ML20210V166

Informs of 861105 Regional SALP Review Board Meeting Re Events from 851001-860930.Members of Palo Verde SALP Board Provided W/Review Guidance Package to Be Used in Preparing Performance Analyses of Functional Areas

ML20210V166
Person / Time
Site:	Palo Verde
Issue date:	10/02/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Chaffee A, Crews J, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8610100562
Download: ML20210V166 (37)

Text

i 1;

-l { > ' 3 [p c.na '}o UNITED STATES E o NUCLEAR REGULATORY COMMISSION j -{  :

,E REGION V

( C g 1450 MARIA LANE, SUITE 210

$, WALNUT CRE EK, CALIFORNI A P *596

% * ~ * ,e l OCT 021986 b EEMORANDUM FOR: J. Crews, RV A. Chaffee, RV L

L. Miller, RV C. Sorensen, RV ,

R. Zimmerman, RV J. Ball, RV R. Scarano, RV

',. G. Knighton, Project Director /LB:NRR E. Licitra, Project Manager, NRR r D. Schaefer, RV G. Temple, RV R. Fish, RV H. North, RV v

FROM: D. Kirsch, Director Division of Reactor Safety and Projects

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) PALO VERDE (Period October 1, 1985 through September 30, 1986)

References:

(1) Proposed changes to the SALP Manual Chapter 0516,

,.. J. M. Taylor Memorandum dated November 5, 1985

[

(2) Region V Instruction 0701 t

Pursuant to reference (1) and (2) above, the regional SALP Review Board Meeting for Palo Verde is scheduled to convene at the Region V Walnut Creek office on November 5, 1986 at 8:30 a.m. The board members will consist of the above addressees and myself.

L This assessment will cover the 12 month period from October 1, 1985 through 7l r September 30, 1986. The evaluation period will include recent events through September 30, 1986.

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

Descriptions of functional areas (Attachment 1)

Evaluation criteria (Attachment 2)

Attributes for the evaluation criteria (Attachment 3)

Performance categories and trending (Attachment 4)

SALP evaluation matrices (Attachment 5)

Sample SALP functional area performance analysis and guidance on SALP functional area evaluation (Attachment 6)

Summaries of Palo Verde LERs (Tables 1 and 2)

Synopsis of Palo Verde LERs (Tables 3 and 4)

Summary of Palo Verde DERs (Table 5)

Enforcement Items (Tables 6, 7, and 8)

L Inspection and Enforcement Summaries (Tables 9, 10, and 11) 8610100562 861002 f PDR ADOCK 05000528 , ,

G PDR i

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l 5 2 Is F

L The following is the anticipated outline of the Palo Verde SALP report, along

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L with the individuals assigned lead responsibility for preparing input for each section.

i i

! I. Introduction Sorensen

II. Criteria Sorensen L III. Summary of Results Sorensen

} IV. Performance Analysis 1 -

f 1. Plant Operations Zimmerman i 2. Radiological Controls North h 3. Maintenance Zimmerman L 4. Surveillance Zimmerman

5. Fire Protection Zimmerman

6. Emergency Preparedness Temple _ __

7. Security and Safeguards Schaefer

8. Outages Zimmerman

9. Quality Programs and Administrative Controls- s All*

Affecting Quality

10. Licensing Activities Licitra

11. Training and Qualification Effectiveness Zimmerman

12. Containment and Other Safety-Related Structures Ball

13. Piping Systems and Supports Ball

14. Safety Related Components - Mechanical Ball

15. Auxiliary Systems Ball

16. Electrical Equipment and Cables Ball

17. Instrumentation Ball p 18. Preoperation Testing Ball

19. Startup Testing Zimmerman V. Supporting Data and Summaries (Including tables) Sorensen

• Each contributor is requested to provide an assessment from his/her

f. perspective on this functional area to C. Sorensen for compilation.

L s Each person assigned lead responsibility for a functional area shall prepare a performance analysis and submit it to C. Sorensen by COB October 17, 1986. )

Each performance analysis shall be prepared as follows-

1

~l. l

1. Assess the licensee's performance in the functional area based upon l inspections performed, available data and observations of the licensee's

(. performance during the SALP period. Obtain inputs from others who had '

inspection responsibilities or have done analysis in the functional area. I For example, in each licensing Division of NRR, the Facility Operations l Branch performs analysis of operational events. This information can be

, valuable in providing a perspective in functional areas outside of t' licensing (i.e., Plant Operations and Quality Programs and Administrative l Controls Affecting Quality). In assessing the licensee's performance, I use the guidan,ce in Attachment 1 through 4.

2. Prepare a performance analysis for the functional area following the format of Attachment 6. If possible, discuss the trend of the licensee's L

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

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

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

performance category for each evaluation criterion.

5. Each performance analysis shall' address each evaluation criteria-clearly' in a separate paragraph .for each of the' functional areas, as per. "

Reference (2). -(See Attachment 6)

By copy of this memorandum, the Director, Office of Investigations, San Francisco. Field Of fice, is requested to provide a summary of major

.: investigative activities and results involving Palo Verde by October 17, 1986.

~

In addition,' by copy of this memorandum, the offices *of NMSS and AEOD'are requested to provide performance analyses by October 17,.1986.

f D. F. Kirsch, Director ,

Division of Reactor Safety and Proj ects ,

cc:

J. Partiow, IE-M. McKee, IE

, J. Davis, NMSS C. Heltemes, Jr., AEOD F. Hebdon, AEOD-

• R.. Marsh, OISFF0 .

F. Wenslawski, RV M. Schuster, RV- -

'J. Martin, RV

- 'G.-Yuhas,.RV ,

J. Montgomery, RV '

, F. Miraglia, NRR '

l

• bec: s RSB/ Document Control Desk (RIDS) ' .' ~ \

Project Inspector,

. Resident Inspector G. Cook a B. Faulkenberry LFMB -

Region V' pm -,

Sore en/ dot.fwMiller Chaffee Kirsch

. la / / /86 /o/ / /86 #/f /86 / /86 i s F

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4 042 Functirnal Arcas. A grouping of similar activities.

a. Operatinc Phase Reactors Plant Operations Consists chiefly of the activities of the licensee's operational  !

staff (e.g., licensed operators, shift technical advisors, and auxiliary operators). It is intended to be limited to operating

' . activities such as: plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities s such as reading and logging plant conditions; responding to off-normal conditions; controls; plant-wide manipulating the reactor and auxiliary housekeeping; and control room professionalism.

, Radiological Controls '

i includes the following areas of activity which may be evaluated i

, as separate subareas to arrive at a consensus rating for this l functional area.

1 '

i (a) Occupational Radiation Safety - includes controls by li

, censees and contractors for occupational radiation pro- ,

tection, radioactive materials and contamination controls, radiological surveys and monitoring, and ALARA programs.

(b) Radioactive Waste Management - includes processing and on-site storage of gaseous, liquid and solid wastes.

(c) Radiological Effluent Centrol and Monitoring -

includes gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological environmental monitoring, and the results of N R C's confirmatory

measurements program.

(d) Transportation of Radioactive Materials - includes procure-ment and selection of packages, preparation for shipment, selection and control of shippers delivery to carriers, receipt / acceptance of shipments by receiving facility, periodic maintenance of packagings and, for shipment of spent fuel, point of origin safeguards activities.

4 (e) Water Chemistry Controls - includes primary and secondary systems affecting plant water chemistry water chemistry control program and program implementation, chemistry facilities, equipment and procedures, and chemical analysis quality assurance.

