ML20136J295

Forwards Assessment of LERs to Be Used as Input to SALP Evaluation.Lers Found to Be of Acceptable Quality Compared to Other Units.Large Number of Personnel Involved in LER Preparation Has Kept Plant from Obtaining Higher Scores

ML20136J295
Person / Time
Site:	Byron
Issue date:	11/14/1985
From:	Ippolito T NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20136J294	List: ML20136J289 ML20136J295
References
NUDOCS 8511250322
Download: ML20136J295 (76)

Text

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'8 o NUCLEAR REGULATORY COMMISSION

$ p WASHINGTON, D. C. 20555

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, NOV 14 W MEMORANDUM FOR: Charles E. Norelius, Director pllt N Division of Reactor Projects, egion III FROM: Thomas A. Ippolito, Deputy Director Office for Analysis and Evaluation of Operational. Data

SUBJECT:

SALP ASSESSMENT INPUT FOR BYRON In his memos dated July 1, 1985 and July 24, 1985, Jack Heltemes described a new methodology that we are using to assess the quality of LERs submitted by licensees.

This assessment would then serve;as an input to the SALP evaluation of the sub-ject facility.

Enclosed (Attachment B) is the assessment of the LERs from Byron. In general, we find the_se LERs to be of acceptable quality based on the requirements contained'in 10 CFR 50.73. The enclosed report provides the basis for this finding. We believe that it would be helpful if a copy of the enclosed report were provided to the licensee so that the specific deficiencies noted can be corrected in future LERs. '

As noted above, the Byron LERs are of average quality compared to other units that have been evaluated using this same methodology. There appears to be a facter that has kept Byron from obtaining higher overall scores. That factor is the large number of personnel involved in preparing LERs at Byron. Of the ,

30 LERs evaluated, there were 25 different licensee contacts representing many I different organizations (e.g., Tech Staff, Health Physics, Fire Marshall, System Testing, and Radiation Chemistry). If the person named as the licensee contact was in fact the principal author of the LER, then it is not practical to train the large number of different individuals with varying backgrounds and other primary responsibilities to prepare quality LERs. As will be seen in the attached report, the scores vary significantly for the LERs that were evaluated.

While there are many high scores, the number of low scores resulted in an overall average score that is mediocre. It appears that the number of indivi-duals preparing LERs should be reduced and that those who continue to be responsible for LER preparation should be provided additional training. If this is not poss Ole, an intensive review effort conducted by a small number of personnel that are very familiar with LER requirements is needed to reduce the number of less than average LERs.

8511250322 851119 PDR ADOCK 05000454 G PDR NOV151985

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Mr. Charles E. Norelius NOV 14 tas In addition, we recently completed a study (AE0D/P504) of unplanned reactor trips that occurred in 1984. A summary table of reactor trip frequencies from that study is provided in Attachment A.

Please call me or Fred Hebdon on (FTS 492-4480) if you have any questions concerning this matter.

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Thomas . Ippolito, Deputy Director Office for Analysis and Evaluation of Operational Data

Enclosures:

As Stated cc: M. Pearson, RIII C. Miller, INEL l

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r APPENDIX A 1984 REACTOR TRIP RATES TRIP RATE PER HEAN T!HE LESS THAN OREATER CRITICAL BETWEEN TRIPS NAME MANUAL AUTO THAN HOURS 1000 HOURS HATIC OR EQUAL POWER GT 15 POWER OT 15%

15% POWER 15% POWER 5.70 175.5 .

4 20 7 17 2983.0 5.30 188.6 WPPSS 2 13 6 6 1131.5 .

3.96 252.5 CALLAWAY 1 1 6 3 4 1010.0 3.26 306.6 GRAND GULF 1 2 1

7 2145.9 2.62 381.8

$USQUENANNA 2 2 10 8

3 7 2672.3 2.61 383.6 SALEM 1- 0 16 6138.3 423.3 13 0 2.36 MCGUIRE 2 5 2 8 3386.0 2.25 444.1 0 10 3108.7 SALEM 2 0 0 7 2.07 483.6 HATCH 2 -

7 2 967.1 496.6 DIASLO CANYON 1 0 7 3 9 4469.8 2.01 619.6 LASALLE 2 3 8 2 12 T435.3 1.61 700.7 2 13 2 700.7 1,43 SURRY 2 0 1 1 1.43 697.8 BROWNS FERRY 3 2 0 9 6280.0 703.8 LASALLE 1 0 9 9 6334.0 1.42 793.3 10 0 1.26 SEQUOYAH 2 0 6 4759.9 819.9 NORTH ANNA 1 2 7 2 9 7379.2 1.22 846.6 9 0 1.18 ST.LUCIE 2 1 6 5079.8 882.3 TURKEY POINT 4 0 11 3 6 5293.7 1.13 882.5 SURRY 1 1 7 2 6 5294.8 1.13 886.6 0.C.C00K 2 2 6 1 7 6206.1 1.13 925.6 SEQUOYAH 1 1 12 4 6 5553.4 1.08 935.6 12 5 1.07

$UMMER 0 0 7 6549.3 972.3 1 6 3889.0 1.03

• SUSOUENANNA 1 0 9 4 4 4895.4 1.02 979.1 ORESDEN 3 5 991.7 TROJAN O 7 2 6941;6 1.01 0 9 0 7 7366.6 0.95 1052.4

• INDIAN POINT 3 1 7

0.94 1062.4 TURKEY POINT 3 1 8 7 7437.0 1111.0 LA CROSSE 1 8 0 5 5555.2 0.90 2 4 1 5638.7 0.89 1127.7

• ST.LUCIE 1 7 3 5 0.82- 1218.2 HATCH ! 3 0 5 6090.8 1267.7 MCGUIRE 1 0 . 5 4 5070.7 0.79 0 9 3 7631.9 0.79 1272.0 SAN ONOFRE 3 6 1279.7 ARKANSAS 2 0 15 6 5 6398.6 0.78 2 3 0 5338.8 0.75 1334.7 YANKEE ROWE 0 4 1325.1 RANCHO SECO 1 0 4 2 2650.1 0.75 1325.4 SRUNSWICK 2 0 3 1 5 6627.1 0.75 1382.3 .

OUANE ARNOLD . 0 6 1 0 4 552* 0 0.72 1396.0 i

DAVIS-8 ESSE 1 1 4 6 8375.7 0.72 i 1 5 0 i FARLEY 2

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APPEN0!x A 1984 REACTOR TRIP RATES TRIP RATE PER HEAN TIME LESS THAN OREATER CRITICAL BETWEEN TRIPS NAME MANUAL AUTO THAN HOURS 1000 HOURS MATIC OR EQUAL POWER GT 15 POWER OT 15%

15% POWER 15% POWER 0.71 1404,8 5 7023,8 1506.2 2 0.66 BRUNSWICK 1 0 7 0 5 7531.0 0.64 1550.5 CALVERT CLIFFS 1 4 1 0 1 1550.5 0.64 1551.5 PALISADES 0 1

'O 5 7757.7 1589.0 1 4 4766.9 0.63 PEACH BOTTOM 3 3 0 3 6319.8 0.63 1579.9 OUA0 CITIES 1 1 6 2 4 0.62 1613.5 ZION 1 0 3 5 8067.4 0.62 1619.1 8AOWNS FERRY 1 4 4 4 6476.3 1630.2 BEAVER VALLEY 1 1 6 0 4 6520.7 0.61 1672.2 OCONEC 3 0 4 0 4 6688,8 0.60 1757.5 MAINE VANKEE 1 7 3 3 5272.4 0.57 1771.8 SAM ONOFRE 2 1 4 2 4 7087.2 0.56

