ML17347B459

LER 89-017-00:on 890125,Tech Spec 3.11.2 Requirement to Maintain Complete Inventory of Licensed Radioactive Matls at All Times Not Met.Caused by Inadequate Procedures. Procedures Revised & New Procedures issued.W/891211 Ltr

ML17347B459
Person / Time
Site:	Turkey Point
Issue date:	12/11/1989
From:	Harris K, Dawn Powell FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-448, LER-89-017, LER-89-17, NUDOCS 8912180016
Download: ML17347B459 (6)

Text

ACCELERATED DISTRIBUTION DEMONSTjRATION SYSTEM

~ ~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8912180016 DOC.DATE: 89/12/11 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME AUTHOR AFFILIATION POWELL,D.R.

HARRIS,K.N.

'lorida Florida Power & Light Co.

Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 89-017-00:on 890125,failure to maintain current inventory of radioactive matl due to inadequate procedures.

W/8 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 EDISON,G 1 1 INTERNAL: ACRS MICHELSON .1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB9H3 1 1 NRR/DET/ESGB 8D 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPE B 1 0 1 1 NRR/DOEA/OEABll 1 1 NRR/DREP/PRPBll 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR/DST/SPLB8D1 1 1 NRR DS~/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 RE E 02 1 1 RES/DSIR/EIB 1 1 G FILE 01 1 1 EXTERNAL EG&G WI LLIAMSi S 4 4 L ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC MAYS,G 1, 1 NSIC MURPHY,G.A 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASIEt CONTACT THE DOCUMENI'ONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENIS YOU DON'T NEEDl FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 38 ENCL 38

P.O. 14000, Juno Beach, FL 33408-0420 Uhli l I lvUv L-89-448 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit 3 Docket No. 50-250 Reportable Event: 89-17 Date of Event: January 25, 1989 Failure to Maintain a Current Inventory of Radioactive Material Due to Inade uate Procedures 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,

. I.'~Vr'"..

K. N, Aarris Vice President Turkey Point Plant Nuclear KNH/MA/rat cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector; USNRC; Turkey Point Plant 8912180016 8;ri211 PDR ADOCj" 0"000250 PDC an FPL Group company

