ML20199H044

Forwards 23 Discrepancy Repts Identified During Review Activities for Independent CA Verification Program. Discrepancy Repts Which Have Been Reviewed & Accepted & Reviewed But Not Accepted Also Encl

ML20199H044
Person / Time
Site:	Millstone
Issue date:	11/21/1997
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9711260003
Download: ML20199H044 (51)

Text

.

d[%-

,b' Sar goM Lundy"*

%W Don K. Schopter Vice Pres: dent 312 ?69-f478 November 21,1997 Project No. 9583100 Docket No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington. D.C. 20555

'I have enclosed the following twenty three (23) discrepancy reports (DRs) identified during our review activities for the ICAVP.

These DRs are being distributed in accorrlance with the Communications Protocol, PI-MP3-01, DR No. DR-MP3-0173 DR No. DR-MP3-0619 DR No. DR-MP3-0178 DR No. DR-MP3-0623

{\\

DR No. DR-MP3 0339 DR No. DR-MP3-0628 DR No. DR-MP3-0499 DR No. DR-MP3-0637 DR No. DR-MP3-0517 DR No, DR-MP3-0638 DR No. DR-MP3-0563 DR No. DR-MP3-0656 DR No. DR-MP3-0590 DR No. DR-MP3-0657 DR No. DR-MP3-0591 DR No. DR-MP3-0658 hog DR No. DR-MP3 0601 DR No. DR-MP3-0659 DR No. DR-MP3-0605 DR No. DR-MP3-0662 i

DR No. DR-MP3-0611 DR No. DR MP3-0664 DR No. DR-MP3-0665 I have also enclosed the following two (2) DRs for which the NU resolutions have been reviewed and accepted by S&L.

DR No. DR-MP3-0099 DR No. DR-MP3-0156 9711260003 971121 ~

l lflflflllflflllllflllflll[l'lI PDR ADOCK 05000 *23 P

PDR

- 55 East Monroe Street

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

I United States Nuclear P ator) Commission November 21,1997 Document Control Desk Project No. 9583-100 Page 2 I have also enclosed the following two (2) DRs for which the NU resolutions have been reviewed but not accepted. S&L comments on these resolutions have been provided.

DR No. DR-MP3-0020 DR No. DR-MP3-0035 Please direct any questions to me at (312) 269-6078.

Yours very truly, 1

MN; i

D.K.S opfer Vice President and ICAVP Marager 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 mhvptwr97aril21 a &w o

Northeast Utilities ICAVP DR No. DR-MP3-0173 Millstone Unit 3 Discrepancy Report Review Group: systern DR VALID Potential Operability lasue Diecipline: 1 & C Desgn O vee Discrepancy Type: Calculation (e') No systemProcess: SWP NRC significance levoi: 4 Date faxed to NU:

Date Putnished:

Discrepancy: Discrepancy of data in calculation SP 3SWP-31 and Various

~

refersace documents identified in calc.

==

Description:==

The purpose of this calculation SP-3SWP-31 Rev 1,is to determine low NPdH setpoint for pressure switches 3SWP*PS150A,B. These pressure switches prohibit operation of tlee control building air conditioning booster pumps 3SWP*P2A,8 if suction pressure is too low.

During the review of Calculation SP 3SWP 31, the fo!'owing was discovered:

1. On page 7, Conclus,lon section applies calculated Total Error value of +/- 1.7 psig va ue from page 6, around the setpoint value of 3.2 psi. Based on this low actuation setpoint is shown to be at 1.5 psig. This is below the minimum NI SH requirement of 32 psig (or 7 feet) required by the pump manufacturer as identified on page 3. The Responsible Power System Engineer review note on page 7 Ir,dicate that the low actuation setpoint is acceptable. However, no justiftcation for this acceptance is provided.

Review Valid invalid Needed Date I..attator: Hirda, R-0 0

0 11'12S7 VT Lead: Nort, Anthony A g

Q

[

11/13/97 VT Mgr: schopfer, Don K G

O O

11'I'S7 IRC Chmn: skgh, Anand K O

O O

it'SS7 D.i.:

INVALID:

Date:

RESOLUTION Previously identsfied by NU7 O Yes sG) No Non Discrepent Condstion?Q ves f No Resolution Pending70 ve.

<*t No Re.oiution unre.oiv.d70 Yes

$2 No Review Acceptable Not Acceptable Needed Date R.

O O

VT Lead: Neri, Anthony A VT Mgt: schopfer, Don K IRC Chmn: singh, Anand K Date:

sL Conwnents:

Pnnted 11/20S7 3.s3 34 PM Page 1 of 1

e Northeast Utilities ICAVP DR No. DR MP3-0178 Millstone Unit 3 Discrepancy Report Review Group: Systern DR VALID Review Element: System Desgi p

g,,

g, Diecipline: I & C Design O Ya D6screpancy Type: Calculaten

%' No SyeserWProcess: sWP NRC Signincance level: 4 Date Faxed to NU:

Date Published:

D6ecrepency. SP-3SWP 32 calculation data discrepancy Dacripuoa: The purpose of calculation SP 3SWP 32, Rev. O, is to determine setpoint values for swiiches 3SWP*PS152A, B. 3SWP*PS152A, B control MCC & Rod Control Area Booster pumps 3SWP*P3A and B based on a positive indication of supply pressure from the main service water pumps.

1. Per PDCR MP3-91-068 & E&DCR T-C 03843, the installed ninge for switch 3SWP'PS152A is 1.5 to 36psig. E&DCR T-C-07300 supplemented E&DCR T-C-03863. E&DCR T C-07300 did not reflect the range change. This is discussed in the ACR M3-961145. ACR M3-96-1135 discusses revision to the setpoint calculation SP-3SWP 32 during design basis event. The celculation in its present form is doqe for the range of 1 to 18 psig, which is the span for switch 3SWP*PS1528. Since the calculation was performed using the lower range (1 - 18 psig),

the calculated inaccuracy is not conservative with respect to switch 3SWP*PS152A.

Hence, on page 7, the dP1 component calculated is valid for 3SWP*PS152B only. This v.ill have an impact on all other calculated values for the 152A switcls.

2. In the static head calculation portion of the calculation (page 3 of the calculation),instrumant elevation of 45.71'is used. Per reference 4 the switches are located at elevation 45'-10* (this translates in to elevation of 45.83').

Review Valid involid Needed Date initiator: Hindia. R.

O O

O

"'12S7 VT Lead: Nerl. Anthony A O

O O

111S7 VT Mgt: schopfer. Don K O

O O

1'1*S7 IRC Chmn: singh, Anand K G

O O

11'1SS7 Date:

INVALID; Date:

RESOLUTION:

P$'vEtkidentined by NU? O Yes @ No Non Discrepant Condition?O Yes t No Resolution Pending?O Ye.

4) No Resolution Unresolved?O Ye.

+ No Review initiator: Hedia. R.

VT Lead: Nort. Anthony A VT fngt: Schopfer, Don K Printed 11/2G97 3 s4 24 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP3 0178 Millstone Unit 3 Discrepancy Report O

O IRC Chmn: Sh0h. Anand K O

O O

Date:

SL Conwnents:

I 8

3 5

i Pnnted 11/2097 3 54 35 PM Page 2 of 2

t Northeast Utilities ICAVP DR No. DR-MP3-0339 millstone unit 3 Discrepancy Report Review Group: System DR VALID Re Ew: Sporn Dwgn Potential Dperetnlity issue Diecipl6ne: I & C Dwgn O va Discrepancy Type: Calculataan (5) No SystenVProcese: QSs

~

NRC &lgnificance level: 4 Date faxed to NO:

Date Published:

Descrepancy: Calculation SP 3QSS 1 Discrepancy

==

Description:==

Background:

Per text of Calculation SP 3OSS-1, Rev 1 on page 3, the RWST temperature is maintained between 46 and 48 degF and the High Temperature Alarm is set to 49 degF increasing, Per Section 1,1 of Operating Procedure OP3353.MB2A, Rev 0, the alarm shall ue set to greater than 49 degF. The Master Setpoint index identifies the alarm setpoint as 49 degF increasing. The PMMS Data Sheet, which references the subject calculation, identifies the alarm setpoint as 49 degF.

Discrepancy; Per calculation results on page 4, the High Temperature Alarm setpoint is specified to be 48 degF increasing which is inconsistent with the above-referenced desigr, basis documents.

The Refueling Water Recirculation Pumps start and stop automatically at 48 and 46 degF, respectively. If the high temperature alarm is set to 48 degF, it may alarm indicating a temperature controlloop problem. Setting the high temperature alarm to 49 degF will prevent an alarm from falsely indicating equipment problems and will allow the operator ample time to investigate the problem before the RWST temperature reaches the Tech Spec high temperature limit of 50 degF, R$v6ew Valid Invaled Needed Date Instaator: Pineias, H-0 0

0

" o'S7 VT Lead: Nort, Anthony A 0

0 0

t i'1 S7 VT Mgr: schopfer, Don K O

O O

"S7 IRC Chmn: Sngh, Anand K O

O O

"SS7 Date:

INVAllO:

Date:

RESOLUTION:

Prev 6ounty identitled by NU7 Q ves S ' No Non Discrepent Condition?O ves it) No Resolution Pendmg70 ves + No ReMut% Un'**d?O vu

6) No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgt: Schopfer, Don K IRC Chmn: S6ngh, Anand K Pnnted 11/2G97 3 5e 03 PM Page 1 of 2

- - ~

Northeast Utilities ICAVP DR No. DR MP3-0339 Millstone unit 3 Discrepancy Report SL Comments:

F.inted 11/20S7 3 58:13 PM Page 2 of 2 4

e - -

Northeast Utilities ICAVP DR No. DR-MP3-0499 Millstone Unit 3 Discrepancy Report Review Group: system DR VALID Y' "

Potential OperatWhty issue Discipime: I & C Design Om Discrepancy Type: Orswing M No SysterWProcess: Rss

~

NRC SigneScance level: 4 Date faxed to NU:

Date Putnished.

Diecrepancy: inconsistent logic between drawings LSK 2711G and LSK-2711F,w/ respect to bypass alarms DeecrW: Logic Diagrams 12179-LSK 27-11G, Revision 9 and 12179-LSK-2711F, Revision 9, show the logic for the containment recirculation spray system bypasted alarm and the logic for the containment recirculation inject system bypassed alarm, respectively.

Notes to FSAR Figure 6.31 identify the emergency core coolli system (ECCS) modes of operation as " injection", " Cold Leg Recirculation", and " Hot Leg Recirculation" No containment recirculation system (RSS) modes of operation are defined in the FSAR. FSAR Section 6.2.2 and Notes to FSAR Figure 6.31 identify the RSS engineered safety features functions to be containment spray eM recirculation of containment sump water through the reactor core for emergency core cooling.

