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| issue date = 10/20/1992
| issue date = 10/20/1992
| title = LER 92-006-00:on 920927,identified That Required Surveillance Not Performed Per TS 4.5.2.b.1.Caused by Personnel Error.All Surveillances in Sys Verified to Have Been Performed Per TS.W/921020 Ltr
| title = LER 92-006-00:on 920927,identified That Required Surveillance Not Performed Per TS 4.5.2.b.1.Caused by Personnel Error.All Surveillances in Sys Verified to Have Been Performed Per TS.W/921020 Ltr
| author name = KNORR J E, PLUNKETT T F
| author name = Knorr J, Plunkett T
| author affiliation = FLORIDA POWER & LIGHT CO.
| author affiliation = FLORIDA POWER & LIGHT CO.
| addressee name =  
| addressee name =  
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:ACCELERA'l.'ED DLS'l'R18U'l'106 DEiV10iiS'L'HA'J AObt SYS'l'EiVL REGULATC INFORMATION DISTRIBUTION STEM (RIDS)ACCESSION NBR 9211020078 DOC'DATE 92/10/20 NOTARIZED NO DOCKET FACIL:50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFILZATION KNORR,J.E.
{{#Wiki_filter:ACCELERA'l.'ED DLS'l'R18U'l'106 DEiV10iiS'L'HA'J AObt SYS'l'EiVL REGULATC       INFORMATION DISTRIBUTION STEM         (RIDS)
Florida Power&Light Co.PLUNKETT,T.F.
ACCESSION NBR 9211020078             DOC'DATE 92/10/20       NOTARIZED NO           DOCKET FACIL:50-251 Turkey Point Plant, Unit 4, Florida Power and Light                   C 05000251 AUTH. NAME           AUTHOR   AFFILZATION KNORR,J.E.           Florida Power & Light Co.
Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION
PLUNKETT,T.F.         Florida Power & Light Co.
RECIP.NAME           RECIPIENT AFFILIATION


