IR 05000423/1987017
| ML20235Z527 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/09/1987 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235Z512 | List: |
| References | |
| 50-423-87-17, IEB-87-001, IEB-87-1, NUDOCS 8710210184 | |
| Download: ML20235Z527 (14) | |
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. ) U.S. NUCLEAR REGULATORY
REGION I
Report No.
50-423/87-17 Docket No.
50-423 License No.
NPF-49 l Licensee: Northeast Nuclear Energy Company ! P.O. Box 270 Hartford, CT 06101-0270 l Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut i l-Inspection Conducted: July 11-September 21, 1987 l Inspectors: W. J. Raymond, Senior Resident Inspector i G. S. Barber, Resident Inspector E. L. Conner, Project Engineer Approved by: d C kM,h 10/9/07 E. C. McCabe, Chief, Reactor Projects Section 3B Date , Inspection Summary: Inspecton on July 11 - September 21, 1987 50-423/87-17 Areas inspected: Routine resident inspection on day and back shifts of: actions on previous inspection findings; physical security; plant operations, including operational status reviews and facility tours; bypass of non-essential diesel generator trips (RI TI 87-04); followup of Allegation RI-87-A-0065 on certified material test reports; review of committee activities; and followup of IE Bulletin 87-01 and licensee event reports (LERs).
The inspection involved ! 197 hours.. Results: No violations were cited.
No unacceptable conditions were identified.
) Licensee followup is warranted on the findings resulting from the facility tour { by the Region I Administrator during the period of August 18-19, 1987 (Detail
6.1).
The question of whether individual emergency diesel generator trip j bypass features should be individually tested was identified for further
evaluation (Detail 7).
Promptness of repair of faulty indicators affecting technical specification compliance and supplementary monitoring while such indicators are inoperable were also identified for evaluation (Detail 10).
, , 8710210104 071014 ' PDR ADOCK 05000423 G PDR j i
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-- - -. _ 'I: I e: i L l' < SUMMARY ' ! An. evaluation of the content and quality of a representative sample of , t l the Licensee Event Reports'(LERs) submitted by Millstone 3 during the . -' period from January 23, 1986 to February 22;-1987 was performed using a ' refinement of the basic methodology presented in NUREG-1022. Supplement i . No. 2.
The results of this evaluation indicate that Millstone 3 LERs have-an overall average LER score of 8.4 out 'of a possible 10 points, compared , .to'a current l industry average score of'8.2.for those unit / stations that - have been evaluated to date using this methodology.
j i Some of the. sore.important requirements for which the discussions are considered to be' weak in the Millstone 3 LERs are the requirements
involving 1) the safety consequences of the event, 2) corrective actions, 'and 3)' personnel error. Deficiencies in the safety assessment discussions prompt. concern about whether or not the potential consequences of.each event are being identified and evaluated. The failure to provide adequate ' personnel error and corrective actions discussions prompts concern as to j whether or not meaningful actions have been taken to prevent recurrence of the event or similar events.
Strong points for the Millstone 3 LERs.are the discussions of the root cause and the failure mode, mechanism, and effect of each failed component.
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y,7 LER QUALITY! EVALUATION FOR.
i ' MILLSTONE 3- < i Introduction L/ In: order to evaluate the overall" quality of the contents of the Licensee Er.nt Reports (LERsl 3ubmitted by Millstone 3 during the period.
from.lanuary 23, 1986. to February 22, 1987, a representative' sample of;the ^ q , i unit's LERs'was evaluated using a refinement of the basic: methodology presented in NUREG-1022, Supplement No; 2.
The sample consists of 15 LERs, which is considered.to be the maximum number of LERs necessary to have-a representative sample (see Appendix A for a list of the LER numbers in the sample).
It was necessary to start the evaluation before the end of the assessment period because the input was due such a short time after the end of the assessment period.
Therefore, not all of the LERs prepared by the unit during the assessment period were available for review.
f Methodology- > The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstracts, and coded fields ! meet the criteria of.10 CFR 50.73(b).
In addition, each selected LER is
compared to the guidance for preparation of LERs presented in NUREG-1022
and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, suggestions were-developed for improving the quality of the reports. The l . purpose of this evaluation is to provide feedback to improve the quality,of-LERs. -It is not intended to increase the requirements concerning the " content" of reporis beyond the current requirements of 10 CFR 50.73(b).
Therefore, statements in this evaluation that suggest measures be taken are j not intended to increase requirements and should be viewed in that-light.
However, the minimum requirements of the regulation must be met, i i l -________-______________-__E
Q Jf; ,t gr i n,< ..rf,. k i .\\- Th'e evaluation-process, for each LER is divided into two parts.
The- -{ .first part of the evaluation consists of documenting coments specific to the content and presentation of each LER.
The second part consists of - determining'a score (0-10 points) for. the text, abstract, and coded fields- [ of each LER.
, 'The LER specific comments serve two purposes: (1) they point out' what the analysts considered to be the specific. deficiencies or observations concerning the informatiose pertaining to.the event, and (2) they provide a basis for 'a. count of general deficiencies for the overall sample of LERs that was reviewed. Likewise, the scores serve two purprses: -(1) they.
serve to illustrate in numerical terms how the analysts perceived the content of'the. information that was presented, and (2) they provide a basis sfor determining an overall score for each LER.
The overall score for each LER is the result ~ of combining the scores for the text, abstract, and coded fields (i.e., 0.6. x text score + 0.3 x abstract score + 0.1 x coded fields score overall LER score).
The results of the LER quality evaluation are divided into two categories:- (1) detailed information and (2) summary information.
The detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A),.a table of the scores for each sample LER (Appendix B), tables of the number of deficiencies and observations for the text,-abstract and coded fields ( Appendix C), and comment sheets containing nar.rative statements concerning the contents of each LER (Appendix D).
When referring to Appendix D, the reader is cautioned not to try to directly correlate the number of comments on a consnent sheet with the LER ] scores, as the analysts has flexibility to consider the magnitude of a j deficiency when assigning scores (e.g., the analysts sometimes make . comments. relative to a requirement without deducting points for that r equirement ). Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the l
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e evaluation of th'e contents of the LERs selected for review and as such represent the analysts' ' assessment of the unit's performance (on a scale of 0 to.10) in submitting LERs that meet the requirements of 10 Cf R 50.73(b) and the guidance presented in NUREG-1022 and its. supplements.
Table 1 presents the average scores for the sample of LERs evaluated for Millstone 3.. In order to place the scores provided in Table 1 in l perspective. the' distribution of the overall average score for.all ' units / stations.that have been evaluated using the current methodology is provided in figure 1.
Figure 1 is updated each month to reflect any . ! changes in this distribution resulting from the inclusion of data for those-l s units / stations that have not been previously evaluated.or those that have j been reevaluated.
(Note: Previous scores for those units / stations that are reevaluated are replaced with score from the latest evaluation). Table 2 { and Appendix Table B-1 provide a summary of the information that is the
basis for the average scores in Table 1.
For example, Millstone 3's ~ average score for the text of the LERs that were evaluated is 8.1 out of a possible 10 points.
From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)) to text presentation.
The percentage scores in the text summary section of Table 2 provide an l indication of how well each text requirement was addressed by the unit for the 15 LERs that were evaluated.
