ML20213F274
| ML20213F274 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/24/1986 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20213F272 | List: |
| References | |
| ANPP-38853-EEVB, NUDOCS 8611140115 | |
| Download: ML20213F274 (7) | |
Text
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lxcg Arizona Nuclear Power Project
~ ' 27 p P O BOX 52034 e PHOENIX, ARIZONA 85072-2034 8-ANPP38853-EEVB/TD$(9p03 October 24, 1986 k/ q.
Mr. John B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA.
94596-5368
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528 (License NPF-41)
STN 50-529 (License NPF-51)
Notice of Violation:
50/528/86-28-01 File: 86-001-493
Reference:
Letter from R. A. Scarano (NRC) to E. E. Van Brunt, Jr. (ANPP),
dated September 26, 1986, NRC Inspection Reports 50-528/86-28 and 50-529/86-27
Dear Mr. Martin:
This letter is provided in response to the inspection conducted by Messrs.
H. S. North and G. A. Brown of the NRC staff on September 2 through September 5, 1986.
Based on the results of the inspection, one (1) violation of NRC requirements was identified. The violation is discussed in Appendix A of the referenced letter. The violation and ANPP's response is provided in Attachment A.
Very truly 6Tiry CLUL_.
g E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/TDS/kj Attachment ec:
0.M. DeMichele (w/ attachment)
J.G. Haynes (w/ attachment)
L.F. Miller (w/ attachment)
R.P. Zimmerman (w/ attachment)
E.A. Licitra (w/ attachment)
A.C. Gehr (w/o attachment) 8611140115 861105 PDR ADOCK 05000528 G
, g, 7
.s Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 Page 2 of 2 bec:
R.M. Butler J.R. Bynum W.E. Ide O.J. Zeringue T.D. Shriver W.F. Quinn P.J. Coffin J.
Vorees R.K. Nelson D.N. Stover L.
Brown G.
Perkins K.G. Voboril D.
Phillips LCTS Coordinator l
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Mr. John B. Martin Palo, Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 Page 1 of 5 ATTACHMENT A NOTICE OF VIOLATION 4
Arizona Nuclear Power Project Docket No. 50-528 P.O. Box 52034 License No. NPF-41 Phoenix, Arizona 85072-2034 As a result of the inspection conducted September 2-5, 1986, and in accordance with the NRC Enforcement Policy, 10 CFR 2, Appendix 0, the following violation was identified:
Technical Specification 3 4 5.1 requires, in part, that the contain-ment atmosphere particulate radioactivity monitoring system, one of three reactor coolant leakage detection systems, be operable l
in Modes 1, 2, 3, and 4 The Action Specification provides that with only two of the required leakage detection systems operable, l
operation may continue for up to 30 days provided grab samples are l
taken, however the reactor must be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after the 30 i
days elapse.
Contrary to the above requirement, from May 20, 1985, to June 27, 1986 the containment atmosphere particulate monitor (RU-1) was in-operable in that the monitor would not respond to radioactivity with the range and accuracy set forth in section 3 3 3 1 of the Technical Specifications and the action to shut down the reactor was not taken. The reactor was operated in modes 1 through 4 for j
periods in excess of 30 days during the period May 20, 1985 through June 27, 1986.
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This is a Severity Level IV Violation (Supplement 1).
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Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 Page 2 of 5 I.
THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED During the course of an ongoing evaluation conducted by ANPP to upgrade the Radiation Monitoring System (RMS), it was noted that data provided by the Unit 1 radiation monitor was inconsistent with values obtained through grab sample analysis.
However, as in each case since the first potential deficiency of this type was dispositioned in June 1985, an evaluation conducted in accordance with the manufacturer's guidance and the' successful completion of the surveillance tests demonstrated that the monitor was operable and functioning as designed. Further evaluations conducted independently by ANPP engineering, identified that the testing techniques developed in conjunction with the manufac-turer were insufficient to verify operability and that the monitor had I
been incorrectly programmed. Based upon the results of the evaluations the RU-1 monitors' particulate channels in both Units 1 and 2 were declared inoperable on June 25, 1986.
In accordance with PVNGS Technical Specifications the applicable action statements for the limiting con-ditions for operations were entered. Subsequent evaluations by ANPP Engineering and the vendor personnel determined the correct conversion factors which were entered into the monitors. To ensure the operability of the monitors the values obtained from the particulate channels were i
compared with grab samples which were taken and analyzed by ANPP person-nel. Based upon the consistent correlation obtained between the grab sample analysis and the particulate channel readings the RU-1 monitors were declared operable on June 27, 1986.
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,s Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 1
Page 3 of 5 II. THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS As a result of the potential deficiency identified with the particulate channels an evaluation to determine the root cause was conducted. The evaluation identified two distinct root causes and one overall contrib-utory cause. In one case the vendor supplied documentation which contained various information including the values to be used in the conversion factor. The conversion factor is used in the monitor's software program to convert the data provided by the internal program of the monitor to engineering units. The format of the information provided was misleading and led to a misinterpretation of the data.
The misinterpretation resulted in the use of incorrect values. In the other case, the vendor modified the erasable programmable read only memory (EPROM) without notifying ANPP that this would require mcdifica-tions to the values used in the conversion factors. In both cases the improper application of the values used in the conversion factors resulted in incorrect readings in the particulate channels.
An evaluation was also conducted to determine the adequacy of the surveillance test procedures which were utilized to verify the operability of the monitor. Based upon the complexity and sophistication of the radiation monitors in use at PVNGS the operability testing and calibration techniques were developed in conjunction with the
,s Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 Page 4 of 5 manufacturer. However, the testing and calibrations conducted did not and would not have identified this particular type of deficiency. As discussed in Section I, the operability verification methods employed are considered a contributory cause and the primary cause of the delay in identifying the deficiency and implementing the necessary corrective actions. In each instance where potential data correlation differences between the results obtained from the monitors and periodic grab samples were identified, the subsequent engineering evaluations and operability testing conducted in accordance with the manufacturer's recommendations demonstrated that the monitors were functioning as designed. Therefore, as discussed above, a deficiency in the surveillance test procedure resulted in the monitor being incorrectly declared operable.
As a result of the evaluations conducted, the following corrective actions will be implemented:
a) Surveillance tests used to verify the operability of radiation monitors will be evaluated to ensure that all required parameters are verified.
b) A program will be developed to independently verify the validity of RMS software changes supplied by vendors or developed by ANPP prior to implementation.
c) Current programs and procedures which govern configuration control have been evaluated.
Specific changes will be implemented to address " configuration control" of the Radiation Monitoring System (RMS) software.
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Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-38853-EEVB/TDS-96.03 Page 5 of 5 i
In order to ensure that this type of deficiency does not have generic implications, the remaining monitors, required to be operational in j
accordance with PVNGS Technical Specifications, were evaluated. Values obtained from the monitors were compared with the analytical results obtained from grab samples. Although in some cases the activity levels identified through the grab samples were below the minimum required Technical Specification range of the monitors, sufficient data was obtained to verify a relatively close correlation between the values from both the grab sample analysis and the monitor readout. Based upon these results, the remaining radiation monitors required by PVNGS Technical Specifications are considered operable. However, as a prudent action, a program is being developed to validate and verify all RMS software currently in use.
1 III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED a
f Full compliance was achieved on June 27, 1986, when the correct conversion factors were entered in the RU-1 monitors in Units 1 and l
2 and the monitors were declared operable.
Items (a), (b), and (c) l described in Section II are expected to be completed by January, 1987.
i The generic program to validate and verify all RMS software is considered i
a long range objective and is currently scheduled for completion during the fourth quarter of 1987.
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