==SUBJECT:==
==SUBJECT:==
LER 92-006-00:on 920927,identified that required surveillance not performed per TS 4.5.2.b.l.Caused by.personnel error.All surveillances in sys verified to have been performed per TS.W/921020 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR i ENCL)SIZE: TITLE: 50..73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES:NRR RAGHAVAN,L 05000251 RECIPIENT ID CODE/NAME PD2-2 LA AULUCKFR INTERNAL: ACNW AEOD/DSP/TPAB NRR/DET/EMEB 7E NRR/DLPQ/LPEB10 NRR/DREP/PRPBll NRR/DST/SICB8H3 NRR/DST/SRXB 8E'RES/DSIR/EIB EXTERNAL: EG&G BRYCEFJ.H NRC PDR NSIC POORE,W.NOTES: COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 2 2 1 1 1 1 1 1 2 2 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD2-2 PD AEOD/DOA AEOD/ROAB/DSP NRR/DLPQ/LHFB10 NRR/DOEA/OEAB NRR/DST/SELB 8D S LB8D1 REG F LE 02 FILE 01 L ST LOBBY HARD NSIC MURPHY,G.A NUDOCS FULL TXT COPIES LTTR ENCL 1 1 1 1 2 2 1 1'1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ,0 NOTE TO ALL"RIDS.RECIPIENTS:
LER     92-006-00:on 920927,identified that required surveillance not performed per TS 4.5.2.b.l.Caused by
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM Pl-37 (EXT.504-'2065)
            .personnel error.All surveillances in sys verified to have been performed per TS.W/921020           ltr.
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!0'UL'L TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL 30 0 0 I 60T RO1M L-92-293 10 CFR 50.73'.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
DISTRIBUTION CODE: IE22T           COPIES RECEIVED:LTR       i ENCL)   SIZE:
Re: Turkey Point Unit 4 Docket No.50-251 Reportable Event: 92-006-00 Two Mode Change Surveillances Not Performed in Accordance with Technical S ecifications The attached'icensee Event Report 251-92-006-00 is being provided in.accordance.with 10 CFR 50.73 (a)(2)(i)(B).'If there.are any questions please contact us.Very, truly.yours, T..F.Plunkett Vice President Turkey Point Nuclear.TFP'/JEK/jk enclosure cc: Stewart D.Ebneter, Regional Administrator, Region II,'USNRC Ross C.Butcher, Senior Resident Inspector, USNRC, Turkey Point Plant 36009<9211020078
TITLE: 50..73/50.9 Licensee Event Report (LER), Incident Rpt, etc.
'921020 PDR ADOCK 05000251 8 PDR an FPL'Groop.company Ib FACILITY NAME (1)LICENSEE EVENT REPORT (LER)DOCKET NUMBER (2)PAGE (3)TURKEY POINT UNIT 4 05000251 1 oF 3 TITLE (6)Two Mode Change Surveillances Not Performed in Accordance with Technical Specifications EveNF DATe (5)LER NUMBER(6)RPT DATE (7)OTHER FACILITZES INV (8)MON DAY YR YR SEQ 9 R)MON DAY YR FACILITY NAMES DOCKET I (S)09 27 92 OPERATING MODE (9)'i 92 006 00 10 27 92 TURKEY POINT UNIT 3 05000250 THIS REPORT IS SUBMITTED PURSUANT TO THE RE UIREMENTS OF 10 CFR 10 CFR 50.73 a 2 i B poweR I,Fvez, (10)0%LICENSEE CONTACT FOR THIS LER (12)James E.Knorr, Licensing Engineer COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED ZN THIS REPORT (13)TELEPHONE NUMBER 305-246-6757 CAUSE SYSTEM COMPONENT MANUFACTURER NPRDS2 cAUse SYSTEM coMpoNENT MANUFACTURER NPRDS2 SUPPLEMENTAL REPORT EXPECTED (14)NO X Yes 0 (if Yee em@>lete EXPECTED SUBMISSION DATE)expFGTeD SUBMISSION DATE (15)DAY YEAR ABsTRAcT (16)On September 27'992I Turkey Point Unit 4 entered Mode 4 from Mode 5 at 0931 hours.At 1330 hours on September 28I 1992I Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4.Technical Specification 4.5.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS)piping is full of water by venting the ECCS pump casings and accessible discharge piping.This requirement applies during Modes 1, 2, 3 and 4.This surveillance was completed for Unit 4 at 1720 hours on September 28, 1992 and Unit 3 at 1400 hours on September 29, 1992.As part of the corrective action process for the above described event, a standby feedwater pump surveillance was also found to be incomplete.
NOTES:NRR RAGHAVAN,L                                                                 05000251 RECIPIENT             COPIES            RECIPIENT          COPIES ID  CODE/NAME          LTTR ENCL        ID CODE/NAME     LTTR ENCL PD2-2 LA                     1      1    PD2-2 PD              1    1 AULUCKFR                     1      1                                                      ,0 INTERNAL: ACNW                           2      2    AEOD/DOA              1    1 AEOD/DSP/TPAB               1      1    AEOD/ROAB/DSP          2    2 NRR/DET/EMEB 7E             1      1    NRR/DLPQ/LHFB10        1    1' NRR/DLPQ/LPEB10              1      1    NRR/DOEA/OEAB                1 NRR/DREP/PRPBll              2      2    NRR/DST/SELB 8D        1    1 NRR/DST/SICB8H3             1      1          S    LB8D1      1    1 NRR/DST/SRXB 8E             1      1    REG F LE      02      1    1
This surveillance is required to be complete prior to the entry into Mode 3.Unit 4 entered Mode 3 from Mode 4 at 0248 hours on September 28, 1992.This surveillance procedure was completed on September 29, 1992.The root cause of the two missed surveillances was an error during the change of dates in a.computerized surveillance tracking system.Corrective actions have been implemented to reduce the probability of this occurrence in the future.
          'RES/DSIR/EIB                 1      1            FILE 01        1    1 EXTERNAL: EG&G BRYCEFJ.H                 2      2    L ST LOBBY HARD        1    1 NRC PDR                     1      1    NSIC MURPHY,G.A        1     1 NSIC POORE,W.                1     1     NUDOCS FULL TXT        1     1 NOTES:                                    1     1 NOTE TO ALL "RIDS. RECIPIENTS:
4l I~l LICENSEE ENT REPORT (LER)TEXT NTINURTION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE NO.TURKEY POINT UNIT 4 05000251 92-006-00 02 oF 03 Z.EVENT DESCRIPTION On September 27, 1992, Turkey Point Unit 4 entered Mode 4 from Mode 5 at 0931 hours.At 1330 hours on September 28, 1992, Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4.Technical Specification 4'.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS)piping (EIIS-BP and BQ)is full of water by venting the ECCS pump casings (EZIS-BP and BQ, IEEE-P)and accessible discharge piping.This requirement applies during Modes 1, 2, 3 and 4.This surveillance is completed by implementation of operations support procedures 3/4-OSP-202.2,.ECCS Venting.4-0SP-0202.2 was completed at 1'720 hours on September 28, 1992.3-0SP-202.2 was completed at 1400 hours on September 29, 1992.As part of, the corrective action process, on September 29, 1992, a required surveillance, O-OSP-074.3,'A'tandby Feedwater Pump, was found to be incomplete.
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
Technical Specification 4.7.1.6.2 requires a completion of the surveillance at least monthly to verify the operability of the standby feedwater pumps (EIIS-BA, IEEE-P)by testing in recirculation on a staggered basis.The surveillance is also required to be complete prior to the entry into Mode 3.Unit 4 entered Mode 3 at 0248 hours on September 28, 1992.This surveillance procedure was completed on September 29, 1992.Both surveillances were last performed prior to the unit shutdown prior to hurricane And'rew on August 24, 1992.ZZ.EVENT CAUSE The root cause was a personnel error.Personnel responsible for surveillance tracking, attempted to reschedule a surveillance by changing a date on a computer based surveillance tracking system to provide a printout of the above required surveillances,to Operations personnel.
ROOM Pl-37 (EXT. 504-'2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
The date change was made to allow the computer to print out the required surveillances on a"Daily Task Sheet" form or a"Seven Day Look-Ahead Schedule" form.If the date had not been changed the surveillance requirements would have appeared on two forms;1)Mode Change Report;2)Surveillance Past Scheduled Date Report.If the surveillances had appeared on either form as incomplete, the surveillances would have been completed prior to the respective mode change.The date change however changed the status of the surveillance in the computer system,to current.That is to say, the surveillance tracking system was automatically updated as if the surveillances were complete and,therefore, did not need to be done for the next 31 days.The surveillances did appear on the Mode Change Report but were indicated as complete.ZZZ.EVENT SAFETY ANALYSIS Prior to the entry into Mode 4, cooling of the reactor coblant system was supplied by the running of a residual heat removal (RHR)pump through a heat exchanger transferring heat to the component cooling water system.The RHR.pumps were.successfully run.The safety 0 J I ICENSEE ENT REPORT (LER)TEXT NTINUATION rACILZTY NAME DOCKET'UMBER LER NUMBER PAGE NO.TURKEY POINT UNIT 4 05000251 92-006-00'3.or 03 injection pumps were run as part of a Temporary Procedure TP-887, High Head Safety Injection Pump Readiness Test, prior to changing to Mode 4 and the system showed no evidence of needing venting of the piping or the pump casings.The RHR and safety injection systems were walked down to verify valve alignment on September 29, 1992.The ECCS system surveillances were later implemented, as discussed above, and the systems were proven to be operable.Prior to entry into Mode 3 the standby feedwater pumps were run as part of Temporary Procedure TP-893, Standby Feedwater Readiness Test[Post Andrew].Both pumps were run on recirculation on.September 16, 1992.The system readiness tests did not examine all the parameters that are reviewed during the surveillance test.However, the subsequent surveillance testing performed on the pumps proved them operable.The standby feedwater system is not a safety grade system.The health and safety of plant personnel and the general public were not compromised as a result of the missed surveillances.
0'UL'L TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR               30  ENCL   30
IV..CORRECTIVE ACTIONS The surveillances.
 