Discussion of Specific Deficiencies i A review.of the percentage scores presented in Table 2 will quickly point out where the unit is experiencing the most difficulty in preparing , I l LERs.
For example, requirement percentage scores of less than 75 indicate j that the unit probably needs additional guidance concerning these l r equir emen t s. Scores of 75 or above, but less than 100, indicate that the unit probably understands the basic requirement but has either: l l (1) excluded certain less significant information from most of the j discussions concerning that requirement or (2) totally failed to address i the requirement in one or two of the selected LERs.
The unit should review l l
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' SUMMARY OF SCORES-FOR MILLSTONE 3 - __'_._._____.._____________________________________________________._______ '..) I - . . _ t- 'f 'i'< Average; 'High' Low 1- -
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, j _______ ____ ___ ' Text-8.1 9.0' 7.0; y6 , ' Abstract' 8.9 9.6 7.0 ' ' ' ! Coded Fields- ' 8.- 9 9.8- ' 7.' 7 i .Overall 8~4 9.2 7.8 , . i a.
.See' Appendix?B foria summary.of scores for each'LER that,was. evaluated.. 'f - - . ! ___________________________________________________________________________ - S i i ' { d
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, , m; ' ..,*m , , w . W,'. STABLE 2; LER REQUIREMENT' PERCENTAGE SCORES'FOR MILLSTONE 3 ,
u------------------------------ .......------------------- w TTEXTs m. - - Percentage c a
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Requirements.[50.73(b)]:- Descriptions Scores-(- )
- ' Plant condition prior to event . 100,(15) L(2)(ii)(A) ' -- - Inoperable equipment that contributed b.
O . (:2 ) ( ii ) (B) - 9(2)(ii)(C)' - Date(s)-and approximate time (s) 83 (15) -l Root cause and intermediate cause(s) 97 (15) l(2)(ii)(D) - '(2)(ii)(E). > - Mode,' mechanism,.and'effect 100 ( 5) - i(2)(ii)(F) --EIIS codes 17 (15) -- (2)(ii)(G)- - - Secondary function affected b ' -(2)(ii)(H).
- Estimate of unavailability 88 ('4) - - (2)(ii)(I). - . Method'offdiscovery 87.(15) .(2)(ii)(J)(1) -LOperator' actions affecting course' 95 ( 7) !(2)(ii){J)(2) - Personnelzerror (procedural deficiency) 82 (11) y(2)(ii)(K) Safety system responses 74.( '3)- - , (12 ) ( i i.) ( L ) - Manufacturer and model no. information 80-( 5) - "( ?(3)' - - - - - - Assessment,of safety consequences.
84 (15) ' ' - ~(4) - - - - - - Corrective actions . 83 (15)- e (5)---- -LPrevious similar' event information 27'(15)
(2)(1) - - - - Text presentation 77 (15)
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'ABSTENCT
Percentage-a Requirements (50.73(b)(1)] - Descriptions Scores (.)
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- Major: occurrences (immediate cause/effect) 99 (15) ' - Plant / system / component / personnel responses 96 (10) - Root cause.information 91 (15) - Corrective action information-83 (15) - Abstract presentation-78 (15)
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vi Percentage ~ ' .y y yp 4 %p.;, ' - Item Number (s) Descriptions Scores ( ) - @ t--------...-_-------------_------_---------__------ - - - - - - - - - - - _., "c R J,1..;2,'andL 3 '- Plant name(unit #),= docket #,'page #s-100 (15) e . r g- ..; w 4. -.,o- ' - - - Title 66 (15)
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,g j bA h[6, and'7. - Event date, LER no., report date 100 (15) ,3 r - p 8 - - -'- '- .Other' facilities' involved 100 (15) %9.j 9 ando10' - , Operating mode and power. level 95--(15) ' 4[
' Reporting requirements 98'(15) -:- ~-- , 4s . F } g. c12 --- - I;4 Licensee contact information 99-(15)- ! i
.g .13. - - - -?. Coded. component failure.information 84 (15) - y e . ' 17 5l.
. 1 14'and 15 - Supplemental' report.information 93'(15) m i l:w ' > - j la T jy a w J '\\ ij g. lg ~)'k';n ' s - q gn ,s
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t l ,- --p. - 9 .--- ------------ x.., < Percentage. scores are the result.of d1viding the total points for a a.
requirement by the. number 'of. points possible for that requirement.
. g/ n.( Note : Some requirements are not applicable to all LERs; therefore, the ' . umber of points possible was adjusted accordingly. ) The number in t p~. ' pa'tinthesis is the' number of LERs for which the requirement was considered . ap)licabl4 $ 2/ L % . , .b. ' )Alpi.cnontsge score for this requirement is ' meaningless as it is not ! pf.
pc s's e t'o determine f rom the ini'ormation available to the analyst whether i h j this@- rqq,direment is applicabfe to a specific LER ' It is always given 100% a $r h if.it is provige.'d and is-alwaisl considered "not applicable" when it is not.
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the!LER specific connents. presented in Appendix D.in' order to ' determine why-
it received'less than a perfect score for certain requirements. ~The text . requirements with'a score of:less than 75'or those with numerous ' deficiencies are discussed below in their order..of-importance.
In addition, the primary l deficiencies in' the abstract and coded fields ~are - discussed.
, Ii 'The. safety assessments, Requirement 50.73(b)(3), for six of the LERs were considered to be inadequate or. marginal. Specific detatis were not . provided to enable the' analysts' to judge the 5,1gnificance of the safety
- consequences of. the events, These details are enumerated in Appendix D,
-Table 0-1.
A detailed safety assessment is r'equired in all LERs and.should include linformation such as: ').'.An assessment,o'f the consequences and implications of the event' - including specifics'as to why it was. concluded that there were .a "no safety consequences", if applicable. 'It is inadequate to- ' state "this event.had no safety consequences or implications" without explaining how that conclusion was reached.
2.
A safety assessment should discuss whether the event could have occurred under a different set of conditions where the safety implications would have been more severe.
If the conditions i during the event are considered the worst probable, the LER i should so state.
] .3.
finally, a safety assessment should name other systems (if any) that Were available to perform the. function of any safety systems that were unavailable during the event.
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Eight of the LERs failed to adequately discuss corrective actions, . Requirement:50.73(b)(4).
Most of the deficiencies noted involved the requirements to discuss those actions taken or planned to reduce the pro' ability of recurrence of the event or similar events. One LER, b LER 86-035-00, failed to discuss whether the corrective action taken to - prevent recurrence (1 e., changing a surveillance procedure to include a
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,. - _ _ _ - - _ _ _ _ - - _ _ - f.; W ' ^ ,., Gf- ,. previously omitted monitor) might;possible need to be implemented in'other .s imilar. procedures as well.. ) j Discussion of the. type of personnel involved in the event (i.e., contractor.' personnel, utility licensed operator,. other utility. personnel) - y /
- was not inclinded. in five of the eleven LERs that involved a personnel
. .y error', Requirement.50.73(b)(2)(ii)(J)(2)(iv).
Also, the distinction as to i whether the personnel error was cognitive or procedural.was not always L provided.. i Adequate information was not provided in six of' the nine-LERs ! involving safety system actuations. Requirement 50.73(b)(2)(ii)(K). As a minimum, the text of the LER must list all safety ' systems that either i > ! -initiated automatically or.had to be manually. initiated as a result of the event.
