ML20133A821

Informs That Regional SALP Review Board Meeting Scheduled to Convene at Region V Ofc on 850807.Assessment Will Cover Dec 1983 - May 1985.Listed Individuals Will Prepare Performance Analysis.Review Guidance Package Encl

ML20133A821
Person / Time
Site:	Rancho Seco
Issue date:	07/19/1985
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Chaffee A, Crews J, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8508050567
Download: ML20133A821 (23)

Text

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! g NUCLEAR REGULATORY COMMISSION

; y REGION V

% g 1450 MARIA LANE, SUITE 210

% ,d WALNUT CREEK, CALIFORN!A 94596 JUL 191985 MEMORANDUM FOR: _J '. Crews , 'RV

A. Chaffee, RV g (p - 31%

L. Miller, RV C. Myers, RV J. Eckhardt, RV G. Perez, RV R. Scarano, RV' G. Lainas, AD/0R, NRR S. Miner, Project Manager, NRR L. Norderhaug, RV M. Cillis, RV R. Fish, RV P. Qualls, RV FROM: D. Kirsch, Acting Director Division of Reactor Safety and Projects, RV

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

FOR RANCHO SECO (Period December 1, 1983 through May 31, 1985)

References:

(1) NRC Manual Chapter 0516 (2) Proposed changes to the SALP process, J. M. Taylor Memorandum dated June 27, 1985 (3) Region V Instruction 0701 (4) SALP Board Schedule, J. B. Martin Memorandum dated July 18, 1985 l

Pursuant to references (1), (2), (3) and (4) above, the regional SALP Review Board meeting for Rancho Seco is scheduled to convene at the Region V Walnut Creek office on August 7, 1985, at 8:30 a.m. The board members will consist of the above addressees and myself who will serve as chairperson.

1 I This assessment will cover the 18 month period from December 1, 1983, through May 31, 1985. Since this period ends during completion of a refueling outage, the evaluation period will be updated to include recent events through July, 1985.

Members of the Rancho Seco SALP Board are herewith provided a review guidance package to be used in preparing performance analyses of the various functional areas. This package consists of the following:

Description of functional areas (Attachment 1)

Evaluation criteria (Attachment 2)

Attributes for the evaluation criteria (Attachment 3)

Performance categories (Attachment 4)

SALP evaluation matrix (Attachment 5)

Sample SALP functional area performance analysis (Attachment 6)

Supporting Data and Summaries (Attachment 7) 7 8508050567 850719 , II PDR ADOCK 05000312 G ,

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Memo on SALP 50-312 2 The'following is the anticipated outline of the Rancho Seco SALP report, along with the individuals assigned lead responsibility for preparing input for each section.

I Introduction Myers II Criteria Myers III Summary of Results Myers IV Performance Analysis

1. Plant Operations Eckhardt

2. Radiological Controls Cillis

3. Maintenance Eckhardt

4. Surveillance Eckhardt

5. Fire Protection Qualls

6. Emergency Preparedness Fish

7. Security and Safeguards Norderhaug

8. Refueling Eckhardt

9. Quality Programs and Administrative Controls Affecting Safety Eckhardt

10. Licensing Activities Minor

11. Eng;ineering & Construction Crews /Echkardt

12. Training Eckhardt V Supporting Data and Summar*Ms Myers (Including tables)

Eachpersonassignedleadresponsibilityforafuncti$nalareashallprepare a performance analysis and submit it to C. J. Myers by C.O.B. July 26, 1985.

Each performance analysis shall be prepared as follows: ,

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1. Assess the licensee's performance in the functional area based upon inspections performed, available ^ data and observations of the licensee's performance during the SALP period. Obt'ain~ inputs from others who had inspection responsibilities in the functional area.

In assessing the licensee's performance, use the guidance in Attachment I through 4. -

2. Prepare a performance analysis for the functional area following the format of Attachment 6. If possible, discuss the trend'of the licensee's performance since the previous SALP period. The analysis should reference pertinent data, enforcement items or events, when appropriate, but should be principally a quantitative analysis of the licensee's performance in the area (depending upon the level of activity, approximately one to one and one-half page in length when single space typed).

3. Include recommendations for licensee actions related to the functional area.

4. Provide a copy of the SALP evaluation matrix (Attachment 5),

assigning a performance category for each evaluation criterion.