Maintenance includes all licensee and contractor activities associated with preventive or corrective maintenance of instrumentation and i

control equipment and mechanical and electrical systems.

t ATTAC101ENT 1 e

Page 1 1

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') Surveillance includes all surveillance testing activities as well as all inservice inspection and testing activities. Examples of activities included are: Instrument calibrations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, anc' all other Inservice inspection activities. -

.9 Fire Protection includes routine housekeeping (combustibles, etc.) and fire protection / prevention program activities. Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation; and those fire protection features provided for structures, systems, and components important to safe shutdown.

4 Emergency preparedness ' -

includes activities relating to the implementation of the emer-gency plan and implementing procedures. Thus, it includes such activities as licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implementation; notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; medical treatment; radiological expo-sure control; recovery; protective actions; and interfaces with onsite and offsite emergency response organizations.

-4 Security includes all activities whose purpose is to ensure the security of the plant. Specifically it includes all aspects of the licensee's security program (e.g., access control, security checks, safeguards).

Outages includes all licensee and contractor activities associated with major outages. Thus, it includes refueling, outage

, management, major plant modifications, repairs or restoration to l major components (e.g., steam generator tube repairs or

! primary loop piping replacement), and all post-outage startup testing of systems prior to return to service.

ATTACIDiENT I Page 2

s i Quality Programs and Administrative Controls Affecting Quality includes all management control, verification 'and oversight activities which affect or assure the quality of plant activities, structures, systems, and components. This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctly. The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities, -

and materials are provided and used during the operation of the nuclear power plant. Principal emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation

• of the quality assurance program along with evaluating the history of ;

licensee performance in theI key areas of: committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action systems, and records.

'1 Licensing Activities Includes all activities supporting the NRC review of amendment requests, exemption requests, relief reports, response to generic letters and bulletins, and TMI items classified as:

Multi-Plant Actions, Plant Specific Actions, and TMI (NUREG-0737) Actions, in addition, it includes an assessment of licensee activities related to design and safety issues. It also includes NRC meetings that dealt with significant licensing issues.

,I Training and Qualification Effectiveness Although this functional area is limited to the following categories of facility training / retraining so as to parallel those training programs covered by the Commission Policy Statement on Training and Qualification, this functional area includes all activities relating to the effectiveness of the training / retraining and qualifications program conducted by the licensee's staff and contractors for these categories of facility training.

(

Other categories of facility training / retraining should be treated as evaluation criteria for the other functional areas.

(a) Non-licensed operators (b) Control room operators (c) Senior control room operators / shift supervisors (d) Shift technical advisors (e) instrument and control technicians ATTACHMENT 1 Page 3

(f) Elactric:1 mtint:ntnca p;rsennIl (g) Mechanical maintenance personnel (h) Radiological protection technicians (i) Chemistry technicians (j) Onsite technical staff and managers

b. Construction Phase Reactors .

o Containment, Safety-Related Structures, and Major Steel Supports includes all activities related to the structural concrete and ,

steel used in the containment (including the basemat) and safety-related structures, and major steel equipment supports. i it includes all aspects of structural concrete (e.g., reinforcing steel; concrete batching , delivery, placement, in process _.

testing, and curing; liner plate erection and fabrication; and *4 containment post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equip-ment supports (for reactor vessel, reactor coolant pumps, steam generators , pressurizer, polar crane, tanks, heat exchangers, etc.).

Pipino Systems and Supports includes those safety-related piping systems described in 10 CFR 50.2(v) and R.G.1.26, quality groups A, B and C. It is intended to be limited to the primary pressure boundary and other safety-related water, steam and radioactive waste containment piping systems. It includes those quality checks necessary to ensure compliance with the applicable codes and other requirements specified in the SAR for these systems. The primary inspection emphasis in this area is on piping systems and their supports / restraints.

Safety-Related Components - Mechanical Covers mechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described in 3, above. The primary emphasis here is on com-ponents rather than piping.

Auxiliary Systems includes those safety-related auxiliary systems included in the nuclear facility which are essential for the safe shutdown of the plant or the protection of the health and safety of the public. Included here are systems such as HVAC, radwaste, fire protection and fuel storage and handling.

ATTACINENT 1 Page 4

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l Electrical Equipment and Cables I includes safety-related electrical components, cables and asso-ciated items used in the electrical systems of the plant, such i as: motors, transformers, batteries, emergency diesel genera- '

tors, motor _ control centers, switchgear, electric raceways, cable (power, control, and instrument), circuit breakers, relays, and other I,nterrupting and protective devices.

instrumentation .

Covers safety-related instrument components and systems that -

are designed to measure, transmit, display, record and/or control various plant variables and conditions. The Reactor Protection System and the Engineered Safety Features Actuation System are two plant systems utilizing such devices as: sen-sors, transmitters, signal conditioners, controllers and other actuating devices, recorders, alarms, logic devices, instru-ment air supplies, racks, and panels.

c. Preoperational Phase Reactors

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i Preoperational Testing Covers the preparation, conduct, and evaluation of test results for preoperational tests performed by or under the direction of the licensee"s staff to demonstrate the proper functioning and conformance to design requirements of components, .

systems, and structures.

d. Startup Phase Reactors Startup Testing Covers the preparation, conduct, and evaluation of test results for testing conducted following the issuance of the operating license, it starts with initial fuel loading and precritical tests, and continues until the plant reaches commercial operat-ing status at or near its licensed power rating.

ATTACHMENT 1 Page 5

, = .- . - -

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

a. The evaluation criteria are as follows:

1. M'anagement involvement in assuring quality

2. Approach to the resolution of technical issues fro.n a safety standpoint -

3. Responsiveness to NRC initiatives

4. Enforcement history

5. Operational and Construction events (including response to, analysis of, and corrective actions for)

6. Staffing (including management)

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ATTACHMENT 2

_ _ _ . - _ __ , - - - - _ _ _ _ - - _ . _ . . _ _ - _ . _ _ _ _ _ _ _ . - - - - - - . _ . . _ _ _ _ . _ _ _ _- . _ _ _ _ ~ _ -

EVALUATION CRITERIA WITH ATTRIBUTES FOR ASSESSMENT OF LICENSEE PERFORMANCE Category 1 Category 2 Category 3

1. Management involvement In Assurina Quality consistent evidence of prior evidence of prior planning and little evidence of prior planning and assignment of assignment of priorities; planning and assignment of priorities; well stated, stated, defined procedures for priorities; poorly stated or controlled and explicit control of activities ill understood procedures procedures for control of activities for control of activities well stated, disseminated, adequately stated and understood poorly stated, poorly under-and understandable policies policies stood or nonexistent policies ,

decisionmaking consistently decisionmaking usually at a decisionmaking seldom at a at a level that ensures level that ensures adequate level that ensures adequate adequate management review management review management review corporate management fre- corporate management usually corporate management seldom

. quently involved in site involved in site activities activities involved in site activities reviews generally timely, reviews not timely, thorough reviews timely, thorough and thorough, and technically sound or technically sound technically sound records generally couplete, records not complete, not well records complete, well well maintained, and available maintained, or unavailable maintained, and available '

proceduras and policies rarely procedures and policies '

procedures and policies violated occasionally violated strictly adhered to corrective action is usually corrective action is not timely corrective action is effective, taken but may not be effective or effective and generally ad-as indicated by lack of at correcting the root cause of dresses symptoms rather than repetition of the problem, as indicated by root causes, events are occasional repetition repetitive