It is notl suf ficient to simply ~ state "all major equipment responded as' designed".
Requirement 50.73(b)(5)'was not adequately addressed in eleven of the - -fifteen LERs in that their text did not include the necessary information concerning previous similar events.
All previous similar events should be appropriately referenced -(by LER number, if possible) and the history of the or, going problem should be discussed, if necessary. If there have been no previous 'similar events,. the text should state this. This information-is important because it can aid a licensee in determining if there is a recurring problem and whether or not the corrective actions are ef fective.
Thirteen of the LERs did not include all of the required Energy Industry Identification System (EIIS) codes.
Requirement 50.73(b)(2)(ii)(F) requires inclusion of the appropriate EIIS code for each system and component referred to in the text.
Improvement in the text presentation score is possible by use of a , consistent outline format that would present the various requirements in an orderly fashion. Better readability and clearer understanding of the event should result from the use of such a format.
In addition, each author
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- 'l l 'f , i LE < would be prompted _ as to what information to include thus resulting in more ' - complete reports.
See-NUREG-1022. Supplement No. 2, page 36 and 37.
- 'While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), the guidance presented in NUREG-1022, Supplement No. 2.says an abstract should, as a minimum, summarize the f ollowing information from the text: < 1.
Cause/Effect What happened that made the event reportable.
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Responses Major plant, system, and personnel responses as a' result of the event.
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Root / Intermediate The underlying cause of the Causes event.
What caused the component and/or system failure or the personnel error.
4.
Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence.
Millstone-3 had good discussions for all of the above items except I tem 4.
Those corrective actions discussed in the text were not always sunnerized in the abstract.
Reporting requirement information is not necessary in the abstract if space is a problem.
The four items listed above should receive first pr iori ty.
Space was not a problem in the abstracts that were evaluated however; in fact, nearly half of the abstracts were considered brief.
full utilize' ion of the space available is suggested.
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The main deficiency in the area of coded fields involves the title, Item (4).- Thirteen of the titles failed to indicate the root cause and two e failed to adequately indicate the result (i.e., why the event was required I to be reported).
' sile the result is considered the most important part of a the title, the lack of cause information (and link, if necessary) results in an incomplete title.
An example of a title that only addresses the result might be " Reactor Scram". This is inadequate in that the cause and link are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Sureci11ance Test L0p-1 Causes Reactor Scram".
From this title, the reader. knows the cause was either personnel or procedural and surveillance testing was the link between the cause and the result.
Example titles are provided in Appendix 0 (Coded fields section), for some of the. titles that are considered to be deficient.
Another area of the' coded field section that should be discussed is Item (13), coded component f ailure information.
In eleven of the LERs,. this field contained information when'no component failure occurred.
This ! field is not required to 'be completed (i.e., should be lef t blank) in the ! case of " component f aults", an example of which is: a relief valve that I lifts prematurely because it was incorrectly set to the wrong lift pressure.
Table 3 provides a summary of the major areas that need improvement for the Millstone 3 LERs.
For more specific information concerning additional deficiencies, the reader should refer to the information presented in Appendices C and D.
General guidanc' oncerning requirements can be found in NUREG-1022, and Supplement Nos.1 J 2.
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'.T ABLE. 3.
AREAS N0ST-NEEDING IMPROVEMENT f 0R MILLSTONE 3 LERs ! i i Areas Comments-Safety assessment information - All LERs should include a detailed safety assessment.
The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstances and provide information concerning the availability of any backup systems capable of limiting the consequences of the event.
Corrective actions Corrective action discussions should always address those actions ~ taken'to reduce the probability of-recurrence of the event or similar events.
Personnel / procedural error Details should be explicitly stated; the type of personnel involved and the cause of personnel error should be discussed, (e.g., cognitive or procedural).
l ' Automatic / manual safety All safety systems that actt3te system responses automatically or that must be manually initiated as a result of the event should be identified in the text.
Previous similar events Previous similar events should be referenced (e.g., by LER number) or if none are identified, the text should so state.
Ells codes Codes for each component and system referred to in the text should be
provided.
i i Text presentation Improvement in text presentation would be made by using an outline format.
Abstracts Corrective actions discussed in the text should be mentioned in the abstract. Use of as much of the 1400 space limit as possible is suggested.
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Areasi Comments _ ' Coded fields: d' a.
Titles-Titles'need to.be written such that they better, describe the event.
This can be-accomplished.by including the root cause, result, and the link between them in each title.
b.
Coded component-failure This field should be completed only in the event of a' component.
failure; it should be left blank 'for component' faults.
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REFERENCES' 1. - Of fice for Analysis and Evaluation'of Operational Data, Licensee Event ' Repor LSystem, NUREG-1022 Supplement No. 2,.U.S.. Nuclear Regulatory l Commission, September-1985.
2.
Office for Analysis 2nd Evaluation of Operational. Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Comission.
September 1983.
3< Office for Analysis and Evaluation of. Operational > Data, Licensee Event' Report System, NUREG-1022 Supplement No. 1, U.S. Nuclear Regulatory Commission, February 1984.
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i i APPENDIX A i LER SAMPLE SELECTION INFORMATION FOR MILLSTONE 3 l l l '
.- . 4' h; : ['i ,. , g , 'ti ' TABLE'A-1. LERiSAMPLE SELECTION FOR MILLSTONE 3 (423)
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Sample Number-LER Number Comments
86-006-00 '
86-007-00 3' 86-012-00 ESF ' -
86-013-00 SC.0AM/E SF - ,
86-017-00 SCRAM '
86-025-00
.86-031-00 'ESF ,. 8-86-034-00.
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86-035-00 SCRAM <
86-038-00
86-041-00 SCRAM
86-043-00
13 '86-049-00 SCRAM /ESF'
86-051-00 SCRAM )
86-054-00 - A-1
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APPENDIX B EVALUATION SCORES Of INDIVIDUAL LERS FOR MILLSTONE 3
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8 .--------------------------------------------------------------------------- 1 Text 8.3 8.9L 8. 3.
7' 9 8.4 7.6 7'5' 7.0 . . ' Abstract' 915 9.6 7.9.
9.0 7.0 8.8 8.8 9.0-Coded Fields 8.4 7.7 8.9 9.2 8.4 8.4 9.0-8.9
. 8.7 . 9.0 8.2 8.4 8.0 8.1 8.0 7.8 Overall ' - - -... - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -. a LER Sample Number.
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15 Average.
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8.8 '8.1 W Abstract 8.6 8.5 9.3.
9.4 9.4 9.5 9.4 8.9 . Coded Fields 8.9 9.1 8.9 9.5 9.8 9.0 9.3 8.9 s.
- Overall 7.8 8.3 8.7 8.7 9.2 8.8 9.0 8.4-
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See AppendixLA for aLlist'of the corresponding LER' numbers.
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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR MILLSTONE 3 } i - _ _ _ _ _ - _ _ _ _
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+ TABLE 'C-1.. '? EXT DEFICIENCIES AND 05StAviiiONS FOR MILLSTONE 3 . -,..-. ,, i Number of LERs with Deficiencies and-
Observations- ! Sub-paragraph . Paragraph-Description of Deficiencies and Observations Totals' Totals ( ) 50.73(b)(2)(li)(Al--Plant' operating 0 (15) conditions before the event were not . included or were inadequate.