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IMemo on SALP 50-312 '3 ,

By copy of this memorandum, the Director, Office of Investigaticas, San Francisco Field Office, is requested to provide a summary of major

-investigative activities and results-involving Rancho Seco by July 26, 1985.

In addition.Iby-copy of'this memorandum .the offices of NMSS and AEOD are requested tolprovide performance analyses by July 26, 1985 (or updated earlier submittals to address the extended SALP period).

k D. F. Kir ch SALP Board Chairman.

Acting Director, Division of Reactor Safety and Projects

Enclosures:

As Stated . . .3 cc: 'J. Davis, NMSS '

• R. Seyfrit,'AEOD - "

O. Shackleton, OI/SFF0 ',

.J. Carter, NRR I

/ j F. Wenslawski, RV ,

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Functional Areas. ,

a. Operating Phase Reactors

1. Plant Operations Consists chiefly of the activities of the licensee's operationalstaff(e.g.,licensedoperators, shift technical advisors, and auxiliary operators). It is  !

intended to be limited to operating activities such as i plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as reading and logging plant conditions; responding to

^ off-normal conditions; manipulating the reactor and auxiliary controls; and training / retraining of licensed operators, shift technical advisors, and auxiliary operators. .

2. Radiolooical Controls Includes controls for occupational radiation protection; radioactive materials and contamination controls; radiological surveys and monitoring; processing of gas-eous, liquid, and solid wastes; transportation of radioactive materials; radiological effluent and environmental monitoring; and the results of the fiRC's independent measurement program.

3. liaintenance Includes all activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.

4. Surveillance Includes all surveillance testing activities as well as -

all inservice inspection and testing activities. '

Examples of activities included are: instrument cali-brations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.

5. Fire Protection Includes routine housekeeping and fire protection /

prevention program activities. Thus, it includes the storage of combustible material; fire brigade staffing and training; fire 50ppression system maintanence and operation; and those fire protection features provided for structures, systems, and components important.to safe shutdown.

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6. Emergency Preparedness -

Includei' activities relating to the implementation of the emergency plan and implementing procedures. Thus, it includes such activities as licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implemen-tation; notification; communications; facilities and equipment; staffing; training;' assessment; emergency ,

classification; medical treatment; radiological exposure

. control; recovery; protective actions; and interfaces  ;

with onsite and offsite emergency response organizations.

7. Security Includes all activities whose purpose is to ensure the security and continued operability of the plant.

Specifically it includes all aspects of the licensee's security program (e.g. access control, security checks, badging).

8. Refueling Includes all activities associated with refueling.

Thus, it includes outage management, and the manipu-lation of new and spent fuel.

9. Quality Procrams and Administrative Controls Affectino -

Quality Includes all verification and oversight activities which affect or assure the quality of plant activities, structures, systems and components. This area may be viewed as a comprehensive management system for con-trolling the quality of work performed as well as the quality of verification activities that confirm that

- the work was performed correctly. The evaluation of ,

the effectiveness of the quality assurance system  :

should be based on the results of management actions to ensure that necessary people, procedures, facilities and materials are provided and used during the opera-tion of the nuclear power plant. Principal emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation of the quality assurance program along with evaluating the history of licensee performance in the key areas of: comittee activities, design and procurement control. control of desion change processes, inspections, audits, corrective action systems, and records.

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Includes the . adequacy; and ~ timeliness of all'. licensing submittals, responsiveness to NRC licedsing' initiatives, and the' licensee's approach to'resolutionfof' technical ~ issues from

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11. Engineering and Construction _;< ,

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Includes all design'and' installation activities associated with plant modifications including design changes and reviews.

12. Training-Includes the following facility training categories:

Non-licensed operators Control room operators .

Senior control room operators / shift supervisors-Shift Technical advisors Instrument and. control technicians Electrical maintenance personnel Mechanical maintenance personnel Radiological protection technicians Chemistry technicians Onsite technical staff and managers Attachment 1 Page 3

045 Evaluation Criteria. Elements'which must be considered when assessing a licensee's performance in a functional ares.

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a. The evaluation criteria are as follows:

, 1. Management involvement in assuring quality .

