ML17304B084
| ML17304B084 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/27/1989 |
| From: | Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-01180-DBK-T, 102-1180-DBK-T, NUDOCS 8904040146 | |
| Download: ML17304B084 (28) | |
Text
A.C CERE RATED DIPIBUTlON REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR:8904040146 DOC.DATE: 89/03/27 NOTARIZED: NO DOCKET IL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATXON KARNER,D.B.
, Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME RECIPIENT A'FFILIATXON R
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 890223 ltr re violations noted in Insp Repts 50-528/89-03,50-529/89-03
& 50-530/89-03.
DISTRIBUTION CODE:
IEOSD COPIES RECEIVED:LTR Q ENCL l
SIZE:
TITLE: Environ
& Radiological (50 DKT)-Insp Rept/Notice of Viola z.on Response NOTES:Standardized plant.
05000528/
Standardized plant.
05000529 Standardized plant.
05000530+
INTERNAL:
RECIPIENT ID CODE/NAME PD5 LA CHAN,T DAVIS,M.J.
ACRS NMSS/LLOB 5E4 NRR/DLPQ/PEB 11 NRR/DREP/EPB 10 NRR/PMAS/ILRB12 OGC/HDS 1 RES RGN5 FILE 01 RGN4 MURRAY,B COPIES LTTR ENCL 1
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1 NOIK K) ALL "RIDS" RECIPIENIS:
D PIZASE HELP US TO REDUCE HASTE! ~CZ 'IHE DOCIJMBG'OPXROL DESK, ROOM Pl-37 (EXT. 20079) Io ELIK2QTE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMEWZS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUXRED:
LTTR 31 ENCL 30 6
102-01180-DBK/TDS/JJN March 27, 1989 U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
Reference:
Letter from G.
P.
Yuhas,. Chief Emergency Preparedness and Radiological Protection
- Branch, U. S. Nuclear Regulatory Commission to Arizona Nuclear Power Project, Attn. D.
B. Karner, Executive Vice President, dated February 23, 1989
Dear Sir:
Subject:
Palo Verde Nuclear Generating Station Units 1, 2 and 3
Docket No.
STN 50-528 (License No. NPF-41)
STH 50-529 (License No. NPF-51)
STN 50-530 (License No. HPF-74)
Reply to a Notice of Violation - 529/89-03-01 File:
89-070-026 This letter is provided in response to the routine inspection conducted by Mr.
G. Cicotte from January 30 through February 3,
1989.
Based upon the results of this inspection a violation of NRC requirements was identified.
The violation is discussed in Appendix A of the referenced letter.
A restatement of the violation and PVNGS's response are provided in Appendix A
and Attachment 1, respectively, to this letter.
PVNGS has recognized the deficiencies in the design of the radiation monitoring system and in the procedural control of the radiological effluent monitors.
As described in Attachment 2,
PVNGS created a task force of eleven full time personnel for approximately one year to improve thh design of the radiation monitoring system.
This task force began in October of 1987 and continued through November of 1988.
Major tasks included updates of vendor technical
- manuals, drawings, and parts list, upgrade of computer hardware and
- software, confirmation of monitor design, evaluation of communications link between monitor and computer, evaluation and correction of software problems, recommendation for flow monitor flow control, development of detector rebuild procedures, responsibility matrix and operability flow chart.
Based upon the results of the task force, recommen'dations were made to further enhance the program as described in Attachment Z.
A comprehensive review of the radiological effluent program which included the regulatory requirements, existing procedures, and training was conducted during 1988.
An action plan and completion schedule have been developed to implement the recommendations resulting from the review and to include enhancements in the use of procedures during radiological effluent activities.
Further details and the schedule for implementation of actions are described in Attachment 3.
@Pod 8904040146 Sr0327 PDR AOOCK 05000523 O
PDC I
i 41 j
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Document Control Desk Page 2
102-01180-DBK/TDS/JJN March 27, 1989 These two major projects are expected to improve the overall reliability of the radiation monitors and the implementation of the radiological effluents program.