2. Approach to the Resolution of Technical Issues from a Safety Standpoint clear understanding of issues understanding of issues understanding of issues demonstrated generally apparent frequently lacking conservatism routinely conservatism generally meets minimum requirements exhibited when potential for exhibited safety significance exists technically sound and thorough viable and generally sound and often viable approaches; but approaches in almost all cases thorough approaches lacking in thoroughness or depth timely resolutions in almost generally timely resolutions resolutions often delayed all cases i

3. g nsiveness to NRC Initiatives meets deadlines 9enerally timely responses frequently requires extensions of time timely resolution of issues few longstanding regulatory longstanding regulatory issues issues attributable to licensee attributable to licensee technically sound and thorough viable and generally sound and often viable responses, but responses in almost all cases thorough responses lacking in thoroughness or depth acceptable resolutions proposed acceptable resolutions considerable NRC effort or initially in most cases generally proposed repeated submittals needed to obtain acceptable resolutions ATTALIDiENT 3 Page 1

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Category 1 Category 2 Category 3

4. Enforcement History major violations are rare and major vlotations are rare and multiple major violations or are not indicative of may indicate minor programmatic programmatic breakdown programmatic breakdown breakdown indicated minor violations are not multiple minor violations or minor violations are repetitive repetitive and not Indicative minor programmatic breakdown and indicative of programmatic of programmatic breakdown indicated breakdown corrective action is prompt and corrective action is timely and corrective action is delayed or effective effective in most cases not effective

5. Operational and Construction Events few significant operational or occasional significant operational frequent significant operational construction events, attribut- or construction events, attribut- or construction events, attribut-able to causes under the able to causes under the licensee's able to causes under the licen-Itcensee's control, have control, have occurred that are see's control, have occurred that occurred that are relevant relevant to this functional area are relevant to this fenctional to this functional area area events are promptly and events are reported in a timely event reporting is frequently completely reported manner, some information may be late or incomplete lacking events are properly identi- events are accurately identified, events are poorly identified or J fled and analyzed some analyses are marginal analyses are marginal, events are associated with programma-tic weaknesses

6. Staffino U ncludino Management) positions are identified, key positions are identified, and positions are poorly identified, authorities and responsibil- responsibilities are defined or authorities and responsibil-itles are well defined ities are ill defined vacant key positions are key positions usually filled in a key positions are left vacant for filled on a priority basis reasonable time extended periods of time expertise is available within expertise it usually available very little expertise within the the staff; rarely needs out- within the staff; makes appropriate staff; excessive reliance on side consultants; staffing is use of consultants; staffing is consultants; staffing is weak or !

ample as indicated by control adequate, occasional difficulties minimal as indicated by excessivei over backlog and overtime with backlog or overtime backlog or overtime experience levels for manage- experience levels for management experience levels for management ment and operations personnel and operations personnel meet and operations personnel are be-exceed commitments made by commitments made by licensee at low commitments made by licensee licensee at time of licensing time of licensing at time of licensing

7. Training and Qualification Effectiveness training and qualification training and qualification program training and qualification pro-i program makes a positive con- contributes to an adequate under- gram is found to be the major tribution, commensurate with standing of work and fair adherence contributing factor to poor procedures and staffing, to to procedure with a modest number understanding of work, as indi-

. understanding of w rk and of personnel errors cated by numerous procedure

. adherence to procedures with violations or personnel errors few personnel errors training program is well de- a defined program is implemented program may be either lacking, fined and implemented with for a large portion of the staff poorly defined, or ineffectively dedicated resources and a applied for a significant sepsent means for feedback experienca; of the staff program is app 11ed to nearly all staff inadequate training could inadequats training could occa- inadequate training could regu-rarely be traced as a root sionally be traced as a root cause larly be traced as a root cause cause of major or minor events of major or minor events or prob- of major or minor events or or problems occurring during less occurring during the rating problems occurring during the the rating period period rating period ATTACm!ENT 3

043 Performance Categories. A rating of licensee performance in a given functional area.

a. Category 1 Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used to that a high level of performance with respect to operational safety and construction quality is.being achieved. ,

b. Category 2 NRC attention should be maintained at normal levels . Licensee j management attention and involvement are evident and are concerned I with nuclear safety. Licensee resources are adequate and reasonably i effective so that satisfactory performance with respect to opera-tional safety and construction quality is being achieved.

c. Category 3 Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear .to be strained or not effectively used so - that minimally satisfactory performance with respect to operational safety and construction quality is being achieved.

044 Trend. The SALP the performance trend of a functional Board may area.determine to include an appraisal of Normally, this performance trend should only be used where both a definite trend of- performance is discernible to in athe Boardofand change the Board level.

performance believes that continuation of the' trend may result The Board's appraisal' of the performance trend, if used, should appear as a Board Comment. It should be used selec-tively and should be reserved for those instances where the Board believes that it is necessary to focus NRC and licensee - attention on an area be-cause because ofofa an declining improving performance trend. trend, or to credit licensee performance The trend, if used, is defined as:

a. _ Improving Licensee performance was determined to be improving near the close of the assessment period.

b. Declining Licensee performance was determined to be declining near the close of the assessment period.

ATTACID1ENT 4

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e & a 5 & M Plant Operations Radiological Controls Maintenance Surveillance -

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Fire Protection Emergency Preparedness Security Outages Quality Programs and Administrative Controls Affecting Quality Licensing Activities l

Training and Qualification Effectiveness

[ Containment, Safety-Related i

Structures, and Major Steel Supports Piping Systems and Supports Safety-Related Components-Mechanical Auxiliary Systems Electrical Equipment and Cables Instrumentation Pronnernefnnn1 Tn e n- 4 m.

Startup Testing ATTACIDIENT 5

- _ _ _ ~ _ _ . _ _ _ _ _ _

PERFORMANCE ANALYSIS A. [ Functional Area being discussed] l

1. Analysis

[The analysis of the licensee's performance in an area should include pertinent facts and observations to highlight the specific strong and weak aspects of the licensee's performance.

These facts and observations shalf be presented in a manner to place matters in perspective and to allow the reader to ,

understand the rationale for stated conclusions. This analysis should concentrate on the adequacy of the licensee's management control systems, adequacy of resources, training of personnel, etc., and the effectiveness of these efforts.

Upon presentation of the analyses, the attributes associated with the specified criteria are to be referred to for purposes of both completeness and to compare the conclusions reached with the attributis of each category. The attributes listed in Part 11 are specifically oriented toward this and should be utilized. In no event, however, are the examples of licensee performance for specific attributes to be used as stand-alone ,

assessments; they represent a sampling of possible- conclusions which must be supported by appropriate facts, observations or analysis. Each analysis should be written to avoid either 10 CFR 2.790 or safeguards information.

The analysis section is composed of three major subsections:

A brief account of the inspection activity which occurred in this area.

A brief summary of the previous evaluation if there has been a significant change or if there should have been significant improvement but there was not.

A cummary of the strengths, weaknesses, and other significant observations made by the NRC staff during the evaluation period.

2. Conclusion

[ Provide the performance assessment (Category 1, 2, or 3) for each functional area considered.)