2. Approach to resolution of technic'al issues from safety standpoint . .

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3. Responsiveness to NRC initiatives

4. Enforcement history . -

5.

Reporting and analysis of _ reportable events

6. Staffing (including management) ,

7. Training effectiveness and qualification

b. Guidance for us+ng these criteria to arrive at a category assignment is found in the Appendix to this Chapter.

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ATTACIDfDJT 2 l e

EVALUATION ClllTEltIA WITil ATThll3UTES FOR ASSESSMLHT OF LICENSEE PEhFORMANCE 1.

MAN AGEMENT INVOLVEMENT AND CONTROL IN ASSURING QtfALITY Category 1 Caterory 2 Category 3 consistent evidence of prior plan- evidence of prior planning ning and assignment of priorities; littic evidence of prior planning and assignment of prioritiest and assignment of priorities; well stated, controUed and explicit stated, defined procedures poorly stated or ill understood procedures for control of activities for control of activities procedures for control of activities well stated, disseminated and under- adequately stated and under-standable policies poorly stated, poorly understood stood policies or non-existent policies decision making consistently at a decision making usuauy at a decision making seldom at a level level that ensures adequate level that ensures adequate management review that ensures adequate management management review review corporate management frequently corporate management usuaUy corporate r.anagement seldom involved in site activities involved in site activities involved in site activities audits complete, timely and thorough audits generally complete, audits frequently not timely, and thorough incomplete or not thorough committecs properly staffed and committees usuauy properly functioning.in abnost au cases committees not properly staffed staffed and functioning or functioning -

reviews timely, thorough and reviews generally timely, reviews not timely, thorough or technically sound thorough and technically sound technicauy sound records complete, weU maintained records generaUy complete, weu records not complete, not weu nnd available maintained and avcDable

• rr.aintained or unavaUable procedures and policies strictly procedures and policies rarely procedures and poUcies ocea-adhered to violated sionauy violated corrective action systems promptly corrective action systems corrective action systen s rarely and consistently recognize and generally recognize and recognize and address non-address non reportable concerns address non reportable concerns reportable concerns procurement weu controued and procurement generally weU documented repetitive breakdown in procure-controUed and documented ment control design weU controUed and verified rare breakdowns of minor repetitive breakdown in designs significance in design control control or verification or verification

2. APPROACl! TO RESOLUTION OF TECllNICAL ISSUES FROM A SAFETY STANDPolNT Category 1 Category 2 Category 3 .

glear understanding of issues understanding of issues understanding of issues demonstrated generally apparent frequently lacking conservatism routinely exhibited conservatism generauy exhibited sneets minimum requirements when potential for safety significance exists technicauy sound and thorough viable and generally sound and of ten viable approaches, but approaches in almost all cases thorough approaches lacking in thoroughness or g

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timely resolutions in almost all generally timely resolutions resolutions often delayed cases

3. RESPONSIVENESS TO NRC INITIATIVES Category 1 Category 2 Cat eged meets deadlines generally timely responses frequently requires ester.sions of tune timely resolution of issues few longstanding regulatory longstandst regulatory issues issues attr6t'utatele to licennet altributable to hetnSee ATTAC1LMEFT 3 Page 1

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. teclinically sound and thorough viable and generally sound and of ten viable rssp:nses, but lacking in tht> roughness of responses in almost all cases thorough responses dcpth acceptable resolutions proposed acceptable resolutions generally considerable NRC effort nr initially in most cases proposed repeated submittals needed to obtain acceptable resolutions

4. ENFORCEMENT HISTORY Category 1 Category 2 Category 3 major violations are rare and are major violations are rare and may multiple major violations or

. not indicative of programmatic indicate minor programmatic programmatic breakdown breakdown breakdown indicated minor violations are not repetitive multiple minor violations or minor violations are repetitive and not indicative of programmatic minor programmatic breakdawn and indicative of programmatic breakdown indicated breakdown corrective action is prompt and corrective action is timely corrective action is delayed effective and effective in most cases or not effective

5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS Category 1 -

Categoryj Category 3 events promptly and ccmpletely events are reported in a timely event reperting is frequently late reported

