ML20141D473
| ML20141D473 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/03/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8604080093 | |
| Download: ML20141D473 (116) | |
Text
F lL APR - 3 1986 Docket No. 50-295 Docket No. 50-304 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen: The NRC's Office for Analysis and Evaluation of Operational Data (AEOD) has completed an assessment of Zion Nuclear Generating Station Licensee Event Reports (LERs) (Unit 1 - 22 LERs; Unit 2 - 12 LERs) as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Report. The report was mailed to you on December 19, 1985. Enclosed (Attachment C) is the assessment of the LERs from Zion Units 1 and 2. In general, AE00 found these LERs to be of barely acceptable quality based on the requirements contained in 10 CFR 50.73. The enclosed report provides the basis for this finding.
'A contributing factor to the low overall scores for Zion 1 and 2 may be the number of different people involved in preparing LERs at these units. (Note:
it was assumed that the person named as the licensee contact was in fact the principal author of each LER.) Of the total number of LERs evaluated for both units (34 LERs) there were 24 different authors. Sixteen of these authors prepared only one LER, while eight prepared more than one (i.e., seven prepared two and one prepared four). Four of the eight that prepared multiple LERs, did so for both units. We believe that it is not practical to try to train such a large number of individuals to prepare quality LERs. As can be seen in the attached report, the scores vary significantly for the LERs that were evaluated. The high scores are comparable with other units, but the low scores are in the majority. It would appear that the number of individuals preparing LERs should be significantly reduced (e.g., to those that are more often meeting the requirements). If this is not possible, an intensive training program is needed for all personnel responsible for LER preparation. In addition, an intensive review effort conducted by a small number of personnel that are very familiar with the LER requirements would also help. In addition to the analysis described above, AE00 completed a study (AEOD/P504) of unplanned reactor trips that occurred in 1984. A summary table of reactor trip frequencies from that study is provided in Attachment B. 8604080093 860403 DR ADOCK050g25 \\ I A/
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Commonwealth Edison Company 2 APR - 3 jus Finally, AE00 also completed a study (AEOD/PSD3) of ESF actuations that occurred during the first half of 1984. Several summary tables from that study are provided in Attachment A. We are providing a copy of the AEOD assessment so that you might be aware of the findings and take action to improve the overall quality of future LERs. We request that you provide Region III with the actions you intend to take to improve the overall quality of future LERs. We appreciate your cooperation with us in this natter. If you have any questions, please contact W. G. Guldemond (312/h?-5574). Sincerely, 80rfgtnal Signed by E.C. Creensen* Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
AEOD Assessment cc w/ enclosure: D. L. Farrar, Director of Nuclear Licensing G. Plim1, Station Manager Jan Norris, Project Manager, NRR DCS/RSB (RIDS) Licensing Fee Management Branch Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division Mayor, City of Zion RIII l' DIII RIII RI ' Ill AII'f
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" TABLE A.1 NUMBER OF ESF ACTUATIONS REPORTED BY COMMERCIAL U. S. NUCLEAR POWER PLANTS JANUARY 1. 1984 THROUGH JUNE 30, 1984 ESF UNIT ESF ACTUATIONS UNIT ACTUATION 3 SAN ONOFRE 2 82 SEQUOYAH 1 ARKANSAS NUCLEAR ONE 1 1 51 BIG ROCK POINT 1 WASHINGTON NUCLEAR 2 37 CALVERT CLIFFS 2 1 MONTICELLO 26 COOPER 1 D. C. COOK 2 25 DAVIS BESSE 1 1 DUANE ARNOLD 25 FT. ST. VRAIN 1 SEQUOYAH 2 21 GINNA LA SALLE 2 20 E. I. HATCH 2 1 1 FORT CALHOUN 20 NORTH ANNA 1 1 GRAND GULF 1 19 OYSTER CREEK LA SALLE 1 17 POINT BEACH 2 1 1 SAN ONOFRE 3 14 PRAIRIE ISLAND 2 1 BRUNSWICK 1 10 QUAD CITIES 2 1 SUSQUEHANNA 1 10 RANCHO SECO 1 DIABLO CANYON 1 9 - ROBINSON 2 1 MCGUIRE 1 7 SURRY 1 1 BRUNSWICK 2 6 CALVERT CLIFFS 1 O KEWAUNEE 6 CONNECTICUT YANKEE MAINE YANKEE O 6 DRESDEN 2 O PALISADES 6 DRESDEN 3 O SUMMER 1 6 FARLEY 1 O ARKANSAS NUCLEAR ONE 2 5 FARLEY 2 O BROWNS FERRY 1 4 E. I. HATCH 1 0 PEACH BOTTOM 2 4 HUMBOLDT BAY O BROWNS FERRY 3 3 INDIAN POINT 2 O D. C. COOK 1 3 MCGUIRE 2 O CRYSTAL RIVER 3 . 3 MILLSTONE 1 TROJAN 0 3 NORTH ANNA 2 O TURKEY POINT 3 3 OCONEE 1 0 TURKEY POINT 4 3 OCONEE 2 O YANKEE ROWE 3 OCONEE 3 BEAVER VALLEY 0 2 PEACH BOTTOM 3 O BROWNS FERRY 2 2 PILGRIM 1 0 CALLAWAY 2 POINT BEACH 1 O FITZPATRICK 2 PRAIRIt ISLAND 1 O INDIAN POINT 3 2 OUAD CITIES 1 O LACROSSE 2 SALEM 2 O MILLSTONE 2 2 ST. LUCIE 1 O NINE MILE POINT 2 ST. LUCIE 2 O SALEM 1 2 SURRY 2 O SAN ONOFRE 1 2 THREE MILE ISLAND 2 0 >s SUSQUEHANNA 2 2 ZION 2 O THREE MILE ISLAND 1 2 A VERMONT YANKEE 2 ZION 1 2 19
Definitions
- 1. Valid (design basis) actuation: the measured parameter actually reached the intended actuation setpoint and the condition that the ESF was intended to mitigate actually existed.
- 2. Valid (non-design basis) actuation: the measured parameter actually reached the intended actuation setpoint but the condition that the ESF was intended to mitigate did not exist. These ESF actuations resulted primarily because the actuation setpoints, as governed by the technical specification, were set very close to the parameter background levels experienced during various unit operational modes. These ESF actuations were considered to be valid but did not represent a required response to
,a design basis event. Rather, they were actuations resulting from non-design basis conditions, such as a accumulation of radioactive trash in front of a radiation monitor during refueling operations. These valid but non-design basis actuations were primarily associated with either toxic gas monitors or radiation-related monitors. The ESF actuations which resulted from these setpoints being reached were principally associated with isolation of the containment or auxiliary building, or with isolation of the control room emergency ventilation.
- 3. False actuation: the measured parameter did not reach the intended actuation setpoint. These actuations were a result of something other than the measured parameter reaching its intended setpoints. They were caused fairly equally by spurious signals, equipment failures, or problems related to personnel. These false ESF actuations principally affected systems whose functions were associated with either isolation or ventila-tion. The main parameters involved with these false actuations were radia-tion and loss of power.
i 0 10 20 30 0 50 60 70 0 90 SAN (NFRE 2 IIIIIIIIIIIIIIIIIIIII!!IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII ) StaJDYM 1 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII : WASHINGTON MJCLEAR 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII PCNi!CIl10 IIIIIIIIIIIIIIIIIIIIIIIIII D. C. COOK 2 IIIIIIIIIIIIIIIIIIIIIIIII l DuME ARNOLD IIIIIIIIIIIIIIIIIIIIIIIII l SEQlX1YAH 2 IIIIIIIIIIIIIIIIIIIII I
.LA SALLE 2 IIIIIIIIIIIIIIIIIIII FORT CALHOLN IIIIIIIIIIIII!!!IIII GLAND CLLE 1 IIIIIIIIIIIIIIIIIII LA SALLE I IIIIIIIIIIIIIIIII SAN ONOFRE 3 IIIIIIIIIIIIII R NSWICK 1 IIIIIIIIII SUSIRENMA 1 IIIIIIIIII DIABLO CANYON 1 IIIIIIIII PC0UIRE I IIIIIII l BRLMSWICK 2 IIIIII KEW UEE IIIIII MAIE YW'EE IIIIII PALISCES IIIIII SLMER 1 IIIIII AAXAN5AS NREAR OPE 2 IIIII 1RGNS FERRY I IIII PEACH BOTTCM 2 .