• 2074.1 FITZPATRICK 0 4 0 3 6222.4 0.48 2170.5 ARKANSAS 1 0 3 0

• 3 6511.4 0.46 2359.2 3 0 0.42 DRESDEN 2 0 2 4718.4 2484.1 INDIAN POINT 2 1 5 2 3 7452.4 0.40

• 2695.3 OCONEE 1 0 3 0 3 8085.9 0.37 2773.8 0.C. COOK 1 0 3 0 3 8321.3 0.36 2947.9 PRAIRIE ISLAND 1 0 4 1 2 5895.7 0.34 2976.3 1

0 3 0 5952.6 0.34 BROWNS FERRY 2 0 3 1 2 6136.0 0.33 3068.0 COOPER 1 4 2 2 6285.2 0.32 3142.6 NORTH ANNA 2 6 5 2 0.31 3257.8 ZION 2 2 2 6515.6 3315.1 NA00AM NECK 1 3 1 2 6630.2 0.30 3494.3 2 0 0.29 CALVERT. CLIFFS 2 0 0 2 6988.6 3557.6 QUA0 CITIES 2 1 4 7115.2 0.28 s' 2 0 2 0.26 3785.3 VERMONT YANKEE O 2 7570.5 4173.3 O $ 2 8346.5 0.24 KEWAUNEE 0 2 0 2 0.23 4298.4 CRYSTAL RIVER 3 2 8596.8 5386.3 HILL $ TONE 2 1 2 1 5386.3 0.19 6848.7 0 0 1 0.15 FORT CALHOUN 1 1 0 1 6848.7 7005.8 R.E.0!NNA 0

• 1 7005.8 0.14 FARLEY 1 0 2 1 1 0 6981.9 0.00 .

BIO ROCK POINT 0 3 3 0 888.6 0.00 SAN ONOFRE 1 0 0 0 0 1700.0 0.00 .

OYSTER CREEK 0 2 2 0 6414.0 0.00 .

NINE MILE POINT 1 0 1 1 0 6990.2 0.00 .

MILLSTONE 1 0 0 0 0 616.1 0.00 .

O 1 0 H.8. ROBINSON 9

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APPENDIX A 1984. REACTOR TRIP RATES .

CRITICAL TRIP RATE PER HEAN TIME MANUAL AUTO LESS THAN GREATER BETWETH TRIPS NAME THAN HOURS 1000 HOURS HATIC OR EQUAL POWER GT 15 POWER pit 15%

155 POWER 15% POWEA 0 810.6 0 . .

0 0 0 HONTICELLO 0 0 6420.1' O 0

POINT SEACH 1 1 1 0 0 8784.0 . .

0 0 0 1

OCONEE 2 0 0 0 0 2583.9 0

> PEACH SOTTOM 2 0 0 0 0 170.3 .

PILGRIM 0 7544.2 0 .

J 0 1 0 0

! POINT SEACH 2 0 0 0 7844,0 ,

PRAIRIE ISLAND 2 0 0.0 .

2 0 0 0 .

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s AE0D INPUT TO SALP REVIEW FOR BYRON 1 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Byron 1 during the May 1,1984 to October 31, 1985 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the unit's LERs was evaluated I

using a refinement of the basic methodology presented in NUREG/CR-4178 .

a The sample consisted of 30 LERs for Byron 1. Byron 2 was not addressed as there were no LERs in the file for Byron 2 at the time the evaluation was started. See Appendix A for a list of the LER numbers in the sample.

It was necessary to start the evaluation before the end of the SALP assessment period because the input was due such a short time after the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for review.

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 2 3 4 the requirements of NUREG-1022 , and Supplements 1 and 2 to NUREG-1022.

The evaluation process for each LER is divided into two parts. The first part of the evaluation consists of documenting comments specific to the content and presentation of each LER. The second part consits of determining a score (0-10 points) for the text, abstract, and coded fields of each LER.

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a. Thirty is considered to be the maximum number'of LERs required to be evaluated for each unit during an assessment period.

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! 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 were reviewed. Likewise, the scores serve two purposes; (1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for the overall score determined for each LER. The overall score for each LER is tne result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score = overall LER score).

I Evaluation Results The results of the LER quality evaluation are divided into two categories: (1) detailed information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix B), tables of'the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analyst has flexibility to consider the magnitude of a deficiency when assigning scores.

Discussion of Results Although the purpose of this evaluation was to assess the quality of the contents of the individual LERs selcted for review, the analysts often make other observations which they believe should be brought to the attention of the reader. The following discussion addresses a general observation that was no,ticed for Byron 1 during the evaluation of the unit's LERs.

A General Observation Byron 1 LERs are average compared to other units that have been evaluated using this same methodology. The specific deficiencies that resultea in Byron's scores will be discussed in a later section; however, there appears to be a factor that has kept Byron from obtaining higher overall scores. That factor is the large number of personnel involved in preparing LERs at Byron. Of tne thirty LERs evaluated, there were twenty-five different licensee contacts representing many different organizations (e.g., Tech Staff, Health Physics, Fire Marshall, System Testing, and. Radiation Chemistry). (Note: It was assumed that the person named as the licensee contact was in f act the principle author of the LER.) The analysts believe that it is not practical to try to train such a large number of different individuals with varying backgrounds and other primary responsibilities to prepare quality LERs. As will be seen in a later table, the scores vary significantly for the LERs that were evaluated. While there are many high scores, the number of low scores resulted in an overall average score that is mediocre. It appears that the number of individuals preparing LERs should be reduced and that those who continue to be responsible for LER preparation should be provided additional training. If this is not possible, an intensive review effort conaucted by a small number of personnel that are very familiar with LER requirements is needed to reduce the number of less than average LERs.

LER Quality Results A discussion of the analysts' conclusions concerning LER quality are 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 represent the analysts' assessment of each units performance (on a scale of 0 to 10)~ in submitting LERs that meet the requirements of 10 CFR 50.73(b).

Table I presents the average scores for the sample of LERs evaluated for Byron 1. The reader is cautioned that the scores resulting from the methodology used for this evaluation are'not directly comparable to the

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SUMMARY

OF SCORES FOR BYRON 1 Average High Low Text 7.5 8.9 5.0 Abstract 7.3 9.8 3.4 8.3 10.0 7.1 Coded Fields Overall 7.5b 8.9 5.1

a. See Appendix B for a summary of scores for each LER that was evaluated.

b. Overall Average = 60% Text Average + 30% Abstract Average + 10% Coded

' Fields Average.

TABLE 2. COMPARIS0N OF AVERAGE SCORES FROM OTHER UNITS Coded Text Abstract Fields Overall End SALP a Average Average Average Average Unit Name Period 8.9 8.9 8.6 8.9 Salem 2 9-30-85 9-30-85 8.6 9.0 8.9 8.8 Salem 1 .