If you should have any questions regarding this response, please contact me.
Very truly yours, Donald B. Karner Executive Vice President DBK/TDS/JJN/kj Attachments cc:
E.
E.
J.
B.
M. J.
T. L.
T. J.
A. C.
Van Brunt Martin Davis Chan Polic Gehr
, Jr.
Pocument Page 3
Control Desk 102-01180-DBK/TDS/JJN March 27, 1989 bcc:
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Bocument Control Desk Page 1 of 1
102-01180-DBK/TDS/JJN March 27, 1989 APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating Station Unit 2 Docket No. 50-529 License No
~
NPF-51 During an NRC inspection conducted January 30 - February 3,.1989, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2; Appendix C (1988),
as modified by 53 Fed.
Reg.
40019 (October 13, 1988) the violation is listed below:
,A.
Technical Specification 3.3.3.8 states, in part, that the radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3. 11.2.
1 are not exceeded, and that the action shown in Table 3.3-12 shall be taken with less than the minimum number of channels OPERABLE.
Table 3.3-12 requires in part that ACTION 42 be taken for inoperability of the particulate sample channels of high range process effluent radiation monitors RU-142, RU-144, or RU-146.
ACTION 42 requires in part that operability be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or that the pre-planned alternate sampling program be initiated.
Contrary to the above, from April 27, 1988, to December 14,
- 1988, the particulate sampler channels of RU-142, RU-144, and RU-146,'were inoperable, in that no sample media were present, and the ACTION specified was not taken.
This is a Severity Level IV Violation (Supplement IV).
Document Control Desk Page 1 of.'5 102-01180-DBK/TDS/JJN March 27, 1989 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 529 89-03-01 I.
REASON FOR VIOLATION On December 14,
- 1988, PVNGS discovered that the particulate filters in all three Unit 2 high range radiation effluent monitors were missing.
The event was subsequently reported in Licensee Event Report (LER) 529/88-17-00 dated January 13, 1989.
Based upon information currently available, PVNGS believes the particulate filters were improperly removed at some time between April 27, 1988 and Hay 9, 1988 and were not replaced until discovery on December 14, 1988.
This assumption is based upon the following information.
On April 27, 1988, Unit 2 Chemistry Department personnel properly replaced all the particulate filters and iodine cartridges in the three high range monitors (RU-142, RU-144, and RU-146).
The replacement iodine cartridge assemblies utilized a plastic enclosure.
On April 29 and May 4,
- 1988, Engineering Evaluation Requests (EER),
88-Sg-084 and 88-Sg-085 respectively, were initiated to evaluate the adequacy of plastic iodine cartridges.
The evaluations conducted determined that it is preferable to utilize metal encased iodine filters vice the plastic enclosed filters.
On Hay 9,
- 1988, an approved work authorization document was issued to
Bocument Control Desk Page 2 of 5 102-01180-DBK/TDS/JJN March 27, 1989 REPLY TO NOTICE OF VIOLATION 529/89-03-01 adjust and/or replace as necessary the filter/cartridge assembly holder in all three high range monitors (RU-142, RU-144 and RU-146) to accommodate the use of metal encased filter cartridges in Unit 2.
Based upon interviews conducted with a Maintenance Department technician performing the work, it is believed that metal encased iodine filters were found to be already installed in seven of the nine cartridge locations.
(Each high range monitor has 3 channels.)
The M'aintenance Department technician noted that two plastic encased iodine cartridges were installed and required replacement with the metal encased iodine cartridges.
The technician does not recall replacing the particulate filters at this time.
Therefore, it is assumed that the. particulate filters would have been discarded with the previously installed plastic cartridges.
The technician did not (and would not be expected to) note whether the particulate filters were installed in the other, seven locations.
On December 8,
1988, Unit 3 Chemistry Department personnel identified a
concern regarding the validity of wet sample media in the Condenser Evacuation System Low Range Monitor (RU-141).
It was noted that moisture periodically condenses and collects in the iodine cartridge.