were completed within 24 hours of discovery.
0 0 I 60T RO1M L-92-293 10 CFR 50.73'.
See the discussion in the Event Description above.2.All surveillances in the computerized, tracking system were independently verified to have been performed, as required by Technical Specifications, to allow a mode change from Mode 4 to Mode 3, Mode 3 to Mode 2, and Mode 2 to Mode 1..3~4~The, person making the date change was counselled to not make changes to dates in the computer tracking system without written approval for the change from the Operations Support Supervisor.
S. Nuclear Regulatory Commission Attn:      Document        Control Desk Washington, D. C.           20555 Gentlemen:
Procedure changes were made to implement this policy.The purpose of the surveillance tracking system was discussed with the planning and scheduling department personnel to emphasize the necessity for care and accuracy'.
Re:    Turkey Point Unit        4 Docket No. 50-251 Reportable Event: 92-006-00 Two Mode Change Surveillances Not Performed in Accordance with Technical S ecifications The    attached'icensee          Event Report 251-92-006-00        is being provided in .accordance .with 10 CFR 50. 73 (a) (2) (i)            (B) .
V,.ADDITIONAL INFORMATION This event was considered reportable in accordance with 10 CFR 50.73 (a)(2)(i)(B).
    'If there .are any questions please contact us.
Ib)/}}
Very,truly. yours, T.. F. Plunkett Vice President Turkey Point Nuclear
    .TFP'/JEK/jk enclosure cc:     Stewart D. Ebneter, Regional Administrator, Region II,
            'USNRC Ross C. Butcher, Senior Resident Inspector, USNRC, Turkey Point Plant 36009<
9211020078 '921020 PDR    ADOCK 05000251 8                        PDR an FPL'Groop.company
 