8.4 8.3 8.5 8.4 Palisades 10-31-85 )

7.9 8.1 8.6 8.0 LaSalle 1 9-30-85 8.0 7.7 8.6 8.0 LaSalle 2 9-30-85 8.0 7.4 8.6 7.9 Catawba 1 9-30-85 7.8 7.6 8.9 7.8 Trojan 10-31-85 10-31-85 7.6 7.8 8.1 7.7 Pilgrim 1 7.2 8.3 8.8 7.7 Beaver Valley 1 9-30-85 7.5 7.3 8.5 7.5 Maine Yankee 10-31-85 7.9 6.4 8.6 7.5 Quad Cities 2 9-30-85 7.5 7.3 8.3 7.5 Byron 1 10-31-85 7.9 6.5 8.4 7.5 Quad Cities 1 9-30-85 6.8 8.5 8.5 7.5 Brunswick 1 10-31-85 6.7 8.3 8.4 7.3 D. C. Cook 2 9-30-85 9-30-85 7.2 7.3 8.0 7.3 Dresden 3 6.8 7.7 8.4 7.3 Palo verde 1 9-30-85 6.4 8.3 8.4 7.2 D. C. Cook 1 9-30-85 9-30-85 7.2 6.7 8.2 Zion 2-7.1 6.9 7.8 7.1 Robinson 2 10-31-85 7.0 7.0 8.2 7.1 Vermont Yankee 10-18-85 6.9 7.3 7.9 7.1 Dresden 2 9-30-85

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i TABLE 2. -(continued) l Coded I Text Abstract Fields Overall i End SALP Average a Average Average Average Unit Name Period 6.0 7.9 8.8 6.8 ,

Brunswick 2 10-31-85 I 6.0 7.5 7.9 6.6 Zion 1 9-30-85 l

a. Units are ordered by overall average score.

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TABLE 3. LER REQUIREMENT PERCENTAGE SCORES FOR BYRON l Percentage TEXT Scores ( )a Requirements f50.73(b)] - Descriptions 81 (29)

Plant condition prior to event b (2)(ii)(A)

Inoperable equipment that contributed 80 (30)

(2)(ii)(B) - Date(s) and approximate times (2)(ii)(C) 78 (30)

Root cause and intermediate cause(s) 79 (9)

(2)(ii)(D) - Mode, mechanism, and effect 3 (30)

(2)(ii)(E) -

- EIIS Codes (2)(ii)(F) b Secondary function affected 44 (16)

(2)(ii)(G)

Estimate of unavailability 90 (30)

(2){fi)(H) - Method of discovery (2)(ii)(1) 77 (16)

(2)(ii)(J)(1) - Operator actions affecting course 63 (17)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 92 (13)

- Safety system responses (2)(fi)(K) 17 (9)

Manufacturer and model no. information 81(30)

(2)(ii)(L)-- - - Assessment of safety consequences 79 (30)

(3) -- Corrective actions (4) -

93 (30)

(5) - -- Previous similar event information 75 (30)

Text presentation (2)(i) - - -

Percentage ABSTRACT ~

Scores (')a Requirements [50.73(b)(1)] - Descriptions 91 (30)

- Major occurrences (Immediate cause and effect information) 67 (30)

- Description of plant, system, component, and/or personnel responses 63(30)

- Root cause information 76 (30)

- Corrective Action information 70 (30)

- Abstract presentation

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TABLE 3. (continued)

CODED FIELDS Percentage Item Number (s) - Description Scores ( )a 100(30) 1, 2, and 3 - Facility name (unit no.), docket no. and page number (s) 43 (30) 4 - - - - - Title 97(30) 5, 6, and 7 - Event date, LER No., and report date 93 (30) 8 - - - - - Other facilities involved

. 97 (30) 9 and 10 - -- Operating mode and power level 100(30) 11 - - - - - Reporting requirements 93(30) 12 - - - - Licensee contact information

- Coded component failure information 89(30) 13 - - -

100 (30) 14 and 15 - Supplemental report information

a. Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.

Some requirements are not. applicable to all LERs, therefore, the (Note:

number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.

b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available It is to the analyst always whether given 100%

this requirement is applicable to a specific LER.

if it is provided and is always considered "not applicable" when it is not.

N In scores contained in NUREG/CR-4178 due to refinements in methodology.

order to place the scores provided in Table 1 in perspective, the scores from other units that have been evaluated using this methodology are provided in Table 2. Additional units will be added to Table 2 as they are evaluated. Table 3 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Byron's average score for the text of the LERs that were evaluated is 7.5 out of a possible 10 points. From Table 3 it can be seen that the text score actually resulted from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions The

• before the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation.

percent scores in the text summary section of Table 3 provide an indication of how well each text requirement was addressed by the licensee for the 30 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 3 will quickly point out where the licensee is experiencing the most difficulty in preparing LERs. For example, the first deficiency that stands out involves text requirement 50.73(b)(2)(ii)(F)-Energy Industry Identification System All thirty (30) of the licensee's LERs which were reviewed (EIIS) Codes.

did not contain any EIIS codes as required. The other requirements with relatively low percentage scores are discussed below.

Discussion of personnel errors.[ Requirement 50.73(b)(2)(ii)(J)(2)] has It appears that there a percentage of score (63%) which is below average.

For is a reluctance to discuss each personnel error in sufficient detail.

LERs involving personnel error, it is imperative that the text clearly indicates that a personnel error has occurred and that all of the apprNriate sections of Requirement 50.73(b)(2)(ii)(J)(2) are discussed.

Seven LERs of the,nine involving component failures, failed to adequately identify the failed component [ Requirement 50.73(b)(2)(ii)(L)].

Most of these seven gave neither the manufacturer nor the model number nor

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' the identification of possible generic problems in the nuclear industry.

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Approximately one-third of the LERs failed to provide adequate dates This and times for the various occurrences discussed in the text.

contributed to the low percentage score (44%) for requirement 50.73(b)(2)(ii)(H). If sufficient dates and times had been provided, the reader would have been able to determine the length of time that safety system trains or components were unavailable.

The text presentations suffer from the fact that they are not presented in a structured format such as would be provided by an outline.

In addition, most of the texts consist of a half page or less. It is difficult to satisfy all the necessary requirements in that amount of space.

The abstract scores are ger.erally low, with the exception of describing the major occurrences, which is a reflection of the deficiencies in the text. Over half of the abstracts used less than half of the space available. Five abstracts contained information that was not contained in the text.

Since the abstract is supposed to summarize the information in the text, all informatin in the abstract should be discussed in the text.

The main deficiency in the area of coded fields involves the title.

Most did Twenty-eight of the thirty titles did not indicate root cause.

provide information concerning the result of the event (i.e., why the event was required to be reported), but the link (i.e. circumstances or conditins which tie the root cause to the result) was inadequate in 21 titles. An example of a title that only addressed result might be " Reactor Scram".

This is inadequte in that the cause and link are not provided. A more appropriate title might be "Inadvertant Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title the reader knows the cause was either personnel or procedural and that testing was the factor that linked the cause to the result.

The remaining deficiencies concerning the coded fields involve Position title was not provided for seven of tne Items (12) and (13).

licensee contacts and eleven of the 30 LERs contain informatio fields of Item 13 even though a component failure is not involved in the event.

Table 4 provides a summary of the areas that need improvement for the For more specific information concerning deficiencies the Byron 1 LERs.

reader should refer to the information presented in Appendices C and D.

General guidance concerning these requirements can be found in NUREG-

- Supplement No. 2.

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h TABLE 4. AREAS MOST NEEDING IMPROVENENT FOR CYRON 1 LERs s Areas Comments Personnel error Some LERs exhibited a need to be more direct in stating that a personnel error had occurred. By _

doing this and discussing the details surrocnding the error, the requirements for personnel error are more likely to be met.

Manufacturer and model Detailed information is needhd in number information the text concerning failed (not -

faulted) components so that possible

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generic problems can be identified. s s ss Safety system unavailability Sufficient dates and timet should be

. included in the text to enable the -

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i reader to determine the length of ,N s time that safety system trains or components were out of service. , f ,

- , ,q EIIS codes All LERs are required to have EIIS ,

,- component function and system idsrtifier codes for each compenent or system discussed in,the tcAt.

Text presfntation Presentations are generally too <w

" ' ' short to adequately discuss all the requirements; An outline format

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Abstracts Abs. tracts-are generally too short to f , provide the necessary informaticn.