Consequently, the alarm entitled," Containment Recirculation inject System Bypassed",is confusing. The function of this alarm is to alert operators when a RSS train is unavailable for recirculation ci the sump contents through the reactor core, A more appropiate alarm titb might be, " Emergency Core Cooling Recirculation System Bypassed".

Furthermore, the logic for the containment recirculation inject system bypassed alarm shows that the alarm is annunciated for breaker to valve 3RSS*MOV20A open, regardles of the valve position.' If valve 3RSS*MOV20A is closed, the RSS train is not bypassed for flow into the reactor core, regardless of the condition of the valve breaker The logic for this alarm should be similar to the logic for the alarm entitled, "Contalment Recirculation Spray System Bypassed", where the alarm is annuncleted for a dual condition of 3RSS*MOV20A open and valve not futiy opened. The only difference to the two alarms should be that in one case the logic is for valve is not fully closed and in the other case the the logic is for valve is not fully open.

The logic for valve 3RSS*MOV23A on drawing 12179-LSK 11F should be similar the logic for the same valve on drawing 12179-LSK-11G. The reasoning for this statement is the same as that applied for valve 3RSS*MOV20A.

Finally, this concem applies to parallel valves 3RSS*MOV238,C,D and 3RSS*MOV208,C,0.

Review Valid Invahd Needed Date Ir.itiator: Feinooid, D. J.

O O

O 11' ' S 7 VT Lead: Nort. Anthony A y

[

]

11/17S 7 ser u y. % w % v mg.n Pnnted 11/2o/97 4 00:24 PM Page 1 of 2

l l

1 1

Northeast Utilities ICAVP DR No. DR-MP34499 Millstone unk 3 Discrepancy Report VT Mgr: Schopter, Don K 11/17/97 IRC Chmn: Singh, Anand K g

1if20/97 Date:

INVAUD; Dele:

RE80LU110N:

Prev 6ously identified by NU7 O Yes @ No Non Discrepent Condation?U Yes tS) No Resolution Pend 6ng?O Yes @ No Resolution Unresolved?O Yes

'*l No

~

8teview Acceptable Not Acceptable Needed Date VT Lead: Nort, Arthony A VT Mgr: Schopfer, Don K

1. X: Cimi: Sbgh, Anend K Date:

SL Commente:

~'

Printed 11/2G97 4 00.35 PM Page 2 of 2

F Northeast Utilities ICAVP DR No. DR-MP3-0617 i

Millstone unit 3 Discrepancy Report Review Grcup: syotem DR VAUD Revh EW; Sporn %

Potential Operatnlety lasue Diecipline: Mechancal Design O va Diacropency Type: Calculaten

($) No SysterrWProcess: SWP NRC Significance level: 3 Date faxed to NU:

Date Pubilehed:

Discrepancy: Severalinconsistencies were found in Calculation SDP SWP-01370-M3 rev.10.

Descripuon: Calculation SDP-SWP-01370M3, Revision 10, d ated 5/23/97.

This calculation is the stress data package for the service water system.

On page 29 of the stress data package, the service water design pressure I:; noted as 100 psig. However, calculation 714P(T) determines the service water design pressure to be 101 psig.

On page 29 of the calculation a value of 145 psig is lis'ed in the temperature and pressure table, with calculation, P(T) 1125 as the source reference. Calculation P(T) 1125 lists a value of 132.7 psig which appears on page 2. Therefore, there is a discrepancy between the value used in the stress data package and the referenced calculation.

On page 29 of the calculation, for 3HVR*ACU1 A/B discharge lines reference MCE-SA 93 362 is cited for a temperature of 98'F. This reference does not show nor discuss the 98'F value.

On page 29 of the calculation, the temperature of 125'F was noted for the discharge piping of 3CCP*E1 A/B heat exchanger.

This temperature was referenced from ER 96-0326. This document was requested from NU and was noted as not in NU system by IRF MP3-0496.

These discrepancies could impact the stress and piping calculations that use this information from the stress data package.

Review Valid invalid Needed Date initiator: Donne. B. J.

O O

O 1' 3S7 VT Lead: Nort. Anthony A g

Q O

11/17/97 VT Mgt: Schopfer, oon K O

O O

$ 17/S7 IRC Chmn: Singh, Anand K O

O O

tii2as7 Date:

INVAUD:

a== -

Date:

RESOLUTION:

Previously identified by Nu? O Yes @ No Non Discrepent Condition?O Yes t No Pdnted 11/2a97 3 59 37 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR MP3-0617 Millstone Unit 3 Discrepancy Report Resolution Pendeng7() Yes

40) No Resolution Unresolved?() Yes

'9) No Review Acceptable Not Acceptable Needed Date VT Lead: Nort, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: Sag Anand K

-a,

SL Corrments:

i l

I Printed 11/20.97 3 59 48 PM Page 2 of 2 l

\\

Northeast Utilities ICAVP DR No. DR-MP3-0663 Millstone Unit 3 Discrepancy Report Review Group: Operatens & Maintenance and Toshng DR VALIO Potential Operab6lity issue Diecipl6ne: Operatens Ow D6ecrepancy Type: Ucenssng Document M No SysternProcess: sWP NRC Significance levet: 4 Date faxed to NU:

Date Published:

Ducrepancy: Service Water Pump Testing inconsistent with FSAR Requirement

==

Description:==

Service Water Pump Testing inconsistent with FSAR Requirement FSAR Section 7.3.1.1.5 states:

"The service water system is periodically tested in accordance with the Technical Specifications.

"This testing will consist of manually starting the pump during normal surveillance of the system or the breaker for the pump will be in the test position. Once the pump is running or the breaker is in the test position, the AUTO start and tripping is verified using the emergency generator load sequencer with safety signals generated intemally or extemally to the sequencer."

The following two surveillances that test the operation of the S

service water pumps were reviewed to confirm that the above requirements were being satisfied, SP 3626.4, " Service Water Pump 3SWP*P1 A Operational Readiness Test * (including checksheet OPS Form 3626.41) and SP 3646A.18, " Train B ESF With LOP Test (IPTE)". No evidence could be found to confirm that the requirements were being met. Neither procedure documents a manual start of the pump. Page 2 of SP 3626.4 (Basis Document edition) s'ates in the Basis information block on page 2 that:

"This procedure provides for two sequencer starts and eliminates the manual start from the control room. No written requirement for a manual start has been found checking the FSAR and the ISI manual. The conclusion has been made that a manual start is not necessary since the pumps are started for other reasons during the month, if a manual start is needed, credit can be taken for pump C in this procedure and for pump A..) 3626.6, since the pumps are started to switch lineup."

Our interpretation of the FSAR requirement is to manually start the pumps so that the AUTO trip function and sequencer loading on the EDG can be venfied. Both procedures test the AUTO start of tne pumps on the load sequencer but do not test the AUTO trip function.

Additionally, a review of the OPS forms associated witn these procedures indicate that change of pump operating states are not I

documented.

Pnnted 11rM7 4 01:19 P6 Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0563 Miiistone Unit 3 Discrepancy Report it was also noted that the FSAR requirement that the pumps be started manually or that the breaker for the pump be in the test i

position are not equivalent actions. The equivalent action to a manual pump start would be to placa the breaker in the test position and close the breaker.

The testing currently performed does not adequately demonstrate that the FSAR requirements are being satisfied.

Review Vaad invalid Needed Date init6etor: Tamlyn, Torn 8

O O

cv31/S7 VT Lead: Bees, Ken 8

O O

1(v31/S7 VT Mgr: schopfer, Don K O

O O

SS7 1RC Clunn: singh, Anand K O

O O

1 '1SS7 Date:

INVAUD; Date:

RESOLUTION:

Peviously identified by NU7 O Yes (#1 No Non Discrepent Condenon?O Yes sel No Resoluuon Pend 6ng?O ve.

@ No Resoluuon unresolved?O v..

@ No Review Acceptable Not Acceptable Needed Date gg, O

O O

VT Leed: Bess. Ken VT Mgr: schopfer Don K IRC Chmn: Singh, Anand K

_e st Comments:

Printed 11/2097 4 01:31 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3 0690 Millstone Uriit 3 Discrepancy Report Rev6.w Group: syeiem DRvAuD Roh E M :s W W Potential Opetabilty issue Diecipline: Electreat Design gg D6ecrepancy Type: Calculation

@ No System 9tocess: DGX NRC Significance level: 4 Date faxed to W:

Date Published:

Descrepancy: Metor Control Center Circuit Breaker Coordination Calculations 848C and 849C Dacr*Pt6on: These calculations verify the contdination required to maintain selective trippin0 on motor control centors 3EHS*MCC1 A1, 3EHS*MCC181,3EHS*MCC183, and 3EHS*MCC1B4, Both calculations du not include a list of references. This makes it difficult to verify the input data to the calculation. The citation of input data sho.ald t.e strengtheried.

In addition, the following comments apply only to Calculation 849C:

The manufacturer's time overcurrent characteristic curve for the ITE FJ molded case circuit breaker shows somewhat longer maximum tripp;ng times at the upper end of the thermal elerrent tripping characteristic. As a result, coordination batween the FJ molded case circuit breaker and the upstream switchgear may be lost at the upper range of the thermal overload characteristic of the FJ molded case circeit breaker.

!TE lisied the short circuit rating of the FJ molded case circuit breaker as 18,000 amperes symmetrical at 480 volts. However, the coordination curves are drawn to a maximum short circuit current of 22,000 amperes. The coordiriation curve of the type FJ molded case circuit breaker should be redrawn so that its curve ends at 18,000 amperes, since its interrupting time is undefined at higher current levels.

Calculation NL 051 indicates that the short circuit current at motor control centers 3EHS*MCC t83 and 3EHS*MCC184 are less than 18,000 amperes, so the molded case breakers are operated within their interrupting capacity. Therefore, the sighnificance level of this disc.'epancy is level 4.

Review Valid invalid Needed Date hdtlator: Bloethe, G. Wilham O

O O

11 5 S7 VT Lead: Neri, Anthony A O

O O

11'1S7 VT Mgt: schopter, Don K O

O O

11'17'97 IRC chmn: singh, Anand K O

O O

1 SS7

<>ai.:

INVAUD:

i Date:

l RESOLUTION Prev 6ously identitled by NU? O Yes (9) No km Discrepent Conddion?Q Yes Jf) No

?

