ML17342A966

LER 87-025-00:on 870914,QA Dept Noted That Surveillance Requirements of Tech Spec 4.1-2 Item 18 Had Not Been Met. Caused by Inadequate Procedure.Procedures 3/4-OSP-201.1 Will Be Revised & Surveillances performed.W/871013 Ltr

ML17342A966
Person / Time
Site:	Turkey Point
Issue date:	10/13/1987
From:	Salamon G, Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-87-408, LER-87-025, LER-87-25, NUDOCS 8710160230
Download: ML17342A966 (5)

Text

~ i REGULATORY l. ORMATlQN DISTRIBUTION SYS 1 <RIDS)

I ACCESSION NHR: 8710160230 DOC. D*TE: 87/10/13 NOTARIZED: NO DOCKET FACIL: 50-250 Tur keg Point Planti Uni 3I Flor t ida Power and Light C 05000250

• UTH. NAME AUTHOR *FFILIATION SALAMONI G. Florida Power 5 Light Co.

WOODY) C. O. Florida Power 4 Light Co.

RECIP. NAME RECIPIENT AFFILIATION

SUBJECT:

LER 87-025-00: on 870914I GA dept noted that surveillance requirements o8 Tech Spec 4. 1-2 Item 18 had not been met.

Caused bg inadequate procedure. Procedures. 3/4-osp-201. 1 will be revised Zv. survei1 lances performed. W/871013 ltr.

DISTRIBUTION CODE: IE22D COPIES RECEIVED: LTR I ENCL TITLE: 50. 73 Licensee Event Report (LER) I Incident Rpt.

g etc.SIZE:

NOTES:

REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2'D 1 1 McDONALDI D 1 1 INTERNAL: ACRS MICHELSON 1 ACRS MOELLER AEOD/DOA 1 AEOD/DSP/NAS AEOD/DSP/ROAB 2 2 AEOD/DSP/TPAH 1 ARM'/DCTS/DAB 1, 1 DEDRO 1 1 NRR/DEST/ADS 1 0 NRR/DEST/CEB 1 NRR/DEST/ELH 1 1- NRR /DEST/ I CSB 1 1 NRR/DEST/MEH 1 NRR/DEST/MTH 1 1 NRR/DEST/PSH 1 1 NRR/DEST/RSH 1 1 NRR/DEST/SGH 1 NRR/DLPG/HFH 1 1 NRR/DLPG/GAH 1 NRR/DOEA/E*B 1 1 NRR/DREP/RAB 1 1 NRR/DREP/RPB 2 NRR/D S/SIH 1 NRR/PMAS/ ILRB 1. 1 02 1 1 RES DEPY GI 1, 1 S TELFORDI J 1 RES/DE/EIB 1 1 RGN2 FILE 01 EXTERNAL: EGhG GROHI M 5 5 H ST LOBBY WARD 1 LPDR 1 =

1 NRC PDR 1 NSIC HARRIS) J 1 1 NSIC MAYS) G 1 TOTAL NUMBER OF'OPIES REQUIRED: LTTR 45 ENCL 44

4RC Form 355 U.S. NUCLEAR REOULATORY COMMISSION (9.83) AppRovED DMB NO. 31604104 EXPIRES; 5/31/Sb LICENSEE EVENT REPORT (LERI DOCKET NUMBER (2) PA FACILITY NAME (II Turke Point Unit 3 0 5 0 0 0250 ioFO 3 Undocumented Surveillance of Coolant Loop 0 erabi EVENT DATE ISI lit Due to Inade uate Procedure LER NUMBER IS) REPORT OATS (7) OTHER FACILITIES INVOLVED (5)

MONTH OAY YEAR YEAR eeavervr/AL nevrexx loON'TH OAY YEAR FACILITYNAMES DOCKET NVMBERISI NUMBER ".rr: NUMBSIV 0 5 0 0 0 0 9 487 7 2 5 00 10 8 7 0 5 0 0 0 THIS REPORT IS SVBMITTEO PURSUANT TO THE REOUIREMENTS OF 10 CFR (I: /Coecx one or more o/ tne /orlowlnp/ (11)

