ML17348A567

LER 90-017-00:on 900817,fire Protection Surveillance Missed Due to Personnel Error.Missed Surveillance Discovered During QA Insp.Procedure O-SME-016.4 Revised to Include App a Fire dampers.W/900917 Ltr

ML17348A567
Person / Time
Site:	Turkey Point
Issue date:	09/17/1990
From:	Harris K, Dawn Powell FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-339, LER-90-017, LER-90-17, NUDOCS 9009250236
Download: ML17348A567 (9)

Text

ACCBLLKAl'BU DIAL'KLBU'I'jUN DEMONSTRA1 los SYS"1'hM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9009250236 DOC.DATE: 90/09/17 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME AUTHOR AFFILIATION POWELL,D.R. Florida Power & Light Co.

HARRIS,K.N. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER due 90-017-00:on 900817,missed to personnel error.

fire protection surveillance W/9 ltr. , D DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

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

NOTES RECIPXENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-2 LA 1 1 PD2-2 PD 1 1 EDISON,G 1 1 D INTERNAL: ACNW 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB11 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR/DST/SRLBSD1 1 1 NRR/DST/SRXB 8E 1 1 REG~LE Oga, 1 1 RES/DSIR/EIB 1 1 RGN2 FXLE 01 1 1 EXTERNAL: EG&G BRYCE,J.H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A '1 1 NUDOCS FULL TXT 1 1 D

D NOTE TO ALL "RIDS" RECIPIENTS:

S PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31 Fj

P.. Box 029100, Miami, FL, 33102-9100 I=PL Sept. 17, 1990 L-90-339 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document'ontrol Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit 3 and Unit 4 Dockets No. 50-250 and 50-251 Reportable Event: 90-017-00 Date of Event: March 10, 1990 Missed Fire Protection Surveillance Due To Personnel Error 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, K. . Harris Plan ice President T urkey Point Plant Nuclear KNH/DPS/ds attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspectorr USNRCg Turkey Point Plant n0 " 900917 9009 -ADCICK 0 5000250 PDR PDC an FPL Group company z L'~

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t UCENSEE EVENT REPORT (LER)

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~CTC Otlt LINC KIN CACN ~CNT >>AILUAC DCNXICCO IN Tlllt AtfOAT (ill COM>>OHCHT 4AHU>>AC tfOIITACLC: CAUSl 5Y5TlM COM>>OHCHT MANU AC f CfOIITACL CAUSC 5YSTCM TUII5 H TO tj>>10$ TUN CN TO H>>405 Wffi.CMCNTAL1CKIIIT CXPCCTlo lie( MOHTee DAY I YCAte

~ XflCTCO 5U 5 M I $ 5 I 0 H DATC Iltl 1 11 39IO Ytl (Ir Yeo >>4MtoM cxfccTco svcet(55(ott OATN HO AMTIIAOT(Le>>ett to f oN Me>>N, AA. ee>>eoeeeeeeatY ettteeee>>eefe~ tv>>>>eeet neet Aeeeet (ill On March 10, 1990, with Units 3 & 4 in Mode 1 (Power Operation) at 100 percent power, the 18 month periodicity of Technical Specification (TS) 4.15.5.a.l, including the 25 percent extension permitted by TS 4.0.1, was exceeded for the inspection of 14 dampers covered by 10 CFR 50, Appendix A and Appendix R. technically Therefore the dampers and their associated fire barriers were inoperable from March 10, 1990, until the Inspection." dampers were inspected The missed using procedure O-SME-016.4, "Fire Damper surveillance of 10 of the dampers was discovered during a Quality Assurance (QA) inspection on August 17, 1990. The other four dampers were discovered on September 12, 1990, during a HVAC review to have also missed the March 10 due date. TS 3.14.5.b.2 requires that a special report be submitted status within if non-functional fire barriers 7 days. This event was are not restored to operable cognitive personnel caused by inadequate procedural guidance and to include the 14 error. Procedure O-SME-016.4first has been revised Appendix A dampers. The 10 dampers were inspected and determined to be functional on August 20, 1990. The other four dampers were inspected and determined to be functional on September 14, 1990. The results of the investigation concerning the four dampers, which were not in the fire damper inspection procedure, will be reported in a supplemental LER.

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I DESCRIPTION OF EVENT h

Oa March 10, 1990, with Units 3 & 4 in mode 1 (power operation) at 100 percent power, the 18 month periodicity of Technical Specification (TS) 4.15.5.a.1, including the 25 percent extension permitted by TS 4.0.1, was exceeded for the inspection of 14 dampers {VI/VF) {BDMP) covered by 10 CFR 50, Appendix A and Appendix R. Therefore the dampers and their associated fire barriers were technically inopexable from March 10, 1990, until the 14 dampers were inspected in accordance with TS 4.15.5.a.l. The missed surveillance on 10 of the dampers was discovered during a Quality Assurance (QA) inspection on August 17, 1990. Four dampers (two sets of two dampers each) were discovered during a review of HVAC drawings on September 12, 1990.

TS 3.14.5.a requires all fire dampers to be functional. 'TS 3.14.5.b.2 requires a Special Report penetrations are not restored to functional status within if the fire barrier seven days.

II CAUSE OF EVENT Inadequate Procedure Procedure O-SME-016.4, "Fire Damper Inspection," did not cover all 10 CFR 50, Appendix R dampers.

