ML20244A478

Responds to 780821 NRC Ltr Re Violation Noted in Inspec Rept 50-366/78-26.Does Not Consider Item to Be a Noncompliance. Corrective Action:Slight Setpoint Adjustment of Refueling Water-Low Instru Channels.(Encl to 7810060211)

ML20244A478
Person / Time
Site:	Millstone
Issue date:	09/12/1978
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
TAC-7317, TAC-7321, TAC-7420, TAC-7546, TAC-8169, TAC-8631, NUDOCS 7810060216
Download: ML20244A478 (2)

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September 12,1978 Mr. Boyce H. Grier Director Region I, Office of Inspection and Enforcement - U.S. NRC 631 Park Avenue King of Prussia, PA. 19406 Gentlemen:

In Inspection 50-336/78-26, you identified an apparent item of noncompliance as follows:

Technical Specification Table 3.3-4, item 6.b requires that the trip value of the Refueling Water Storage Tank-Low instrument channels be set at 30 inches above the tank bottom.

Contrary to the above, as of August 3,1978, the subject trip value settings were not set at 30 inches above the tank bottom. The results of the level sensor calibration performed in April 1978 documented that the following trip value settings referenced to the bottom of the tank were established: L1-3001, 27.5"; L1-3002,28"; L1-3003,27"; and L1-3004,27.5".

You indicated in your report tnat because the item was corrected orior to the completion of the inspection, no response was required.

NNEco has nonetheless elected to respond because we do not consider this item to be in noncompliance with the intent of the technical specifications. In l fact, the corrective action involved adjusting the setpoints a slight amount in a nonconservative direction, although the end result was still conservative with respect to the bases.

The item which in actual fact requires correction is that the numerical value of the setpoint does not have "less than" in front of it. The basis for tr.e j specification is to ensure that during the design basis incident a sufficient

! portion of the volume of the RWST is injected into the containment prior to sump l recirculation actuation. There is no basis or reason to establish a lower value for this setpoint other than to ensure the setpoint is above the instrument tap.

The setpoint has previously been the subject of review and, as noted in the in-spection report, prior to the referenced inspection a Technical Specification Change request had been submitted to modify the setpoint.

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2-T NNECo strongly feels that at the most this item should have been classified as an open item pending issuance of the change to the specifications.

We request that you reconsider your classification of this item.

s Very truly yours, Northeast Nuclear Energy Company W. G. Counsil Vice President WGC/ECF:daa

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