ML20140A683

Forwards Final Rept of Davis-Besse Study Group Review of Performance History of Plant.Two Areas Showing No Evidence of Improvement Include Procedure Violations & Control of Doors W/Multiple Functions

ML20140A683
Person / Time
Site:	Davis Besse
Issue date:	03/14/1986
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8603210095
Download: ML20140A683 (47)

Text

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SUlR 141SSG MEMORANDUM FOR: Charles E. Norelius, Director, Division of Reactor Projects THRU: Carl J. Paperiello, Director, Division of Reactor Safety FROM: Luis A. Reyes, Chief, Operations Branch, Division of Reactor Safety

SUBJECT:

DAVIS-BESSE STUDY GROUP REPORT

Reference:

1. Memo dated July 5,1985, C. E. Norelius to J. G. Keppler

2. Memo dated June 21, 1985, C. E. Norelius to J. G. Keppler As stated in references "1" and "2" above, the Davis-Besse Study Group conducted a broad review of the history of Davis-Besse. The Study Group conducted its review using LER and inspection history, status of TMI items, and a historical review of management and enforcement meetings. In addition to the attached report, the Study Group actively supported the responses to Representative E. J. Markey.

As a result of this review, the Study Group identified areas where there was no evidence of improvement. These areas include (1) procedure violations and (2) the control of doors with multiple functions such as fire and ventilation boundaries. These areas should be reviewed by the inspection staff during the upcoming startup activities to assure that the licensee has taken effective corrective action in these areas.

During the review of LERs, the Study Group identified deficiencies regarding maintenance and housekeeping activities. The Study Group did not pursue these findings because this area is the subject of review by the Division of Human Factors Safety as part of the Safety Evaluation Report to be issued prior to the unit startup, and significant improvement in housekeeping was observed subsequent to the June 9, 1985, event.

The most significant finding of the Study Group is the fact that there were multiple equipment failures during five different reactor trips in the last six years. Although the corrective action for each event and equipment failure appears to be adequate, the historical performance raises questions about the licensee's overall programs and the lack of NRC historical review subsequent to similar events. The Study Group reconnends that current inspection procedures for event followup (93700 series) be revised to include guidance regarding a review of other reactor trips with multiple equipment failures.

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Charles E. Norelius 2 The attached report covers the remaining activities covered under references "1" and "2" above and is considered the last activity of this group.

i ORIGINAL SIGNED BY LUIS A. REYES Luis A. Reyes, Chief Operations Branch ,

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Attachment:

As stated 1

cc w/ attachment:

J. Gleason,'ASLBP

, J. G. Keppler A. B. Davis J. A. Hind

, C. J. Paperiello T. N. Tambling B. L. Burgess P. M. Byron, SRI, Davis-Besse 1

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4 STUDY GROUP REVIEW 0F PERFORMANCE HISTORY FOR DAVIS-BESSE NUCLEAR POWER STATION FINAL REPORT Study Group Members:

1 L. A. Reyes 1 T. N. Tambling l B. L. Burgess

, D. L. Williams i

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TABLE OF CONTENTS Section Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . I Introduction and Methodology . . . . . . . ........... II ,

Observations and Findings. . . . . . . . . ........... III Attachment A - Chronological Listing of Procedure Violations Attachment B - Total number of LERs by System Attachment C - Selected LER Listing by System Attachment D - Selected Deviation Reports Attachment E - Status of TMI Items Attachment F - Summary of Violations Attachment G - Summary of Inspector Man Hours Attachment H - Regulatory Performance History Attachment I - Summary of Procedural Violations t

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I. Executive Summary Subsequent to the Davis-Besse June 9, 1985 event, Region III established a study group to review the performance history of Davis-Besse. The study group conducted a review of Licensee Event Reports, Deviation Reports (DVRs), and Enforcement History. Upon completion of the review the study group concluded that:

A. Multiple equipment failures were experienced during five reactor trips that occurred during the period of review. (See Section III.D.)

8. Prior to the June 9, 1985, event the licensee had not successfully identified the root causes and provided lasting corrective action for many component failures / malfunctions.

C. Poor housekeeping has been identified on many occasions as the cause for safety-related equipment malfunctions. Significant improvement was observed subsequent to the June 9, 1985, event. (See Section III.B.1.)

D. Many instances of inadequate maintenance activities have resulted in safety-related equipment being degraded or inoperable. (See Section III.B.2.)

E. Numerous procedure violations were identified throughout the review period with no indications of improvement. (See Section III.E.)

F. Plant regulatory performance has historically been poor (numerous Level IV and V violations and several escalated enforcement cases in the last year).

G. A decrease in overall SALP rating occurred subsequent to SALP 3.

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II. Introduction and Methodology The Study Group conducted a review of the Davis-Besse Nuclear Power Plant Licensee Event Reports (LERs) beginning with TMI restart activities in 1979 until the present (Attachment C). Due to the revised threshold for LER reportability instituted in January of 1984, the LERs for 1984 and 1985 are not detailed in the review but a listing of the more significant events is included in Attachment C.

A review of licensee Deviation Reports (DVRs) for calendar years 1984 and 1985 was also conducted. The purpose of the review was to evaluate potential trends and determine if these trends could have identified the probability of the events of June 9, 1985, and to determine if any other problems surfaced which are not already being addressed by the licensee or the NRC.

In addition, the enforcement history of the Davis-Besse Nuclear, Plant was reviewed starting in 1979 and continuing through August 1985. The review consisted of an examination of violations and performance history and an analysis of any trends found. Details of the review are delineated in Attachments F, H, and I. The analysis is based on a breakdown of violations into the categories of (A) Procedural Violations, (B) Technical Specification violations, and (C) miscellaneous violations. These categories were selected to give the reviewer a different perspective than that gained utilizing the more conventional methodology of the Systematic Assessment of Licensee Performance (SALP) process. However, a breakdown of violations into SALP Categories is provided in Attachment F.

To provide-the reader with a perspective of the number of man-hours spent per calendar year, Attachment G was devised and comparisons can be made ,

between Attachments F and G to draw conclusions as to the number of violations vs. man-hours.

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III. Observations and Findings A. The licensee has demonstrated inadequate investigation and corrective actions for some system component failures. These are:

1. Repetitive failure of valve CC1467 Component Cooling Water Heat exchanger outlet to operate correctly. The licensee adjusted the torque switch setting, initiated a design change to the actuator linkage and subsequently discovered that a flanged bearing had not been installed for several years or as early as

- initial installation. Failure to install the flanged bearing was determined to be the root cause for the failures experienced. See LERs 79-98,79-125, 81-23 and 82-64 (Attachment C).

2. Repetitive failure of source range nuclear instrument NI-1.

. Following each failure the licensee would declare the instrument operable after successfully completing surveillance procedures. Subsequent investigation revealed a weak preamplifier signal and ultimately the containment penetration associated with NI-1 was replaced. Problems with NI-1 have i continued to reoccur and were present during the June 9, 1985 event. This finding is addressed by the licensee in the Course of Action (C.O.A.) Plans 15A and 158. See LERs 79-78, 79-92, 80-54, 80-59 and 82-35 (Attachment C).

3. Continuous problems with the latching mechanism for the personnel air lock. The licensee is currently evaluating possible resolutions recommended by the vendor and proposed under Facility Change Request (FCR) 85-0178. These changes are scheduled to be implemented during the next refueling outage.

See LERs 80-73, 81-67 and 83-39 and DVRs81-181, 83-087 and 85-009 (Attachments C and D).

4. Continuing problems with fire and ventilation boundary doors closing / latching mechanisms. As of the time of this review, the licensee does not appear to have resolved these problems.

See LERs 81-07, 81-42, 82-03, 82-16, 82-31, 82-43, 82-57, 83-06, 83-21, 85-14 and DVRs84-044, 85-087,85-095 and 85-116 (Attachments C and D).

5. Recent recurrent problems maintaining nitrogen pressure in electrical containment penetrations. The licensee is developing a corrective action at this time and has proposed a facility change request to install a bank of nitrogen bottles to resolve this problem. See DVRs84-102, 84-108,84-109, 84-112,84-115, 84-121,85-068 and 85-090 (Attachment D).

6. Repetitive failure of Auxiliary Steam supply valve MS106 to open. Originally identified in LER 79-02, ten months later the l licensee finally discovered that the valve actuator had been l

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assembled incorrectly. This is part of the licensee's C.O.A. l action plan 27. See LERs 79-73 and 79-112 (Attachment C). I I

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B. The licensee's housekeeping and maintenance program appears inadequate as demonstrated by the following examples of equipment problems directly attributable to the presence of dirt, improper lubrication or inadequate assembly during maintenance.

1. The failure of several Containment Isolation valves to operate successfully due to inadequate housekeeping. See LERs 80-02, 80-14, 80-42, 81-20, 82-27, 83-20, 83-44, 83-60, 84-14, 85-04 and DVRs84-018, 84-059,85-037, 85-052, and 85-126 (Attachments C and D). Significant improvement was observed in this area subsequent to the June 9, 1985, event.

2. The following LERs indicate as their cause code inadequate maintenance or inadequate maintenance procedures. These actions or lack of actions rendered the following equipment inoperable. Auxiliary Feedwater (6 times), Diesel Generator (2 times), Emergency Ventilation (2 times), Fire Protection (2 times). See LERs 79-71, 80-03, 80-94, 81-40, 83-10 and 83-57 for Auxiliary Feedwater (AFW);79-128 and 79-129 for Emergency Ventilation; 83-22 and 83-27 for Diesel Generator; 82-56 and 83-46 for Fire Protection (Attachment C).

