IR 05000206/1988032

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SALP Meeting Repts 50-206/88-32,50-361/88-33 & 50-362/88-35 on 881213.Major Areas Discussed:Results of Most Recent SALP, Covering Period Oct 1987 - Sept 1988
ML13329A130
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/31/1989
From: Huey F, Johnson P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML13329A129 List:
References
50-206-88-32-MM, 50-361-88-33, 50-362-88-35, NUDOCS 8902270289
Download: ML13329A130 (66)


Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No /88-32, 50-361/88-33, 50-362/88-35 Docket No, 50-361, 50-362 License No DPR-13, NPF-10, NPF-15 Licensee:

Southern California Edison Company P. 0. Box 800, 2244 Walnut Grove Avenue Rosemead, California 92770 Facility Name:

San Onofre Units 1, 2 and 3 Meeting Location:

SCE Corporate Offices, Rosemead, California Meeting Date:

December 13, 1988 Prepared by:

LC_ 'A PF. R. Huey, Senior Resident Inspector Date Signed San Onofre Units 1, 2 and 3 Approved By:

___

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_

_

_

P. H. 'ohnson, Chief Date Signed Reactor Projects Section 3 Meeting Summary Management Meeting on December 13, 1988 (Report Nos. 50-206/88-32, 50-361/88-33, and 50-362/88-35)

A Systematic Assessment of License Performance (SALP) meeting was held on December 13, 1988 to discuss the results of the most recent SALP, covering the period October 1, 1987 through September 30, 1988. Other items of interest relating to the San Onofre Nuclear Generating Station were also discusse =-p 8901 PDE AOK0000

DETAILS Meeting Participants Nuclear Regulatory Commission (NRC)

J. Martin, Regional Administrator D. Crutchfield, Acting Associate Director for Projects, NRR D. Kirsch, Director, Division of Reactor Safety and Projects G. Knighton, Director, Reactor Project Directorate V, NRR R. Zimmerman, Chief, Reactor Projects Branch G. Yuhas, Chief, Emergency Preparedness and Radiological Protection Branch P. Johnson, Chief, Reactor Projects Section 3 C. Trammell, San Onofre Unit 1 Project Manager, NRR D. Hickman, San Onofre Units 2/3 Project Manager, NRR F. Huey, Senior Resident Inspector J. Tatum, Resident Inspector A. Hon, Resident Inspector Southern California Edison Company D. Fogarty, Executive Vice President K. Baskin, Vice President, Nuclear Engineering, Safety and Licensing C. McCarthy, Vice President, Site Manager R. Rosenblum, Manager of Quality Assurance D. Nunn, Manager of Nuclear Engineering & Construction M. Medford, Manager of Nuclear Regulatory Affairs H. Morgan, Station Manager D. Heinicke, Deputy Station Manager D. Herbst, Quality Assurance Manager D. Stonecipher, Quality Control Manager R. Krieger, Operations Manager D. Shull, Maintenance Manager J. Reilly, Technical Manager P. Knapp, Health. Physics Manager K. Slagle, Material & Administrative Services Manager D. Peacor, Emergency Preparedness Manager P. Eller, Security Manager J. Schramm, Operations Superintendent, Unit 1 V. Fisher, Operations Superintendent, Units 2/3 L. Cash, Maintenance Manager, Unit 1 R. Santosuosso, Maintenance Manager, Units 2/3 C. Chiu, Assistant Technical Manager M. Wharton, Assistant Technical Manager C. Couser, Compliance Engineer Management Discussion Mr. Martin opened the meeting by stating that the primary challenge of the SALP process is to provide increased licensee and NRC attention on the actions which are needed for sustained excellent operation of