Ib LICENSEE EVENT REPORT                                                          (LER)
FACILITY NAME (1)                                                                                        DOCKET NUMBER (2)       PAGE (3)
TURKEY POINT UNIT 4                                                    05000251                1    oF      3 TITLE (6)          Two Mode Change              Surveillances Not Performed in Accordance with Technical Specifications EveNF DATe (5)            LER NUMBER(6)            RPT DATE  (7)            OTHER FACILITZES  INV  (8)
MON      DAY      YR            YR    SEQ 9      R)    MON    DAY    YR                      FACILITY NAMES                DOCKET  I  (S) 09        27 OPERATING MODE (9) poweR I,Fvez, (10) 92
                        'i        92    006        00    10      27      92        TURKEY POINT UNIT 3 THIS REPORT IS SUBMITTED PURSUANT TO THE 10 CFR 50.73 a 2                i RE UIREMENTS OF 10 CFR B
05000250 0%
LICENSEE CONTACT FOR THIS LER (12)
James      E. Knorr, Licensing Engineer                                                                              TELEPHONE NUMBER 305-246-6757 COMPLETE ONE  LINE FOR  EACH COMPONENT FAILURE DESCRIBED ZN THIS REPORT (13)
CAUSE    SYSTEM          COMPONENT      MANUFACTURER              NPRDS2      cAUse      SYSTEM        coMpoNENT  MANUFACTURER      NPRDS2 SUPPLEMENTAL REPORT EXPECTED    (14)   NO  X          Yes  0                                    expFGTeD SUBMISSION DAY         YEAR DATE  (15)
(if Yee  em@>lete EXPECTED SUBMISSION DATE)
ABsTRAcT (16)     On September 27'992I Turkey Point Unit 4 entered Mode 4 from Mode 5  at 0931 hours. At 1330 hours on September 28I 1992I Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4. Technical Specification 4.5.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS) piping is full of water by venting the ECCS pump casings and accessible discharge piping. This requirement applies during Modes 1, 2, 3 and 4. This surveillance was completed for Unit 4 at 1720 hours on September 28, 1992 and Unit 3 at 1400 hours on September 29, 1992.
As part of the corrective action process for the above described event, a standby feedwater pump surveillance was also found to be incomplete. This surveillance is required to be complete prior to the entry into Mode 3.
Unit 4 entered Mode 3 from Mode 4 at 0248 hours on September 28, 1992. This surveillance procedure was completed on September 29, 1992.
The root cause of the two missed surveillances was an error during the change of dates in a .computerized surveillance tracking system.                                                           Corrective actions have been implemented to reduce the probability of this occurrence in the future.
 