Since the validity of data obtained utilizing wet iodine cartridges was
- unknown, an Engineering Evaluation Request was initiated to request an engineering evaluation of the wet cartridge problem.
During the preliminary stages of the engineering evaluation, it was noted that excessively wet iodine cartridges potentially rendered sample results
Document Control Desk Page 3 of 5 102-01180-DBK/TDS/JJN March 27, 1989 REPLY TO NOTICE OF VIOLATION 529/89-03-01 invalid.
This information was communicated to the Unit 2 Chemistry Department personnel on approximately December 13, 1988.
On December 14,
- 1988, a Unit 2 Chemistry Department Technician was inspecting the Condenser Evacuation System High Range Monitor (RU-142) for moisture problems when the technician noted that the particulate filter was missing.
The technician 'then inspected the Plant Vent High Range Monitor and noted that the particulate filter was missing.
The technician replaced the filters in RU-142 and RU-144 and requested another technician to inspect the Fuel Building Ventilation System High Range Monitor (RU-146).
The particulate filters were also discovered missing in RU-146 and were repl'aced.
Based upon the above, it is assumed that new particulate filters were not installed when the plastic iodine cartridges were replaced between April 27, 1988 and May 9, 1988 and, therefore, the particulate channels in the three high range monitors (RU-142, RU-144, and RU-146) were inoperable for approximately 7 months.
The cause of the event is personnel error as a result of inadequate controls for installing consumable parts (e.g., filters, cartridges, etc.) utilized in the radiation monitoring system monitors and the responsibility to perform the filter/cartridge change out.
There were no PVNGS procedures to ensure that the filter/cartridge replacement is controlled in accordance with approved, documented methodologies (e.g.,
Document Control Desk Page 4 of 5 102-01180-DBK/TDS/J JN March 27, 1989 REPLY TO NOTICE OF VIOLATION 529/89-03-01 Chemistry Department procedures, approved work authorization documents, etc.).
II.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED As an immediate corrective action, new particulate filters were installed in Unit 2.
The particulate filters in Units 1 and 3 were verified to be correctly installed.
No discrepancies were noted in Units 1 and 3.
III.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Additional controls have been developed delineating the appropriate consumable items to be utilized in the radiation monitoring system monitors and the responsibility for the Chemistry Department to perform the filter/cartridge change out.
Procedural controls utilized by Chemistry Department personnel for filter/cartridge change out in the low range monitor have been revised to include appropriate instructions for high range filter/cartridge change out.
Direction have been provided to all appropriate Unit 1, 2, and 3 personnel that only Chemistry Department personnel are to replace consumable items (e.g.,
filters, cartridges, etc.) in the Radiation Monitoring System Monitors.
The additional controls, in conjunction with Chemistry Department procedures provide adequate traceability of activities such as filter change out performed on the Radiation Monitoring System Monitors.
These
Bocument Control Desk Page 5 of 5 102-01180-DBK/TDS/JJN March 27, 1989 REPLY TO NOTICE OF VIOLATION 529/89-03-01 instructions require verification of the proper flow orientation of the particulate filter and iodine cartridge and independent verification of the appropriate parts and assembly.
IV.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED As discussed in Section II of this response, full compliance was achieved on December 15, 1988 when the filters were replaced in the monitors.
The procedural controls/revisions discussed in Section III will be implemented on March 28, 1989.
Document Control Desk Page 1 of 16 102-01180-DBK/TDS/JJN March 27, 1989 ATTACHMENT 2 Radiation Monitoring System (RMS)
Improvement Program I.
INTRODUCTION In October
- 1987, an RMS Reliability Improvement Project was formed to improve the overall reliability of the RHS.
The project consisted of
, eleven full time personnel and lasted for approximately one year.
Three system engineers assured prompt response to operating system problems.
Two software engineers were assigned the microcomputers (used at each monitor) and the host minicomputers used to display data in the Control Room and Effluent Groups office.
Two hardware engineers were assigned the microcomputer hardware and communications link between the microcomputers and minicomputers.