IIII U IR0lMS FERRY 3 III N D.C.CDOK1 III I CRYSTAL RIWR 3 III T TROJAN III RREY POINT 3 III N 115BIY POINT 4 !!! A YMIE ROLE III ' N KAVER VAL 1EY II - E BR0lMS FERRY 2 II S CALIAiAf II FITZPATRICX II INDIAN POINT 3 II LACROSSE II MILLST@E 2 II NIE MILE POINT II IMITS PETETIE m ESF ACTlMT!DG: SG 1 II SAN DERE 1 II CALVERT CLIFFS I OCDEE 2 SUSQLBW M A 2 II CD#ECTICIIT Yt#IE OCDEE 3 TifEE MILE ISUWD 1 II DRESEN 2 PEACH BOTTON 'l II IRESEN 3 PlLCRIM i
$ VERENT .ZICM I YWIE II FARLEY l POINT BEACH I ARKAN3AS MREAR DE I I TK1IY 2 F%AIRIE 1R # 0 1 BIG ROCX POINT I E.I. MIDI 1 QlAD CITIES I C4.WRT CLIFFS 2 I H.MBOLITT BAY SM 2 CDDPER I INDIAN FT)!NT 2 ST. LLCIE I DAVIS BESSE I I PC3JIPE 2 ST. LUCIE 2 FT. ST. VRAIN I MILLSTD E I StFRY 2 GIMM I NCRTH A N 2 TWIE MILE ISt#O 2 E.1.14TDI 2 I OCDEE 1 ~i Zl0N 2 NORTH AWA I I OYSTER CREEX I POINT BEACH 2 I PRAIRIE ISt# G 2 I 000 CITIES 2 I RAN W D SECD I ROBINTN 2 I SLERY I I 0 10 20 30 40 50 60 70 00 90 MMER 0F EST ACTUAi!OG Figure 1: Unit Distribution of Engineered Safety Features Actuations (January - June 1984)
0 10 20 30 40 50 60
- I i i : : :
SE0VOYAH I IIIIII IGJIE 1 II UN NA 10(T! CELLO II IM i E GRAND GLA.F I I SAN ON0FRE I I 0 10 20 30 40 50 60 LOSER (F VALID ESF ACTIMil(NS (DESIGN FASIS) 0 10 20 30 40 50 60 i : I ! : : SAN CNTRE 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII ' SER0YAH 1 IIIIIIIIIIIII D. C. C00K 2 IIIIIIIIIII FORT CAU U)I IIIIIIIIIII LA SALLE 1 IIIIIII LA SALLE 2 IIIIIII U GRAND 011F 1 IIIII N kPPSS 2 IIII
-! BRLNSWICX 1 III T FITIPATRICX II SUSQtD MPed 1 II N 210N 1 II
.A @NONS FURY I2 M iRNSWICK 2 I E D. C. CDCK 1 I NIE MILE POINT I SEGUDYAH 2 I SUKR 1 I TIR TY POINT 4 I YAl#IE ROE I I I ! I i ! :
0 to 20 30 40 50 60 LOSER OF VALID EST ACitni!0PG (N0pHESIGN BAS!$1 Figure 3: Unit Distribution of Valid ESF Actuations
l i 0 10 20 30 40 50 i I I i ! ! IPPSS 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII SEQUDYM 1 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII SM 90FPE 2 IIIIIIIIIIIIIIIIIIIIIIIIII IRJAE ARNCLD IIIIIIIIIIIIIIIIIIIIIIIII ft]NTICELLO IIIIIIIIIIIIIIIIIIIIIIII SEQl0VAH 2 IIIIIIIIIIIIIIIIIIII D. C. COOK 2 IIIIIIIIIIIIII SAN CBOFRE 3 IIIIIIIIIIIIII (RAND CtLF 1 IIIIIIIIIIIII LA SAuf 2 IIIIIIIIIIIII , LA SALLE 1 IIIIIIIIII DIABLO CMYCN IIIIIIIII FCRI CALMAN IIIIIIIII 1RtNSWICX 1 IIIIIIII SUS 0l0 WeM i IIIIIIII DI'mAlfEE IIIIII MIE YWIE IIIIII PALISACES IIIIII ARK MSAS 2 IIIII IfihSWICX 2 IIIII MEUIRE 1 IIIII SUPER I IIIII NONS FERRY ! IIII PEA 0f BOTTON 2 I!!! U lROWNS FERRY 3 III N CRYSTAL RIG 3 III I TR06M III T TlMIY POINT 3 III BEA ER VillEY II N Ct(LAWAY II A D.C.CQX 1 II M INDIM POINT 3 II E LA00SSE II MILLSTC8E 2 II SAE M 1 II SUSGt0 Wed 2 II TMI I II TLBIY POINT 4 II VEPJtNT YWIE II YWIE R0WE II ARV1 MAS I I BIG RCCX P0!MT I BROWS FEI6Y 2 I CALWRT C11FFS 2 I CDEKR I DAVIS BES T 1 I FT. ST. WAIN I G!ted I E. I. MTCH 2 I N!E MILE POINT I NCRTH 4ed i I OYSTER CRED( I POINT 10012 I PRAIRIE IRAND 2 I GUAD CITIES 2 I RATH0 SECO I ROBINSCN 2 I SM ONCffi ! I 9%Yl I I I I I I I o 10 20 30 40 50 AWER OF FALSE ESF ACTlMTIONS Figure 8: Unit Distribution of False ESF Actuations
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l l APPENDIX B 1984 REACTOR TRIP RATES h4ME MANUAL AUTO LESS THAN GREATER MATIC CRITICAL TRIP RATE PER MEAN TIME OR EQUAL THAN HOURS 1000 HOURS 15% POWER 15% POWER BLIWEEN TRIPS power GT 15 POWER OT 13% WPPSS 2 4 20 7 17 CALLAWAf 1 2983.0 5.70 175.5 1 13 6 6 1131.5 5.30 CAAhD GULF 1 2 6 3 4 1010.0 188.6 SuSQu(MAhmA 2 2 8 1 7 2145.9 3.96 252.5 SALEM 1 0 10 3 7 2672.3 3.26 306.6 MCGu!AE 2 5 13 0 16 6138.3 2.62 381.8 SALEM 2 0 10 2 2.61 383.6 MATCH 2 0 8 3386.0 2.36 423.3 7 0 7 3108.7 2.25
- DIASLO CANYON 1 0 7 3 444.1 l LASALLE 2 3 2 967.1 2,07 483.6 8 2 3 4469.8 2.01 Susav 2 2 13 2 12 7435.3 496.6 SeCaswS FERRY 3 2 0 1 1.61 619.6 LASALLE 1 0 1 700.7 1.43 700.7 9 0 9 6280.0 i SEQu0fAH 2 0 10 0 9 1.43 697.8 i
NORTH ANh4 1 2 7 2 6334.0 1.42 703.8 l ST LUCIE 2 1 9 0 6 4759.9 1.26 793.3 l TuenEY POINT 4 0 11 9 7379.2 1.22 819.9 3 6 5079.8 Suear 1 1 7 2 6 5293.7 1.18 846.6 D C C004 2 2 6 1 6 5294.8 1.13 802.3 SEQuov4H 1 1 12 4 1.13 802.5 SUMMER 0 12 7 6206.1 1.13 886.6 5 6 5553.4 SuSOUEM4hhA 1 1 6 0 7 6549.3 1.08 925.6 DaEEDEN 3 0 9 4 1.07 935.6 TROJAN 0 4 3889.0 1.03 972.3 7 2 5 4895.4 Ih0IAN POINT 3 0 9 0 7 1.02 979.1 Tunney POINT 3 1 8 6941.6 1.01 991.7 LA CROSSE 1 7 7366.6 0.95 1052.4 1 8 0 7 7437.0 0.94 ST LUCIE 1 2 4 1 5 5555.2 1062.4
- MATCM 1 3 7 0.90 1111.0 3 5 5638.7 0.89 MCGUIRE 1 0 5 0 1127.7 SAN Oh0FRE 3 0 9 5 6090.8 0.82 1218.2 l 3 4 50FO.7 0.79 AanAmSAS 2 0 15 6 1267.7 VAhKEE ROhE 2 6 7631.9 0.79 1272.0 3 0 5 6398.6 0.78 RANCMO SECO 1 0 4 0 1279.7 StumSWICK 2 0 3 4 5338.8 0.75 1334.7 OuAhE Ash 0LD o 6 1 2 2650.1 0.75 1325.1 Dav!S-5 ESSE 1 1 4 1
0 5 6627.1 0.75 1325.4 FARLEY 2 4 5529.0 0.72 1382.3 1 5 0 6 8375.7 0.72 1396.0 O e ' e w-
l .. l APPENDIX 8 1984. REACTOR TRIP RATES ( mAME MANUAL AUTO LESS THAN GREATER CRITICAL
- MATIC OR EQUAL THAN
- TRIP RATE PER MEAN TIME HOURS 1000 HOURS 15% POWER 15% POWER BETWEEN TRIPS POWER GT 15 POWER GT 15%
SRCNSWICK 1 0 7 2 CALVERT CLIFFS 1 4 1 0 5 7023.8 0.71 1404.8 PALISADES 0 1 0 5 7531.0 0.66 1506.2 PEACM SOTTOM 3 1 4 0 1 1550.5 0.64 1550.5 OUAD CITIES 1 5 7757.7 0.64 ZION 1 1 3 0 3 4768.9 1551.5 0 6 2 0.63 1589.0 BRowh5 FERRY 1 4 4 3 4 6319.8 0.63 1579.9 8EAVER VALLEY Z 5 8067.4 0.62 OCOmEE 3
! 6 0 4 6476.3 1613.5 0 4 0 4 6520.7 0.62 .
