ML17352B167

LER 94-003-00:on 940720 & 21,util Discovered That Several Required Valve Stroke Time Surveillances Had Not Been Performed.Caused by Personnel Error.Personnel Reassigned & Procedures and Surveillance Tracking Software Enhanced

ML17352B167
Person / Time
Site:	Turkey Point
Issue date:	08/16/1994
From:	Mowrey C FLORIDA POWER & LIGHT CO.
To:
References
LER-94-003-03, LER-94-3-3, NUDOCS 9505190285
Download: ML17352B167 (9)

Text

PRIDRIT'Y Z REGULATOR A&%SIBIZ I!f'III!ATION %STEM (RIDE)

<<CACCESSION NBR:9505190285 DOC.DATE: 94/08/16 NOTARIZED: NO DOCKET N

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FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME- AUTHOR AFFILIATION MOWREY,C.L. Florida Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 94-003-00:on 940720 a 21,util discovered that several required valve stroke time surveillances had not been performed. Caused by personnel error. Personnel reassigned and surveillance tracking software enhanced. I!'rocedures DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR G ENCL ( SIZE: S 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 PD2-1 PD CROTEAU,R 1 INTERNAL: A PD RAB AEOD/SPD/RRAB FILE NTER NRR/DE/ECGB NR NRR/DE/EMEB NRR/DISP/P IPB NRR/DOPS/OECB NRR/DRCH/HHFB NRR/DRCH/HICB NRR/DRCH/HOLB NRR/DSSA/SPLB NRR/DSSA/SPSB/B NRR/DSSA/SRXB RES/DSIR/EIB RGN2 FILE 01 EXTERNAL: L ST LOBBY WARD LITCO BRYCEPJ H 2 2 NOAC MURPHYPG.A NOAC POORE,W. 1 1 NRC PDR NUDOCS FULL TXT 1 VOTE TO ALL"Rl DS" RECIPIENTS:

PLEASE HELP US TO REDUCE O'ASTE! COYTAC:TTIIE DOCL'RIED'I CONTROL DESK, ROOil PI.37 (EXT, 504- OS3 ) TO ELIXIIi<<'ATEYOUR <<'AME FROil DIS'I'Rl IIL"I'ION LISTS I'OR DOCL'NIEYTS YOL'Oi "I'EED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR ENCL 26

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FEB-23-'9S THU 12:49 ID "LIC TEL NQ- ZGS-24 651 AGS9 PG3 XXCENSKR RVRNT REX'ORT (XdPR) TEXT CO~XHUATZOM FACILITY PANE DOCKET NUMBER LER HUNGER PAGE RO, TURKEY POINT UNIT 3 05000250 94-003-00 02 OF 05 On July 20, 1994, with both units at about 100% powez, Florida Power & Light Company (FPL) personnel discovered that a quax'texly inservice valve exercise (stroke timing) had been missed three times since January 1993. On July 21, 1994, further investigation revealed that a total of nine quarterly suxveil-lances required by Turkey Point's Inservice Testing program (IST) had not been performed. The missed surveillances involved a total of twenty valves, covered a period of about 16 months from January, 1993 to April 1'994, The details of the missed suzveillances are as follows:

PROCEDURE / SECTION AFFECTED VALVES MISSED QUARTER (S) 4-OSP-022.4 / 7-3 SV-4-3434 A & B 1/93, 3/93, 1/94 3-OSP-047.1 7.5

/ 7. 4 & CV-3-200 A, Bp CV-.3-310 A & B C 2/93, 1/94 4-OSP-047.1 7.5

/ 7.4 & CV-4-200 A, B, C CV-4-310 B & C 1/94 3-OSP-050.2 / 7.5 MOV-3 860 A MOV-3-86a A B

B 2/93, 3/93 4-0SP-050.2 / 7.5 MOV-4-860 A MOV-4-861 A

& B

& B 2/94 Valves SV 4-3434A & B open to provide flow to the Emexgency Diesel Generator Fuel Oil Day Tank fDC:tk) from the Diesel Oil Transfex Pump {DC:p} on low Day Tank level, Valves CV-*-200A, B, & C isolate the Chemical & Volume Contxol System letdown line between containment and the letdown orifices (CB:or].

Valves CV-*-310A & B open to provide flow from the Chemical & Volume Contxol System charging pumps {CB:p) to the Reacto~ Coolant System {AB).

Valves MQV-"-860 A & B and Mov-"-861 A & B open to allow flow fram the containment recirculation sump to the suction of the Residual Heat Removal pumps [BP:p].

The surveillances aze required to satisfy Technical Specification 4.0.5, which requires Turkey Point to test pumps and valves in accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.Section XI requires ASME Code Class 1, 2, and 3 pumps and valves to be tested at least quarterly unless specific relief is granted pursuant to 10 CFR 50. 55a (g) (6) (i) .

These missed stroke time suxveil lances are being reported as a condition prohibited by Technical Specification 4.0.5, in accordance with 10 CFR 80.73(a) (2) (i) (B) .

F EB-23-'95 THU 12:51 ID TN-LLC TEL NO-585-246-6651 tf gE E~g~ ~pORg (~/) gzxm CGHTZNUATXCH FhCZf ITY HAHB QOCRET NUMBER LER NUMBER PAGE HO.

TURKEY POINT UNIT 3 05000250 94 003-00 03 OP 05 Taeadiate Cause The immediate cause of the condition was that the scheduling of stroke time surveillance performances was not adequate to ensure that they were dona.

hdministrative procedure 0-ADM-215 describes the scheduling of plant surveillances by reference to specific surveillance procedures, but some surveillances are listed in 0-ADM-215 by train or component, some axe listed by surveillance procedure section, and some surveillance procedures are listed in their entirety. Therefoxe specific valve stxoke times were not listed separately.