licensed facilities. In this regard, Mr. Martin noted that during this last SALP period, the NRC and the licensee had focused significant atten tion and resource on the performance of engineering and technical work at San Onofre. This attention resulted in the identification of significant deficiencies (many of which were programmatic in nature) in the manner in which engineering and technical activities have been performed at San Onofre. Although SCE has initiated aggressive actions to correct the observed deficiencies, as noted during the management conference held at the site on November 2, 1988, the low SALP marks in the Engineering/Tech nical Support and Safety Assessment/Quality Verification areas reflect the significance of these deficiencies and the shortcomings of management involvement and quality oversight which allowed them to remain so long undetected. Mr. Martin encouraged SCE management to not only follow through with identified corrective actions, but to apply the lessons learned from the engineering program review to other areas of probable benefit. In particular, Mr. Martin noted that additional attention will be placed on licensee maintenance activities during the new SALP perio Mr. Kirsch briefly reviewed the results of the November 25 SALP repor In particular, he noted: Significant strengths were noted in Operations (particularly in the areas of trip reduction, operator knowledge and well-written proce dures) and in the Radiation Protection, Emergency Preparedness and Security area.

Failure to follow procedures was noted as a continuing problem in the Maintenance/Surveillance are.

The most significant problems were noted in the Engineering/

Technical Support and Safety Assessment/Quality Verification areas, although significant improvement was noted in root cause evaluation and chemistry program implementation. In particular, major weaknesses contributing to the assignment of a Category 3 rating in these areas were observed to include:

Engineering/Technical Support

-

Insufficient understanding of plant design

-

Inadequate control of design processes

-

Inadequate design data base Safety Assessment/Quality Verification

-

Insufficient management involvement/self critical attitude

-

Ineffective quality oversight group involvement

-

Inadequate safety reviews

-

Improper reportability determinations

-

Inadequately supported amendment requests Mr. Crutchfield briefly reviewed NRR concerns with SCE licensing submit tal In particular, he noted that Unit 1 submittals had not been of the

same quality as Unit 2/3 submittals. In this regard, he noted that SCE needed to place more attention on the quality of all Unit 1 submittals and not just those needed to support continued plant operation. M Knighton noted that late and inadequate event reports to the NRC were also a significant concern. In this regard, Mr. Martin added that he believed that the problem may involve a tendency on the part of the licensee to not tell the NRC about developing problems until they have the full story. He encouraged SCE to correct this problem and emphasize timely and open discussion of potential or significant plant problems with the NR Licensee management acknowledged this comment and stated that SCE would strive for improved communication Mr. Baskin stated that SCE would like to briefly review the specific corrective actions which are being pursued to improve performance in the Engineering/Technical Support and Safety Assessment/Quality Verification functional area Mr. Nunn discussed specific actions being taken in the Engineering/Tech nical Support are With regard to staffing, he noted that the existing level of engineering personnel was about 119, with a near-term projection of about 150 engineers. Mr. Martin questioned the ratio of engineering supervision to working engineers, noting that other successful engineer ing organizations seem to use a rule of thumb of engineering reviews and supervision requiring about 33% of the total engineering effor Mr. Nunn stated that SCE was sensitive to this concern and would put emphasis on effective engineering supervisio Mr. Rosenblum and Mr. Medford discussed the actions being taken to improve performance involving quality oversight groups and licensing activitie The licensee's presentations were concluded with a brief presentation by Mr. Knapp on the actions being implemented by SCE to improve control of spent fuel particle contamination during the Unit 1 refueling outage, which began in late Novembe In closing, Mr. Martin acknowledged the actions initiated by SCE to improve performance in the above areas and stated that he expected significant improvements would result from SCE's efforts. He noted that it is often easier to correct bad performance than to sustain excellent performance. In this regard, he emphasized the need for SCE management to maintain its level of effort in all areas impacting safe plant operation in order to provide continued excellence in this are Mr. Martin then led the discussion to other areas of current NRC concer In particular, he noted that recent NRC initiatives associated with operation at reduced coolant inventory (i.e., mid-loop operation of shutdown cooling) had underscored the significant risks involved during plant shutdown periods. In this regard, Mr. Martin stated that licensees should take prompt actions to dispel any lingering attitudes by plant operating personnel that diligence can be relaxed during plant shutdown periods. He noted that recent NRR reviews have established that as much as half of the total risk of core melt is associated with plant shutdown periods. He requested that SCE management provide specific attention to

ensure that special diligence is maintained by all plant personnel during periods of mid-loop plant operatio Mr. Martin noted that SCE was continuing to find illegal drugs within the protected areas of the plant. He emphasized that continued poor perfor mance in this area could not only undermine NRC confidence, but might also affect public confidence in the adequacy of the licensee's drug program. Mr. Martin stated that a particularly embarrassing aspect of the problem was the continuing finds in the Unit 2/3 lube oil rooms. He stated that SCE must quickly implement effective measures to stop this problem. Mr. Slagle briefly discussed measures being taken or considere Southern California Edison Company J 1 '