3. Board Recommendations

[ Include any general or specific Board recommendations per-taining to either licensee management attention or NRC inspection activities in a functional area. If appropriate, include a trend assessment (improving or declining),

characterizing licensee performance near the close of the assessment period. Note that even in the absence of a recommendation to vary inspection levels, the Regional Office may do so based on the assessment as discussed in appropriate chapters of the IE manual. )

ATTACIDIENT 6 Pace i

5. Fire' Protection >

During this SALP period, approximately 210 hours0.00243 days <br />0.0583 hours <br />3.472222e-4 weeks <br />7.9905e-5 months <br /> of direct NRC inspection effort was spent in this functional area. One NRC inspection on Appendix R was conducted at Diablo Canyon Units 1 and -

2, specific to fire protection, in addition to Resident Inspector's normal observations of fire protection requirements and -

implementation during facility tours.

i The one specific Appendix R inspection examined the licensee's routine fire protection program, and also verified licensee's compliance to the guidelines given in 10 CFR 50 Appendix R. This inspection was conducted by an onsite team of six individuals.

Two LERs concerning missed fire watches and no violations were ._,'

reported for Diablo Canyon Units 1 and 2 during this SALP period.  %

A clear understanding of fire protection issues was demonstrated by the licensee in their approach to the resolution of technical issues -

from a safety standpoint. Reviews and records appeared to be generally thorough and technically sound. A number of identified deficiencies were examined by the Appendix R team. The licensee exhibited a degree of conservatism, viable and sound approaches and timely resolutions.

The licensee met all fire protection deadlines to demonstrate responsiveness to NRC initiatives. Issues were resolved in a technically sound manner, thorough and acceptable responses were proposed in almost all cases.

There was no NRC enforcement action in this functional area and no significant events such as a major fire, but there were two LERs during this period. The LERs were promptly reported, and properly identified and analyzed.

The licensee's onsite staff consists of a station emergency services supervisor with a station fire marshall and fire protection engineer working for him. A corporate fire protection engineer and staff are based in the Corporate Office. The large number of fire watch personnel used at the site are under the direction of the fire f

ATTACHMENT 6 Page 2

s marshall. The staff appears to be well qualified and of adequate size for the workload. Site personnel appear to have been well trained and are conscious of fire program requirements. These positions are identified with defined responsibilities and any.,

vacant positions are filled in a reasonable time.

Management involvement in this area was evident, in that there was

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consistent evidence of prior planning; actitities were condacted in accordance with well defined' procedures; and policies were established and understood. Decision making consistently occurred at the proper management levels to ensure adequate review.

Corporate management eas frequently involved in site activities.

W 1, conclusion Performance Assessment - Category 1 Board Recommendation Continued management attention and commitment of resources is encouraged to maintain proficiency in this functional area.

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Licenste Event Reports ,

-(10/1/85 .9/30/86) ,

Functiona1: Area /

, 'LER Descriptien ,

Cause Code *:

! 85-70 'Azmuthal power tilt not verified after rod: drop' '1/E -

? - - erroneous data was used.

? i 85-71 Unanticipated RX trip following planned turbine 1/B-trip, on' errant low SG level signal. Also SIAS, CIAS, & MSIS actuation. 'SBCS did not operate l 'as-designated.

4 85-72. Inadequate monitoring ~of gaseous radwaste during 2/A. ,

31 regassin'g of primary coolant. '

'85-73 41ST-l'ZZ18 not' fully performed a's required by T/S. 4/A-

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.. 85-74~ -Bus' fault between NAN-S03 and NAN-S01 resulte'd'in 1/E FBEVAS, CREFAS,.&.CPIAS.act6ation.

,85-75 Inadvertent actuation of SIAS.and CIAS by I&C c4/A

..Techs during~PPS surveillance tests.

85-76 RX trip caused by loss of power:due to 3/Ei troubleshooting work on plant multiplexer FBEVAS,- '

, CREFAS,l& CPIAS' actuation occurred EDG's started.

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85-77' "A" CPIAS, "A" CREFAS, & cross-train trip to B" ~

4/A t-CPIAS & CREAS during radiation monitoring channel

- funct. test.

I85-78 Noble gas grab sample and. flow estimation for.the 2/A~ '

condenser air removal effluent monitor, RU-141 within

the specified T/S time interval.

'7 t 85 '

- Op'eration'in a condition prohibited by tech. specs. ~ '

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'] channel functional test for 4.16 kv emergoney bus ' '

U loss of~ voltage-relays was not complete and 7 q ; ,, response time sury. was. unacceptable.

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85-80, RX trip due to out of tolerance.setpoint in _3/E

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' turbine demand runback module.

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,85-81; , ' Pass inoperable for more than seven days and the 2/X ~4-

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preplanned alternate. sampling program had not been )

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established. -

a

!!. . .85-82 Diesel generator failure to: load during testing 4/A-

! ~

, ' was not. reported. ~

i, ,

!J, [ , .

dW *- ' .

4 1

s

-'L i f' i

. - 4<. - , . . -. .-. ~ . -< * , , . - - - - - - . . . - ---.-,v-m , , - - . , - , , . -

,c . .r ; 4-pu,;m, . ', .

4R ' * '-

4 6 *

,. r - +

.3 p.4y .

.) ,N:_, y' ,

Functional Area /

LERI '

Description Cause Code * ,

,,e ,

f*1

~

,85-83? Spurious ESF actuations caused by overheated ESF 1/E

= sequencer module.

85-84 Inadvertent initiation of CREFAS while returning 1/A

rad. monitor to. normal from bypass.

85 Ra'iation d monitor,.RU-144, declared inoperable 4/D due to inadequate surv. test procedure.

85-86 Inadvertent MSIS actuation while testing the MSIV's. l4/B 85-87 Inadequate review resulted in'the failure to 4/A.

identify a surveillance failure for the loss of power = relays.

85-88 RX trip-on loss of power to the part length CEA 1/E drive mechanism due to a defective phase synchronizing card.

85-90 RX trip due to feedwater anomally which. prevented 1/E ,

sufficient feed flow. l 85-91 Valve retest not performed due to misinterpretation 3/A of retest requirements.

92 Inadvertent termination of firewatch for the MSSS. 5/A 85-93 Improper valve lineup on rad, monitor RU-142, 2/B 1 85-96 Unanalyzed fire area between DG building and 5/B control buil' ding (seismic gap).

85-97, Spurious CPIAS and CREFAS initiated by failure.of. 1/E

a. Rad monitor CPU card.

7 c' - 86-01 DG failed to start and T/S action statement 1/E ,

. was exceeded. '

,a 86-02 Failure to ship 3rd quarter.1985 strontium air 2/A j filter samples. ,

Reactor trip and ESFAS actuations due to loss

_ '86-va

~

1/E

.of power from faulty current transformer.

yi -

,. + 8$-04 s<PZR pressure was raised above 430 psig without 1/A .

g; j ,

first removing power to the SIT isolation valves-m* e .as required by T/S.

u 86-05 -Inadequate monitoring of gaseous radwaste during 2/A

' degassing of primary coolant, t 3 c

,

• e 5 m N

,,e . . . -

y,

[ ] . . 4 - , c,-

7r , ,

s

. . h. ~

-(, .

d' f - Functional Area /T' y 'C 'LER4 Description s Cause Code *

' 86-06: RX. trip. caused when'a synchronization check'. 4/B' G^

4 tblocked the transformer of.non-essential loads osc ,

'duringo testing'. MSIS actuation also.

86 Incomplete composite RU-143, filter analysis. 2/A

, 86-08: '3' inoperable charging pumps requiring' entry into 1/E '

LT/S23.0.3.

