IR 05000443/1987013

Insp Rept 50-443/87-13 on 870505-0706.Violations Noted.Major Areas Inspected:Work Activities,Procedures & Records Relative to Design Control,Mods & Testing.Quality of Evaluation of LERs During Period Apr 1986-Apr 1987 Encl

ML20236E677
Person / Time
Site:	Seabrook
Issue date:	07/23/1987
From:	Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236E633	List: IR 05000443/1987013 ML20236E629 ML20236E655
References
50-443-87-13, NUDOCS 8708030046
Download: ML20236E677 (57)

Text

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o U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-13 Docket N License N NPF-56 1

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Permit N .CPPR-135 Priority -- Category B/C I Licensee: Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Unit 1 Inspection at: Seabrook, New Hampshire Inspection conducted: May 5 - July 6, 1987 Inspectors: A. C. Cerne, Se 'er Resident Inspector D. G. Rusc~ t , Resident Inspector Approved by: r, 1 5 f 4 T. C. Els g Chief, Reactor Projects Section 3C Date Inspection Summary: Inspection on May 5 - July 6, 1987 (Report No. 50-443/87-13)

Areas Inspected: Routine inspection by two resident inspectors of work activities,

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procedures, and records relative to design control, modifications, testing, main-tenance, surveillance and plant operations during cold shutdown. The inspectors also reviewed licensee action on previously identified items, including licensee event reports (LER), and performed plant inspection-tours. The inspection involved 280 inspection hours by two NRC inspector Results: One violation was identified concerning the conduct of safety evaluations performed under the temporary modification program. Licensee corrective action was taken during the reporting period. Weaknesses in the area of post-modification testing were noted during inspection of design changes to the atmospheric steam dump valves and the startup feedwater pump (SUFP). The SUFP issue remains unre-solved and additional NRC inspection will be focused in this area. Increased licensee attention in the area of equipment tagging appears warranted based on inspection findings and the flooding event of July 3, 198 Attachment I to this report is an assessment compiled by the NRC Office for Analy-sis and Evaluation of Operational Data (AE0D). This document provides an evalu-ation of the quality of Seabrook's LER Qeogg h g G

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.v DETAIL ' Persons Contacted

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W. B. Derrickson, Senior Vice President, New Hampshire Yankee (NHY)

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_ C. Feigenbaum, Vice President, Engineering and Quality Programs W. J. Hall, Regulatory Services Manager D. E. Moody, Station Manager P. M. Richardson, Training Center Manager G. S. Thomas, Vice President, Nuclear Production J. M. Vargas, Manager of Engineering-J. J. Warnock, Nuclear Quality Manager Plant Status During this reporting period, the plant remained in operational Mode 5, cold shutdown, with primary temperature about 115 degrees F and depressurize On May 23, 1987, one phase of a capacitor bank on the construction power feeder line to the owner's management building (0MB): arced over. The OMB is located outside the protected area and the construction power is supplied by the Exeter & Hampton Electric Company and is not connected to the station power network.' This incident was of no safety signific-ance, however the noise generated by the arc-over could be heard from the nearby beaches and media interest was generated. The licensee made a courtesy notification to NRC headquarters via the Emergency Notifica-tion System-(ENS). On July 3, 1987 approximately 20,000 gallons of borated water was inad-vertently drained from the refueling water storage tank (RWST) to the containment, floor via the "A" train residual heat removal (RHR) system which was open to atmosphere because of the removal of the "A" train RHR suction relief valve (RC-V-24). The drain-down flow path was partially established following clearance of tags for testing of RH-FCV-610, the RHR mini-flow recirculation valve. Tags for RH-V-35 were later cleared under partial release completing the flowpath through the suction cross-over leg between the charging and RHR systems. The cause of the incident was personnel error in the conduct of equipment tagging operation The inspector responded and witnessed licensee corrective action includ-ing review of the operator's log, computer data logger, instrument re-corder traces and discussions with operators on shift as well as licensee managers. He verified by observation inside containment that licensee activities to recover from the event including cleanup and retagging were in progress. There was no safety impact to this event under current plant conditions. The majority of the water flowed into the containment recirculation sumps located directly below RC-V-2 ,

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w Based upon this event and several prior discussions between NRC and lic-ensee representatives concerning the NHY tagging program (refer to para-graph _9 of this report), the NHY equipment safety tagging program will

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'be the subject of specific future NRC inspectio . Plant Inspection Tours The inspectors observed work activities in progress, completed work and' plant status in several areas during general inspections of the plant. They ex- !

amined work for any obvious defects or noncompliance with regulatory require-ments or license conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspectior, records, material identification, . nonconforming material identification, housekeeping and equipment preservation. The inspectors interviewed station staff, craft, quality inspection and supervisory personnel as such personnel were available in the work area !

During frequent control room observation periods, the inspectors reviewed control room -logs and records including night orders, shift journals, shift turnover sheets, completed-Repetitive Task Sheets (RTS), the temporary modi-fications log, weekly surveillance schedules and control board indication *

Specific note was taken of equipment in " pull-to lock" conditions, equipment tagged, alarm status and adherence to Technical Specifications (TS) Limiting i Conditions for Operation (LCOs) and Action Statement ' During various plant inspections and visits to the control room for observation of plant operations, the inspector examined the following components, conditions and activities, noting appropriate licensee cor-rective action, where required:

(1) Verified reactor coolant system (RCS) and connected system boron concentrations to be in accordance with operating license (NPF-56)

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condition i (2) Noted one cover nut on valve CS-V-496 to be of a different grade material than'was specified on the valve design specifications and confirmed that this condition had been documented on nonconformance report (NCR) 82/001448 and accepted with the concurrence of the valve manufacture (3) Identified cracking and peeling of paint in the polar crane rail trench inside containment and verified that a work request (WR 87W003995) had been initiated to repair this condition and reviewed disposition to a request for engineering services (RES) 87-0935 which added the total crane trench surface area to the " Unqualified l Coatings Log" as a conservative engineering assumption as to the impact of flaked paint on containment sump recirculation flow.

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S-(4) Questioned a discrepancy between the physical location of the con-tainment level elements,' (CS-LE-2384 & 2385) and their depiction on'NHY piping and instrumentation diagram (P&ID) 1-CBS-820233. The j inspector confirmed that the NHY' drawing was revised (Rev.9) on June

18, 1987 to reflect the current configuration per engineering change authorization (ECA 99/116211A).

(5) Identified a leaking air supply to the solenoid (1-SI-FY-2419) for safety injection (SI) valve, SI-V-157 and checked licensee initi-ation of a work request (87W005196) on June 9, 1987 to repair this conditio (6) Noted missing plugs on the test posts for instrument tubing related to containment spray pressure transmitters, CBS-PT-2312, 2313, 2314

& 2315 and checked licensee initiation of a work request (87W005394)

on June 17, 1987 to install the required plug (7) Questioned the acceptability of an apparently abandoned ground cable running inside "A" train cable trays located in the mechanical penetration area. He confirmed disposition on June 11, 1987 of an ..

RES (87-0844): requiring removal of the cable per grounding notes and details (UE&C drawing 300226) and in accordance with work con-trols for BISCO seals per NHY procedure ASP-1 (8) Discussed with on-shift operating personnel the incoricct status of a danger tag on valve CS-V-143 and a caution tag on valve SI-V-114 in relation to their respective tagging orders, 87-1005 and 86-1868, which already had been cleared. He verified that incorrect-tags were subsequently removed and that the status of other older tagging orders will be evaluate ;j (9) Checked the positioning of SI flow transmitter equalizing valves, SI-FT-918-V6 & SI-FT-922-V6, verifying procedural controls (IS1668.110 and .112) for closing'the subject valves prior to re-turning the SI flow transmitters to operable service. This includes documented evidence of signature and second person verification of i this operation as a critical step in the instrument calibration )

proces (10) Identified, over the course of this inspection, the following fire doors either fully open or ajar: P902, P1203, P1208, D304. The inspector also noted a health physics door, P408, which would not latch and which was not being controlled by its associated card reader. He discussed the as-found door conditions, as appropriate, I with station staff personnel located in the respective areas, sta-tion staff management and with the security department superviso He observed subsequent cui recthe action to door hardware, where applicable, to access controls and to the dissemination of the management position of vigilance with respect to maintaining fire doors closed when not within view of a fire watc _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ -

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(11) The inspector reviewed the following work requests and verified compliance with the licensee's work control program:

87W001689 N2 pressure alarm does not reset on FW-V57 87W001150 RC-V-81 failed to close 87W004556 Pinhole leaks on CC-V298 87W001741 Low oil cutout switch problem on SY-BKR-163 During frequent inspections of the control room and periods of observa-tion of licensed operator activities, including random visits on all

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three shifts, the overall control room environment was monitored utiliz-ing the guidance established by IE Circular No. 81-02. With respect to licensed operator professionalism, noise control, control room access,.

and control room appearance, acceptable standards of performance and .

working environment were in evidence and being maintained. In this area  !

of inspection, as well as the other plant inspection tour' items, noted above, no violations were identifie On May 21,1987 while touring the service water (SW) pumphouse, the in-spector noted a temporary hose connected between the vent of service water pump "B" (SW-P-418) and the vent of the Unit 1 SW screen wash (SCW)

pump (SCW-P-79). The Unit 2 SCW pump is not installed. This. hose jumper had been installed by operations personnel to ensure an adequate backup supply cf lubricating water to the circulating water (CW) pumps. The unit shift supervisor (USS) authorized the modification with caution tags on each vent valve believing that use of a tagout obviated application of the temporary modification procedure. The temporary modification pro-cedure specifies that the requirements of that procedure do not apply

.to equipment tagged out per MA4.2, Equipment Tagging and Isolatio As a result, a temporary jumper hose was placed on a safety related system without evidence of the requisite work controls. The technical support department was unaware of the modification because no work re-quest was written. The inspector discussed the modification with several control room operators who were aware of its installation and generally believed that the method used to install the hose was fully in accordance with the intent of the Seabrook Station Maintenance Manual (SSMA).

.Although the SW system was not required to be fully operational by the i SW technical specification (TS 3.7.4), cooling water was required to be available for primary temperature control in support of the RHR system (T.S. 3.4.1.4.1). Since SW was the only medium available to provide the heat sink to support operation of the RHR pump, it was required to be operable as prescribed by the noted conditions even though no decay heat exists at the present tim The inspector raised the following concerns and discussed them with cog-nizant licensee management:

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(1) A safety related system was modified without a work request cr tem-porary modificatio (a) This removed any mechanism by which the required safety evalu-ation per 10 CFR 50.59 could be performe (b) In the absence of a work request, the responsible system engi-neer was unaware of the modification thereby presenting the opportunity for subsequent safety evaluations to be based on incorrect system statu .

(c) The modification was performed without the benefit of detailed technical guidance with respect to such activities as flange bolt torquin (2) The temporary modification procedure, MA 4.3 implies that the equipment tagging program is an equivalent substitute for the tem-porary modification program. This interpretation was widely held by other members of the station staff. This bypasses necessary features of the temporary modification program such as periodic re-evaluation, independent review, SORC approval, and testing re-quirements. Part 50.59 of Title 10 of the Code of Federal Regula-tions (10 CFR 50.59) requires that each licensee provide a written safety evaluation which includes the bases for the determination that changes, tests or experiments do not involve unresolved safety questions. By modifying the SW system and providing a jumpered connection to the SCW system as described above, the licensee acti-vity was identified to be in violation of 10 CFR 50.5 Subsequent to discussion of the noted condition with the NRC in-spector, the licensee opted to remove the hose jumper in lieu of performing a safety evaluation. The inspector verified that the work request written to cover the removal specified the flange bolt torquing requirements. The licensee revised the temporary modifi-cation procedure and the Operations Manager sent a memorandum to all licensed operators describing the incident and the appropriate use of temporary modifications. This topic will be included in the next requalification training program. Based on licensee corrective action taken, including actions to prevent recurrence, during the course of this reporting period, this violation is closed. Effec-tive implementation of the revised procedure and the training to be performed in future requalification programs will be the subject of future NRC inspectio __ ._ _ _ _ _ _ _ _

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e Previous Items

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- (0 pen)' Unresolved Item-(87-10-03): Atmospheric Steam Dump Valve (ASDV)

Design Questions (1) Background This issue was discussed in NRC Region I Inspection Report (IR)

443/87-10. .The unresolved issues were as followsi .

(a) Dynamic testing of individual train controls (b) Demonstration of " position maintained" feature (2) Chronology  !

-j A brief history was provided in IR 443/87-10. The following chron- i ology is' supplied for continuity and includes some events prior to initiation of the modifications in questio October 1985 Phase I Testing of ASDV This covered the basic pre-modification, single = train circui November 1985 Hot Functional Testing'. This covered stroke times, valve indication and controls, interlocks, alarms and operation from the remote safe shutdown pane December 1985 BER 787A issued in response to 10CFR50, Appendix "R" review. Included.DCN 65/0272B providing safety grade -!

controls and air supply and adding a disabling cap- '

ability.

L May/ June 1986 ECA 05/112599C issued for wiring details of BER 78 Work performed under WR MS-139 June / July 1986 ECA 03/804116J issued to add disable switches and l modify control circuitry including " dual train" con-trol " Sneak path" and opposite train actuation problems exist as a result of this change. Work l performed under WRs MS-1433, MS-187 '

July 1986 Phase I retesting of above changes. Problems re-l sulting from ECA above are not-discovered.

I January 1987 ISEG reviews INP0 SER on rapid cooldown and depres- 3 surization during remote shutdown tes ISEG recom-mends changes to A0P for remote shutdow !

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February 1987 ST-55 performed to verify operation of ASDV control Valve misoperation discovered. RES87-191 initiate Item #1 dispositioned by DCR

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Item #2 dispositioned by change to A0P DCR 87-64 issued to remove " sneak path". DIP issued under WR 87-1407 for installation and testin July 1987 To date procedural changes required by RES and INP0 review not implemente (3) Discussion During continuing discussions with licensee management, this issue was expanded by NRC inspector questions into the basis for declaring the ASDVs operable prior to entry into Mode 3 for pre-critical hot functional testin (a) Dynamic Testing of Individual Train Controls The licensee provided meeting notes to indicate that the test-ing requirements for the ASDVs were reviewed in July 198 Additionally, the Program Support Manager provided information regarding the testing of individual air lines under test GT-I-48, Instrument Tubing Verification. Based on review of GT-I-48, GT-E-21, Wiring Verification and Functional Checks and ST-55, Steam Dump System Testing, the inspector determined that the train related testing of the ASDVs to date has been adequat Questions of timeliness and testing methodology are discussed belo (b) Demonstration of " Position Maintained" Feature The licensee provided information that indicates that this feature was in fact tested but not clearly documented. The licensee agrees that the test procedure was not as specific as it could have been in this regard and supplemental test in-formation was added to the DCR/ DIP 87-64 package to indicate how this feature was tested. The inspector is satisfied that adequate testing of this feature was conducte (c) Basis for Declaring ASDVs Operable The inspector questioned the licensee regarding the basis by which the ASDVs were declared operable after the ECA was com-pleted. At this point in time it was the licensee's intention to heat up and perform ST-55 to verify that the modifications made under the ECA functioned properl Simultaneously the ASDVs were being relied upon to fulfill their safety require-

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ments under the technical specifications. It would have been appropriate to have run as much of ST-55 as possible in the cold condition prior to heat up to demonstrate with confidence that the ASDVs could perform their design safety functio NHY's stated position is that ST-55 was written to satisfy post-ECA retest requirement (d) Findings Inspector evaluation of this position indicates that normally, post-modification testing should stand alone to the extent possible prior to routine surveillance or special (in this case, '

startup) testing. Refer to paragraph 4b for related discussion of this issue with respect to the startup feedwater pum j Neither of the design errors discussed herein would have pre-vented the valves from performing their safety function and as such no violation was identified. The licensee has com-mitted to modify MT 3.1, DCR Implementation Plan to ensure that post-modification testing requirements are more clearly speci-fied. The inspectors will continue to review this area in following up unresolved item 87-10-4 below. This item is con-sidered close (0 pen) Unresolved Item (87-10-04): Startup Feedwater Pump Design Ques-tions (1) Background This item concerns inspector questions with respect to design changes and testing of the startup feedwater pump (SUFP). Inspec-tion report 87-10 identified the following issues:

} (a) Adequacy of the original ECA which installed the low suction j pressure trip (b) Adequacy of post-ECA testing

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(c) Adequacy of post-DCR testing (2) Chronology

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September 30, 1985 AT-1.3, SUFP test completed.

j October 25, 1985 AT-1.3, SUFP test results accepte February 19, 1986 ECA 99/111854 issued to add low suction pressure trip.