~ gRC Feim 366 (983I 0 V.S. NUCLEAR REGULATORY COMMISSION APPROVEO OMB NO 3150410k LICENSEE EVENT REPORT (LER) EXPIRES 8/31/BS FACILITY NAME (11 DOCKET NUMBER (21 PAGE (31 Turkey Point Unit 3 o s o o o 25p ToF04 Failure to Maintain A Current Inventory of Radioactive Material'ue EVENT DATE (51 In de t Procedur LER NUMBER (61 REPORT DATE (71 OTHER FACILITIES INVOLVED (51 MONTH DAY vEAR 5 6 O U 6 rc T i A L llCVISlOrv MONTH QAY vEAR FAC/LtTY NAMES DOCKET NUMBER/SI YEAR ~ it/Mdd R NUMBER Turkey Point Unit 4 osooo 251 1 258 9 8 9 0 1 0 1 2 8 9 THIS AEPORT IS SUBMITTED PURSUAN'7 T 0 THE REQUIREMENTS OF 10 CFR (I- /Chere one or moie or tne looowinpl (11 0 5 0 0 0 OP E RATING MODE (1) 20.C02(dl 20.c05(cl 50.73(el(2)(iv) 7(L71(d I POWER 20.605( ~ l(1)(i) 50.38 Ic) (11 50.73(c) (21(vl 73.71(cl LEVEL p p p 20.C05(c) lllldl S0,38 (c)(2) 50.7 3( ~ I (21(v 8) OTHER /Sotciry in Rot/rect oeiow eno in peer HRC Form 20.405(t) I( I(nil 50,73( ~ l(21(i) 50.73( ~ 112) lviiiHAl 366AI 20.C05 ( ~ 111) I I el d0.73( ~ )(21(iil 50.73( ~ ) (21(viiil (SI 20.C05( ~ I(1)(v) 50.73(t) I 21(iii1 50,73( ~ I(21(cl LICENSEE CONTACT FOR THIS LER (121 NAME TELEP>ONE rgVMBER AREA CODE David R. Powell, Re ulation and Com liance Su ervisor 305 46- 6559 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE OESCAIBEO IN THIS REPOIIT i(31 MANUFAC. REPORTABLE MANUFAC EPORTABLE CAUSE 5'/STEM COMPONENT TO hPROS CAUSE SYSTEM COMPONENT TVRER TURER TQ NPAQS SUPPLEMENTAL REPORT EXPECTED (ICI MONT/c DAY YEAR EXPECTED SUSM/SS/ON DATE Ildr YES lll y4 COmfiert Eg(FECFED S(/Egt/$ $ /DH Dg(FE/ NO ABSTRACT /L/mit to le00 goeceg, iteoorotime/Ny lilrttn tinpi~ gotce tyoewntrtn lint/i (181 On January 25, 1989, with Turkey Point Unit 3 in mode 5 (cold shutdown) and Unit 4 in mode 1 (power operation), a Quality Assurance (QA) audit identified where the inventory of radioactive materials required by Technical Specification (TS) 3.11.2, "Miscellaneous Radioactive Materials Sources," was not met. TS 3.11.2 requires a complete inventory of licensed radioactive materials in possession tomaintenance be maintained current at all times. The inadequate inventory was caused by inadequate procedures. To correct these deficiencies, been applicable procedures have been revised and new proceduresas have required issued. This LER was not submitted by February 24, 1989 the Regulations by 10 CFR 50e73 due to non receipt of the QA audit by and Compliance Group.

NRC Form 366 i9 83i

SS'ICENSEE NAC Seen SSAA 19 EVENT REPORT ILER) TEXT CONTINUATION U 9 NUCLEAA 4ECULATOAV COMMISS1ON A>>4OVEO OU9 4O SI SOLI Ci Es ~ 14ES 4 91 SS SACILITY NAME lll OOCKE9 NUMCE4 IXI LE 4 NUMIE4 191 ~ ACE ISI

$ 9Qvl49'AL alVqiC4 4uv 94 4UMSIS Turke Point Unit 3 o 5 o o o 2 5 0 89 0 17 00 02 OF 0 4 SEXS III SNVS ISSSS il teqWttd. vSS SSSil~ NIIC SOrm SSSA II Il)1 I DESCRIPTION OF EVENT On January 25, 1989, with Turkey Point. Unit 3 in mode 5 (cold shutdown) and Unit 4 operating at 100 percent power, a Quality Assurance (QA) audit identified an area of concern where Health Physics (HP) failed to meet Technical Specifications (TS) 3.11.2, "Miscellaneous Radioactive 'Materials Sources," requirements. TS 3.11.2 requires a complete inventory of licensed radioactive materials in possession to be maintained current at all times.

A. Inventory During the QA audit, it was discovered that a complete and up to date inventory of radioactive mater ials at the site was not maintained. This was contrary to the requirements of TS 3.11.2. Sources mentioned in the audit consisted of liquid and gaseous materials used for sample analysis or instrument calibration, instrumentation containing sealed sources (i.e. radiochemistry's liquid scintillation counters) and sources containing less than one gram of special radioactive material.

B. Late Report This report was not submitted within 30 days of discovery date. (January 25, 1989) as required by 10 CFR50.73(a).'I CAUSE OF EVENT A. Inventory Violation of TS "3.11.2 was attributed to deficiences in plant procedures O-HPS-092, "Inventory Control and Leak Testing of Radioactive Sources," and AP 190.4, "Procurement Document Control." These deficiencies included inadequate materials purchase, receipt and issue controls as well as inadequate controls of inventory requirements for instrumentation containing sealed sources.

