ML17348A773

LER 90-022-00:on 901114,discovered That Tech Spec Required Fire Protection Surveillance Not Performed within Max Allowed Time Interval.Caused by Inadequate Administrative Controls.Memo issued.W/901212 Ltr

ML17348A773
Person / Time
Site:	Turkey Point
Issue date:	12/12/1990
From:	Plunkett T, Dawn Powell FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-431, LER-90-022, LER-90-22, NUDOCS 9012180043
Download: ML17348A773 (10)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9012180043 DOC.DATE: 90/12/12 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.PLUNKETT,T.F.

Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 90-022-00:on 901114,discovered that Tech Spec required fire protection surveillance not performed within max allowed time interval.Caused by inadequate administrative controls.Memo issued.W/901212 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: RECIPIENT ID CODE/NAME PD2-2 LA EDISON,G INTERNAL: ACNW AEOD/DS P/TPAB NRR/DET/ECMB 9H NRR/DLPQ/LHFB11 NRR/DOEA/OEAB NRR/DST/SELB 8D NRR/DST/SQLBS Dl REG-FXXB~~02 GN2 FILE 0 1 EXTERNAL EG&G BRYCE g J~H NRC PDR NSIC MURPHY,G.A 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 3 3 1 1 1 1 RECIPIENT ID CODE/NAME PD2-2 PD AEOD/DOA AEOD/ROAB/DSP NRR/DET/EMEB 7E NRR/DLPQ/LPE B 1 0 NRR/DREP/PRPB11 NRR/DST/SICB 7E NRR/DST/SRXB 8E RES/DSIR/EIB L ST LOBBY WARD NSIC MAYS,G NUDOCS FULL TXT.COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!FULL.TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31 DEC 12 1990 L-90-4'31 10 CFR 50.73 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 Reportable Event: 90-022 Date of Event: November 13, 1990 Fire Protection Surveillance Not Performed Within Technical S ecification Maximum Allowed Time Interval The attached Licensee Event Report is being provided pursuant to the requirements of lOCFR50.73 to provide information on the subject event.Corrective Action g 4-corresponds to a corrective action previously identified in LER 50-250/90-020-0.

The scheduled date for completion of this corrective action is being escalated by Turkey Point Nuclear Plant management from February 15, 1991 to January 18, 1991 due to the additional instance of a missed Technical Specification surveillance described herein.Very truly yours, cP7+~~T.F.Plunkett Vice President Turkey Point Nuclear Plant TFP/DRP/dwh Attachment cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC, Senior Resident Inspectorr USNRCr Turkey Point Plant 9012180043 901212 PDR ADOCK 05000250 S-PPR an FPL Group company NRC Form 364 (903)LlCENSEE EVENT REPORT (LER)US.NUCLEAR REOULATORY COMMISSION APPROVED DMS NO.3160010C EXPIRESt SI$'II44 FACILITY NAME (I I Turkey Point Unit 3 PA DOCKET NUMSER (1)o 5 o o o 250 10F04 TITLE (Cl s re ro ec s on urve)ance o er orme 1 s n ec ns ca pec1 s ca on Maximum Allowed Time Interval MONTH OAY YKAR EVENT DATE ISI YEAR LER NVMSER (5)Ifcx$4QUENTIAI, NUM4ER.c:e,.NUM44ti MONTH DAY YEAR REPORT'ATE (7)OTHER FACILITIES INVOLVED (4)DOCKET NVMSER(SI o so o o 25 1 FACILITY NAMES Turkey Point Unit 4 1 390 9 0 0 2 00 12 1 2 9 0 0 5 0 0 0 OPERATINO MODE 14)POWER LEVEL (10)20.402(4)20A05 (e l(1)0)20A05(e l(1)(SI 20A054)(I l(iii)20A05 4)I I I lir)20.605 (e)ll I (el 20.e06(cl 50.$6(c)II I 50.35(cl(21 50.73(el(1)(il 50.7$(e l(21(4)S0.7 34)(2)I it i)LICENSEE CONTACT FOR THIS LER (11)50 73(e l(2)(irl 50.734)12)4)50.'1341(2l(r41 50.734)(2l(riiil(A) 50.73(e I (2)(ri 4 H 4 I 50.7$(e I (2 I (nl THIS REPORT IS SVSMITTKD PURSUANT TO THE REOUIREMENTS OF 10 CF R g: ICneee One Or mtye Of tne IOIIOw'npl (11)7$.71(4)73.71(cl OTHER (Specify In Apttrect pefow errf In Tert, HRC Form JFFAI NAME David R.Powell, Licensing Superintendent TELEPHONE NUMSER AREA CODE 30 524 6-559 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE OESCRISED IN THIS REPORT (13)CAUSE SYSTEM COMPONENT MANUFAC TURER EPORTABLE TO NPRDS 4%4~$44: CAUSE SYSTEM COMPONENT MANVFAC.TURER EPORTASL TO NPRDS c4%%>~: SUPPLEMENTAL REPORT EXPECTED Ile)9er9:e'rr.L%'.<.