1619.1 MA t hE V AhnE E 1 7 3 0.61 1630.2 san ONOFRE 2 1 4 2 4 6688.8 0.60 1612.2 FITZPATRICK O 3 5272.4 0.57 4 0 4 7087.2 1757.5 i ARRANSAS 1 0 3 0 3 0.56
- 1771.8 l DRESDEN 2 0 6222.4 0.48 l Ih0IAN PO!hi 2 3 0
- 3 6511.4 2074.1 1 5 2 0.46 2170.5 OCOhEE 1 0 3 0 2 4718.4 0.42 2359.2 D C.C004 1 0 3 0 3 7452.4 0.40 2484.1 PRAIRIE !$ LAND 1 0 4 3 8085.9 0.37 2695.3 SROWNS FERay 2 0 3 0 1 3 8321.3 0.36 2773.8 COOPER 2 5895.7 0 3 0.34 2947.9 hCRTH Ah4A 2 1 4 1
2 2 5952.6 0.34 2976.3 ZION 2 2 6 5 2 5136.0 0.33 3068.0 MADOAM NECn 1 3 2 6285.2 0.32 3142.6 CALVERT CLIFFS 2 0 1 2 6515.6 0.31 QUAD CITIES 2 2 0 2 6630.2 3257.8 1 4 0 2 0.30 3315.1 VERMONT VAhnEE O 2 0 6988.6 0.29 3494.3 REWAuMEE O 5 2 7115.2 0.28 3557.6 2 2 7570.5 CRYSTAL RIVER 3 0 2 0 2 0.26 3785.3 MILLSTONE 2 1 2 1 8346.5 0.24 4173.3 FORT CALMOUN 1 0 1 0 2 8596.8 0.23 4298.4 a.E.GINmA 0 1 0 1 5386.3 0.19* 5386.3 FARLEV 1 0 2 1 1 6848.7 0.15 6848.7 BIG ROCK POINT 0 3 3 1 7005.8 0.14 7005.8 SAM ChCFRE 1 0 0 6981.9 0.00 0 0 0 Ov5TER CREEn 0 2 888.6 0.00 MIhE MILE POINT 1 0 2 0 1700.0 0,00 MILLSTChE 1 0 1 1 0 6414.0 0.00 0 0 0 M 8 RC8IhSON O 6990.2 0.00 1 0 0 616.1 0.00 ' l l l l
i APPENDIX 3 1984. REACTOR TRIP RATES hAMC MANUAL AUTO LESS TMAN GREATER CRITICAL } MATIC 08 EQUAL THAN TRIP RATE PER MEAN TIME MOURS 1000 HOURS ISE POWER 15% POWER BETWEEN TRIPS POWER GT 15 POWER GT 151 nossTICELLO O O O O 310.8 POINT SEACM 1 1 0 0 OconEE 2 0 1 0 6420.1 0 0 0 0 PEACM s0TTOM 2 0 0 0 8784.0 0 PILGRIN O 0 2583.9 0 O O O POINT SEACH 2 0 1 0 170.3 0 PR4!#!E ISLAM 0 2 0 0 0 7544.2 0 SveON
- 0 0 7844.0 I O O 0 O 0.0 5
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ENCLOSURE AE00 INPUT TO SALP REVIEW FOR ZION 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Zion 1 and Zion 2 during the May 1, 1984 to September 30, 1985 Systematic Assessment of Licensee Performance (SALP) assessment period, a sample of each unit's LERs was evaluated using a refinement of the basic methodologt presented in NUREG/CR-4178 . The sample consisted of 22 LERs Qr Zion 1 and 12 LERs for' Zion 2 which represents fifty percent of the LERs that were available for review at the time the evaluation 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 consisted of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields stet NUREG-1022 , and Supplements 1 and 2 to NUREG-1022. The evaluation process for each LER was divided into two parts. The first part of the evaluation consists of documenting coments specific to the content and presentation of each LER. The second part consists of determining a score (0-10 points) for the tert, abstract, and coded fleids of each LER. The LER specific coments serve two purposes; (1) they point out what the analysts considered to be the specific deficiencies or observations 1
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 the result of combining the scores for the text, abstract, and coded fields (i.e. 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields j score = overall LER score). Evaluation Results
' No attempt is made at this time to explain differences between results for multiple units beyond providing general coments, when applicable, in the Discussion of Results. However, as data 15 collected, scores for the units that have been evaluated will be presented for comparison purposes.
The results of the evaluation are presented by unit and are divided l into two categories: (1) detailed information and (2) sumary information. The detailed information, presented in Appendices A through 0, cansists of LER sample information (Appendix A), a table of the specific scores for each sample LER (Appendix B), tables of the number of l deficiencies and observations for the text, abstract and coded fields (Appendix C), and coment sheets for each LER ( Appendix D). When referring to these appendices, the reader is cautioned not to try to directly correlate the number of coments on an individual coment sheet with the assigned scores, as the analyst has flexibility to consider the magnitude of a deficiency when assigning scores. In the case where multiple units are evaluated, the results are i submitted in one enclosure and the summary tables are assigned an alphabetic character so that the different units can reference the same table numbers. f or example, the letters A and 8 assigned to a table number correspond to Unit 1 and 2, respectively for this enclosure. 2
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Discussion cf Results Although the purpose of this evaluation was to assess the quality of , the contents of the individual LERs selected for review, the analysis often make other observations that they believe should be brought to the attention of the reader. The discussion that follows addresses some general observations that were noted for Zion 1 and 2 during the course of the evaluation. General Observations Zion 1 and 2 are below average compared to other units that have been evaluated using the same methodology. The specific deficiencies that resulted.in the low overall scores for Zion 1 and 2 will be discussed in a later section; however, a contributing factor may be the number of different people involved in preparing LERs at these units. (Note: It was assumed that the person named as the licensee contact was in fact the principle author of each LER.) Of the total number of LERs evaluated for both units (34 LERs) there were 24 different authors. Sixteen of these authors prepared only one LER, while eight prepared more than one (i.e., seven prepared two and one prepared four). Four of the eight that prepared multiple LER's, did so for both units. The analysts believe that it is not practical to try to train such a large number of individuals to prepare quality LERs. As will be seen in a later table, the scores vary significantly for the LERs that were evaluated. The high scores are comparable with other units, but the low scores are in the majority. It would appear that the number of individuals preparing LfRs should be significantly reduced (e.g., to those that are more often meeting the requirements). If this is not possible, an intensive training program is needed for all personnel responsible for LfR preparation. (Note: An intensive review effort conducted by a small number of personnel that are very familiar with the LER requirements would also help.) 3
A minor administrative problem was noted that is possibly related to the large number of different authors, as well. Two of the Zion 1 LERs had duplicate numbers. Although not a major deficiency, such practices, even when corrected later, can lead to confusion for the user. One final observation involves two similar LERs, one for Zion 1 and one for Zion 2 (LER 85-002-00 at each unit). The events described in these LERs happened less than one month apart and toth LERs have the same licensee contact (author). Both events involve tubing leaks on a diesel (one in the fuel line and one in the lube oil line). What appears contradictory about these two LERs is that the Zion 1 report states the
" steel tubing was replaced with carbon steel pipe" while the Zion 2 report states the " copper tubing will be replaced with steel tubing". Unless there is a significant difference between the mechanism of failure for the fuel line versus the lube oil line, it appears that carbon steel piping may l
be needed for both diesels. LER Quality Results l 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 analyst's 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). I The analysts made no attempt to assess differences in scores or the number of deficiencies between units of a multiple unit plant because sufficient infornation is not available concerning how LERs are generated or reviewed at each unit. l The reader is cautioned that the scores resulting f rom the methodology l used for this evaluation are not directly comparable to the scores l contained in NUREG/CR-4178 due to refinements in the methodology. 4 ! i l l . _ _ _ _ _ _ - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _
Evaluation Results for Zion 1 Table 1A presents the average scores for the sample of LERs evaluated for Zion 1. In order to place the scores provided in Table 1A in perspective, the scores from other units that have been evaluated using this methodology are provided in Table 2. (Note: Additional units will be added to Table 2 as they are evaluated.) Table 3A and Appendix Table 8-1 provide a summary of the information that is the basis for the average scores in Table 1A. For example, Zion l's average score for the text of the LERs that were evaluated is 6.0 out of a possible 10 points. From Table 3A, 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 before the event [10 CfR 50.73(b)(2)(11)(A)] to text presentation. The percent scores in the text sunenary section of Table 3A provide an indication of how well each text requirement was addressed by the licensee for the 22 LERs that were evaluated. (Note the large spread between the high and low scores on Table 1A. Those spreads lead to the general observation concerning the number of different authors involved.) Discussion of Specific Deficiencies A review of the percentage scores in Table 3A will quickly point out where the unit is experiencing the most difficulty in preparing LERs. for example, the first requirement that has a score that is below average is 50.73(b)(2)(11)(A)--Plant conditions prior to the event. Eight of the LER, for which this requirement was deemed applicable, failed to provide adequate information concerning the conditions prior to the event, (e.g., inforn.ation such as plant power level, mode of operation, or plant or system,temperatureandpressure) The analysts realize that the plant power level is at times immaterial to the event being discussed, but other details are then needed to give the reader the necessary background to adequately understand the event. This may be as simple as stating what the person was doing when the occurrence, which led to the event, was 5
TABLE 1A. St# NARY OF SCORES
- FOR ZION 1 Averaae M Low Text 6.0 8.3 3.6 Abstract 7.5 9.1 4.5 Coded fields 7.9 9.2 6.2 Overall 6.6b 8.0 4.9 a.' See Appendix 8 for a summary of scores for each L[R that was evaluated,
- b. Overall Average . 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.
s - _ _ _ _ _ - - _ - - _ - - - - - - _ _ _ _ _ . _ . - _ _ - - - _ _ . _ _ . _ _ - - _ _ - _ _ _ - _ _ _ _ - - _ - _ _ . - - - - - _ - - _ - . _ . _ _ . - . _ _ _ _ _ _ . - _ - _ _ _ - . - _ _ _ _ . - - _ _ . _ _ . _ _ . _ _ - .
