ML19351D371
| ML19351D371 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/18/1980 |
| From: | Counsil W, Fee W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19351D367 | List: |
| References | |
| AO1152, NUDOCS 8010100038 | |
| Download: ML19351D371 (3) | |
Text
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P. o. BOX 270 HARTFORD. CONNECTICUT 06101 NORTHEAST NUCLEAR ENERGY COMPANY 203-666-6911 d A NORTHEAST UTILITIES COMPANY August 18, 1980 Docket No. 50-336 A0ll52 Mr. Boyce H. Grier, Director Region 1 Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Office of Inspection and Enforcement Inspection Report 50-336/80-08 License DPR-65 Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Inspection Report No. 50-336/80-08 Pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, this reply is submitted to the above referenced audit report, which informed Northeast Nuclear Energy Company of apparent items of non-compliance with NRC requirements.
The response is included directly below the deficiency item of non-compliance ac identified in the Notice of Violation.
Deficiency ' tem of Non-Compliance Technical Specifications 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering... surveillance activities of safety related equipment."
ANSI N18.7-1972, 5.1.2, states, in part, " Procedures shall be followed....the written procedure to be present and followed step-by-step while the task is being performed."
Procedure ACP-QA-9.02, " Plant Surveillance Program", paragraph 6.4.4.1 requires in part, "...the surveillance testing shall be completed in accordance with the applicable procedure and any associated documents,...."
80101000X Contrary te the above, the following surveillance and inservice inspection activities were completed without consistent use of written procedures, and subsequently failed to meet the test prerequisites and the requirements.
EN21117, Containment Spray Pump 'B' Operational Readiness ISI test performed June 25, 1980.
EN21014, Azimuthal Power Tilt Measurement performed June 25, 1980.
Response to EN21117 Deficiency EN21117 was found to be performed using a Model 444A Mini-Ubiquitous Spectrum Analyzer that was not in current calibration. The instrument was subsequently checked for calibration and found to be satisfactory.
All data taken with this instrument were thus valid.
and This instrument has been formally entered into the station QA instrument program and will be periodically checked for calibration in accordance with that program. A review of all other equipment used for pump operability testing found no other uncalibrated equipment.
Engineering department personnel who perform inservice operability tests have been instructed to assure they comply with all procedure requirements.
As an aid in determining that only calibrated equipment is used for operability testing, pump operability data sheets will be changed to' require the instrument calibration date be recorded.
These changes will be conpleted by 10/1/80.
Response to EN21014 Deficiency A copy of procedure EN21014 was reviewed prior to the test and was in hand during test performance for reference.
The following arguments support that all initial conditions and prerequisites were met for the performance of this procedure.
1.
Azimuthal power tilt test, EN21014, was performed with the intent of using incere detectors.
This calculation is performed by computer and both incore and excore data sets print out simultaneously. Although both data sets were obtained, the intent was to use the incore measurement.
This was stated to the NRC inspector prior to the test.
The excore detector data obtained were not utilized.
The status of the excore system (with D' channel undergoing calibration) was reported with the incore measurement results.
2.
Although the reactor was in a mild xenon transient during the performance of the test, the reactor was in a " stable condition" with respect to tilt measurement for the following reasons:
The reactor was at a steady state power (82Il%) in excess a.
of 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
b.
Incore tilt was at a steady state value (0.004I.001) during that period.
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The computer scan time needed for acquiring the analog incore signals to perform the calculation is less than 30 seconds.
The measurement was completed at 82% power as this was the first significant (greater than 50%) power plateau.
The measurement was performed again at 100% power for conservatism.
EN21014 will be revised to more clearly define a " stable reactor" prior to 10/1/80.
Should you have any questions, please contact us.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY dif W. G ldounsil Senior Vice President i
By:
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W. F. Fee Executive Vice President t
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