaluations and analysis were j submitted to the NRC, and both the old FSAR analysis and the WOG evaluations and analysis were maintained.
The NRC resolution came on December 22,1994. NU's practice ,
was to submit FSAR revisions annually in January / February for l Unit 3. Since the SER was received in December, there was not l sufficient time to include it in the 1995 update.
The method of resolution of the NRC question posed another l dilemma for the FSAR update prepared in 1996. When the NRC l accepted the WOG methodology, it required confirmation of the !
response times assumed in the WOG analysis and a plant specific offsite dose analysis. The WOG analysis showed a l different single failure was limiting for offsite dose than for operator response. The limiting single failure for offsite dose is a j stuck open atmospheric dump valve on the affected steam generator and the limiting single failure for operator response (also called the margin to overfill analysis) is a failed closed atmospheric dump valve on an unaffected steam generator.
In responding to the NRC request for a plant specific offsite dose analysis, an evaluation was performed in 1988 based upon the offsite doses calculated for the reference plant. The appropriate offsite dose parameters were used as scaling factors so that the Millstone Unit 3 offsite doses could be bounded. However, a Pnnted 4/30/98 407:28 PM Page 2 of s
1 N2rtheart Utilities ICAVP DR No. DR-MP3-0980 Millstone unit 3 Discrepancy Report plant specific analysis that would provide the plant response in terms of RCS and secondary side pressures and temperatures was not done.
For the confirmation of the operator response times, however, the Millstone Unit 3 specific times were not bounded by the generic analysis. Thus, a Millstone 3 specific analysis was necessary. Westinghouse was contracted to perform the SGTR analysis with the failed closed atmospheric dump valve on the unaffected steam generator for Millstone Unit 3. Thus, plant specific analysis was available to provide the plant response in terms of RCS and secondary side pressures and temperatures.
The FSAR Section should contain the limiting analysis for offsite doses. However, no Millstone Unit 3 plant response information was available for this case, since the offsite doses were just scaled from the reference plant.
Plant response data was available for the limiting operator response case, but this was not appropriate for the offsite dose case since the limiting single failure is different. Thus, in 1995 it was decided to process a change to FSAR Section 15.6.3 that added a paragraph that discussed the operator response case and to leave the offsite dose evaluation unchanged. It was planned to contract Westinghouse to perform the offsite dose case of a SG TR with a stuck open atmospheric dump valve on the affected steam generator. When the results became available, the FSAR section 15.6.3 would be completely rewritten. Because of the Millstone Unit 3 shutdown in March 1996 and the 10CFR50.54(f) program, the schedule for the new offsite dose analysis was significantly delayed such that the analysis was not completed until very recently. The results are currently undergoing intemal review. The intemal review of the i analysis and initiation of the FSAR Change Request, as required, is being tracked to completion by ACR M3-96-0875. A/R i 96030845 is a Mode 2 restraint.
PART 2 The FSAR indicates that the operator controls the ruptured steam generator at the steam generator relief valve setting. The E-3 procedure directs the operator to control the ruptured steam generator at a pressure of 60 psi below the relief valve setting.
This is done to prevent the steam generator relief valve in the ,
ruptured steam generator from lifting to minimize radiological j releases. A lower SG pressure results in a lower RCS pressure, 1 since the RCS pressure is driven by the secondary side. In addition, RCS to secondary leakages are independent of SG pressure if in the critical flow regime or are a function of primary to secondary differential pressure, which is also controlled by primary flow. Therefore, a lower SG pressure may not result in i higher RCS to secondary leakages.
As explained above, the analysis discussed in the FSAR was never approved by NRC. The analysis recently completed by Westinghouse using approved methodology shows that the limitina sinale failure for the offsite dose is a stuck open Pnnted 4/30/98 4:07 29 PM Page 3 of 5
N:rthe=t Utilities ICAVP DR No. DR-MP3-0980 Millstone Unit 3 Discrepancy Report atmospheric dump valve on the affected steam generator. The limiting single failure for operator response is a failed closed atmospheric dump valve on an unaffected steam generator. E-3 was used in performing the new analysis, so that the analysis is consistent with the EOPs. Therefore, there is no inconsistency which could cause an under prediction of release from the RCS to the steam generator.
% Based on the bounding nature of the single failure assumptions and the use of appropriate offsite dose parameters as scaling ,
factors the items listed on this DR are considered a Significance level 4.