OPERATINO

'ODE (5) 20.402 (5) 20.405(c) 50.7$ (e I (2 II iv) 73.710I) 20.405( ~ I(1) (ll 50M(cl(I) 50,734)(2)(vl (vill)(AI 73.71(cl POWER LEYEL p 3 p 20.405(e)(1) (ri) 50.$ 5(el l2) 50.73(el(2l(vb) OTHER /Speci/y in Apttrect peIOW enr/ In Text, IY/IC FOrm 20.405( ~ I (1)(illI X 50,7$ (el(2)(ll 50.7$ (el(2) 3644/

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MANVFAC COMPONENT MANUFAC EPORTABLE CAUSE SYSTEM COMPONENT TVRER CAUSE SYSTEM TVRER TO rroROS i

et'.;yoE I ',"'ONTH SUPPLEMENTAL REPORT EXPECTED 114) OAY vEA/l EXPECTED SUBMISSION v DATE (15)

YES /II yer, COmplere EXPECTED St/bet/SSION DATE/ /ra ABsTRAcT /Limit ro tc(x) /peter, / ~ ., epproximere/y /i/teen tlnfie./pete typewnrten liner/ 115)

On September 14, 1987, the Quality Assurance department noted that the surveillance requirements of Technical Specification (TS) 4.1-2 item 18 had not been met. This TS requires that with average coolant temper-ature less than 350 degrees F, a second coolant 1oop is to be verified operable once every 7 days. TS 3.4.l.e requires that "with average coolant temperature less than 350 degrees F, at least 2 coolant loops shall be operable or immediate corrective action must be taken to return two coolant loops to operable as soon as possible." Even though no documented surveillance in accordance with TS 4.1-2 item 18 was being performed, compliance with TS 3.4.l.e assures an ongoing observation of coolant loop operability for two coolant loops. The cause of the undocumented surveillance was an inadequate procedure. Procedures 3/4-0SP-201.1, "RCO Daily Logs", were upgrades of the RCO Log Sheet.

Upon completion of 3/4-0SP-201.1, the old RCO Log Sheets, which addressed this surveillance, were cancelled. The upgraded procedures failed to include this surveillance requirement. Transition Documents (TD) were not generated, as the old RCO Log Sheets were not considered to be pro-cedures. TD s will be generated for all future procedure upgrades.

Existing upgraded procedures which were generated without a TD will have a TD generated .

NRC form $ 5(

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@DOCK 71013 0 5000250

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NRC Form 3SSA U.S. NUCLEAR REGULATORY COMMISSION (943)

EPORT (LER) TEXT CONTINUATION

~

LICENSEE EVEN APPROVED OMB NO. 3150M(04 EXPIRES: B/31/BB FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (Sl PAGE (3)

YEAR SEQUENTIAL ~>"'j REVISION NVMSSR ~VW NVMSSR Turkey Point Unit 3 o s o o o 25 0 87 0 5 0 0 0 20F0 3 TEXT /// more S>>ce /e /eee/mrL eee a4Wona/ NRC Femr 3SIIAS / (17)

EVENT On September 14, 1987, with Unit 3 in mode 1 at 30% power, the Quality Assurance department issued a Corrective Action Request (CAR) noting that the surveillance requirements of Technical Specification (TS) 4.1-2 item 18 had not been met. This TS requires that at shutdown, with average coolant temperature less than 350 degrees F, a second coolant loop is to be verified operable once every 7 days.

The CAR noted that during the most recent Unit 3 startup, it was discovered through observation by the Quality Assurance department that this surveillance was not being documented . Technical Specification 3.4.l.e requires that "with average coolant temperature less than 350 degrees F, at least two coolant loops shall be operable or immediate corrective action must be taken to return two coolant loops to operable as soon as possible." Even though no documented surveillance in accordance with TS 4.1-2 item 18 was being performed, compliance with TS 3.4.1.e requires and assures an ongoing and continuous observation of coolant loop operability for two coolant loops. Procedure 3/4-0SP-201.1 "RCO Daily Logs",was issued on March 27, 1987. Since that time and prior to the issuance of the CAR, both Units 3 and 4 have been in modes which are subject to this surveillance.