These individuals also assisted in the preventive and corrective maintenance of the minicomputer.
A hardware technician was assigned to assist in the maintenance of the computer portions as well.
Two warehouse support personnel were assigned the responsibility to update Purchase Orders and the class and item numbers for spare parts.
In addition, a project lead was assigned the task of coordination.
The major areas assigned to the task force were:
Overall System:
including systems,
- drawings, documentation, spare parts, training, and reliability analysis and reporting.
Computer Hardware:
including microcomputer hardware, minicomputer
- hardware, and communication hardware.
Document Control Desk Page 2 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program Computer Software:
including microcomputer software and minicomputer
- software, and Field Device Hardware:
including detectors/signal conditioning and sampling hardware II.
OVERALL SYSTEM 1.
System Drawings:
A.
Action Completed Documents which were previously not available or inadequate were added or revised.
For example:
A manufacturers'ross reference parts list of Kaman parts will be useful for determining equivalent substitute parts.
A bill of materials subdivided by monitor has also been generated.
This provides a complete breakdown of each monitor into its sub-assemblies and then the sub-assemblies are further broken down to their individual I
components, This is very useful in obtainir3g information on ordering parts for personnel in the field.
Document Control Desk Page 3 of 16 102-01180-DBK/TDS/JJN Harch 27, 1989 Radiation Honitoring System (RHS)
Improvement Program The monitor cross-reference report was completely revised to list for each monitor the most pertinent drawing and assembly numbers associated with that monitor.
This assists field personnel during maintenance and troubleshooting to quickly locate the correct drawing.
B.
Outstanding Action All RHS vendor supplied drawings are being upgraded to a mylar version of the latest revision.
This requires an extensive review of some 650 vendor supplied drawings.
This is resulting in much more legible prints with added details reflecting upgrades that have occurred since original print.
The drawings are also being reviewed for applicability and configuration control.
Expected Completion Date:
November 1,
1989 Work requests have been submitted to perform an as-built verification program.
These investigative work orders may be worked in conjunction with preventive maintenance or surveillance tests.
This was done so that a representative investigation will be performed across the entire site.
The RHS System Engineer will coordinate with Engineering to complete this item as field data is provided.
Document Control Desk Page 4 of 16
~
102-01180-DBK/TDS/JJN March 27, 1989 Radiation Honitoring System (RHS)
Improvement Program Expected Completion Date:
January 1,
1990 2.
Documentation A.
Action Completed A detailed system documentation review was conducted which led to the discovery and correction of a number of significant problems.
This investigation was an objective of all personnel assigned to the project;
- however, major emphasis in this review was as a result of the evaluation in the isotopic calibration program and the in-depth troubleshooting on the microcomputers.
A complete rewrite of the mini-to-micro communications theory was necessary since the originally supplied generic description was not fully applicable to PVNGS.
The communication theory description has also been included into the training manual and provided to the maintenance organizations.
B, Outstanding Action An evaluation will be performed to determine the value of I
rewriting the Kaman Operat-ion and Maintenance manuals.
Expected Completion Date:
January 1,
1990.
Document Control Desk Page 5 of 16 102-01180-DBK/TDS/J JN Harch 27, 1989 Radiation Honitoring System (RHS)
Improvement Program 3.
Parts A.
Actions Completed Spare parts which were previously unidentified have been inventoried, and transfer packages to return these parts to proper storage locations have been developed for Procurement Engineering review on approximately 150 items.
All Class and Item warehouse stock numbers. were reviewed and resubmitted with current information regarding the following:
technical references, minimum/maximum stocking levels, and a
re-order policy.
These Class and Item number updates have been submitted for approval.
Once approved and entered by inventory control, they will completely reflect the necessary spare parts for the RHS.
This was an extensive task:
2500 Class and Item numbers were reviewed.
The sale of Kaman Instrumentation's RHS Business Unit had a
negative impact on spare parts availability.
At the time Kaman announced their plan for the sale, there were open spare and repair parts purchase orders in the amount of $300,000 that were active with PVNGS.