@at MONTH DAY YEAR EXPECTED SVSMISSION DATE (ISI YES III yeL comptete fXPf CTED SVSMISSIOH DATfl NO AssTRAcT (Limit to 1400 tpeceL I e., epprorimeteiy ftf4en tinpie tpece typewNHen linet)116)On November 14, 1990, with Unit 3 and Unit 4 in Mode 1 at 100 percent power, FPL personnel discovered that a Technical Specification (TS)surveillance requirement had not been performed within the maximum allowed time interval.TS 4.15.4.a.1 requires the Unit 3 and Unit 4 fire hose stations to be visually inspected at least once per 31 days.TS 4.0.1 allows this specified interval to be adjusted plus or minus 25 percent to accommodate normal test schedules.

The TS 4.15.4.a.1 surveillance requirement is implemented by performance of Appendix A to Maintenance Procedure (MP)15537.5,"Fire Protection Equipment Surveillance." On November 13p 1990p Appendix A to procedure MP 15537'was performed as scheduled by Operating Surveillance Procedure O-OSP-200.1,"Schedule of Plant Checks and Surveillances." Appendix A to procedure MP 15537.5 was previously performed on October 4, 1990, five days earlier than scheduled by procedure 0-OSP-200.1.The maximum time interval allowed by TS between these surveillances was exceeded.The cause for this condition was inadequate administrative controls.A non-cognitive error by a non-licensed utility individual contributed to this event.A memorandum concerning this event has been issued to plant departmental supervisors responsible for the performance of surveillances identified in procedure O-OSP-200.1.

NRC Form 366 (9 8)I

NRC Form 3SSA I84)3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REOULATORY COMMISSION APPROVED OMS NO.3180M)Cd EXPIRES: 8/31/88 FACILITY NAME 11)DOCKET NUMBER I2)LER NUMSER IS)/P/P/SSOVSNTIAL PW ASVISION NVMSSA iArd NVMSSII PACE 13)Turkey Point Unit 3 TEXT///moro/poco/d/or/o/rod, o/o odd//lono/HRC Fomr 3//843/))7)0 5 0 0 0 250 gp 0 2 OF DESCRIPTION OF THE EVENT On November 14/1990/with Unit 3 and Unit 4 in-Mode 1 at 100 percent power, FPL personnel discovered that a Technical Specification (TS)surveillance requirement had not been performed within the maximum allowed time interval.TS 4.15.4.a.1 requires the Unit 3 and Unit 4 fire hose stations to be visually insp'ected at least once per 31 days.Per TS 4.0.1, this specified interval may be adjusted plus or minus 25 percent to accommodate normal test schedules.

The TS 4.15.4.a.1 surveillance requirement is implemented by performance of Appendix A to Maintenance Procedure (MP)15537.5,"Fire Protection Equipment Surveillance." Procedure MP 15537.5 is scheduled by Operating Surveillance Procedure 0-OSP-200.1,"Schedule of Plant Checks and Surveillances/U to be performed on the second Tuesday of each month.Depending on which day of the month the second Tuesday falls, the normal scheduled time interval between surveillances can be either 28 days or 35 days.The normal scheduled time interval between the October and November surveillances was 35 days.For the month of October, procedure MP 15537.5 was scheduled to be performed on October 9, 1990.On October 4, 1990, Appendix A to procedure MP 15537.5 was completed five days earlier than scheduled.