• manner, some information may or incomplete be lacking events are properly identified events are accurately identified, events are poorly identified or and analyzed . some analyses are marginal analyses are mangmal, events are associated with programmatic weaknesses corrective action is effective corrective action is usuaUy corrective action is not timely as indicated oy lack of repetition taken but may not be effective nor effective, events are as indicated by occasional repetitive repetition

6. STAFFING (INCLUDING MANAGEMENT)

Caterosy 1 Category 2 Category 3 positions are identified, authorities key positions are identified, positions are poorly identified, and responsibilities are weu defined and authorities and responsi* or authorities and responsibil.

bilities are defined ities are (U defined vacant key positions are filled key positions ususUy filled key positions are left vacant on priority basis in a reasonable time for extended periods of time staffing is ample as indicated by staffing is adequate, staffing is weak or minimal ns control over backlog and overtime occasional ddficulties with indicated by eacessive backlog backlog or overtime and overtime

7. TRAINING AND QUALIFICATION EFFECTIVENESS Category 1 Category 2 Category 3 training and qualification program training and hualification training and quahfication makes a positive contribulton, program conttsbutes to an program is found to be the commensurate with procedures adequate understanding of major contributmg factor to and staffing, to understanding work and fair adherence poor understanding of work, of work and adherence to procedures to procedures with a modest as indicated by numerous proce-with few personnel errors number of personnel errors dure violations or personnel errors training program is weU defined a defined program is program may be either lacking.

and implemented with dedicated implemented for a large portion poorly defined, or ineffectively resources and a means for feed of the staff appbed for a signdicant segment back esperience; program is applied of the staff to nearly su staff ATTACletENT 3 e

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4 Criteria for Use in Evaluating Training Asetional Area Catenarv 1 Category 2 Category 3 management frequently involved in management occasionally involved management seldom involved in review of training activities in review of training activities review of training activities acceptable resolution to NRC train- acceptable resolution generally , considerable NRC effort needed ing initiatives proposed initially proposed to obtain acceptable resolutions in most cases few significant events have occurred occasional significant events have frequent significant events have that are indicative of a training occurred that are indicative of a occurred that are indicative of a deficiency training deficiency training deficiency

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Attachment 3  :

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Performance Cateoories.' ~ % rating of licensee perforsynce in a given functional area.

, s. Cateoory 1 Reduced 'NRC attention say be appropriate. Licensee management attentierr and . involvement are aggressiv' e and oriented toward

. nuclear safety; licenset resources are ample and effectivsly J used so that a high level.of perfo'rmance with respect to operational safety or construction is being achieved. , .,

b. Catenory 2 , ,

NRC attention should be maintained at normal levels. Lican-see management attention and involvement are evident and are concerned with nuclear safety; licensee resou'rces are ade-quate and reasonably effective so that satisfactory perform-ance with respect to operational safety or construction is being achieved. .

c. ' Category 3

• Both NRC and licensee attention should be increased. Licen-see management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licen-see resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieved.

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Sample Performanca Analysis

4. Surveillance The surveillance program has been inspected on a monthly basis by '

the resident inspectors throughout this SALP period. (See also Section IV.5, Fire Protection).

During this SALP period the licensee asked the NRC for, and received, Technical Specifications changes to delay surveillances because of outage delays. Bowever, good planning and scheduling techniques and stronger usangement control could have precluded the need for some of these changes. Even though specific surveillance tests were covered in certain Technical Specifications changes, there have been a ausber of licensee event reports (LERs) written on missed surveillances.

In general, there was a decline in the licensee's performance in this area. partially in response to NRC criticism of this area, the licassee has instituted a daily asnagement meeting in which the status of surveillances is discussed. The effectiveness of this meeting in eliminating missed surveillances is yet to be

determined by the inspectors.

I An item of noncompliance issued during this SALP period dealt with j

the failure to meet surveillance and technical specification requirements on parse valve leakage. The licensee did not respond l in a timely usaner to the failure of the surveillance because of an apparent lack of awareness of Technical Specifications by the engineer in charge of the work. This illustrates the fact that there any not be proper sensitivity at all levels in the organization on issues important to safety or, as *the inspectors i have stated in past inspection reports, there may be a ceamunications problem between people within the operating organisations. The 12R synopsis (Table 5) La this SALP report indicates that a ausber of reports have been issued which are surveillance related. Ceemusications related problems contributed

• to a number of these IIRs. ,

Conclusion

. performance assessment - Category 3. This represents a decline in perforssace from the Category 2 assigned during the previous SALP cycle. . #

Board Receamendation Increased awareness of and attention to related Technical Specifications requirements should be demonstrated by persons involved la scheduling, performing, and reviewing surveillance activities.