Project personnel resolved these open purchase orders since many unknowns existed about the
'availability of parts for the long term.
This was
Document Control Desk Page 6 of 16 102-01180-DBK/TDS/JJN Harch 27, 1989 Radiation Honitoring System (RNS)
Improvement Program accomplished in minimal time to reduce impact on field personnel with regard to the availability of spare parts.
The new company, Amalgamated Services Incorporated (ASI), has been evaluated by vendor guality Assurance and placed on the approved vendor list.
Since ASI purchased all design documentation from Kaman Instrumentation, ASI is capable of supplying materials.
ASI has begun to supply replacement parts for the system.
B.
0'utstanding Action PVNGS will complete the transfer of all RHS material.
Expected Completion Date:
June 1,
1989 PVNGS will update and approve the Class and Item numbers.
Expected Completion Date:
June 1,
1989 4.
Training A.
Action Completed A significant portion of the project's emphasis was placed in
Document Control Desk Page 7 of 16 i 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program the training area.
This was accomplished by assisting the Training Department with their task of organizing a formal training class on the RHS and working with field personnel on a routine basis.
Construction of an off-line development system by the RHS Reliability Improvement Program personnel has been a major asset in support of training and maintenance.
This consists of a minicomputer, Data Acquisition System, and a selected assortment of actual radiation monitors to replicate, on a
small scale, an actual plant RHS.
This provided the ability to debug software and verify hardware changes.
In addition, it allows field personnel to both train on and have access to a functional off-line unit.
B.
Outstanding Action The formal classroom training is still under development.
Training is revising classroom materials and the lesson plans to reflect these changes.
Expected Completion Date:
June 1,
1989 P
5.
Reliability Analysis and Reporting Monthly project status reports with availability data and other key
Document Control Desk Page 8 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program system parameters were issued.
- Also, a monthly walkdown checklist was developed for use by the System Engineers.
In addition, periodic site user group meetings were held and were useful in disseminating information about problems encountered and improvements being implemented.
An "Areas of Responsibility" matrix is being developed for each monitor which indicates the responsibility for certain key areas with respect to maintenance and operability questions.
In
- addition, a flow chart was developed for each of the Technical Specification monitors as an aid for determining operability of that monitor.
Expected Completion Date:
June 1,
1989.
III.
COMPUTER HARDWARE 1.
Microcomputer Hardware A.
Action Completed An in-depth evaluation of the microcomputer hardware was performed.
A valuable portion of this endeavor arose from the construction of the off-line development system (as discussed
- above, section 11.4.A).
This allowed members of the project
Document Control Desk Page 9 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RHS)
Improvement Program to assemble portions of the system while performing a
comprehensive evaluation of each assembly under construction.
The primary method of evaluation utilized a Hewlett Packard 1650 logic analyzer with an 8085 cross assembler software
'ackage.
The logic analyzer has the capability of examining what instructions the microprocessor is performing.
The analyzer proved to be successful in diagnosing problems.
The results of these investigations revealed few hardware design
- errors, but did help locate numerous software errors which
.have been documented and are being corrected.
Overall, the design and implementation of the microcomputer hardware appears very solid and the processor very reliable.
The change to re-manufactured CPU and RAN boards for "old scope" monitors has shown a vast improvement in reliability.
These circuit boards are a direct functional replacement for the older style circuit boards.
The new scope CPU board is essentially an off the shelf Intel product which is fully supported by Intel.
B.
Outstanding Action Failures of new scope Revision F system boards have occurred
Document Control Desk Page 10 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program and have been documented on Root Cause of Failure Engineering Evaluation Requests.
This increased failure rate appears coincident with the change from Revision D to Revision F and was identified to 'the original vendor as early as October 1986.
Unfortunately, all circuit boards of this'ype, which have failed during the period of the RHS project, either could not have their failure condition duplicated or the failure was easily isolated to a single component.
For this reason, no conclusive solution could be provided for these failures, and consequently a letter was written to the original vendor to attempt to obtain more details about the circuit board.