I l l TASLE 2. COMPARIS0N OF AVERAGE SCORES FROM OTHER UNITS Coded End SALP Text Abstract Fields AI39' Unit Name a Period Average Average Average ( lb Salem 2 9-30-85 8.9 8.9 8.6 8.9 (0.7) Salem 1 9-30-85 8.6 9.0 8.9 8.8 (0.9) LaSalle 1 9-30-85 7.9 8.1 8.6 8.0 (1.2) LaSalle 2 9-30-85 8.0 7.7 8.6 8.0 (1.3) Catawba 1 9-30-85 8.0 7.4 8.6 7.9 (1.0) Seaver Valley 1 9-30-85 7.? 8.3 8.8 7.7 (1.2) Quad Cities 2 9-30-85 7.9 6.4 8.6 7.5 (0.9) Quad Cities 1 9-30-85 7.9 6.5 8.4 7.5 (1.1) Cook 2 9-30-85 6.7 8.3 8.4 7.3 (0.8) Dresden 3 9-30-85 7.2 7.3 8.0 7.3 (1.4) Palo Verde 1 9-30-85 6.8 7.7 8.4 7.3 (1.7) Cook 1 9-30-85 6.4 8.3 8.4 7.2 (1.3) Zion 2 9-30-85 7.2 6.7 8.2 7.1 (1.0) Dresden 2 9-30-85 6.9 7.3 7.9 7.1 (1.4) Zion 1 9-30-85 6.0 7.5 7.9 6.6 (1.0)
- a. Units are ordered by overall average score.
- b. Standard deviation of overall average score.
TABLE 3A. LER REQUIREMENT PERCENTAGE SCORES FOR ZION 1 TEXT Percentage Requirements ISO.73(b)1 - Descriptions Scores ( )* (2)(11)(A) - - Plant condition prior to event 68 (20) (2)(11)(B) - - Inoperable equipment that contributed b (2)(11)(C) - - Date(s) and approximate times 50 (22) (2)(ii)(D) - - Root cause and intermediate cause(s) (2)(11)(E) - - Mode, mechanism, and effect 69 (22) 89 (13) (2)(11)(F) - - EIIS Codes 0 (22) (2)(ii)(G' - - Secondary function affected b (2)(11)(F -- Estimate of unavailability 78 (9) (2)(11)(13 -- Method of discovery 77 (22) (2)(11)(J)(1) - Operator actions affecting course 88 (15) (2)(11)(J)(2) - Personnel error (procedural deficiency) 53 (12) (2)(11)(K) - - Safety system responses 88 (8) (2)(11)(L) - - Manufacturer and model no infornetton 11 (9) (3) ----- Assessment of safety consequences 22 (22) (4) ----- Corrective actions 75 (22) (5) ----- Previous similar event information 32 (22) (2)(1) - - - - Text presentation 64 (22) ABSTRACT Percentage Reautrements f 50.73(b)(111 - Descriptions a Scores ( l
- Major occurrences (Immediate cause and effect 81 (22) information) - Description of plant, system, component, and/or 94 (19) personnel responses - Root cause information 63 (22) - Corrective Action information 68 (22) - Abstract presentation 72 (22)
TABLE 3A. (continued) CODED FIELDS Percentage item Number (s) - Description Scores ( l a 1, 2, and 3 - facility name (unit no.), docket no. and 97 (22) page number (s) 4 - - - - - - Title 39 (22) 5, 6, and 7 - Event date, LER No., and report date 94 (22) 8 - - - - - - Other facilities involved 89 (22) 9 and 10 - - Operating mode and power level 95 (22) 11 - - - - - Reporting requirements 98 (22) , 12 - - - - - Licensee contact information 78 (22) 13 - - - - - Coded component failure information 77 (22) 14 and 15 - - Supplemental report information 93 (22)
- a. Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(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 applicable.
- b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100%
- if it is provided and is always consideied "not applicable" when it is not.
discovered. However, for events involving safety related systems or components it is always a good idea to provide the operating mode and the power level or plant temperatures and pressure as appropriate. The remaining deficiencies will be discussed in their order of importance. The Zion 1 LERs were very deficient in the area of assessing safety consequences and implications. fifteen of the 22 LERs lack any statements concerning the safety consequences or implications of the event, five of the 22 LERs are deficient in that they lack information concerning how the stated conclusions were reached or they fail to state what the consequences might have been had the conditions at the time of the occurrence been more l severe. It is inadequate to state that "the consequences were mininu1 bec~ause all systems operated as designed". What if they hadn't operated as designed? In this case, the consequences may have been different. A better statement would be that "the consequences were minipal because Systems X and Y operated as designed and System Z was operable had Systems X and Y not functioned". Likewise, it is inadequate to state that "the consequences were minimal because the reactor was shutdown at the time of the occurrence" if it is possible for that same occurrence to happen during power operation. Immediate corrective actions are addressed adequately in most of the LERs. However, ter. of the 22 LERs fail to adequately address the long term aspect of corrective actions adequately (i.e., they failed to address the fix of the root cause and/or the application of the fix to other components, systems, personnel, or procedures). It is only through the implementation of long term corrective actions that the recurrence and the prevention of similar events will be lessened. Obviously to address root cause fixes, a root cause must be determined. Approximately half of the root cause discussions lacked the detail necessary to relate root cause and long term corrective actions. Personnel error discussions are not adequate for the 12 LER$ that involved personnel error. In many of these LERs, personnel error was not stated but could only be inferred from other information such as corrective 6
actions. As a minimum, the words personnel error should appear somewhere in the LER (i.e., text, abstract, or coded fields) so that a key word search would identify these LERs as involving personnel error. These LERs should also provide information as to the cause of the personnel error (cognitive or procedural) and the type of personnel involved. It should be remembered that the LERs are supposed to be written from the perspective of the operator. If this is done, the discussions involving personnel error should improve. Adequate dates and times are not present in over half of the 22 LERs. Dates, and especially times, are important information that enables the reader to gain a clearer understanding of the sequence of occurrences. Times should be provided for occurrences such as: discoveries, initations, scrams, significant plant transients, taking a system out of service, placing a component back in service, and the plant being placed in a safe and stable condition. Eight of the nine applicable LERs are deficient in that they do not contain adequate information concerning the nanufacturer and/or model number of the failed component discussed in the LER. Failed component identification is very important in that it can lead to the discovery of generic problems. Whenever there is any doubt as to whether the design of a component contributed in any way to the components failure, or even unavailability, that component should be properly identified within the text of the LER. - Previous similar event information is generally lacking. Sixteen of the 22 LERs either fail to reference similar events or fail to state that there were none. None of Zion's LERs contained Energy Industry Identification System (EIIS) codes as is required by 50.73(b)92)(ii)(F). Eleven of the 22 LERs contain acronyms or plant specific designators, which contributed to the low (64%) text presentation percentage score. Another factor that contributed to the low text presentation score involves 7 '
consistency. The use of an outline format as suggested in NUREG-1022 Supplement 2 would help in the preparation of more consistent and complete LERs. An outline would be especially helpful considering the number of individuals involved with LER preparation at Zion. The abstract deficiencies primarily involve root cause and corrective actions and are the result of failing to provide an adequate summary of these two areas in some abstracts. The abstract percentage scores for these areas should have been at least as high as the percentage scores for these same requirements in the text if the information in the text had been adequately summarized in the abstract. The abstract presentation percentage score reflects a number of deficiencies including: using undefined acronyms or plant specific designators, presenting information that was not discussed in the text, and failing to use the available space. The main deficiency in the area of coded fields involves Item 4--Title. Twenty of the 22 LER titles did not indicate root cause. All titles should contain root cause infornation as well as the effect of the failure or fault described in the LER. The effect (result) can be thought of in terms of why the event had to be reported (e.g., a technical specification violation, a scram, or a release of radioactive effluent). Often, the root cause and result need to be linked by a descriptive phrase that allows the reader to understand how the two ideas are related. Eleven of the 22 LERs for Zion 1 failed to provide such a phrase. It should be noted that the text should explain how the "other facility involved", Item 8, was involved. Naming another unit in Item 8 without any explanation does not help the reader. Fourteen of the LERs fail to provide a position title for the licensee contact as is required by NUREG-1022, page 24, Item 12. Seven of the 22 LERs contain information in the component failure fields (Item 13) even 8
though no component failure had occurred. This is obviously not a major deficiency, but can be misleading to the individual who scans this field to get a count of component failures. Table 4 provides a summary of the areas that need improvement for Zion 1 LERs. For more specific information concerning deficiencies the reader should refer to the information presented in Appendices C and D. General guidance concerning these areas can be found in NUREG-1022, Supplement No. 2. d
TABLE 4 AREAS MOST NEEDING IMPROVEMENT FOR ZION 1 AND ? LERs Areas Comments Safety assessment information Statements involv;ng consequences or implication of the event are typically missing. More effort needs to be placed on providing these details and discussing the consequences of the event occurring under a more severe set of conditions. Root cause discussions More details are needed; cause information could sometimes only be inferred from corrective actions. Corrective actions to More details are needed; immediate prevent recurrence correct 1ve actions are usually discussed but discussions concerning the actions necessary to reduce the probability of recurrence (i.e., fixing the root cause) and the
" prevention of similar events" are generally lacking. Prevention of similar events means applying the planned corrective actions to other components, personnel, or procedures when appropriate.
Personnel error discussions More details are needed; at times, personnel error was not even identified as being the root cause of the event although that appeared to be the case from the discussion. Operating conditions More details concerning power level, prior to the event mode of operation, and in some cases temperature and pressure should be provided. Previous similar Previous similar events should be events referenced (LER Number) or the text should state that there are none.