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~JuneL15, 198 _ECA 99/116685 issued to add low suction pressure trip bypass circui February 13, 1987 RES87-193 initiated because-of continued ac-tuation of low suction pressure tri February 26, 1987 DCR 87-68 issued to add time delay to trip circui March-10, 1987 DIP 87-68 issued to install time dela April 2, 1987 Testing. completed per DIP 87-6 April 30,.1987 Fdi service notification on DCR 87-6 May 24, 1987- SUFP breal'.er trips continue during operatio May 28, 1987 Temporary modification to install test equipment to monitor SUFP trip logi (3) System Design The design change which originally installed the low suction pres-sure trip (ECA 99/111854) was initiated because the SUFP has two-possible suction flow paths. When operating as an emergency feed-water pump, its suction is off the bottom of the condensate storage tank (CST) and the low suction pressure trip may be bypassed. When operating in'its normal mode, the suction is from the 20' elevation and the icw suction pressure trip is in effec Other various non-emergency suction flowpaths are possible depending on'the desired 1 condensate /feedwater configuration and plant status. While drawing off the high suction line, the potential exists to lower CST 1evel-to the' level of the high suction tap and subsequently drain the suction line causing pump damag When the first ECA was written, no consideration was given to the full range of plant operations and suction configurations that might arise and the potential effect of suction pressures on the low suc-tion pressure tri Even though the ECA was completed after AT- was finished, only Phase I tests were conducted on the pressure switche Dynamic system response was subsequently observed during actual operation at which time the pump tripped several times on low suction pressur J (4) Discussion When the design change (DCR 87-68) was initiated to add time delays in the low suction pressure trip circuitry, the inspector questioned the method by which this new modification would be tested. DCR Implementation Plan -(DIP) 87-68 simply stated, "After circuit modi-

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fication, verify that the startup feed pump will not trip during 1 starting due to momentary low suction pressure." The lack of I specificity _in these test requirements appears to have impacted the 1 licensee's ability to correct the initial problem of inadvertent i

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It_was not until the repetitive trip phenomena manifested itself

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during steady state operations that the licensee conducted an in-depth testing program to determine the actual cause of the trip I In the meantime, the pump had been returned to a fully operational status. Subsequently, the pump was not able to complete its sur-veillances due to the trip problem. The SUFP is not required by T until Mode 3; however, it is station policy to perform sur-veillances on safety related equipment following maintenance even if the equipment is not required for plant operations in the present mod The inspector attended the S0RC meeting which reviewed the SUFP test instrumentation temporary modification and discussed the test with the system enginee During the course of this inspection period, the inspector had frequent discussions with cognizant licensee engineering, test and support personnel. Some discussions related to test requirements and the licensee's intention to modify proce-dure MT3.1, DCR Implementation Plan as described in paragraph 4a of this repor (

The licensee agrees that performance of a surveillance normally assumes that the equipment is fully operational to begin with and that comprehensive post modification testing is normally required before surveillance are performed. Surveillance alone may not always be an adequate method of post modification testing although in some cases it may be appropriat The licensee further indicated that even though the SUFP is a piece of equipment and considered safety related, the low suction pressure trip and the high suction flowpath are not part of the safety related system and therefore do not require controls as rigorous as those associated with safety system (5) Findings The inspectors reviewed this position and determined that the in-terface between the design and testing aspects of the SUFP modifi-cations were not as comprehensive as required for safety related applications. This apparent weakness requires further programmatic review particularly with respect to additional SUFP testin No evidence exists that the SUFP as designed and modified would not perform its safety function and therefore, no violation was identi-fied. However, further follow-up as described above appears war-l

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ranted and as such, unresolved item 87-10-04 will remain open pend-ing licensee completion of additional modifications to the SUFP and its control circuits and piping. Specific NRC attention will be given to the post modification testing of the new changes and im- .

p .plementation of the revision to procedure MT (Closed) Deviation (85-25-03): Reactor Vessel Level Indication System (RVLIS) Concerns The. inspector reviewed the NHY response (SBN-905) dated December 11, 1985 to this deviation, noting both the specific corrective action and that taken to prevent recurrence of this proble All USNRC Regulatory Guide (RG) 1.97 systems and components, which have been categorized as Design Category 1, have been placed under the full program of quality assurance (QA) controls associated with safety-related item With regard to the specific RVLIS lines, which were installed under a quality-related (QAS-5), but not full 10CFR50, Appendix B, QA program of controls, the inspector reviewed quality control (QC)-inspection re-ports, work requests and NCRs all documenting quality installation cri-teria. Approximately, one-third of the RVLIS installation was reworked by design change after the identification of the deviation. The inspec-tor verified that this rework was performed in accordance with the QA requirements of RG 1.97, design category The licensee also performed an evaluation to determine if the application of the QAS-5 program to the RVLIS installation had any adverse quality impact with respect to inspection criteria. Because the capillary tubing was validly installed to non-ASME requirements, the RVLIS components were identified to have been erected to the typical seismic ANSI B31.1 cri-teria. Also, the licensee revised the various installation procedures to assure that the traceability and inspection. requirements of 83 equipment, categorized as safety-related, were commensurate to the ASME installations from a QA standpoin During the pre-critical hot functional testing, the inspector confirmed l that Seabrook specific reactor pressure vessel differential pressure data was taken as a function of RCS temperature to provide " hot" calibration of the RVLIS Dynamic Head readings. This data collection was performed in accordance with Station Operating Procedure, ES-86-1-28, and the re-sults have been reviewed per 87-RES-035 No specific problems were identified during either cold, as-built system tests or hot calibration of the RVLIS system which would indicate any construction concerns. The inspector reviewed overall licensee action to this deviation and determined that adequate corrective measures were taken to assure quality installation of the RVLIS syste This item is considered close _ _ _ - _ -

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5. Licensee Event Reports (Closed) LER 87-011: ESF Actuation - Loss of Power to Vital Bus. This LER was opened in NRC IR 443/87-10 and remained open pending final review of the associated station information report (SIR) and revised procedure On December 12, 1986, while attempting to restore 125 Volt Vital DC Bus 11A, the bus E5 UAT breaker tripped and the RAT breaker did not close causing a loss of Bus E5 because diesel generator "A" was out of servic The loss of Bus 11A which initiated the loss of Bus E5 was due to opera-tor error in cross-connecting battery chargers 1A and IC. A problem had been discovered during pre-operational testing in which the offgoing charger drove the oncoming charger off the line when one charger was in the equalize mode and the other was in the float mode. For this reason, a caution was placed in the 125 Volt DC system operating procedure, 05104B.0 On April 3, 1987 a similar event occurred; however, on this occasion the available diesel generator started because the RAT breaker was out of service. The post incident review concluded that the root cause of the event was identical to the December 12, 1986 event. Although the proce-dure had been changed, the operators still did not realize the signific-ance of the load sharing phenomenon of the battery chargers. Follow-up corrective action appears to have been incomplet The first incident was not reported under 10 CFR 50.73 because an actu-l ation of the emergency power sequencer (EPS) without a diesel start is not considered an engineered safety features (ESF) actuation. The April event included a diesel start and ws.6 therefore reportable.

l The inspector reviewed the NHY submittal (letter NYN-8,7062) dated May 4, 1987 and noted that it did not mention the previous event. Paragraph

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50.73 (b)(5) of 10CFR states that the LER shall contain reference to any previous similar events at the same plant that are known to the license NUREG-1022, Licensee Event Report System, further amplifies 10 CFR 50.73 stating:

The licensee should reference any previous similar events or fail-ures, particularly if they were reported as LERs, and discuss why prior corrective action did not prevent recurrence (i.e., any earlier events which in retrospect are significant in relation to the subject event.)

While the inspector agrees that this is the first " reportable" occurrence, enough similarity exists between the two events that discussion of the first incident even if it was not strictly a " previous occurrence" would have been appropriat NHY Regulatory Services engineers acknowledged that the events were similar but not identical and therefore not a " pre-vious occurrence".

