ML20148N633

Responds to Conversation Re Nuclear Data Sys Prompt Notification Sys That Have Software That Might Cause Public Reportability,Per 10CFR21.Steps Taken to Modify Internal Procedures to Notify All Power Plant Customers

ML20148N633
Person / Time
Site:	Callaway
Issue date:	03/18/1988
From:	Samsky D CANBERRA NUCLEAR (FORMERLY NUCLEAR DATA, INC.)
To:	Wigginton J NRC
Shared Package
ML20148N630	List: ML20148N633
References
NUDOCS 8804070177
Download: ML20148N633 (1)

Text

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Nuclear Data Inc.

instrumentation Division 2734 South Cobb Industrial Boulevard Smyrna, Georgia 3o062 E Telephone (404) 434 9889 March 18, 1988 Mr. Jim Wigginton U.S. Nuclear Regulatory Comission Washi.1gton, D.C. 20555

Dear Mr. Wigginton:

This letter is in response to our recent conversations concerning prompt notification of Nuclear Data customers that have software that might cause public repertability under 10CRF part 21.

Nuclear Data has taken steps and modified our internal procedures to include the notification of all power plant customers when we become aware of a "critical software" problem. These procedures have been in effect since March 13, 1987.

The notification includes two parts.

1. Notification of the proolem and its possible consequences.

2. If known, a "work-around" solution to temporarily correct the problem  !

until a formal program correction is announced.

Nuclear Data will work with our customers with sof tware support contracts on formally correcting the problem. Customers not under contract have the responsibility to implement action that will, in their opinion, correct the problem. Nuclear Data will enter into a contract with any customers that request assistance in correcting a critical software problem.

Last year at the time of the problem with the Waste Editor program at Callawa/, we determined that this problem was not generic with all customers having a Waste Editor program, but was specific to the modifications required by Callaway's requirements for set-point calculations and off-site dose calculations. Accordingly, we working with Callaway to assure ourselves and them that the problem had been resolved. Callaway personnel corrected the I

l problem.

I If you have additional questions or would like to audit our procedures that cover the above situations, please call either mysalf at 404/434-9889 or Bob Kujawa at 312/884-3738, t

Sincerely, A A 8904070177 0D0318 I DR ADOCK 050 4 l

David Samsky Manager, Software and Services DNS/mpe

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Mr. Michael Ault Technical Manager Nuclear Power Division Nuclear Data, Incorporated 2734 S. Cobb Indiana Boulevard Smyrna, Georgia 30080

Dear Hr. Ault:

The Nuclear Regulatory Comission has received a nuclear power reactor (Callaway) licensee event report (LER) that describes a computer software i deficiency relating to control of radioactive liquid releases. The software package,"WasteEditorProgram"(WEP),issuppliedbyyourcompany(ND)andis run on the. ND 6685 computer. As stated in detail in the enclosed copy of the LER, in some instances the WEP calculated non-conservative values for the alam/ isolation setpoint function required by the facility's technical speci-fications. This isolation function eutematically teminates the liquid release when the calculated alam level is reached. These setpoints values were non-conservative (too high) by approximately three orders of magnitude. The Callaway plant's review of the affected releases showed no actur.1 abnomal levels of radioactivity were released and no regulatory requirements were violated as a result of the software defect.

As Mr. Wigginton of my Branch discussed with you on April 2,1987, computer code deficiences that could cause or lead to a major reduction in the degree of protection provided to the public is reportable under 10 CFR Part 21 (for clarification, see enclosed IE Infomatie,i Notice, IN 85-52). After disi:ussions with the licensee and a review of the events snd circumstances at Callaway plant, we believe the WEP problem was reportable under 10 CFR Part 21. From our review of a ND memorandum (Kujawa - Scheckel, March 13,1987) which clarifies ND's customer problem notification policy,' we understand that your company will notify all effected NRC licensees when a product problem such as WEP deficiency arises.