Conclusion:
NU has concluded that Discrepancy Report DR-MP3-0980, has identified a condition previously discovered by NU which j requires correction. Westinghouse has completed an analysis of '
the offsite dose case of a SGTR with a stuck open atmospheric dump valve on the affected steam generator. The resulic of this I analysis are currently undergoing review and when approved j appropriate changes will be made to the FSAR as rNulred prior to Mode 2. The analysis recently completed by Westinghouse using approved methodology shows that the limiting single failure for the offsite dose is a stuck open atmospheric dump valve on the affected steam generator. The limiting single failure for operator response is a failed closed atmospheric dump ]
i valve on an unaffected steam generator. Both single failure assumptions bound any previous potentialinconsistency between the analysis assumption of steam generator relief valve setting and the E-3 procedure. Completion of the analysis and any necessary updates are being tracked to completion by ACR M3-96-0875. A/R 96030845 is a Mode 2 restraint.
Based on the bounding nature of the single failure assumptions l and the use of appropriate offsite dose parameters as scaling I factors the items listed on this DR are considered a Significance level 4.
Attachments- ACR M3-96-0875 Previously identined by NU? (e) Yes O No Non Discrepant Condition?O Yes (e) No Resolution Pending?O Yes (5) No Resolution Unresolved?O Yes @ No Review initiator: Johnson, W. J.
VT Lead: Raheja. Raj D VT Mgr: schopfer, Don K 1RC Chmn: singh. Anand K Date: 4/27/98 sL comments: ICAVP review of the Westinghouse reanalysis of the steam generator tube rupture accident indicates that the radiological consequences are based on:
Printed 4/30/98 4 07:31 PM Page 4 of s
Northent Utilitie3 ICAVP DR N2. DR-MP3-0980 Millstone Unit 3 Discrepancy Report
- Millstone specific operator times to identify and isolate the faulted steam generator
- An assumed single failure consisting of a stuck open relief valve on the faulted steam generator
- An assumption of 30 minutes to isolate the relief valve These assumptions are appropriately conservative for the scenario described. ICAVP did not perform additional system analyses to identify other single failure modes. Discussions with NU personnel on 4/24/98 indicates that they periodically test their operator crews to measure their ability to respond to this accident. The results, which may differ from the operator response values used in the design basis, are reported to operations to demonstrate their ability to maintain the margin to overfill, and are not intended to change the design basis radiological analysis.
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N:rthert Utilities ICAVP DR NA DR-MP3-1002 Millstone unit 3 Discrepancy Report i Review Group: Acektent Mitigsten DR RESOLUTION ACCEPTED )
Discipline: Other Potential Operability lasue Discrepancy Type: Licensing Document g i System / Process: N/A Ow NRC Significence level: 3 Date faxed to NU: ,
Date Published: 2/19/96 I Discrepancy: Implementation of Leakage Control Program Per Technical Specification 96.8.4 Could Not Be Verified Descril dion: Millstone Unit 3 Technical Specifications 96.8.4 requires the establishment, implementation and maintenance of a program to l reduce leakage from those portions of systems outside I containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The l systems include the recirculation spray, safety injection, charging, and hydrogen recombiners. This program is required to include the following:
- 1) Preventative maintenance and periodic visual inspection requirements, and
- 2) Integrated leak test requirements for each system at refueling cycle intervals orless.
NU committed to this program in FSAR 9 5.2.5.5, and letters to the NRC dated October 1,1985 and November 6,1985. SSER, Revision 4,915.9.15 found the program as described above acceptable.
The implementation of this program, as described in Technical Specification 6.8.4, could not be confirmed.
Review Valid invalid Needed Date initiator: Peebles, W. R.
O O O 2/10/98 VT Lead: Rahoja, Raj D 0 0 0 2/10/98 VT Mgr: schopfer, Don K B O O 2/12/98 1RC Chmn: singh, Anand K O O O 2/t4/98 Date:
INVALID:
Date: 4/28/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1002, has been previously identified by NU, documented on CR M3-97-1936, and requires corrective actions.
In addition, this discrepancy was identified by the NRC during the ICAVP Safety System Functional Inspection (SSFI) of the emergency core cooling and safety injection functions of the Charging System (Out of Scope inspection Request No.321) and documented on CR M3-97-3218. NRC Inspection Report No. 50-423/97-206 dated December 5,1997 further addressed this issue.