4l I~
l
 
LICENSEE ENT      REPORT  (LER) TEXT NTINURTION FACILITY NAME        DOCKET NUMBER    LER NUMBER      PAGE NO.
TURKEY POINT UNIT 4        05000251          92-006-00          02 oF 03 Z. EVENT DESCRIPTION On  September 27, 1992, Turkey Point Unit 4 entered Mode 4 from Mode 5 at 0931 hours. At 1330 hours on September 28, 1992, Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4. Technical Specification 4 '.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS) piping (EIIS-BP and BQ) is full of water by venting the ECCS pump casings (EZIS-BP and BQ, IEEE-P) and accessible discharge piping. This requirement applies during Modes 1, 2, 3 and 4. This surveillance is completed by implementation of operations support procedures 3/4-OSP-202.2,
.ECCS Venting. 4-0SP-0202.2 was completed at 1'720 hours on September 28, 1992. 3-0SP-202.2 was completed at 1400 hours on September 29, 1992.
As  part of,the corrective action process, on September 29, 1992, a required surveillance, O-OSP-074.3, 'A'tandby Feedwater Pump, was found to be incomplete. Technical Specification 4.7.1.6.2 requires a completion of the surveillance at least monthly to verify the operability of the standby feedwater pumps (EIIS-BA, IEEE-P) by testing in recirculation on a staggered basis. The surveillance is also required to be complete prior to the entry into Mode 3. Unit 4 entered Mode 3 at 0248 hours on September 28, 1992. This surveillance procedure was completed on September 29, 1992.
Both surveillances were last performed prior to the unit shutdown prior to hurricane And'rew on August 24, 1992.
ZZ. EVENT CAUSE The  root cause was a personnel error. Personnel responsible for surveillance tracking, attempted to reschedule a surveillance by changing a date on a computer based surveillance tracking system to provide a printout of the above required surveillances,to Operations personnel. The date change was made to allow the computer to print out the required surveillances on a "Daily Task Sheet" form or a "Seven Day Look-Ahead Schedule" form. If the date had not been changed the surveillance requirements would have appeared on two forms; 1) Mode Change Report; 2) Surveillance Past Scheduled Date Report. If the surveillances had appeared on either form as incomplete, the surveillances would have been completed prior to the respective mode change. The date change however changed the status of the surveillance in the computer system,to current. That is to say, the surveillance tracking system was automatically updated as the surveillances were complete and,therefore, did not need to be if done for the next 31 days. The surveillances did appear on the Mode Change Report but were indicated as complete.
ZZZ. EVENT SAFETY ANALYSIS Prior to the entry into  Mode 4, cooling of the reactor coblant system was  supplied by the running of a residual heat removal (RHR) pump through a heat exchanger transferring heat to the component cooling water system. The RHR .pumps were .successfully run. The safety
 