B. Late Report The Regulations and Compliance Group (RCG) was .verbally contacted by QA about the potentially reportable event and was awaiting receipt of the written report. Failure to receive the report resulted in the QA report not being reviewed for reportability in accordance with procedure AP 103.6, "Evaluation And Reporting Of In House Events."

At the time, only written notification was considered "notification."

44C form $ 94A U 9 IIUCLEAA KSGULATOAY COMMISSIOV

>>99$

LICENSEE EVENT REPORT (LERI TEXT CONTINUATION Aoo4OYED OUI 4O $ ISG~IGo ErolIIESSOI SS fACILITYIIAME II I DOCKET IIV' II IS I LEK VUMIEII I ~ I ~ AGE ISI vT JA SLQULVT>>AL ~ Lv'S'OV 94 VU>>l 9 ~

Turkey Point Unit 3 0 5 0 0 0 P 5 0 8 9 0 1 7 0 0 0 OF 0 4 TEXT lll moro IAOTO rl rOO>>r>>>>O>>T. ufo oOO>>NWal IYJIC form $65A'll I ITI III hNhLYSIS OF EVENT A. Inventory Turkey Point's failure to maintain a current inventory of licensed radioactive material on site in no way degraded the safe operation of the units. In addition, there are several radiation monitors located in key areas within the Protected Area (PA) which would detect any attempts made to remove radioactive materials fi om the PA. Some radioactive materials are maintained outside the PA. In the adJacent store's warehouse.

Radioactive material kept there possess low activity. Admininistative controls are in place at the warehouse to assure no unauthorized removal of sources occur. In the near

.future, as part of Turkey Point's Security Upgrade Program, the warehouse will be included within the PA; IV CORRECTIVE ACTION A. Inventory This LER, 250-89-017-0, reports a finding of the January, 1989, QA audit of HP records for 1988. ,This finding showed that a complete and current inventory of radioactive sealed sources was not maintained . Corrective actions taken to prevent reccurence of this event include the creation of procedures'O-ADM-022, "Procurring of Radioactive Sources," and O-ADM-023, "Inventory Control and Accounting of Radioactive Sources," and the revision of AP 190.4, "Procurement Document Control," to provide stricter material purchase, receipt and issue controls. These procedures also included additions to the 'inventory requirements to encompass applicable instrumentation containing sealed sources. In addition, nuclear chemistry procedure O-NCSP-200.1, "Control of Chemistry Radioactive Sources," was developed to control how that group handles its inventory of radio-active sources. This procedure was implemented on August 10, 1989.

LER 250-89-012-0 reported a similar occur rence discovered on July 7, 1989, as a result of the June, 1989, semi-annual inventory of radioactive sources. In this event, the plant failed to leak test a source because it was not part of the radioactive materials inventory. This was due to failure to add a newly received source to the inventory in 1987.

Corrective actions taken as a result of the QA audit in January, 1989, were not completed until after the event reported in LER 250-89-012-0 took place.

Therefore, corrective actions taken as a result of the QA audit in January, 1989, could not have precluded LER 250-89-012-0 from occurring.

AAC 5er~ 444A V 5 HVCLEAA AECVLATQAY COMMISSION

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION AliAOVEO OM4 IO )I50%I04 EarIAES 4 SI 45 FACILITY NAME ITI COCKET HVM4EA IEI LEA IIVM4EA IEI 9ACE ISI EA1 5EQVlieT>AL +Tv 5~0%

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Turke Point Unit 0 5 0 0 0 OF TEXT III ~ carry S ~~. vM Ser~l~ @AC f~

3 444A'I I IITI B. Late Report This event has been discussed with the applicable RCG engineers. Evaluations are now being per formed upon receipt of verbal notification. Direct distribution of final QA audit reports to RCG'ill ensure that followup written notifications are being performed in accordance with AP 103.6.

V ADDITIONAL INFORMATION Similar occur ences: LER 250 89-012-0