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Coded Fields -

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"" Titles are' lacking in the, area of

a. Titics. '( ' '

providing cause information and linking the cause to the result.

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s b, -Licensee contact Position title is reqJired in N, position title

• It9m 12 (see NUREG-1022, page 24).

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REFERENCES

1. B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (URAFI), NUREG/CR-4178, March 1985.

2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.

3. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 1, U.S. Nuclear Regulatory Commission, February 1984.

4. Office for Analysis and Evaluation of Operational Data, Licensee Event

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. Neport System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory y,

Commission, September 1985.

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR BYRON 1 l

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. TABLE A-1. LER SAMPLE SELECTION FOR BYRON 1 (454)

LER Sample Number LER Number Comments 1 84-006-00 2 84-009-00 3 84-014-00 4

84-021-01 ESF 5 84-031-00 6 84-032-00 7 84-034-00 8 84-036-00 9 84-039-00 ESF 10 84-040-00 SCRAM 11 84-041-00 12 84-043-00 13 85-016-00 SCRAM 14 85-017 L 15. 85-019-01 16 85-022-00 SCRAM 17 85-026-00 l

18 85-030-00 ESF

'19 85-034-00 ESF 20 85-035-00 ESF 21 85-046-00 SCRAM

.22 85-047-00 23 85-048-00 ESF 5

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- TABLE A-1. (continued)

Comments LER Sample Number LER Number 85-049-00 ESF 24 25 85-050-00 85-053-00 SCRAM 26 85-054-00 SCRAM 27-28 85-055-00 29- 85-056-00 30 85-059-00 i

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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR BYRON 1

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8 .' a-TABLE B-1. 'EVALCATION SCORES OF.IN0lVIDUAL LERs FOR BYROM.1 a-LER Sample Number 10 '11 12 13 14 15 16_1 4 5 6 7 8 9 1- 2 3 5.7 7.9 8.2 8.5 8.8 - 6.0 7.1 6.7 8.8 -5.6 8.1 7.4 8.8 5.3 ~

Text .5.5 8.6 5.0 9.8 8.6_ 9.5 6.0 5.0 6.7 9.3 6.1 5. 5 - 8.8 8.1 9.4 Abstract 3.4 8.9 7.5.

Ceded 8.3 8.1. 7.9 8.7 8.3- 8.3 8.3 7.8 7.6 8.9 9.3 8.3 .7.7 8.4 9.2 F itids 8.3

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8.6 6.8 5.7 8.6 8.3 8. 8 ~ .7.9 5. 9 '

Ovtra11 5.1

• 8.6 7.4 7.0 8.9. 5.9 7.4' ,8.0 LER Sanvle Number 27 28 29 30 AVERAGE 22 23 24 25 26 17 18 19 20 21

-7.8 7. 9 6.6 '8.2 8.4 7. 6 8. 9 6.9 ~ 7. 5 '

Text 5.0 8.6 8.5 8.3 8.5 6.6 6.6 9.1 8.5 9.5 4.7 8.8 7.3 7.8 7.0 9.5 3.9 8.0 . 7. 5 6.0 6.0

- Abstract Coded 7.3 8.1 10.0 9.5 8.8 '7.1 7.9 8.3 8.1 8.3 ' 8.4 8.8 8.3 . 8. l ' 8.4 Fields 8.7 8.5 8.3 7.4 7.6 7.5 8.8 7. 0 8.4 7.0 7.3 ~7.2 6.7 Overall 6.1 8.1

a. See Appendix A for a list of the corresponding LER numbers.

9

. ee APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR BYRON l e

i 9

i

TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR BYRON 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b 50.73(b)(2)(ii)(A)--Plant operating 8 (29) conditions before the event were not included ~or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 (9) 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 inadequate.

50.73(b)(2)(ii)(C)--Failure to include 9 (30) sufficient date and/or time information.

4

a. Date information was insufficient.

9

b. Time information was insufficient.

50.73(b)(2)(ii)(D)--The root cause and/or 10 (30) intermediate failure, system failure, or personnel error was not included or was inadequate.

a. Cause of component failure was not 5 incleded or was inadequate

b. Cause of system failure was not 3 included or was inadequate

c. Cause of personnel error was not 3 included or was inadequate.

50.73(b)(2)(ii)(E)--The failure mode, 3 (9) mechanism (immediate cause), and/or t.fect (consequence) for each failed component was not included or was inadequate.

a. Failure mode was not included or was 1 inadequate

b. 3 Mechanism (immediate cause) was not included or was inadequate

c. Effect (consequence) was not included 0 or was inadequate.

w TABLE C-1. (continued)

Numbr. of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )D 50.73(b)(2)(ii)(F)--The Energy Industry 30 (30)

Identification bystem Component function identifier for each component or system was not included.

0 (3) 50.73(b)(2)(ii)(G)--For a failure of a

. component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

8 (16) 50.73(b)(2)(ii)(H)--For a failure that rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

50.73(b)(2)(ii)(I)--The method of discovery 3 (30) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

a. Method of discovery for each 1 component failure was not included or was inadequate

b. Method of discovery for each system 1 failure was not included or was inadequate 2

c. Method of discovery for each l

personnel error was not included or was inadequate 0

l d. Method of discovery for each procedural error was not included or was inadequate.

s G

F.-

TABLE C-1. (continued)

Number of LERs with  !

Deficiencies and Observations Sub-paragraph Paragraph a Totals ( )D Totals _

Description of Deficiencies and Observations _ 6 (16) 50.73(b)(2)(ii)(J)(1)_--Operator actions that

~a ffected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

12 (17) 50.73(b)(2)(ii)(J)(2)--The discussion of each personnel error was not included or was inadequate, 5

a. OBSERVATION: A personnel error was implied by the text, but was not 1

b.

explicitly) 50.73(b)(2stated.

(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural was not included or was inadequate. 1

c. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 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. 0

d. 50.73(b)(2)(ii)(J)(2)(iii) -Discussion of any unusual characteristics of the work location (e.g., heat, noise) that -

directly contributed to the personnel error was not included or was inadequate. 0

e. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.

I h

TABLE C-1. ~(continued)

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

Description of Deficiencies and Observations Totals Totals ( )b

50.73(b)(2)(ii)(K)--Automatic and/or manual 2 (13) saf ety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 7 (9) model number of each failed component was

! - not included or was inadequate.

50.73(b)(3)--An assessment of the safety 8 (30) consequences and implications of the event was not included or was inadequate.

a. OBSERVATION: The availability of 3 other systems or components capable of mitigating the consequences of the event was not discussed. If no other systems or components were available, the text should state that none existed.

b. OBSERVATION: The consequences 3 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 state.

50.73(b)(4)--A discussion of any corrective 14 (30) 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 inadequate.

. l 1

TABLE C-1. (continued)

Number of LERs with I'

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

a. A discussion of actions required to 1

correct the problem (e.g., return the component or system to operation condition or correct the personnel error) was not included or was inadequate.

b. A discussion of actions required to 9 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.

8

c. OBSERVATION: A discussion of actions required to prevent similar failures in similar and/or other systems (e.g.,

correct the faulty part in all components with the same manufacturer '

and model number) was not included or was inadequate.

50.73(b)(5)--Information concerning previous 2(30) similar events was not included or was i inadequate.

4 9

' TABLE-C-1.- (continued) l Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observat1)ns Totals Totals ( )D I 50.73(b)(2)(1)--Text presentation 3 (30) inadequacies.

a. OBSERVATION: A diagram would have 0 aided in understanding the text l .. discussion.

l

b. Text contained undefined acronyms 3 and/or plant specific designators.