Subsequently, during the ICAVP Accident Mitigation (Tier 2)
Inspection of the Containment Recirculation (RSS) and Service Printed 4/30/96 4 06:06 PM Page 1 of 3 t
Northert Utilities ICAVP DR No. DR-MP3-1002
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Millstone Unit 3 Discrepancy Report Water (SWP) Systems, Tier 2 Inspection Request No.135 was generated questioning NU compliance with Technical Specification $ 6.8.4. CR-M3-97-4588, a Level 1 CR, was generated in response to this inspection request and established corrective actions (CA) to resolve these issues. LER 97-61-00 was generated to identify regulatory commitments resulting from this issue and NU has committed to the following:
- 1. NU will perform a review of systems outside of containment that could leak highly radioactive fluids during a serious transient or accident, to ensure potential offsite dose consequences are within the design / licensing basis. This will be accomplished prior l to entry into Mode 4. (See CA#14 of CR M3-97-4588.)
- 2. NU will perform a leak test of each potential leakage path to establish valve baseline leakages and incorporate the results into the offsite dose assessment calculation. This will be accomplished prior to entry into Mode 2. (See CA#1-5,8-12 of CR M3-97 4588.) j
- 3. NU will prepare an overall MP3 leakage reduction program document and a program owner identified. Program elements determined to be inadequate will be addressed in accordance with the Millstone Corrective Action Program. This will be accomplished prior to 7/31/98. (See CA#13 of CR M3-97-4588.)
NU concurs with Sargent & Lundy that this discrepancy is a i Significant Level 3.
1
Conclusion:
i NU has concluded that the issue reported in Discrepancy Report, DR-MP3-1002, has been previously identified by NU, documented on CR M3-97-1936 and requires corrective actions.
In addition, this discrepancy was identified by the NRC during the ICAVP SSFI of the emergency core cooling and safety injection functions of the Charging System (Out of Scope Inspection Request No. 321) and documented on CR M3 3218. NRC inspection Report No. 50-423/97-206 dated December 5,1997 further addressed this issue. Subsequently, during the ICAVP Tier 2 Inspection of the RSS and SWP Systems, Tier 2 Inspection Request No.135 was generated questioning NU compliance with Technical Specification 9 6.8.4.
The approved corrective actions for CR M3-97-4588 will ensure performance of the following;
- 1. Review systems outside containment that could Mak highly radioactive fluids during a serious transient or accident to ensure potential offsite dose consequences are within the design licensing basis.
- 2. Leak test each potential leak path to establish valve baseline leakages and incorporate the results into the offsite dose assessment calculation.
- 3. Prepare an overall MP3 leakage reduction program document and identify a program owner. Program elements determined to be inadequate will be addressed in accordance with the Millstone Corrective Action Program.NU is committed to complete item i by entry into Mode 4 ltem 2 by entry into Mode Printed N3098 to8:00 PM Page 2 of 3
N:rtheart Utilities ICAVP DR N3. DR-MP3-1002 Millstone Unit 3 Discrepancy Report i 2, and item 3 by 7/31/98.
NU has concluded that this discrepancy is a Significant Level 3.
Previously idenufied by NU7 O Yes (9) No Non Discrepant Condition?O Yes (y) No Resolution Pending?O ves @ No Resolution unresolved?O ve. @ No Review initiator: Peebles, W. R.
- VT Lead: Rahoja, Raj D VT Mgr: schopfer, Don K IRC Chmn: singh, Anand K I Date: 4/28/98 SL Comments: The earliest date of discovery provided in the documentation is June 25,1997. This is after the cut off date for discovery for items related to ICAVP. Therefore, ICAVP does not agree that NU had previously discovered this issue.
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i Nc& ext Utilitie3 ICAVP DR N2. DR MP3-1070 Millstone Unit 3 Discrepancy Report Review Group: System DR RESOLUTION ACCEPTED Review Element: System Design Diecipline: I & C Design Discrepancy Type: Licensing DocM Ow SystenVProcess: SWP @ No NRC Significance level: 4 Date faxed to NU:
Date Published: 2/28/98 Discrepancy: SER Section 7.3.2.8 inconsistent with isolation of nonsafety-related Service Water piping.