C. The licensee has experienced a continuing problem ~with motor-operated valves' torque switch settings. At least 11 LERs are attributed to incorrect torque switch settings. Many of these LERs have multiple valves listed. Several valve failures that occurred during the June 9, 1985 event were due to incorrect torque switch settings.

See LERs 79-83, 79-90,79-112, 80-14, 80-24, 83-09, 83-20, 83-27, 83-44, 83-60,84-003, and DVRs84-058, 84-060 and 85-118 (Attachments C and D).

D. During the review of licensee DVRs, 11 incidents of personnel failing to follow the lifted leads and jumper procedure were identified. The incidents involved failure to notify operations personnel, improper tagging of lifted leads, and jumpers left installed in systems. See DVRs83-131, 84-049,84-074, 84-086,84-152, 84-153,84-157, 84-160,85-005, 85-035 and 85-079 (Attachment D).

A comprehensive independent review of LERs prior to 1984 would havo raised concerns for the adequacy of the licensee's programs. It appears that the possibility for multiple failures of components during the June 9, 1985 event could have been foreseen. Some LERs indicate that multiple component failures had already occurred when systems were called upon to function. -See the following LERs:

LER 79-96 Reactor trip, loss of offsite power due to failure of ,

generator output breaker, failure of Component Cooling j Water (CCW) and Service Water (SW) pumps to start, and ;

inability to restart a Reactor Coolant Pump (RCP) due )

to defective couch relay.

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LER 81-37 Reactor trip, loss of instrument power due to abnormal lineup, AFW pump did not respond properly, and Main Steam Safety Valve (MSSV) SP1784 failed to reseat and loss of more than one saturation meter due to wiring diagram error.

LER 84-03 MSIV closure, reactor trip, one MSSV failed to open (SP17A1), one MSSV failed to reseat (SP17A4), failure of AF599 to open (Auxiliary Feedwater supply to SG).

LER 85-02 Integrated Control System (ICS) controlling steam generator levels erratically, reactor trip, AFW Train No. I transferred suction to service water, attempts to restore proper lineup isolated an AFW pump and caused short-term cavitation of pump.

LER 85-11 High turbine vibration, reactor trip, main feedwater pumps trip, AFW pump 1 did not respond properly.

E. During the LER/DVR review, over 300 procedure violations have been identified. This appears to be a significant number of violations.

The areas that indicate the most concerns are:

1. Technical specification violations due to inoperable equipment (31 incidents); failure to complete surveillances (65 incidents)

(Attachment A).

2. Control of valves; 22 incidents identifying valves mispositioned, seven incidents for valves position not reflected in locked valve log and six incidents for valves not properly locked into position (Attachment A).

3. Control of equipment; seven incidents of improper removal of equipment from service and ten incidents of failure to follow jumpers and lifted leads procedure (Attachment A).

4. Fire protection, 19. incidents of fire doors open, 31 incidents of improperly sealed fire barrier penetrations, eight incidents of inadequate fire watch, and 13 incidents of equipment inoperable (Attachment A).

The review was unable to attach significance to the number of procedure violations, but the examples listed above indicate more attention by the licensee is needed. The procedure violations did not show a significant decreasing trend, and this area should be addressed by the licensee's staff.

F. Approximately 233 violations were issued at Davis-Besse during the period 1979 through 1985. This number does not include the proposed violations under consideration for the June 9, 1985 event, but does include the nine violations proposed for the escalated enforcement package under consideration in the fire protection area. Of the 233 4

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violations, 46 were issued for failure to follow procedures and nine violations for inadequate procedures. The majority of these violations are clustered in the areas of Operations, Maintenance, and Quality Assurance. The root cause was identified by both Region III and the licensee as inadequate management controls and training. Of particular concern were the repetitive violations issued for failure of the Site Review Board (SRB) to review procedures and the licensee's inability to maintain controlled drawings and procedures. (See Attachment I.A. Report Nos. 7914, 7919, 8008, 8301, 8401, 8412, 8429, 8501).

Thirty-seven violations of Technical Specifications (T.S.) were issued excluding T.S. 6.8.1 (failure to follow procedure) which is discussed above. The type of repetitive violations identified in the above paragraph are again highlighted here. The Site Review Board and the Corporate Nuclear Review Board were repeatedly cited for failure to review violations and procedures (See Attachment I.B.

Report Nos. 7928, 8103, 8225, 8409, 8501.) The remainder of the violations fall into the areas of Operations, Maintenance, Surveillance, and Fire Protection and do not indicate any unusual or previously unidentified trends.

Thirty-seven violations of 12 of the 18 Appendix B criteria were identified (excluding Criterion V) and were broken down as follows:

• Criterion XVI - Corrective Action - 9 violations

• Criterion III - Design Control - 4 violations

• Criterion VI - Document Control - 4 violations

• Criterion XVII - Quality Assurance Records - 4 violations

• Criterion XII - Control of Measuring and Test Equipment -

3 violations

• Criterion XIII - Handling and Storage - 3 violations

• Criterien II - Quality Assurance Program - 2 violations

• Criterion X - Inspection --2 violations

• Criterion XI - Test Control - 2 violations

• Criterion XV - Nonconforming Materials, Parts and Components -

2 violations

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• Criterion XIV - Inspection, Test, and Operating Status -

1 violation

• Criterion XVIII - Audit - 1 violation

• See Attachment I.B.

Although the issuance of only one violation in an area might not indicate a problem, the repetitive violations issued for Criteria III, VI, XVI, and XVII indicate a lack of adequate management controls and inability to identify root causes and/or effectively implement adequate corrective actions.

Seventy-four violations were included in the miscellaneous section of Attachment I. The majority of these violations (51) are security violations, of which 44 were identified in the 1979 to 1982 time frame. Recent inspections in the security area have shown improvement in licensee performance and this improvement is indicated in Attachment 3.

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! The remainder of the violations can be clustered in the areas of fire protection, failure to report noncompliances, and license violations. These violations do not indicate any unusual trends with the exception of the failure to report noncompliances, which,

, in hindsight can be said to indicate an underlying communication

problem.

Based on a review of the violations and enforcement and management meetings, the review did not' identify trends in licensee performance that were not previously identified by the inspection program. The number and repetitive nature of procedural violations as well as continued lack of adequate management controls and adequate j corrective action are key elements in the inability of the licensee 3

to turn around their regulatory performance. (Recent corrective action addressing these problem areas has been taken by the licensee.) However, the number of management and enforcement meetings, as well as the continue concentrated inspection effort by the Region, was ineffective in providing lasting improved licensee l performance. Although almost every tool with respect to regulatory J

actions was taken in an attempt to turn around licensee performance, the final result was only marginal improvement in some areas with no improvement noted in others. (See SALPs 2-4 Attachment F.)

G. A decrease in overall SALP rating occurred subsequent to SALP 3.

i The issues identified in the SALP 4 report indicated a further i decline in licensee performance and resulted in increased NRC attention. Several management meetings resulted in the licensee implementing an extensive and comprehensive corrective action i program entitled the Performance Enhancement Program (PEP).

Subsequent to the June 9, 1985 event the licensee determined that full implementation of the PEP was not cost effective and instituted

the Course of Action regulatory improvement program. Region III

dedicated inspectors and management to overview COA activities and j results of inspections completed to date have indicated an improved overall performance.

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ATTACHMENT A l

PROCEDURE VIOLATIONS IDENTIFIED VIA LER/DVR REVIEW i

YEAR I

ll 79 l 80 l 81 1 82 l 83 l 84 I 851 l Total ll l l l l 1 1 I Technical Specification violations ll l l l l l l l due to ll l l l l l l l

1. equipment ll 0 l 4l 5l 7l 7l 6l 2 l 31 i

2. surveillance ll 8 l 17 l 15 l 6l 5 l 11 l 3 l 65 ll l l l l l l l Control of valves ll l l l l l l l

1. mispositioned ll 1 l 1l 3l 4*l 1*l 7*l 5* l 22

2. log book not reflective of ll 1 l 0l 0l 3l 1l 0l 2 l 7 actual position ll l l l l l l l

3. improperly locked ll 0 l 1l 1l 2l 0l 1l 1 l 6

4. miscellaneous (procedures, ll 1 l 2l 0l 01 0l 1l 0 l 4 drawings ll l l l l l l l ll l l l l l l l

• 82 - not fully shut (1); ll l l l l l l l 4

83 - uncapped, mislabeled (1); ll l l l l l l l 84 - uncapped, open (2); ll l l l l l l l l uncapped (1); ll l l l l l l l 85 - uncapped (5), gagged (2) ll l l l l l l l Control of equipment ll l l l l l l l

1. improper removal of equipment ll 0l 1l 2l 0l 2l 1l 1 l 7

from service ll l l l l l l l l 2. failure to follow jumper and ll 0l 1l 0l 0l 2l 6l 1 l 10 i

lifted wire procedure ll l l l l l l l ll l l l l l l l 4

Fire protection ll l l l l l l l t

1. open fire doors ll 0l 0l 1l 6l 7l 4l 1 l 19

2. improper fire seals ll 0l 1l 4 l 10 l 5 l 11 l 0 l 31 (penetrations) ll l l l l l l l

3. inadequate fire watch ll 0l 0l 11 4l 1l 1l 1 l 8

4. equipment inoperable ll 1l 0l 1l 2l 2l 5l 2 l 13

ll l l l l l l l l Non-detailed procedure violations ll 19 l 6 l 18 l 16 l 15 l 14 l 10 l 98 ll l l l l l l 1 1

ll l l l l l l l Total procedure violations ll 31 l 34 l 51 l 60 l 48 l 68 l 29 l 321 ll l l l l l l l 1

as of September 1985 ll l l l l l l l l

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N I ATTACHMENT B TOTAL NUMBER OF LERs BY SYSTEM YEAR Grand System ll 79*l 80 1 81 l 82 l 83 lTotall 84 l 85 l Total l~ ll l l l l l l l l Fire Protection ll 3l 7l 7l 6 l 12 1 35 l 6l l 41 Cooling / Ventilation ll 41 3l 7 l 13 l 7l 34 l 4l l 38