~

l

c. The text contains other specific 0 deficiencies relating to the l

j. readabili;y.

L .

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than i one deficiency for certain requirements, (e.g., an LER can be deficient in  !

.the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.

b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the rzquirement was applicable.

6

7. -

o TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR BYRON 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b A summary of occurrences (immediate cause 7 (30) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 18 (30) responses was not included or was

- inadequate.

a. Summary of plant responses was not 1 included or was inadequate.

b. Summary of system responses was not 4 included or was inadequate.

c. Summary of personnel responses was not 15 included or was inadequate.

A summary of the root cause of the event 12 (30) was not included or was inadequate.

A summary of the corrective actions taken or 15 (30) planned as a result of the event was not included or was inadequate.

l

TABLE C-2. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b Abstract presentation inadequacies 14 (30)

a. OBSERVATION: The abstract contains 5 information not included in the text.

The abstract is intended to be a summary of the text, therefore, the

~

text should discuss all information summarized in the abstract.

b. Tne abstract was greater than 1 1400 characters

c. The abstract contains undefined 1 acronyms and/or plant specific designators.

d. The abstract contains other specific 9 deficiencies (i.e., poor sunnarization, contradictions,etc.)

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (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 LERs that have one or more b.

i deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was applicable.

)

e

e.

TABLE'C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR BYRON 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b Facility Name 0 (30)

a. Unit number was not included or incorrect.

b. Name was not included or was incorrect.

. c. Additional unit numbers were included '

but not' required.

Docket Number was not included or was 0 (30) incorrect.

Page Number was not included or was 0 (30) incorrect.

Title was left blank or was inadequate 29 (30)

a. Root cause was not given in title 28

b. Result (effect) was not given in title 3

c. Link was not given in title 21 Event Date 3 (30)

a. Date not included or was incorrect. O

b. Discovery date given instead of event 3 date.

LER Number was not included or was incorrect 0 (30) l Report Date 0 (30)

a. Date not included

b. OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).

-Other Facilities information in field is 2 (30) inconsistent with text and/or abstract.

Operating Mode was not fncluded or was 1',30) inconsistent with text or abstract.

i

TABLE C-3. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )b Power level was not included or was 0 (30) inconsistent with text or abstract Reporting Requirements 1 (30)

a. The reason for checking the "0THER" 0 requirement was not specified in the abstract and/or text.

b. OBSERVATION: It would have been more 0 appropriate to report the event under a different paragraph.

c. OBSERVATION: It would have been 1 appropriate to report this event under additional unchecked paragraphs.

Licensee Contact 7 (30)

a. Field left blank 0

b. Position title was not included 7

c. Name was not included 0

d. Phone number was not included. O Coded Component Failure Information 14 (30)

a. One or more component f ailure 1 sub-fields were left blank. -

b. Cause, system, and/or component code 4 is inconsistent with text.

c. Component failure field contains data 11 when no component failure occurred.

d. Component f ailure occurred but entire 0 field left blank.

I

TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b Supplemental Report 0 (30) J

a. Neither "Yes"/"No" block of the sepplemental report field was checked,

b. The block checked was inconsistent l with the text.

Expected submission date information is 0 (30) inconsistent with the block checked in Item (14).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or i observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.

b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was applicable.

0

e

• =

APPENDIX D LER COMMENT SHEETS FOR BYRON 1

~

\

TABLE D 1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) t Comments Section LER Number: 84-006-00

1. Overall = 5.1 Coded Fields = 8.3 Text = 5.5 Abstract = 3.4 Scores:

1.

50.73(b)(2)(ii)(Al--Discussionofplantoperating Text __ conditions before the event is not included.

2.

50.73(b)(2)(ii)(Cl--Dates and approximate time ,

information for occurrences is not included.

3. 50.73(b)(2)(ii)(D)--The cause discussion for each system root and/or f ailure is intermediate <

inadequate.

4. 50.73(b)(2)(ii)(F1--TheEnergyIndustry Tdentification System component functioniden system referred to in the LER is not included.

5.

50.73(b)(2)(ii)(J)(1_l-Discussionofoperatoractions that affected the course of the event is inadequate.

Personnel error

6. 50.73(b)(2)(ii)(J)(21-08 is SERVAT implied but is not explicitly 10N:in the text.

stated 7.

50.73(b)(2)(ii)(J)(21 -Discussion of personnel error is not included.

8. 50.73(b)(2)(ii)(Kl_--Discussion manual safety system responses is inadequate. of automatic an

9. 50.73(b)(31--Discussion of the assessm not included.

10. 50.73(b)(4)--Discussion or planned is inadequate.

of corrective A discussion of actions actions t required to reduce the probability of recu or is inadequate.

j l-TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section l

1. LER Number: 84-006-00 (continued)

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.

1. 50.73(b)(1)--Summary of occurrences [innediate Abstract cause(s) and effects (s)] is inadequate.

2. 50.73(b)(1)--Summary of personnel responses is inadequate.

3. 50.73(b)(1)--Sunnary of system responses is not included.

4. 50.73(b)(1)--Summary of root cause is not included.

5. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is not included.

6. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

1 Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (13)--Cause, system, and/or component code is inconsistent with text.

G

M -

TABLE 0-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comnents LER Number: 84-009-00 2.

Scores: Text = 8.6 Abstract = 8.9 Coded Fields = 7.6 Overall = 8.6 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.

2. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.

3. 50.73(b)(4)--Discussion of corrective actions taken j or planned is inadequate. Were specific instructions written into the appropriate procedures?

4. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.

2. 50.73(b)(1)--Summary of root cause is inadequate.

OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

r TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

3. LER Number: 84-014-00 Scores: Text = 7.1 Abstract = 7.5 Coded Fields = 8.9 Overall = 7.4 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.

2. 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion for each personnel error is not included.

~

3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate. More detail describing how the personnel error occurred are needed.

Abstract 1. 50.73(b)(1)--Summary of root cause is not included.

Coded Fields 1. Item (4)--Title: Root cause is not included.

2. Item (13)--Component failure field contains data when no component failure occurred.

l

4 TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

4. LER Number: 84-021-01 Scores: Text = 6.7 Abstract = 6.7 Coded Fields = 9.3 Overall = 7.0 Text 1. 50.73(b)(2)(ii)(A)--A brief description of the operating mode number should be included.

2. 50.73(b)(2)(ii)(D)--The text should include the root cause for the setpoint error.

3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the component failure is not included.

5. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.

6. 50.73(b)(5)--Information concerning previous similar events is not included.

7. 50.73(b)(5)--If no previous similar events are known, the text should 50 state.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is nut included.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause is not iacluded.

2. Item (8)--Field should be filled in with Not Applicable or NA.

9 l

l

_ _ . __-__________-___--__1

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

5. LER Number: 84-031-00 Scores: Text = 8.8 Abstract = 9.3 Coded Fields = 8.3 Overall = 8.9 Text 1. ' 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the f ailure of a safety system train until the train was returned to service is not included.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

OBSERVATION: The abstract contains information not included in tne text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

1 l

l e

\

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

6. LER humber: 84-032-00 Abstract = 6.1 Coded Fields = 7.7 Overall = 5.9 Scores: Text = 5.6 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is not included.

Personnel error

2. 50.73(b)(2)(ii)(J)(2)--0CSERVATION:

is implied but is not explicitly stated in the text.

3. 50.73(b)(2)(ii)(J)(2)_--Discussion of personnel error is not included. The fire penetration being improperly sealed had to be the result of a personnel act ion.

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error A should be considered and discussed if applicable.

discussion of actions required to reduce the probabilit of recurrence (i.e correction of the root cause is not included or is inadequate.

5. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function

! ioentifier(s) and/or system name of each component or i

system referred to in the LER is not included.

1. 50.73(b)(1)--Summary of occurrences [immediate Abstract

' cause(s) and effects (s)] is liadequate.

2. 50.73(b)(1)--Summary of personnel responses is inadequate.

3. 50.73(b)(1)--Summary of root cause is not included.

4 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) i Section Comments

6. LER Number: 84-032-00 (continued)

5. OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

6. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (5)--Discovery date is given instead of event date.

8

( -

J

r TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

7. LER Number: 84-034-00 Scores: Text = 8.1 Abstract = 5.5 Coded Fields = 8.4 Overall = 7.4 Text 1. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate. More details in regards to how this error occurred (e.g., did the Rad / Chem Technician actually see all nine of the radioactive sources or did he actually see only six?).

2. 50.73(b)(4)--Discussion of corrective actions taken

- or planned is inadequate. Were the Chem / Rad Technicians counseled?

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is not included.

2. 50.73(b)(1)--Summary of personnel responses is not included.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

4. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 20.402(b).

3. Item (13)--Component f ailure field contains data when no component failure occurred.

.O-TABLE D-1. . SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

8. LER Number: 84-036-00 Scores: Text = 7.4 Abstract = 8.8 Coded Fields = 9.2 Overall = 8.0

-Text 1. 50.73(b)(2)(ii)(A)--A brief description of the operating mode number should be included.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(3)--0BSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed. If no other systems or components are available, the text should so state.

OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state.

4. 50.73(b)(4)--The long term corrective actions should indicate how this incident will be prevented in the future (e.g., warning tags, increased training of new employees,etc.).

5. Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1. No comments.

Coded Fields 1. Item (4)--Title: Root cause is not included.

2. Item (8)--Field should be filled in with Not Applicable or NA.

3. Item (13)--Component f ailure field contains data when no component failure occurred.

F l

TABLE D 1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) l Comments Section

9. LER Number: 85-039-00 Coded Fields = 8.3 Overall = 8.6 Scores: Text = 8.8 Abstract = 8.1

1. 50.73(b)(2)(ii)(F)_--The Energy Industry Text Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 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 is not included.

3. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.

1, 50.73(b)(1)--Summary of occurrences [immediate Abstract cause(s) and effects (s)] is inadequate.

2. 50.73(b)(1)_--Summary of personnel responses is inadequate.

Coded Fields 1. Item (4)_--Title: Root cause and link are not Included.

O e

l TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) l Section Coments

10. LER Number: 84-040-00 Scores: Text = 5.3 Abstract = 9.4 Coded Fields = 8.1 Overall = 6.8 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure is inadequate.

2. 50.73(b)(2)(ii)(E)--The mechanism discussion of each failed component is inadequate.

3. 50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.

5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implicr.tions of the event is inadequate. What would be tna safety aspects if the plant was operatingi

6. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to correct the problem (e.g., return the component or system to an operational state or correct the personnel error) is not included or is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.

7. 50.73(b)(2)(ti)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate ciuse(s)andeffects(s)]isinaaequate.

m__ .

3 O

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

10. LER Number: 84-040-00 (continued)

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (12)--Position title is not included.

Note 1. The operating modes, and event dates given in the coded fields and the text do not agree.

l t f

l l  :

l i

r h

! 1 1 ,

l

TABLE 0-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

11. LER Number: 84-041-00 Scores: Text - 5.7 Abstract - 5.0 Coded fields = 7.9 Overall - 5.7 Text 1. 50.73(b)(2)(11)(0)--The root and/or intermediate cause discussion for each component failure and personnel error is not included.

2. 50.73Lb)(2)(ii)(F)--The Energy Industry Ident1fication System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(2)(ii)(J)(11--Discussion of operator actions that affected the course of the event is not included.

4. 50.73(b)(2)(11)(J)(21--Discussion of personnel error is inadequate. More details concerning the circumstances which caused the personnel error should be included.

5. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.

6. 50.73(b)(41--01scussion of corrective actions taken or planned is inadequate. What action was taken to satisfy the Technical Specification upon discovery of its violation?

Abstract 1. 50.73(b)(1)--Sumnery of personnel responses is not included.

2. 50.73(b)(1)--Summary of root cause is not included.

3. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.

Coded F telds 1. Item (41--Title: Root cause is not included. The occurrence involving technical specification i

violation was not included in the title.

l l 2. ' Item (131--Cause, system, and/or component code is

! inconsistent with text. The ultraviolet detector did not fail due to personnel error.

l I l 3. A logical transition does not exist between all ideas. l i

l i

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

12. LER Number: 84-043-00 Coded Fields = 8.7 Overall = 8.6 Scores: Text = 7.9 Abstract = 9.8

1. 50.73(b)(2)(ii)(A)--Theoperatingconditionsduring Text each event should be included, and operating mode numbers should be accompanied with a brief description.

2. 50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function

, identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(3l--Discussion of the assessment of the safety consequences and implications of the event is inadequate.

4. 50.73(b)(4)--The preventative measures should include long term actions, so that even a new employee will be made aware of the problem.

1. No comments.

Abstract Coded Fields 1. Item (4)--Title: Root cause is not included.

2. Item (8)--Field should be filled in with Not Applicable or NA.

3. Item (9)_--The operating mode in field differs from text or abstract.

4. Item (13)--Component failure field contains data when no component f ailure occurred.

I e

e

. l TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

13. LER Numoe_r_:

85-016-00 Coded Fields = 8.3 Overall = 8.3 I Abstract = 8.6 Scores: Text = 8.2

1. 50.73(b)(2)(ii)(F1--The Energy Industry Text Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time Trom the discovery of the failure of a safety system train until the train was returned to service is not included.

3. 50.73(b)(2)(ii)(J)(21--Discussion of personnel error

'is inadequate.

4. 50.73(b)(2)(ii)(J)(2)(il--Discussion as to whether the personnel error was cognitive or procedural is not included.

~

5. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 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 ana procedure is not included.

6. 50.73(b)(4)_--Discussion of corrective A discussion actions taken of actions or planned is inadequate.

required to reduce the probability)of recurrenceis not included (i.e, correction of the root cause or is inadequate.

OBSERVATION: Additional corrective actions based on the generic implications of the failure or errorsho l

1.

50.73(b)(11--Summary of occurrences [immediate Abstract Cause(s)andeffects(s)]isinadequate.

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Consnents Section __ __

85-016-00(continued)

13. LER Number:

2.

50.73(b)(11--Summary of system responses is

• inadequate.

3.

50.73(b)(1)_--Summary of corrective actions taken or planned as a result of the event is inadequate.

Root cause and link are not

1. Item (41--Title: -

Coded Fields Tncluded.

i i

. 1 I

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1

" ^ ^ - - - - . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _

l .

I TABLE 0-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

14. LER Number: 85-017-00 ,

Scores: Text = 8.5 Abstract = 9.5 Coded Fields = 8.3 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error  ;

is inadequate. ,

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or ,

system referred to in the LER is not included. 1 Abstract 1. 50.73(b)(1)--Summary of personnel responses is inadequate.

Item (4)--Title: Root cause and link are not Coded Fields 1.

included. l

2. Item (7)--0BSERVATION: Report date is not within ,

thirty days of event date (or discovery date if l appropriate).

+

t I

l 6

i

[

t

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

15. LER Number: 85-019-01 Coded Fields = 8.3 Overall = 7.9 Scores: Text = 8.8 Abstract = 6.0

1. 50.73(b)(2)(ii)(F)_--The Energy Industry Text Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(1)--Discussion of the method of discovery of the personnel error is not included.