Printed 11/2097 4 02.25 PM Page 1 of 2

i l

Northeast Utilities ICAVP DR No. DR-MP3-0590 Millstone Unit 3 Discrepancy Raport Resolution Pend 6ng7L) Yes

'9) No Resolution Unrvoolved70 Yes ? No Review A-:-? t '

Not Acceptable Needed Date gg VT Lead: Nort. Anthony A 0

0 0

vr ur, scnover. Don x RC Chmn: $@. Anand K

- e:

St Comments:

4 e

s I

Printed 11/2097 4 02.36 PM Pg 2 of 2

)

l l

Northeast Utilities ICAVP DR No. DR-MP3-0691 Millstone unit 3 Discrepancy Report Review Group: Pivy. i.. :c DR VALID Potential Operabilety issue D6ecipl6ne: Other O=

D6screpen.:y Type: 0 & M & T Procedure 4g SystemfProcess: N/A

~

NRC Signifncance level: 4 Date faxed to NU:

Date.**ublished:

D6screpancy. Technical Errors in Past Procedure Changes DescitPt6on* Procedure SP 3601F.5, Revision 3, effective 6/17/92, titled "Rtactor Coolant Valve Operability" and OPS Form 3601F.5-3, Revision 2, effective 10/28/93, titled "RCS Check Valve Refueling Outage Stroke Testing" were reviewed as part of the assessment of the technical adequacy and compliance with the licensing bases of past procedure changes.

Both procedures contain technical errors which have not been corrected in later procedure revisions as viewed on WoridView, nor were any corrective action documents or pending changes found which are tracking the correction of these procedures.

1. The note following paragraph 7,1 of SP-3601F.5 states that the plant must be in Mode 6 in order to test valves 3RCS*V26 and 3RCS*V102. Table 1.2 of the Technical Specifications defir:ss Mode 6 in part as the reactor vessel head closure bolts less than fully tensioned or ths reactor head removed.

Relief R 1, added to the inservice Test Program (IST) Program on 5/20/95, states under "Altemate Testing" for these valves:

"The valves will be full stroke exercised during refueling outages when the reactor closure head is removed." The reason given in R 1 for not fully stroking the valves at cold shutdown is that doing so risks overpressurizing the reactor coolant system.

Therefore, SP-3601F.5 does not agree with R-1 insofar as it allows these valves to be fully stroked with the head on the reactor and the bolts detensioned.

Paragraph 3.4 of SP 3601F.5 refers to the 1980 Edition of ASME Section XI with the Winter,1480 Addenda. The IST Program is based on the 1983 Edition with the Summer,1983 Addenda.

2. SP 3601F-5, page 3, shows the te" position for 3SlH*V19 as open whereas the IST Program shows it as closed. Page 3 also shows the test position of 3SlH'V100 as closed whereas the IST Program shows it as both open and closed.

Review Val 6d invalid Needed Date initiator: sheppard. R. P.

Q

[~]

11G97 VT Lead' Ryan. Thomas J B

O O

ins 7 VT Mge: Schopfer, Don K Q

O O

11/10/97 IRC Chmn: singh. Anand K G

O O

' '1SS7 Date:

INVALID:

Printed 11/20,97 4 06.00 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0591 Millstone Unit 3 Discrepancy Report Oste:

RESOLUTK)N:

Prev 6ously idervtined by NU? O Yes @ No Non D6screpard Condition?O yes in) Na Resolution Ponding?O vos @ No ResolutionUnresolved?O vos

<!) No Review Acceptable M Acceptable Needed m,. g VT Lead: Ryan, Thomes J VT Mgt: Schopfer, Don K IRC Chmn: Singh, Anand K Date:

SL Coewnents:

l l

l Printed 11r&S7 4 OC 09 M Page 2 d 2 i

j

Northeast Utilities ICAVP DR No. DR-MP34601 Millstone Unit 3 Discrepancy Report Rev6ew Group: tretem DR VALID

==

Pote.ge-,,s.ue D6ecrepancy Type: ceiculeton

@ No SysterrVProcess: DGX NRC signincence level: 3 Date FAXe:S to NU:

Date Published-06ecrepancy: SettinQ of Bus Tie Overcunent Relays for Buses 34C and 34D (Calculation 418CA)

==

Description:==

This calculation determines the settings of the overcurrent relays protecting the bus tie from the Class 1E 4160 voit buses. It also verifies that these relays coordinate with the main feed relays and with the relays of downstream loads.

The setting of the bus main breaker is based on a load current of 3123 amperes. However, the circuit breaker and bus are only rated 3000 amperes and the cable between the circuit breaker and the transformer has an ampacity of less than 2900 amperes according to page 4 of Calculation NL-026. The load current used for selecting the taps of the main and tie overcurrent relays should be consattant with the ratings of the switchgear and interconnecting cable.

The maximum loading on the main breaker is about 2740 amperes and the maximum loading on the tie breaker is about 2120 amperes based on the loadings in Calculation NL-38 and adjusting the current to account for operation at the analytical limit voltage of 3671 volts. Therefore, the equipment is l

adequately sized and it is only necessary to change the relay I

setting to use the actual equipement rating as a basis.

The cooMination curve on Revision 1 of page 41881 shows that the relay used to protect the load center transformer is a General Electric type IAC '3. However, the load tabulation (page GM 03.413) shows this relay as a General Electric type IFC-53. The motiel and style number shown in Calculation 413CA as well as these documents should be revised to agree with the relays that are installed at the switchgear.

Review Valid inve16d Needed Date lastletor: Bloothe. G. William O

O O

11'15S7 VT Lead: Nort, Anthony ^

O O

O 1'15S7 VT Mgr: Schopfer, Don K G

O O

11'15S7 IRC Chmn: Singh, Anand K Q

Q Q

11/2G97 Date:

INVALID:

Date:

RESOLUTION:

Preytously identified by NU7 O Yes @ No Non Descrepent CondruonrO Yes P No Resolution Pending70 v.e

@ No R..oiution unt. ev.d70 -vos

@ No Review Printed 11/2097 4 06.50 PM Page 1 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0601 Millstone Unk 3 Discrepancy Report Acceptable Not AcceptaW Needed Date g g.

O O

O VT Lead: Nwl, Anthony A VT Mgr: Schopfer, Don K IRC Chmn: S4, Anand K Date:

SL Comnents:

Printed 11N7 4 06.57 F M Page 2 of 2

4 Northeast Utilities ICAVP DR No. DR-MP3 0606 Miiistone Unit 3 Discrepancy Report Review oroup: Pii,vr i.i. sac DR VALIO Potential OperetntNy iseue Discipline: mwr O vee D6ecrepancy Type: Correctra Acton g)

System /Procees: N/A EIW h***4 Date faxed to NU:

Date Published:

Discrepancy: Insufficient Corrective Action Plan Deecripilon: The ACR # M3-97 0429 Corrective Action Plan does not require documentation of the "as built

• condition in either the drawings or specification.

Per the ACR Block # 2, the installations (as described in Block

1. 2) are not in accordance with drawing CE 54 and expose the Blue Cable to less than 3-feet horizontal (21 inches) from Neutral Cables from penetration 3RCPB-6V. This violates separation requirement from Specification SP-EE-076.

Per the ACR Block # 4, this ACR was reviewed against the operability evaluation MP3-247 96 provided for ACR 96131.

Since the cables are greater than 6 inches away horizontally from neutral cables from penetration, the cables are considered operable based on Wyle Test Configuration 3.

This "as-built

• configuration should be documented on design documents (e. g. through a drawing or specification revision).

Update of the design documents are not a part of the Correctivo Action Plan.

Review Valid invalid Needed Dete inMietor: Caruso, A.

O O

O 1'1/97 VT Lead: Ryan, Thomme J G

O O

1'S7 VT Mgt: Schopfer, Don K Q

Q Q

11/6,97 IRC Chmn: Singh, Anand K Q

Q Q

11/1&97 D.i.:

INVALID:

Date:

RESOLUTION:

Prevuely identifled by NU7 O vee O' No Non Discrepent Condition?Q vee el No Resolut6on Pending7O ves + No Resuuiwunresoeved70 vee

+ No Review Acceptable Not Acceptable Needed Date b

VT Lead: Rysa Thomme J VT Mgr: schopfer, Don K IRC Chmn: Segh, Anard K Date:

SL Corrvnente:

Printed 11/2G97 4 07.34 PM Page 1 of 1

Northeast Utilities ICAVP DR No. DR MP34611 Millstone Unit 3 Discrepancy Report Review oraup: r,y..a DR vAuD Review Elerneet: Operatog Procedure Potem6al Operebnity issue Discipline: Operatxns Q yo.

D6ecrepancy Type: 0 & M & T Procedure

@ No SystemProcess: N/A NRC Sigrecance level: 4 Date faxed to NU:

Date Publisind:

D6screpancy: Abnormal Operating Procedure AOP 3572 Minor Discrepancy Descripoon: AOP 3572 Rev. 4 included in part, a change to step 8b RNO (Response Not Obtained) column to

• establish emergency makeup using EOP 3505A, Loss of Spent Fuel Pool Cooling *.

Entrance to the RNO column stems from failure to successfully implement step Sa which says

• Establish normal makeup from RWST using OP 3305...Section 7.3.2*,

Of the makeup supplies identified in Attachment A of EOP 3505A, steps 2,5 and 6 are identified as

• Emergency Makeup *,

Step 2 is for emergency makeup from the RWST, Step 5 is for local emergency makeup from the fire protection water system, Step 6 is for local emergency makeup from the service water system EOP steps are performed in order, unless specifically directed otherwise. The wording used (i.e. Emergency Makeup) in the revision of AOP 3572 Rev. 4 step 8b RNO column could be taken as an instruction not to perform step 4 of EOP 3505A (Attachment A Rev.2) which is to supply makeup from the primary grade water system since this supply is not identified as an " Emergency Makeup

• supply. Since it is the intent of EOP 3505A Attachment A to attempt makeup from the Primary Grade Water System (step 4) prior to attempting makeup from the Fire Protection (step 5) or Service Water System (step 6), and since the Primary Grade Water Supply is not identified as an

• Emergency Makeup

• supply in the EOP, AOP 3572 step 8b RNO column should be revised to be consistent with the intent of the EOP and to avoid confusion.

Review Valid invalid Needed Date initiator: Navarro. Mar

• G O

O 11'1'S7 VT Leed: Ryan, Thomas J G

O O

1 3'S7 VT Mgr: Echopfer. Don K G

O O

11 5 S7 IRC Chmn: singh, Anand K O

O O

11/1S'S7 Date:

INVAUD:

-a Date:

RESOLUTION:

Previously identified by NU? O Yes @ No Non Discrepent Condition?Q Yes 18' No Resolution Pending?O Yes @ No Resolution Unresolved?O Ye.