ATTACIMENT 6 L

4 V DRAFT ,

SUPPORTING DATA FOR' RANCHO SECO'SALP (12/1/83 - 5/31/85)

OPERATION ACTIVITIES LICENSEE EVENT REPORTS (LERs)

SYNOPSIS OF LERs ENFORCEMENT ITEMS INSPECTION AND ENFORCEMENT

SUMMARY

ATTACHMENT 7 i

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OPERATION ACTIVITIES During the first three months of the SALP period the plant operated within the range of approximately sixty to ninety percent power except for two automatic reactor trips. The first trip occurred on December 3, 1983 while troubleshooting the "A" inverter power supply. The second reactor trip occurred on February 29, 1984, when the "A" reactor coolant pump tripped off line in coincidence with a power oscillation on the power grid, and the plant was not able to respond and automatically tripped.

On March 19, 1984 while the plant was operating at ninety-two percent power a leak of the main generator cooling medium, hydrogen gas, developed into an explosive mixture in the space between the main generator and the high pressure turbine. A major explosion and subsequent fire occurred. The fire was extinguished by the carbon dioxide fire protection system within fourteen minutes. The operators manually tripped the turbine and reactor. The incident was declared an unusual event.

The licensee brought the plant back to power on April 15, 1984, after completion of repair and maintenance activities. The plant operated at approximately ninety percent power from April 25 through June 1, with exception of a seven day period where the power was reduced to fifty percent to repair a condenser tube leak. On June 1, the reactor experienced an automatic trip due to feedwater overspeed. The plant returned to power and operated at ninety-two percent through July 3, until the plant was manually shutdown for the first of three steam generator tube leak repairs. The plant remained in cold shutdown until August 12 while a licensee investigation of piping fittings was performed. The plant was brought back to power u 11 August 31whentheplantwasagainmanuallyshutdownduetothesecon[d"B" steam generator tube Icak. The plant started back to power on October 7, but was shutdown for a "A" steam generator tube leak. The plant returned to power operation on October 11 and had to be shutdown on October 13 to investigate a hot spot on the main generator lead box. Repairs were made and the plant was on line on October 19. The plant remained in operation until the end of December although power was reduced due to feedwater heater leaks. A six day outage occurred to repair the known leak in the feedwater heater system and ended on January 6, 1985 when the plant went critical. The plant remained on line at various power icvels until March 15, 1985, when the licensee began the Cycle seven refueling outage.

ATTACl! MENT 7 Page 1

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RANCHO SECO Licensee Event Reports Table (12/01/83 - 05/31/85)

LER TITLE SALP AREA /CAUSE CODE

• 83-38 DHR PUMP B SUCTION VALVE FROM 4/E BWST FAILED TO OPEN 83-39 OPERABLE PRESSURIZER LEVEL 4/A D CHANNELS BELOW MINIMUM TECli. 9/D SPEC.

83-40 INCORRECTLY SIZED AUXILIARY 9/B FEED FLOW ORIFICES 11/B 83-41 COOLING WATER FOUND ISOLATED 1/D FROM AUX. FEED PUMP TURBINE 4/D BEARINGS 83-37-01 REACTOR BUILDING EMERCENCY 4/D Followup SUMP VALVE FAILED TO OPEN DURING SURVEILLANCE TEST 84-01 EXHAUST FAN BEARING FAILURE 2/E 84-02 SUBMITTAL OF ISI RESULTS REPORT TO NRC LATE 9/A,C 84-03 PROCEDURE WRITTEN IN CONTRADICTION TO 4/D TECH. SPECS.

84-05 EMERGENCY SIREN MALFUNCTION 6/E 84-06 FIRE BRIGADE. TRAINING 5/X 9/X 84-04 METEOROLOGICAL TOWER POWER FAILURE 6/E 84-07 REACTOR TRIP 1/E 84-08 FAILURE OF ION CllROMATOCRAPH .