1. 50.73(b)(1)--Summary of root cause is not included.

Abstract

2. 50.73(b)(1)_--Summary of corrective actions taken or planned as a result of the event is inadequate.

3. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to providr the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (12)--Position title is not included.

3. _ Item (13)_--Component failure field contains data when no component failure occurred.

l r

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments t

16. LER Number: 85-022-00 Scores: Text = 6.0 Abstract = 5.0 Coded Fields = 7.8 Overall = 5.9 Text 1. 50.73(b)(2)(li)(C)--The text should include dates and/or times for all occurrences, such as, the ,

investigation and repairs. l

2. 50.73(b)(2)(ii)(0)--When a root cause cannot be found (i.e., the reason for instrument N41 spiking), be  !

. sure to include details of all activities taken to ,

l locate the cause. i

3. 50.73(b)(2)fii)(F)--The Energy Industry  !

Identificatlon System component function j identifier (s)and/orsystemnameofeachcomponentor system referred to in the LER is not included.

l 4. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.

5. 50.73(b)(?)( ti)(L)_--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.

I

6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is ,

inadequate.

OBSERVATION: The availability of other systems or i components capable of mitigating the consequences of the event should be discussed. If no other systems  :'

or components are available, the text should so state.

OBSERVATION: The consequences of the event had it occurred under more severe conditions should be  !

discussed. If the event occurred under what are l considered the most severe conditions, the text

' should so state, ,  ;

7. 50.73(b)(4)--Discussion of corrective actions taken  !

& planned is inadequate. The discussion should include actions necessary to prevent recurrence. j

(

i

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

I a

L TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments ,

16. LER Number: 85-022-00(continued)

Abstract 1. 50.73(b)(1)--The abstract should give more details abouthowthedetectorfailed(i.e., erroneous signals).

2. 50.73(b)(1)--Summary of root cause is not included.

3. Abstract does not adequately summarize the text. l' Additional space is available within the abstract field to provide the necessary information but it was not utilized. 1 r

Coded Fields 1. Item (4)--Title: Rootcauseandresult(effect)are not included. .

2. Item (8)--Unit I was indicated under Item 1 and should not be shown in Item 8.

l I

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1 1

i I

l

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

P i

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Coments l

17. LER Number: 85-026-00 Scores: Text = 5.0 Abstract = 7.8 Coded Fields = 8.1 Overall = 6.1 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.

2. 50.73(b)(2?(ii)(F)--The Energy Industry Identification System component function .

identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(2)(ii)(1)--Dt.cussion of the method of discovery of the system f ailure is inadequate.

4. 50.73(b)(2)(ii)(1)--Discussion of the method of discovery of the personnel error is inadequate.  !

5. 50.73(b)(2)(ii)(J)(1)_--Discussion of operator actions that affected the course of the event is not included. L

6. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.

7. 50.73(b)(2)(ii)(J)(2)_--Discussionofpersonnelerror (

is not included.

8. 50.73(b)(3)_--Discussion of the assessment of the i

safety consequences and implications of the event is inadequate. ,

9. 50.73(b)(4)--Discussion of correctiva actions taken or planned is inadequate; correctivo actions i portaining to the mentioned, but undefined, air leakage should be discussed. A discussion of actions requiredtoreducetheprobability)ofrecurrence (i.e,correctionoftherootcause is not included

[

or is inadequate.

(

I OBSERVATION: Additional corrective actions based on the generic implications of the f ailure or error should be considered and discussed if applicable, Abstract 1. 90.73_(bilj,--Summary of occurrences (immediate I cause(s)andeffects(s)]isinadequate.

i i

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

_ _ _ _ _ _ _. _ ._. -. . _ __ ___ _ _._ .= __.__ _

l TABLE D-1. SPECIFIC LER CO M NTS FOR BYRON 1 (454)

Section Coments

17. LER Number: 85-026-00(continued)

2. 50.73(b)(1)--Summary of parsonnel responses is inadequate.

3. 50.73(b)(1)--Summary of root cause is inadequate.

4. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

Item (4)--Title: Root cause and link are not Coded Fields 1.

Included. l

[

2. Item (5)--Discovery date is given instead of event '

date.

3. Item (7)--0BSERVAT10N: Report date is not within thirty days of event date (or discovery date if appropriate).

i i

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, b

L TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON I (454)

Section Comments

18. LER Number: 85-030-00 Scores: Text = 8.6 Abstract = 7.0 Coded Fields = 8.3 Overall = 8.1 Text 1. 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion for each system failure is inadequate.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s)andeffects(s)]isinadequate.

2. 50.73(b)(1)--Summary of personnel responses is inadequate.

3. 50.73(b)(1)_--Summary of root cause is inadequate.

4. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (13)--Component f ailure field contains data when no component failure occurred.

3. Item (13)--Cause, system, and/or component code is inconsistent with text.

4 i

9 l

t I

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

19. LER Number: 85-034-00 Scores: Text = 8.5 Abstract = 9.5 Coded Fields = 8.4 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. To state that "all safeguards equipment operated properly" is not adequate; justification is needed.

Abstract 1. No comments.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (13)--Component f ailure field contains data when no component failure occurred.

9 l

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

. J I

! TABLE D-1. SPECIFIC LER COMMEhTS FOR BYRON 1 (454) i Section Comments

! 20. LER Number: 85-035-00 Scores: Text = 8.3 Abstract = 3.9 Coded Fields = 8.8 Overall = 7.0 i Text 1. 50.73(b)(2)(ii)(A)--When operating mode numbers are  ;

used, include a brief description with the number.

2. 50.73(b)(2)(ii)(C)--Include additional times for occurrences such as the second opening of the atmospheric relief valves and opening of the power operated relief valve.

3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or .

system referred to in the LER is not included.

4. 50.73(b)(3)--The safety assessment should consider i the implications of the pressure transients including i the possibility that the difficulty in controlling the pressure could have occurred under more severe ,

conditions and the availability of other systems and [

methods to help control pressure transients.

5. 50.73(b)(4)--The corrective actions given in the text +

address training of current employees, but the corrective actions should also indicate how future employees will be made aware of the event.

Abstract 1. 50.73(b)(1)--Summary of plant responses is not included.

2. 50.73(b)(1)--Summary of root cause is inadequate.

3. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause is not included.

l

_. . _ _ _ _ _ _ _ . , . _ . _ _ _ _ _ _ _ _ _ . . l

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

20. LER Number: 85-035-00(continued)

2. Item (8)--Field should be filled in with Not Applicable or NA.

3. Item (12)--Position title is not included.

4. Item (13)--Component f ailure field contains data when no component failure occurred.

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

21. LER Number: 85-016-00 Scores: Text = 8.5 Abstract = 8.0 Coded Fields = 8.3 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(E)--The mechanism discussion of each failed component is inadequate.

2. 50.73(b)(2)(ii)(F)--The Energy Industry 4 Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.

4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.

. 2. 50.73(b)(1)--Summary of system responses is inadequate.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

Coded Fields 1. Item (4)--Title: Root cause and link are not ircluced.

4 .

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON l (454)

Section Comments

22. LER Number: 85-047-00 Scores: Text = 6.6 Abstract = 7.5 Coded Fields = 8.1 Overall = 7.0 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system failure is inadequate.

2. 50.73(b)(2)(ii)(E)--The mechanism discussion of each failed component is inadequate.

3.

50.73(b)(2)(ii)(E)--The failure mode discussion of each failed component is inadequate.

4. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

5. 50.73(b)(2)(ii)(H)--Tne estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.

6. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.

7. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce (i.e, correction the probability)of of the root cause isrecurrence not included or is inadequate.