TABLE 4. (continued) Areas Comments Manufacturer and model Detailed infornetton should be number infornetton provided in the text concerning failed (not faulted) components so that possible generic problems can be identified. Text presentation consistency Most presentations lack any structuring or consistency such as would be provided by using an outline format. Date and approximate time (s) Sufficient dates and times should be information included in the text to enable the reader to have a time history of the occurrences within the event and to permit determination of the length of time that system trains and components were out of service. Text readability The use of acronyms and/or plant specific designators made some LERs hard to follow. Abstracts Root cause and corrective action information is generally lacking. The infornation concerning these requirements that is available in the text should be summarized in the abstract. Coded Fields
- a. Titles Titles should be written such that they better describe the essence of the event.
- b. Other facilities The text and/or abstract should involved state how the other facility is actually involved.
TABLE 4. (continued) Areas Consnent s
- c. Position title Position title should be included in addition to the licensee contact name.
- d. Component failure These fields should only be used when a component failure is involved, not faulted components.
l [ t
- -~ -,
w . - -- . _ - , - - , , - - - ,-,-e.,-- -,v--,--, ,_,,_,-,y _w , . . . , , -- ,- - - - nn,, ,,.. - e. - . - - , _ _ , - ,m- ,,.,
4 l l Evaluation Results for Zion 2 Tables 18 and 3B provide a summary of the Zion 2 evaluation. See l Table 2 to place the Zion 2 scores in perspective. A review of Table 3B indicates that Zion 2 has basically the same deficiencies as Zion 1 and, therefore, a separate discussion of Zion 2 deficiencies is not required. Table 4 applies to Zion 2 as well as Zion 1. O 0 9
a TABLE 1A.
SUMMARY
OF SCORES FOR ZION 2 Averaae Nich Low Text 7.2 8.8 5.0 Abstract 6.7 9.5 1.9 Coded Fields 8.2 8.8 7.6 Overall 7.lb 8.4 5.1
- a. See Appendix B for a sumary of scores for each LER that was evaluated.
- b. Overall Average = 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.
TABLE 38. LER REQUIREMENT PERCENTAGE SCORES FOR 710N 2 TEXT Percentage Requirements ISO.73(b)1 - Descriptions Scores ( l a (2)(11)(A) - - Plant condition prior to event 63 (12) (2)(11)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 69 (12) (2)(ii)(D) - - Root cause and intermediate cause(s) 78 (12) (2)(ii)(E) - - Mode, mechanism, and effect 96 (6) (2)(11)(F) - - EIIS Codes 0 (12) (2)(11)(G) - - Secondary function affected b (2)(li)(H) - - Estimate of unavailability 80 (5) (2)(11)(I) - - Method of discovery 92 (12) (2)(ii)(J)(1) - Operator actions affecting course 85 (9) (2)(11)(J)(2) - Personnel error (procedural deficiency) 79 (7) (2)(11)(K) - - Safety system responses 71 (4) (2)(11)(L) - - Manufacturer and model no. information 17 (6) (3) ----- Assessment of safety consequences 53 (12) (4) ----- Corrective actions 81 (12) (5) ----- Previous similar event infornation 54 (12) (2)(1) - - - - Text presentation 77 (12) A_BSTRACT Percentage Reautrements ISO.73(b)(1)1 - Descriptions Scores ( )*
- Major occurrences (Immediate cause and effect 83 (12) information) - Description of plant, system, component, and/or 90 (11) personnel responses - Root cause information 46 (12) l - Corrective Action information 52 (12) - Abstract presentation 67 (12) l l
l l l
l TABLE 3B, (continued) i i CODED FIELDS Percentage Item Number (s) - Description Scores ( )# 1, 2, and 3 - Facility name (unit no.), docket no. and 100 (12) page number (s) 4 - - - - - - Title 42 (12) 5, 6, and 7 - Event date, LER No., and report date 100 (12) 8 - - - - - - Other facilities involved 92 (12) 9 and 10 - - Operating mode and power level 100 (12) 11'- - - - - Reporting requirements 98 (12) 12 - - - - - Licensee contact information 83 (12) 13 - - - - - Coded component failure information 72 (12) 14 and 15 - - Supplemental report information 100 (12)
- a. Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(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 applicable.
- b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100%
if it is provided and is always considered "not applicable" when it is not.
REFERENCES
- 1. B. S. Anderson, C. F. Miller, 8. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), 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, licenseee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Commission, September 1985.
10
l APPENDIX A LER SAMPLE SELECTION INFORMATION FOR ZION 1 AND 2 11
TABLE A-2. LER SAi1PLE SELECTION FOR ZION 2 (304) LER Sample Number LER Number Comments 1 84-019-00 2 84-020-00 3 84-021-00 4 84-026-00 5 84-027-00 6 84-029-00
. 7 84-031-00 ESF 8 85-002-00 9 85-003-00 10 85-004-00 11 85-006-00 12 85-008-01 SCRAM
TABLE A-1. LER SAMPLE SELECTION FOR ZION 1 (295) LER Sample Number LER Number Comment s 1 84-015-00 2 84-018-00 3 84-021-00 Note that LER sample Number 3 and 4 have the same LER numbers; however 4 84-021-00 they are different events. 5 84-027-00 6 84-028-00 7 84-031-01 8 84-033-00 9 84-034-00 10 84-035-01 11 84-036-00 12 84-037-00 13 84-038-00 SCRAM 14 85-002-00 , 15 85-003-00 , 16 85-004-01 17 85-005-00 SCRAM 18 85-010-00 19 85-011-00 20 85-015-00 21 85-019-00 ESF 22 85-021-00 SCRAM BREAKER TRIP
APPENDIX B EVALUATION SCORES OF INDIVIOUAL LERs FOR ZION 1 AND 2 1 l I l 12
l l TABLE B-1. 9 EVALUATION SCORES OF INDIVIDUAL LERs FOR ZION 1 LER Sample Numbera 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 ! Text 5.3 7.4 4.2 5.3 5.3 6.2 3.7 6.5 5.9 6.8 8.3 8.3 3.6 6.4 7.2 7.0 Abstrac t 5.0 7. 0 6.6 8. 6 7. 0 8.1 6.6 8.8 4.5 9.1 7.9 7.4 6.5 6. 7 8.4 8. 9 Coded Fields 6.8 7.2 7. 9 7.6 8-9 7.2 8.0 7.6 7.7 8.3 6.2 7.3 8.3 8.0 8.1 7.8 Overall 5.4 7.3 5.3 6. 5 6.2 6.9 5.0 7.3 5. 7 7. 6 8.0 7. 9 4.9 6. 7 7. 7 7. 7 LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE I Text 4.5 5.1 7. 0 4.8 6. 5 6.6 -- -- -- -- -- -- -- -- 6.0 Abstract 6.2 6.5 8.6 8.5 9.0 9.0 -- -- -- -- -- -- -- -- 7.5 Coded Fields 8.3 7.3 8.1 S.0 8.8 9.2 -- -- -- -- -- -- -- -- 7.9 Overall 5.4 5. 7 7. 6 6.2 7. 5 7. 6 -- -- -- -- -- -- -- --
- f. . h a.
See Appendix A for a list of the corresponding LER numbers.
TABLE B-2. EVALUATION SCORES OF IN0!VIDUAL LERs FOR ZION 2 s LER Sample Number
- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Text 7.2 8.0 8.8 8.1 6.9 7.9 6.9 5.0 7.6 6.2 8.3 5.3 Abstract 8.3 9.3 5. 0 4.7 4.8 7. 5 7. 0 5. 7 9.2 1.9 7. 0 9. 5 Coded Fields 8.2 8.3 8.7 7.8 3.0 8.3 8.8 7.6 8.0 8.5 8.4 7.6 i
Overall 7.6 8.4 7. 7 7.1 6.4 7. 8 7.1 5.5 8.1 5.1 7. 9 6. 8 1 i LER Sample Number i
- 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE .
4 ! Test -- -- -- -- -- -- 4
-- -- -- -- -- -- -- -- 1.2 .
Austract -- -- -- .- -- --
-- -- -- -- -- -- -- -- 6.7 Coded
] Fields -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.2 Overall -- -- -- -- -- -- -- -- -- -- -- -- -- -- 7.1 Y
- a. See Appendix A for a list of the corresponding LER numbers.
,' m
-~
d 4 I i t
- n. , e r .- _ . . _ - -- _ -- - -_ __ _
I APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR ZION 1 AND 2 13
TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR ZION 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a Description of Deficiencies and Observations Totals Totals ( ) 50.73(b)(2)(11)(A)--Plant operating 8 (20) ' conditions before the event were not included or were inadequate. 50.73(b)(2)(11)(B)--01scussion of the status 0 (7) 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)(11)(C)--Fa11ure to include 13 (22) sufficient date and/or time infornation.
- a. Date information was insufficient. 11
- b. Time information was insufficient. 8 50.73(b)(2)(ii)(01--The root cause and/or 11 (22) intermediate failure, system failure, or personnel error was not included or was inadequate.
- a. Cause of component failure was not 7 included or was inadequate
- b. Cause of system failure was not 2 included or was inadequate
- c. Cause of personnel error was not 3 included or was inadequate.,
50.73(b)(2)(11)(E)--The failure mode, 2 (10) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
- a. Failure mode was not included or was 1 inadequate
- b. Mechanism (immediate cause) was not 1 included or was inadequate
- c. Effect (consequence) was not included 0 or was inadequate.