One of the responsibilities of my Branch is to identify and help resolve generic industry problems. When appropriate, this responsibility also includes notify-ing industry. We would appreciate a copy of the end-user notification, written sumary of corrective actions, and a. list of all affected NRC licensees. In cases such as this, when vendor's problem resolution is reasonable and thorough, we typically do not issue an infomation notice to industry, thus avoiding dupli-cation of efforts.

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Mr. Michael Ault APRS 41987 If you have any questions about tnis matter, please contact me (301) 492-4734 or James Wigginton (301) 492-4663.

Sincerely, I LeMoine J. Cunningham, Acting Chief Radiation Protection Branch

. Radiation Protection and Emergency Preparedness Division

Enclosure:

As stated cc: R. E. Kujawa, Nuclear Data Incorporated 0

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is January 14, 1987 Cahay Pwit U. S. Nuclear Regulatory Commission Docunent Control Desk Washington, DC 20555 ULNRC-1431 Gentlemen:

DOCKET NUFBER 50-483 CALLAWAY PLANT UNIT 1 FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 86-039-00 ACTION STATEMENT NOT ENTERED WHEN LESS CONSERVATIVE RADIATION MONITOR SETPOINT CALCULATED DUE TO COMPUTER SOFTUARE E The encloa, Licensee Event Report is submitted pursuant to 10 CFR 50.73(a)(2)(i) concerning a failure to enter Action Statement (a) for Technical Specification 3.3.3.9, Radioactite Liquid Effluent Monitoring Instrumentation, when a less conservative alare/ trip sa.tpoint van calculated for Radiation Monitor HB-RE-18 due to computer sof tware error.

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. . . . ,..~,. , a, , , , -,,.. w., n s i Ant a AC1,0 on 12/15/86, a utility Health Physicist discovered that a liquid radioactive release from Discharge Monitor Tank 'B' on 10/19/86 at 230!.

CDT to 10/20/86 at 0521 CDT, was perfor=ed with the Liquid Radwaste Discharge Monitor, HB-RE-18, set at a trip setpoint less conservative than that required by Technical Specification (T/S) 3.3.3.9. Upon Accordingly, Action Statement (a) of this T/S was not met.

l subsequent review, it was discovered that 7 similar events have occurred l since initial criticality '10/2/84). The plant was in Mode 1 - Power j

I Operation at 98'; power at the time of discovery.

A Health Physics Nuclear Data, Inc. ND6685 computer software deficiency (k'aste Editor Progran [k'EP)) caused the non-gamma emitter value to be summed with the gamma emitters resulting in a less conservative setpoint calculation.

Technicians were instructed to check non-gamma emitterAll designatorr liquid release on permits and in the interim, a prccadure was revised. Software has been te permits were reviewed.

k'EP will be permanently revised to permit editing non-gaena emitters.

l Technicians will receive additional training.

Actual post There was no threat to the health and safety of the public.

Sampling and release data shows that T/S limits were not exceeded.

analysis, release calculations, permit approvals, and discharge line

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 13,ipt5 l'3188 E i W8 il 4th Uwelm its g . A C E 13'

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0l0 0l2 0' 0 16 rtxw - w ,emo.wcn mem This LER covers eight similar reportable events. The events are summarized in Table 1, Evaluation of Post-Release Data.

Plant conditions at the time of each event are summarized in Table 2, Plant Conditions at Time of Events.

Description and Innediate Corrective Actions Event Eight referenced in Table I was discovered on 12/15/86 at 1310 CST by a utility nonlicensed Health Physicist while obtaining dataThe from plant liquid release permits for r'-sons unrelated to this event.

was in Mode 1 - Power Operation at 98% Reactor Power at the time of discovery. The tritium (H-3) concentration was erroneously used in the Discharge d

sumofggg HB-RE-18, alarm / trip setpoint for a Discharge Monitor Tank Monitggy'yaemitterstocalculatetheLiquidRawaste B' release perforned on 10/19/86 at 2304 CDT to 10/20/86 at (DMT) 0521 CDT. The calculated setpoint, 2.81 E-2 uCi/ml, was less l

conservative than the correct Technical Specification (T/S) setpoint of 2.9E-5 pC1/ml and therefore, the requirements of T/S 3.3.3.9, Radioactive Liquid Ef fluent Monitoring Instrumeacation, Action (a) were not net.