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During the discussion with NHY Regulatory Services personnel, the in-spector noted that the licensee had performed a detailed review of the issue prior to making the decision not to include the additional infor-matio There is no question regarding the thoroughness of the NHY in-vestigation of the events nor whether they met the requirements of 10 CFR 50.73 in reporting only the April actuation. This LER is close During the December 12, 1986 loss of buses, a related event occurred which did not bear on the deportability question, but did require further review by the inspectors. Upon loss of power, it was noted~that RC-V-23 moved slightly to the intermediate position. Subsequent review deter-mined that this occurred because of the sequence of events in which in-verter 1A was deenergized slightly before bus E5 was lost, causing the the valve to move slightly to the closed position. The inspector re-viewed the Station Information Report (SIR 87-004), reviewed the logic and schematic diagrams and confirmed this evaluation with the system engineer. The inspector had no further concern b. (0 pen) LER 87-012: Inadvertent Safety Injection. A one-hour ENS notifi-cation was made to the NRC Operations Center in accordance with 10 CFR 50.72 following an inadvertent safety (SI) injection on April 16, 198 This event was subsequently reported to NRC by letter NYN-87065 on May 15, 1987. The cause of the SI was faulty contacts in the Westinghouse OT2 type switches. Licensee testing indicated momentary switch overshoot was causing makeup of the reset contact The inspector observed licensee post-SI activities in the control room and determined that operator actions were appropriate. He reviewed the post trip data logger output and verified that all systems performed as designe Design Coordination Report (DCR)87-18T was generated to re-place these and other similar dual function set / reset switches with separate function switch /pushbutton combinations. The inspector reviewed DCR 87-185 and had no question This LER will remain open pending NRC review of the DCR Implementation Plan with specific emphasis on retestin Refer to licensee commitments in paragraph 4 of this repor c. (Closed) LER 87-013: Area Temperature Monitorin The inspector reviewed this LER and determined it to be a routine report. The inspectors peri-odically spot-checked battery room temperatures on plant tours and veri-fied installation of the temporary thermometer. This LER is close d. On July 6, 1987, the inspector provided the licensee a copy of the de-tailed evaluation of LER quality developed by the NRC Office of Analysis and Evaluation of Operational Data (AE0D) using the basic methodology presented in NUREG-1022, Supplement No. This evaluation is herewith attached to this inspection report. It should be noted that such an AEOD analysis routinely covers the period of time associated with a plant's Systematic Assessment of Licensee Performance (SALP). Therefore, the evaluation period (April 1, 1985 to April 30, 1987) commences with the o

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start of the current SALP period, even though LERs were not written until after the issuance of zero power license (NPF-56) in October, 1986. In an attempt to include initial criticality in the SALP evaluation, the 4 SALP period was exterded to August 30, 1987; however, the period for the AE0D analysis was not correspondingly extended. Hence, the difference in the end dates for the two evaluation period In general, the Seabrook LER evaluation provided results of above-average LER quality. Only one weakness, regarding 10 CFR 50.73(b)(2)(ii)(L),

was identified and will be reviewed in future LERs for an improving tren However, as noted in sub paragraph a above, AE0D only evaluates what is reported. In the case of LER 87-011, additional trending information and an analysis of the adequacy of corrective action may have been lost with the failure to connect, this LER with a previous event which was correctly deemed to be not reportabl . Maintenance On April 30, 1987 a tube leak was identified in the "A" primary component cooling water (PCCW) heat exchanger (1-PCC-E-17A). One train of PCCW is required in Mode 5 to support operation of the RHR system when it is used to satisfy T.S. 3.4.1.4.1, Reactor Coolant Loops and Coolant Circu-lation. The "A" train of PCCW was tagged out, drained and opened. It was found that the baffle plate in the upper channel head was deformed to such a degree that several tube outlets were actually exposed to inlet pressure. The licensee conducted eddy current testing (ET) to locate ,

the leaking tube and determine the status of the tubes in general. The inspector discussed the planned evolutions with the lead system enginee He inspected the upper channel head, cervice water (SW) inlet and outlet nozzles and the tube sheet, observing some minor tube blockage with marine debris and piping liner material. A NHY Technical Support Engi-neer stated that the lining material had been identified as the original Belzona coating and could be distinguished from the newer coating by its color. He also observed ET of both the PCCW and diesel generator heat exchanger The results of the ET indicated that 40 tubes were partially degrade The single leaking tube was also identified. Two mechanisms of tube damage were note Near the tube inlets within the tube sheet, there was erosion in the first one to two inches; attributed to high air en-trainment in the SW system. In the body of the tubes, pitting was noted in some tubes and this is due to intermittent stagnation of SW in the system when the SW pumps are not running. The 41 degraded tubes were plugged as a temporary measure until new tube sleeves could be manufac-tured and installe The upper channel head was removed and transported to the vendor, Joseph Oat Co., for inspection and repair. Baffle plate weld damage was found, ground out and rewelded. This operation required removal and later re-

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placement of the neoprene liner. The inspectors closely followed each stage of repair, reviewing work requests (WR) interviewing workers, supervisors and engineers and independently verifying adherence to the NHY work control progra The inspector questioned the support of large service water pipe spools which were partially disassembled. Specific concern was expressed with respect to the influence of these incompletely supported structures on opposite train systems located nearby. The licensee instituted an engi-neering review and as a result of this detailed analysis, temporary sup-ports were installed in various location The inspector noted that erection of scaffolding and temporary supports complied with NHY's new program to ensure that temporary supports and equipment will not affect nearby equipment required to be operabl While performing an inspection of the service water system with the upper channel head removed, the licensee noted seat damage on SW-V-5, the out-let valve on the "A" train PCCW heat exchanger. This valve is a 24" motor operated butterfly valve manufactured by Fischer. The solid disc closes against a hard elastomer seat. Previous valve seat rework was reported under 10 CFR 50.55(e) as CDR 85-00-13 which was closed in NRC l IR 443/86-47. Further licensee investigation revealed a generic problem with all the Fischer valves, the majority of which are 24" diamete Other valve sizes are 12" and 16" diameter. The inspectors have followed the repaias which included valve removal, seat removal, liner sandblast-ing and cleaning, seat replacement, machining and testing. The licensee established an " assembly line" style process to conduct the repairs to the approximately thirty affected valves. As an added precaution, the licensee also inspected the SW cooled "A" diesel generator jacket water heat exchanger for tube damage. No significant degradation was found and the "B" train diesel heat exchanger will be inspected concurrently with other "B" train PCCW/SW inspection and repair The repair program developed by the NHY Technical Support Department in coordinating this large scale effort was well prepared, organized and executed and is considered a licensee strength in the maintenance are On several occasions. repair techniques proved unsatisfactory and licen-see testing and evaluation provided sound engineering corrective actio NHY will submit a report under 10 CFR 21. This issue will be tracked under NRC open item number 87-88-0 The inspectors will continue to follow licensee repair effort Additional NRC specialist coverage of this issue may be found in Region I IR 443/87-1 b. Battery Chargers Inspection report 443/87-10 indicated licensee intent to establish the following based on NRC concerns fcllowing repair to battery charger 1A:

l (1) A method to ensure that QAIRs with operability or safety signific-ance are given a prioritized dispositio .____ _ ______

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f ( :s 17 1

. j (2) A mechanism to differentiate between QA inspector questions'and d specific criteria deviations so that answering lower priority in-quiries does not interfere with'the disposition of higher priority item '

'(3) Measures to require that a formal technical evaluation be conducted 3

~in those cases where inspection'has not verified that engineering-  ;

criteria have been me '

I The-inspector reviewed the licensee's proposed revision to the NHY Qual- .

ity Assurance Manual (NYQA). This revision included guidance on how '

quality inspection results should be identified and prioritized. .This

-" appears to address the first two concerns abov The third concern has been resolved with issuance of a new procedure ED1820.001, Technical Support Group Engineering Evaluation and Calculation. The inspecto reviewed the preliminary copy and determined that the licensee has de-veloped a comprehensive program whereby engineering evaluations are to be performe He noted that particular attention was paid to definitions and examples which.should assist station staff and-' engineering personnel in determining whether evaluation or calculation techniques are applic-able in a given situation. The inspector had no further concerns on this issue and feels that licensee initiatives in this area of identified weakness have .heen appropriate, timely and properly directe . Design Changes The inspector rev'iewed licensee evaluation, disposition, and implementation of design and design change activities representative of three separate engi-neering activities, as documented below

Engineering Change Authorization (ECA) 99/107028C: Modification of the SI. flow measurement system from a filled capillary design to the use of flow transmitters, utilizing in-line, process fluid instrument tubing tap The inspector examined the field changes on both "A" and "B" trains, walking the tubing lines from the SI pump discharge flow elements to both the pressure transmitter instrument racks and the drain manifolds.

l He noted proper consideration of the new transmitter as design category 2 instruments in accordance with USNRC Regulatory Guide 1.97, to include their method of seismic mounting in the racks. The abandonment in place of the unused capillary tubing, as well as the tie-in to the new process tubing lines were checked and evaluate The inspector discusssed with licensee personnel certain questions on SI pump flow calibration controls and reviewed the pertinent I&C procedures. No violations were identified.