0 J
 
I ICENSEE ENT                (LER) TEXT NTINUATION
                                                              '3 REPORT rACILZTY NAME          DOCKET'UMBER    LER NUMBER      PAGE NO.
TURKEY POINT UNIT 4          05000251        92-006-00          .or 03 injection pumps were run as part of a Temporary Procedure TP-887, High Head Safety Injection Pump Readiness Test, prior to changing to Mode 4 and the system showed no evidence of needing venting of the piping or the pump casings. The RHR and safety injection systems were walked down to verify valve alignment on September 29, 1992.
The ECCS system surveillances were later implemented, as discussed above, and the systems were proven to be operable.
Prior to entry into Mode 3 the standby feedwater pumps were run as part of Temporary Procedure TP-893, Standby Feedwater Readiness Test
[Post Andrew] . Both pumps were run on recirculation on .September 16, 1992. The system readiness tests did not examine all the parameters that are reviewed during the surveillance test. However, the subsequent surveillance testing performed on the pumps proved them operable. The standby  feedwater system is not a safety grade system.
The health and safety of plant personnel and the general public were not compromised as a result of the missed surveillances.
IV.. CORRECTIVE ACTIONS The   surveillances. were completed within 24 hours of discovery.
See  the discussion in the Event Description above.
: 2. All surveillances in the computerized, tracking system were independently verified to have been performed, as required by Technical Specifications, to allow a mode change from Mode 4 to Mode 3, Mode 3    to Mode 2, and Mode 2  to Mode 1.
.3 ~  The, person making the date change was counselled to not make changes to dates in the computer tracking system without written approval for the change from the Operations Support Supervisor.
Procedure changes were made to implement this policy.
4 ~  The purpose of the surveillance tracking system was discussed with the planning and scheduling department personnel to emphasize the necessity for care and accuracy'.
V,. ADDITIONAL INFORMATION This event was considered reportable in accordance with 10 CFR 50.73 (a) (2) (i) (B) .
 
Ib  )
  /}}

Latest revision as of 07:48, 22 October 2019

LER 92-006-00:on 920927,identified That Required Surveillance Not Performed Per TS 4.5.2.b.1.Caused by Personnel Error.All Surveillances in Sys Verified to Have Been Performed Per TS.W/921020 Ltr
ML17349A450
Person / Time
Site: Turkey Point NextEra Energy icon.png
Issue date: 10/20/1992
From: Knorr J, Plunkett T
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-92-293, LER-92-006-03, LER-92-6-3, NUDOCS 9211020078
Download: ML17349A450 (10)
v • d • e


Text

ACCELERA'l.'ED DLS'l'R18U'l'106 DEiV10iiS'L'HA'J AObt SYS'l'EiVL REGULATC INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR 9211020078 DOC'DATE 92/10/20 NOTARIZED NO DOCKET FACIL:50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILZATION KNORR,J.E. Florida Power & Light Co.

PLUNKETT,T.F. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 92-006-00:on 920927,identified that required surveillance not performed per TS 4.5.2.b.l.Caused by

.personnel error.All surveillances in sys verified to have been performed per TS.W/921020 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR i ENCL) SIZE:

TITLE: 50..73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:NRR RAGHAVAN,L 05000251 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 AULUCKFR 1 1 ,0 INTERNAL: ACNW 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 1 1' NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 NRR/DREP/PRPBll 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB8H3 1 1 S LB8D1 1 1 NRR/DST/SRXB 8E 1 1 REG F LE 02 1 1

'RES/DSIR/EIB 1 1 FILE 01 1 1 EXTERNAL: EG&G BRYCEFJ.H 2 2 L ST LOBBY HARD 1 1 NRC PDR 1 1 NSIC MURPHY,G.A 1 1 NSIC POORE,W. 1 1 NUDOCS FULL TXT 1 1 NOTES: 1 1 NOTE TO ALL "RIDS. RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-'2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

0'UL'L TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL 30

0 0 I 60T RO1M L-92-293 10 CFR 50.73'.