50.73(b)(2)(ii)(E)--Discussion of the status
0 ( 3) ! of the structures, components, or systems that were inoperable at the: start of the 'j event and that contributed.to the event was not. included or was inadequate.
50.73(b)(2)(11)(C)--Fa11ure to include 8 (15) suf ficient date and/or time information, a.
Date.information was insufficient.
i b.
Time information was insufficient.
j 50.73(b)(2)(ii)(D)--The root cause and/or 2 (15) intermediate failure,' system failure, or personnel error was not included or was inadequate, a.
Cause'of component: failure was not
included or was inadequate.
b.
Cause of' system failure was not
l i included or'was inadequate, l 50.73(b)(2)(ii)(El--The failure mode, 0 ( 5)
mechanism (immediate cause), and/or effect ' (consequence) for each failed component was not included or.was inadequate, a.
Failure mode was not included or was inadequate.
b.
Mechanism'(immediate cause) was not included or was inadequate.
c.
Effect (consequence) was not included or was inadequate.
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- t.
i ' , i.
TABLE C-l'. (continued)- Number of LERs with' L Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies'and Observations Totals # Totals ( ) 50.73(b)(2)(11)(f)--The Energy Industry 13 (15) Identification System component function identifier;for each component or~ system was not included.
! 50.73(b) 2)(ii)(Gh--for a failure of a - componen, with mu1tiple. functions, a list. -- ( 0) of systems or secondary functions which.
were also affected was not' included or was i na dequa te'. 50.73(b)(2)(ii)(H)--for a. failure that 1 ( 4) l rendered a train of a safety system - inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(I)--The method of discovery 3 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
a.. Method of discovery for each
component failure was not included or was inadequate.
b.
Method of discovery for each system
failure was not included or was inadequate.
c.. Method of discovery for each
. personnel error was not included or was. inadequate.
Ed.. Method of discovery for each I procedural error'was not included or was inadequate.
C-2 _ _ _ _ _ _. -
,' ( , l i '$'
- L
-. /? I 'f I d . ' ; , }l '}. $ + 4.1 ,/< 3., , t - --i.
, f , _ . .}._ % - , I . :. , p' M ?TABLEC-1.'t(continued)1 ' , 8. ,
- \\
Number of LERs with' Deficiencies'and- ' - ' , Observations t,-
- r Sub-paragraph-Paragraph
,b
- description'of Deficiencies and Observations'
Tot'a l s' Totals-i ) 50;73(b)(2)(ii)(J)(1)--Operator actions that - 1 ( 7) l affectedlthe, course of:the event including-l - operatorEerr_ ors and/or: procedural deficiencies?were not included or were l
- inadequate, boa 50.73(b)(2)(ii)(J)(2)--The' discussion of 5 (11)
' each per_ sonne.1: error was not. included or was Linadequate.
- ..
- a'.
OBSERVATION':,.A personnel error was
implied by:the: text,-but.was not explicitly stated.
tb.
50.73(b)(2)(ii)(J)(2)(1)--Discussion-
.as to'whether the personnel error.was.
' . cognitive:or-procedural _was not:
included'or was inadequate.
c.
50.73(b)(2)(11)(J)(2)(ii)--Discussion
cas to whether the personnel error was contrary to an~ approved procedure, was 'a direct result of an error in an approved procedure, or was associated with.an activity or task that was not-covered by an approved procedure was - not-included or was inadequate.
d-50.73(b)(2)(11)(J)(2)(iii)--Discussion ~
of any unusual characteristics of the , work location (e.g., heat, noise) that " directly contributed to the personnel error was not included or was inadequate.
. . e.
50.-73(b)(2)(ii)(J)(2)(iv)--Discussion
.of the type of personnel involved (i.e.,Lcontractor personnel, utility J.g licensed operator, utility nonlicensed operator. other utility personnel) was not included or was inadequate.
C-3 ,
_.. .s q .
- ..
, . i
- '
l ! ' 1ABLE C-1. :(continued)
.! ] l-l l Number of LERs with i Deficiencies and
3-Observations Sub-paragraph Paragraph
~ Description of Deficiencies and Observations Totals Totals'( )b ^ a 'U 50.73(b)(2)(ii)(K)--Automatic and/or manual 6 (,9) < safety system responses were not included or were inadequate.
- a 50.73(b)(2)(ii)(L1--The manufacturer and/or 1.( 5) I model number of each' failed component was ' ! not included or was inadequate.
' '50.73(b)(3)--An assessment ~of the safety 6 (15) consequences:and implications of the event was not included or was inadequate.
a.
OBSERVATION:- The availability of
i other. systems or' components capable .of mitigating the consequences of the , event was not discussed.
If no other
systems or components.were available, the text should state that none existed, b.
OBSERVATION: The consequences
of_the event had it occurred under l-4 more severe conditions' were not discussed. If the event occurred under what were considered the most severe conditions, the~ text should so l state.
' ! 50.73(b)L4 --A discussion of any corrective 8 (15)
j actions planned as a result of'the event including those to reduce the probability
l of similar events occurring in the future ! was'not included or was inadequate.
! 'l g--- i , i C-4 !
b, ] ' g.
- ;...
., , , 1: l , L TABLE C-1.
(continued) L i l l
' Number of LERs with-Deficiencies and Observations Sub-paragraph . Paragraph a D.escription of Deficiencies and Observations Totals Totals ( ) a; A, discussion of actions required to O correct the_ problem (e.g., return the component or system to an operational condition or correct the personnel-error) was not included or was inadequate.
i b.
A discussion of actions required to
reduce the probability of recurrence of the problem'or'similar: event-(correct the root.cause) was not inclu~ded or was inadequate.
l c.
0BSERVATION: A discussion of actions
J required to prevent'similar failures
in similar and/or other systems (e.g., I correct the. faulty part in all components with the same manufacturer i and model number) was not included or ' was inadequate.
'50.73(b)(5)--Information concerning previous 11 (15) l similar events was not included or was ' inadequate.
l l j ! i l C-5 i - -
- , - _ .. .. . , . p- ' ..
~,z", 7* a .,. u - m d ' TABLEC-1.l(continued)L '
Number of LERs with-l Deficiencies and
Observations j Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals'(- ) 50.73(b)(2)(1)--Text presentation 2 (15)- l .. inadequacies, a. ' OBSERVATION: A diagram would have
aided >in. understanding the text . discussion.
b. 'Taxt contained undefined-acronyms
and/or plant ~ specific designators.
c.
The text-contains'other specific
deficiencies relating to~the readability.
'a. ;The "sub-paragraph total" is a tabulation of specific deficiencies or , observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can' be deficient in the area of both'date and time.information), the sub-paragraph totals do not necessarily add up to the paragraph total.
! b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the number of.LERs for, which the requirement was considered applicable.
, ! ! ! C-6
- - - - .
- ,%
f. i - , '4' J, TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR MILLSTONE 3 Nun 6er of LERs with Deficiencies and Observations Sub-paragraph-Paragraph Description of Deficiencies and Observations Totals' Totals ( ) A summary of occurrences (immediate cause 0 (15) and effect) was not included'or was
- c inadequate.