i Design Coordination Report (DCR) 87-0071: Rewiring of torque bypass switch contacts on certain valves to prevent incorrect main control board valve position indication. As a result of a licensee engineering evalu-ation of motor operated valve (M0V) limit switch settings, in conjunction with IE Bulletin 85-03 criteria, thirty valves were checked to determine  ;

if the current wiring of the torque bypass switch could lead to incorrect l L

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valve position indication because of the use of the same internal motor contacts.for both the bypass switch and full-closed position indication {

for the valve. As a result of this evaluation, seven MOV's required l rewiring as directed by the subject DC The inspector examined in process control of the rewiring work activitie to include subsequent M0 VATS testing of the valve inspection effort on SI miniflow isolation valves, SI-V-89, 90 & 93, He concentrated this 'q noting that a 10CFR50.59 safety evaluation was accomplished with West- 1 inghouse concurrence, to address the increased stroke times of the sub-ject valves caused by the wiring change. Since the design of the.SI system electrically interlocks these valves with certain residual heat removal valves utilized during the recircualtion phase of ECCS actuation, the inspector reviewed this design change to confirm that the. wirin revisions did not affect the interlock functions. The relevant elec-tried schematic drawings for both the SI & RHR valves, involved in the interlocks, were reviewed and train-related limit switch connections to the interlocks inspected on the subject valves. Where the SI valve motor operators were open for the rewiring work, the inspector examined contact conditions on the rotors, checking the valve position switch criteria called for by the revised schematics with the actual rotor utilized on the valve operator itsel '

No violation" were identifie c. Request for Engineering Services (RES) 87-0695: Question on the effect of slightly negative pressure in the containment enclosure area upon differential pressure transmitter setpoints for containment pressure signals. The inspector reviewed the response to the RES and discussed it with NHY and YAEC engineering personnel. It was determined that the effect of the normally negative pressure environment inside the contain-ment enclosure area would be indiscernible on the main control board instruments and conservative with respect to containment pressure safety signals (eg: SI).

The inspector also requested information on the relationship of the reference leg heatup error, discussed in Supplement 5 to the Safety Evaluation Report (SER), to the setpoint change for the steam generator low-low level trip and also on the channel statistical accuracy and mar-gin used in calculating the Hi-1 containment pressure SI setpoint. Cor-despondence between the licensee and NRR was reviewed and discussed with engineering personnel and all of the inspector's questions were satis-factorily answered. These responses were documented in the disposition of 87-RES-069 No violations were identifie _. ___ ____ _ _ _ _ _ _ -

19

. Other Inspection The inspector questioned the licensee concerning a construction defi-ciency identified at another nuclear power plant. A report made under 10 CFR 50.55(e) had been filed indicating that Telemechanique, the sup-plier for safety related motor control centers (MCC) had specified torque values for the MCC hold-down bolts. That plant determined that their installation would not meet seismic design criteria due to under-torquin NHY indicated that all MCCs at Seabrook were welded to their base founda-tions and that this problem was not applicable. The inspector had no further question While inspecting drained SW system piping, the inspector noted air flow-ing between rooms in the primary auxiliary building via the open, drained, piping runs. He discussed the potential for the violation of radiologi-cal ventilation boundaries when large diameter through-wall piping was disassembled, with the Systems Support Manager. He indicated that they were aware of the phenomenon but that it was unlikely that radiation barriers would be breached due to the ventilation system design. Future maintenance activities would, he stated, evaluate this on a case by case basis. The inspector indicated that this would be the subject of routine NRC inspection during future maintenance periods. No violations were identifie NRC Region I IR 443/87-02, paragraph 3a discussed NRC identification of superceded or uncontrolled electrical schematic and schedule drawings inside the doors of several low voltage power panel The inspector observed two licensee auxiliary operators performing veri-fication walkdowns on power panel He discussed the walkdown program and the new drawings and their findings to date. Preliminary results of the walkdown confirm the inspector's prior concern that the existing drawings within the panels were not fully accurat NHY provided the inspector with the preliminary walkdown summary indi-cating that several discrepancies require configuration control resolu-tion to determine whether the drawings or the installation is in erro The inspector will monitor progress in this area. Licensee actions to ,

date appear well directed and progressing satisfactorily. No violations l were identifie . Equipment Tagging On May 11, 1987 the inspector noted several charging system valves which were danger tagged at the valve but not tagged at the remote handwheel which was connected by a reach rod. He discussed the tagging policy with the Assistant Operations Manager and verified that station practice was to tag the remote operator only. The Assistant Operations Manager wrote a night order to re-inforce this procedure to all operators. The night order indicated that the

_ .__ _ _____________ -

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local operator may also be tagged, if appropriate, but that in all cases the remote operator must be tagge With respect to this. specific tagging issue, the inspector had no further question .During the past three months the inspector noted several minor recurring i errors in implementation of the tagging program. Typical deficiencies in-cluded failure to sign the "placed by" line on danger tags; uninitialled lineouts to equipment identification numbers on tags; missing tags; two'dif-

.ferent tagouts'with different positions specified on the same component (i.e.,

one says."open", the other says " locked open" while the breaker is actually open but not locked).

In each case discussion was held with cognizant licensee supervisory personnel and corrective actions taken. Based on the above and the results of other NHY initiated ~ audits, the equipment tagging program is presently under licen-see revie In light of the July 3, 1987 event (refer to paragraph 2b of this report), the NRC will closely monitor licensee progress in this are !

1 Training 4 1,

The inspector observed a simulator training session for the current replace-ment operator class. The subject of the lesson was steam generator tube rup-ture. The inspector noted excellent instructor / trainees interface and di-alogue. .The instructors were noted to be extremely knowledgeable in their

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subject areas. The training methodology used whereby the students are given increasingly more complex scenarios to handle was determined to be challenging to the students and of maximum training benefit. .. Instruction on the use of the emergency operating procedures (EOPs) demonstrated a' sound basis of under-standing on the part of the instructors. This methodology appeared to b successfully transmitted to the students as their exposure to the E0Ps in-creased with repeated use. The inspector had no concerns in this area. NRC conducted licensing examinations are presently scheduled for August, 198 . Management Meetings At periodic intervals during the course of'this' inspection, meetings were held with senier plant management to discuss the scope and findings of this in-spection. An exit meeting was conducted on July 6, 1987 to discuss the in-spection findings during the period. During this inspection, the NRC inspec-tors received no comments from the licensee that any of their inspection items or issues contained proprietary information. As discussed in paragraph 5 of this report, a copy of an AE0D LER evaluation was provided to the licensee and is appended to this report as Attachment 1. No other written material, except for some written technical questions, the subjects of which are ad-dressed in paragraph 3 of this report, was provided to the licensee during this inspectio l

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ATTACHMENT I TO NRC REGION I

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INSPECTION REPORT 50-443/87-13

l LICENSEE EVENT REPORT (LER)

QUALITY EVALUATION FOR SEABR00K -

DURING THE PERIOD FROM APRIL 1, 1986 TO APRIL 30, 1987

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SUMMARY

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An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Seabrook during the period from April 1, 1986 to April 30, 1987 was performed using a refinement of the basic methodology presented in NUREG-1022, Supplement No. The results of this evaluation indicate that Seabrook LERs have an overall average LER score of 8.8 out of a possible 10 points, compared to a current industry average score of 8.3 for those unit / stations that have been evaluated to date using this methodolog The principle weakness identified in the Seabrook LERs involves the

- requirement to adequately identify failed components in the text (Requirement 50.73(b)(2)(ii)(L)]. The failure to adequately identify each component that fails prompts concern that possible generic problems may not be identified in a timely manner by others in the industr Strong points for the Seabrook LERs are the discussions of the personnel / procedural errors (Requirement 50.73(b)(2)(ii)(J)(2)] and the failure mode, mechanism, and effect of each failed component

[ Requirement 50.73(b)(2)(ii)(E)].

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LER -QUALITY EVALUATION FOR

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SEABROOK INTRODUCTION

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In order'to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Seabrook during the period from April 1, 1986 to April 30, 1987, a representative sample of the unit's LERs was evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. The sample consists of a total of six LERs, which were all the LERs on file at the time the sample w'as drawn. See

. Appendix A for a list of the LER numbers in the sampl 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, all of the LERs pr'epared by the unit l

during the assessment period may not have been available for review, i METHODOLOGY

, The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, 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 2 and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, I i

suggestions were developed for improving the quality of the reports. The 4 purpose of this evaluation is to provide feedback to improve the quality of LfRs. It is not intended to increase the requirements concerning the

" content" of reports beyond the current requirements of 10 CFR 50.73(b).  ;

Therefore, statements in this evaluation that suggest measures be taken are I not intended to increase requirements and should be viewed in that ligh However, the minimum requirements of the regulation must be me ]

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The evaluation process for each LER is divided into two parts. The

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first part of the evaluation consists of document',ag comments specific to the content and presentation of each LER. The second part consists of

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determining a score (0-10 points) for the text, abstract, and coded fields of each LE The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was evaluated. Likewise, the scores serve two purposes: (1) they

, serve to illustrate in numerical terms how the analysti perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER. The overall score for each

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LER is the result of combining the scores for the text, abstract, and coded

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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) sunsMry 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 narrative statements concerning the contents of each LER (Appendix D).