+ No Review Pnnted 11/2or97 413.14 PM Page 1 of 2

Northeasi Utilities ICAVP DR No. DR MP3-0411 Millstone Unk 3 Discrepancy Report O

O O

VT Leed: Rysa, Thomme J O

O O

vr w n scro n, con g o

r 0

0 0

m e et nn: sv. An.no x O

O O

SL Commerds:

6 Prtnted 11/2CV97 413 21 PM p

^ ^

Northeast Utilities ICAVP DR No. DR-MP3-0619 Millstone Unit 3 Discrepaticy Report Review oroup: System DR VAUD Review Element: System W Potential Operatuisty lasue Diecipline: Electrical Doogn O vee Diecreparwy Type: Calculaten (6_) No systemrProcess: DGX NRC Significance level: 4 Dele faxed to NU:

Date Published:

~

DiecrePancy: Coordination Between EDG Neutral Circuit Breaker and Lockout for Bus and EDG Differential Trips D*ectiPhon: Calculations 420CB ano 421CB give the time delay between the time that the generator neutral circuit breaker is opened until all of the circuit breakers on the bus or emergency diesel generator are tripped by the bus or generator differential relay. The operation of a differential relay indicates that there is a short circuit inside the protectior. zone of the differential relay.

Calculation 420CB concems the bus differential relay (87). Its protective zone is the entire bus of a Class 1E 4.16 kV switchgear. It trips all circuit breakers at the bus.

Calculation 421CB concems the emergency diesel generator (EDG) differential relay (87G). Its protective zone is the emergency diesel ger.arator and its connections to the switchgear. It trips the diesel generator circuit breaker.

Time delay relay 62E is associated with the bus differential relay.

Time delay relay 62G is associated with the generator differential relay. If either differential relay operates, the diesel generator neutral is opened up in an attempt to clear ground faults, the moA likely type of short circuit. If this falls, all of the circuit t'reakers on the bus are opened and locked out if 62E operates and the diesel generator breaker is opened if 62G operates. A 0.2 second time delay is provided for both relays. However the discussion on Section 14.2.2 of IEEE 2421986 suggests that this time interval is somewhat short to guarantee reliable i

j coordination. The neutral circuit breaker is normally rated to open in 5 cycles (0.083 s). The auxiliary relay used to open the breaker will require another 0.004 s. Additional time is required to allow the PVD bus differential relay to drop out if opening the neutral breaker successfully clears the fault. (See the note on c

page 5 of General Electric instruction leaflet GEK-45405C conceming the dropout time of the 87L unit within the PVD relay.) The adequacy of the 0.2 second coordination time interval should be verified. A coordination time interval of 0.3 second is used elsewhere at Millstone and should be adequate.

"*lRC Comment : Correction of spelling error""

l Review l

Valid invalid Needed Date j

Initiator: Bloethe, G. Witham B

O O

11/15S7 1

VT Leed: Nort. Anthony A 8

O O

1'1SS7 i

VT Mgr: schopfer, Don K Q

Q Q

11/18,97 IRC Chmn: singh, Anand K G

O O

1 ' o'S7 Printed 11/20/97 4 De.4o PM Page 1 of 2 I

I Nodheast Utilities ICAVP DR No. DR MF3 0419 Millstone unn 3 Discrepancy Report Date:

INVN 10:

Date:

RESOLUTION:

PreMy klordihed by NU7 C Yes

'ei No Non Discrepent Condskm?O Yes

9) No Reeolutlem Pensng?O vs.

i i No R sotinnuar.coevedrO vee r#> No Review 4

Acceptable Not Acceptable Needed Date gg O

O VT Leed: Nort, Anthcny A O

O O

VT Mgr: Schopfer, Don K O

O 1RC Chmn: Engh, Anano K O

O O

osie:

SL Commerds:

h e

Printed 11/2097 4 06 47 PM Pg 2 of 2 y---

q-r,

,r

-~,-,-

't--m+ - - -

p

,m e

y v,,-r,,,m

,w-,pw,

,p g _ws4 y y

- - - -. - + -

.,_,m,..--,,v,,--,,g

,--.g-.m,

--u-m--,,-+---,

-, - --w-.v,w--

i Northeast Utilities ICAVP DR No. DR MP3 0423 MillstDne unit 3 Discrepancy Report Review Orcup: Prog.amrnetc DR VALID Rev6ew Element: Correctrve Acton Process p

g Diecienne: u**nence O vee D6ecrepency Type: Correcttve Action 4g system 9tocese: NA NRC $6gnancance hel: 3 Date Faxed to NU:

Date Published:

Diecropency: Crtteria Determining which Vendor Technical Manuals Need Upgrading oy Startup Descr4dion: Adverse Condition Report (ACR) 013783 is part of the *out of-scope" Tier 3 review of corrective actions. The ACR deals with a procedure inadequacy which affects the maintenance of reactor trip switchgear, This ACR, together with o;her corrective action documents such as ACR M3-97 0295 and ACR 10562, addresses the broader problem of Vendor technical manual inadequacies related to updating manuals with current vendor recommendations.

Section 1,7 of Procedure DC 16 Rev'slon 0, is titled " interim Recovery of Key Safety Related Vendor Technical Manuals".

Section 1.7 defines key safety related equipment as:

" Components which in the performance (;f their safety related functions, change operating modes or positions', it is our understanding that most of these key manuals will be upgraded during Phase 2 (after startup).

No criteria or schedule was found, however, for determining when vendor technical manuals will be upgraded. Additionally, it was not evident which manuals wili be upgraded by startup.

Rev6ew Val 6d inve66d Needed Date initiator: Shepperd. R. P.

O O

O iitt/S7 VT Lead: Ryan. Thomas J O

O O

' it'/S7 VT Mgt: SchopW, Don K Q

Q Q

11/1097 IRC Chmn: Singh. Anand K O

O O

15/ SS7 D*:

11/7/97 IN1'AUD:

4 "Jete:

• tESOLUTION:

Prev 60usly 6 dent Aed by NU7 O vos

.Gi No Non Discrepnt Conddion?Q Yes

1. i No Resoluuon PeMing?O ve.

• ) No MesolutionUnresolved?O ve.

si No Review Acceptable Not Acceptable Needed Date g

b b

VT Lead: Ryan, Thomas J VT Mer: Schopfer. Don K IRC Chmn: Singh. Anand K

_e SL Conenents:

Pnnted 1U2097 4 09 25 PM Page 1 of 1

Northeast Utilities ICAVP DR No. DR-MP3 0628 Mill : tone Unit 3 Discrepancy Report Revlow Group: Progrenimetet, DR VAUD I

Potent 6el Operobddy leeue D6ecip66ne: I & C De**"

O vee D6ecropency Type.* O & M & T Procedure

'e) No SysterWProcese: N/A NRC SignWicence level: 3 Data FAXert to NU:

Date Published:

06ecrepency: Simulated Test Pressure Selected for Performance of Technical Specification Surveillance Descr6Mion: Licensee Event Report (LER 97 03100) describes an evert whefeln the Licensee identified that pressure interiock bistables associated with the RHR syr, tem were calibrated inproperty.

Although the calibration procedure (when revised as documented in LER 97 03100) would set tiie bl stables Dappropriately, the surveillance documented in the LER was conducted at a simulated pressure of 600 psia. The interlock is required to be functional anytime RCS pressure is greater than or equal to 390 psia. Testing at a simulated or actual pressure of SOO psia does not provide assurance that the interiock will function between RCS pressures of 390 psis and 500 psia. As written. the technical specification surveillance requirement 4.5.2.d.1) could be construed so as to allow testing at higher pressures, however we believe the intent of this tesiis to prove functionality of the l

instrument such that positive assurance is afforded that it would trip pnor to exceeding 390 psia on increasing pressure as spscified.

j Ref. SP3442J01 Rev. 4. Eoctions 4.3 and 4.4 Review Volid invalid Needed Date irtitietor: Neverro. Mark O

O O

i'S7 VT Lead: Ryan. Thomme J G

O O

5 'S7 VT Mgt: Schopfer. Don K O

O O

$ 17'S7 1

'i'1SS7 IRC Chmn* singh, Anand K O

O O

Date:

INVAUD:

Date:

RESOLUTION:

Previously identsred by NU? O Yee

'95 No Non Discropont Condst6on?U vee

6) No Resolutkm Pendmg?O ves + No Resolut6onUnresolvea?O ves + No Review Acceptable Not Acceptable Needed Date g

VT l. sed: Ryan, Thomas J VT Mge: Schopfer. Don K IRC Chmn: singh, Anand K Date:

sL Conwnente:

Pnnte( 11C097 410.18 PM Pope 1 of 1

e Northeast Utilhies ICAVP DR No. DR MP3-0437 Millstone UnR 3 Discrepancy Report Review Group: Operatens & Mordenence end Testing DR VALID Revlow Element: Operating Procedure Diecipline: Operstens O Ya D6ecropency Type: O 4 M & T Procedes fM No systerrvProcess: SWP

~

NRC segr48tcence level: 4 Date faxed to NU:

Date Published:

mecrepency: MOVs 3SWP'MOV71 A(B) are not included in the control room rounds valve lineup verifict'lon.

Deecript6on: Technical Specification 4.7.4 requires that *At least two service water loops shall be demonstrated operable: At least once per 31 days by verifying that each valve (manual, power operated or automatic) servicing safety related equipment that is not locked, sealed or otherwise secured in position is in its correct position.

l Contrary to this, safety-related valves 3SWP*MOV71 A(B) are not included on the Conti01 Room Rounds sheet of the ' Service j

Water Train A(B) Valve (Jneup Verification

• surveillance procedure checklist, OPS Form 3626.1 1(2). These motor operated valves have position indication in the control room and j

therefore would fall under Section 1.2 (General Instructions and Guidance for Equipment Control), paragraph 4 of Equipment Control procedure OP 3260B and should be listed on page 6 of 6 of the aforementioned forms.

A search of the procedwe database could not determine any other procedure or surveillance form where this requirement is satisfied or documented.

Rev6ew Valid invalid Needed Date Instietor: Tamiyn. Tom O

O O

15 5 S7 VT Lead: Bese Ken 8

O O

15 5 S7 VT Mgt: Schopfar, Don K Q

Q 11/1097 IRC Chmn: Singh, Anand K O

O O

5 $S7 Date:

INVALID:

Date:

RESOLUTION:

~

~

Previously identtried by HUF U Yes

'91 No Non Decrept Condsuon?Q Yes

• )

No Resolution Pendmg?O Yee ;s) No Resolut6osworeeolved70 Yes No Review Acceptable Not Acceptable Needed Date g

O O

O VT Lead: Bees, Ken VT Mgt: Schopfer, Don K IRC Chmn: Singh, Anand K Dele:

sL comments:

1 I

Pnnled 11/2097 411.15 PM Page 1 of 1 l

l l

t

d Northeast Utilities ICAVP DR No. DR MP3-0438 Millstone Unit 3 Discrepancy Report w w.