Aux Feedwater ll 6l 6l 4l 5l 8l 31 l 21 4l 37 i

Containment Isolation ll 0 l 13 l 6l 2l 8l 29 l 2l 2l 33 Radiation Monitors ll 7l 1l 7l 8l 5l 28 l 0l 2l 30 Control Rods / Indication ll 8l 8l 5l 1l 4l 26 l 0l 1l 27 l- Decay Heat ll 3l 7l 5l 3l 4l 22 l 0l 0l 22 SFRCS ll 6l 4l 2l 4l 4l 20 l 1l 0l 21 Nuclear Instruments ll 3l 5l 0l 3l 2l 13 l 1l 0l 14 120V AC Essential ll 2l 4l 11 2l 4l 13 l 1l 0l 14 Diesel Generators ll 1l 4l 3l 11 3l 12 l 0l 0l 12

! MSIV/MSSV ll 0l 2l 3l 11 2l 8l 2l 0l 10 l BWST ll 0l 4l 2l 1l 1l 8l 01 01 8 Snubber / Hangers ll 2l 4l 0l 1l 1l 8l 0l 0l 8 SFAS ll 2l 5l 2l 1l 1l 11 l 0l 1l 12

RPS ll 2l 3l 51 0l 1l 11 l 0l 0l 11 BAAT ll 1l 1l 0l 1l 1l 3l 0l 0l 3 Spent Fuel Pool Level ll 0l 1l 0l 1l 1l 3l 0l 0l 3

RCS ll 3l 3l 7l 2l 3l 18 l 1l 1l 20

! HPI ll 2l 1l 2l 2l 1l 8l 1l 0l 9 l CS ll 1l 1l 0l 1l 0l 3l 0l 0l 3 CFT ll 1l 1l 0l 1l 0l 3l 0l 0l 3 CCW/SW/MU ll 2l 2l 1l 4l 0l 9l 1l 0l 10 4

480/4160/offsite ll 1l 2l 5l 1l 1l 10 l 01 0l 10 OPT /APSR ll 01 0l 2l 1l 3l 6l 1l 0l 7 i

Incore ll 1l 0l 0l 1l 0l 2l 0l 0l 2 Other ll 2l 2l 5l 1l 2l 12 l 1l 1l 14 ll 65 l 94 l 81 l 68 l 78 l 391 l l l I

• Beginning with 1979 Restart activities after TMI Order was lifted.

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ATTACHMENT C SELECTED LERs LISTING BY SYSTEM FIRE PROTECTION LER REVIEW Event l Cause l LER ll Date l Code l Number ll Description l l ll 31/22/79 l D l 79-115 ll Computer failure, failed to conduct fire watch I l ll tours 12/10/79 l X l 79-127 ll System 7 Contact Data logger failure 12/29/79 l X l 79-134 ll System 7 Contact Data logger failure 01/12/80 l A l 80-06 ll Fire damper inoperable - material interference 01/16/80 l D l 80-08 ll Penetration not sealed, procedure not clear 03/13/80 l E l 80-21 ll Diesel fire pump would stop, start 03/30/80 l E l 80-26 ll Fire detector DS 8656 failed twice, cleaned contacts 07/09/80 l X l 80-55 ll Fire damper HA 5441 inoperable, cause undetermined 08/23/80 l E l 80-63 ll Fire damper HA 5442 blown fuse 08/28/80 l E l 80-70 ll Diesel firepump inoperable, multiple problems 03/16/81 l A l 81-22 ll Penetrations unsealed, 2 events 08/07/81 l A l 81-46 ll 5 penetrations not sealed 10/18/81 l A l 81-65 ll Fire watch not established after turnover 10/24/81 l D l 81-68 ll Penetration not sealed, procedure 11/05/81 l A l 81-72 ll 3 penetrations unsealed 12/02/81 l B l 81-77 ll Conduit pull boxes not sealed

12/03/81 l A l 81-78 ll Fire door 308B propped open 05/30/82 l A l 82-26 ll Fire door 504 propped open 3 times 08/08/82 l A l 82-36 ll Penetration not sealed 08/29/82 l E l 82-43 ll Fire door 428C latching mechanism not working 09/17/82 l A l 82-48 ll Perso.1nel left fire watch station 11/04/82 l E l 82-56 ll Jocky fire pump seized 11/16/82 i B l 82-61 ll Doors 509 and 512 had improper UL rating labels 01/26/83 l E l 83-06 ll Door 311 would not latch 04/29/83 l E l 83-25 ll Fire zone detector failure, containment 06/14/83 l A 183-30* ll Floor plugs removed in Auxiliary Building 06/20/83 l Y l 83-33 ll Fire detector failure, containment 07/27/83 l B l 83-41 ll 3 fire dampers wouldn't work, original construction 08/01/83 l A l 83-42 ll 3 fire doors open, 601, 602, 101A 08/30/83 l 8 l 83-46 ll 15 fire dampers inoperable 10/06/83 l A l 83-55 ll 2 fire doors found open, 203 and 108 10/21/83 l C* l 83-58 ll Penetration not sealed 11/10/83 l B l 83-63 ll Separation criteria "Bechtel did not verify l l ll as-built conditions" 11/24/83 l A l 83-67 ll Failure to post fire watch 11/30/83 l B l 83-69 ll Attachments could degrade fire doors 4

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COOLING / VENTILATION LER REVIEW Event l Cause l LER ll Date l Code l Number l Description l l l.

08/06/79 l 8 l 79-84 ll Response time of containment air coolers 07/25/79 l B l 79-86 ll CRVS compressor motor failure 12/10/79 l E l 79-128 ll Charcoal beds not torqued down 12/11/79 l E l 79-129 ll Charcoal beds not torqued down 06/08/80 l D l 80-47 ll Doors blocked open 08/29/80 l A l 80-66 ll Doors open, 9 times 10/13/80 l B l 80-77 ll C.R. ventilation did not close in T.S. time 01/22/81 l E l 81-07 ll Door 306 latch not working 02/18/81 l E l 81-13 ll Blown fuse in chlorine detector caused dampers l l ll to close, heat tracing and fuse size 02/27/81 l A l 81-15 ll Door 107 propped open 07/24/81 l E l 81-42 ll Door 302 latch not working 09/25/81 l E l 81-55 ll Door 108 found open, twice l 09/15/81 l D l 81-57 ll ECCS room coolers out of service at same time *

! 11/30/81 l B l 81-76 ll Door 306 open twiceclosure not adequate 01/08/82 l 8 l 82-03 ll Door 400 failure of latch 01/12/82 l A l 82-04 ll Door 108 open 02/08/82 l E l 82-08 ll AP transmitter vent line frozen 02/09/82 l D l 82-09 ll Door 107 open twice 03/11/82 l A l 82-14 ll Door 101A open i 03/12/82 l A l 82-15 ll C.R. ventilation not in recirc. when CL 2 l l ll detector failed 03/12/82 l E l 82-16 ll Door 108 latching mechanism 05/12/82 l A l 82-22 ll Door 302 open

, 06/25/82 l B l 82-31 ll Doors 500, 302 and 426 door, closing mechanism 08/16/82 l l 82-37 ll Door 306 seal damaged X

10/21/82 l A l 82-54 ll Door 107 open 11/05/82 l A l 82-57 ll Door 400 open, closing mechanism 12/01/82 l A l 82-65 ll CRVS not in recirc. when CL2 out of service 03/03/83 l D l 83-12 ll 1 of 2 ECCS room coolers inoperable 03/04/83 l E l 83-13 ll Plugged orifice CL 2detector actuated all l I ll control room HVAC 05/02/83 l E l 83-21 ll Door 406 closing mechanism 06/14/83 l A l 83-30* ll Floor plugs in Auxiliary Building (fire) 07/06/83 l E I 83-35 ll Door 306 open 09/05/83 l E l 83-49 ll Door 306 broken j 11/17/83 l B l 83-65 ll Conduit not properly supported i

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AUXILIARY FEEDWATER LER REVIEW Event l Cause l LER ll Date l Code l Number ll Description l I ll 07/04/79 l E l 79-71 ll Valve AF 3870 motor failure, maintenance, I l ll component 07/08/79 l B l 79-73 ll Valve MS106 torque settings 07/07/79 l B l 79-74 ll Pressure switch (CST to SW) had wrong diaphram l l ll and microswitch setting 07/05/79 l E l 79-77 ll MS106 relay sockets, inadequate contact '