, A summary of. plant, system, and/or personnel 2 (10) ! responses was not included or was inadequate, a.
Summary of plant responses was not
! included or was inadequate.
! b.
Summary of system responses was not
included' or was inadequate.
c.
Summary.of' personnel' responses was not
included'or was inadequate.
s A-summary of the root:cause of the event 2 (15) ! was not included or wasLinadequate.
i A summary of the. corrective actions taken or 6 (15) planned as a result of the event was not included or was inadequate.
_ i i i C-7 l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ '
'i e ' v J. ' ,. ' f/ ( ,,
- TABLE (C-2.: (continued)
, W E l-Number of LERs with ' , Deficiencies and Observations ' . .Sub-paragraph.
Paragraph ' Description'of' Deficiencies and Observations Totals' Totals ( ) ' Abstract' presentation' inadequacies.
3 (15) .a.
0BSERVATION:= The. abstract contains'
' ~information notJincluded in the text.
! The abstract is intended.to be a summary of the text,-therefore, the- . text'should' discuss-all information i summarized in.the abstract.- ~~ b.
The abstract was. greater than-O s1400-spaces.
_ . c.>.The abstract contains undefined
~ acronyms'and/or: plant specific designators.
, d. LThe abstract contains other specific
y L deficiencies (i.e.', poor- ' summarization, contradictions, etc.). ! a.
The "sub paragraph total" is a tabulation of specific deficiencies or observations within certain. requirements.
Since an LER can have more than ! one deficiency-for certain requirements, the sub-paragraph totals do not necessarily' add 'up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more deficiency. or-observation.
The number in parenthesis is the number of LERs for~which'a certain requirement was considered applicable.
- i i C-8
- -_ i, v'h .,y; . , TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR MILLSTONE 3 Number of LERs with m Deficiencies and Observations Sub-paragraph _ Paragraph Description of Deficiencies and Observations Totals' Totals ( ) -facility Name 0 (15) a.
Unit-number was not included or-incorrect.
b.
Name was not included or was l ' incorrect.- I c.
Additional-unit numbers were included but not required.
Docket Number was not included or was 0 (15) l incorrect.
' Page Number was not included or was 0 (15)- incorrect.
Title was lef t blank or was inadequate.
13 (15)- a.
Root cause was not given or was
inadequate, b.
Result (effect) was not given or was
. inadequate, c.
Link was not given or was
inadequate.
. Event Date 0 (15) ' Date not included or was incorrect, a.
b.
Discovery date'given instead of event date.
l LER Number was not included or was incorrect.
0 (15) Report Date 0 (15)
a.
Date not included.
R .b.
OBSERVATION: Report date was not within thirty days of event date (or s discovery date if appropriate).
I !' ' Other. Facilities information in field is 0 (15) , inconsistent with text and/or abstract.
l Operating Mode was not included or was 2 (15) ! inconsistent with text or abstract.
! !
C-9 l - D
- - _ _ _ _ ! l . p *. . f 'N
< L TABLE C-3. '(continued) < . Number of'LERs with Deficiencies and Observations ! _ _ _ Sub-paragraph.
Paragraph a Description of Deficiencies and Observations Totals Totals ( ) Power' level was not: included or was .0 (15) inconsistent with text or abstract, i Reporting Requirements l'(15) . r a.
The reason.for' checking the.'OTHER"
requirement was not specified in the abstract and/or-text, b.
OBSERVATION: ~It'may have been more
appropriate to report the event under a different paragraph.
c.
OBSERVATION: It may have been
appropriate to report this event under an ! additional unchecked. paragraph.
Licensee to,ntact 1 (15) ' a.
Field left' blank.
b.
Position title was not. included.
c.
Name was not included.
O d.
Phone number was not included.
O Coded Component'f ailure Information 12 (15) a.
One or more component failure
, ' sub-fields were left blank.
b.
Cause, system, and/or component code
is inconsistent with text.
c.
Component failure field contains data
when no component failure occurred.
d.
Component failure occurred but entire
i field left blank.
C-10 . .. _. _ _ _ _ _. _
---_-- .. _ _ _ ' Of . [v => b j
- 4 k
u ,. . l TABLE C-3. :(continued):
-l ! ' Nunter of LERs with . Deficiencies and . Observations
Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( i ., Supplemental Report 1 (15) 4.
Neither "Yes"/"No" block of;the
supplemental report field was ' checked, b.
'The block checked.was-inconsistent
, with the text.
' Expected submission date information is 0 (15) - LV t inconsistent with the block checked in I t em '(14 ). i , , . The "sub-paragraph total" is.a tabulation of specific deficiencies or a.
- !' observations' within cer tain' requirements.
Since an LER can have more than - .one deficiency for.certain requirements, the sub-paragraph totals do not necessarily' add up to the paragraph total.
.b.
The " paragraph total" is the number of LERs that have one or more requirement ' deficiencies or observations. - The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
! t ! t i C-11 _ _ _ _. _... _. _ L
l .... ,
j i i .
APPENDIX D LfR COMMENT SHEETS FOR MILLSTONE 3 ,
l _ _ _ _ _ _ _ _ _ _
_ - _ - - - _ _ r i I i ' f
i TABLE 0-1.
SPECIFIC-LER COMMENTS FOR MILLSTONE 3 (423) f , < Sec t ion -- Comments _ 1.
LER Number: -86-006-00
Scores: ' Text =~8.3 Abstract = 9.5 Coded fields 8.4 Overall - 8.7' Text 1.
50.73(b)(2)(ii)$--Date/timeinformationis inadequate.
How long did it take to secure the
penetrations and when will the form be available for i use? l 2.
50.73(b)(2)(ii)(f)--The Energy Industry Identification System codes for each component and/or t system referred to-in the text is not included.
3.
50.73(b)(3)--The safety assessment-did not include an i j evaluation of severity of the event.
In the
evaluatio'n it would be helpful to indicate whether or l not.a p.ressure differential,can be maintained with the seals missing'and whether~other systems are
available to help mitigate the consequences if a pressure differential cannot be maintained.
4.
50.73(b)(5)--Information concerning previous similar '
events is not' included.
If no previous similar.
j events are known, the text should so state.
.: i Aostract 1.
No comment.
I Coded Fields 1.
Item (4)--Title: Root cause is not included. A more I appropriate title might be " Violation of Pressure ! Boundarios Without Proper Notification due to a
Deficient Work Order Authorization Procedure".
l 2.
Item (9)--Operating mode is not included.
i ! 3.
Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(ii).
4.
Item (13)--Component failure field contains data when ) no component failure occurred.
I f D-1
--. =,..r.
-[?'lq jY, y.- ' 4:-
L 1 TABLE D-1.
SPECIFIC.LER COMMENTS FOR MILLSTONE' 3-(423) } , , b . . ~ . .. ' , nn Section Coment s J 2.
LER Number: 86-007-00'
s t ! i ScoresajLText - 8.9 Abstract - 9.6 Coded Fields 7.7' Overa11'- 9.0- " Texts 4 ' !- L 1, '50.73(b)(2)(11)(F)--The Energy' Industry Identification System codes for each component and/or ' system referred to in the' text is not-included.
2.. 50.73(b)(2)(ii)(I)--Discussion of"the method of a ' Y ' discovery of.the Technical Specification violation is .,.