Review Group: 4* One & Monterance and Teehng DR VAUD Rev6ew Element: Oresung Procedure p

g Diecipline: Operstone O vee D6ecrepancy Type: Teet impnementaten to) No SystenvProcess: sWP NRC s6gnif6conce level: 4 Date faxed to NU:

Date Puteshed:

Deecrepeacy: Surveillance program does not assure that s't SWPs are tested for all operating requirements.

Deecr6peion: Technical Specification 4.7.4.a.2 requires th it *Each Service Water System pump starts automatically on an SIS test signal."

It could not be determined that the existing surveillance tests assure that this requirement is met. SP 3646A.15, SP 3646A.17 OPS Forms 3646A.151 and 3646A.171 are used in conjunction to venfy that both service water pumps in Train A are started automatically with an SIS signal. Ideally OPS Form 3646A.151 tests pump A and OPS Form 3646A.171 tests pump C.

At the bottom of OPS Form 3646A.151, page 2, note 2 states that *3SWP*P1 A should be the lead pump. If 3SWP*P1 A is not available, select 3SWP*P1C as the lead pump and ensure 3SWP*P1 A is the lead for SP3646A.17 or is documented on 3646A17 2 as requiring a retest when it is availab!e." 11 is not apparent how this requirement is followed through since there is no requirement on OPS Form 3646A171 to test the opposite pump. The only notation is *lf possible, the SW pump not tested in lead during SP3646A.15 should be lead pump." This doesn1 reflect a requirement to venfy and document. Neither SP3646A.15 or SP3646A.17 list the completion of the other as a prerequisite so the order of performance isn't required to assure that equipment isn1 missed.

OPS Form 3646A.15-1 (161,171,181) footnotes suggest that a specific pump be made the lead pump for the test but the form does not provide a place to document that this requirement is met. Footnote 2 on OPS Form 3648.171 states that "If possible the SW pump not tested in lead during SP3646A.15 should be lead pump.* The same footnote on the corresponding procedure for B train states "The SW pump not tested in lead during SP3646.16 must be lead pump." These two requirements are not equivalent.

A review of the test results of SP 3646A.15,16,17 and 18 and their associated OPS Forms 3646A.15-1,16-1,171 and 161 for the period 5/96 through 7/96 reveal the following:

No requirement exists that all equipment associated with a specific test 15 to be available prior to performing the test.

Testing prerequisites are not specific regarding system alignment. The SPs are mute on prerequisites for SWP status and leaves the decision on which pump should be running to the test director based on footnotes on the OPS Forms.

Annen nn inrmt that nrn inhalad *lNITIAl

• hnum heen c.herind Pnnled 11/20W 411'52 PM Page 1 or 2

Norttx.ast Utiinies ICAVP DR No. DR MP3 0434 Millstone Unit 3 Discrepancy Report i

in some instances and initialed in others. However, the test was accepteo and approved as satisfactory.

SP 3646A.15,16,17 and 18 are also used to satisfy the sequencing of equipment following a loss of off sitd power (TS 4.8.1.1.2.G.4 (6)), The to:!ing does not require that any pump is in " follow" and therefore the testing does not demonstrate that the " follow" pump will start if the *iend* pump falls to start.

Review Valid inva!6d Needed l'We i

trelator Tarrdyn. Tom O

O O

555S7 VT Lead: Base, Ken O

O O

itSS7 Sc pter, Don K O

O O

i $S7 VT Mer:

e IRC Chrm: Singh. Anand K O

O O

5SS7 o.t.:

INVALID:

Date:

RESOLUTION:

Prev 6ously ident6fbed by Nu? C) Yes iti No Non Diecreperd Condd6on?C) Yes JGi No Resolut6on Pend 6ng?O vee + No Ree uion uaree*ed?O ve.

• No Rev6ew inMietor: (none)

VT Lead Base, Ken VT Mgri Schopfer. Don K IRC Chmn: Singh, Anand K o e:

SL Cortunents:

i Printed 11/2017 4.12.00 PM Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3-0454 Millstone UnN 3 Discrepancy Report Rev6ew Group: Syesem DR VALID Poderd6al Operstaty issue Dikgene: Mechenal Dessip

,3 Discrepency type: Component Data O No Systerdrocess: HVX MC segrdAconce level: 3 Da* s faxed to NU:

Date Puteshed:

Discrepency: Radiation Monitor 3HVR*RE10A/B Sample Lines Deecripuan: During the review of the sample lines for the ventilation vent radiation monitor (3HVR'RE10A/B) a discrepancy regarding the safety and seismic classification of lines 3-HVR 750L 14,3 HVR-750-2-4,3-HVR-006-3-4, and 3HVR 750-40-4 was identified.

FSAR Section 3.1.2.64 states that after a postulated accident, the safety related ventilation vent high range monitors and the safety related Millstone i stack monhors are used to monitor the affluents from spaces contiguous to the containment structure including areas tha' contain loss of-coolant accident fluids.

FSAR Section 11.5.1 states that the potential pathways for release of radioactive materials during accident conditions are continuously monitored to ensure agreement with the guidelines of Regulatory Guide 1.97 Technical Specification Table 3.313 requires the ventilation vent monitor to be operable at all times.

Lines 3-HVR 75014 and 3-HVR 750-2 4 are identified as tubing class ICN08 and non-QA lines on the Millstone ill Line Report and in the Plant Design Data System (PDDS) database. Tubing class ICN08 is identified as non-seismic, ANSI B31.1, Class 4 per specification 2472.800-943, Rev.10.

Line 3-HVR-006-3-4 is identified as pipe class 151 and non-QA in the line report and PDDS. Line 3-HVR 750-4-4 is identified as pipe class 152 and non-QA in the line report and PDDS.

The use of c. lass 4 lines does not support the FSAR Section 3.1.2.64 and 11.5.1 commitments to continuously monitor the ventilation vent discharge post accident.

Review Valid invalid Needed Date Irdttetor: Stout, M D.

Q Q

Q 11/11/97 VT Lead: Nort, Anthony A O

O O

'1'11/S7 VT Mgr Schopfer. Don K Q

]

11/17/97 IRC Chmn: $1ngh. Anand K Q

O O

11/20 S7 Date:

INVALID:

Dele:

RESOLUTION:

Previously identified by NU7 C) Yes

1. 1 No Non Discrepent Condahon?O Yes @ No Printed 11/2G97 414 oO PM Pope 1 of 2 i

Northeast Utilities ICAVP DR No. DR-MP3 0664 Millstone Unit 3 Discrepancy Report ReeolutionPonengFU Yes

!9) No ReeclusionUnrosoived?U Yes G) No Review Accepdeble Not Acceptable Needed Date MWor: W)

O O

O VT Lead: Nort Anthony A b

b VT Mgr: Schopfer. Don K IRC Ctwnn: Segh. Anand K Dets:

SL Ccenents:

PfWed 11/2097 414 07 FM Page 2 of 2 I

Northeast Utilities ICAVP DR No. DR MP3 0467 Millstone Unit 3 Discrepancy Repoft Review Group: system DM VALID i

Polential Opretnuty issue piecip66ne. Doctra D"*"

O vee D6ecrepency Type: Ucerweg Deumont g

Systemfrocese: DGX f#tC SigrWAconce level: 3 Dete FAXW to NU:

"ete Putd6ehed.

D6ecrepency: Descrepancy between Reg Guide 1.9, Design Basis Summary Document & Differential Trip of Generator Deecription:

Background:

Per Table 1.81 of the FSAR NU has committed to Revision 2 of REG GUIDE 1.9 " Selection, Design, and Qualification of Diesel-Generator Units Used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants", Revisio,12. December 1979 Section B. DISCUSSIGN states in part:

" Protection of the diesel-generator unit from excessive overspeed, which can result from a loss of load, is afforded by the immediate operation of a diesel 1enerator unit trip, usually set at 115 percent of nominal speed. In addi' ion, the generator differential trip must operate immudiately in order to prevent substantial damage to the generator..."

Section C.7 of the Reg Guide states in part:

" In conjunction with Section 5.6.2.2, engine-overspeed and generator-differential trips may be implemented by a single.

channel trip.

• Paragraph 4.1.15 of Design Basis Summary 3DBS-EDG 001 states:

" lf protective features other than engine overspeed and generator overcurrent a*e retained during a design basis accident, two (2) or more independent measurements of these parameters with coincident trip logic shall be provided."

Discussion:

Generator differential relay 87G trips the diesel via lockout relay 86HP. If a design basis event occurs (SIS /CDA/ LOP) the lockout relay cannot be directly e'ergized because it is blocked by a contact from relay TSR. The lockout relay will energize through a contact from time delay relt, e ?G, but only after a delay of 0.05-3.0 seconds, depending on s Lere the timer is set.

The Design Basis Summary Document implies that genu itor overcurrent and engine overspeed trips shall be treated alike.

Tha Rnn Mulda indiatae thnt annina nvartnpad nad_ggnnentar l

Prtraud 11r2097 418 27 PM Page 1 of 3 l

Northeast Utilities ICAVP DR No. DR MP3 0467 Milistone Unit 3 Discrepancy Report differential trips, not generator overcurrent, are to be treated alike.

Conclusion Section 8:

The second sentence in the paragraph states: 'In addition, the generator differential trip must operate immediately in order to prevent substantial damage to the generator." Since a condition can occur in which the diesel-generator will not immediately trip on a generator differential fault, there appears to be a discrepancy with the Reg Guide.

Conclusion Section C,7:

The Design Basis Summary Document (DBSD) and the Reg Guide appear to be in disagreement.

This is based on a review of the following drawings:

ESKSDR Rev 18 Elem Diag 4.16kV [15G 14U 2)

Emergency Diesel Gen Bkr [3 ENS'ACB-G A)

ESit SDS Rev 18 Elem Dicg 4.1CkV [15G 15U 2)

Emergency Diesel Gen Bkr [3 ENS *ACB G B)

ESK 70 Rev 11 Emerg Diesel Generator Brkr 15G 14U

[3 ENS *ACB-G A) Aux Ckt ESK 7R Rev 11 Emerg Diesel Generator Brkr 15G 15U 2

[3 ENS *ACB-G-B) Aux Ckt ESK-8KC Rev 11 125V DC Emer Diesel Gen Start Ckt 3EGSAO'i [3EGS'G-A)

ESK8KD Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSA03 [3EGS*G-A)

ESK-8KF Rev 12 125V DC Emer Diesel Gen Start Ckts Ckt 3EGSB01,2 [3EGS*G-B)

ESK-8KG Rev 12 125V DC Emer Diesel Gen Stop Ckt 3EGSB03 [3EGS*G B)

ESK 8KJ Rev 09 125V DC Emer Diesel Gen Shutdown Ckt 3EGSA06 [3EGS*G-A)

ESK 8KK Rev 09 125V DC Emer Diosel Gen Shutdown Ckt 3EGSBO6 [3EGS*G B)

Review vand imend Needed Date inR6etor: Womer, t.