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considereo and discussed if applicable.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.

2. 50.73(b)(1)--Summary of personnel responses is -

inadequate.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

l

T

. TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) -

i l

Comments Section J

22. LER Number: 85-047-00(continued) i.

Coded Fields 1. Item (4)--Title: Root cause and link are not included.

1

2. __

Item (12)--Position title is not included.

9 1 i

i' I

1 $

I, 9 i l  !

i i

i

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

23. LER Number: 85-048-00 Scores: Text = 7.8 Abstract = 6.0 Coded Fields = 8.4 Overall = 7.3 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadequate. A better description of plant operating conditions, as they apply to the event, is needed.

2. 50.73(b)(2)(ii)(C)--Approximate time information for

- occurrences is inadequate.

3. 50.73(b)(2)(ii)(F)--The Energy industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4. 50.73(b)(2)(ii)(L)_--Identification (e.g. manufacturer and in the model text no.) of included is not the f ailed(i.e.,

component filter . (s)) discussed Abstract 1. 50.73(b)(1)--Summary of personnel responses is not included.

2. 50.73(b)(1)--Summary of corrective actions taken or ,

planned as a result of the event is inadequate.

3. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--The title contains acronyms which make it hard to read. Enough space is available to use the full length of the required words.

2. Item (4)--Title: Root cause is not included.

3. Item (13)--Cause, system, and/or component code is l

inconsistent with text. The code for filter is "FLT".

I r

l

. t l

s I

( TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments l-

24. LER Number: 85-049-00 Scores: Text = 7.9 Abstract = 6.0 Coded Fields = 7.3 Overall = 7.2 Text 1. 50.73(b)(2)(ii)(A)--Include a brief description of the operating mode number and indicate the power level.

2. 50.73(b)(2)(ii)(F)--The Energy' Industry Identification System component function identifier (s) and/or system name of each component or

. system referred to in the LER is not included.

3. Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1. 50.73(b)(1)--Include a summary of the personnel action taken to try to determine the cause of the actuation.

2. Abstract does not adequately summarize the text.

Additional space is assilable within the abstract field to provide the necessary information but it was not utilized.

3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.

Coded Fields 1. Item (4)--Use of acronyms in the title makes the title hard to understand. The title should also indicate that the root cause was a spurious signal.

2. Item (8)--The text implies that Unit 2 was involved.

3. Item (13)--Component f ailure field contains data when no component failure occurred.

9

4 s + -n-,< hW,~

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

25. LER Number: 85-050-00 Scores: Text = 6.6 Abstract = 6.6 Coded Fields = 8.1 Overall = 6.7 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.

3. 50.73(bl(2)(ii)(J)(2)--Discussion of personnel error is not included.

Abstract 1. 50.73(b)(1)--Summary of personnel responses is inadequate.

2. 50.73(b)(1)--Summary of root cause is not included.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

t Coded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (12)--Position title is not included.

l l

l l

l

l i - ..

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454) l

! Section Comments

26. LER Number: .85-053-00 l Scores: Text = 8.2 Abstract = 9.1 Coded Fields = 10.0 Overall = 8.7 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure is inadequate.

l

! 2. 50.73(b)(2)(ii)(F)--The Energy Industry ,

Identification System component function  !

identifier (s) and/or system name of each component or system referred to in the LER is not included.

l 3. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer

and model no.) of the failed component (s) discussed in the text is not included.

l Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate l

cause(s)andeffects(s)]isinadequate.

i

2. 50.73(b)(1)--Summary of personnel responses is l Inadequate.

l Coded Fields 1. No comments.

i l

e

r' '

i i TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section _ _

85-054-00

27. LER Number: Overall = 8.5 Coded Fields = 9.5 .

Abstract = 8.5 Scores: Text = 8.4 1.

50.73(b)(2)(ii)(F1--The Energy Industry Text Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. Ihat affected the course of the event is Personnel actions as a result of the scram a included.

3.

50.73(b)(2)(ii)(Ll-Identification (e.g. manufacturer d and model no.) of the failed component (s) discusse in the text is not included.

1.

50.73(b)(ll--Summary of personnel and system Abstract responses is not included.

Link is not included.

1. Item (41--Title:

Coded Fields 0

/

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Section Comments

28. LER Number: 85-055-00 Scores: Text = 7.6 Abstract = 9.5 Coded Fields = 8.8 Overall = 8.3 Text 1. 50.73(b)(2)(ii)(C)--The text shoulo include additional dates for such things as the corrective actions.

2. 50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.

4. 50.73(b)(2)(ii)(L)--The text did not include the model number of the valves involved.

5. 50.73(b)(4)--0BSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.

6. 50.73(b)(5)--Information concerning previous similar events is not included.

7. 50.73(b)(5)--if no previous similar events are known, the text should so state.

8. Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1. No comments.

Coded Fields 1. Item (4)_--Title: Root cause and link are not included.

2. Item (8)--Field should be filled in with flot Applicable or NA.

1 TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Coments Section _

28. LER Numbe_r:

85-055-00 (contini!ed) 1

3. Item (12)_--Position title is not included.

4. Item (13)--Component failure field contains data when This field should be no component failure occurred. filled in only for actual failures n failures.

l s

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b.

1

TABLE D-1. SPECIFIC LER COMMENTS FOR BYRON 1 (454)

Comments Section

29. LER Number _: 85-056-00 Coded Fields = 7.1 Overall = 7.4 Scores: Text = 8.9 Abstract = 4.7

1. 50.73(b)(2)(ii)(F)_--The Energy Industry Text Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(3)--Discussion of the assessment of the saf ety consequences and implications of the event is not incl,uded.

1. 50.73(b)(1)_--Summary of occurrences [immediate Abstract cause(s) and effects (s)] is not included.

2. 50.73(b)(1)_--Summary of personnel responses is inadequate.

3. 50.73(b)(1)_--Summary of root causes is not included.

4. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized ir. the abstract.

LCoded Fields 1. Item (4)--Title: Root cause and link are not included.

2. Item (5)_--Discovery date is given instead of event date.

3. Item (12)_--Position title is not included.

s

4. Item (13)--Component failure field contains data when no component failure occurred.

l I

L l

<< 1 TABLE D-l. SPECIFIC LER COMMENTS FOR BYRON l (454) l Comments Section --

30. LER Number: 85-059-00 Coded Fields = 7.9 Overall = 7.6 Abstract = 8.8 Scores: ' Text = 6.9 1.

Submittal of an LER without a text is acceptable; Text however, the abstract must then meet all the requirements of a text and still be less than 1400 characters.

The following comments apply to the abstract that was evaluated as if it were a text.

2. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.

3. 50.73(b)(2)(ii)(C)_--Dates and approximate time

'information for occurrences is inadequate.

4. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is inadequate.

5. 50.73(b)(2)(ii)(F)_--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

6. 50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is inadequate.

7. 50.73(b)(2)(ii)(J)(1)_--Discussion of operator actions that affected the course of the event is inadequate.

8. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.

9. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is inadequate.

10. 50.73(b)(41--Discussion of corrective A discussion actions taken of actions

~

or planned is inadequate.

! required to reduce the probability of recurrence

• (i.e, correction of the root cause) is not included or is inadequate.

e i TABLE D-1. SPECIFIC LER C0f44ENTS FOR BYRON 1 (454)

Section Comments

30. LER Number: 85-059-00(continued)

Abstract 1. The abstract contains greater tiieri 1400 characters.

Coded Fields 1. Item (4)--Title is incorrect. Title is misleading as the event was caused by personnel error and not by computer failure.

2. Item (4)--Title: Root cause and link are not included.

.