2/B.E 84-09 LIFTING SLING FAILURE , 3/D 4

,9/D 84-10 FAILURE TO COMPLETE SURVEILLANCE PROCEDURE 9/D i

84-12 MISSED STACK SAMPLE ,

2/A 84-11 INCORRECT CONFIGURATION TABLE IN' -

4/D SURVEILLANCE PROCEDURE 84-13 SECURED !!IGli RADIATION AREA DOORS OPEN 2/A l

• Cause Codes identified in LER Synopsis Table.

Attachment 7 Page 2

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LER TITLE SALP FUNCTIONAL AREA CAUSE CODE 84-14 SURVEILLANCE PROCEURE SP 205.02 ' 4/D,A 84-15 RELATED INCIDENTS TO HYDROCEN EXPLOSION 1/E 3/D 84-16 CONTAINMENT ISOLATION VALVE STROKE TIME 4/D IN EXCESS OF TECH. SPEC. LIMIT- .

84-17 CORE FLOOD TANK VENT VALVE ,

1/D 83-0301 TESTING OF MASTER REACTOR TRIP RELAY 4/D Follow-up 84-18 PLANT TRIP i 1/E 84-19 AMBIENT STARTUP OF DIESEL CENERATOR 4/D 84-20 TUBE LEAK OF REACTOR TRIP 1/E 2/E 84-18-01 PLANT TRIP - FOLLOW-UP 1/E 84-21 FAILURE OF SURVEILLANCE PROCEDURE TO SATISFY 4/D i TECH SPECS 83-40-01 AUXILIARY FEEDWATER FLOW ORIFICES Revision 84-22 TUBE LEAK 1/E 84-24 SIf.0LTANEOUS PLANT llEATUP AND DEB 0 RATION 1/A 84-25 FEACTOR TRIP 1/E 84-23 F1.TER TESTING 4/D 84-22-01 TUBE L"* 2/E Supplement 84-23-01 FILTER TESTING 4/A Follow-up 9/A 85-01 LOSS OF CONTAINMENT INTEGRITY VIA OPEN 2/A VALVES 9/D 85-02 UNRESTRAINED HEAVY LOAD IN REACTOR BUILDING 3/A 85-03 INCORRECT BORON CONCENTRATION TECll 1/C SPEC LIMIT 9/C 85-04 FIRE DAMPERS NOT INSTALLED 5/B Attachment 7 Pago 3

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SYNOPSIS OF LICENSEE EVENT REPORTS **

Functional SALP Cause Code

• Area A B, C, D E, X Totals

1. Plant Operations 1 0 1 2 7 0 11

-2. Radiation Protection 3 1 0 0' 4 0 8

3. Maintenance 1 0 0 2 0 0 3

4. Surveillance 3 0 0 10 2 0 15

5. Fire Protection 0 1 0 0 0 1 2 ,

6. Emergency Preparedness 0 0 0 0 2 0 2

7. Safeguards 0 0 0 0 0 0 0 t' . Refueling 0 0 0 0 0 0 0

9. Quality Programs and 2 1 2 4 0 1 10 Administrative Controlu Affecting Safety ,

10. Licensing 0 0 0 0 0 0 0-

11. Engineering and 0 1 0 0 0 0 1 .

4 Construction

12. Training 0 0 0 0 0 0 0 TOTALS 10 4 3 18 .15 2 52

• Cause Codes:

A-Personnel Error B-Design. Manufacturing or Installation Error , ,

C-External Cause

.D-Defective Procedures

'E-Component Failure ~ .

1 X-Other ,

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• • l .m Synopsis includes LER Nos. 83-38 through 85-04 *

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i NOTE: Several LER's categorized in multiple. areas of cause codes _--- l

! follow-up LER's which do not. identify additional areas or causes

( were not double accounted along'with the original LER during'this '

period.

Attachment 7 !

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Table Rancho Seco Enforcement Items (12/01/83 - 05/31/85)

Inspection Report No. '< Subject , . Severity Level Functional Area 83-34 Failure of PRC to review temporary '1V 9 change to emergency dicac1 generator operating procedure.

Failure of PRC to review a IV 9 temporary change to an incore instrument. surveillance proceu(y@.

Inadequate control of abnormal tags. V 9 83-36 Failure to follow revised pro-cedure for hydrogen monitor and purge system.

