ST-HL-AE-2541, Responds to Violations Noted in Insp Rept 50-498/88-01. Corrective Actions:Procedure 1POPO2-SI-0002 Revised to Correct Forms 3,7 & 11 to Indicate Proper Handswitch Alignments for All Modes

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Responds to Violations Noted in Insp Rept 50-498/88-01. Corrective Actions:Procedure 1POPO2-SI-0002 Revised to Correct Forms 3,7 & 11 to Indicate Proper Handswitch Alignments for All Modes
ML20196F197
Person / Time
Site: South Texas STP Nuclear Operating Company icon.png
Issue date: 03/01/1988
From: Vaughn G
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196F181 List:
References
ST-HL-AE-2541, NUDOCS 8803020084
Download: ML20196F197 (21)
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,7 APPENDIX B Page 1 of 15 The Light company P.O. Box 1700 Houston, Texas 77001 (713) 225 9211 Hoe @ti@ Pom March 1, 1988 ST-HL-AE-2541 File No.: G2.04 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Response to Violations 8801-01 through 8801-08 HL&P has reviewed the Notices of Violation included in Inspectier. Report 88-01 and submits the attached responses pursuant to 10CFR Part 2.

If you have any questions, please contact Mr. H. A. McBurnett at (512)972-8530.

G. E. Vaughn Vice President Nuclear Plant Operations GEV/WH/km

Attachment:

Responses to Notices of Violation i

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A Subsidiary of Houston Industries Incorporated NL.88.053.03

,8803020084 880301 l PDR ADOCK 05000498 L P DCD

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APPENDIX B 'Page of 15 ST-HL-AE-2541 File No.: G2.04-Page 2:

cc Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive. Suite 1000 Houston Lighting & Power Co:pany Arlington, TX 76011' P. O. Box 1700 Houston, TX 77001 N. Prasad Kadambi, Project Manager U. S. Nuclear Regulatory Commission INPO 1 White Flint North Records Center 11555 Rockville Pike 1100 Circle 75 Parkway Rockville, MD 20859 Atlanta, Ga. 30339-3064 Dan R. Carpenter Senior Resident Inspector / Operations c/o U. S. Nuclear Regulatory Commission P. O. Box 910 Bay City. TX 77414 J. R. Newman. Esquire Newmar.& Holtzinger. P.C.

1615 L Street . N .W.

, Washington, DC 20036 R. L. Range /R. P. Verret Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 copies)

Chief Operating Officer City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Revised 02/03/88 NL.LER. DISTR.1

1 APPENDIX B Page 3 of 15 Attachmsnt.

ST-HL-AE-2541 Page 1 A. Statement of Violation 8801-01:

High Head Safety In iection Pump Controls System Lineup Technical . Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 3 of this appendix reconsends procedures for operation of the emergency core cooling system.

Procedure IPOP02-SI-0002 Revision 6 dated December 30, 1987 Safety Injection System Initial Lineup, has been established in accordance with Technical Specification 6.8.1 to imple:ent, inter alia. Technical Specification 3.5.3.

Centrary to the above, on January 7, 1988, the NRC inspector found that this procedure was not adequate to control the alignment of the high head safety injection pumps in Mode 4. Forms 3, 7, and 11, providing the Mode 4 alignment of safety injection system Trains A, B, and C, respectively, specified the required pcsition for the high head safety ir.jection pump main control board handsvitches to be "PTL" (Pull to Leck). Following this procedure would have made all three high head saf ety injection pumps inoperable in Mode 4. contrary to Technical Specifica tion 3.5.3.

Reason for violation:

The root cause of this violation was inadequate review of the procedure tc assure its consistency with the requirements of the applicable Technical Specifications.

Cerrective actions that have been taken:

1. Procedure 1 POP 02-SI-0002 has been revised to correct Forms 3, 7 and 11 to indicate the proper handswitch alignments for all modes.
2. A review of other system lineup precedures was performed to ensure their consJstency with the Technica. Specifications.
3. Procedute OPGP03-ZA-0002 has been revised to incorporate requirements for an independent technical review of new procedures.

C0rrective actions that will be taken:

No further action is required.

Full Compliance:

The plant is in full compliance.

NL.88.053.03

APPENDIX B Psgs 4 of 15

'AttachrGnt ST-HL-AE-2541 Page 2 B. Statement of Violation 8801-02:

Temporary Modifications Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatcry Guide 1.33, Revision 2, February 1978.