Q Q

Q 11/11/97 VT Leed: Nort, Anthony A Q

Q Q

11/11/97 VT Mgri Schopfer, Don K Q

Q Q

11/17/97 Printed 11/m'97 418 33 PM Page 2 or 3

Northeast Utilities 10AVP DR No. ORAP 3 0657 Millstone Unk 3 Discrepancy Report IRC Civnn: Singh, Anand K Q

Q Q

11/1997 Date:

IW Auo:

Date:

RESOLUTKW:

Previously identened by NUP Q Yes

'9) No NonDescropontCondst6on?Q Yes t ho Reso4ut6on PendingPC Yes

45) No Resolution unresolvedFO vos + No Review Accephbee Not Acceptab4e Needed Me gg; VT Lead: Nw1. Anthony A VT Mgr: Schopfer, Don K O

O IRC Civnn: Singh, Ana.uf K O

O Date:

SL Comments:

h PrWed 11/2097 418 36 PM Page 3 of 3

Northeast Utilities ICAVP DR No. DR-MP3 0668 Milletone linit 3 Discrepancy Report Rev6ew Group System DR VALID O '"**

"'#*I Y

Potential Operets66Wy leeue Diecap66 tie: Mechancel Doogn O va D6ecropency Type: componard Date s No SysterrVProcess: HVX NRC signeticence level: 3 Date FAAed to NU:

Dele Published:

D6.crepency: ADVS Filter Unit Electric Heater Capacity Dactlpelon: During review of the Auxiliary Building Ventilation System (ABVS) filter units 3HVR*FLT1 A/18 a discrepancy regarding the capacity of the ilectric heating coil in the filter units was identified, Regulatory Guide 1.52, Rev. 2, position C 3.b requires the heaters to be designed, constructed, and tested in accordance with the requirements of Section 5.5 of ANSI N5091976. ANSI N5091976 Section 5.5.1 states that the heater shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air steam mixture (RH=100%) to approximately 70% in the housing space between the moisture separator and prefilter stage, at system des;gn flowrates. FSAR Table 1.8 2 and FSAR Table 6.51 state that the filter Units are in compliance with Regulatory Guide 1.52. Rev. 2, position C.3.b.

The results of calculations 97 ENG 01453M3, Rev. O and B235-9915 Rev. B indicate that for degraded voltage and the specified 170*F,100%RH entering air conditions the electric heater capacity results in a relative humidity of 75.2%. The 75.2% RH value does not meet the RG 1.52 requirements.

Rev6ew Ve86d invaled Needed Date iner'stor: Stout. M D.

O O

O i 15 'S7 VT Leed: Nort, Anthony A O

O O

1 '11' 7 VT Mge: Schopfer. Don K O

O O

157'S7 IRC Chmn: Singh. Anand K O

O O

iir20S7 w e:

INVALID:

Date:

RESOLUTION:

Previously identthed by Nu? O Yee

1. ' No Non D6screpent Condrtton70 Yee

1. i No Resolution Pend 6ng?O vee + No Renoiui6on unre.oeved?O vee

8) No Review Acceptable Not Acceptaide Needed Date d

VT Leed: Nort, Anthony A VT Mgt: Schopfer. Don K IRC Clwnn: $1ngh, Anand K

- e:

EL Conenente:

P.inted 11/2097 4 21:58 PM Page 1 of 1

Northeast utsties ICAVP DR No. DR MP3 0669 j

Milhtorie Unit 3 Discrepancy Report i

Review Grpup: System DR VALID Rev6ew Element: system Deegn p

g, Diecip46ne: Mechatucal Desgn O va D6ectopency Type: Componert Data e) No SystervVProcess: HVX NRC Sleneficance level: 3 Date faxed to NU:

Date Publ6shed:

06*ctopency: SLCRS Filter Unit Electric Heating Coll Capacity De*citpt6cn: During review of the the Supplementary Leak Collection and Release System (SLCRS) filter units 3HVR*FLT3A/3B a discrepancy regarding the capacity of the electric heating coilin the filter units was identif'ad.

Regulatory Guide 1.52, Rev. 2, position C.3.b requires the hesiers to be designed, constructed, and tested in accordance with the requirements of Section 5.5 of ANSI N5091976. ANSI N5091976 Section 5.5.1 states that the heates shall be sized on the basis of heat transfer calculations showings its capability of reducing the entering air steam mixture (RH=100%) to approximately 70% in the housing space between the moisture separator and prefilter stage, at system design flowrates. FSAf.

Table 1.8 2 and FSAR Table 6.5-1 state that the filter units are in compliance with Regulatory Guide 1.52, Rev. 2, position C 3 b.

Calculations 97.ENG-01453M3, Rev. O and 8235 ' J15, Rev. B show that at are air flow rate of 8500 scfm and ente,ing air conditions of 120'F & 100% RH the required heater capacity is 1

36 kW. The capacity of the heater at degraded voltage conditions is 37.2 kW At the current maximum SLCRS air flow j

rate of 9.800 cfm shown on P&lD EM 148E 12, the required heater capacity increases above the available capacity of the heaters. This will result in a relative humidity greater than 70T Review Val 6d inval6d Needed Date 1

initiator: stout, M D.

O Q

Q 11/11/97 VT Leed: Nort. Anthony A Q

Q Q

11/11/97 VT Matt schopfer. Don K Q

Q Q

11/17/97 IRC Chmn: singh, Anand K Q

Q Q

11/2097 Date:

INVALID:

Dele:

RESOLUTION:

Prev 60usly identifled by NU7 O Yes

'ei No on Discrepent Condstum70 Yes

>#1 No Reco4ution Pending70 Yes + No Re.osuiion uare,4v.d70 Yes + +

Rev6ew Acceptable Not Acceptable Needed Date g

VT Lead: Nort. Antreny A D

D D

vt Mer: schopter. Don K IRC Chmn: singh, Anand K Date:

Pnnted 11/2097 4 25 43 PM Page 1 of 2

~- -.

- - - ---- q Northeast UtilMies ICAVP OR No. DR MP34689 Millstone Unit 3 Discrepancy Report m.co 1

Printed 11/20D7 4 25 de PM Page 2 of 2

-e,,-

---

e e.-,-

-m----w

~ - - - - - - - - - - - - - - - - - - - -

4 Northeast Utilities ICAVP DR No. DR MP3 0442 Millstone Unit 3 Discrepancy Report Rev6ew Group: Operetsons & Mortenance and Teetrg DR VAUD Review Element: Test Procedure p

g 5"""'**"""*

O Yes D6ecrepancy Type' Corrocove Acton M No Systemerocess: DGX

~

NRC sign 6Acence level: 4 Date faxed to NU:

Date Putd6thed:

D6uropency: DG surveillance tests could be conducted with lube oil temperatures less than 115 degrees F D*ecrtPt60n: LER 87 003-00 commits to "... surveillance tests will not be conducted unless lubc oil temperatures are at least 115 degrees F (and increasing) after the lube oil heater has been re.

l energized."

A search of NU maintenance and operating procedures for the diesel generators could find no reference to this specific commitment.

A review of operating procedures reveals that in OP 3346A,

• Emergency Diesel Generator", there is a prerequisite (Step 4.1.1.e) that the Ith oil temperatt'" := greater than 110 degrees F or rising. The basis for W atpoint is a manufacturer's recommended low temperature alarm. A search of station documents did not reveal any subsequent transmittal to the NRC that changed the commitment made in the referenced LER.

Other diesel generator operating procedures reviewed reference the prerequisites in OP 3346A.

The use of the phrase " greater than 110 degrees F or rising" could also be interpreted to mean that the lube oil temperature could actually be less than 110 degrees F as long as the temperature was rising, it is concluded that there is nothing in the evisting procedures trom precluding the diesel from being started with the lube oil i

temperture less than 115 degrees F and possibly less than 110 degrees F.

Review Valid invol6d Needed Date truttator: Terrdyn, Tom O

O O

$ 5' 2S7 VT Lead: Bees, Ken O

O O

11'1 S7 VT Mgr: Schopfer. Don K O

O O

11'17/87 IRC Chmn: Singh, Anand K Q

Q Q

11/2097 Date:

WVAUD:

Date:

RESOLUTION:

Previously identined by NU7 O Yee t No Non Discrepent Condspon?L Yes @ No Printed 11/2097 4 26.20 PM Page 1 of 2

I Northeast Utilities ICAVP DR No. DR4AP3-0662 Millstone Unit 3 Discrepancy Report ResokA6oriPerdng?U Yes

1. 1 No Reso4utxwiUrwetoived?U Yes

1. 1 No Rev ew Acceptatae Not Accordatde Needed Date VT Lead: Bass, Ken VT Mgr: Schopfer. Don K IRC Ctann: $sngh, Anand K Date:

SL Carments:

e Pnnted 11.%97 4 26 27 PM Page 2 of 2 l

4 NDrtheast Utilities ICAVP DR NO. DR MP3-0664 MillstDn Unit 3 Discrepancy Report Review Group: Operstons & Maintenaru and Testng DR VALID Rev6ew Elorrient: Systern instatiston p

Discipl6ne: Operstons O Yn Desceepancy Type: 0 & M & T linplernertaton M No SysterrvProcess: N/A NRC &lgn ncance level: 4 Date Fated to NU:

Date Published:

tx.crepancy: Monitor li0ht Oration at the simulator does not match the plant.

Desertptkm: The Engineered Safety Features (ESF) monitor lights provide Information in a concise Grouping as to the status of important plant equipment. At the simulator, the power to individual 1::SF lights is from the same source as the equipment it monitors.

Therefore when power to the equipment is lost, its indication is also lost. At the plant, the power in individual ESF lights is from a more reliable source, Safety Related DC, and equipment status would have been available.

Observation of simulator training showed that the cont"01 room staff was confused by this loss of ESF monitor light Indication.

This mismatch between the plant and simulator decreases the effectiveness of the training to the operators. Plant / simulator differences are to be minimized, but if they exist, then the differences are to be noted in the lesson plan. Notation of th's difference was not contained in the lesson plan.