- _ - - - ~ _ _ _ _ - - - - ,~-..-----m - ----- ~ . . -,- - ,-,m. -
-y- - - - - - , - - - - --r r
TABLE C-1. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )D i 50.73(b)(2)(11)(F)--The Energy Industry 20 (20) Identification System component function identifier for each component or system was not included. 50.73(b)(2)(it)(G)--For a failure of a 0 (9) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate. 50.73(b)(2)(ii)(H)--For a failure that 1 (9) 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)(11)(I)--The method of discovery 6 (22) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
- a. Method of discovery for each 2 component failure was not included or was inadequate
- b. Method of discovery for each system 2 failure was not included or was inadequate
- c. Method of discovery for each 3 personnel error was not included or was inadequate
- d. Method of discovery for each 0 procedural error was not included or was inadequate.
TABLE C-1. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph b Description of Deficiencies and Observations Totals # Totals ( l 50.73(b)(2)(ti)(J)(ll--Operator actions that 3 (15) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate. 50.73(b)(2)(iil(J)(2)--The discussion of 9 (12) each personnel error was not included or was inadequate.
- a. OBSERVATION: A personnel error was 3 implied by the text, but was not explicitly stated,
- b. 50.73(b)(2)(ii)(J)(2)(1)--Discussion 2 as to whether the personnel error was cognitive or procedural was not included or was inadequate.
- c. 50.73(b)(2)(ii)(J)(2)(11)--Discussion 4 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. 50.73(b)(2)(11)(J)(2)(111)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
- e. 50.73(b)(2)(11)(J)(2)(iv)--01scussion 6 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.
TABLE C-1. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )D 50,73(b)(2)(11)(K)--Automatic and/or manual 2 (8) safety system responses were not included or were inadequate. 50.73(b)(2)(11)(L)--The manuf acturer and/or 8 (9) model number of each failed component was not included or was inadequate. 50.73(b)(3)--An assessment of the safety 20 (22) consequences and implications of the event was not included or was inadequate,
- a. OBSERVATION: The availability of 2 other systems or components capable of nitigating 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 scre 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)(41--A discussion of any corrective 10 (22) 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 j
TABLE C-1. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals ( )
- a. A discussion of actions required to O correct the problem (e.g., return the component or system to operation condition or correct the personnel error) was not included or was inadequate.
- b. A discussion of actions required to i 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 3 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 presious 16 (22) similar events was not included or wa2 inadequate.
l TABLE C-1. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph b Description of Deficiencies and Observations Totals' Totals ( l 50.73(b)(2)(11--Text presentation 12 (22) inadequacies.
- a. OBSERVATION: A diagram would have 0 aided in understanding the text l discussion.
- b. Text contained undefined acronyms 11 and/or plant specific designators, l
- c. The text contains other specific 4 ,
deficiencies relating to the readability.
- a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
- b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was applicable, l
-~. , --
TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR ZION 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals ( )U A summary of occurrences (immediate cause 10 (22) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 1 (19) responses was not included or was inadequate.
- a. Summary of plant responses was not 0 included or was inadequate.
- b. Summary of system responses was not 1 included or was inadequate.
- c. Summary of personnel responses was not 1 included or was inadequate.
A summary of the root cause of the event 14 (22) was not included or was inadequate. A summary of the corrective actions taken or 13 (22) planned as a result of the event was not included or was inadequate.
TABLE C-2. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( l b Abstract presentation inadequacies 16 (22)
- 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. The abstract was greater than 2 1400 characters
- c. The abstract contains undefined 8 acronyms and/or plant specific designators.
- d. The abstract contains other specific 7 deficiencies (i.e., poor summarization, contradictions, etc.)
- a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (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 deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was applicable.
TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR ZION 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( 1 D Facility Name 2 (22)
- a. Unit number was not included or 2 incorrect.
- b. Name was not included or was 0 incorrect.
- c. Additional unit numbers were included 0 but not required.
Docket Number was not included or was 0 (22) incorrect. Page Number was not included or was incorrect. 0 (22) Title was inadequate 22 (22)
- a. Root cause was not given in title 20
- b. Result (effect) was not given in title 9
- c. Link was not given in title 11 Event Date 0 (22)
- a. Date not included or was incorrect,
- b. Discovery date given instead of event date.
LER Number was not included or was incorrect 0 (22) Report Date 0 (22)
- a. Date not included
- b. OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).
Other Facilities inf.ormation in field is 4 (22) inconsistent with text and/or abstract. Operating Mode was not included or was inconsistent with text or abstract. 0 (22)
TABLE C-3. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( l b Power level was not includeo or was 0 (22) inconsistent with text or abstract Reporting Requirements 2 (22)
- 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 2 appropriate to report the event under a different paragraph.
- c. OBSERVATION: It would have been 0 appropriate to report this event under additional unchecked paragraphs.
Licensee Contact 14 (22)
- a. Field left blank 0
- b. Position title was not included 14
- c. Name was not included 0
- d. Phone number was not included. O Coded Component failure Information 8 (22)
- a. One or more component failure O sub-fields were left blank.
- b. Cause, system, and/or component code 1 is inconsistent with text.
- c. Component failure field contains data 7 when no component failure occurred.
- d. Component failure occurred but entire O field left blank.
TABLE C-3. (continued) Number of LERs with Deficiencies and Observations i Sub-paragraph Paragraph Description of Defic'iencies and Observations Totals a Totals ( l b Supplemental Report 1 (22)
- a. Neither"Yhs"/"No"blockofthe O supplemental report field was checked.
- b. The block checked was inconsistent I with the text.
Expected submission date information is 1 (22) inconsistent wif h the block checked in 1 Item (14).
- 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 du not necessarily add up to the paragraph total. e
- 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.
t 4 l
TABLE C-4. TEXT DEFICIENCIES AND OBSERVATIONS FOR ZION 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations a b Totals Totals ( l 50.73(b)(2)(11)(A)--Plant operating 7 (12) conditions before the event were not included or were inadequate. 50.73(b)(2)(ii)(B)--Discussion of the status 0 (5) 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 6 (12) sufficient date and/or time information.
- a. Date information was insufficient. 5
- b. Time information was insufficient. 6 50.73(b)(2)(11)(D)--The root cause and/or 5 (12) intermediate failure, system failure, or personnel error was not included or was inadequate.
- a. Cause of component failure was not 2 included or was inadequate
- b. Cause of system failure was not 0 included or was inadequate
- c. Cause of personnel error was not 3 included or was inadequate.
50.73(b)(2)(11)(E)--The failure mode, 1 (12) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
- a. Failure mode was not included or was 0 inadequate
- b. Mechanism (immediate cause) was not 0 included or was inadequate
- c. Effect (consequence) was not included 1 or was inadequate.
l l l l
TABLE C-4. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( l b 50.73(b)(2)(ii)(F)--The Energy Industry 12 (12) Identification System component function identifier for each component or system was not included. 50.73(b)(2)(ii)(G)--For a failure of a 0 (1) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate. 50.73(b)(2)(ii)(H)--For a failure that 1 (5) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the tailure until the train was returned to service was not included. 50.73(b)(2)(11)(I)--The method of discovery 1 (12) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
.a. Method of discovery for each 0 component failure was not included or was inadequate
- b. Method of discovery for each system 0 failure was not included or*was inadequate
- c. Method of discovery for each 1 personnel error was not included or was inadequate
- d. Method of discovery for each 0 procedural error was not included or was inadequate.
l l
TABLE C-4. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )U 50.73(b)(2)(ii)(J)(11--Operator actions that 3 (9) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate. 50.73(b)(2)(ii)(J)(2)--The discussion of 5 (7) each personral error was not included or was inadequate. I-
- a. OBSERVATION: A personnel error was 2 implied by the text, but was not explicitly stated.
- b. 50.73(b)(2)(11)(J)(2)(i)--Discussion 3 4
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
- c. 50.73(b)(2)(ti)(J)(2)(11)--Discussion 3 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. 50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
- e. 50.73(b)(2)(11)(J)(2)(iv)--01scussion 1 of the type of personnel involved (i.e., contractor _ personnel, utility itf.ensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.
N
TABLE C-4. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( l b 50.73(b)(2)(11)(K)--Automatic and/or nunual 2 (4) safety system responses were not included or were inadequate. 50.73(b)(2)(11)(L)--The manufacturer and/or 5 (6) model number of each failed component was not included or was inadequate. 50.73(b)(31--An assessnent of the safety 8 (12) consequences and implications of the event was not included or was inadequate.
- a. 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 existed,
- b. OBSERVATION: The consequences 1 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe ccnditions, the text should so state, 50.73(b)(4)--A discussion of any corrective 6 (12) 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.
TABLE C-4. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals" Igtals ( l b
- a. A discussion of actions required to O 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 O 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 1 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 6 (12) similar events was not included or was inadequate.
TABLE C-4. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a Description of Deficiencies and Observations Totals Totals ( )D 50.73(b)(2)(1)--Text presentation 3 (12) inadequacies,
- a. OBSERVATION: A diagram would have 0 aided in understanding the text discussion.
- b. Text contained undefined acronyms 2 and/or plant specific designators.
- c. The text contains other specific 1 deficiencies relating to the readability.
- a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
- b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was applicable.
l
TABLE C-5. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR DRESDEN 3 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals # Totals ( ) A summary of occurrences (immediate cause 5 (12) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 3 ('ll) responses was not included or was inadequate.