PVNGS anticipates that this data will provide some solution to the problems which have been observed with this board.
Expected Completion Date:
July 1, 1989 A replacement power supply is being evaluated for old scope monitors and is currently under evaluation through Plant Change Request 88-13-Sg-001.
The presently installed power supply has been identified as a high failure item.
Expected Completion Date:
July 1-,
1989 2.
Minicomputer Hardware The primary concern in this area was insufficient processing
Qocument Control Desk Page 11 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program capability with the standard Digital Equipment Corporation PDP 11/34.
Modifications were considered for increasing the processing power of the existing system.
This eventually led to the approval of a work authorization for upgrading the processor, disk drives, control room printers, screen dump capability addition, and software required to make use of the increased memory capability present in the upgraded CPU.
Software was also purchased which monitors CPU loading and provides statistics on various key parameters indicative of overall system performance.
The resulting data indicated that after the changes were installed that there is approximately 70 percent spare CPU utilization of the minicomputer.
Based on this fact and the overall improvement of reliability of the minicompter, future software enhancements for operator friendliness are achievable without degradation of system performance.
1 3.
Communications Hardware An in-depth analysis of communications has provided significant insight into overall system operation.
A functional description of communications was developed.
It is anticipated that this detailed description of operation will assist maintenance personnel to gain a better insight into the monitor communications so that overall reliabili.ty of communications may remain high.
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Jocument Control Desk Page 12 of 16 102-01180-DBK/TDS/JJN Harch 27, 1989 Radiation Honitoring System (RHS)
Improvement Program IV.
COMPUTER SOFTWARE Software documentation was generated for the system which included software requirement specifications and software design descriptions.
This set of documents provides a means to judge design versus rework changes in the future and also provides a means for gaining an in-depth knowledge of the operation of the monitor software.
A software Validation and Verification was performed on the system resulting in the identification oF 101 deficient items.
None of these items were significant to be reported.
A plan for resolution of these deficiencies has been developed.
1.
Hicrocomputer Software A.
Action Completed During investigation of problems in an unrelated area of the
- project, a deficiency was found in the algorithm of process monitors for Particulate/Iodine channels which had previously used a stepped filter mechanism for sampling.
This was initially reported to the vendor, who in turn reported it to the NRC as a Part 21 reportable condition.
Correction of this deficiency resulted in significant expenditure of resources to resolve and rewrite the applicable software.
1
. document, Control Desk Page 13 of 16 102-01180-DBK/TDS/JJN March'27, 1989 Radiation Honitoring System (RHS)
Improvement Program In excess of 20 separate microcomputer software problems were identified and documented during the course of, the project.
A high priority was placed on this activity since the types of problems encountered required immediate evaluation to ensure that all operability requirements had been and were met.
A third party vendor performed and documented an independent
'eview of all monitor algorithms as the result of continuing concerns over monitor operability.
The findings of this report indicated no additional problems other than the previously identified stepped filter algorithm.
Additionally, this independent review concurred with the resolution which was installed to correct the problem.
Again, the development system proved invaluable for software testing and debugging with the alternative to this approach being to use an actual in-plant monitor.
B.
Outstanding Action Approximately ten identified deficiencies affecting microcomputer software remain and require retesting and implementation in each unit.
These deficiencies have been evaluated for operability impact, and although each one is important, they were found not to impact continued operation of the monitor.
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document Control Desk Page 14 of 16 102-01180-DBK/TDS/JJN Harch 27, 1989 Radiation Honitoring System (RHS)
Improvement Program Expected Completion Date:
Harch 31, 1990 2.
Hinicomputer Software A significant number of software changes have been accomplished to enhance the overall availability and maintainability of the PDP-ll/34 minicomputer.
The availability was in excess of 99.6 percent since January 1988.
Changes which require testing prior to implementation in the units have been made on the off-line development system.
These were enhancements to many of the commonly used minicomputer displays.
Expected Completion Date:
Harch 31, 1990 V.
FIELD DEVICE HARDWARE A.