- g
' gr not included.
- J g, 3, 50.73(b)(5)--Information concerning previous similar events.is notLincluded.:.If no previous similar , g ' events are known, the text'should so' state.
. At[s trac t 1.
0BSERVATION: The deportability requirements'are not a necessary in. the: abstract.
Space.then would be .i .7 .available for more detailed summaries of causes, ' ' .results, and corrective actions.
m . .. 1.
Item (4)--Title: Root cause (personitel error) is not ' Coded fields included.- Also the result is inaderjuate and the Technical Specification violation isinot defined. A better' title might be: "Verificatidri of the Position wir.
of Inoperable Containment Penetrailbn Breakers Was Not Performed Due' to Personnel Er}nt - Technical Specification Violation".
.; ~ ' y -
' 2.
Item (9)--The operating' mode in iteld differs from text or abstract. The text and ab'stract indicate the E-operating mode was "2".
- ' 3.
Item (13)--Component f ailure field contains data when U no component failure occurred.
e ! , h5
- f t' '
i , 0-2 f _ _ _ -.. -. _ _ _ _ _ - - _ _ - -.
_ _ _ _ - _- ,... g TtBLE D-1.
SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) Section Comments 3.
LER Number: 86-012-00 Scores: Text 8.3 Abstract - 7.9 Coded fields 8.9 Overall - 8.2 Text 1.
50.73(b)(2)(ii)(C)--Time of the restoration of the feedwater isolation and the taking of manual control " of the bypass valves is not included.
2.
50.73(b)(2)( ti)(F )--The Energy Industry ' identification System codes for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. All ESF systems that actuated properly should be named including those which were actuated manually.
4.
50.73(b_)151--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
5.
A logical transition does not exist between all ideas.
ADstract 1.
50.73(b)(1)--Summary of cause inf ormation is inadequate.
The abstract should indicate that ILC technicians shorted out the signal because the probes s they were using were too long.
2.
50.73(b)(1)--Summary of corrective actions taken or ' planned as a result of the event is inadequate.
The corrective actions taken to prevent recurrence are not mentioned in the abstract.
3.
Abstract does not adequately summarize the text.
Additional space is available within the abstract i field to provide the necessary information but it was J not utilized.
,. , Coded fields 1.
Item (4)--Title: Cause is nct included. The phrase '- " - - Caused by I&C Technicians Accidently Shorting i Out A Pressure Signal During Testing" would add to I the current title.
l 2.
Jtem (13)--Component failure field contains data when l I no component failure occurred.
faulted components need not be entered in Item (13).
0-3
I
.__ _- .i-k 3 p'o K ' ]1 4 <
'in ., : ct N l[ g' g i J TABLO V U USPICIFIC;LER COMMfWTS FOR MILLSTONE 3 ~(423) .s y 3.: .# . Ek r ' .;, g k y:3
-Section
Comments ! w v. Jty
- 4.
LER' Number:\\BS-.013-00 , n s
, Scores: Text - 7.9' Abstract + 9.0 Coded Fields - 9.2 Overall'- 8.4 ' ' ' Text-1.
- 50.73(b)(2)(ii)(0)--The root and/or-intermediate H d cause discussion concerning setpoint problems is ' 4(' . inadequate. Ac discussion.was not included as to why , ." the-relief valve setpoint was low and-the FRVBV . controller gain was high.
' ?., 50.73(b)(2)( 11 )( F )--The Energy. Indus try. < Identification. System codes for each component and/or . .
, system referred to in the text is not included.. '3.
. 50.73_(b_)(2)(ii)(K)--It is insufficient to state that ali safety systems actuated properly.
As'a minimum, , . a list of safety. systems.which actuated should be' provided.
4.
50.73(b)(2)(i1)(L)--Although no components actually g failed, and therefore, identification is not s M technically required, it would be helpful to identify ' the faulty relief valve and controller.
' k 5.
50.73(b)(4)--Without knowing why the settings were y'
wrong, it is not possible to know if resetting of the -
,' , . ? ' setpoints is suf ficient to prevent recurrence (see ' , '/ text comment number 1).
'k
s \\A 6.
50.73(b)(5)--Information concerning previous similar
' ' ' s events is not includid.
If no previous similar ' events are known, the text should so state.
.A s , ' = Ab$ll'41c f 1.
No ' c ommen t. . ..o. . i Codec Fields s 1.
Item (4)--Title: Root cause (improper valve and < !' controller settings) is not included.
Preferably, ' the reason for the improper settings would be given n i }; t as the root cause (see text comment number 1).
1 2.
11em (131--Component failure field contains data when no c.omponent failure occurred.
Faulted component
information need not be identified in this field.
\\ , i ) E ( , $. 't D-4 l ,o.
t
. '{f ! b l - , _ _ _ - _ _ _. ___ __ A
_-__ - - - - _.
- - - - _ _ .- , i,}g -- f;, ., i jmi , , g ', N
i T A'8L E ' 0-l '. SPECIFIC LER' COMMENTS FOR MILLSTONE 3 (423) . [' 'Section Comments- ' ' 5.
LER Number: ;86-017-00 . Scores:. Text. 8.4 Abstract - 7.0 Coded Fields - 8.4-Overall - 8.0
- ,.'
Text.
1.
50.73(b)(2)(ii)(C)--Time:of the plant's return to . normal. operation 1s not' included.
2.
50.73(b)(2)(11)(F)--The Energy _ Industry identification System codes for each component and/or { _ system referred to in the text is not included.
3.
50.73(b)(2)(11)(K)--Discussion of automatic and/or.
' manual safety system responses is inadequate. A list of the safety systems which responded to the-trip is not included.
'
4.
50.73(b)(5)--Information concerning previous similar j events is not included.
If no previous similar events are known, the text should so state.
-1 T Abu.act 1, 50.73(b)(1)--Summary of-the safety system responses ! .is inadequate.
See text comment number 3.
2.
50.73(b)(1)--Summary of the root cause is inadequate.
Discussion of the attempts to find the i.
root cause is not included.
3.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included, s Discussion of the. ongoing review-of the computer ' alarm log is not included.
I c 4.
OBSERVATION: The deportability requirements are not
necessary in tne abstract.. ' Coded Fields 1.
Item (4)--Title: Root cause is not included.
Acronyms should be used in the title only when space is limited. A better title might be: " Solid State-Protection System Alarm of Unknown Origin Results in Reactor Trip".
' 2.
Item (13)--One or more component failure sub fields are blank.
D-5 ! u = _
_ 7_ - .gy ; r, " . . 1 e I ..[' < iTABLE D-1.
.SPECIflC LER COMMENTS FOR MILLSTONE 3:(423); Section-Comments m 6. ILER' Number: 86-025-00 Shores: Text ='7.6 . Abstract = 8.8 Coded fiel!1s - 8.4 Overall = 8.1 KText . 1 '.. 50.73(b)(2)(ii)(C)--Time of placing Control Room Emergency Ventilation. System in the' recirculation mode (first paragraph)L and time of. immediate corrective action (nextl to last paragraph) is not included.
~ '2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System name codes for each component .and/or system referred to in.the text is not included, c m 3.