- a. Summary of plant responses was not 0 included or was inadequate.
- b. Summary of system responses was not 0 included or was inadequate.
- c. Summary of personnel responses was not 3 included or was inadequate.
A summary of the root cause of the event 8 (12) was not included or was inadequate. A summary of the corrective actions taken or 7 (12) planned as a result of the event was not included or was inadequate. l l
TABLE C-5. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals ( l b
Abstract presentation inadequacies 6 (12)
- a. OBSERVATION: The abstract contains 2 information not included in the text.
The abstract is intended to be a sumnery of the text, therefore, the text should discuss all information summarized in the abstract,
- b. The abstract was greater than 1 1400 characters
- c. The abstract contains undefined I acronyms and/or plant specific designators.
- d. The abstract contains other specific 4 deficiencies (i.e., poor summarization, contradictions, etc.)
- a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-parag.aph totals do not necessarily add up to the paragraph total.
- b. The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was applicable.
l 1 1 _ ~ _ - _ _ - . - - _ _ _ . , -
TABLE C-6. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR ZION 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a gescription of Deficiencies and Observations Totals Totals ( )D Facility Name 0 (12)
- 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 (12) incorrect. Page Nut.ber was not included or was 0 (12) incorrect. Title uas inadequate 12 (12)
- a. Root cause was not given in title 12
- b. Result (effect) was not given in title 2
- c. Link was not given in title 6 Event Date 0 (12)
- a. Date not included or was incorrect.
- b. Discovery date given instead of event date.
LER Number was not included or was incorrect 0 (12) Report Date 0 (12)
- 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 0 (12) inconsistent with text and/or abstract. Operating Mode was not included or was 0 (12) inconsistent with text or abstract.
TAL'tE C-6. (continued) NJmber of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' 19tals ( ) Power level was not included or was 0 (12) inconsistent with text or abstract Reporting Requirements 2 (12)
- 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 2 appropriate to report the event under a different paragraph.
- c. OBSERVATION: It would have been 0 appropriate to report this event under additional unchecked paragraphs.
Licensee Contact 6 (12)
- a. Field left blank 0
- b. Position title was not included 6
- c. Name was not included 0
- d. Phone number was not included. O Coded Component Failure Information 3 (12)
- a. One or more component failure 0 sub-fields were left blank.
- b. Cause, system, ar.d/or component code 0 is inconsistent with text.
- c. Component failure field contains data 3 when no component failure occurred.
- d. Component failure occurred but entire O field left blank.
l TABLE C-6. (continued) Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals ( l b
Supplemental Report 0 (12)
- a. Neither "Yes"/"No" block of the supplemental report field was checked.
- b. The block checked was inconsistent with the text.
Expected submission date infornetton is 0 (12) inconsistent with the block checked in Item (14).
- a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
- b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was applicable.
l APPENDIX D LER COMMENT SHEETS FOR ZION 1 AND 2 14 @*;n
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 1. LER Number: 84-015-00 Scores: Text = 5.3 Abstract = 5.0 Coded Fields = 6.8 Overall = 5.4 Text 1. 50.73(b)(2)(ii)(C)--Date information for occurrences was 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 was not included.
- 3. 50.73(b)(2)(11)(I)--Discussion of the method of discovery of the personnel error was not included.
- 4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
- 5. 50.73(b)(5)--Information concerning previous similar events was not included.
- 6. Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73--The abstract should give more specifics about the root cause.
- 2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was not included.
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 til information summarized in the abstract. Coded Fielc. 1. Item (4)--Title: Root cause and effect were not included.
- 2. Item (8)--The field should be filled in with Not Applicable or NA.
- 3. Item (12)--Position title was not included.
- 4. Item (13)--Comporent failure field cortains data when no component failure occurred.
TABLE D-1. SPECIFIC LER CDMMENTS FOR ZION 1 (295) Section Comments
- 2. LER Number: 84-018-00 Scores: Text = 7.4 Abstract = 7.0 Coded Fields = 7.2 Overall = 7.3 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event was inadequate.
- 2. 50.73(b)(2)(ii)(C)--Date and approximate time information for occurrences was inadequate.
- 3. Even though root cause was not determined, discuss those actions taken to try to determine it.
- 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 was not included.
- 5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what were considered the most severe conditions, the text should so state.
- 6. Some conclusions reached are inconsistent with the facts presented. Why does the release quantification need to be corrected? What was 10PR038 supposed to be monitoring?
Abstract 1. The abstract should have stated that the root cause could not be determined. Coded Fields 1. Item (4)--Title: Result was not included. The title implies that there is a definite connection between the blower being off while the release was in progress; the text contradicts this implication.
- 2. Item (12)--Position title was not included.
- 3. Item (8)--Information in field is inconsistent with text and/or abstract. Applying corrective actions to another unit does not require naming the other unit as a " facility involved".
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 2. LER Number: 84-018-00(continued)
- 4. Item (7)--0BSERVATION: Report date was not within thirty days of event date (or dis overy date if appropriate).
t f f I I i i f n i i 1
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 3. LER Number: 84-021-00 Scores: Text = 4.2 Abstract = 6.6 Coded Fields = 7.9 Overal Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operati conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(C)--Time information for occurr.
was not included.
- 3. 50.7.T(b)(2)( t i)(D)--The root and/or intermediat.
cause discussion for each personnel error was n-included.
- 4. 50.73(b)(1)--Summary of corrective actions take:
planned as a result of the event was not includ.
- 5. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel e was implied but was not explicitly stated in the
- 6. 50.73(b)(2)(11)(J)(2)--Discussion of personnel a was not included.
- 7. 50.73(b)(2)(11)(J)(2)(iv)--Discussion of the ty; personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not incit
- 8. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the ever not included.
- 9. 50.73(b)(4)--Disci::, ion of corrective actions ti-or planned ws; inadequate.
- 10. 50.73(t,J(5)--Info mation concerning previous sit events was not incicded.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) was not included.
- 2. 50.73(b)(1)--Summary of corrective actions taker planned as a result of the event was inadequate.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 3. LER Number: 84-021-00 (continued)
- 3. The abstract contained greater than 1400 characters.
Abstract describes the text as opposed to summarizing it. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included. ,
- 3. Item (12)--Position title was not included.
Observation 1. Same LER number as another LER with different event, title, dates. 4 l l
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 4. LER Number: 84-021-00 Scores: Text = 5.3 Abstract = 8.6 Coded Fields = 7.6 Overall = 6.5 Text 1. 50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event was not included.
- 2. 50.73(b)(2)(11)(C)--Date and approximate times information for occurrences was not included.
- 3. 50.73(b)(2)(ii)(0)--The corrective actions (use of manual isolation valves) imply a possible procedural deficiency which was not discussed.
. 6. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate. 8e more specific about the amount of release. The volume of gas released does not show a reader how much radioactive release occurred in comparison to allowable limits.
- 8. 50.73(b)(5)--Information concerning previous similar events was not included.
- 9. Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. The abstract summary of root cause is deficient for the same reason as the text.
- 2. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1. Item (4)--The use of acronyms as a title is not encouraged. The root cause was not included.
- 2. Item (7)--A grace period to the next working day is allowed when the due date falls on a weekend and/or a holiday. It would be a good idea to point this out in the text.
- 3. Item (8)--The field should be filled in with Not Applicable or NA.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Coments
- 4. LER Number: 84-021-00(continued)
- 4. Item (12)--Position title was not included.
t
- 5. Item (14)--The corrective actions imply the a supplemental report to update the final a taken.
, - . . - - - __- - ~ #---4 - - - - . _ _ , -_.__y,, __---,..--,,.__,-.v._...w---ve , --- - , - - , - -
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 5. LER Number: 84-027-00 Scores: Text = 5.3 Abstract = 7.0 Coded Fields = 8.9 Overall = 6.2 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 was not included.
- 2. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 3. Abstract contains acronym (s) and/or plant specific
, designator (s) which are undefined.
- 4. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate.
- 5. 50.73(b)(5)--Information concerning previous similar events was inadequate.
- 6. A logical transition does not exist between all ideas. Some ideas were not presented clearly (hard to follow). Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s)andeffects(s)]wasinadequate.
- 2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate.
- 3. Abstract does not adequately summarize the text.
Additional space was available within the abstract field to provide the necessary information but it was not utilized. Coded Fields 1. Item (4)--Title: Root cause was not included.
! TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 6. LER Number: 84-028-03 Scores: Text = 6.2 Abstract = 8.1 Coded Fields = 7.2 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant t conditions before the event was inadequat
- 2. 50.73(b)(2)(ii)(C)--Date information for was inadequate. Was the discovery date !.
i
- 3. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each system referred to in the LER was not inc .
- 4. 50.73(b)(2)(ii)(J)(2)--Discussion of pert was inadequate.
- 5. 50.73(b)(2)(11)(J)(2)(ii)--Discussion as the personnel error was contrary to an at :
procedure, was a direct result of an errc approved procedure, or was associated witi activity or task that was not covered by ' procedure was not included.
- 6. 50.73(b)(?)(ii)(J)(2)(iv)--Discussion of '
personnel involved (i.e., contractor part - utility licensed operator, utility nonlit operator, other utility personnel) was nt:
- 7. 50.73(b)(3)--Discussion of the assessa.ent>
' safety consequences and implications of 1:
not included.
- 8. OBSERVATION: Additional corrective actic' the generic implications of the failure (
should have been considered. Could otheti have the same problem with their procedui control procedures? ,
- 9. 50.73(b)(5)--Informationconcerningprev' events was not included.