S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit 4 Docket No. 50-251 Reportable Event: 92-006-00 Two Mode Change Surveillances Not Performed in Accordance with Technical S ecifications The attached'icensee Event Report 251-92-006-00 is being provided in .accordance .with 10 CFR 50. 73 (a) (2) (i) (B) .

'If there .are any questions please contact us.

Very,truly. yours, T.. F. Plunkett Vice President Turkey Point Nuclear

.TFP'/JEK/jk enclosure cc: Stewart D. Ebneter, Regional Administrator, Region II,

'USNRC Ross C. Butcher, Senior Resident Inspector, USNRC, Turkey Point Plant 36009<

9211020078 '921020 PDR ADOCK 05000251 8 PDR an FPL'Groop.company

Ib LICENSEE EVENT REPORT (LER)

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

TURKEY POINT UNIT 4 05000251 1 oF 3 TITLE (6) Two Mode Change Surveillances Not Performed in Accordance with Technical Specifications EveNF DATe (5) LER NUMBER(6) RPT DATE (7) OTHER FACILITZES INV (8)

MON DAY YR YR SEQ 9 R) MON DAY YR FACILITY NAMES DOCKET I (S) 09 27 OPERATING MODE (9) poweR I,Fvez, (10) 92

'i 92 006 00 10 27 92 TURKEY POINT UNIT 3 THIS REPORT IS SUBMITTED PURSUANT TO THE 10 CFR 50.73 a 2 i RE UIREMENTS OF 10 CFR B

05000250 0%

LICENSEE CONTACT FOR THIS LER (12)

James E. Knorr, Licensing Engineer TELEPHONE NUMBER 305-246-6757 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED ZN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER NPRDS2 cAUse SYSTEM coMpoNENT MANUFACTURER NPRDS2 SUPPLEMENTAL REPORT EXPECTED (14) NO X Yes 0 expFGTeD SUBMISSION DAY YEAR DATE (15)

(if Yee em@>lete EXPECTED SUBMISSION DATE)

ABsTRAcT (16) On September 27'992I Turkey Point Unit 4 entered Mode 4 from Mode 5 at 0931 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.542455e-4 months <br />. At 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> on September 28I 1992I Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4. Technical Specification 4.5.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS) piping is full of water by venting the ECCS pump casings and accessible discharge piping. This requirement applies during Modes 1, 2, 3 and 4. This surveillance was completed for Unit 4 at 1720 hours0.0199 days <br />0.478 hours <br />0.00284 weeks <br />6.5446e-4 months <br /> on September 28, 1992 and Unit 3 at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on September 29, 1992.

As part of the corrective action process for the above described event, a standby feedwater pump surveillance was also found to be incomplete. This surveillance is required to be complete prior to the entry into Mode 3.

Unit 4 entered Mode 3 from Mode 4 at 0248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br /> on September 28, 1992. This surveillance procedure was completed on September 29, 1992.

The root cause of the two missed surveillances was an error during the change of dates in a .computerized surveillance tracking system. Corrective actions have been implemented to reduce the probability of this occurrence in the future.

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LICENSEE ENT REPORT (LER) TEXT NTINURTION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE NO.

TURKEY POINT UNIT 4 05000251 92-006-00 02 oF 03 Z. EVENT DESCRIPTION On September 27, 1992, Turkey Point Unit 4 entered Mode 4 from Mode 5 at 0931 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.542455e-4 months <br />. At 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> on September 28, 1992, Turkey Point personnel identified that a required surveillance had not been completed prior to the entry into Mode 4. Technical Specification 4 '.2.b.1 requires that at least once each 31 days plant personnel verify that the Emergency Core Cooling System (ECCS) piping (EIIS-BP and BQ) is full of water by venting the ECCS pump casings (EZIS-BP and BQ, IEEE-P) and accessible discharge piping. This requirement applies during Modes 1, 2, 3 and 4. This surveillance is completed by implementation of operations support procedures 3/4-OSP-202.2,

.ECCS Venting. 4-0SP-0202.2 was completed at 1'720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> on September 28, 1992. 3-0SP-202.2 was completed at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on September 29, 1992.