08/27/79 l A l 79-90 ll MS107 seat wear, corrosion, torque setting 09/25/79 l X l 79-95 ll MS 106 control fuse-fault l l ll M5106A R2 relay-socket replaced twice 10/22/79 l X* l 79-102 ll AFW pump 1-1 loss of lube oil, loose sight glass 11/19/79 l B l 79-112 ll MS106 failed to open, appears torque setting l I ll changed, subsequent investigation 3 weeks later l l ll it was discovered spacers installed upside down 01/03/80 l E* l 80-03 ll AF Pump 1-1 clutch misadjusted 03/27/80 l E l 80-24 ll MS107 closed randomly, changed torque setting l l ll low suction switchover added 2 sec. delay 04/11/80 l E l 80-34 ll Pressure switch PSL-1068, vendor found microswitch l l ll mounting screws loose 11/28/80 l E l 80-84 ll PSL-1070 microswitch stem worn-replaced 12/19/80 l E l 80-92 ll Couch relay R1, replaced 12/26/80 l D l 80-94 ll AFWP 1-2 bad outboard bearings, lack of lubrication 06/04/81 1 E l 81-32* ll AF599 failure activation circuits, relay driver I l ll board 06/24/81 l A* l 81-37* ll AFP 1-2 governor 07/22/81 l D* l 81-40 ll AFWP 1-2 speed element not adjusted 07/30/81 l E l 81-45 ll AFWP 1-2 governor 03/23/82 l A l 82-17 ll AFWP 1-1, 1-2, FW 786 and 790 suction isolation l l ll in wrong position (appear to have been locked) 04/19/82 l B l 82-19 ll AFW header in SG damaged 07/04/82 l A l 82-32 ll AFP 1-2, SW6 supply in wrong position 09/04/82 l X l 82-45 ll FW 786 closing / closed, no cause determined 12/13/82 l B l 82-66 ll AFW Pump 1-1 terminal board not mounted seismically l l ll (Aux. shutdown panel) 02/07/83 l E* l 83-10 ll MS106A stem dirty, lubricated, PM 02/11/83 l A l 83-11 ll Personnel bumped trip throttle valve to trip 04/07/83 l E l 83-16* ll LT-SP9A3 amplifier - AFWP 1-2 could not control l l ll SG 1evel in auto-essential 05/24/83 l E l 83-26* ll Failed input buffer in SFRCS would have prevented l l ll AFWP flow to SG No. 2 06/28/83 l B*  ! 83-32 ll Personnel turned off power supply for AFW flow l l ll indication to SG No. 1 07/25/83 l 8 l 83-40 ll AFWP 1-1 clutch, adjustment attempted, had to l l ll install new style clutch 10/15/83 l E l 83-57 ll AFP 1-2 started then tripped, trip linkage l l ll sticky, happened during feedwater transient 11/03/83 l D l 83-59 ll AFP 1-2, MS107A control power fuse, no cause l l ll determined C-3

CONTAINMENT ISOLATION LER REVIEW Event l Cause l LER ll Date l Code l Number ll Description I l ll 01/03/80 l E l 80-02 ll Valve DW6831B limit switch - LER unclear if l l ll valve actually closed or LLRT tested after l l ll maintenance 02/08/80 l D* l 80-14 ll 2 events RC2408 - 1) torque switch setting wrong l l ll 2) stripped screw-replaced torque switch

02/13/80 1 0 l 80-16 ll Failure to do T.S. surveillance after containment l l ll entry 03/06/80 l A l 80-20 ll Valve CV 5072 breaker open personnel bumped 03/17/80 l E l 80-22 ll Valve CV 5010E had power removed - breaker open 05/10/80 l E l 80-42 ll 4 valves exceeded leakage MU 242, MU 243, MU 244, l l ll MU 245 valve seats lapped 08/12/80 l D l 80-61 ll SV 5005 installed in 1076, not qualified 10/02/80 l E l 80-72 ll Valve CV 5011E failure 10/08/80 1 E l 80-73 ll Personnel airlock, inner door would not latch l l ll due to broken cam roller bearings 10/08/80 l D l 80-74 ll Personnel airlock T.S. surveillance missed 11/17/80 l 0 l 80-79 ll Inadequate testir.g containment pressure l l ll transmitters 12/06/80 l X l 80-87 ll Valve CV 5006 would not stroke, cause unknown 12/19/80 l 8 l 80-93 ll Valve DW 6831B would not meet stroke time 03/24/81 l E l 81-20 ll Valve CV 501A, handweel would not disengage 06/24/81 l 8 l 81-35 ll Valves CV 5005, 5006, 5007, 5008 design could l l ll prevent closing 07/18/81 l A l 81-39 ll Personnel airlock surveillance not completed 08/20/81 l D l 81-50 ll Failed to test check valves (CV 124, CV 125, I l ll NN 58, SA 502, IA 501) per ASME XI & T.S.

10/04/81 l D l 81-62 ll Valve SA 535 open, required for isolation 10/22/81 l E* l 81-67 ll Personnel airlock outer door did not latch shut, I l ll cam roller bearings. Inner door was opened l l ll during this event.

06/08/82 l E l 82-27 ll 8 valves failed leakage limits SA 502, SA 2010, I l ll CV 125, CF 1451, CC 14118 l B, A l ll CV5010A, CV 5005, CV 5006 l l ll 4 had dirty seats, 2 had wrong seat material l l ll (hard). 2 had limitorque adjustments.

, 08/20/82 i B l 82-39 ll Annulus T.S. pressure limit exceeded. Purge l l ll valves closed due to design problems 01/27/83 l D l 83-05 ll Personnel airlock surveillance limits and T.S.

l l ll limits different 02/07/83 l E l 83-09 ll Valve CV 5010D torque switch failure

! 04/28/83 l E l 83-20 ll Valve RC 2408, torque settings, lack of lubrication 07/26/83 l B l 83-39 ll Personnel airlock, door remained open while l

l l ll latching handwheel indicated shut. Design l l ll from vendor I

C-4 i

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Event l Cause l LER ll Date l Code l Number ll Description i I ll 08/22/83 l E l 83-44 ll 4 valves CC 14078, SA 2010, DR 2012A, CC 1411B l l ll Dirty internals, rust, dirt on seat, torn liner l l ll and torque settings 11/04/83 l E l 83-60 ll 3 valves CV 5090, CV 5071, CV 5070 l l ll Torque switch, improper maintenance, faulty l l ll control switch. 2 occurrences 11/11/83 l E l 83-64 ll Valve FV 1CS-11A loss of auto closure solenoid 12/19/83 l X l 83-73 ll Valve CV 5011E failed to close electrically, no l l ll cause determined 1

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RADIATION MONITORING LER REVIEW Event l Cause l LER ll Date l Code l Number ll Descriptio7 l l ll 07/16/79 l B l 79-80 ll RE 2005 failed 07/17/79 i B l 79-81 ll RE 5029 pump failure - bearings 07/20/79 i B l 79-82 ll RE 5030 pump failure - carbon vanes 07/22/79 i B l 79-85 ll RE 5030 pump 08/11/79 l B l 79-89 ll RE 2005 vibration causes spiking 10/17/79 l B l 70-101 ll RE 2005 low range boards; auxiliary boards 12/03/79 l D (79-119 ll RE 1878A, RE 18788 procedure allowed contaminated l l ll fluid to increase setpoint 07/09/80 l A l 80-56 ll RE 2006 procedure 05/05/81 l D l 81-28 ll Liquid releases without current surveillances I l ll complete - RE 1878A, RE 18788 i- 06/16/81 l X l 81-36 ll RE 5030 inoperable, hose loose 07/24/81 l E l 81-43 ll RE 5030 pump worn out 09/09/81 l E l 81-54 ll RE 5029 pump components worn out 09/26/81 l E l 81-59 ll RE 5030 paper tape filter torn 10/21/81 l E l 81-64 ll RE 5029, RE 5030 low flow setpoints 09/19/81 l E l 81-69 ll Several rad, monitors, blown power supply fuse 01/03/82 l 8 l 82-02 ll RE 2007 broken wire 01/26/82 l E l 82-05 ll RE 2007 failed 03/02/82 l E l 82-13 ll RE 2007 failed, 3 times '

09/20/82 l E l 82-49 ll RE 4597AB software, flow control valve 10/21/82 l E l 82-55 ll RE 2007, failed twice, replaced 11/06/82 l E l 82-58 ll RE 4597E microprocessor 11/08/82 l E l 82-59 ll RE 4597AA, RE 4597BA failed boards 12/17/82 l E l 82-67 ll RE 8447 detector failed 04/17/83 l E l 83-18 ll RE 2007 detector failed 06/03/83 l E l 83-28 ll RE 8445, RE 8447 failed, fuse 07/15/83 l X l 83-36 ll RE 2007, failed 3 times 09/25/83 l X l 83-53 ll RE 8446 de-energized - cause unknown 10/10/83 l E l 83-56 ll RE 8446 inoperable, fuse in power supply cabinet l

l C-6

CONTROL R0D MECHANISM / INDICATION LER REVIEW l

Event l Cause 1. LER ll Date l Code l Number ll Description

. I l 11

. 07/08/79 l l 79-72 ll Group 8 Rod 2 reed switch B

07/12/79 l B l 79-79 ll Group 8 Rod 4 oxide buildup reed switch 07/20/79 l B l 79-83 ll Group 5 Rod 4 reed switch 07/31/79 l B l 79-87 ll Power supply failure, Group 6 out > T.S. limit 10/14/79 l C l 79-100 ll Group 7 Rod 7 cable replaced 11/23/79 l X l 79-116 ll Group 5 Rod 11 reed switch 11/29/79 l B l 79-120 ll Rod 7-5 reed switch 11/30/79 l B l 79-121 ll R3d 8-1 position indication meter 01/07/80 l D l 80-04 ll Rod 5-11 reed switch 01/16/80 l A l 80-07 ll Missed T.S. surveillance - LER 80-04 02/08/80 l E l 80-13 ll Blown fuse Rod 5-11 02/10/80 l D l 80-15 ll Rod 5-11 reed switch 03/27/80 l E l 80-23 ll +24V OC power supply, Groups 3 and 4 stepping in 03/30/80 l D l 80-25 ll Rod 5-11 reed switch 05/14/80 l B l 80-40* ll 20 holddown springs broken 11/03/80 l X l 80-80 ll Control Rod trip breakers would nat trip l l ll breaker C (2X), breaker D (IX) 02/12/81 l E l 81-12 ll Rod 1-3, noise at containment electrical penetration 03/23/81 l E l 81-19 ll Rod 4-7, elect. penetration module 06/25/81 l E l 81-38 ll Rod 5-8, anti rotation device shattered 10/03/81 l E l 81-61 ll Rod 4-7, containment penetration 10/26/81 l E l 81-70 ll Control Rod trip breaker B failed to trip 02/25/82 l E l 82-11 ll Blown fuse transfer switch module -