The computer software used to implement 0-ADM-215 contained similar inconsistencies, one of which was that the pump surveillances were scheduled, with the expectation that the valve stroke times ~ould be perfozmed in con)unction. As an example, sections 7.1 and 7.2 of 4-0SP-22.4 direct the surveillance on the 4A and 4B Emergency Diesel Oil Transfer pumpsg respecti~ely, while section 7.3 directs the performance of the IST stroke timing on valves SV-4-3434 A 4 B. The Plant Surveillance Tracking Pxogram contained specific scheduling line entries fox the surveillances on the 4A and 48 pumps, but contained no specific line entry for the valve stroke times. The result of these inconsistencies was that valve suxveillances were occasionally not performed.

Roet Causa The root cause of this event is cogniti~e pexsonnel error in that the IST Coordinator {other utility personnel) did not ensure that the scheduling of the quarterly surveillances was adequate to ensure that they were performed. The IST Coordinator is responsible for ensuring IST pxogram changes aze incorporated into plant pxoceduzesI and fox'nsuring conformance to plant procedures pertaining to IST testing. He is also responsible fox reviewing the completed suzveillances in order to trend the valve stroke times, In the past, IST pump suxveillances were perfoxmed and reviewed by the System Performance Group in the Technical Department; IST valve euzveillances were then performed by Operations, at the direction of Technical Department, in order to complete the procedure. About two years ago, the review and performance of the IST pump suxveillances was separated. Surveillance performance moved from Technical Department to Operations Department, while final surveillance review to ensure all testing is completed remained with Technical Department.

The methods of ensuring the perfonnance of the ZST valve surveillances which sufficed for Technical Department, were not fully implemented for the Operations Department, but the implementation deficiency was not recognized.

As a result, the scheduling of the IST valve suxveillances was not fully implemented into the 0-ADM-215 pxocesses to ensure a clear understanding of what testing was required when the surveillance test responsibility was transferred to Operations.

FEB-23-'95 THU 12:52 ID THYMIC TEL NO: 3GS-246-6651 6 AG59 PG5

~x~gmg g~~g PPPORg (~~) +ging COHTXSQATXOS FACILITY NAKE DOCKET NUHBER LER NtjMBER PACE NO.

TURKEY POINT UNIT 3 05000250 94-003-00 04 OF 05 Hoot surveillances demonstrate that systems or components in fact are a surveillance is missed, it is primarily a question of operability that has not been verified by the pexformance of the required surveillance.

operable.'hen Xt is overly conservative to'ssume that. systems or components are inoperable when a surveillance has not been performed.

Satisfactory surveillances were completed on all twenty valves during the current. quarter, thereby demonstrating the valves'ontinued opexability.

The maintenance records for the valves indicated that, none of them were out of service during the quarter(s) in which the surveillance(s> was (were) missed.

Therefore, despite the .failure to measure the stroke time, the operability of the'alves was not in question duxing the quarters indicated in the table Lbovb>>

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

XVE TXONS The IST Coordinator has been reassigned to another position.

2. The maintenance history for all twenty valves, was reviewed. No operability concerns existed dux'ing the period of the missed aurvbillances.

Since the process for controlling surveillances changed two years ago, the past two years of IST surveillance history was reviewed. No other instances existed of missed TST surveillances on valves. Since scheduling procedures track pump suxveillances specifically no review of pump surveillance history was performed.

4. An independent review of the surveillance scheduling program is being performed by the FPL Quality Assurance Department.

5. The Plant Surveillance Txacking Program (computer sof twaxe used to implement 0-ADM-215) has been revised to include the IST surveillances on the specific valves which were missed. It will be further revised to include line entries for each valve or pump test section, in lieu of identifying the procedure as a whole- This action will be completed by August 31, 1994.

For the specific surveillance procedures directing the performance of IST surveillances on pumps and valves> a signoff step has been added to the affected subsections for the pump testing sections, which requires the valve exercising to be performed quarterly.

F EB-23-'95 THU 12-53 ID TH-LlC TEL NO: 385-246-6651 tt859 PQ6 RXCENSEE EVENT REPORT (LER) TEXT CORTXHUATXON FACZLITY HAMS OOCKET MUHQl 8 LE'.R MUHOER $ ACE NO.

TURKEY POINT UHXT 3 05000250 94-003-00 05 OF 05 ElIS Codes are shown in the format jEIIS SYSTEM: IEEE component function identifier, second component function identifier (if approprs.ate) ] .

Missed surveillances have been reported previously in LKRs 251/92-002 251/92-006, and 251/94-001. These three are summarized below:

LER 251/92-002 reported a surveillance missed because a commitment to perfoxm the surveillance had not been adequately captured. The commitment to pexform stroke timing was made in a relief request submitted several months earlier.

IER 251/92-002 involved a surveillance missed on SV-4-34348, one of the valves on which missed surveillances are reported hexa, but the earlier event took place before the separation of performance and review functions described, in Root Causa above, and was caused by inadequate txacking/implementation of a commitment.

LER 251/92-006 reported a surveillance missed due to an error in the use of the surveillance tracking program. The error caused a surveillance, required to be performed prior to a mode change, to be indicated as complete when in fact it had not yet been performed.

MR 251/94-001 reported several surveillances missed as a result of a diffexence in the scheduling techniques used by the Operations and Maintenance Departments. The result of the difference was the addition of a second grace period into the scheduling for the subject survelllances.