Procedure OPGP03-ZO-0003, Revision 7. dated September 12, 1987, "Temporary Modifications and Alterations," has been established in accordance with this Technical Specification.

Section 4.7 of this procedure requires that the control room hard copy of piping and instrumentation drawings af fected by a temporary modification be annotated and clouded in red to identify the existence of a temporary modification. It further requires that a copy of the temporary modification request be attached to the drawing and a notation of which drawings were updated to be made on the original of the temporary modification request.

Contrary to the above, on January 5. 1988, the NRC inspector found that the requirements of Section 4.7 of Frocedure OPGP03-ZO-0003 had not been met f or Temporary Modification TI-EV-87-252 f or Drawing SR289F05038 in that no markup had been made.

Reason for violation:

The root cause of this violation was the Systems Engineer's lack of attention to detail in following the procedure. A contributing factor wts a lack of positive controls (e.g., signature verifications) on the Temporary Modification Request (THR) form to ensure compliance with the procedure. Another contributing factor was a lack of clarity in the .

procedure with regard to the treatment of blank and blind flanges.

Corrective actions that have been taken:

1. Drawing SR289F05038 was updated in compliance with procedure OPGP03-ZO-0003 (i.e., red lining of drawing. attaching a copy of the TMR, noting drawing update)
2. A review of outstanding temporary modifications -' performed agains; the requirements of the procedure. Identified discrepancies were Corrected.

NL.58.053.03

APPENDIX B Pagn 5 of 15 Attachment ST-HL-AE-2541 Page 3 3.' Procedure OPGP03-ZO-0003. Temporary Modifications and Alterations, was revised to clarify treatment of blank and blind flanges. The procedure was also revised to implement the following additional controls:

a. Identification of Key Drawings on the Temporary Modification Request.
b. Addition of a confirmation signature indicating that the affected drawing (s) have been red lined.
c. Addition of a restoration signature indicating that the drawings have been restored to normal af ter tempcrary modification is removed.
4. System Engineers have been formally advised of the procedural changes and the requirement to follow them in detail.

Corrective action that will be taken:

No further action is required.

Full Compliance:

l The plant is in full compliance.

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NL.88.053.03

APPENDIX B Page 6 of 15 Attachm2nt ST-HL-AE-2541 Page 4 C. Statenent of Violation 8801-03:

L2sked Valves Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained ccvering the activities recommended in Appendix A of Regulatory Guide 1.33. Revision 2, February 1978. Section 3 of this appendix recommends procedures for operation of the emergency core cooling system.

Procedure IPOP02-SI-0002, Revision 6, dated December 30. 1987, "Safety Injection System Initial Lineup." has been established in accordance with this Technical Specification.

Form 9 of this procedure, Initial Lineup Train C, requires Manual Valves SI-0059C. SI-0224C. and SI-0070C to be locked closed.

Contrary to the above, on January 6. 1988. the NRC inspectors found that SI-0059C was closed, but not locked and tha: SI-0224C and SI-0070C were closed but inadequately locked. The cables and padlocks on these latter two valves could easily be removed by hand.

Reason for violation:

The root cause of the violation was lack of attention to detail on the part of operations personnel who inspect valves in accordance with the Locked Valve Program in that inadequately lecked and/or unlocked valves were net identified and corrected in accordance with the Locked Valve Program OPGP03-ZO-0027.

Corrective actions that have been taken:

1. Valves SI-0070C and SI-0224C were locked and valve SI-0059C was tagged as allowed by procedure.
2. Valves required to be locked in accordance with the Locked Valve Program were inspected for proper posit 10n and locking devices or administrative controls. None were found to be improperly positioned. Those that were found to be inadequately locked were either properly locked or administrative controls were implemented through the station clearance process.

Corrective actions which will be taken No further action is required.

Full Ccmpliance:

The plant is in full compliance.

NL.88.053.03

E APPENDIX B Page 7 of 15 Attachment ST-HL-AE-2541 Page 5 D. Statement of Violation 8801-04:

Containment Integrity Technical Specification 3.6.1.1 requires that containment integrity be maintained in Modes 1, 2, 3, and 4. The conditions of license regulation,10CFR50.54 invokes Appendix J to 10 CFR 50 to defire containment integrity and to limit combined leakage, measured by test, to less than 0.6 La.