' 50.73(b)(2)(ii)(I)--Discussion of the. method of discovery of the monitor not being operable as required by the plant Technical Specifications is not included.
_~ 4; 50.73(b)(2)(ii)(J)(2)--01scussion of the personnel error / procedural deficiency is. inadequate.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether-the personnel error.was cognitive or procedural is not' included.
50.73(b)(2)(li)(J)(2)(iv)--Discussion of-the type of personnel. involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
5.
50.73(b)(3)--Discussion'of the assessment of the safety consequences and implications of the event is inadequate.
It is not clear whether monitor < 3HVC*RE16A (alone) would have been able to start the Control Room Emergency Ventilation or was just available to provide indication.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
It appears that an additional long' term solution would be to change
procedures such that modifications (to any safety ' equipment) could not be made prior to their approval I by the PORC.
(It is assumed that PORC approval for
this modification would mean that the monitor response time problem was resolved such that the response time would have net functional specifications for the monitor).
] ! J 0-6 - _ - _ - _ _ - _. --
_ _ - -. , ' f,; y.... ! J vTABLE D-1 LSPECIFIC LER CDP.MENTS FOR MILLSTONE 3'(423) . Section Comments < - 6.~ 'LER-Number:- 86-025-00-(continued) 7.- A logical transition does not exist between all ideas.
. 8.
'Some ideas are not presented clearly (hard to follow).
' ~ Abstract - 1.
50.73(b)(1)--Summary of cause information. is inadequate. The abstrs;t would be.somewhat clearer if there was an. explanation'of'why (how) installing ' an unapproved software modification. led to a _ " technically" inoperable monitor.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of'the event is inadequate.
See text connent number 6.
3.
OBSERVATION: The abstract is intended to be a summary.of the text; therefore, the' text must inclu'de all information summarized in the abstract.
This abstract contains information that.was not included in the text.
Coded fields - 1.
Item (4)--Title: Cause and result are not included.
A better-title might be " Installation of an Unapproved Software Modification Results In A Radiation Monitor That Did Not Meet The functional Requirements of.the Technical Specifications".
2.
Item (13)--Component failure field contains data when no component failure occurred.
..
. 0-7 l l
t _ _ __ ._ _ _. _ _ _ _. _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _. _. _ _ _ _
_ _ _ _ .' g.
Q;.. , . > . I eTABLE:D-1.
SPECIFIC;LER COMMENTS >FOR MILLSTONE 3.(423).
'Section" Conwents-7.
'LER Number:- 86-031-00: . Scores: -Text - 7.5 Abstract - 8.8' Coded Fields - 9.0: Overall = 8.0 ~ Text 1.
50.73(b)(2)iti)(F)--The Energy Industry Identification System codes for each component and/or , system referred to in the text.is not included.
2.
50.73(b)(2)(ii)(J)(2)--Discussion of the. personnel , error / procedural deficiency is inadequate.
Some u: explanation as to why the oversight occurred would be helpful, especially for evaluating the corrective . actions discussion.
.50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the' type of personnel involved (e..g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not. included.
3.
50.73(b)(2)(1))(L1--Although the detector did not actually fail, it would be useful to identify the make and model number of the detector anyway.
. ~4.
510.73(b)(3)--The safety assessment should provide justification for the conclusion that~there were no safety implications, f or example, justification could be that backup systems were available to detect and/or prevent any problems from a chlorine leak.
5. - 50.73(b)(4)--See text comment 2.
Are other systems _ being checked to see if they should also be added to the surveillance schedule? 6.
50.73(b)(5)--Information concerning previous similar
events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
The use of acronyms should be avoided in a title unless space is a problem.
2.
Item (13)--Component failure field contains data when no component failure occurred.
0-8 _ _ _ _ _ _ - _ _ __ _
_ ,; % 7f-T ABL E._0-1.
. SPECIFIC LER COMMENTS F0'R MILLSTONE 3 (423) 'Section Comments .'8._ LER Number: 86-034-00 ' Scores: Text - 7.0 Abstract = 9.0 Coded Fields - 8.9 Overall = 7.8 Text.
1. - 50.73(b)(2)(ii)(C)--The date of the previous monitor calibration is not included.
- 2.
- 50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes.for each component and/or
' system referred to in the text is not included.
, ,
'3.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the omission of_the monitor surveillance in the procedures is inadequate.
The text does not mention the ongoing review of surveillance procedures as stated in the abstract.
4.
,50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate.
How often were the two surveillance procedures, which were believed to surveil the sampler flow rate monitor, used? Why wasn't the discrepancy noted earlier?
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. OBSERVATION: The availability of other systems, components, or means (e.g. personnel actions, procedural requirements, etc.) capable of mitigating the consequences of the event were not discussed.
If no other systems, components, or means are available, it would be helpful to state so in the text. Were other radiation monitors available in the area of the Ventilation Radiation Monitor to detect radiation if the stated monitor had not been l calibrated correctly? 6.
50.73(b)(4)--Discussion of corrective actions taken L or planned is inadequate. Were other similar ' monitors and corresponding surveillance procedures examined? 7.
50.73(b)(5)--Information concerning previous similar events is not included, if no previous similar events are known, the text should so state.
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- --- _ _ , q., W , , ' TABLE D-1. - SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) 'Section-Comments 8.
LER.. Number: 86-034-00'(continued) . Abstract: 1. - '50.73(b)(1)--Summary.of correcttve actions taken or -, planned as a result of the event is inadequate.
See text comment. number 6.
2.
OBSERVATION: Deportability requirements are not.
necessary in the abstract if space is limited.
Coded fields ~ 1.
Item (4)--Title: Root cause (procedure error) is not . included.
It is best to avoid the use of acronyms in the title unless space is a problem.
. ! 2.
. Item (13)--Component failure field contains data when no component failure occurred.
h
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. D-10
l I
l (- _ _ _ - _ - - - _ _ - _ _ _.
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i ( TABLE 0-1.. SPECIfl0 LER COMMENTS FOR MILLSTONE 3 (423) L L I' Section Consnen t s : i . 9.
LER Number: 86-035-00~ . Scores: Text - 7.3 Abstract - 8.6 Coded Fields - 8.9 Overall - 7.8 Text 1, 50.73(b)(2)(ti)(A)--The power. level at the time of-the scram would be good information to provide in the text (as it was in the abstract).
2.
'50.73(b)(2)(ii)(C)--Time of the scram is not provided in the text.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes for each component and/or-system referred to in the text is not included.
4.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course ot' the event is inadequate.
Was the manual rotating and working of the screens a norraal evolution (i.e., one covered by a procedure and one for which the operators are trained)7 5.
50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency error is inadequate.
, 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
50.73(b)(2)(li)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The i safety equipment (systems)'that performed its intended safety function should be named.
l l 7.
50.73(b)(4)--Discussion of corrective actions taken , or planned is inadequate.
i ) A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included.
- b 8.
50.73(b)(5)--Information concerning previous similar i events is not included.
If,no previous similar events are known, the text should so state.
D-11 _ _ _ _ _ _ _ _
c] . ,.... t + ;,: ' . ,, . TABLE 0-1.
SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) -Section Comments . . I
- 9.
LER Number: 86-035-00 (continued).
i Abstract' 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment number 7.
2.
OBSERVATION:..The abstract is intendedL o be a t summary of the text; therefore, the text must include all information summarized in the abstract.