I l l ll dropped Rod 5-2 09/30/83 l E l 83-54 ll Group 8 motor programmer 11/09/83 l E l 83-62 ll Group 2 and 3 programmer board and dirt 11/29/83 l E l 83-68 ll Rod 7-12 motor programmer 12/05/83 l F l 83-71 ll Rods 5-2, 7-1 and 7-9 motor power return gate SCR C-7

DECAY HEAT REMOVAL SYSTEM Event l Cause l LER ll Date l Code l Number ll Description l I ll 10/04/79 l B l 79-98 ll DH/CCW Hx outlet valve CC 1467 would not open -

l l ll slippage of control linkage 11/08/79 l E l 79-108 ll DH pump 1 cutout switch damage - breaker would l l ll not close 12/08/79 l 8 l 79-125 ll Valve CC 1467 - slippage of linkage - LER 79-98 04/18/80 l E l 80-30 ll DH 62 actuator out of calibration 04/10/80 l E l 80-35 ll Valve DH 14A mechanical interference, radial l l ll arm mounting bolts 05/28/80 l D l 80-43 ll Procedure allowed I&C to inadvertently close DH 11 l l ll valve. (No jumper called for) No flow to RCS 05/31/80 l A l 80-44 ll Personnel removed discharge pressure indication l l ll while running 07/10/80 l D l 80-57 ll Procedure allowed removal of DC power from DH 14A, I l ll resulted in exceeding T.S. limit for DH flow to RCS 07/24/80 l A, D* l 80-58 ll 3 events stopped DH flow when needed I and A l ll 08/13/80 l A l 80-60 ll Personnel failed to defeat interlock and caused l l ll loss of flow to RCS when required

, 01/07/81 l 8 l 81-04 ll DH pump 1-1 breaker would not operate. Cut off l I ll switch 02/26/81 l E* l 81-14 ll Set rod bushing installed incorrectly DH 64 03/09/81 l E l 81-17 ll DH 63 torque switch faulty 04/03/81 l X* l 81-23 ll Flanged bearing CC 1467 not installed LER 79-98, I l ll LER-125 l 81-44 ll Fuse cartridge plug-in bent - DH pump 1-2

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07/27/81 l A 02/19/82 l A l 82-10 ll DH 10 locked into wroag position verified, l l il signed off 09/09/82 l E l 82-46 ll 24V DC power supply - flow indication 11/29/82 l B l 82-64 ll CC 1467 flanged bearing not installed 01/19/83 l A l 83-04 ll Personnel failed to remove jumper - could have l l ll overpressurized system 09/06/83 l X l 83-50 ll Failed to perform T.S. surveillance 09/22/83 l A l 83-52 ll Failed to position valve DH 13A prior to mode l l ll change 12/17/83 l A l 83-72* ll Procedure failed to position valves for l l ll overpressure protection C-8

i STEAM FEEDWATER RUPTURE CONTROL SYSTEM Event l Cause l LER ll Date l Code l Number ll Description i I ll 07/05/79 l E l 79-70 ll +24V DC power supply channel 1 09/01/79 l E l 79-91 ll Optical isolator channel 3 09/17/79 l E l 79-83 ll Optical isolator channel 3 10/04/79 l E l 79-97 ll +15V DC power supply channel 4 11/09/79 l B l 79-105 ll Low level setpoints less conservative that T.S.

l l ll limits 12/12/79 i B l 79-131 ll 2 events, setpoint drift, +15V DC channel 4 l l ll power supply 01/31/80 l E l 80-11 ll +15V DC power supply channel 11 03/31/80 l E l 80-27 ll +15V DC power supply channel 04/18/80 l E l 80-37 ll GS level setpoint zero shift, 2 setpoints, 2 SG 10/08/80 l X l 80-75 ll SG 1evel setpoint zero shift channel 3 04/01/81 l E l 81-21 ll +24V DC power supply 06/04/81 l F l 81-32* ll Failed Relay driver card, SFRCS channel 2 09/16/82 l .i l 82-44 ll Personnel failed to complete T.S. surveillance 09/21/82 l E l 82-51 ll 48 V DC power supply channel 3 10/18/82 l E l 82-53 ll 24V DC power supply channel 2 11/18/8' l E l 82-60 ll 48V DC power supply channel 2 04/07/81 ' E l 83-16* ll LT SP9A3 amplifier, would not control in auto-l l ll essential 04/21/83 l E l 83-19 ll 15V DC power supply 2X channel 3 05/24/83 l E l 83-26* ll Failed input buffer, channel 2 - No AFW to SG 2 07/25/83 l E l 83-38 ll 48V DC power supply channel 2 l l ll 48V DC power supply channel 3 f

C-9

NUCLEAR INSTRUMENTC 1.ER REVIEW Event l Cause l LER ll Date l Code l Number ll Description I l ll 07/10/79 l X l 79-78 ll NI 1-1 failed twice; LER 80-59 no cause l l ll determined 09/08/79 l E l 79-92 ll NI-1 & NI-3 failed low, clean cable connector l l ll and during later outage replace NI-1 cable l l ll and NI-3 detector 12/31/79 l 0 l 79-132 ll Procedure allowed non-conservative values 01/22/80 l 8 l 80-09 ll NI-7 out of calibration 05/11/80 l E l 80-41 ll NI-2 test module failure, personnel were turning l l ll down audible count in containment 06/09/80 l A l 80-45 ll NI-2 input for audible not connected 06/27/80 l E l 80-54 ll NI-1 failed, no cause determined 07/20/80 l E l 80-59 ll NI-1 failure - discovered weak preamp signal -

l l ll LERs 79-78, 92 and 80-54, 59 03/26/82 l B* l 82-18 ll Personnel cut power cable for NI-2 05/05/82 l D* l 82-21 ll Personnel disconnected audible input during l l ll surveillance 07/19/82 l E I 82-35 ll NI-1 containment penetration module rep' aced 08/27/83 i B* l 83-45 ll NI-2 inoperable, technician shorted leads 12/20/83 l X l 83-66 ll NI-5 indication perturbations, no cause l I ll determined C-10

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120V AC ESSENTIAL POWER a

Event l ll Cause l LER Date l Code l Number ll Description l l ll 4 08/07/79 l B l 79-88 ll Fault in BAAT room heater, tripped F1 essential l l ll bus j 11/12/79 l B l 79-107 ll Power supply inverter YV2 l 80-29 ll Personnel error, B Bus tripped E2, Y1, F2, Y3 04/19/80 l X 08/23/80 l E l 80-64 ll Component failure - Y2 11/23/80 l A l 80-81 ll Loss of Y2, input fuse blown, personnel error 12/03/80 l B* I 80-86 ll Loss of Y3, input fuse, personnel error 10/18/81 l E l 81-66 ll +15V DC power supply inverter YV3, Y3 04/09/82 l A l 82-20 ll Fuse *YV2 personnel 06/08/82 l E l 82-29 ll Inverter YV2, Bus Y2, DC power supply 01/31/83 l E l 83-07 ll YV1 inverter fuse, Bus Y1, cause unknown 05/10/83 l A l 83-23 ll YV4 inverter; personnel allowed water in 11/09/83 l E I 83-61 ll Blown fuse YV2, Bus Y2, cause unknown 12/17/83 l A l 83-72* ll Short in component; personnel error Bus Y1 l

4 4

i C-11 i

.,.-------.---.A

J DIESEL GENERATOR LER REVIEW

, Event l Cause l LER ll Date l Code i Number ll Description l l ll 12/09/79 l A, E* l 79-126 ll 2 events, 1) DG1-1 Governor allowed voltage e- l l ll swings, 2) personnel racked out wrong DG 07/09/80 l B l 80-52 ll Original design of exhaust ductwork 08/26/80 l A l 80-65 ll Personnel removed DC control power 09/02/80 l B* l 80-69 ll Bolts holding idler gear for turbo charger DG1-1 l l ll loose 09/23/80 l E l 80-71 ll Oil seal failure, turbo charger fire DG1-2 01/07/80 l A l 81-01 ll Personnel removed supports for D0 on DG1-1, DG1-2

, 01/28/81 l E l 81-09 ll Air start motor broken shaft DG1-2 09/25/91 l D l 81-53 ll Personnel failed to replace tornado barriers 08/14/82 l B l 82-38 ll Bolt on DG1-1 day tank broke

^

03/05/83 l E l 83-15 ll 2 events, 1) Governor problems DG1-1, 2) output l l ll breaker would not close 05/13/83 l E l 83-22 ll Governor had screw cross threaded DG1 not l I ll tight 05/27/83 l D* l 83-27 ll 2 events, 1) DG1-1 Tripped on overspeed twice, I l ll 2) Guvernor settings, tachometer out of I l ll calibration F