Contrary to the above, the licensee was in Mode 4 on October 31 and November 1 1987, with Containment Isolation Valve BIRAX0VOOO3, not tested for local leak rate after maintenance so that the ability to meet the 0.6 La criterion was not determined.

Reason for violaticn:

The root causes of the event were determined to be:

1. Failure to provide maintenance planners and maintenance supervisors with adequate training concerning post maintenance testing (PMT) requirements regarding containment integrity.
2. Failure to identify the appropriate PMT requirements for local leak rate testing on the MWR during supervisory review.

Corrective actions that have been taken:

1. A Local Leak Rate Test was satisf actorily performed en the subject valve and it was returned to an operable status at approximately 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on January 6. 1988.
2. A review of MWRs and LLRT records was conducted to ensure that proper testing had been done to assure containment integrity.
3. Information regarding this event was discussed with maintenance supervisory personnel and maintenance planners. The intent of these briefings was to make these personnel aware of the importance of maintaining cor.tainment integrity. Maintenance planners were advised to discuss PMT requirements with the cognizant systes engineer prior to issuing a MVR, especially in regards to containment isolation valves.
4. To enhance the current MVR program, NWR procedure. CPGP03-ZM-0003, was revised to assure that the required PMTs are identified on MWRs involving containment isolation valves.

NL.88.053.03

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APPENDIX B Pags 8 of 15 Attechient ST-HL-AE-2541 Page 6 Corrective action that will be taken:

Training-of shift supervisors and support personnel will be conducted to '

reinforce the importance of post-maintenance testing with regard to containment integrity requirements.

Full Compliance:

The plant will be in full compliance upon completion of the training.-

This is expected to be done by March 3, 1988.

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NL.88.053.03

APPENDIX B Page 9 of 15 Attachasnt ST-HL-AE-2541 i

Page 7 E. Statement of Violation 8801-05:

Surveillance Procedure Discrepancies Criterion V of 10 CFR 50. Appendix B, requires, in part, that activities affecting quality be performed in accordance with approved drawings, instructions, and procedures appropriate to the activity.

The licensee's approved Operations Quality Assurance Plan, Section 112.

"Test Control." Paragraph 6.4 requires that test procedure shall provide instructions for performing tests and provisions for documenting results.

Contrary to the above, the licensee f ailed to follow procedures associated with the Surveillance Program and/or failed to provide adequate procedure to control the activities affecting the quality of Technical Specification surveillance as identified in the six examples cited below:

1. In Lecember 1987, the licensee collected 250 milliliter waste liquid discharge samples in lieu of the one liter samples required by Procedure 1 PSP 07-VL-0001.
2. On January 7. 1988, it was found that Precedure OPSP07-CR-0002 was inadequate in that it failed to provide the necessary requirement to calculate an average sample. Chemistry Technicians were observed to be calculating the average sample in accordance with verbal instructions in lieu of following the procedure.
3. On January 6. 1988, it was found the Procedures 1 PSP 02-RC-0454, 0461.

and 0462 had been improperly modified by Field Change Request to waive Stegs 7.4.2 and 7.7.lb when reactor coolant temperature is below 538 F in that the data sheet was not modified to support the change. .

4. On January 7, 198u, it was found that Procedure OPSPO4-XC-0001 Revision 1. had been improperly revised such that changes were incorporated into an unapproved draft of Revision 0 in lieu of an approved copy of Revision 0, resulting in a Revision 1 that contained l draf: errors. This is contrary to the requirements of OPGP03-ZA-0002. Revision 10, "Plant Procedures."
5. On January 6. 1988, it was found that Procedure 1 PSP 11-RH-0004 Revision 1 failed to contain numeric values of the acceptance j criteria due to a series of inappropriate changes. This is contrary

! to the requirements of OPGP03-ZE-0005. Revision 6. "Plant Surveillance Procedure Preparation," Section 3.2.6.

6. On January 6, 1988, it was found that two completed surveillance test packages for OPSPO4-DG-0001 were presented to the Plant Operations Review Committee (PORC) for acceptance of the results based on previously accomplished preoperational test information with missing data. The packages were approved by the PORC with missing data.

NL.88.053.03

. APPENDIX B Pega 10 of 15 AttschEsnt ST-HL-AE-2541 Page 8 Reason for violation:

Item 1 was attributable to poor judgement by technicians who decided to substitute a different size container for the size specified in the procedure.