For the month of November, procedure MP 15537.'5 was scheduled to be performed on November,13, 1990.On November 13, 1990, Appendix A to procedure MP 15537.5 was completed as scheduled.

The total elapsed time interval between these surv'eillances exceeded the maximum time interval allowed by TS.CAUSE OF THE EVENT The cause for exceeding the maximum allowed TS interval between fire hose station surveillances was inadequate administrative controls.If surveillances are performed on the date scheduled by procedure O-OSP-200.1, the surveillances will be performed within maximum time intervals allowed by TS.If a surveillance is not performed by the scheduled date, Control Room personnel will identify this condition during their daily review of procedure O-OSP-200.1 scheduling sheets and track the surveillance to completion.

However, if a surveillance is performed earlier than scheduled by procedure O-OSP-200.1, no guidance or controls exist to ensure the maximum time interval allowed by TS is not exceeded.NAC FOAM SddA

NRC Form 366A (983)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REOULATORY COMMISSION APPROVED OMB NO, 3)50-0IOE EXPIRES: 8/31/68 FACILITY NAME (1)DOCKET NUMBER (2)LER NUMBER (6)YEAR Po)" SEQUENTIAL

%I(1 REVISION~??NUMSER NN NUMSER PACE (31 Turkey Point Unit 3 TEXT//f moro E/Moo/E roEV/rod, u>>odd/o'ooo/rYRC Forrrr 36//AS/(17)o s o o o 9 0 2 2 0 0 03 oF 0 4 A contributing factor was a non-cognitive error by a non-.licensed utility individual.

Procedure O-OSP-200.1 provides a schedule for performing TS required surveillances and identifies the department responsible for each surveillance.

When the scheduled dates in procedure O-OSP-200.1 are not met, the responsible plant departmental TS surveillance scheduler should ensure the interval between surveillances is within the maximum time interval allowed by TS.ANALYSIS OF THE EVENT Performance of Appendix A to procedure MP 15537.5 within the TS maximum allowed time interval demonstrates continued operability of the Unit 3 and Unit 4 fire hose stations.If the TS maximum allowed time interval between surveillances is exceeded, then the fire hose stations are technically inoperable.

Appendix A to procedure MP 15537.5 was satisfactorily completed on November 13, 1990.Therefore, the Unit 3 and Unit 4 fire hose stations were in fact physically capable of performing their intended function.CORRECTIVE ACTIONS 1.Appendix A to procedure MP 15537.5 was satisfactorily completed on November 13, 1990.2.The requirement for performing TS surveillances within the maximum time interval allowed by TS was conveyed to the TS surveillance planner responsible for procedure MP 15537.5.3.A memorandum has been issued to plant departmental supervisors responsible for the performance of surveillances identified in procedure O-OSP-200.1.

The requirement for performing TS surveillances within the maximum time interval allowed by TS was re-emphasized.

4.In Licensee Event Report (LER)50-250/90-020-0, dated November 9, 1990, FPL committed to perform a management review of the generic problem of surveillance scheduling and tracking to determine applicable corrective actions to reduce the number of missed surveillances.

The incident described in this LER will be included in the management review.The scheduled date for completion of the review is being escalated from February 15, 1991 to January 18, 1991 due to the additional instance of a missed TS surveillance described herein.A supplement to LER 50-250/90-020-0 will NRC FORM 366A O.ESI D

NRC Form 3ddA (9 83)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REOULATORY COMMISSION APPROVED OMB NO.3ISOW104 EXPIRES: 8/31/88 FACILITY NAME (I)DOCKET NUMBER (2)YEAR LER NUMBER (8)SEOUENTIAL NUMSEII II E V Id I 0 N NUM ER PACE (3)Turke Point Unit 3 TEXT///moro r/rrco/r>>r/vtrrd, v>>odd/rroor///RC Form SSSA'r/(17)6 0 0 0 25 090 0 2 2'00 0 OF 0 4 be submitted to report the results of this management review and the corrective actions determined to be necessary.

ADDITIONAL INFORMATION Incidents of missed TS surveillances have been reported in previous Licensee Event Reports (LERs).However, those~incidents did not share the same root cause as identified in this LER.NRC FORM dddA