CAUSE OF EVENT The cause of the undocumented surveillance was an inadequate procedure.

Procedures 3/4-0SP-201.1, "RCO Daily Logs", were upgrades based on the previous RCO Log Sheet and the need to incorporate certain additional requirements into the logs. Upon completion of 3/4-0SP-201.1, the old RCO Log Sheets became obsolete and were no longer used. The old RCO Log Sheet addressed this surveillance, however it was incorrectly identified as being required by TS 4.1-2 item 20. During the preparation of 3/4-0SP-201.1, the procedure writer could not locate item 20 in the TS, and incorrectly assumed that this surveillance was not required by Technical Specifications.

The usual process of procedure upgrade and review involves the generation of a Transition Document (TD). The TD s purpose is to identify point-by-point specifically how each step in an obsolete procedure is incorporated into the new procedure. In this instance, though the old RCO Log Sheets were formal documents,

.they were not considered to be procedures. As they were not pr'ocedures, no TD was generated, thus making less visible the deletion of the TS 4 '-2 item 18 surveillance. This was not discovered in the'normal review process because neither the TD s nor the cancelled procedures/documents are included in the routed review package.

NRC FORM SSSA (9 B3)

V.S. NUCLEAR REOULATORY COMMISSION NRC Form 3SSA

(%$ 31 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVED OMS NO. 3150-0(04 EXPIRES: 8/31/88 FACILITY NAME (11 DOCKET NUMBER 121 LER NUMBER (51 PACE (3l SEQUENTIAL REVISION YEAR ~P' NUMSSR gg NUMSSR Turkey Point Unit 3 o s o o o 5 0 0 2 5 0 0 0 3 OF 0 3 TExT //F mors <<wss /F /rr/roar L rrss pr/I//rrsrM///Ac Fsrrrr 3/I//AS/ (IT(

ANALYSIS OF EVENT Even though no documented surveillance in accordance with TS 4.1-2 item 18 was being performed during this event, compliance with TS 3.4.1.e requires and assures an ongoing and continuous observation of coolant loop operability for two coolant loops. The plant was in compliance with TS 3.4.1.e during the time of this event.

Based on the above, the health and safety of the public were not affected.-

CORRECTIVE ACTIONS

1) Procedures 3/4-0SP-201.1 will be revised.

2) The surveillances will be performed prior to the revision of 3/4-0SP-201.1, as required.

3) Transition Documents will be generated for all future procedure upgrades.

4) Existing upgraded procedures which were generated without the benefit of a TD, will now have a TD generated in order to assure that no other requirements have been similarly missed.

5) Future procedure upgrade review packages will include both the TD and the cancelled procedure. in the review package.

ADDITIONAL DETAILS Similar occurrences: No previous undocumented surveillances were caused by deletion of the surveillance requirement through an inadequate revision of a procedure. However, the plant has identified missed surveillances previously in LER s 250-86-027, .250-85-028, 250-85-001, and 250-87-019.

NRC FORM SSSA (983 (

P. O. BOX, JUNO BEACH, FL 33408 0420 USh'RC-OS Sloe~ t~ A g03 OCTOBER 1 5 1987 L-87-408 IO CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gent lemen:

Re: Turkey Point Unit 3 Docket No. 50-250 Reportable Event: 87-25 Date of Event: September l4, l987 Undocumented Surveillance of Coolant Loop 0 erabilit Due to Inade uate Procedure The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of the subject event.

Very truly yours, Y).

C. O. Woody Group Vice President Nuclear Energy COW/SDF/gp Attachment cc: Dr. J. Nelson Grace, Regional Administrator, Region il, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF I/064/I an FPL Group company