Item 2 was attributable to inadequate description of required calculations in the procedure.

. Items 3, 4. and 5 were attributable to a f ailure to follow procedures regarding the use of FCRs.

Item 6 is attributable to two factors:

1. Personnel reviewing the pre-operational test package prict to its presentation to PORO failed to detect a copying error.
2. The level of review performed by PORC was not of sufficient detail and depth to detect the copying error.

Corrective actions that have been taken:

Item 1: Chemical Analysis personnel have been reinstructed regarding the importance of following procedures verbatim.

Item 2: Chemical Analysis surveillance procedures requiring calculations have been reviewed and revised as necessary to ensure that adequate instruction on performance of the calculations is provided.

Items 3-5: A Departmental bulletin was issued providing additional guidance to NPOD personnel regarding the control cf Field Change Request changes to surveillance procedures.

Procedure OPGP03-ZA-0002 "Plant Procedures" was revised to include specific guidelines for the review and implementation of Field Change Requests.

Item 6: The data missing from the subject packages was reviewed and approved by PORC and inserted in the file packages.

An ISEG special investigation was conducted to review the PORC process to recommend possible enhancements. The recommendatices, which were issued February 22, 1988 include more formal control of the PORC meetings, more control of "walk-on" items, better definition of scope of review.

NL.88.053.03

- APPENDIX'B Page 11 of 15 l Attachment ST-HL-AE-2541 Page 9

' Corrective action that will be taken:

Management will review the ISEG recommendations and identify any improvements and a schedule for implementation by March 31. 1988.

Full Compliance:

The plant is in full compliance, however, enhancements to the PORC process may be made f ollowing review and analysis of the ISEG report.

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, ,- APPENDIX B Page 12 of 15 Attachment ST-HL-AE-2541 Page 10 F. Statement of Violation 8801-06:

Implementaticn of Technical Specification Eeouirements Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978.

Contrary to the above, it was found on January 7, 1988, that the licensee had failed to provide test procedures. which completely implemented the final technical specifications as cited below:

1. Procedure 1 PSP 10-RC-0001. Revision O. contained an acceptance criterion calling for a figure in the technical specifications which had been deleted when the final technica1' specifications were issued.

thus resulting in an incomplete and inadequate procedure for conducting the surveillance.

2. Procedure OPSP10-II-0003 was found to contain an incorrect and nonconservative equation for adjusting the core radial peaking factor limit for fractional power levels. thus resulting in an incorrect and inadequate procedure conducting the surveillance.

Reason for violation:

The root cause of this violation was that the process to incorporate changes in the Technical Specifications into procedures did not track required actions to completion.

Corrective actions that have been taken:

1. OPSP10-II-0003 has been corrected to be consistent with the Technical Specifications. Procedure 1 PEPO 4-ZG-0007 has been identified as the proper procedure for use in RCS flow mer.surement in lieu of 1 PSP 10-RC-0001.
2. Suf ficient review of surveillance procedures has been completed to assure cespliance with Technical Specification requirements for operation through Mode 2.
3. Procedure OPGP03-ZA-0002 has been revised to require an independent technical review of new procedures. Requirements have been added to the procedure to perform a "walk through" of new surveillance procedures to confirm the procedure can be accomplished as written.

Additional procedure review criteria have been imposed by means of an attribute check sheet which includes items for confirming Technical Specification requirements.

4. Interdepartmental Procedure 3.200 is now in effect which requires Technical Specification changes to be tracked from request through implementation. It also requires a OA verification of implementation.

NL.88.053.03

APPENDIX B Page 13 of 15 Attschment ST-HL-AE-2541 Page 11 Corrective action that will be taken Suf ficient review of surveillance procedures to assure that Mode 1 Technical Specification requirements are incorporated will'be completed prior to exceeding 5% power.

Full Compliance:

The plant is in compliance for operation through Mode 2. Confirmation of  ;

full ec=pliance will be achieved upon completion'of the remaining reviews as described above.

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APPENDIX B Pegs 14 of 15 Attachment ST-HL-AE-2541 Page 12 G. Statement of Violation 8801-07:

Overdue Station Problem Report Investigation Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance plan require that activities af fecting quality be conducted in accordance with approved procedures. Interdepartmental Procedure IP 1.450, "Station Problem Reporting," requires that corrective investigations te completed within 17 days.