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C-12 L- I

1

, MSIV, MSSV LER REVIEW i

Event l Cause l LER ll Date l Code l Numbec ll Description l l ll 08/29/80 l B l 80-67 ll Valve MS101B bypass would not open; AC coil in i I ll DC system /per design 11/11/80 l E l 80-82 ll MS100-1 would not close, packing and corrosion, I l ll mechanical binding (twice) 02/02/81 l E l 81-10 ll M5100A would not close, increased spring tension 06/01/81 l X l 81-34 ll Main steam line code safeties had low setpoints 06/24/81 l X l 81-37* ll Safety valve SP1784 bent spindle wouldn't reseat 08/21/82 l E l 82-41 ll 3 MSSV setpoints wrong; 2 due to aging, 1 personnel l l ll error 01/19/83 l X l 83-03 ll MSIV 100 failed to close after reactor trip -

l l ll no cause determined 06/12/83 l X l 83-29 ll MSSV low setpoints 13 of 15 l

r C-13

REACTOR COOLANT SYSTEM LER REVIEW Event l Cause l LER ll Date l Code l Number ll Description i I ll 10/23/79 l B l 79-103 ll No. 1 & 3 seal failure RCP 10/25/79 l B l 79-104 ll RCP 2-2 tripped, relay failure 11/22/79 l X l 79-114 ll RCS flow below T.S. limitation 04/17/80 l X l 80-28 ll TMI backfit, RCP trip at 1650 psi would remove l l ll motive force for Pzr spray 05/14/80 l 8 l 80-40* ll Hold-down springs on fuel assemblies broken *20 12/03/80 l E l 80-89 ll I limits exceeded after Rx trip 01/02/81 l E l 81-02 llSd$kfailureRCP1-2&RCP2-1 01/14/81 l 0 l 81-05 ll Chloride T.S. limits exceeded 03/08/81 l E l 81-16 ll I T.S. limits exceeded 05/21/81 l E l 81-29 llRdh12-1 seal failure 05/12/81 l E l 81-31 ll I activity level exceeded 08/05/81 l D l 81-41 llBbhbndilutions0.9^K/Kreactivityinsertion 08/14/81 l D l 81-48 ll Rx coolant flow not recorded during deboration 03/14/82 l A l 82-12 ll Inadvertent boron dilution *1803

• 1698 06/15/82 l D l 82-30 ll Improper boron sampling method changed DH pump l l ll did not compensate 01/15/83 l E l 83-02 ll I T 07/07/83 l E l 83-34 llPh$dsur.S.limitsexceeded izer amplifier module failure (level) 12/10/83 l E l 83-70 ll Chloride levels - had placed weak base resin l l ll in service 3

C-14

I 1984 LERs Event i Cause l LER ll Date l Code i Number ll Description l l ll l l ll Containment Isolation i I ll 01/19/84 i D l 84-02 11 Vent valves on transfer tube not closed or l l ll capped 09/21/84 l X l 84-14 ll 4 valves failed LLRT SA2010, CV5005, CC14118, l l ll CF1541 I I ll l l ll Auxiliary Feedwater l l 11 03/02/84 l 8 l 84-03 11 Valves AF 599 and AF 608 torque setting 06/18/84 I B I 84-09 ll Design requirements for pipe rupture of moderate l l ll energy could impact AFW suction piping l l 11 l l ll Cooling Ventilation i i 11 05/07/84 l A l 84-05 ll Switches not returned to operable position after I I ll maintenance 11/20/84 l D l 84-16 ll Failed to verify operability of EVS prior to i l ll fuel movement 12/20/84 i B l 84-21 ll Seismic design / installation problems with HVAC l l ll ductwork 12/17/84 l A l 84-22 11 CRVS flow exceeded design since 1980 l l 11 l l ll MSIV/MSSV l 1 ll 03/02/84 i B l 84-03 ll Wiring problems in MSIV logic; MSSV failed to l l ll close, another failed to open 09/11/84 l X l 84-13 ll MSSV failed to reseat - control solenoids l l ll i I ll Fire Protection l l ll 03/21/84 l B l 84-04 ll Fire doors did not meet NFPA 80 standards, l l ll U.L. labels 05/17/84 l X l 84-07 ll Diesel Fire pump right angle drive failed 08/08/84 l B l 84-11 11 Fire penetration not sealed 08/21/84 l A l 84-12 11 Penetration seal inadequate 11/23/84 l A l 84-17 ll T.S. surveillance for fire hose station exceeded l l ll time limit 12/04/84 l B l 84-20 ll Fire campers inoprable, 18, various reasons C-15

. 1985 LERs Event l Cause l LER ll Date l Code l Number ll Description l l ll l l ll Auxiliary Feedwater l l ll 01/15/85 l A l 85-02 ll Loss of AFW, suction switched to SW cause unknown 03/23/85 l B l 85-07 ll Speed bushings in AFWP 1-2, wrong one installed 06/02/85 l X l 85-11 ll AFW-1 failed to deliver design flow 06/03/85 l A l 85-12 ll AFW control room indicator wired backwards l l ll l l ll Containment Isolation l l ll 01/09/85 l D l 85-01 ll Failed to meet T.S. surveillance frequency for l l ll atmospheric vent valves 02/20/85 l A l 85-04 ll RC 229A failed LLRT on 2/7/85 discovered 2/26/85 NOTES:

• Do not agree with Cause Code assignment

• 0n LER number, used for two entries of LER review I

C-16 l

ATTACHMENT D DEVIATION REPORTS Containment Personnel Airlock 81-181 Personnel hatch lock malfunction 83-087 Inner door of CTMT airlock would not close 85-009 Containment personnel lock outer door jammed in open position Fire Door Latch Mechanism 84-004 Loose door mechanism 85-087 Door 318 latch mechanism inoperable 85-095 Door 515 latch mechanism missing 85-116 Door 500 wouldn't close against pressure Nitrogen Gas Pressure to Electrical Containment Penetrations81-024 Found water in penetration PAP 4F 84-102 Nitrogen pressure excessive penetration No. 1 84-108 Nitrogen pressure < 60 psig, both electrical penetration rooms84-109 Nitrogen pressure < 60 psig, containment penetration 84-112 Nitrogen pressure < 60 psig, containment penetrations84-115 Nitrogen pressure < 60 psig, containment penetration 84-121 Nitrogen pressure < 60 psig, containment penetrations85-068 Nitrogen pressure < 60 psig, containment penetrations85-090 Nitrogen pressure < 60 psig, containment penetrations Containment Isolation Valves / Housekeeping / Preventative Maintenance 84-018 DH 2735 valve would not close electrically 84-059 SW 1368 would not close electrically, broken wire at lug 85-052 CV 5005/CV 500G leakage greater after work 85-126 CV 5007/CV 5008, overpress.rized penetration during leak rate testing Torque Switch Problems84-058 SW 1379 valve torqued out opening 84-060 DR 2012 torque switch setting 85-118 SW 1379 torque switch setting, caused motor failure D-1 l

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DEVIATION REPORTS Lifted Leads, Jumpers and Tagging 83-131 Jumper not removed after testing ilV 107 84-049 Improper hanging of tags84-074 Work started on diesel generator without permission 84-086 Resistors replaced without using procedure 84-152 Tagging procedure not followed for MV 4 84-153 Improper lifting of wires for FW 488 and FW 450 84-157 Improper removal of tags, seismic monitors i 84-160 Improper tagging  !85-005 Switches PSL 3687L and PSL 3689K isolated without informing operations l

85-035 CRD breakers closed using jumper, no temporary modification i written to permit this action

.85-079 Jumper left installed, caused CRD breaker to open l

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ATTACHMENT E TMI STATUS DAVIS-BESSE Items still open:

II.B.1.2 Install RCS Vents Due Date: 1st refueling after July 1, 1982 (with the exception of the reactor vessel head vents)

Ready for Inspection: Yes Responsible Group: DRP Pertinent Inspection Report: None Note: Reactor vessel head vents do not have to be installed. NRR closed this item October 5, 1983.

II.B.1.3 Procedures for RCS Vents Due Date: 1st refueling after July 1, 1982 Ready for Inspection: No Responsible Group: DRP Pertinent Inspection Report: Statused in Inspection Report No. 86005.

Note: See Item II.B.1.2 II.E.1.1.2 Auxiliary Feedwater System Evaluation - Long-Term System Modifications Due Date: October 1985 Ready for Inspection: N/A Responsible Group: NRR Pertinent Inspection Reports: Nos. 79-13, 81-04, 86-05 Note: Final closeout pending T.S. amendment (NRR letter dated February 21, 1984)

II.F.2.3.8 Inadequate Core Cooling Instrument (Implement)

Due Date: Still negotiating with NRR Ready for Inspection: Yes Responsible Group: DRP Pertinent Inspection Report: No. 82-21 Note: 82-21 inspected installation of incore thermocouples and T-Sat meter. T.S. addition and review of surveillance tests and drawing changes are still to be done.

The need for a reactor vessel monitoring system is still to ,

be negotiated between NRR and licensee. j II.K.2.9 Orders on B&W Plants - FEMA on ICS '

l Due Date: Refueling outage - 1984 Ready for Inspection: No Responsible Group: DRP Pertinent Inspection Report: No. 82-21, statused in 86005.

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III.A.2 (1 item) Emergency Preparedness Due Date: July 1, 1982 Ready for Inspection: Closure contingent upon EP Appraisals to be scheduled.

Responsible Group: DRSS/EP Pertinent Inspection Report: None Note: February 27, 1984 Confirmatory Order for Supplement 1 No. of Items No. of Items -

Open Ready for Inspection DRP 5 4 DRSS/EP 1 1 Total 6 5 1

E-2

ATTACHMENT F

SUMMARY

OF VIOLATIONS SALP Functional Areas l 78 l 79 l 80 l 81 1 82 l 83 1 84 I 85 l l l l l l l l l l Plant Operations l 2 1 5 I 3 1 2 1 7 l 2 l 5 l 5 l l l 1 1 I I I I I Radiological Controls l 5 l 1 1 8 1 0 1 0 1 0 1 0 l 1 I I I I I I I I I I Maintenance i 1 l 2 l 1 l 4 1 6 l 6 l 5 I 3 l l l l l l l l l l Surveillance l 3 l 1 l 2 l 3 1 4 l 2 l 5 l 2 l l l l l 1 1 I I I Fire Protection l 2 l 4 1 2 l 1 1 6 i 9(A) 1 0(C) 1 0 l l l l 1 I I I I I Emergency Preparedness 1 0 1 0 1 0 1 0 l 0 l 0 2 l 1 l l l l l l l l l Security I 8 7 1 24 l 1 1 4 2 l 4 1 1 I I I Refueling l 0 l 0 1 0 1 0 1 0 1 0 l 0 l 0 l i I I I I I i l l Quality Programs & l I l l l l l l l Administrative Controisi 8 l 9 l 1 l 2 l 4 l 3 l 16 l 11 l 1 1 I I I I I I I Training l (B) l (B) l (B) l (B) l (B) i 2 l 1l 2 I I I I I I I l l l TOTALS l 29 l 29 l 41 l 13 1 31 1 26 1 38 l 26 I (A) Fire protection violations under consideration for possible escalated enforcement action.