P.O. BOX Bo WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH-P BASKIN TELEPHONE VICE PRESIDENT ELuEH ON, E

4 818-302-1400 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:

Mr. John B. Martin, Regional Administrator Subject:

Systemic Assessment of Licensee Performance (SALP)

Docket Nos. 50-206, 50-361 and 50-362 San Onofre Nuclear.Generating Station Units 1, 2 and 3 References: A. Letter from Mr John B. Martin (USNRC) to Mr. Kenneth Baskin (SCE) dated November 25, 1988, same subjec B. Letter from Mr. Kenneth P. Baskin (SCE) to Mr. John B. Martin (USNRC) dated October 3, 1988, Subject:

Independent Assessment of Engineering and Technical Support for San Onofre Nuclear Generating Station Units 1, 2 and Reference A transmitted the SALP report which documents the NRC evaluation of the Southern California Edison Company's (SCE) performance in the operation of San Onofre Nuclear Generating Station Units 1, 2 and 3 for the period of October 1, 1987 through September 30, 1988. Overall SCE's performance was found to be acceptable and directed toward safe facility operation. Good performance was noted in the functional areas of Plant Operations, Radiological Controls, Emergency Preparedness, and Security. However, the report noted that SCE's performance was below average in the functional areas of Engineering/Technical Support and Safety Assessment/Quality Verificatio The purpose of this letter is to describe ongoing and planned future corrective actions to improve SCE's performance in these area As you are aware, SCE has recently completed an exhaustive review of engineering and technical support and is continuing to expeditiously act on the findings and recommendations to correct deficiencies in this are Details of this review and the actions being taken were discussed in Reference B and during our November 2 and December 13, 1988 meetings. The SALP report recognized that most of these changes were initiated too late in the SALP evaluation period to allow for their impact to be fully effective and that many other changes were to be phased in over several months in 1989. SCE is confident that these actions directly address the SALP findings in the

Mr. J. B. Martin-2-January 13, 1989 Engineering/Technical Support functional area. SCE reiterates that because of the significance and sweeping nature of the organizational changes and relocation described in Reference B, it will take some time before the new organization can reasonably be expected to achieve its full potentia The review of engineering and technical support concluded that the major contributors to the identified problems were the complexity of the organization, heavy reliance on engineering contractors combined with inadequate allocation of SCE engineering resources, and the lack of readily accessible comprehensive design basis documentation. The principle corrective actions to address these conclusions include the reorganization and relocation of offsite nuclear support organizations, augmentation of in-house engineering resources, and the establishment of a design basis documentation (DBD) program to recapture and maintain the design basis for all three unit The DBD program plan was forwarded to you by letter dated January 9, 198 While these actions primarily address the problems in the Engineering/

Technical Support area, they will undoubtedly have a positive effect on improving SCE's performance in the area of Safety Assessment/Quality Verification. For example, the complex interfaces and poor definition and understanding of responsibilities in the old organization has undoubtedly contributed to problems in the Licensing and Oversight area Inadequate design bases documentation detracts from the ability to perform adequate safety assessments. Important considerations may be overlooked in the absence of adequate design basis documentation. In the old organization, with engineering and technical support distributed among four separate departments, adequate technical support and review of licensing submittals also was difficult to achieve consistently. Without well defined responsibilities, the oversight organizations cannot direct the need for corrective actions to the responsible parties when problems are identified. The mis-allocation of resources devoted to engineering/technical support, overlap of responsibilities and duplication of effort existing in the old organization also contributed to less effective use of oversight resource SALP observations in the Safety Assessment/Quality Verification functional area related to deficiencies in oversight activities, licensing and reporting. The SALP Board observed that oversight groups lack aggressiveness and miss opportunities to identify and correct significant problems before they become self evident or are discovered by others. Observed licensing and reporting deficiencies included inadequately supported or late licensing submittals, excessive time being devoted to evaluating potentially reportable situations prior to making a reportability determination, and not appraising the NRC of developing issues of potential interes In response to the SALP observations relating to oversight activities, an independent critical review of oversight organization effectiveness is being initiated,.-focusing on "missed opportunities" to identify problems at an early stage and correct them. A consultant has been retained to conduct an independent review of SCE oversight functions. The first phase of the review will consist of an assessment of the current structure and mission of the