As part of,the corrective action process, on September 29, 1992, a required surveillance, O-OSP-074.3, 'A'tandby Feedwater Pump, was found to be incomplete. Technical Specification 4.7.1.6.2 requires a completion of the surveillance at least monthly to verify the operability of the standby feedwater pumps (EIIS-BA, IEEE-P) by testing in recirculation on a staggered basis. The surveillance is also required to be complete prior to the entry into Mode 3. Unit 4 entered Mode 3 at 0248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br /> on September 28, 1992. This surveillance procedure was completed on September 29, 1992.

Both surveillances were last performed prior to the unit shutdown prior to hurricane And'rew on August 24, 1992.

ZZ. EVENT CAUSE The root cause was a personnel error. Personnel responsible for surveillance tracking, attempted to reschedule a surveillance by changing a date on a computer based surveillance tracking system to provide a printout of the above required surveillances,to Operations personnel. The date change was made to allow the computer to print out the required surveillances on a "Daily Task Sheet" form or a "Seven Day Look-Ahead Schedule" form. If the date had not been changed the surveillance requirements would have appeared on two forms; 1) Mode Change Report; 2) Surveillance Past Scheduled Date Report. If the surveillances had appeared on either form as incomplete, the surveillances would have been completed prior to the respective mode change. The date change however changed the status of the surveillance in the computer system,to current. That is to say, the surveillance tracking system was automatically updated as the surveillances were complete and,therefore, did not need to be if done for the next 31 days. The surveillances did appear on the Mode Change Report but were indicated as complete.

ZZZ. EVENT SAFETY ANALYSIS Prior to the entry into Mode 4, cooling of the reactor coblant system was supplied by the running of a residual heat removal (RHR) pump through a heat exchanger transferring heat to the component cooling water system. The RHR .pumps were .successfully run. The safety

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I ICENSEE ENT (LER) TEXT NTINUATION

'3 REPORT rACILZTY NAME DOCKET'UMBER LER NUMBER PAGE NO.

TURKEY POINT UNIT 4 05000251 92-006-00 .or 03 injection pumps were run as part of a Temporary Procedure TP-887, High Head Safety Injection Pump Readiness Test, prior to changing to Mode 4 and the system showed no evidence of needing venting of the piping or the pump casings. The RHR and safety injection systems were walked down to verify valve alignment on September 29, 1992.

The ECCS system surveillances were later implemented, as discussed above, and the systems were proven to be operable.

Prior to entry into Mode 3 the standby feedwater pumps were run as part of Temporary Procedure TP-893, Standby Feedwater Readiness Test

[Post Andrew] . Both pumps were run on recirculation on .September 16, 1992. The system readiness tests did not examine all the parameters that are reviewed during the surveillance test. However, the subsequent surveillance testing performed on the pumps proved them operable. The standby feedwater system is not a safety grade system.

The health and safety of plant personnel and the general public were not compromised as a result of the missed surveillances.

IV.. CORRECTIVE ACTIONS The surveillances. were completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery.

See the discussion in the Event Description above.

2. All surveillances in the computerized, tracking system were independently verified to have been performed, as required by Technical Specifications, to allow a mode change from Mode 4 to Mode 3, Mode 3 to Mode 2, and Mode 2 to Mode 1.

.3 ~ The, person making the date change was counselled to not make changes to dates in the computer tracking system without written approval for the change from the Operations Support Supervisor.

Procedure changes were made to implement this policy.

4 ~ The purpose of the surveillance tracking system was discussed with the planning and scheduling department personnel to emphasize the necessity for care and accuracy'.

V,. ADDITIONAL INFORMATION This event was considered reportable in accordance with 10 CFR 50.73 (a) (2) (i) (B) .

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