~

~ ~

t 86 FailurEto.isolatewastegasholdupsys. 1/A' 186-10 ' Unacceptable sury. test results not recognized.' 4/A1  ;

86-11. Inadequate radiation monitoring during RU-141 ' 2/A inoperability-.,(timeliness of sampling .,

86-12 Max. sury.-interval exceeded for'41ST-1ZZ16.. 4/A

,; '86-13 Spurious FBEVAS initiated by' electrical. noise. . 1/B q

! 2 spurious.actuations:ofFBEVASand'cr'os' strip _[

~

86-14 '1/E -i of CREFAS. - -

, r.

^

86-15. Missed T/S iodine samp15 after-RX trip. '

. _ 2/A- i

, i ., '

t 3 : . . ". u ~

r 86-16 . Surveillance noti performed within T/S allowdd' s 1/A ; ,

time. limit. ";;g* , , , ,

'r y,  ; . . s. .

'.RX trip on-low-SG level-dus to anomaly in -

' ~

'86-18J ;1/E feedwater pump ' speed control circuitry. ;. '

_ , . .. , t 2.

...CREFAS, CRVIAS, CPIAS,1FBEVAS initiation due (to3

86-19 1/D

. loss of power.to "A"[ vital ~ instr; distribution panell& 125;VDC'dist. panel.

~ ,

86 RX trip on low SG leveNdue to anomaly inJ j ' 1/E -

.feedwater pump' speed control; circuitry.

p 86-21: Low air pressure transmitters.to the ADV's were -1/A cross connected.

~ 86-22 'CPIAS initiated and cross-trip of CREFAS spurious. 1/A-

~ 86-23 PASS declared inoperable due to misapplication 2/A of. cont. ATM sample pump. '

86-24 RX trip.due to low SG level. 1/A.

e 86-25 Unsealed AFW pump room penetrations left pump 9/A operability in question.

i. .

.i

-l 7 ,

I t

1 k ,,

, . . - , ~ , . _ ,, - . - . _ _ . - _ _. - . _ - - - . _ _ .- . . . _

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9-

/k [ ' , k g7' A -

• <i ,

, 1 s

3 x

", ~

Functional Area /E lLER _ ~ Description'?' '

'Cause Code *- '

86-26: '-Inoperable _ class IE batteries due to inadequate s $/A

' surveillance testing.

. J

, 86-27 ' PPS actuation and MSIS initiation by spurious i ,

1/E low SG pressure trip (signal, noise).' ,

6 86-28 Survi testing of Halon systems invalidated due to -4/A pressure gauge which could not be calibrated.

86-29 Sury.1 test performed . incorrectly due to improper 4/D

calculation method in procedure.

86-30 MSIS actuation due to SG overfill. -1/A 86-31 - Control. room essential filtration units inoperable 9/A-

due to unqualified charcoal.

, 86-32 - Inadvertent CREFAS during surv. testing. 4/D

~

86-33 Reactor trip due to 1 w reactor coolant flow trip 1/X -

. (spurious). .

86-35 Inadvertent operation with; inoperable SG downcomer 3/A- -

' ~

isolation valvesfdue to! failure to complete retests.

86-36 - Unconservative-reactor coolant low' flow trip- 9/X-setpoints supplied by vendor.

86-37 Spurious FBEVAS actuation and cross-trip of CREFAS. 1/E

_ 86-39 Inoperable main feedwater isolation valves-due to' 9/A

, incorrect engineering evaluation.

< r 86-41 - Missed surv.-tests'on rad. monitor RU-141.

~

4/A 3 86 . Low DNBR'RX trip due to CEA misalignme'nt. 1/D

86-43 ' Potential T/S. violation'due.to video c'amera use '

. 5/A

, for-fire watch patrol.

86-45 Reactor-trip' initiated by manual generator trip. . 1/E-86-46 Containment rad monitor (RU-1) inhp able due to. 9/B incorrect computer constants supplit bd vendor..

86-47 RX trip caused by two" conservative lreactse coolant , ' 1/X~ .

flow trip setpoints plus' SIAS, . CIAS, AFAS; and MSIS

- actuation. '

3- ,

a e

3 9 4

G v -

,a

-i,.-_ - , , - . . . . . - - . , - . . -. , , - , . . , _ _ .- . , , ., , - . . , . . , . - - . _ - _ . . .

,, + 1

,;,_\ n y

- g9 v. 9 et.m  %,." . i

, .e.

' < 9 '

;,18

, , -; _<  ;- >; ', , . . . ~

i

- y ; w. . .,

,-. . 9; *

>r

! '. - , ' . i -

Functional Area 7 .

~

j .' ; , -, h " : LER - s Description Cause Code * . -

. s- l.. . -

s .

r a '%  ; t. 49- ,

Auto.' actuation of FBEVAS and cross-trip of.CREFAS~ 3/A- 1 .

'~-

. < 'during a setpoint change for rad ~ monitor (RU-31) . . ,

-a ,

, . .. e . .

• Cause codes identified in LER synopsis tables.

5

i o

, y ,

cw \ . ,

^

.s 4 ,' +

s

~* . .

k b t

t 4

A e

}

,4,- e 484

y*

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4 e

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• 1 4 ,  ;

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. .- ,ww- .

s , ,y - ,

ji a '10-g;#bk g n I ;; $['n; ", I ,y, l . .-

>v .< .a ;. - '

v a% Y . #A *' N ' .-

%g' d ';

,f b- ' ' '

',y*,

[

y l. k i Il!  : TABLE 2 '

^;.

g+ ! . 9 -; 1 i 1 ,

..PALO VERDE UNIT 2~ e p

[9] [.T; ' ?m ' ; ' '

1

,9 . Licensee Event Reports ~,9 ' T ' . a ". . s (10/1/85 - 9/30/86) f .+ -;.

3  % , , ., t

~* '

~*SiJ.f .

' Functional" Area /. c

~

• 3 ^ >

Description di 4.

< LER =

r. .

, Cause Code *: }"

l "; . . . ._ . .

' ~ ( s .. ';a ' 185-0,1 ~o,, Spurious signal tripped CREFAS. -

1/E

~

8502; 2 jI/C' troubleshooting --CREFAS actuated.' 3/E ,

85 Spurious-signal .CREFAS actuated. 1/E ,

. - 1 85-05 CR essential vent removed from open'- required by 1/A l} .T/S at time. ,

i 85-06 Improper reset by operator caused CREFAS actuation. .1/A -

.86-01 42ST-2SE01 not performed within T/S max allowable 14/A time.

86-02 MSIS actuation.due to improper fuse size. l9/E, 86-03:, -Surveillance test not' performed within time frame. - 4/A 12d>-04L CREFA/CPIAS' actuated when I/C'were testing on: '4/A wrong RIC.

~

86-05 CREPAS and emergency-loss of SDC du'e to improper 9/A modification.

86-06 .CPIAS/CREFAS trip when I/C' tech was hooking up 4/A recorded _ interrupted power supply. .

86-07 Routine surveillance test'not completed within 4/A time frame.

08' MSIS actuation.- I/C performing surveillance test 4/A

-deviated from procedure.

86-09 MSIS actuation - incorrect fuse size. 9/E 86-10 Proper retest not_ performed on a containment -3/A isolation value following maint.