Mr. 3. B. Martin-3-January 13, 1989 oversight organizations. The second phase will consist of an evaluation of past examples of oversight failure as noted in the SALP report. The objective of this initiative is to determine root causes of oversight failures, implement corrective actions where indicated, and develop an ongoing process to assess future oversight performance, thereby providing a mechanism to learn from our experienc Several actions are already underway to correct oversight difficulties based upon our own evaluations of previous performance. These actions include efforts to improve the depth and insight of oversight activities by increasing the technical capability of our staff through training and cross-training, increased real time supervisory involvement in oversight staff activities, and a reduction in after-the-fact reviews, and a greater emphasis on real time, performance based activitie As a means to learn from our peers within the industry, one senior oversight supervisor will participate in an INPO plant evaluation approximately every three months. We believe that participation in an INPO plant evaluation is the most effective means to become familiar with both good and bad practices within the industr SCE is aggressively seeking to eliminate inappropriate restrictions which tend to focus oversight efforts on low payback-traditional paper reviews, and reduce the flexibility necessary to allow us to focus our resources most effectively on emergent issues. In 1988, both Technical Specification and Topical Report changes were requested and approved, which increased the flexibility of the Quality Assurance effort As noted above, the reorganization, will also have positive results in the Safety Assessment/Quality Verification area. The reorganization has consolidated the oversight functions of the Nuclear Safety Group, Independent Safety Engineering Group, Quality Assurance and Quality Control under a single manager, allowing better coordination of oversight activities and utilization of resources. Management changes have also been made which bring new perspectives to the oversight organization In a yet to be completed change, the nuclear licensing function will be focused by transferring appropriate elements of the current Station Compliance organization to Licensing. This will provide for better coordination of the interfaces between Licensing and the Station, and SCE interfaces with NRR and Region The reorganization will afford better technical support for licensing submittals. The consolidation of engineering responsibilities within the Nuclear Engineering, Safety and Licensing engineering organization will make that organization the primary source of engineering support for licensing activities. In many previous instances, licensing has contracted and overseen engineering work related to licensing activities. This had the effect of diluting licensing resources and control of the design base Reestablishment of engineering responsibilities in the new organization will allow licensing resources to be concentrated on licensing activitie Mr. 3. B. Martin-4-January 13, 1989 The appointment of a senior manager in the new organization, who is responsible specifically for licensing, will increase management oversight of licensing activities. This will provide for coordination at a higher level and prioritization of resources to improve SCE's on time performance for licensing submittals. SCE is re-examining our tracking mechanisms, and changes will be made to ensure that licensing actions are identified, tracked and given management visibility to facilitate timely responses. This action will be completed during the first quarter of 198 Management attention has been focused on reportability. This focus has established tighter time frames for making reportability determinations for potentially reportable situations. SCE will improve our communications with both the Resident Inspectors and the NRR Project Managers and involve them earlier in developing issues than has been the case in the past. Actions initiated by Station management late in the SALP review period to delineate timing of notification desired by the Resident Inspectors for a range of plant evolutions and events, and to heighten Station management sensitivity to early involvement of the Resident Inspectors, have already had a positive impact in this area. Responsibility for properly addressing reportability issues associated with work performed by the offsite organizations will be formally establishe SCE believes that the actions taken late in the SALP period in response to concerns related to the adequacy of technical support for SONGS directly address the deficiencies identified by the SALP report in the Engineering/

Technical Support functional area. In addition, these same corrective actions will have a positive effect on the Safety Assessment/Quality Verification functional area, and in combination with other actions which we have discussed, will result in significantly improved performance in the current evaluation period. To ensure that we continue to make adequate progress in improving performance, periodic critical assessments will be mad If you have any questions regarding the actions we are taking, please call m Very truly yours, cc: U. S. Nuclear Regulatory Commission, Document Control Desk F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3