Contrary to the above. on January 4, 1988. 68 of 204 station problem reports were overdue (past 17 days) for completion.

Reason for the violation:

The root cause cf the violation was inadequate assignnent of resources to prioritize and resolve the SPRs.

Corrective acticns that have been taken:

1. The saf ety significance of each SPR is evaluated when the SPR is first initiated. and immediate action is taken if required to assure plant safety. A review was performed which confirmed that the conditions described in the open SPRs have been adequately addressed so that plact safety is not adversely affected.
2. Revision 1 cf Procedure 1.450 was implemented on Tebruary 22. 1988.

This new precedure increased management's involve ent in the process by requiring an early establishment of priority and due date by the Plant Manager. The revision also requires the SPI originator to take the SPR directly to the Shift Supervisor.

3. Additional licensing engineers have been assigned to coordinate resolution cf SPRs. These personnel have participated in a concerted effort to resolve overdue SPRs. The backlog of overdue SPRs has been reduced to an acceptable level.

Correction actica that will be taken:

No further actica is required.

Full Compliance:

The plant is in full compliance.

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  • APPENDIX B Page 15 of 15 Attsch:2nc ST-HL-AE-2541 Page 13 H. Inadecuate corrective Acticn (8801-08):

Criterion XVI of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance plan require conditions adverse to quality be promptly identified and corrected. In August 1987, a quality assurance audit deficiency report was issued which identified 55 of 179 station problem reports were overdue for ccepletion. The deficiency was closed on the basis that tracking responsibility for station problem report investigation tracking was procedurally changed.

Contrary to the above, it was found on January 4, 1988, that the corrective action was not adequate in that 68 of 204 station prcblem reports were overdue for completion.

Reason for the violation:

As noted in the statement of the violation, the backlog of overdue SPRs was identified in an audit in August 1987. and as corrective action procedures were changed to assign responsibility for coordinatics of SPRs to Licensing. Nuclear Assurance accepted this response and a fcilow up audit to determine the effectiveness of the corrective action was scheduled for February 1985. Prior to the follow-up audit, management failed to identify that the corrective action had not been effective.

Corrective actions which have been taken:

In accordance with the schedule adopted upon acceptance of the response to the August 1987 audit, in February 1988 Nuclear Assurance cc:pleted The its follow-up audit of the effectiveness of the corrective acticss.

follow-up audit identified inadequate effectiveness of the earlier corrective action as a significant deficiency (DR S87-064 Rev. 1).

Response to DR S87-064 Rev. 1 is due by March 18, 1988. The response to DR S87-064, Rev. I will be reviewed by Nuclear Assurance.

The corrective actions described in response to Notice of Violation 88 01-07 have been implemented, and are expected to resolve DR 567-064.

Rev. 1. As an interim measure, until management gains added cc:fidence in the effectiveness of the revisions to the SPR program. Licensing is providing management with weekly reports of SPR status.

Corrective actions that will be taken:

As a result of the DR, a review of Station Problem Reports is being conducted to assure that root causes were adequately addressed and that supporting documentation properly dispositions the required acticas.

This activity is expected to be complete by 60 days after the issuance of the Full Power Operating License.

Full Compliance:

of the The plant will be confirmed to be full compliance upon completic:

SPR review described above.

NL.88.053.03

s -s-Page11 of 2 APPENDIX C 4

Summary of' Performance Indicators -

I. .Information Provided to INPO l' Equivalent' Availability Factor 2 Unplanned Automatic Scrams While Critical

.-3 Unplanned Safety System Actuations 4 Forced Outage Rate 5 Thermal Performance 6 Fuel Reliability 7 Collective Rad'ation i Exposure 8 Volume of Low Level Solid Radioactive Waste 9 Industrial Lost Time Accident Rate 10 Safety System Performance P II. NRC Comparison of NTOL Plants 11 RPS Actuation Events per 1000 Critical Hours <- 15% Power (since initial criticality) 12 RPS Actuation Events per 1000 Critical Hours > 154 Power (since full power authorization) 13 ESF Actuations Events other than RPS (since issuance of power license) 14 Significant Reportable Security Events (since . issuance of low power license) 15 Other Significant Events That Require NRC Immediate Notification Reports (since issuance of low power license)

III. Other Performance Indicators 16 Net Generation MWHr 17 Capacity Factor 18 Personnel Radiation Exposures Outside Administrative Limits