Description:
SER Section 7.3.2.8 states that on receipt of a safety injection signal or loss-of-power signal, the water supply lines to the nonsafety-related equipment are isolated. Per the below listing of Service Water isolation valves and drawings, the nonsafet}-
related piping isolation valves are isolated by a Containment Depressurization Actuation signal or a Loss of Power signal, but not a safety injection signal.
The following drawings depict the valve position required on receipt of the automatic initiation signal:
SIGNAL SERVICE VALVE LCS DRAWINGS
= = = = = = = = = = = = = = = = = = = = = = = ====
CCP hx 3SWP*MOV50A,B +C+ EM-1338-34 LSK-9-1G Rev8 TBCCW 3SWP*MOV71A,B CC+ EM-133B-34 LSK-9-7D,E Rev9,8 Circ Lube 3SWP*MOV115A,B C C + EM-133D-23 LSK-2-1.1E Rev 10 Chlor 3WTC*AOV25A,B NC+ EM-133C-16 LSK-9-10G Rev 12 LSK-9-10L Rev 4 L = Loss of Offsite Power; C = CDA; S = SIS C = Close; N = No Change; + = Remains Open Review Valid invalid Needed Date initiator: DeMarco, J. O O O 2/21/98 VT Lead: Neri, Anthony A O O O 2/21/98 VT Mgr: Schopfer, Don K O O O 2/21/98 IRC Chmn: Singh, Anand K O 2/2ss8 O O Date:
INVAUD:
Date: 4/28/98 RESOLUTION: Disposition:
NU has concluded that the issue reported in Discrepancy Report DR-MP3-1070, has identified a condition not previously discovered by NU which requires correction. The approved corrective action plan for CR M3-98-1614 (attached) will provide technical justification for the current design basis, submit a docketed letter to the NRC detailing the incorrect statement in the SER, and provide technicaljustification of the existing MP3 service water system design post startup.
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1 Northert UtilKie3 ICAVP DR No. DR-MP3-1070 Millstone Unit 3 Discrepancy Report i l
Conclusion:
NU has concluded that the issue reported in Diecrepancy Report
)
DR MP3-1070, has identified a condition not previously discovered by NU which requires correction. The approved '
corrective action plan for CR M3-98-1614 (attached) will provide technical justification for the current design basis, submit a docketed letter to the NRC detailing the incorrect statement in the SER, and provide technicaljustification of the existing MP3 service water system design post startup.
Previously klentified by NU7 O Yo. (9) No NonDiscrepentCondition?O ve. (*) No !
Rete *Alon Pending70 ve. @ No Re.oiotion unr..oiv.d70 ve. @ No Review in".': *.or: DeMarco, J.
VT Lead: Neri, Arthony A B O O -
VT Mgr: Schopfer, Don K O **
1RC Chmrt: cingh, Arund K Dete: j i SL CommerAs:
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Northert Utilities ICAVP DR N2. DR-MP3 4294 Millstone Unit 3 Discrepancy Report l l
Review Group: System DR RESOLUTION REJECTED I I
Review Element: System Design Discipline: Piping Design Discrepency Type: ceicunstion System /Procese: SWP g
NRC Significence level: 4 I Date faxed to NU:
Date Published: 1o/1o/97 I
Discrepency: Lack of documentation for qualification of tie rods l
Description:
In the process of reviewing the following documents, (i) Pipe Stress Calculation 12179-NP(B)-X1900 Rev. 3 CCN's 1 to 3 (ii) Pipe Stress Calculation 12179-NP(B)-X53900, Rev. 5 (iii) Pipe Stress Calculation 12179-NP(B)-X53901, Rev. 6, CCN's 1 to 3 we noted the following discrepancy:
Background:
According to (i): Expansion Joint Data Sheet for Joint Mark No.
3SWP*E1B, at Nodes 501 - 511, shows the tie rod load for the worst case Thermal condition to be 191,716 lbs. The actual tie rod load should be 19,716 lbs, which is the load at NP 511, the attachment point between the expansion jo!at and Strainer 3SWP*STR1B (Inlet). Tie Rod loads for all other load cases correspond to the load at the Strainer inlet NP 511.
Discrepancy:
The thermal condition load for expansion joint (3SWP*E18) tie rods is numerically incorrect.