This- ,. abstract contains infornetton that was not included in the text.
Coded fields l '. Item (4)--Title: Cause information is inadequate.
A better title might be " failure To Anticipate The Rate of fouling On The Main Circulating Pump Intake Screens During Maintenance Activities Results in a Reactor Scram Due To Low Condenser Vacuum".
2.
-Item (13)--Component failure field contains data when no component failure occurred.
. l l 0-12 i L
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L
- TABLE D-1.
SPECIFIC LER COMME,.'TS FOR MILLSTONE 3 (423) Section Comments i 10. LER Number: 86-038-00 . Scores: Text = 8.1' Abstract = 8.5 ' Coded Fields - 9.1' Overall 8.3 y Text ' 1.
50.73(b)(2)(11)(C)--Time information concerning how long the action statement allowed for the repair is not included.
' 2. - 50.73(b)(2)(ii)(F)--The Energy Indus try . . Identification System codes for each component and/or t system referred to in the text is not included.
3.
50.73(b)(2)(ii)(J)(2)(iv)--01scussion of the type of personnel involved (e.g.. contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) in preparing and executing the work order is not. included.
4.
50.73(b)(3_}.--The safety assessment mentions a potential inability to maintain a slight negative pressure but does not explain the possible consequences of not maintaining the negative pressure, nor does it discuss whether or not other systems were available to help mit4ga,te the consequences of the loss of the pressure differential.
l . Abstract-1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The fact that the penetration was sealed within the action statement-time limit was not mentioned, nor was the fact that other open work orders were revi'ewed to insure that they were all under the new program.
Coded fields 1.
item (4)--Title: Root cause (improper penetration and pressure boundary identification) is not included.
2.
Item (13)--Component failure field contains data when {
no component failure occurred.
j l 0-13
_ _ _ _ _ _ _ _ _ _ - -
__ _ _ _ _ J. ;ts '7y y J ' TABLE 0-1._ SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) [' 'Section Conrnent s . 11..LER Number: 86-041-00 Scores: Text - 8.4: Abstract - 9.3 Coded fields - 8.9 Overall - 8.7
.. Text 1.
50.73(bl(2)(ii)(f)--The Energy Industry ,ldentif'ication System codes'for each component and/or system referred to in the text is not included.
2.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. What safety system;" components." responded to the reactor trip? 3.
50.73(b)(2)(11)(L)--Identification te.g., manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4.
50.73(b)(4)--01scussion of corrective actions taken or planned is inadequate.
How often was surveillance periormed.on the FBRV positioners, and was the frequency of surveillance changed until new positioners were installed? 5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are Known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of safety system responses after the trip are not included.
See text comment number 2.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 4.
3.
OBSERVATION: Deportability requirements are not necessary in the abstract if space is limited.
Coded fields 1.
Ite# (4)--Title: Cause information (valve positioners and limit switches out of adjustment) is not included.
Acronyms should be avoided in the title unless space is a problem.
2.
Item (12)--Position title is not included.
0-14 ! _ _ _ _ _ _ _ _ - _ _ _ - ._.
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SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) ' !. Section-Comnents '
- ..
112e.LER: Number: 86'-043-00 Scoresi Text - 8.2-. Abstract 9'4-Coded Fields 4 9.5 Overall - 8.7, . L Tex t.
1.
50.73(b)(2)(1))(F)--The Energy Indnstry Identif.1 cation. System codes:for=each component and/or system referred to in the' text is not included, e
- 2.
-50.73(b)(2)(11)(H)--When were the. valves originally-installed?- 3.
50.73(b)(3)--Discussion of the assessment of the ~ safety consequences.and implications of the-event is.
inadequate. An estimate of the magnitude of the higher radiation releases would be appropriate.
-4.
50.73(b)(5)--Information'concerning previous similar - ' events is not included.
If no previous similar events are known, the text should so state'. Abstract 1.
No comments.
Coded Fields 1.
Item (4)--The word-"Non-Conservative" in parentheses
af ter the: word " Incorrect" would be a good addition to the titie. 'In addition, the~phas_e " -.- Vendor i - Did Not Address Final Settings In The Supplied Procedures" would help explain the cause.
2.
Item (13)--Component failure field contains data when L no component failure occurred.
) i i I i i D-15 l
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lABLE'D-1.- SPECIFIC' LER. COMMENTS' FOR MILLSTONE 3 (423) Section' Comments 11 3. LER Number: 86-049-00 ' Scores:. Text - 9.0 ' Abstract - 9.4.
Coded Fields - 9.8-Overall - 9.2 . Text 1.
50.73(b)(2)(ii)(C)--It would be helpful to know when the load increase was started.
_ 2.
50.73(b)(2)(11)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is i not included. -The text does not indicate whether or not the operators were following the procedure properly when the event occurred.
Abstract 1.
No comment.
Coded Fields-1.
No comment.
i 0-16 _ -. - _ _ _ - - - _ _ - _ _ - _ - - S Ej TABLE D-1.
SPEClfl0 LER COMMENTS FOR MILLSTONE 3 (423) Section Comments 14. LER Number: 86-051-00 Scores: Text.
8.4 Abstract = 9.5 Coded Fields - 9.0 Overall - 8.8 L Text 1.
50.73(b)(2)(ii)(f)--The Energy Industry _ i Identification System codes for each component and/or system referred to in the text is not included.
2.
50.73(b)(2)(it)(K)--Discussion of autonatic and/or manual safety system responses is inadequate. The safety systems which responded to the trip were not listed.
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
Discussion of any plans to correct the feedwater isolation valve packing leak is not included.
4.
50.73(b)(5)--Information concerr.ir.g previous similar events is not included.
If no previous similar events are known, the text should so state.
5.
A supplemental report appears to be needed to describe the results of checking the feedwater isolation valve's local terminations during the next shutdown.
Abstract 1.
OBSERVATION: The deportability requirements are not necessary in the abstract if space is limited.
Coded fields 1.
Item (14)--The block checked appears to be inconsistent with information provided in the text; see text comment number 5.
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.c ' i i T TABLE D-1.
SPECIFIC LER COMMENTS FOR MILLSTONE 3 (423) Section Coment s 15.
LER Number: 86-054-00 Scores: Text - 8.8 Abstract = 9.4 Coded Fields = 9.3 Overall - 9.0 I Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate l-cause discussion concerning the failure to establish a fire watch is inadequate. How long does it " typically take to make a containment entry? l 2.
50.73(b)(2)(11)(.1)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
3.
50.73(b)(2)(ii)(L)--Was there anything unique to the valve (e.g., its size, design, material, 'etc.) that made it more susceptible (than any other valve) to damage from this source? If yes, information concerning identification of the valve should be provided.
., 4.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was anything done to prevent future damage to valves and' piping during excavation work? Abstract 1.
No comment s.
Coded fields 1.
Item (4)--A slightly better title might be ' Impossible To Establish A fire Watch In Reactor Containment (While in Mode 1) Within The Time Allotted in The Technical Specifications".
2.
Item (13)--One or more component failure sub-fields are blank.
3.
Item (13)--Cause, system, and/or component code . appears inconsistent with information provided in the text.
It appears from information provided in the text, that the cause should be "A".
D-18 }}