(B) Not rated as a SALP functional area during this year.

(C) Following inspection conducted in June 1984 (IR 84-10); no violations were identified.

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l ATTACHMENT G INSPECTOR MAN-HOURS l 79 l 80 l 81 82 l 83 I 84 l 85* ITOTAL i i l I I I l Plant Operations l 934 l 834 1 734 I 594 l 745 11,027 l 928 15,796 l l l l l l l l l l Radiological Controls l ** l ** l 5l **i 2l 162 l 41 1 210 l l l l l l 1 I I I Maintenance l 124 l 110 l 197 l 228 l 234 l 332 1 500 l1,715 l l l l l l l l l l Surveillance l 8 89 205 180 l 168 l 212 l 238 11,100 i i l l I (est)I I Fire Protection l ** l ** **

31 1 36 ** l 72 139 l l l .

l . 1 I Emergency Preparedness ** l **

• • 1 **l 230 l 388 382 l1,000 l l l l l l l Security i ** l 34 l 58 l 41 46 l 75 1 217 I I I I I I I I I Refueling 51 l 93 l 28 1 63 l 10 l 142 l 118 l 505 I I I I I I I I l Quality Programs & I I l l l l l l l Administrative Controls l 125 l 44 l 47 55 l 120 l 143 l 271 805 l l l l l l 1 i TOTALS 11,242 11,204 l1,206 11,209 l1,549 l2,452 12,625 l11,4871

• Hours of inspection prior to June 9, 1985.

• • Indeterminate i

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ATTACHMENT H Regulatory Performance History

1. Enforcement Conference April 18, 1979 - Areas covered included enforcement history, number of personnel errors, breakdowns in management controls, equipment problems and general effectiveness of management in dealing with identified problems.

2. Management Meeting May 31, 1979 - Second in a series of management meetings. Licensee outlined a program, based upon their assessment of problem areas, to improve the level of management controls, staffing, training, the correction of equipment problems, and plant operations.

3. Management Meeting July 17, 1979 - Third in a series of meetings. Licensee reported status of their program to improve management controls.

Region III acknowledged progress made in ten areas to improve management controls and operations of Davis-Besse (staffing, procedures, management control, training, LERs, maintenance, surveillance testing, communication, Nuclear Services Group).

4. Management Meeting September 19, 1979 - Fourth in a series of management meetings. Concerns were identi-fied by the licensee relative to difficulty in filling vacancies, LERs in area of personnel errors declined in the past six months, Nuclear Services Group to handle support activities established, training position vacancies being filled.

5. Management Meeting February 29, 1980 - Licensee committed to immediate implementation of three short term actions (return of experienced and qualified equipment operators to shift, provide one additional person for day shift, expedite off-shift training, not yet fully qualified). Meet ANSI 3.1 by December 1979.

6. Management Meeting and June 4, 1984 - Sixth in a series of Enforcement Conference management meetings and enforcement

($13,000 Civil Penalty conference to discuss April 30, 1980 Issued) overexposure. Additionally, security l inspection findings discussed. Licensee l

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effort would be directed towards equipment problems, morale, training. Region III stated that problems in implementation of the security program and the overexposure seriously detracted from apparent improve-ment in other areas. Reemphasized licensee's need to identify and correct problems in security.

7. SALP 2 July 1980 November 1980 - March 1982. Identified lack

_ of aggressive corrective action before issues become regulatory issues. Weaknesses in capability to recognize design basis require-ments for equipment operability.

8. IAL January 29, 1981 - Issued to require licensee to determine root cause of water in electrical penetration problem and to establish long term isulation resistance program.

9. Management Meeting January 21, 1982 - Licensee identified corrective actions in the areas of drawing control, nonconformance reports, personnel errors. Region III commented on licensee's corrective actions and provided constructive criticism.

10. Enforcement Conference March 9, 1983 - Discussed NRC concerns regarding lack of improvement in the main-tenance program, the adequacy of the corrective action in drawing control, the licensee's equipment " operability" philosophy.

Licensee introduced Comprehensive Corrective Action Program.

11. SALP 3 July 1983 - Improvements noted in confirmatory measurements and procurement.

Maintenance continued at a poor performance level. Personnel errors and operator cognizant of design and FSAR assumptions still a NRC concern.

12. Management Meeting November 4, 1983 - Meeting held to request licensee to develop a Regulatory Improvement Program. Meeting was to address compre-hensive corrective action program concerns identified during a site visit by Commissioner V. Gilinsky.

13. Enforcement Conference December 1, 1983 - Discussion of fire (Escalated Enforcement protection violations.

Pending)

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14. CAL March 3, 1984 - Issued to ensure effects of the Stuck Open Main Steam Safety Valve event of March 2 were assessed and evaluated.

15. Enforcement Conference July 13, 1984 - Discussion of recent events

$90,000 Civil Penalty that indicate a breakdown in management control systems, and the inability of TECo to recognize design basis requirement for equipment operability. TECo corrective actions were specific to the identified violations, but failed to address root causes. PEP was identified as the program that would address root causes and necessary corrective action.

16. Management Meeting November 1984 - Management meeting among the President of Toledo Edison, the Director OIE, and the Regional Administrator to discuss the need for improved licensee communication and support for program improvements.

17. SALP 4 January 5, 1985 - Five Category 3 ratings given in the areas of maintenance, fire protection, emergency preparedness, quality programs, administrative controls, and training. Licensee outlined the PEP actions to address poor performance areas.

18. Management Meeing March 4, 1985 - Management meeting to further discuss the licensee corrective actions from SALP findings.

19. Enforcement Conference May 24, 1985 - Discussion of inspection

$100,000 Civil Penalty findings regarding a sleeping operator in issued the SUFP room, inadequate communications between security and operations personnel <

and failure to maintain proper reactor power )

for the indicated reactor coolant flow rate. ,

Discussion of the repetition of inadequate l corrective action to correct problem and j lack of inadequate management controls. '

In addition to 'che above, working level meetings were held on a biweekly (twice a month) oasis during the first months of 1985 to status the Performance Enhancement Program and to provide Region III middle level management opportunity to observe, first hand, the communication and activities of plant management and technical personnel.  !

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ATTACHEMNT I A. Procedural Violations I. Failure to Follow Procedures Report Number Subject

1. 7902. Required reading list not maintained, resulting in operators not aware of plant changes / modifications.

2. 7904 Prerequisites for T and stable power level not met and deficient conditionf*fegarding differential boron worth not documented.

3. 7905 Biweekly testing required for HPI Pump 1-1 surveillance

, results not performed and maintenance on Emergency Diesel Generator (EDG) 1-2 ventilation fan not documented, reviewed, and approved.

4. 7907 Safety relief valves maintenance instruction not reviewed by SRB.

5. 7913 Valve in spent fuel pool not aligned in accordance with T-Mod 3431.

6. 7914 Emergency Plan not reviewed annually in the SRB.

7. 7915 Fire protection preplan not reviewed by SRB and approved by station superintendent.

8. 7916 Procedure for operation of radwaste solidification not reviewed by SRB and approved by the station superintendent.

9. 7919 Drawings not revised to reflect as-built condition of plant.

10. 7919 Flammable materials not controlled in switchgear room "B".

11. 8008 Technical Section not audited in 1978 for activities related to nuclear fuel management.

12. 8012 Job planning associated with tunnel sump entry not followed.

13. 8019 AF599 and AF608 were open and the locked valve log indicated

, closed.

14. 8019 Fire extinguishers found without inspection tags or tags

not signed.

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15. 8023 Operations engineer did not tour plant as required.

16. 8025 Latest approved procedure-for surveillance testing not used.

17. 8101 Pipe supports for EDG removed without a work requirements checklist prepared.

18. 8103 Five examples of Appendix B violations involving maintenance section training, receipt inspection, corrective action reports and audits, storage and handling of equipment and maintenance procedures. .

19. 8104 Maintenance personnel did not inform Shift Supervisor of troubleshooting of EPG 1-2.

20. 8166 (a) MW0s for safety-related work not approved by the foreman and Shift Supervisor.

(b) Grouted seismic supports for SFRCS instrument lines not painted.

(c) Unplanned release of radioactive water due to improper removal of RCDT rupture disk.

21. 8203 (a) Failure to control combustibles and flammable liquids.

(b) Failure to post a fire watch.

(c) Failure to conduct fire brigade drills.

22. 8208 Required MWO not generated for moving Motor Control Center F16B.

23. 8209 Disconnected radiation meter cables not labeled.

24. 8218 Valves repositoned from their normally locked condition were not logged.

25. 8221 Safety-related conduit hung from nonsafety-related hanger and conduit support hardward not in accordance with design drawings.

26. 8221 Safety-related cable left unprotected on cable spreading room floor.

27. 8229 Preparation, approval, and administration of reactor theory exam without Training Supervisor approval.

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28. 8301 Drawing not updated to reflect plant "as-built condition.