.86-11' BOP ESFAS inoperable / excessive time to cool'down. 1/B y 86-12 Preop tests used to declare batteries operable to 4/A , ,

)

• meet T/S surveillance. requirement inadequate.

p '

86-13 Incomplete surveillances on two overcurrent 4/A -

protection devices.

g Y

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• I

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} , .. . , .,f*' *

,1.-, i . . :11 .

, e- .

, i .

Functional Area /

LER. -Description ~ Cause Code

• I '86-14 .MSIS actuation when:I/C deviated from procedure- 4/A' when doing surveillance test. '

O' '86-15, ;RX: trip.with all CEAS.inserte'd.when RCP was. tripped 1/E 1

when seal -injection lost while flushing filters.

'e N ~86-161 ' Improper calculation m'ethod for pressurizer heater 9/D

,- capacity caused operation in.a~ condition contrary

'to tech. specs.

86-19 ' Inadequate monitoring of gaseous radwaste system 2/A

during degassing operations.

i 86-20 Inadvertent BOP /ESFAS actuation caused by inadequate 1/B

, pin contact insertion length in. load shed modules.

86 Incorrect setting of safety injection valve (LPSI; ~3/A discharge).

86-23 ' PASS declared inoperable' due to misapplication of 2/A-containment atmosphere sample recire. pump.

. , '86 . Inoperable SG sn'ubbers due to lack of visual 3/A-examination after performing work.

86-25 RX trip ~on SG low level, MSIS, CIAS, SIAS, and 1/A

-SBLS actuat' ion, due to licensed-operator error on feedwater control.

~

86-26 ' Reactor trip initiated by main turb'ine generator 1/A

-trip.

, r 86-27.. RX trip caused by a turbine. trip'-(unanticipated). 11/D 28  : Hourly fire watch.not performed due to high gss :5/A concentrations'. '

86-29. 4ZST-22Z18,t42ST-2ZZ23,Jand 72ST-9SB02 were-not; 4/A' performed within the required.T/S time interval. ,

86-30 .ESF actuation due to rad monitor. relay malfunction. ) 1/E 86-33 Incorrect wiring in generator results in reactor- 1/B

' ~

trip.

86'-34 RX trip-on high PZR pressure following^an 1/B unanticipated turbine trip.

86-35 HZST-2ZZ23 not performed within T/S time interval. 4/A i

• - ~.

y. .

,,,.~ '

_ 12 *

' ~

Functional Area /

LER Description. '

Cause Code *

~ RX trip setpoints for the rea'ctor coolantflow flow; 5 9/X

~

86-36 trip were established outside'T/S-limits (as, supplied-by the vendor). .

86-36 RXshutdownduetodroppedpart. length'CEA'cauhed -1/E by faulty timer card. ,

86-37 MSIS actuation due to SG 1.high level'when' operator- _ 1/A opened ADV too far and~cau' sed a swell. '

86-40 containment spray system and pumps rendered 4/A inoperable due to failure-to perform surveillance test.

86-41 Unidentified leakage resulted in shutdown 1/D (identified.as RCP 2B seals), root cause was strainer flushing techniques.

86-43 SIAS actuation during the performing of a 4/A surveillance test (deviation from procedure).

86-46 Containment rad. monitor.(RU-1). particulate 9/B channels setpoints. incorrect as supplied by vendor.

86-47 Invalid floating point fault in core protection '1/X calculator caused a reactor trip.

86-48 Safety injection tanks inoperable due to personnel 4/A-error.

• Cause codes identified in LER synopsis tables.

l b,

i , .- ,'

7~. A; . . . - .

4

~

iw 4- -

13 _ - -

_j * .

[.

g4 .

t. - -

TABLE-3 ' '

PALO VERDE UNIT 1 .

hyl:^fi;sd c -

SYNOPSIS OF LICENSEE EVENT REPORTS **- ,

i u Lic'

,g, . Functional SALP Cause Code *' >

.t:.eJ# ,

I Area' A B -C D E X ' Totals - -

e,% 4 c _ ' .

i*

m s. . -

' ' u n 1,, i/ 1. ' Plant Operations- 8 2 0 22 '15 2 ~ 29 s -

z, - m

)Ra'dioldgical Controls ,N ' "

.;cdi]!,,-

2 .'

-8 1 0 0- 0 1 10 , i v v" ., j "

g ! ;!

. 3. Maintenance 3 0 0 0 .2 0 5 -

c , _

Surveillance- 10, 0'

. , 4. 2 4 0 0- '16 -,' . . ,

• q- ;-

}- 5. ~ Fire Protection 2- 1 <0 0 0 0 -- 3 - #

o q t _f n ,- -

6 .~ -Emergency Preparedness 0 0 .0 0 .- 0 . 0 0 *-

..y _

~7. ' Security'and Safeguards 0 0' 0 0- 0- 0 <0 ,

N- 8. ' Outages .

0 0 0 0 0 0 '0-t-.

~9. Quality Programs and 3 1 ~0 0 0 -1 5

. Administrative Controls Affecting Safety

+

10. LiEensing Activities 0 0 0 0 0 0 0

.11. Training and Qualification 0 'O O 'O O O O Effectiveness 34 7 0 6 17 4 68

• Cause Codes:

-At- ' Personnel Error ,

B - Design, Manufacturing or Installation Error-C ' External Cause.

. D - Defective Procedures E Component Failure X -'Other

• • Synopsis includes LER nos. 85-70 through 86-49.

4 ,

, ,' in ';

IO ~~

1, t'4 . . . . - _ . _ . . - , .._ ,._ . . .

~

w ;. ' 14-1

- TABLE 4 PALO VERDE UNIT 2~ . ,,

r^ , i ~

IL-a-

w

!j . ISYNOPSIS OF LICENSEE EVENT REPORTS **. ,;

- Functional 1 SALP Cause. Code * <

tj .  ! Area A B C D E X Totals .

N- ..

TL ,. 1. '-Plant-Operations 5 4 0' 2- 5 1 17 ~

e n. ,

ii'

'2.' Radiological Controls 2 0 0 0 0 0 2 , ,,

i 32 : ; Maintenance 3 0 0 ~0 1 0 4~ -' '

n s - , -

Surve'illance 14 0 0 0 0 0 14 '

._ , - 4 . -~

5. Fire Protection 1 0 0 0 0 0 l' '

. 6. Emergency Preparedness. 0 0 0 0 0' 0 0 ,

/>; -

^

7. Security and Safeguards 0- 0 0 -0 0 0 0

" e

8. Outages 10 0 0 0 0 0 0 n.

9. - Quality Programs and .

I 1 0. I 2- 1 6 Administrative Controls

, Affecting Safety

10. ' Licensing Activities 0 0 0 0 0' 0 0

11. -Training and Qualification' 0 0 0 0 0 0' 0 Effectiveness 26- 5 0 3 0- 2 44

• Cause Codes:

A - Personnel Error ~

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

-X - Other

• • Synopsis includes LER nos. 85-01 through 86-48.

r r ,

n V

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s r=,- ,

' ~

34 s.t:

he t.l l , ([ '

F 'l 'R '

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n

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'l )i:, , ,

?-

j.

., TABLE 5. ,~ ?

~: , . .

REPORTABLE'10 CFR 50.55(e) REPORTS t?

, Verb 51 3 Written Notification- Report. . .ANPP  : Functional

.Date. . ,9 Date Description. DER No~. ' Area 8/21/85' L10/28/85 CE Instrument rack flexible 28 17 c conduit installation-9/17/85- 11/13/85- Minimum seismic separation 85-32 12-

3.  ; -

between buildings

L ,

~9/30/85- 10/28/85 Failure of Unit 2 diesels- .