In response to this event,, utility personnel began an immediate investigation into the circumstances of Event Eight. They found that the Offsite Dose Calculation Manual (0DCM) and procedures governing sampling and analysis, release calculations, release permit generation l "*d- A andapproval,anddischargelinevalvinghadbeenpropt5)Y' software error i

Health Phvsics (HP) Nuclear Data, Inc. ND6685 computer was suspected due to the fact that the non-gamma emitter designator On 12/15/86, the on-shift for H-3 ha/. not appeared on the permit printout. the HP technicians were instructed to ensure upon permit reviev chat A thorough review of all non-gamma emitter designators were present.

l liquid release permits generated at the Callaway Plant since initial

( criticality (10/2/84) was initiated. As a result of this review, it was discovered that a total of eight of the 1225 permits exhibited the same error. Extensive testing and review of the computer software was l

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immediately initiated to determine the exact cause.

The post-release data in Table I shows that all releases were well within the 11 nits of T/S 3.11.1.1, Liquid Eftluents, and T/S 3.11.1.2, Dese. This evaluation is based on actual grab sample analysis, actual start /stop times, dilution and waste flow rates, and discharge line valving. This data is documented in each release pernit package.

These events are being reported pursuant to 10 CFR 50.73(a)(2)(1) as operation prohibited by the plant's T/S's and are being submitted 30 days from the discovery date (12/15/86) of Event Eight.

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010 0 13 0 16 YIAT t# nears apsee e reeweset was sepeewur MC /was Jose 's/ 0 71 Root Cause The root cause was determined to be the use of the Nuclear Data, Inc.,

ND6685 computer's Weste Editor Program (WEP) to edit the H-3 concentration value. The software used to generate release permits allowed use of the WEP to correct any erroneous data. When used to edit a non-gamma emitter such as H-3, the non-gamma designator was removed and the value for H-3 would be summed with the gamma emitters resulting in a less conservative setpoint calculation. This deficiency was not described in the software operator's manual. The software vendor has been notified of this problem.

Corrective Actions and Actions Taken to Prevent Recurrence

1. On 12/17/86 and 12/31/86 during routine meetings, HP technicians were again instructed to ensure non-gamma emitter designators were present during their release permit reviews.

2. In the interin, HP technical procedure HTP-ZZ-02014, "LRW/GRW Release Permit Generation," was revised on 12/31/86 to require that the non-gamma emitter designators be checked on each liquid release permit and that the waste editor not be used to edit a non-gamma emitter until the WEP is upgraded.

3. The review of all liq'uid release permits generated since 10/2/84 was completed on 1/6/87.

4. The computer software was extensfvely evaluated and tested to determine the cause of the problem. Testing was completed on 12/31/86. The sequence of programs used for release pernit generation was temporarily modified on 12/31/86 such that the WEP cannot be used to edit a non-gamma emitter. The WEP will be revised to permit editing a non-gam =a emitter and seccing the proper designators. The new software vill also produce a report shewing l

l designator status and if a value has been edited. Although the l Nuclear Data, Inc. ND6685 computer software was initially tested to l

verify calculation accuracies, this testing would not have revealed the WEP edit problem.

l S. Additional training will be developed and presented to the l

I appropriate Rad / Chem personnel regarding the review of release permits.

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oIo n14 o16 rixr,,. .w. -,wewasumm Safety Significance Sampling These events posed no threat to the public health and safety.

and analysis, release calculations, permit approvals, and discharge line valving for all eight events were performed in accordance with approved procedures and the ODCM. Additionally, T/S limits were not exceeded during these events.

Previous occurrences: none Footnotes The system and component codes listed below for items 1, 2, and 3 are from IEEE Standards 805-1983 and 803A-1983, respectively.

(1) System - IL, Component - MON (2) System - WD, Component - TY.

( } System - code not available, Component - CPU LRW/GRW - Liquid Radioactive Waste / Gaseous Radioactive Waste 4

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