ML040200300

10 CFR Part 21 Report Notification Regarding Radiation Monitoring System, Particulate Type, Possible Underestimation of Volumetric Activity Following an Automatic Filter Advance

ML040200300
Person / Time
Site:	San Onofre
Issue date:	01/14/2004
From:	Wilson M MGP Instruments
To:	Document Control Desk, NRC/FSME
References
-RFPFR
Download: ML040200300 (4)

Text

5000 Highlands Parkway Suite 150 Smyrna, GA 30082 Tel (770)432-2744, Fax (770)432.9717 Via: Fax and Courier 14 January 2004 US NRC Headquarters Operations Center Document Control Desk Nuclear Regulatory Commission Washington, DC 20555

Subject:

10 CFR part 21 Notification - MGP Instruments Inc.

Radiation Monitoring System, Particulate Type Possible underestimation of volumetric activity following an automatic filter advance

Reference:

NRC Event Number: 40445 Part name: Local Processing Unit, PIPS Particulate (LPU PIPS-P)

Part number: RMS-9041-SR with Application Software 564J

Dear Madam or Sir,

On 19 December 2003 MGP Instruments Inc. (MGPI Inc.) became aware of a potential anomaly in particulate radiation monitor, involving a specific family of local processing units (LPUs) manufactured b MGPI. Several LPUs were delivered for use in a safety related application as part of a fixed radiation monitoring system. MGPI Inc. hereby notifies the Commission, and the affected utility, in accordance with, the requirements of 10 CFR Part 21.

Based upon operational experience in a European nuclear facility, our sister organization (MGP Instruments SA) has determined that when an automatic filter advance occurred and, following a significant step change in specific activity, the measurement results could be underestimated. This underestimation exceeds the instruments specified accuracy level. Subsequent investigation into the cause of this anomaly indicated that the LPU's Application Software is not correctly updated with the filter advance signal.

The radiation monitor's particulate filter is stationary and it advances upon command from the LPU. The automatic filter advance scenarios are:

• High/low flow rate

• High/low differential pressure

• High activity

• Elapsed time In addition to the above, the filter can also be advanced upon manual command to the LPU.

The observed anomaly only occurs under certain conditions of automatic filter advance following a significant step change in activity. No credible anomaly is observed under manual filter advance command.

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5000 Highlands Parkway Suite 150 Smyrna, GA 30082 Tel (770)432-2744, Fax (770)432-9717 This anomaly is unlikely to affect the measurement results under normal operating conditions, or when a filter advance occurs prior to a step change in activity. However, a possible operational scenario exists that could occur, under accident or mild accident conditions, where a filter advance follows a step change in activity and therefore measurement results could be under-reported.

No such anomaly had been observed by MGPI Inc. or reported to MGPI Inc. from users within the US, prior to the information received through MGPI SA.

On 14 January 2004 MGPI Inc. completed a technical review and concluded that the anomaly constituted a failure to comply with the specification. Initial notification of this matter was provided by telephone to the NRC Operations Center, and the affected utility, in accordance with 10 CFR Part 21.

The safety related application of this device is limited to its installation at Southern California Edison's San Onofre Nuclear Generating Station. In particular, these devices are used exclusively in the Particulate Radiation Monitoring channel designated by the utility as skids 7804 and 7807. Eight (8) LPU PIPS-P were delivered for this application including those provided as replacement and spare parts (serial number listing indicated in attachment B).

Additional information about this issue may be obtained by contacting the undersigned or Mr. David Jarrow MGP Instruments Inc. Quality Assurance Manager at (770) 432-2744, extension 119 or Dr. Mike Edelman, Vice President at (770) 432-2744, extension 132.

Sincerely Yours:

Michael S. Wilson Vice President and Chief Operating Officer MGP Instruments Inc.

MSW/ME/dj Attachments:

Attachment A: 10 CFR Part 21 Notification Summary Attachment B: Equipment Serial Number and Location Listing cc:

By Fax:

Southern California Edison - Caroline McAndrews, Nuclear Oversight Division

- Robert McWey, Nuclear Oversight Division Southern California Edison - Art Shean, Supervisor Nuclear Oversight By E Mail:

MGP Instruments SA, Lamanon France: 0. Dieudonne, V. Ponclet, J.L Gouronc, A. Pommier, MGP Instruments Inc. Atlanta: D.Jarrow, M. Edelman, S.Lopez

5000 Highlands Parkway Suite 150 Smyrna, GA 30082 Tel (770)432-2744, Fax (770)432-9717 Attachment A:

10 CFR Part 21 Notification Summary:

MGP Instruments Inc. (MGPI Inc.) is providing the following information in accordance with 10 CFR 21.21 (c) (4).

I. Michael S. Wilson, Vice President and Chief Operating Officer, 5000 Highlands Parkway, Suite 150 Smyrna, Georgia 30082 is the responsible officer notifying the Nuclear Regulatory Commission under the provisions of 10 CFR Part 21.

II. The basic component involved in this condition are the Local Processing Units, PIPS- Particulate Type (LPU/PIPS-P) bearing the MGP Instruments Inc. part numbers RMS-904 1-SR, containing application software 564J. These components were specifically configured for installation in Southern California Edison, San Onofre Nuclear Generation Station's - Particulate Monitoring skids 7804 and 7807 and associated spare / replacement parts.

III- The local Processing Units indicated in (II) above were manufactured by MGP Instruments Inc.,

Smyrna, Georgia.

IV. The possible underestimation of volumetric activity following an automatic filter advance is not in compliance with the requirements for accuracy and response time as detailed in the Southern California Edison Procurement Specification No. SO I23-060-12 (rev. 2 dated January 16 1995) sections 1.6.2.3.4 and 1.22.5.3 V. The discovery of a potentially reportable condition was identified under the provisions of 10 CFR part 21 on 19 December 2003. A technical review, completed on 14 January 2004, confirmed that there was a potential for safety impact.

VI. Southern California Edison, San Onofre Nuclear Generation Station, has eight (8) safety related local processing units LPU PIPS- P Type. The identification for these units is listed in Attachment B of this notification.

VII. MGPI Inc. will take the following corrective action:

The LPU PIPS Application Software (Version 564J) will be revised to properly process automatic filter advance signal. The revised software will be provided to the utility as soon as possible (estimated 60 days).

VIII. MGPI Inc. recommends that Southern California Edison take the following actions prior to the installation of the revised Application Software:

It is recommended that the particulate filter on skids 7804 and 7807 be manually advanced at a frequency determined by recent operational experience on-site (typically once every two to three days) and following any alarm condition.

5000 Highlands Parkway Suite 150 Smyrna, GA 30082 Tel (770)432-2744, Fax (770)432-9717 Attachment B:

Applicable Equipment Identification SCE PO # Equipment MGPI P/N Qty SIN Location

______ _____T ype _ _ _ _ _

6V2D3002 (RAMSYS LPU/PIPS-P RMS-9041-SR 4 960203 Skid: 3RE7804 Monitors) 960204 Skid: 3RE7807 960205 Skid: 2RE7804 960207 Skid: 2RE7807 6E256015 Delivered to: SCE (Spare Part) LPU/PIPS-P RMS-9041-SR 2 960202 Warehouse Delivered to: SCE 960206 Warehouse 6G279914 Delivered to: SCE Release A014 LPU/PIPS-P RMS-9041-SR 1 020401 Warehouse (Spare Part) _

6G279914 Delivered to: SCE Release A024 LPU/PIPS-P RMS-9041-SR 1 030506 Warehouse (Spare Part)