When referring to Appendix 0, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER $

scores, as the analysts have flexibility.to consider the magnitude of a a deficiency when assigning scores (e.g., the analysts sometimes make i

)

comments relative to a requirement without deducting points for that i

]

requirement).

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RESULTS

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A discussion of the analysts' conclusions concerning LER quality is

presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such

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represent the analysts' assessment of the unit's performance (on a scale of 0 to 10) in submitting LERs that meet the criteria of 10 CFR 50.73(b) and I the' guidance presented in NUREG-1022 and its supplement Table i presents the average scores for the sample of LERs evaluated for Seabrook. In order to place the scores provided in Table 1 in perspective, the distribution of the latest overall average score for all

- unit / stations that have been evaluated using the current methodology is provided on figure 1. Figure 1 is updated each month to reflect any changes in this distribution resulting from the inclusion of data for those

units / stations that have not been previously evaluated d'r those that have been reevaluated. (Note: previous scores for those units / stations that are reevaluated are replaced with the 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, Seabrook's average score for the text of the LERs that were evaluated is 8.5 out of a

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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 indication of how well each text requirement was addressed by the unit for the six LERs that were evaluate Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the unit is experiencing the most difficulty in prep,aring LERs. For example, requirement percentage scores of less than 75 indicate that the unit probably needs additional guidance concerning these

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. TABLE SUMMARY OF SCORES FOR SEABROOK

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Text .5 i

7.6 L

Abstract .0 Coded Fields .0 Overall .5 See Appendix B for a summary of scores for each LER that was evaluate .------------------------------------------------

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TABLE 'LER REQUIREMENT-PERCENTAGE SCORES FOR SEABROOK

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. TEXT

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Percentage a

Requireme'ts n [50.73(b)) - Descriptions Scores-(: -)

______________________________________________________ _____________

(2)(ii)(A). - - Plant condition prior to event (2)(ii)(B) -i- Inoperable-equipment that contributed 67 ( 6)

b

- - Date(s)'and approximate time (s)

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(2)(ii)(C)

100 ( 6)

(2)(ii)(D) - -Mode, Root cause and intermediate cause(s)

L (2)(ii)(E). -

mechanism, and effect- . 85.( 6)

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(2)(ii)(F) - - EIIS codes 100 ( 1).

8 (.6)

-(2)(iA)(G) -

- Secondary function affected b-(2)(ii)(H) - - Estimate of unavailability

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(2)(ii)(I)- - - Method of discovery 100 ( 1)

7y

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100 ( 6)

. ( :2 ) (ii ) (J ) ( 1 ) - Operator actions affecting' course ( 0)

(2)(ii)(J)(2) - Personnel error (procedural deficiency)

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(2)(ii)(K) - - Safety system responses 100 ( 5)

. 100 ( 4)

(2)(ii)(L) - - Manufacturer and model no. information 50 ( 1)

(3)'- - - - - - Assessment of safety. consequences 80 ( 6)

(4) - - - - - - Corrective actions 88 ( 6)

(5) - -- - - - Previous similar event information (2)(1) - - - Text presentation 92 ( 6)

80 ( 6)

t ABSTRACT

________

Percentage Requirements [50.73(b)(1)] - Descriptions Scores ( )

______________________________________________________ _____________

- Major occurrences (immediate cause/effect) 97 ( 6)

- Fl ar.t/ system / component / personnel responses 100 ( 4)

- Loot cause information 97 ( 6)

. Corrective action information 89 ( 6)

Abstract presentation 92 ( 6)

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i TABLE (continued)

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CODED FlELDS

____________ i Percentage a

ltem Number (s) - Descriptions Scores ( )

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1, 2, and 3 - Plant name(unit #), docket #, page #s 100 ( 6)

4------ Title  !

44 ( 6) !

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5, 6, and 7 - Event date, LER no., report date t 100 ( 6) 1

8------ Other facilities involved 100 ( 6)

9 and 10 --

Operating mode and power level 100 ( 6)

11 - ----

Reporting requirements 100 ( 6)

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Licensee contact information 83 ( 6)

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Coded component failure information

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100 ( 6)

14 and 15 - - Supplemental report information 92 ( 6)

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, Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requiremen (Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicabl A percentace score for this requirement is meaningless as it is not I

ible to determine from the information available to the analyst whether

+*:t requirement is applicable to a specific LE It is always given 100%

_: ;t is provided and is always considered "not applicable" when it is no __________-_______.--___________-________________________________________

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, requirements'. Scores of 75 or above, but less than 100, indicate that the

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unit probably understands the basic requirement but has either: (1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. Those responsible for preparing LERs should review the LER specific comments presented in Appendix D in order to determine why the unit 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 as are the primary deficiencies in the the abstract and coded fields section ~

l Text Deficiencies and Observations R

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Unique component identification was not provided in the text of the one LER that involved a component failure, Requirement 50.73(b)(2)(11)(L).

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Components that fail should be identified in the text se that others in the I industry can be made aware of potential problems. An event at one station can often lead to the identification of a generic problem that can be corrected at other units or stations before they experience.a similar event. In addition, although not specifically required by the current regulation, it would be helpful to identify components whose design

' contributes to an event even though the component does not actually fai Two of the LERs failed to provide information in the text concerning plant operating conditions prior to the event, Requirement 50.73(b)(2)(ii)(A).

As a minimum, the power level should be given and any operating mode numbers referred to should be defined. For some events temperatures and pressures may also be appropriat !

All six of the LERs failed to provide the necessary Energy Industry Identification System (EIIS) codes. Requirement 50.73(b)(2)(ii)(F)

requires inclusion of the appropriate EIIS code for each component and/or system referred to in the tex .

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, The text presentation, while acceptable, could be improved by

, presenting the required information in an outline format as suggested in NUREG-1022, Supplement No. Two other requirements, while having scores of greater than 75%, were i l

considered deficient in a number of LERs. The root cause discussion j

[ Requirement 50.73(b)(2)(ii)(D)) and the safety assessment discussion

[ Requirement 50.73(b)(3)] were each considered lacking in four LER Review of the specific LER comments concerning these requirements in  !

Appendix D would probably result in improved discussion k Abstract Deficiencies and Observations

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Although the Seabrook LERs, in general, have well above average abstracts, reviewing the specific comments relative to abstracts in

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Appendix D could help to eliminate those problems that do exis Qded Fields Deficiencies and Observations The main deficiency in the area of coded fields involves the titles, Jtem (4). All six of the titles failed to provide adequate cause

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information, two failed to adequately indicate the result (i.e., why the event was required to be reported), and four failed to include the link between the cause and the result. While the result is considered the most important part of the title, the lack of cause information (and link, if necessary) results in an incomplete titl Example titles are provided in Appendix D (Coded Fields Section) for most of the titles that are considered to be deficien Although the score for Item (12) is acceptable, all six LERs failed to j include the position Title of the Licensee Contact as requested in ,

NUREG-1022, page 2 Table 3 provides a summary of those areas nf the Seabronk IFRs thst require the most improvement. For additional and more specific information

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TABLE AREAS MOST NEEDING IMPROVEMENT FOR SEABROOK LERs 1

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Areas Comments Manufacturer and model number Component identification information should 2 be included in the text whenever a I component fails or (although not 1 specifically required by the current regulation) is suspected of contributing to the event because of its' desig Operating conditions Details such as power level, mode names, prior to the event and in some cases temperature and pressure

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should be provided in the tex .

EIIS codes An EIIS code should be provided in the text for each system and/or component referred

,

to in the tex Coded fields

- Titles Titles should be written such that they better describe the eve 6t. In particular, provide the cause information and a link between the cause and result where appropriat Licensee contact The position title of the licensee contact position title named in Item 12 should be provided (see NUREG-1022, page 24).

.