Continued operation without IV 1 minimum required operable pressurizer level instruments.

84-02 PRC did not evaluato Technical Specification violations IV 9 (2 examplen)

PRC did not review Abnormal Tags IV 9 Inadequate PRC membership V 9 PRC failed to review V 9 proceduto changes Failure to document PRC V 9 determination of procedure review Failure to document PRC V 9 datormination as to unreviewed safety questions MSRC did not review QA audit IV 9 reports Tardy responses to QA audit IV 9 findings Use of out-of-date equipment IV 9 classification documents by Hafntenance and Procuromont Attachment 7 Page 6 u_

Inspection Severity Functional Report No. Subj ect Level Area

_85-02 No training programs for IV 12 (continued) Maintenance or Procurement personnel 84-07 Failure to maintain up-to-date V 9 i revisions of surveillance procedures in the Control Room 84-09 Nuclear instrument calibrations were IV 1 not performed as required.

l 84-11 Emergency Preparedness training IV 12 not given after reassignment.

Inadequate data and procedures for IV 6 meteorological program.

84-13 Insufficient records relating to 9 storage and protection of Class IE motor control centers.

! A contractor QC inspector wss not 11 listed as an authorized inspector.

84-14 Welding filler material was not V 3 adequately controlled by, Tool Room.

Written quizzes were not administered '"

- V 12 during requalification training. ,

84-15 Designcalculationsfor'theauxiktary 4 IV 11 feedwater flow orificies plates were not adequately reviewed and approved.

84-19 Improper control of combustible daterials. V ,

5 Improper setting of code safety valve. IV, , 3 84-22 Expanded Fire Brigade Training Deviation 5 had not been performed. ,

A Senior Control Room Operator had not IV 5 been trained in his designated role as ftre brigade leader.

Improper control of combustible IV 5 materials.

Annual training with the Herald IV 5 Fire Department was not held.

Attachment 7 Page 7

Inspection Severity Functional Report No. Subj ect Level Area t

85-25 Inadequate radiological survey of radioactive fragment removed from steam generator.

Inadequate placement of personnel monitoring devices.

Inadequate records of surveya of radioactive fragment.

Improper reporting of unusual radiation levels.

Inadequate posting of source of radiation.

Improper use of radiological work permit (RWP).

Inadequate airborne radioactivity III 2 survey. (collectively)

MSRC audits of facility staff IV 9 qualifications did not extend below the level of supervisory personnel.

84-29 A Licensed Senior Operator was not Deviation 12 present during licensed operator instruction.

85-01 Inadequate design verification and Deviation 11 i field change procedures.

Four NSEB HVAC seismic supports did IV 11 not conform to drawings but had been. ,

inspected and accepted by QC..

s 85-02 Inaccurate welder recertification V 9 records.

Incomplete welding filler material IV 9 control records. (repeat) 85-03 Air particulate and charcoal filter IV 2 saspies were not taken and analyzed on u regular weekly schedule.

85-08 Inadequate battery testing procedures. IV 4

. Incomplete updating of drawingo '

'V 9 associated with NCR dispositions.

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Attachment 7 Page 8 I <

s-- t TABI.E INSPECTION ACTIVITIES AND ENFORCEMENT SIMMARY -(12/01/83 '-- 05/31/85)

,. RANCHO SEC0 Inspections conducted " Enforcement Items Inspection

• Percent Severity Level **

Functional Area Nours of Effort I II 111 IV V Dev.

1. Plant Operations 3671 '57 2

2. Radiological Controls 544 9 1 1

3. Maintenance 270 4 1 1

.4. Surveillance 108 2 1

,. 5. Fire Protection 72 1 3 1 1

6. Emergency Preparedness 398 6 1

7. Security and Safeguards 404 6

8. Refueling 81 1 1)9. Quality Programs and 378 6 9 8 Administrative Controls

10. ticensing 0 0 11". Engineering & Construction 336 5 2 1 12.' Training 212 , ,3 2 1 1 Total *

• Allocations of inspection hours vs. functional areas are approximations based upon inspection report data, and include onsite and inoffice inspection effort.

• • Severity levels are in accordance with NRC Enforcement Policy (10 CFR Part 2, Appendix C).

Data reflects Reports 83-32 through 85-12 ,

Attachment 7 Page 9

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