ML19305B132
| ML19305B132 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/06/1980 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19305B127 | List: |
| References | |
| NUDOCS 8003190214 | |
| Download: ML19305B132 (3) | |
Text
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L L T J ::::r%M2rg'/ l0 February 6, 1980 Docket No. 50-245 Mr. Eldon J. Brunner Chief Reactor Operations and Nuclear Support Branch V. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Inspection 50-245/79-27
Dear Sir:
In reference to your letter received January 16, 1980, this report is submitted pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
1.
Apparent Item of Non-Compliance Technical Specification 6.8.1 states that written procedures shall be established and implemented for surveillance activities of safety related equipment.
Technical Specification 6.8.3 states that temporary changes to procedures be documented.
Technical Specification 1.Z.a states that test perfomance frequency shall not exceed 25% of the test intervals.
Contrary to the above, it was observed that:
Three surveillance tests were being accomplished without use of established procedures.
Temporary changes, which were not documented, were made to two calibration data sheets.
Three surveillance tests exceeded their required test i ntervals.
800319a 7g
Mr. Eldon J. Brunner U. S. Nuclear Regulatory Commission Page 2
Response
The apparent item of non-compliance involved failure to establish surveillance procedures, failure to document temporary changes and failure to adhere to surveillance frequencies.
Item 4.C(1)
Calibration of suppression chamber level instruments as required by TS 4.7.A.1 e or d was being accomplished using a generic calibration. A new procedure SP 411C was written and approved 1-1-80 to correct this item.
Item 4.C(l)
Functional tests of four heat detectors in the Diesel Generator Room as required by Technical Specifications 4.12.B.1.h.i.2, 4.12.E.1 and Table 3.12.2 were not accomplished by use of a plant procedure. However, these tests were completed in conjunction with the fire insurance companies inspection.
In the process of complying with both Technical Specification requirenents and the fire insurance company requirements this surveillance requirenent was overlooked. A new procedure SP
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680Q was approved on 1-1-80 to ensure future compliance.
Item 4.C(l)
Calibration of pressure instruments used to measure drywell to torus differential pressure was accomplished by a generic procedure in the past but this was corrected by the licensee in August of 1979. No further corrective action is necessary.
Item 4.C(2)
In two cases interim changes were either not made or were made a day late.
In these cases corrective action was taken and ACP-QA-3.02, " Station Procedures and Foms" was reviewed with the personnel in that department.
Item 4.C(3)
Semi-annual functional test of five detection instruments were accomplished in an interval in excess of the six months required by Technical Specifications. This is the same item as in 4.C(l) above and it has since been accomplished by new procedure SP 680Q which was approved on 1-1-80.
This new surveillance
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has been added to the ccmputer surveillance schedule.
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Mr. Eldon J. Brunner U. S. Nuclear Regulatory Comission Page 3 Item 4.C(3)
Semi-annual suppression chamber water level instrumentation calibration was accomplished in an interval in excess of that allowed by Technical Specifications. This item is the same deficiency as one in Item 4.C(1) above.
It is now being accomplished by procedure SP-411L which has been added to the computer surveillance schedule.
The items noted above are considered to be isolated examples of problems in a thorough and extensive surveillance program for Unit 1.
The Millstone Station QA Department will continue audits of this program to prevent recurrence of these deficiencies.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY f
&e:MY W.
. Counsil Vice President By:
W. F. Fee Vice President i