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10

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_ _ _ _ _ _ _ _

- - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ - __ - _ _ _ _ _ _ _ _

,

concerning' deficiencies, the reader should refer to the information

-

,

presented in Appendices C and General guidance concerning these requirements can be found in NUREG-1022, and NUREG-1022 Supplement No. 1 and . i

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-

- _ _ _ _ _ _ _ _ - _ _ _ _ _ _

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REFERENCES

, Office for Analysis and Evaluation of Operational Data Licensee Event Report System, NUREG-1022 Supplement No. 2 U.S. Nuclear Regulatory Commission, September 198 . Office for Analysis and Evaluation of Operational Data. Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 198 . Office for Analysis and Evaluation of Operational Data. Licensee Event Report System, NUREG-1022 Supplement No. 1. U.S. Nuclear Regulatory Commission, February 198 .

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W APPENDIX A LER SAMPLE SELECTION INFORMATION FOR SEABROOK

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_ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ . _ _ . _ _ _ _ _. ___.__m__ _ _ _ _ . - _ _ _ __

. _ _ - . _ - _

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, TABLE A- LER SAMPLE SELECTION FOR SEABROOK

Sample Number LER Number Comments 1 86-001-00 l

2 86-002-00 ESF 3 86-003-00 ESF 4 87-001-00 ESF 5 87-002-00 ESF 6 87-003-00

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A-1

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_ . . . . . . .

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- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

. - - -- _ _

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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR SEABROOK L

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_-m_ _ _ _ _ __ ____ .

-. . - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _

TABLE B- EVALUATION SCORES OF INDIVIDUAL LERS FOR SEABROOK

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________-___-_ --_______-______-__---________ __---_---_______-_____- _-- .

a LER Gample Number

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1 2 3 4 5 6 7 8

____________-_-________________--_____-_________-___-__________-___________

Text .3 .8 .9 . .

Abstract 1 .0 .2 1 .7 . .

Coded Fields .5 .9 8,4 . .

Overall .5 .2 .0 . .

___--_______-_-__-_-__-__---__ -_--_-___-_________----_____--___--__-___-__

a LER Sample Number

? 10 11 12 13 14 15 Average

-- __--_-_-___--___-__--__-____--__________--_-__---__________-__------___

Abstract . . . . . . '

Coded Fields . . . . .' . . )

i Overall . . . . . . . _-__-_______ --____-_-_--- See Appendix A for a list of the corresponding LER number ,

________--____________________________-__-_____--______---..________-_____

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• s APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR SEABROOK i

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__ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ . _ _

_ _ - _ _ - . -

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. TABLE C- TEXT DEFICIENCIES AND OBSERVATIONS FOR SEABROOK

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Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( l b

50.73(b)(2)(ii)(Al--Plant operating 2 ( 6)

conditions before the event were not included or were inadequat .73(b)(2)(ii)(B)--Discussion of the status -- ( 0)

of the structures, components, or systems that were inoperable at the start of the

' event and that contributed to the event was not included or was inadequat .73(b)(2)(ii)(C)--Failure to include 0 ( 6)

.

sufficient date and/or time informatio Date information was insufficien Time information was insufficien .73(b)(2)(ii)(D)--The root and/or 4 ( 6)

intermediate cause of the component or system failure was not included or was inadequat s Cause of component failure was not 2 included or was inadequate.

l Cause of system failure was not 2 included or was inadequat l 50.7_3(b)(2)(ti)(E)--The failure mode, 0 ( 1)

mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate, Failure mode was not included or was inadequat Mechanism (immediate cause) was not l

'

included or was inadequat Effect (consequence) was not included or was inadequat .

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0-1 L__----__--_--- ----- _ - -- - ------ ----

_ - _ _ - _ _ - - - _ _ - . - _ - _ - . . .. . - - _ - ._ _ _ - _ _ _

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TABLE'C-1- (continued)

.- __

Number of LERs with Deficiencies and Observations

'

Sub-paragraph Paragraph

' Description of Deficiencies and Observations a Totals Totals ( )

. LO 73(b)(2)(ii)(F)--The Energy Industry 6 ( 6)

Identification System component function

.

identifier for each component or system was

' not include .73(b)(2)(ii)(G)--For a failure of a

.

-- ( 0)

. component with multiple functions, a list

. - of systems'or secondary functions whic were also cffected wts not included or was inadequat '

50.73(b)(2)(iil(H)--For a failure that ' 0 (1)

rendered a train of a. safety-system inoperable..'the estimate of elapsed time from the time of the failure uniti the train was returned to service was not include . 1Q.73(b)(2)(til111--The method of discovery 0 ( 6)

of each component failure, system failure,

,. personnel error, or procedural error was not included or was inadequ. at ' Method of discovery for each component failure was not included or was inadequat b. Method of discovery for each system failure was not included or was inadequat ,

c. Method of discovery for each personnel error was not included or was inadequat d. Method of discovery for each procedural error was not included or was. inadequate, j l

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C-2

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7--____-- ,

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TABLE C- (centint'ed)

__

..

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Deecriotion of Deficiencies and Observations Totals Totals ( )

50.73(b)(2)(ii)(J)(1)--Operator actions that affected the course of the event including -- ( 0)

operator errors and/or procedural deficiencies were not included or were inadequat .73(b)(2)(ii)(J)(2)- The discussion of 0 ( 5)

.each personnel error Las not included or was

, inadequat OBSERVATION: A personnel and/or procedural error was. implied by the text, but was not explicitly state .73(b)(2)(ii)(J)(2)(il--Discussion -

as to whether the personnel error was cognitive or procedural was not included or was inadequate;- . 73( b )( 2 ) ( 11 ) ( 3 ) ( 2 ) ( i i )--Di s c us s ion as 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. 10.73(b)(2)(it)(J)(2)(iiil--Discussion of any unusual characteristics of the work location (e.g., heat, noise) that alrectly 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., contractor personndl, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequat .

C-3 I l

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - -------A

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ -

-

[' . , . -

1 TABLE C- (ccntinued)

Number of LERs with

-

Deficiencies and Observations Sub-paragraph Paragraph Description of' Deficiencies and Observations a Totals Totals'( )

50.73(b)(2)(ii)(K)--Automatic and/or manual 0 ( 4)

safety system responses were not included or were inadequat '50.73(b)(2)(ii)(L)--The manufacturer and/or 1 ( 1)

model number of each failed component was not included or was inadequat .73(b)(31--An assessment of the safety 4 ( 6)

consequences and implications of'the event was not included or was inadequat . OBSERVATION: The availability of 1

. 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 existe OBSERVATION: The consequences -2 of the event had it occurred under more severe conditions were not

. discussed. If the event occurred under what were considered the most severe conditions, the' text should so stat .;73(b)(4)--A discussion of any corrective 3 ( 6)

actions planned as a result of the event including those to reduce the probability of-similar events occurring in the future was not included or was inadequat .

C-4

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- _ _ - - - _ _ _ _ _ _ _-_ _ . _ _ _ - _____ - . _ _ . _ _ _ _ __ __ __

- - _ _ _ _ - - __

, . TABLE C- (csntinued)

. ]

.

Number of LERs with

- Deficiencies and )

Observations lj Sub-paragraph Paragr6ph j a b Description of Deficiencies and Observations Totals 'otals ( l a. A discussion of actions required to 0 )

correct the problem (e.g., return the i component or system to an operational  !

condition or correct the personnel  !

error) was not included or was inadequat p!

b. A discussion of actions required to 3 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not

- included or was inadequate, c. OBSERVATION: A discussion of actions 0 required to prevent similar failures l in similar and/or other systems (e.g.,

correct the faulty part in all components with the same manufacturer

'

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and model numt+r) was not included or was inadequat .73(b)(5)--Information concerning previous 1 ( 6)

similar events was not included or was inadequat '.

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_____ _ _____ -

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, TABLE C- (continued)

.'

Wumber of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )D 50.73(b)(2)(i)--Text presentation inadequacie ( 6) OBSERVAT10fl: A diagram would have aided in understanding the text discussio Text contained undefined acronyms and/or plant specific designator The text contains other specific deficiencies relating to the readabilit .

- 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, The " paragraph total" is the number of LEPs that have one or more s requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicabl !

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- _ - _ _ _ _ _ _ -

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TABLE C- *

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ABSTRACT DEtlCIENCIES AND OBSERVATIONS FOR SEABROOK

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' Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

A summary of occurrences (immediate cause and effect) was not included or was 1 ( 6)

inadequat A summary of plant, system, and/or personnel responses was not included or was 0 ( 4)

inadequat i

'

- Summary of plant responses was not included or vas inadequat Summary of system responses was not included or was inadequate, Summary of personnel responses was not

.

included or was inadequat ,

A summary of the root cause of the event was not included or was inadequat ( 6)

A summary of the corrective actions taken or planned as a result of the event was not 2 ( 6)

included or was inadequat >

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TABLE C- (continued)

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'&

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph-Description of Deficiencies and Observations Totals a

Totals ( )

Abstract presentation inadequacie ( 6) OBSERVATION: The abstract contains 1 information not included in the tex The abstract is intended to be a summary of the text, therefore, the text should discuss all information summarized in the abstrac . The abstract was greater than 0 1400 spaces, The abstract contains-undefined 0 acronyms and/or plant specific designator The abstract contains other specific 0

'

deficiencies (i.e., poor summarization, contradictions, etc.), 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

,

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necessarily add up to the paragraph tota 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 applicabl __

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C-8

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TABLE C- CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SEABROOK 1;

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph description of Deficiencies and Observations ___ Totals' Totals ( )

Facility Name 0 ( 6) Unit number was not included or I incorrec Name was not-included or was incorrec Additional unit numbers were included but not require .

Docket Number was not included or was 0 ( 6)

incorrect.

'

Page Number was not included or was

incorrec ' 0 ( 6)

. Title was left blank or was inadequat ( 6) Root cause his not given or was 6 inadequate, Result (effect) was not given or was 2 inadequat , Link was not given or was 4 inadequat Event Date 0 ( 6)

Date not included or was incorrect, Discovery date given instead of event dat LER Number was not included or was incorrec ( 6)

Report Date 0 ( 6) i Date not include OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).

Other facilities information in field is 0 -( 6) 1 inconsistent with text and/or abstrac Operating Mode was not included or was inconsistent with text or abstrac ( 6) I C-9

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TABLE C-3-.

(centinued)

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Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a b Description of Deficiencies and Observations Totals 1 tais 0 l Power level was not included or was 0 ( 6)

inconsistent with text or abstrac Reporting Requirements 0 ( 6) The reason for checking the "0THER" requirement was not specified in the abstract and/or tex OBSERVATION: It may have been more appropriate to report the event under a different paragrap OBSERVATION: It may have been appropriate to report this event under an

-

additional unchecked paragrap Licensee Contact 6 ( 6) Field left blan O Position title was not include Name was not include O Phone number was not include '

Coded Component failure Information 0 ( 6) One or more component failure sub-fields were left blan i Cause, system, and/or component code is inconsistent with tex Component failure field contains data when no component failure occurre Component failure occurred but entire field left blank.

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,. TABLE C-3.':(continued)

N Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals # Totals ( )

Supplemental Repor ( 6) Neither."Yes"/"No" block of the 1 supplemental report field was checke The block checked was. inconsistent 0-with the tex . Expected submission date information i ( 6)

inconsistent with the block checked in Item (14).

-

- 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 tota The " paragraph' total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the c number of'LERs for which a certain requirement was considered applicabl I e i C-11 k

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APPENDIX D LER COMMENT SHEETS FOR SEABROOK t

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• TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK (443)

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Section Comments LER Number: 86-001-00 Scores: Text - Abstract - 1 Coded Fields - Overall - Text .73(b)(2)(11)(0)--The reason for the valve sticking was not discusse . 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not include . 50.73(b)(2)(ii)(L)--Wh11e the valve did not fail and l

, therefore, does not technically have to be identified, identification could be useful to others trying to determine whether they might have the same ;

proble . 50.73(b)(3)--0BSERVATION: The consequences of the event had it occurred under more severe conditions were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text. What would have j happened if pumps had been in operation? Abstract No commen *

Coded Fields Item (4)--Title: Root cause is not included and result is vagu A more appropriate title might be

"Possible Boron Dilution due to Chemical and Volume Control Valve being Erroneously Locked Open (Personnel Error)". Item (12)--Position title is not include . l l

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_ _ _ _ _ _ _ _ _ - - - _ - - - - - - -

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, TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK (443)

. Section Comments i LER Number: 86-002-00 Scores: . Text - Abstract - Coded Fields - Overall - Text .73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the pressurizer overflow is inadequate. Were the 89% pressurizer level and the open manual vent valve normal operating conditions for Mode 57 If not, why did these conditions exist? .73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not include . 50.73(b)(31--Discussion of the assessment'of the safety consequences and implications of the event is

-

inadequat OBSERVATION: The consequences of the event had it occurred under more s'evere conditions were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the tex See text comment number . 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions

,

required to reduce the probability of recurrence (i.e correction of the root cause) is not inc15de See text comment number Abstract 1, 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate. The pressurizer overflow problem is not mentione . 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The human factors analysis to determine the appropriateness of installing protective guards on the switches is not mentioned. Corrective actions to prevent recurrence of the pressurizer overflow are {

not mentione ;

Coded Fields Item (4)--Title: Root cause and link are not included. A better title might be: " Operator Inadvertently Resets Safety Injection Switch During Surveillance, Resulting in Safety Injection". Item (12)--Position title is not include I l

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TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK (443)

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l Section Comments LER Number: 86-003-00  !

l Scores: Text - Abstract - Coded Fields - Overall - Text .73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not include . 50.73(b)(2)(ii)(0)--The text states the cause of the spike but does not indicate what contributing factor is being investigated by the engineering analysi ! .73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or

.

system referred to in the text is not include . 30.73(b)(3)--Are there any safety implications concerning a transfer of the CBA to the recirculation mode? If no, the text should indicate same; if yes,

, they should be discusse , .73(b)(4)--Were other workers, who might also have to do similar work in the same area, also made aware of the details of this event? It is suggested that an outline format be used to present the text information (see NUREG-1022 Supplement No. 2. Appendices C and D),

s Abstract .73(b)(1)--Summary of corrective actions taken or  ;

planned as a result of the event is inadequate. The fact that an engineering analysis was initiated and why should have been mentioned in the abstrac Coded fields Item (4)--Title: Cause and link information is not provided. A better title would be " Control Room Ventilation Transfers To The Recirculation Mode When A Worker Inadvertently Struck A Radiation Monitor." Item (12)--Position title is not include .

!

0-3

- _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -

_ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- - -

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TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK (443)

/[ Section Comments LER Number: 87-001-00 Scores: Text , Abstract = Coded fields - Overall ~

Text .73(b)(2)(ii)( A)--Information concerning the plant operating conditions before the event is not include . 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the Geiger-Muller tube is not include ' .73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or ,

,

system referred to in the text is not include . 50.73(b)(2)(ii)(L)--Identification (e.g.,

manufacturer and model no.) of the failed component (s) discussed .in the text is inadequat . 50.73(b)(41--A discussion of actions required to reduce the probability of recurrence (i.e. correction of the root cause) is not included. Without knowing the cause for the failed Geiger-Muller tube (see text comment 2), it is not possible to determine if the new tube will also fail for the same reaso I

• .73(b)(5)--Information concerning previous similar events is inadequat This LER does not indicate if the causes for the isolation are similar or no Abstract The abstract summary of root cause and corrective actions is deficient for the same reasons as the tex Coded Fields Item (4)--Title: Root cause is not include . Item (12)--Position title is not include !

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-.__-__-..-_.-...-----:----7

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TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK (443)

,

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Section Comments LER Nunser: 87-002-00 Scores: Text - Abstract - 1 Coded fields - Overall - Text .73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not include Abstract No comment Coded fields Item (4)--Title: Root cause and link are not included. A better title might be: " Licensed Operator Inadvertently Opened Essential Bus Supply Breaker During Ter!'ng Resulting in Synchronization of Diesel Generat.. with Offsite Grid".

- Item (12)--Position title is not include !

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TABLE D- SPECIFIC LER COMMENTS FOR SEABROOK-(443)

'b

.. Section Comments a LER Nwter: 87-003-00 Scores: Text - Abstract - Coded Fields - Overall - Text .73(b)(2)(ii)(Al--Operational modes should be defined in the text (e.g., cold shutdown). .73(b)(2)(ii)(D)--Is the vendor-supplied computer program deficient in that there was no internal check for insufficient data?

' .73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not include . .73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. What are the safety consequences (if any) of having an analog channel of source range instrumentation not operational and not knowing about

-

it?

Abstract OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the tex '

Coded Fields Item (4)--Title: Cause and link information is not provided and the result is inadequate. A better title would be " Personnel Error (Failure To Input Sufficient Data) Results In Source Range Analog Channel Not Being Checked for Operability In The Time Required By The Technical Specification".

! Item (12)--Position title is not include . Item (1_41--Neither "Yes"/"No" block of the supplemental report field is checke .

D-6

,