FINAL SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION V

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-206/88-25, 361/88-26, 362/88-28 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION OCTOBER 1, 1987 THROUGH SEPTEMBER 30, 1988

SUMMARY Enforcement Items*

Functional Inspection Percent Severity Level Area Hours of Effort I II III IV V D*** Plant Operations 1802 33.14

B. Radiological 622 11.44

1 Controls Maintenance/

-

1262 23.21

Surveillance D. Emergency Pre.10 E. Security 247 4.54 F. Engineering/

584 10.74 1**

1 Technical Support G. Safety Assessment/

860 15.82

1

Quality Veri Totals 5437 100.00

15 2 2

Severity levels are discussed in 10 CFR 2, Appendix C. Two deviations (one each in areas F and G) were identified during this SALP perio **

This violation was a Category B violation concerning E *

Denotes deviations discussed in Table 2 This information is current through inspection reports 206/88-23; 361/88-24; and 362/88-2 TABLE 2 ENFORCEMENT ACTIVITY Unit 1 Inspection Severity Functional Report N Subject Level Area 88-03 Failure to make proper safety system IV A

operability determinations 88-06 Failure to post a high radiation area IV B

88-07 Failure to conduct an audit of the

V G

Emergency Preparedness program 88-10 Environmental qualification deficiencies B

F/G 88-23 Whole body exposure in excess of the IV B

quarterly limit

Applies to Units 1, 2, and Unit 2 Inspection Severity Functional Report N Subject Level Area 87-25 Failure to post a radiation area V

B 87-31 Failure to report steam generator

IV G

safety valve inoperability 88-03 Failure to document nonconforming

IV C

conditions during maintenance 88-03 Failure to comply with Technical

IV F

Specification requirement for testing main steam safety valves 88-10 Failure to report component cooling ##

IV G

water system design deficiencies 88-10 Failure to include analyses of

IV F/ adverse effects of earthquakes on the design of equipment

Table-2, Enforcement Items (Continued)

Inspection Severity Functional Report N Subject Level Area 88-10 Failure to include saltwater cooling #W IV F

valves in the in-service testing program 88-10 Deviation - Mode of operation of

F component cooling water provides no monitoring ability for the loop containing the letdown heat exchanger 88-15 Inadequate control of M&TE (two examples)

IV C/G 88-15 Deviation - Fuel pool purification piping ##

G not installed in accordance with the FSAR 88-18 Train A and B cables in direct contact with IV F

one another in a post accident panel

Applies to Units 2 and Unit 3 Inspection Severity Functional Report N Subject Level Area 87-25 Continued operation with a main feedwater IV G

isolation valve and ADS valves inoperable 88-04 Inadequate QA audit program for radioactive IV G

transportation packages 88-20 Failure to comply with procedures for IV C

temporary spent fuel pit transfer pumps 88-22 Failure to adequately control the IV C

performance of an integrated leak rate test Functional Areas A -

Plant Operations B -

Radiological Controls C -

Maintenance/Surveillance D -

Emergency Pre E -

Security F - Engineering/Technical Support G - Safety Assessment/Quality Verification L

TABLE 3A -

Unit 1 SYNOPSIS OF LICENSEE EVENT REPORTS (LERs)

Functional SALP Cause Code*

Area A

B C

E X

I Totals Plant Operations

2

B. Radiological

1 Controls C. Maintenance/

2

7 Surveillance D. Emergency Pre E. Security

F. Engineering/

1

Technical Support G. Safety Assessment/

Quality Veri Totals

1

4

18

  • Cause Code, A -

Personnel Error B - Design, Manufacturing or Installation Error C -

External Cause D -

Defective Procedures E -

Component Failure X -

Other Functional Areas A -

Plant Operations B -

Radiological Controls C - Maintenance/

Surveillance D - Emergency Pre E - Security F -

Engineering/

Technical Support G -

Safety Assessment/

Quality Veri The above data are based upon LERs 87-15 through 88-1 TABLE 3B - Unit 2 SYNOPSIS OF LICENSEE EVENT REPORTS (LERs)