85 16 ,

to pick up loads.in override 11/8/85. 6/11/86 Deficiencies identifie'd '85-38 *16

.during audit of GE Company:

12/9/85 '

,1/9/86

~'

" Burned wire insulation on" 85 16e

.some-SG valves

~

112/9/85 3/11/86 Diesel ~ generator slipped 85-42 14=

fuel rack linkage 2/7/86 3/31/86 Lack'of supports for Bisco 86-04 15 fire seals-7; 2/21/86 6/24/86 Inadequate wire lug 06 >

'16; terminations on DG control-panels and battery chargers

^

3/26/86 4/23/,86 Partial penetration welded- 86-12 .13

- nozzle's .

L . .

3/20/86; 8/7/86 ~ Weld failure.on pipe support 86 13 structure Carbon , steel gate guides';ine 86-17

~

4/29/86. 6/10/86 14 stainless. steel gate valves

• ~

.4/18/86 5/16/86 MSSS west wall seals,not '86-~18, 12 installed! ,

I~v 4/24/86' '

6/27/86 Missing lockwashers'in BOP 4 86-19

~

-16 ESFAS modules ,

76/3/86- .Potentially; HVACI damper seals; n'ot meet'ing 86-20 . 14 Reportable; . required specifications Brok'en nut on'#1 SG sliding

~

7/25/86- Potentially. 86-23 , 12 Reportable base support forging J

4

> e' *,r--

r

-se, .

p

., 4 t..

.,.a - - 16 4

Verbal Written

. Notification Report .

ANPP ' Functio'nal .

'Date Date- Description DER'No. - Area.

"~

7/25/86-1Potentially . Wrong conversion factors on: 86-25 17 Reportable- Rad monitor.RU-1 ,

'8/27/86 ~ Potentially Softer than required nuts, 86-26 12 with heat trace 6C

~

Reportable

, 8/29/86 Potentially Copper plated . cylinders on - 86-27 14 Reportable DGs- '

t h J r t?

r

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4 4

4

~

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^

J. a s c I7.

1. i:f >

., ~ -

x' . . TABLE 6-

f

. PALO VEllDE ENFORCEMENT ITEMS

, - UNIT 1-

<'m .

I'NSPECTION SEVERITY FUNCTIONAL

~

REPORT NO. SUBJECT LEVEL AREA' 50-528/85-31 TWO TEMPORARY MODIFICATIONS WERE NOT ' IV i 1' VERIFIED WITHIN EIGHT HOURS OF-IMPLEMENTATION AS REQUIRED.BY PROCEDURE -- - <

, INDEPENDENT AIR RECEIVER TANKS WERE- -V -3 0

~

v4 -2 4 CROSS CONNECTED.BY A TEMPORARY JUMPER i.l ...

>'i e ~ ? HOSE WITHOUT A WRITTEN SAFETY EVALUATION I.

(6~ A '

1BECHTEL SUPERVISORS PERFORMED DESIGN D. 9

• Mi '

' ~

. . VERIFICATION REVIEWS WITHOUT ADVANCE

~

~

APPROVAL i o M ',4 ..% I

' ~

'; 1 IV 528/85 38 "

SCREENING RECORDS FOR CONTRACT 7- -

? .

y it . EMPLOYEES

- ; i- *- ,

7;

~

. i; , ,

.!aL_.L-

+

-, LICENSEE DESIGNATED VEHICLES IV -- 7 -

~

I ' y ', , ' ( -< PROTECTED AREA DETECTION AIDS - IV . 7. .

E s .

528/85-43 EIGHT INCH CONTAINMENT PURGE VALVES IV 1 -

I x . w '?

WERE NOT SEALED CLOSED TO THE MAX. -

EXTENT POSSIBLE IN THAT THE' VALVES ,

.' . REMAINED OPEN WITHOUT JUSTIFICATION , ,

FOLLOWING. COMPLETION OF CONTAINMENT , . ,

W/

ENTRY

fs ' '

LER 85-70 AND 85-72 EXAMPLES OF LATE V '9

-SUBMITTALS OF LERS TO.NRC .

50'-528/86-07 FAILURE TO REPORT SECURITY EVENT TO IV 7

, . NRC FAILURE TO PROVIDE ADEQUATE VITAL III 7 AREA BARRIERS -

528/86-07 FAILURE TO PROVIDE ADEQUATE VITAL IV 7 AREA BARRIERS FAILURE TO LIMIT VITAL AREA ACCESS III 7 TO AUTHORIZED INDIVIDUALS 4 528/86-17 FAIIURE TO RECORD REQUIRED SECURITY V 7 EVENTS IN A SEPARATE LOG FAILURE TO PROVIDE ADEQUATE RECORDS IV 7 FOR LOCING DEVICES ON VITAL AREA DOORS.

p r 9--wwe w - .,-p ..* - . -9 --w- . , . . - - + = - - .ui *y,m w*.-w+ -- e e -p +w rp.- 9- m,,-y g--- g t-

i ; ..

_., l-' ! gg TABLE 6 PALO VERDE ENFORCEMENT ITEMS UNIT 1.

- INSPECTION SEVERITY FUNCTIONAL REPORT NO. SUBJECT LEVEL AREA 50-528/86-20 HOURLY FIRE WATCH PATROLS OF LPSI ROOM IV 5 WERE NOT ESTABLISHED WHEN EQUIPMENT:

WAS REQUIRED TO BE OPERABLE AND

- SPRINKLER WAS INOPERABLE

350-528/86-24 CHANGES TO FACILITY AS DESCRIBED IN V 9 ,"

FSAR WERE NOT INCLUDED IN LICENSEE'S 1985 ANNUAL REPORT f

50-528/86-28 FAILURE TO SHUTDOWN WHEN RU-1 WAS IV 2 ,,

INOPERABLE FOR GREATER THAN 30 DAYS ,

7 , .

pi

) -

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4A ,. l 5

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+ ; 3, -

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-o

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,.  ; _' s.

.\

., .i 7 TABLE ,

j .. .,

i. ,

,. . PALO VERDE: ENFORCEMENT ITEMS- , ,- e ,

, UNIT-2 *

- ,+;

INSPECTION ,  ! '

'SEVERITYN FUNCTIONAL REPORT NO. SUBJECT , l[ , 4 y

f LEVEL. , AREA

' ' _ + ,

50-529/86-02 7RU-37 TESTED WHILE CHANNEL WAS - *-IV-t J4 UNBYPASSED-RESULTING;IN INADVERTENT' -+ , _

CPIAS, ., ,-

4

. 50-529/86-06' FAILURE TO RESPOND TO SECURITY.: ALARMS- III '7

1 FAILURE TO PROVIDE' ADEQUATE IV' 7 ~ ,.

. ILLUMINATION IN-PROTECTED AREA 50-529/86-07 . LER 005. SUBMITTED BY LICENSEE TO NRC

~

V' 9 DID NOT DISCUSS WHETHER THE' ERROR WAS s

CONTRARY TO APPROVED PROCEDURE WAS AN' ERR 0NEOUS PROCEDURE, ETC.

W<$29/86-17 UNIT 2 I40N LEVEL CONTAINMENT INNER V. .1 ~

D00R' FAILED SEAL LEAK TEST AND OUTER '

- DOOR WAS' OPENED PRIOR TO-SATISFACTORILY' REPAIRING AND RETESTING INNER DOOR 50-529/86-23 ' . FOREIGN MATERIALS LOCATED IN AND ON IV '3- '

g

- CLASS 1E: RELAYS-IN AUX RELAY CABINET.