29. 8304 Waivers for two individuals were not obtained for missed Rad Control training.

30. 8319 Acceptance criteria for test procedure not assigned to appropriate test.

31. 8320 Equipment returned to service without Shift Supervisor approval.

32. 8324 Maintenance individual used respiratory equipment although his certification expired.

33. 8401 Controlled drawings not used for repair of core flood tank level indicator.

34. 8401 Test not suspended nor adjustments made due to test deficiency.

35. 8402 Electrical junction boxes not protected from the fire protection sprinkler system.

36. 8412 Six examples of failure to implement procedures for startup, operation, and shutdown of the Startup Feed Pump.

37. 8415 (a) Control Room Emergency Ventilation System (CREVS) inoperability not reported to Shift Supervisor.

(b) Pressure door connecting AFW pump rooms left open.

(c) Test leader not assigned.

(d) Chronological log not maintained.

(e) Proper administrative controls not maintained.

i (f) Deficiency Report (DR) not generated for test deficiencies.

. 38. 8429 Drawing M029B did not include valve for Channel 3 of the RPS.

39. 8501 Two examples of the use of uncontrolled technical manuals

to calibrate instruments.

j 40. 8501 MW0s not to sufficient detail for the type of activity

{ being performed.

1 41. 8503 Piping not capped.

42. 8505 QA vendor audit responses not addressed.

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43. 8509 Hand calculations not performed to verify calculation of thermal power.

44. 8512 (a) Completed work steps not signed off prior to time work was completed on CRDM.

(b) Completed work steps not signed off prior to time work on Control Rod position indication was completed.

(c) Crane operator left control of polar crane with bolting tool suspended over reactor vessel head.

45. 8516 RCS boron concentration not determined or,e every two hours during rod movement and a test deficiency list was not attached to a completed test.

46. 8524 Daily checks on Eberline BC-4 Beta Counters were outside the control line.

II Inadequate Procedures

1. 7907 Maintenance Instruction M-46 not adequate for safety relief valves inspection and repair.

2. 7915 Inadequate written procedure for the brigade program.

3. 7916 Radwaste solidification system procedures not adequate.

4. 8012 Failure to follow procedure resulting in inadequate survey of tunnel sump cavity prior to entry.

5. 8221 Quantitative and qualitative criteria not included in drawings for attributes such as slope, etc. for instrument impulse lines.

6. 8231 Inadequate procedures regarding repair of buried fire piping.

7. 8319* Quality Assurance (QA) elements not adequately implemented for personnel training.

8. 8409 Procedure not provided for independent verificaton subsequent to initial tagging of plant equipment.

9. 8501 Approval procedures not established for calibration of M&TE.

• This violation covers seven Appendix B criteria.

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B. Technical Specification Violations Report Number Subject

1. 7925 Fire detection alarm point remained in alarm for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> without posting a fire watch, T.S. 3.3.3.8.

2. 7928 Logic channels not operable with RCS > 200 F during the startup of a RCP or a Circulating Water Pump, T.S. 3.3.2.1.

3. 7928 SRB did not investigate nor prepare a report for a violation, T.S. 6.5.1.6e.

4. 7929 Setpoint for Flux.-D Flux-flow trip not verified with one RCP out of service, T.S. 3.4.la.

5. 7930 CNRB did not review violations for reports 79-02, 79-16, 79-79, and 79-29, T.S. 6.5.2.7.

6. 8001 Control Room EVS system switch found in local position T.S. 3.7.6.1.

7. 8014 Failure to establish a fire watch, T.S. 3.3.3.8.

8. 8019 Log of events for containment leak test not maintained, T.S. 4.6.1.2.

9. 8029 Surveillance test did not include exercising of a containment pressure channel, T.S. 4.3.2.1.1.

10. 8103 CNRB did not review violations, T.S. 6.5.2.7.

11. 8103 (a) SRB membership did not include a reliability engineer, T.S. 6.5.1.6e.

(b) SRB did not review violations, T.S. 6.5.1.2.

12. 8104 Containment purge accumulated time lot determined, T.S. 4.6.1.7.

13. 8105 (a) Pump inlet pressure no t measured prior to pump startup and values not established for pump inlet pressure, T.S. 4.0.5.,

ASME Section XI.

(b) Instruments used for pump testing did not meet accuracy or range requirements, T.S. 4.0.5., ASME Section XI.

14. 8112 Failure to post a fire watch after identification of holes in fire sealed penetrations were identified, T.S. 3.7.10.

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15. 8113 Valve manipulations not logged during ST 5099.11, T.S. 4.0.5, ASME Section XI.

16. 8118 RPS temperature trip setpoints not calibrated properly, T.S. 2.2.1 and 3.3.1.

17. 8202 Valves in the CV, SA, IA and NN systems not exercised, T.S. 4.0.5 and ASME Section XI.

18. 8203 Fire doors not maintained in a functional condition and firewatch not posted, T.S. 3.7.10.

19. 8225 CNRB did not review 50.59 re: Cross Core Fuel Shuffle, T.S. 6.5.2.7.

20. 8227 With containment isolation valves inoperable, T.S. LC0 violated, T.S. 3.6.3.1.

21. 8227 All SFRCS low pressure steam line channels not tested at required frequency, T.S. 3.6.3.1.

22. 8234 Axial Power Imbalance not calculated hourly, T.S. 4.2.1.

23. 8320 NCR 83-32 not reported as NCR within thirty days, T.S. 6.9.1.9b.

24. 8409 RCS chloride concentration not maintained within limits, T.S. 3.4.7.

25. 8409 SRB did no review Temporary Modifications to procedures and NCRs, T.S. 6.5.1.6 and 6.5.1.7a.

26. 8401 SRB did not review audits, T.S. 6.5.1.6e. "

27. 8415 Control Room EVS rendered inoperable by removal of both trains, T.S. 3.7.6.1.

28. 8415 Supply fan for EDG taken out of secure thus rendering EDG inoperable, T.S. 3.8.1.1.

29. 8422 Ventilation system for storage pool area not demonstrated operable, T.S. 4.6.5.1.

30. 8422 Source range monitor not adequately tested prior to core alterations, T.S. 3.9.2.

31. 8428 Fire hose stations not tested, T.S. 4.7.9.3.

32. 8501 SRB and Station Superintendent did not review and approved procedures implemented pursuant to 6.8.1, T.S. 6.8.2.

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33. 8501 SRB failed to review 8-10% of temporary modifications to procedures, T.S. 6.8.3c.

34. 8508 Valve leak rate data not treated or evaluated, T.S. 4.0.5, ASME Section XI.

35. 8510 STA did not receive training in 1984, T.S. 6.4.1.

36. 8510 Valve RC229A exceeded isolation time and was not restored to .

operability within four hours, T.S. 3.6.3.1.

37. 8518 Reactor power not maintained for the indicated reactor coolant flow rate, T.S. 3.2.5.

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C. Miscellaneous Violations Report Number Subject

1. 7903 Fire drills not conducted on a quarterly basis, Fire Hazards Analysis, Table 4-1, Section B6(b).

2. 7903 Surveys to determine radiation levels in incore tunnel not conducted and high radiation area not locked, 10 CFR 20.203(c)(2).

3-7 7910 Five security noncompliances.

8-9 7918 Two security noncompliances.

10-18 8002 Nine security noncompliances.

19. 8012 Exposure limit exceeded during normal tunnel sump entry, 10 CFR, Part 20.

20-24 8013 Five security noncompliances.

25. 8015 NRC not notified of tornado and an accidental release, 10 CFR 50.72.

26-28 8018 Three security noncompliances.

29. 8023 Security noncompliance involving vital area doors.

30-33 8024 Four noncompliancer. involving Environmental Technical Specifications, Appeadix B.

34-39 8032 Six security noncompliances.

40. 8203 Fixed fire suppression system not provided in control room, 10 CFR 5048 and Appendix R, Criterion 3.

41. 8103 Security noncompliance, uncontrolled access to protected area, Security Plan.

42. 8203 Fire protection administrative active control procedures not upgraded, Facility License NPF-3, Amendment 18.

43. 8204 Assigned reading not completed by 7 R0s and SR0s, 10 CFR 55, Appendix A.

44. 8307 Safety evaluation non conducted for operation of BWST

> 90 F, 10 CFR 50.59.

45-46 8217 Two security noncompliances.

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47-48 8230 Two security noncompliances.

49-50 8308 Two security noncompliances.

51-59 8316 Nine fire protection noncompliances, escalated enforcement pending, enforcement conference December 1, 1983.

60. 8402 Adequacy of interfaces with State and local governments not reviewed, 10 CFR 50.54(f).

61. 8402 Semi-annual health physics drills not conducted, 10 CFR 50.54(g).

62-64 8403 Three security violations.

65. 8406 RPS inadvertent actuations not reported within four hours, 10 CFR 50.72.

66. 8412 Six examples of deficiencies in the procedures used to evaluate 10 CFR 21 issues.

67. 8413 Security violation - improper iaentification of 2 NRC inspectors.

68. 8428 Fire hose stations inoperability not reported per 10 CFR 50.73(g)(2)(i)B.

69. 8429 Isolation valve leakage not quantified and combined leakage not calculated, 10 CFR 50, Appendix J.

Paragraph III.C.3.

70. 8504 Exam results for R0s and SR0s not evaluated for Summer 1983 exam, 10 CFR 55, Appendix A.

71. 8513 Extent of hanger damage not reported to NRC, 10 CFR 50.73.

72. 8514 Security violation.

73. 8518 SUFP piping not properly monitored, Section 2.c.3(f) cf Facility Licensa.

' 74. 8523 State not notified within 15 minutes, 10 CFR 50, Appendix E, Paragraph IV.D.3.

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