The 14 Appendix A dampers involved in this event were installed and were being inspected in accordance with 10 CFR 50, Appendix Al before 10 CFR 50, Appendix R~ was written. When Appendix R was issued, new fire dampers were installed to meet the new requirements. The 14 Appendix A dampers involved in this event met the Appendix R requirements, therefore were not'art of the work package installing the new Appendix R dampers. A new procedure was written to provide the required inspections to the Appendix R dampers. This procedure, O-SME-016.4, was written using the design change package that had installed the new Appendix R dampers.

Therefore, the previously installed dampers were not included even though they were covered by the new Appendix R requirements.

2. Cognitive Personnel Error (non-licensed contract personnel)

On September 22, 1989, an independent contractor performing an Appendix R audit for FPL notified FPL that 10 Appendix A dampers were not 'covered by any plant procedures. Procedure O-SME-016.4 was revised to include the 10 Appendix A dampers in December, 1989. Due to a cognitive personnel error by non-licensed contract 4RC fORM Sttk h$ 4$ l

tI, I-vAC i945I ior~ ~. U S. VUCI.SAA ~ SCUEJTOAy CQO<4%IOI LICENSEE EVEN PORT ILER) TEXT CONTINUATIO Af+'+OySOalHVO 515DMI04 SS ~ XII%5 SISI SACII,ITY IIASAS Ill IIU~SIS l1I I Cll VUSACgII ISI M'OCIIST SSQvSHT)AI vSyg~V VVII ~A vvM sv Turkey Point Unit o 5 o o o(2 5 0 0 7 000 3 OF 0 4 rgCT IIT IvoIS sgwe e ~. ~ ssssSvyI 3

VISC 4one ~ 5I I1 tl personnel, the surveillance was not immediately scheduled and accomplished. The surveillance for the 10 Appendix A dampers identified by the audit was accomplished August 20, 1990, after a Quality Assurance (QA) audit identified that the surveillance had been missed.

3. Cognitive Personnel Error (non-licensed contract technician)

Procedure covering inspection of the 10 Appendix A dampers was canceled without adequately verifying that the dampers were covered by other procedures On April 4I 1989I procedure O-SME-016.3 "Fire Barrier Penetration Seal Inspection," was issued replacing procedure MP-15537.3, "Surveillance of Penetration Fire Barrier." The 10 fire barriers were covered by MP-15537.3. However, since Appendix R dampers were now covered by procedure O-SME-16.4 and O-SME-16.3 was to cover penetration seals only, when procedure MP-15537.3 was canceled, on April 4, 1989, the 10 fire dampers were no longer covered by any procedure.

4. The two sets of dampers discovered on September 12, 1990, were on a supplemental list when they were inspected in April, 1988. The results of an investigation to determine why they were not included in procedure MP-15537.3 will be included in a supplement to this LER.

III ANALYSIS OF EVENT Between April 15 and April 19, 1988, all appendix R dampers installed were satisfactorily inspected in accordance with the requirements of TS 4.15.5.a.l.

During the time period the fire dampers were technically inoperable, an hourly fire watch patrol previously established from an earlier FPL commitment, was in effect. The surveillance performed on August 20, 1990, found no problems with the 10 fire dampers. The four dampers discovered on September 12, 1990, were satisfactorily inspected on September 14, 1990. These successful inspections provide a reasonable

~ degree of confidence that the 14 dampers were capable of performing their intended function during the time period the.

dampers were technically inoperable. Thus, the health and safety of the public were not affected by this event.

v1C SCAM SSSA

rl'C lena itrl I

~ LICENSEE EVEN PORT (LER) TEXT CONTINUATlO V 5 VUCLCAA 154VLATOII> CCW&IQI AAerOvfO OUO vO )I54WIOA fX A W 5 5 5/5 I,%$

fAcILITYHAAIf III OOOO 5 7 IIUSW 5 II I1I LlII rvMOfll < ~I ~ AOl 15I flOUlVTsAL af vrlOv VUU VVU ~A Turkey Point Unit s o o o 2 50 90 7 o oo 4 OF a T55IT or acre ayece r ~. ~ 3 erroenr vrc AcaaII IITI o 1 0 IV CORRECTIVE ACTIONS The contract technician responsible for reviewing MP 15537.3 was admonished for not correctly verifying that all dampers included in that procedure were covered in other procedures or determined to not be required.

2. On December 19, 1989, procedure O-SME-016.4 was revised to include the 10 Appendix A fire dampers.

3.. On August 20, 1990, the first 10 fire dampers were inspected and found to be functional.

4 ~ Fire Protection has designated a technician to ensure that Fire Protection TS required surveillances are completed as required. I

5. In September, 1989, an independent contractor performed an audit of the Appendix R fire protection requirements.

At that time, the 10 Appendix A dampers were the only dampers determined" to have been left out of the 0-SME-016.4. Fire Protection is performing a review of HVAC drawings to determine have been left out of this procedure.

if any other Appendix R dampers This review is expected to be completed by October 31, 1990.

additional Appendix R dampers are. discovered to have If any missed the March 10, 1990, due date, they will be reported in a supplemental LER.

In addition, Fire Protection will do a complete review of the material covered by the September, 1989, audit to ensure there are no other omissions. This review is scheduled to be complete by December 31, 1990.

'7. The four additional dampers were added to procedure 0-SME-016.4 by use of an on-the-spot-change (OTSC) on September 13, 1990. These four dampers successfully passed the surveillance on September 14, 1990.

8. A supplemental LER will be submitted to report the results of the investigation as to why the four dampers were never incorporated into a procedure.

V ADDITIONAL INFORMATION Similar Events LER 250-88-012 described four fire barrier penetration seals identified as deficient. that were not inspected .

within one hour as specified in the TS.

2. Failed Components None VAC aOAU 5frA i945 I

~ 1