A SIMILAR CONDITION HAD BEEN PREVIOUSLY IDENTIFIED, CORRECTED AND REPORTED TO NRC. >

E;

.;f-

• s ~{

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- ~i20 g ':e

. m TABLE 8 PALO VERDE ENFORCEMENT ITEMS

~

UNIT 3

-INSPECTION ~ SEVERITY FUNCTIONAL-

REPORT NO. , SUBJECT ~ LEVEL AREA

50-530/86-03 MASONRY WALLS INCORRECTLY CLASSIFIED IV 12 AS QUALITY CLASS

'50-530/86-03 NUMEROUS DEFICIENCIES IN VENDOR IV ~9 SUPPLIED COMPONENTS AND MATERIALS

~

50-530/86-03~ .AS-BUILTS.NOT IN ACCORDANCE WITH DESIGN IV

~

9

-AND INSTALLATION REQUIREMENTS'.i'~  %.

Y

~ '

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E m .)

A ,

t

• 4 E 1,

5 6 g i .

I s.

e

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~

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k y. yd[ 3[ <

+

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• ~i ;.. , ,

. TABLE'9

~

INSPECTION CTIVITIES'AND ENFORCEMENT

SUMMARY

R0/1/85 - 9/30/86) ,

,PALO VERDE UNIT 1 Inspections Conducted Enforcement Items Inspection * - Percentz- Severity Level.**

Functional Area Hours of Effort I II:III 1V V .Dev -

~

1. - '. Plant Operations 11620 45 '. 5' - 2 fRadiol'gical Controls ~

2. o 210 6 1

3. Maintenance 220 ' 6.5 1

~

4. -Surveillance 230 .6.5 *

5. Fire-Protection 50 1.0 1

6. . Emergency Preparedness -300- . 8.5 .,

1-

! - ' 7. -Security and Safeguards .120- -3 ,

2 61  ; ,

, +- ,

~8 . Outage 20 ,

0.5 m-$

<t . ;. . > I

.j'*,'

7'~

-9. ) Quality Programs and 670 18.5 2 1 ,  ! .

6 Administrative Controls ~ e! -

+

Q [ 1,, ,

, ~. .

i 1, 10. Licensing Activities N/Ai N/A s .. , <+ ,

'c

'~ 11. ' Training and 50, 1.5 . ,

r.

J+> -

l Qualification Effectiveness .

,>y .,

' '192 Startup Testing .90 2.5 ~

- a - -

' o

. ' c. / '

TOTAL. -3580 100; 2 .10 4 1' -

~

• - " Allocations of inspection. hours to each functional area are , [

s 1 approximations based upon NRC form 766 data. [ a

.  ;. a,

-.W ** " Severity levels are in accordance with NRC Enforcement Policy (10 CFR ~

Part 2, Appendix C).

[ - Data' reflects Reports 85-31 through 86-29 (see Note 1).

, Note 1 Does not include 766. data for IR 86-30. This data will be included with draft report.

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. TABLE 10 4

' INSPECTION ACTIVITIES AND ENFORCEMENT

SUMMARY

, ~(10/1/85 9/30/86) .,

PALO VERDE UNIT 12-Inspections Conducted : ' Enforcement Items Inspection *  : Percent.. Severity Level **' .

Functional-Area-Hours' .of Effort I II III IV V,Dev

-1. Pla'nt ' Operations 1210L 135 11-

, 2. .$$diologicalControls ~160 4 -

3. Maintenance 80 2.5 1

4. Surveillance 80 2. 1 5 . Fire Protection 30 1 7 .,7

6. -

_ Emergency Preparedness 180 5- . ,

-  ?

'7 .

Security and Safeguards 340 10.

I 1-

=,'

. ) 7 ;p -

t 8. Outage <

O' 0

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~

~ 9 .' i Qdality Programs and 640 18.5 -1 , .<

i ,

%s -

~ Administ ative. Controls

'm +

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10. Licensing Activities. N/A N/A j l f.""r' . t -[j h ,

~

M .-11. (Training and- 50 1.5 - + -

^c.- ' xi ,

)'.. Qualification -

f 4 . Effectiveness '

s, N l'2. ~ Containment and Other. 30 1 e' ,

t

't~. .

' Safety Related Structures =  ;

p

13. Piping. Systems and 20 0.5 i

Supports "

~

3 -_14. Safety-Related 20 .1-Components-Mechanical

15. Auxiliary Systems. 0 0

16. ; Electrical Equipment 50 2 and Cables

> 17. - Instrument'a tion..

140 4

.18. Preoperational Testing 250 7

'i '

~

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=1

~

. Inspectioris Conducted iEnforcement Items Inspection *i *

,Percentt ' Severity Level **-

.g

, Functional Area ' Hours .of Effort I II III IV V -i,cv

, a - L19. Startup Testing ..190- 5.0 Tb'IAL 3470 ,

1. 100'.' -

1 c3:2

< * . Allocations'ofl inspection hburs to-each? functional" area,'are^ ,

approximations based upon NRC form,766 data. -f 3 7' 3 ..

, , Severity levels are in accordance with NRC Enforcement. Policy:(10 CFR

~ Part 2, Appendix C).

/ "-

3. . , , , ,

s Data reflects' Reports 85-27 through 86-28'(see Note lj [ '_ v s'

n Note 1 ' ,,

Does not include 766 data for'IR'86-29. Thi, data will be_ included with draft report, ,

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, . TABLE 11

. INSPECTION ACTIVITIES'AND ENFORCEMENT

SUMMARY

a-(10/1/85 - 9/30/86)

, PALO VERDE UNIT 3 Inspections Conducted Enforcement Items Inspection

• Percent  ; Severity Level **

Functional Area ' Hours-of Effort I II III-IV V -Dev s_:

1. Plant Operations -0=

2. Radiological Controls 70 2-

^

3. ~ Maintenance- 0

-4' . Surveillance l 0-1 5.

Fire. Protection 'O m

16. cEmergency Preparedness 0

7. Security and Safeguards 0

8. Outage 0  ;

~

. 9, fQuality Programs and .

830 '20;5. i

• 2 Administrative Controls >

10. Licensing Activities N/A - t ,N/A .- ,

s

11. Training and 0 '

Qualification ' '

Effectiveness

T d c,

- i. -

12 '. Containment and Other 7$0 -18 '

1-Safety-Related Structures ~

l13. Piping Systems and 260- '

7.

Supports , ,

14. Safety-Related '420' 11 Components-Mechanical-

, E15. Auxiliary Systems 130 3

16. Electrical Equipment 570 14.5 and Cables

, '17. Instrumentation 250 6.5

18. Preoperational-Testing 740 17.5 5

4

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_ Inspections Con'ucted d Enforcement Items

~

Inspection

• Percent Severity Level **

-Functional Area = Hours of Effort I II III IV V Dev

19. Startup Testing 0. 0 _

. TOTAL. 3980 -100 .3

• :- Allocations of inspection hours to'each functional. area are approximations based upon NRC form 766 data.

• • Severity levels are in accordance with NRC Enforcement Policy ~(10 CFR '

.Part 2, Appendix C).

Data reflects Reports 85-22 through 86-23 (see Note 1)'.

Note 1

- Does not' include 766 data for report 86-22. This data.will be included with the' draft report.

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