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APPENDIX C Summary cf Performance Indicators 19 . Personnel Skin Contamination 20 Plant Contaminated Areas 21 Total Chemistry Out of Specification 22- NRC Notices of Violation

. :23 Total LERs 24 Operating Experience Review Status (SOERS) 25 Outstanding Commitments-26 Ratio of Preventive to Total Maintenance 27 Status of Open Maintenance Work Requests 28 Plant Modification Status (Temporary) l 29 Plant Drawing Update Status 30 Plant Modification Status (Permanent) 31 INPO Accreditation Status 32 Simulator Availability 33 HL&P Staffing l' 34 Personnel Turnover Rate 35 HL&P Overtime 36 Capital Budget Performance 37 O&M Budget Performance 38 STPEGS Costs per Net KWHR

Page.1 of 3 APPENDIX D LER

SUMMARY

Date of LER No. Occurrence Description Cause Codes (1)87-001 08/24/87 Inoperable Unit Vent Radiation A Monitors87-002 08/26/87 Containment Ventilation Isolation X 87-003 08/28/87 Sheared Actuator Motor-Shalf to- B Pinion Keys87-004 09/3/87 Control Room Ventilation Actuation A To Recirculation Mode 87-005 09/4/87 Control Room Ventilation Actuation A To Recirculation Mode 87-006 09/5/87 Control Room Ventilation Actuation A To Recirculation Mode 87 007 09/6/87 Control Room Ventilation Actuation X To Recirculation Mode 87-008 09/10/87 QDPS Error Initiator RX Trip B

& AFW Actuation 87 009 09/18/87 Surveillance Deficiency Due To D Procedural Inadequacy Resulting in a T.S. Violation 87-010 09/26/87 FHB HVAC Auto actuation B To Filteration Mode 87-011 10/17/87 Control Room Ventilation B Actuation 87-012 11/02/87 HHSI System Inoperable A 87-013 11/02/87 Control Room Ventilation A Actuation 87-014 11/13/87 Control Room Ventilation E Actuation 87-015 11/21/87 Initiation of Cooldown Due to X Inoperability of 2 Essential Chiller Units 87 016 11/05/87 AFW Hydraulic Transients B l

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SUMMARY

Datn of LER No. Occ.rrence Descr1ption Cause Codes (1) 87 017 11/24/87 Pressurizer Low Pressure SI D Setpoint Too Low 87-018 11/24/87 Initiation of Cooldown Due to B Inoperability of 2 Trains of Cont. Spray 87-019 11/24/87 Slave Relay Surveillance A Deficiency 87-020 11/28/87 Control Room Ventilation B Actuation 87-021 11/30/87 Actuation of ESF Load X Sequences & Standby DG 87-022 12/06/87 Inoperability of 2 Toxic E Cas Monitors87-023 12/08/87 Loose Valve Shaft-To Actuator B Drive Keys in MOV's 87 024 12/08/87 Control Room Ventilation A Actuation 87-025 12/09/87 Standby DG Actuation X 87-026 12/12/87 Degraded Undervoltage Coincident D with a SI circuitry Surveillance Deficiency 88-001 01/02/88 RCP Start with Secondary Water D Temperature Greater than 50% Above RCS/PORV Actuation 88-002 01/05/88 Failure to Perform Post Maintenance E Leakage Rate Testing on Containment Isolation Valves 88 003 01/06/88 Control Room Ventilation Actuation A to Recirculation Mode 88-004 01/10/88 Loose or Corroded Toxic Cas Monitor B Computer Board Electrical Connection Resulting in an ESF Actuation

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APPENDIX D LER

SUMMARY

Date of LER No. Occurrence Description Cause Codes (1)88-005 01/11/88 Inadequate Surveillance Performed on a D Control Room Intake Air Radioactivity Monitor 88 006 01/13/88 Inadequate Surveillance Testing of D Master Relays 88 007 01/15/88 Incorrect Formula in a HVAC Surveillance D Procedure 88 008 01/20/88 . Safety Related Electrical Cable Splices E 88 009 01/23/88 Unanticipated SI Signal from SSPS Resulting D from a Procedural Deficiency (1) Cause Code is based on NUREG - 1022 description A - Personnel Error B - Design, Manuf., Const, or Installation C - External Cause D - Defective procedure E - Mgmt/QA deficiency X - Other l

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APPEND::X E .

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