Rev6ew Valed loval6d Needed Date initLetor: Plenien2, R O

O O

iiii2/97 VT Lead: Base. Ken g

Q

[

11/12/97 VT Mgt: Schopfer, Don K Q

[

]

11/17/97 IRC Chnn: $sngh, Anand K O

O O

iSS7 Dnee:

INVALID:

Date:

RESOLUTION:

Prov60usly identified by NU? C Yes

1. 1 No Non 04scrs' pant Condit6on?U Yes - #l No Resolut6on Pending?O Yes tid No Resolution Unresolved?O Yes

1. 1 No Rev6ew ccega e Acce a N

DMe initiator: (none)

O O

O VT Lead: Bass.Ke, VT Mgt: Schopfer, Om K IRC Chmn: Singh, Anand M Date:

EL CostmentE Preted 11/2097 4 77.14 PM Page 1 of 1

Northeast Utilities ICAVP DR No. DR MP3 0668 uilistone Unit 3 Discrepancy Report Review Group: Operatens & Meiruenance and Testing DR VAUD Review Elemord: Charge Process g

06ecipl6ne: Operaton.

O va D6ectopency Type: O & M & T trnplementaten M No Systamf.vcess: N/A NRC SagedAcance level: 4 Date Faxed to NU:

Date Published:

Diecrepancy: Control Room labels and operator lesson plans do not conform to industry standards.

Deeceipuon: The industry has developed standards and a code of conduct to enhance profer.s'onalism and ensure conservative decision making by tha operatonn. The labels for the megawatt ou'put Indicator and the clock as well as the language used in certain lesson plans do not conform to generally recognized standards in the industry.

The labels for the megawatt output indicator is ' Big Bucks

• and the clock is

• Big Ben'. These labels promulgate or condone an attitude that loes not support professionalism and conservativo decision rnaking. The message sent is that the generation of megawatts, rather than safe operation, is the priority of managemesit.

Additionally, the language, in some lesson plans used for operator training, minimizes the seriousness of the specific topic.

Some examples are:

A note on the lesson plan for changes to AOP's and EOP's states *Does it matter in the great sdieme of things what the order of the steps are? (NO).*

The ECA 0.0 lesson plan states

• this will be your worst day if you lose all AC and aux, feed cannot be established to the S G 's...'

Again, this language dilutes tne importance of the message and does not support the industry standards.

Review Valid invalid Needed Date initiator: Pioneewca. R.

O O

O ii'12S7 VT Lead: Bass. Ken O

O O

11'12S7 VT Mgr: 3chopfer. Don K O

O O

$ 57/87 1RC Chmn: Singh. Anand K O

O O

'i' SS7 Dele:

INYAUD:

Date:

RESOLUTION:

Previously idents6ed by NU1 O Yes ' G i h'o A.ie...nopant Condn6on?O Yes 1% No Resoluuan Pending?O Yes M No Resolution Unresoeved70 ve.

+ No Rev6ew Acceptable Not Acceptable Needed Date O

O O

VT Lead: Bass, Ken VT Mgr: Schopfer. Don K Pnnted 11/2097 4 37.39 PM Page 1 of 2

4 Northeast Utildles ICAVP DR No. DR MP3 0666 Millstone UnN 3 Discrepancy Report O

g e

mc chmn: s% Anand K O

e st c==

f 1

Prrted 11/2097 4 37.43 pg Page 2 of 2

Northeast Utilities ICAVP DR No. DR MP3 0099 Millstone UnN 3 Discrepancy Report Review Oroup: Programmate DR RESOLUTK)N ACCEPTED Rev6ew Eternord: Correctree Acton Process p

Disc 6phne: Other D6screpancy Type: Correctrve Acton O vee SystenWProcess: DGX No N*tc s6gn6hcence levet: 3 Date Faxed to NU:

Date Putd6shed: 6397 Descrepancy: liisufficient Significance Level for ACR M3 96-0221

~

De*crisd6on: The ACR describes that both the EDG's had Control Panel Doorsets which were not latched or had broken latchr1 NU assigned a Significance Level *D' for this ACR per Form RP4 4, Rev. 2. The NU evaluatiore of the ACR states 'The condition is reportable as a condition outs;de the design basis, similar to the i

reporting condition made on the 4160V Switchgear'. In addition,

the condition is identified by NU as an operability concem for A FDG due to two broken doorlatches.

A Significance Level *D'is not considered appropiate considering the Reportability and Operability condition and

)

because the condition is not of

• Low Consequence and Low Complexity".

Rev6ew I

Valid invaled Needed Date inellator: Caruso. A.

Q Q

8/2097 VT Leed: Ryan Thomas J Q

Q Q

&7097 VT Mge: schopfer Don K Q

Q Q

&72,97 1RC Ctwnn: Singh, Anand K O

O O

5?$S7 Date:

INVAUD:

D*Ie: 11/17/97 R ' SOLUTION: Disposition:

NU has concluded that Discrepancy Report DR-MP3-0099 does not represent a discrepant condition. Severalinitiatives, including the corrective actions taken as a result of ACR M3-96 0221, have ensured that both the specific issue desciibed in this ACR and the site issue relating to a weak Corrective Actions Program, have been appropriately attended to.

Regarding the ACR specific issue of seismic cabinet hardware functionality, subsequent ACR M3 961142 resulted in the completion of a root cause determination / corrective actions which resulted in a significant upgrade to the program for ensuring maintenance of equipment seismic qualifications. The ACR eddressed in this D!screpancy Report (DR) was encompassed in and referenced by this root cause evaluation.

The appropnais links / notes have been made in ACR M3 0221 to tie ACR M3 96-0221 to ACR M3 96-1142, Additionally, the Millstone Corrective Actions Program was significantly upgraded in February,1997 following the performance of QAS Audit QAS-96-4108, dated June 19,1996, and the Oorrective Action Plans for ACR 13318 and CR M3 97-Printed 117.n97 3 36 59 PM Pope 1 of 2

l

\\

Northeast Utilities ICAVJ DR No. DR MP3 0099 j

Millstone Unit 3 Discrepancy Report 0111. The goveming procedure, RP-4, provides specific guidance to tne Management Review Teams On the significance level classification of Condition Reports (CRs). Specifically relating to the subjed matter of this DR, RP-4 ensures that all CRs which are cetermined to describe a condition which is reportable are assigned our highest significance level of 1.

Discrepancy Report Significance Level critena do not apply here as this is not a discrepalit ccndition, f

==

Conclusion:==

NU has concluded that the issue reported in Discrepancy Report, DR-MP3-0099, does not represent a discr6 pant condillaa.

Station management hat 'mplemented program improvements independent of this DR which have correcied the root cause of this error.

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

~

Previou61y iderWahed try NU7 ISi Yes O No Non Descrepent Condd6on?O ves

!Si No Resolut6on Pending70 v..

• ' No RewMon Unresolvd?O vos

• No Rev6ew inatletor: Caruso. A V Lead: Ryan. Thnmes J VT Mgr: Sctiefer, Don K IRC Chmn: Singh. Anand K Date:

11/17/97 sL Conenents: The concem noted in this DR has been previously identified through the issuance of ACR M3-961142. Althou0th ACR M3 96-0221 Significance Level was "D", the processing of this ACR included the determination that the condition was reportable,

issuance of LER 96-022, completion of the corrective action to venfy that all bolts, screws, and latches required per c-iginal Vendor's testing are installed and property fastened, and the issuance of Seismic Inspection Criteria M3 EV 06009 for providing training to the plant pesonnel conceming the importance of cirmic is:,tses and plant equipment.

Therefore, the assigning of Significailon Level"D" did not appear to have any significant impact on the piocessing of this ACR.

PtWed 11CQ97 3 37:06 PM Pope 2 of 2

Northeast Utilities ICAVP DR No. DR MD3 0164 Millstone Unit 3 Discrepancy Report Rev6ew Group: Programmate DR RESOLUTION ACCEPTED Review Element: Conectrve Achon Process g

Diecipline: Other Om De*Pency Type: Conocuve Actson

) No SystenvProcess: DCX NRC $6gn6Acence level: 3 Dese Faxed to NU:

Date Pubi6shed: 9/1497 Descrepancy: Insufficient Significance Level for ACR M3-96-0181 Deecription: The ACR describes that many bolts on the hinged side of the back doors to the 4160V Switchgear were found to be missing durtng the 50.54f walkdown.. The Significance Level for the ACR is Level'D' per Form RP4 4, Rev. 2. The condition associated with ACR M3-96-0181 is reportable Reference LER.96-016. In addition, the condition is identified as an operability concem as no reasonable assurance was provided for operability; therefore, the 4160V Switchgear was determined to be inoperable.

A Significance Level *D' P. 30t considered appropriate considering the Reportability and Operability Condition and because the condition is not of " Low Consequence and Low Complexity".

Note: The same type of discrepancy is covered in DR MP3-0099.

Review Veied invalid Needed Date itwtietor: ceruno. A.

D 0

0

$5S7 VT Lead: Ryan. Thomes J D

D D

S5S7 VT Mor: schopfer, Don K O

O O

SSS7 iRC Chmn: singh, Anand K O

O O

SSS7 Date:

INVALID:

Date: 11/17/97 RESOLUTION: Disposition:

NU has concluded that Discrepancy Report DR MP3 0156 does not represant a discrepant condition. Severalinitiatives, including the corrective actions taken as a result of ACR MS 96 0181, have ensured that both the specific issue described in this ACR and the site issue relating to a weak Corrective Actions Program, have been appropilately attended to.

The generic issue of insufficient significance level was addressed in detail in M3 lRF 00318 in response to DR MP3-0099 and is applicable to this instance as well.

Discrepancy Report 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 MP3-0156, does not represent a discrepant condition.

Station management previously impitamented program l

improvements independent of this DR which have corrected t!'e root cause of this error. M3-lRF 00318 discusses this issue in Pnnled 11/2097 3 s2.41 PM Pega i af 2 f

Northeast Utilities ICAVP DR No. DR MP3-0164 Ministone Unit 3 Discrepancy Report detail.

Significance Level enteria do not 9pply here as this is not a discrepant condition.

Prev 60uely identlhed by Nu?

'80 Yes O No Non Descrepeed Condsuon?O Yes

'94 No R**olution PendengiO Ve.

