ML19256E101
| ML19256E101 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/25/1979 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19256E097 | List: |
| References | |
| NUDOCS 7910290047 | |
| Download: ML19256E101 (2) | |
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September 25, 1979 11r. Eldon J. Brunner Docket fio. 50-245 Chief Reactor Operations and Nuclear Support Branch U. S. iluclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Inspection 50-245/79-19
Dear Sir:
In reference to your letter received September 4,1979, this report is submitted pursuant to the provisions of Section 2.201 of the f4RC's
" Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
1.
Apparent Item of Noncompliance Technical Specifications, Section 4.2, Table 4.2.1, requires a functional test to be performed on the ventilation exhaust duct and refueling floor radiation monitors, once every 3 months.
Technical Specifications, Section 1, Item F defines " instrument functional test" to mean the injection of a simulated signal into the instru-ment primary sensor to verify the proper instrument channel response, alarms, and/or initiating action.
Contrary to the above, the functional test of the above described equipment consisted of injecting an electrical signal into the measurement channel and not testing the primary sensor as required.
Response
The apparent item of noncompliance involved insertion of an electri-cal signal into the measurement channel rather than conducting the test with a known source applied to the primary sensor.
The subject surveillance procedure has now been modified to specifically require the use of a known source at the primary sensor for demonstration of functional operability.
Presently, a Technical Specification change is being processed to allow the use of an inserted electrical signal for this functional demonstration.
This is being done for two reasons.
First, the radiation monitors have installed radiation sources which continu-ously demonstrate the functional response of the instrument channel.
Secondly, since the primary sensors are already source calibrated quarterly, it is not felt that the additional personnel expo:ure incurred during a monthly source fur.ctional demonstration is justi-fied consistent with the present ALARA program.
77-7 7 9102 9 0 C + 7
2.
Apoarent Item of Noncompliance Technical Specifications, Section 6.8.1, requires that procedures be established, implemented and maintained for surveillance activi-ties.
The administrative control procedure, ACP-QA-9.02 requires the review of surveillance test data sheets for compliance with the established acceptance criteria and to write on the data sheet the basis for accepting those items not within the established accept-ance criteria.
Contrary to the above, the inspector found eight surveillance tests where the data on the data sheets did not meet the established acceptance criteria and were not properly reviewed as required by the licensee's administration procedures.
Response
This apparent item of noncompliance involved improper review of surveillance test data sheets.
Surveillance test data sheets often contain more information, in the form of test data, than is required to meet the Technical Specification requirement for the specific surveillance test.
The non Technical Specification information is typically used for component trending / reliability studies and therefore reviewed by the particular discipline requesting the information.
Personnel responsible for test data sheet review have been reminded to more closely compare the test data to ensure Technical Specifica-tion requirements are met and note any deviations from non Technical Specification data so that the appropriate discipline review can occur.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
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4 W7LG W. G. Counsil Vice President n ! ?t6