Tie rod loads are documented in pipe stress calculations, but no documentation is provided for the qualification of tie rods for these loads. This is a Generic discrepancy applicable to all the cases reviewed where expansion joints with tie rods are used, see for example (i to iii).
Review Valid invalid Needed Date initiator: Prokesh, A.
O O O s/2397 VT Leed: Nerl, Anthony A O D D sr24/s v VT Mgr: Schopfer, Don K B O O or '87 IRC Chmn: Singh, Anand K O O O tor 2ro7 Date:
INVALID:
Date: 4/29/98 RESOLUTION: Response ID: M3-IRF-00841 Disposition:
Printed 4/30/96 4:0948PM Page 1 of 3
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Northeast Utilities ICAVP DR No. DR-MP3-0294 Millstone Unit 3 Discrepancy Report NU has concluded that Discrepancy Report, DR MP3-0294, 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 attachmer t 11 of U3 PI-20 criteria and found to have no operability or reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. Condition Report M3-98-2026 will be closed out to Bin CR M3-98-0138. The issues identified in DR-MP3-0294 are addressed as follows:
The qualification of ali MP3 Tie Rods is found in the attached
- Millstone Unit No. 3 Expansion Joint Modeling and Qualification Report" supplied by Stone & Webster and Senior Flexonics. This report is tied to EWR No. M396061. The remaining issue is the correction of the typographical error associated with the tie rod oad for the worst case thermal condition for EJ 3SWP*EJ1B.
The load is listed at 191,716 lbs and it should be 19,716 lbs. This is a typo error only. This has no impact on the calculation as the typo error was not carried through any calculation.
Bin CR M3-98-0138 corrective actions will correct calculation 12179-NP(B)-X1900 post startup.
Conclusion:
NU has concluded that Discrepancy Report, DR-MP3-0294, 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 f attachmer,! 11 of U3 PI-20 criteria and found to have no 1 operability or reportability concems and meets section 1.3.2.e of U3 PI 20 deferral criteria. Condition Report M3-98-2026 will be closed out to Bin CR M3-98-0138. The issues identified in DR-MP3-0294 are addressed as follows:The qualification of all MP3 I Tie Rods is found in the attached ' Millstone Unit No. 3 Expansion Joint Modeling and Qualificatior. Report" supplied by Stone & Webster and Senior Flexonics. This report is tied to EWR No. M396061. The remaining issue is the correction of the typographical error associated with the tie rod load for the worst case thermal condition for EJ 3SWP*EJ18. The load is listed at 191,716 lbs and it should be 19,716 lbs. This is a typo error only. This has no impact on the calculation as the typo error was not carried through any calculation. Bin CR M3-98-0138 corrective actions will correct calculation 12179-NP(B)-X1900 ;
post startup. j Attachments:
- 1. Condition Report M3-98-2026
- 2. Millstone Unit No. 3 Expansion Joint Modeling and Qualification Report Previously klontifled by NU? O vos it) No Non Discrepant Cond6 Hon?O vos fGi No Resolution Pendeng?O ve. @ No ResoluuonUnresolved?O vos @ No Review l
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1 Northert Utilities ICAVP DR No. DR-MP3-0294 Millstone Unit 3 Discrepancy Report initiator: Prakash, A.
VT Lead: Neri. Anthony A VT Mgr: schopfer, Don K 1RC Chmn: segh. Anand K l Date: 4/29/98 SLComnents The DR addressed two issues:
(i) typograpt,ical error in tie-rod loads for EJ 3SWP*EJ1B
)
(ii) generic issue of lack of documentation for tie rod qualification.
Issue (I) has been addressed thru Bin CR M3-98-0138. This is acceptable.
Issue (ii), is addressed by reference to
- Millstone Unit No. 3 Expansion Joint Modeling and Qualification Report" supplied by )
Stone & Webster and Senior Flexonics. This report was supposed to be attached with tne response. What is actually attached to the response is a letter from Stone & Webster to NU, dated July 14, 1997, on the subject of ' Expansion Joint Modelling and Qualification", and a Millstone Unit 3 Tied Expansion Joint Database.
]
This letter transmits a database for tied expansion joints, and provides recommendations for future tied expansion joint computer modelling and qualificatio i, and describes the methods used historically by S&W to model and qualify tied expansion joints. It does not provide the qualification of all MP3 Tie Rods as stated in NU's response. Therefore, NU's response to issue (ii) is unacceptable.
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