• No R.

iuiionun,e.oev.orO Yes 51 No Review P'

init6stor: Caruto, A b

VT Lead: Ryan, Thomas J O

O m 787 VT Mgr: Schopfer. Don K O

i 7

BRC Chmn: Singh, Anand K Date:

11/17/97 SL Correnents:

The concem noted in this DR has been previously identified through the issuance of ACR M3-96-1142. Althougth ACR M3 0181 Significance Level was 'D", the processing of this ACR included the determination that the condition was reportable,

issuance of LER 96-016, completion of the corrective action to replace the missing bolts and NU development of Seismic Inspection Criteria M3-EV 06009 for providing training to the plant personnel conceming the importance of seismic issues and plant equipment.

Th9tefore, the assigning of Signification Level"O" did not apear to have any significant impact on the processing of this ACR, Printed 11/2097 3 52.52 PM Pe 2 d 2

-, ~ _...

_.., _. ~ =

Northeast Utilities ICAVP DR No. DR-MP3-0020 Millstone Unit 3 Discrepancy Report Review Group: Accacert Megaton DR RESOLUTION REJECTED Rev6ew Element: system Des' n g

PoterW6el OpereNiety losue Discipl6tw: Oth" O vee D)ecrepency Type: Licenang Documord

@ No SysterrvProcese: N/A NRC $6pnmcence level: 4 Date faxed to NU:

Date Publ6shed: W2297 Dacrepency: Westinghouse Comments on FSAR Section 15.0 and 15.6 Deecr6pt6on: We have reviewed Westinghouse Electric Corporation letter NEU 96-615,' Northeast Utilities Service Company Millstone Unit 3 Review of FSAR Chapter 15 LOCA,' dated November 1, 1996, which provkfed NU suggested page markups for FSAR Section 15.0, Introduction, and Section 15.6, Decrease in Reactor Coolant inuntory. The purpose of these comments an.1 markups was to provide assurance that the Millstone 3 FSAR is consistent with the Plant Safety Evaluation of record for the current fuel cycle.

The comments on this section identify changes to the input assumptions and results for the accidents unalyzed in this section. The Westinghouse changes leave unresolved the observation that the analysis was performeo using a 2% loop uncertainty whereas the FSAR lists the N 1 loop uncertainty as 2.3%. These changes have not been incorporated into the FSAR, making the FSAR and the Plant Safety Evaluation inconsistent.

A review of applicable corrective action databases for Millstone 3 has not identified any pending FSAR change notice items that willincorporate the Westinghouse comments into the FSAR.

Rev6ew Velid inval6d Needed Date initiator: Johnson, W, J.

g Q

Q 8/11/97 VT Lead: Rehoje, Raj D Q

Q 8/11/97 VT Mgr: Schopfer, Don K O

O O

8' '/S7 IRC Chmn: Segh. Anand K Q

D 0

8'1257 Date:

INVALID:

Date: 11/18/97 RESOLUTION: Disposition:

During the FSAR venfication activities perfomied pursuant to the requirements of 10CFR50.54f, NU discovered the discrepancy involving the loop uncertainty value for N 1 loop operation.

Table 15.0-2 was revised to clarify that the value is 2% for N 1 loop Vet: aing to LOCA. Notes (g) and (h) were added to Table 15.0-2 in FSAR CR 97 MP3 91, initiated 2/27/97, to show the maximum initial power and the uncertainty value for the LOCA event. Since the text in section 15.0.3.2 is generic explanation of typical values used in such evaluations,it was deemed unnecessary to revise the text and retain plant specific values in Table 15.0-2.

Printed 11/2097 3 So 34 PM Page 1 of 2

9 Nortneast htl[ities ICAVP DR No. DR MP3 0020 Millstone Unit 3 Discrepancy Report Note that the maximum power limit of N 1 loop LOCA event is analyzed at 75E Unit 3 is procedurally limited to 65% power during N 1 loop operation. Moreover, Unit 3 is administrstively prohibited from N 1 operations altogether.

Refer to the copy of FSAR CR 97 MP3 91 attached to M3-IRF.

00226 (ICAVP Response to DR MP3 0017) for changes associated with FSAR section 15.0. The FSAR CR is awaiting PORC approval.

]

==

Conclusion:==

DR MP3-0020 identified a discrepant condition with FSAR Chapter 15.0 previously addressed by NU. The clarifications written in Table 15.0-2 will be incorporated into FSAR section 15.0 through FSAR CR 97 MP3 91. Section 15.0.3.2 does not need to be changed because it is a generic explanation. Specific information is found in the table.

Prev 6ously identined by Nu? O Yes iG1 No Non D6screpent Conddion?O Yes 98 No Resolution Pending?O ve.

' O ' No Roewunon unte.av.d?O ve.

+ tw Rev6evr inMietor: Johnson. W J.

VT Leed: Rahep.RajD VT Mgt: Schopfer Don K IRc Chmn: Singh. Anand K Date:

11/12/97 sL corrents: NU response addresses the issue of loop uncertainty and the effect of FSAR Section 15.0, but does not address the recommended changes to FSAR Section 15.6 identified in Westinghouse letter NEU-96-615. These changes include items such as changes to the peak cladding temperature in Table 15.6-

11. Since the NU response did not address these changes, ICAVP considers the response to be incomplete.

Pnnted 11/2097 3 50 4s PM Pope 2 of 2

Northeast Utilities ICAVP DR No. DR-MP3-0035 Millstone unM 3 Discrepancy Report Revlew Group: Oper:amns & Maritenance and Testng DR RESOLUTION REJECTED Revtew Eksnent: Operetang Procedure PotentW Operab68ay lasue D6ecipiene: Operetons e3 y,,

06screpancy Type: Licenang Docurwit O no systern' Process: SWP NRC sbgnificance level: 3 Date faxed to NU:

Date Published: 8/31/97 Discreparwy: Not all Service Water heat exchangers are included in the surveillance p ocedure per LER 90-020-00 Descriptkm: Licensing event report (LER) 90-020-00 dated July 16,1990 was issued as a result of both trains of Quench Spray and High Pressure Safety injection being inoperable due to a deficient surveillance procedure. The corrective action section of this LER ststed in part... 'To prevent the recurrence, the surveillance procedure covering all Service Water System heat exchangers has been changed. When the established limits for a heat exchanger are exceeded the unit will be c'eclared inoperable and the appropriate Technical Specification Limiting Condition of Operations Actions Statement entered",.

Contrary to the above commitment, not all Service Water System heat exchangers are included in the applicable surveillance procedure. The applicable surveillance procedure is GP 3626.13, Service Water Heat Exchangers Fouling Determination, Rev 15, Change 1 with an effective date of April 1,1997. This procedure does not include any reference to or established limits for the following heat exchangers:

Containment Recirculation Heat Exchanger,3RSS'E1 A Containment Recirculation Heat Exchanger,3RSS*E1B Containment Recirculation Heat Exchanger,3RSS*E1C Containment Recirculation Heat Exchanger,3RSS*E1D Post Accident Sampling Sample Cooler,3 SSP SCL3 v view Vel 6d Invol6d 4 eded Date initiator: Spear. R O

O O

SnS7 VT Lead: Bass.Kan Q

Q Q

8/2297 VT Mgt: schopfer. Don K O

O O

S'25S7 IRC Chmn: Singh, Anand K Q

Q Q

&?A97 Date:

INVALID:

Date: 10/29/97 RESOLUTION: Disposition:

NU has concluded that the issue reported in Discrepancy Report,

DR MP3-0035, does not represent a discrepant condition.

Millstone Unit 3 has a history of mussel fouling of the service water heat exchangers, Upgrades and corrective actions to address mussel fouling include: new hypochlorite metering pumps; weekly surveillance of active or filled heat exchangers (3626.13); schedulod preventativa maintenance and inspection on heat exchangers per EN 31084 (revision 3 attached); and, I

Pnnted 1112097 3 512C PM Page 1 of 3

Northeast Utilities ICAVP DR No, DR MP3 0036 Millstone unit 3 Discrepancy Report development of a Special Procedure (SPROC 96 3-07) to flush the RSS heat exchangers on a quarterly basis, in addition, prompted by corrective actions for ACR 02994, permanent screens on the inlet of the RSS heat exchangers are scheduled to be installed during RFO6. Currently, during flushes these are installed, procedurally controlled and then removed.The corrective actions on LER 90-020-00 were intended to include the requirements of Generic Letter 89-13. GL 8913 was issued to address safety related portions of the Service Water system.

Post Accident Sampling System sample cooler,3 SSP SCL3,is not safety related nor is it QA. It does not fall under the requirements of GL 8913. 3 SSP SCL3 is kept in dry lay up (i.e.

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

3ignificance level enteria do not apply here as this is not a discrepant condition.

Cor,0.lusion:

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

Surveillance Procedure 3626.13 surveils eli service water heat exchangers except for the PASS sarnple cooler and the RSS heat exchangers. The PASS sample cooler is not a safety related component and as such, does not fall under the requirements of GL 8913. The RSS heat exchangers are surveilled and inspected under ESF / LOP Testing Surveillance (3646A.17 and 3646A.18 step 4,4.26.) and the regular quarterly preventative maintenance schedule. Significance level criteria do not apply here as this is not a discrepant condition.

Prev 6ously kjenuf6ed by Nu? O Yes i No Non D6ecropent Condeuon?U Yes

+ No Resolunon Pend 6ng70 ve.

4) No nosoivisonunre.oevedrO vos v No Review Acceptable Not Acceptable Needed Date lon6etor: spear.R.

O O

O

' 2SS7 VT Lead: Bass,Ke" O

e O

' ' SS7 VT Mgr: schopfer, Don K O

G O

53i32s7 IRC Ctwnn: Singh, Anand K O

G U

' ' '2""

Dem

.0/2 M 7 SL comments: We have reviewed NU's resolution to Discrepancy Report # DR-MP3-0035 and have determined that it does not provide enough additional information to resolve the discrepancy.

NU's response identified that the Containment Recirculation heat exchangers are surveilled for fouling during ESF/ LOP testing Prned 11/2097 3 51:32 PM Pege 2 of 3

Northeast Utilities ICAVP DR N3. DR44P3 0035 Millstone Unit 3 Discrepancy Report each refueling. The identified surveillances for the containment Recircula'lon Heat Exchangers is actually a sys'.em flush intended to remove biofouling debris from the long stagnant legs that are not in dry lay up and not a surveillance with cateria for determination of degraded and inoperable heat exchangers. NU recognizes that biofoullag will occur in theso stagnant portions an1 has determir.ed that flushing is the appropriate method for rentoval.

There is no determination made after flushing as to Miether the quantity of material removed from the heat exchangers or if other fouling was present bufficient to render the heat exchangers non-functionalif the system had been called upon between the flushiPg intervals. Additionally, since the amount of debris is not quantified, no deteimination can be made if the periodicity of the flushes is appropriate Pnnted 11/20'97 3 51:34 PM page 3 of 3

..