Functional SALP Cause Code*

Area A

B C

D E

X Totals A. Plant Operations

3

B. Radiological

1

Controls C. Maintenance/

5

Surveillance Emergency Pre Security F. Engineering/

18

Technical Support G. Safety Assessment/

Quality Veri Totals

18

3

  • Cause Code A -

Personnel Error B - Design, Manufacturing or Installation Error C -

External Cause D -

Defective Procedures E -

Component Failure X -

Other Functional Areas A -

Plant Operations B -

Radiological Controls C -

Maintenance/

Surveillance D -

Emergency Pre E -

Security F -

Engineering/

Technical Support G -

Safety Assessment/

Quality Veri The above data are based upon LERs 87-22 through 88-2 TABLE 3C -

Unit 3 SYNOPSIS OF LICENSEE EVENT REPORTS (LERs)

Functional SALP Cause Code*

Area A

B C

  • D E

X

_---

Totals A. Plant Operations

1

B. Radiological

1 Controls C. Maintenance/

1

4 Surveillance D. Emergency Pre E. Security F. Engineering/

2

Technical Support G. Safety Assessment/

Quality Veri Totals

2

1

10

  • Cause Code A -

Personnel Error B - Design, Manufacturing or Installation Error C - External Cause D - Defective Procedures E - Component Failure X -

Other Functional Areas A -

Plant Operations B - Radiological Controls C - Maintenance/

Surveillance D - Emergency Pre E - Security F - Engineering/

Technical Support G - Safety Assessment/

Quality. Veri The above data are based upon LERs 87-17 through 88-0 ATTACHMENT 1 Unit 1 Licensee Event Reports (LERs)

The Analysis Branch of the Office for Analysis and Evaluation of Operational Data (AEOD) reviewed 17 LERs issued by Southern California Edison, not including revisions, for Unit 1 during the assessment period from October 1, 1987 through September 30, 1988. The review included LERs numbered as follows: - 87-015 to 88-013 The LER review followed the general instructions and procedures of NUREG-1022. The specific review criteria and the findings were as follows:

1. Significant Operating Events The following four occurrences were determined to be potentially significant by the AEOD screening process:

-

LER 87-15, concerning single failures of engineered safety features systems pertaining to decay heat removal, main steam line break mitigation, and steam generator overfil LER 87-16, involving failure of four air operated valves to function due to solenoid valve failures, rendering independent trains in multiple systems inoperabl LER 88-01, referring to environmental qualification program deficiencie LER 88-09, regarding electrically loading both emergency diesel generators in excess of the Technical Specification maximum allowable kilowatt loadin. Causes Root causes associated with the 17 events included:

-

Three personnel errors

-

Four procedural/administrative errors

-

Four design/installation/fabrication

-

Six undetermined These events evaluated did not appear to involve related occurrences, and no causes were found to be prominent. However, on two occasions (LERs 87-17 and 87-18) voluntary entry into Technical Specification 3.0.3 occurre Attachment 1 (Continued) LER Quality The LERs reviewed adequately described all the major aspects of the events, including component or system failures that contributed to the event and corrective actions taken or planned to prevent recurrence. The reports were reasonably complete, well written and easy to understand. Root causes were identified, as appropriate, and previous similar occurrences were properly referenced in the LER However, many LERs indicated the root cause was unknown pending further investigations (e.g., LERs 87-16, 87-17, 88-04, 88-06, 88-08, and 88-09). Updated LERs were then to be issued at the conclusions of the investigations. As of the date of this evaluation performed by AEOD, none of the supplemental reports were received by the NR Units 2 and 3 1. LER Review San Onofre submitted about 34 reports and four updates for Unit 2 and about eight reports for Unit 3 during this assessment period. Unit 2 promised updates for LERs 87-02, 87-24, 88-05, 07, 08, 09, 11, 13, and 17 which have not been received. Unit 3 has one outstanding update, 88-02. Our review included the following LER numbers:

Unit 2, 87-18 to 87-31 and 88-01 to 88-20; Unit 3, 87-17 and 88-01 to 88-0 One LER was classified as significant, 88-17 for Unit 2 concerning the siphoning of the spent fuel poo The causes were the following:

-

Six personnel errors for Unit 2 and two for Unit 3

-

Four maintenance errors for Unit 2 and none for Unit 3

-

Six design/installation errors for Unit 2 and none for Unit 3

-

Eight procedural/administrative errors for Unit 2 and four for Unit 3

-

Six causes unknown for Unit 2 and one for Unit 3

-

Four equipment failures for Unit 2 and one for Unit 3 The majority of the LERs were concerned with actuations of the toxic gas isolation system, fuel handling building isolation system, control room isolation system, and the containment isolation syste These problems were recurring and have been for a long tim Because of this, the arguments for the causes given were not persuasiv That is to say, the root cause for these spurious problems was probably not know The LERs adequately described the major aspects of the events, including component or system failures that contributed to the event and the corrective actions taken or planned to prevent recurrenc The reports were well written. Updated LERs provided new information, denoting the portion of the report that was revised by a vertical line in the right hand margi Attachment 1 (Continued)

2. Preliminary Notifications (PNs)

The Region wrote a number of PNs during this period concerning the two plants. No LER could be found for three of these which may have been reportabl PNO-V-88-022 Reactor Shutdown Caused by Increased Steam Generator for Unit 2 Tube Lea PNO-V-8-002 Reactor shutdown Commenced for More Than 48 Hours for Unit 3 Due to Alarms on the Main Generator Hydrogen Detraining Uni PNO-V-88-047 Cavitation of the Shutdown Cooling Pump Occurred for Unit 3 During Drain Down of the Reactor Vesse.

10 CFR 50.72 Reports A review of reports made pursuant to 10 CFR 50.72 identified no reporting deficiencie GENERAL PURPOSE FINANCIAL STATEMENTS Combined Balance Sheet -

All Fund Types and Account Group Combined Statement of Revenues, Expenditures and Changes in Fund Balances -

All Governmental Fund Type Combined Statement of Revenues, Expenditures and Changes in Fund Balances -

Budget and Actual Governmental Fund Type Combined Statement of Revenues, Expenses and Changes in Retained Earnings -

All Proprietary Fund Type Combined Statement of Changes in Financial Position -

All Proprietary Fund Type Notes to Financial Statement GENERAL PURPOSE FINANCIAL STATEMENTS

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SPECIAL REVENUE FUNDS Special Revenue Funds are used to account for specific revenues that are legally restricted to expenditure for particular purpose SPECIAL REVENUE FUNDS

Library Fund -

To account for the operations of the City and Riverside County Public Library Syste Traffic Safety Fund -

To account for the financial transactions as prescribed by State of California statute on California Vehicle Code Fine Special Gas Tax Fund -

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To account for Federal grants received from the Depart ment of Housing and Urban Development (HUD). The grants are used for the development of a viable urban community by providing decent housing, a suitable living environment, and expanding economic opportunities, principally for persons of low and moderate incom Redevelopment Agency Fund -

To account for the portion of Redevelopment tax increment monies which California Redevelopment Law requires to be set aside for the development of low and moderate income housin Air Quality Improvement Fund - To account for qualified air pollution reduction programs funded by South Coast Air Quality Management Distric Citrus Grove Management Fund -

To account for the maintenance and operations of citrus groves purchased to preserve the citrus industry in the City's greenbelt area. Additional citrus groves will be purchased as revenues from operations become availabl DEBT SERVICE FUNDS Debt Service Funds are used to account for the accumulation of resources and payment of general long-term debt obligations of the City and related entitie Debt Service Fund -

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To accumulate monies for the payment of interest, principal and trustee fees on certificates of participation issued by the Corporation. Debt service is financed via lease payments from the Cit Riverside Redevelopment Agency Tax Allocation Bond Fund - To accumulate monies for the payment of interest and principal on tax allocation bonds sold by the Agency. Debt service is financed via property tax increment revenue ~~~o m m m-

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CAPITAL PROJECTS FUNDS Capital Projects Funds -

are used to account for the acquisition and construction of major capital facilities other than those financed by proprietary fund Capital Outlay Fund -