Action Completed 1.
A review of the vendor supplied calibration reports resulted in a proposed isotopic calibration program.
Radiation Protection and Chemistry Standards is evaluating this plan.
As a result of this in-depth review, a significant deficiency was noted in reference to the Post Accident High Range Particulate/Iodine detector and channel operation.
This resulted in the following:
Document Control Desk Page 15 of 16 102-01180-DBK/TDS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program EER 88-SQ-072
- Dispositioned to provide details of the method which the software should control valves and to remove the fixed time for the alarm to change channel.
EER 87-SQ-054
- Dispositioned to provide details on the collection and handling of a post accident
- sample, also referenced EER 88-SQ-158.
Amalgamated Services Incorporated technical report 460052-002
- Contracted by RMS Reliability Improvement Program to provide calibration details on P/I detector since no primary isotopic calibration had been performed on this detector.
-: Performed In-situ calibration with NBS traceable sources for data collection to be included with EER 88-SQ-158.
EER 88-SQ-158
- Initiated to resolve questions concerning design flow rates of plant effluents, how these effect monitor sample flow rates, and collection times for the isokinetic nozzle design for site mod 13-SM-SQ-004 and PCP 85-13-SQ-037.
1
'Document Contr'ol Desk Page 16 of 16 102-01180-DBK/TOS/JJN March 27, 1989 Radiation Monitoring System (RMS)
Improvement Program B.
Outstanding Actions The isotopic calibration program will be evaluated.
Expected Completion Date:
June 1,
1989.
2.
Sampling Hardware Two separate changes have been initiated to resolve the moisture problems associated with the condenser vent monitors RU-141 and RU-142.
The first change installs a moisture trap, and changes to sample line drains under site mode 13-SM-AR-001.
The second change provides heat tracing to the sample lines under PCP 86-13-Sg-030.
The combination of these changes will resolve moisture carryover into the detector and pumping systems of the monitor which has been the source of numerous problems in the past.
Expected Completion Date:
January 1,
1990 3.
EER 88-Sg-158 final resolution.
Expected Completion Date:
May 30, 1989
"Document Control Desk Page 1 of 2 102-01180-DBK/TDS/JJN Harch 27, 1989 Attachment 3
Radiological Effluent Improvement Program The primary objective of the Radiological Effluent Improvement Program is to define and issue a
PVNGS policy containing the functional responsibilities required for successful implementation of radiological effluent activities, to
- revise, develop and issue the implementing procedures needed to ensure compliance with regulatory requirements, and to improve radiological effluent personnel's knowledge of the process and qualification requirements.
An action plan and schedule has been developed to achieve this objective.
The following discussion provides a description of the action plan.
The Chemistry Standards Section is'currently developing a policy to define the radiological effluents program and functional responsibilities to support the program.
The policy will establish a single point of accountability for the radiological effluents program.
The policy will provide the appropriate interface for implementing procedures.
The new policy and instructions will be process oriented.,
This will replace the number of procedural interfaces required to perform a task.
Expected Completion Date:
September 1,
1989 Concurrently, the existing implementing procedures will be revised to support all radiological effluent activities until completion of the newly developed procedures.
Instruction Change Requests and LER commitments will be reviewed to ensure instruction adequacy.
Additionally, recommendations from Unit Chemistry Personnel and an independent consultant will be included in the review.
~'ocument Control Desk Page 2 of 2 102-01180-DBK/TDS/JJN March 27, 1989 Effluent Improvement Program Expected Completion Date:
June 1,
1989 In addition to the enhancement of the administrative controls, further enhancements of the training program, radiological effluents tracking system
- software, and RMS hardware designs are in progress.
(As discussed in the RMS Reliablity Improvement Program).
The training requirements for the radiological effluent technicians are being re-evaluated to upgrade the current on-the-job qualifications.
In particular, additional training in the general knowledge of the system and design vice task oriented skills will be included.
The training will also include the revised/new procedures,
- policies, and instructions as discussed above.
Expected Completion Date:
September 1,
1989