To account for the construction and installation of street and highway capital improvements in the City, including improvements funded by the 1/2% sales tax approved by Riverside County voters in 198 Special Capital Improvements Fund - To account for the acquisition, construction and installation of capital improvements and Community Facilities Districts within the Cit Storm Drain Fund -

To account for the acquisition, construction and installation of storm drains in the Cit Parking Facilities Replacement Fund -

To account for the acquisition, construction and installation of replacement parking facilities in the City from funds received in the sale of land assigned to City of Riverside Parking Authorit Transportation Fund - To account for the construction and installation of street and highway improvements in accordance with Articles 3,8, and 6.5 of the Transportation Development Act of 1971 of the State of Californi Riverside Municipal Improvements Corporation Fund -

To account for the capital acquisitions from the proceeds of the sale of certificates of participation on behalf of the Corporatio Redevelopment Agency Fund -

To account for the acquisition, relocation, demolition and sale of land for those portions of the City designated in need of redevelopment related activitie M m

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ENTERPRISE FUNDS Enterprise Funds are used to account for operations that are financed and operated in a manner similar to private business enterprises. The intent of the City is to determine that the costs of providing services to the general public on a continuing basis are financed or recovered primarily through user charges or that the periodic determination of net income is appropriate for accountability purpose ENTERPRISE FUNDS

Electric Fund -

To account for the operations of the City's electric utility which renders services on a user charge basis to residents and businesse Water Fund -

To account for the operations of the City's water utility which renders services on a user charge basis to residents and businesse Airport Fund - To account for the operations of the City's airport and the Riverside Airport Lease Company debt service account Refuse Fund -

To account for the operations of the City's solid waste and sanitation program which provides for the collection and disposal of solid waste on a user charge basis to residents and businesse Sewer Fund -

To account for the operations of the City's sewer system which renders services on a user charge basis to residents and businesse Transportation Fund - To account for the operations of the City's Senior Citizens Transportation System in accordance with Article 4 of the Transportation Development Act of 1971 (SB 325) of the State of Californi Urban Mass Transportation Act Funds are also accounted for in this fun o m-

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INTERNAL SERVICE FUNDS Internal Service Funds are used to account for the financing of goods and services provided by one City department to other City departments on a cost-reimbursement basi INTERNAL SERVICE FUNDS

Workers' Compensation Fund -

To account for the operations of the City's self-insured workers'

compensation progra Unemployment Compensation Fund -

To account for the operations of the City's self-insured unemployment compensation progra Public Liability Fund -

To account for the operations of the City's self-insured liability progra Central Stores Fund -

To account for the operations of the City's centralized supplies inventory, including receiving and delivery services provided to City department Central Garage Fund -

To account for the maintenance and repair of all city-owned vehicles and motorized equipment, except for Police and Fire vehicle m-e--m-9ammage AGENCY FUNDS Agency Funds are used to account for assets held by the City in a fiduciary capacity for individuals, private organizations, or other governmental units. The Agency Funds are custodial in nature and do not involve measurement of results of operation Deferred Compensation Fund -

Established in accordance with Internal Revenue Code Section 457 and is offered to eligible employee Special Deposits Fund -

To account for deposits held by ihe City as trustee for specific project Act Improvement Fund -

To account for neighborhood Assessment District collection Payroll Clearing Fund -

To account for payroll related activitie ABC Cities Trust Fund -

To account for Power Agency of California funds for the cities of Azusa, Banning and Colto mmmlm-mmma m9a-nmma-n-m

ACCOUNT GROUPS GENERAL FIXED ASSETS The General Fixed Assets Account Group is used to account for the cost of fixed assets that are used in the performance of general government functions and that are not accounted for in the Enterprise or Internal Service Funds of the Cit GENERAL LONG-TERM OBLIGATIONS The General Long-Term Obligations Account Group is used to account for the unmatured long-term indebtedness of the City and the City's Redevelopment Agenc ~m4F m

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STATISTICAL SECTION Statistical Information is included to provide detailed data on applicable physical, economic, and social characteristics..The information will provide a broader and more complete understanding of the City and its financial affair STATISTICAL SECTION

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