- 10. 50.73(b][5)--If no previous similar event i the text should so state.
I 1
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 6. LER Number: 84-028-00(continued)
Abstract 1. OBSERVATION: The abstract contains information not included in the text. The abstract is intended to b'e 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 result was not included.
- 2. Discovery date appears to be in the " EVENT DATE" area.
- 3. Item (8)--Information in field is inconsistent with text and/or abstract. Applying corrective actions to
. another unit does not mean the other unit needs to be named in Item 8. '
- 4. Item (121--Positiontitlewasnotincluded.
- 5. Item (13)--Component failure field contains data when no component failure occurred.
1 l
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 7. LER Number: 84-031-01 Scores: Text = 3.7 Abstract = 6.6 Coded Fields = 8.0 Overall = 5.0 Text 1. 50.73(b)(2)(11)( A)--Discussion of plant operating conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(C)--Date information for occurrences was not included.
- 3. 50.73(b)(2)(ii)(C)--Time information for occurrences was not included.
- 4. 50.73(b)(2)(ti)(0)--The root and/or intermediate
, cause discussion for each personnel error was inadequate.
- 5. 50.73(b?(2)(11)(J)(2)--0BSERVATION: Personnel error was imp'1ed but was not explicitly stated in the text.
- 6. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was not included.
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
i 1 1 i i i I
l TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) i Section Comments l 7. LER Number: 84-031-01 (continued)
- 8. Item (8)--Information in field is inconsistent with text and/or abstract.
- 9. Some ideas were not presented clearly (hard to follow). Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73(b)(1)--Summaryofoccurrences[immediate cause(s)andeffects(s)]wasinadequate.
- 2. 50.73(b)(1)--Summary of root cause was not included.
. 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of t + event was inadequate.
OBSERVATION: The abst ract 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 was not included.
- 2. Item (4)--Title: Link was not included.
- 3. Item (12)--Position title was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 8. LER Number: 84-033-01 Scores: Text = 6.5 Abstract = 8.8 Coded Fields = 7.6 Overall = 7.3 Text 1. 50.73(b)(2)(ii)(C)--Date information for occurrences was inadequate.
- 2. 50.73(b)(2)(ii)(0)--The text should discuss why the change did not get put into the procedure. Knowing the root cause is necessary so that the analyst can determine whether or not the corrective actions in the LER are adequate.
- 3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
Abstract 1. 50.73(b)(1)--The corrective actions summary is incomplete. With the space available the abstract could summarize the other actions listed in the text. Coded Fields 1. Item (4)--Title: Root cause was not included. l 2. Item (8)--Information in field is inconsistent with ! text and/or abstract. The field should indicate that Unit 2 was involved.
- 3. Item (12)--Position title was not included.
- 4. Item (13)--Component failure field contains data when no component failure occurred.
- 5. Submission date was not given. The text should also indicate what new information is to be supplied, l
l i l l
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 9. LER Number: 84-034-00 Scores: Text = 5.9 Abstract = 4.5 Coded Fields = 7.7 Overall = 5.7 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error was not 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 was not included.
- 3. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error was not included.
- 4. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was inadequate.
- 5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
Abstract 1. 50.73(b)(1)--Summaryofoccurrences[immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of root cause was not included.
- 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate.
- 4. Abstract does not adequately summarize the text.
Additional space was available within the abstract field to provide the necessary information but it was not utilized. Coded Fields 1. Item (4)--Title: Root causes and result were not included.
- 2. Item (12)--Position title was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 10. LER Number: 84-035-01 Scures: Text = 6.8 Abstract = 9.1 Coded Fields = 8.3 Overall = 7.6
! Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event was inadequate.
- 2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER was not included.
- 3. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was inadequate.
- 4. 50.73(b)(2)(11)(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.
- 5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should have been considered and discussed if applicable. Could other procedures involving safety related snubbers also be deficient?
- 6. 50.73(b)(5)--Information concerning previous similar events was 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 (CSD).
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate. A time history (dates) would help.
- 2. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined (CSD).
s TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments-
- 10. LER Number: 84-035-01(continued)
Coded Fields 1. Item (4)--Title: Root cause and result (technical specification violation) were not included.
- 2. Item (13)--Component failure field contains data when no component failure occurred.
s 4 A i I > l
! -{
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 11. LER Number: 84-036-00 Scores: Text = 8.3 Abstract = 7.9 Coded Fields = 6.2 Overall = 8.0 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure was 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 was not included.
- 3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
4 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) was not included or was inadequate. OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should have been considered. Acronym (s) and/or plant specific designator (s) are undefined. Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of root causes was inadequate.
- 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate.
- 4. The abstract contained greater than 1400 characters.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. Abstract does not adequately summarize the text. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included.
- 3. Item (12)--Position title was not included.
- 4. Item (1)--Unit measures were not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 12. LER Number: 84-037-00 Scores: Text = 8.3 Abstract = 7.4 Coded Fields = 7.3 Overall = 7.9 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 was not included.
- 2. 50.73(b)(3)--The safety assessment adequately discusses the safety limits, but an estimate of the peaking factor that occurred would have helped to put the safety consequences of the event in perspective.
The safety assessment should also indicate other systems, if any, which were available to mitigate the consequences of an excessive power transient.
- 3. Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73(b)(1)--The root cause summary should indicate that the operator was distracted by other problems.
- 2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was not included.
- 3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1. Item (4)--The title gives a reader very little information about the event.
- 2. Item (81--The field should be filled in with Not Applicable or NA.
- 3. Item (12)--Position title was not included.
- 4. Item (13)--Component failure field contains data when no component failure occurred.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 13. LER Number: 84-038-00 Scores: Text = 3.6 Abstract = 6.5 Coded Fields = 8.3 Overall = 4.9 Text 2. 50.73(b)(2)(11)(C)--Dates and approximate time information for occurrences was inadequate. When was the new Hagan M/A Station installed?
- 2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system component failure was not included (i.e., Hagan M/A Station).
- 3. 50.73(b)(2)(ii)(E)--The failure mode discussion of each failed component was not included (i.e., for old Hagan).
- 4. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER was not included.
- 5. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the system component failure was 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 was not included.
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
- 8. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate.
- 9. 50.73(b)(5)--Information concerning previous similar events was not included.
- 10. 50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of root cause was not included.
- 2. 50.73(b)'(1)--Summary of corrective actions taken or planned as a result of the event was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 13. LER Number: 84-038-00(continued)
Coded Fields 1. Item (4)--Title: Root cause and link were not included.
- 2. Item (12)--Position title was not included.
1
- - -- , ,-,,-n,.- , - - , - , - , - - - - - . . , - , ,
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 14. LER Number: 85-002-00 Scores: Text = 6.4 Abstract = 6.7 Coded Fields = 8.0 Overall = 6.7 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure was inadequate. Is this a manufacturing design problem or were these steel tubings installed after D/G installation?
- 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 was not included.
- 3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included. Was it also a Technical Specification violation to have 2 diesels inoperable during Mode 37
- 4. Wasn't it a personnel error that resulted in 2 diesels being inoperable?
- 5. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate. What was done to ensure that 2 diesels would not be inoperable again during Mode 3?
- 6. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 7. How many other diesel fuel lines had to be repaired?
Was this a generic problem?
- 8. 50.73(b)(5)--Information concerning previous similar i events was not included. '
- 9. 50.73(b)(5)--If no previous similar events are known, the text should so state.
l
- 10. Acronym (s) and/or plant specific designator (s) are l undefined. Overall, presentation leaves the reader '
with many unanswered questions.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) l l Section Comments
- 14. LER Number: 85-002-00(continued)
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of corrective actions taken or
~
planned as a result of the event was 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.
- 3. Abstract contradicts the text. Abstract does not adequately summarize the text. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1. Item (4)--Title: Root cause and result were not 4 included.
- 2. Item (12)--Position title was not included.
- 3. Item (13)--Cause, system, and/or component code was inconsistent with text.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 15. LER Number: 85-003-00 Scores: Text = 7.2 Abstract = 8.4 Coded Fields = 8.1 Overall = 7.7 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 was not included.
- 2. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was
. not included.
- 4. 50.73(b)(5)--Information concerning previous similar events was not included.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of root cause was inadequate.
- 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate.
4. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included.
- 3. Item (12)--Position title was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 16. LER Number: 85-004-01 Scores: Text = 7.0 Abstract = 8.9 Coded Fields = 7.8 Overall = 7 7 Text 1. 50.73(b)(2)(ii)(D)--The root cause would appear to be one step further back, and be the reason why the circuit time was too short.
- 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 tc in the LER was not included.
- 3. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 5. 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 were available, the text should so state.
- 6. 50.73(b)(4)--As text Comment 1 indicates, the root cause appears to be one step back. Knowing the root cause is important for assuring proper long term corrective action (e.g., increased maintenance schedule or possibly protecting the circuit from a harsh environmental condition).
- 7. 50.73(b)(5)--Information concerning previous similar events was not included.
Abstract 1. No comments. Coded Fields 1. Item (4)--A reader gets very little idea about the event from the title, especially since most readers have no idea what the acronym INOV-518812 A & B refers to.
- 2. Item (8)--The field should be filled in with Not Applicable or NA.
- 3. Item (12)--Position title was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 17. LER Number: 85-005-00 l
Scores: Text = 4.5 Abstract = 6.2 Coded Fields = 8.3 Overall = 5.4 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system failure was not included.
- 2. 50.73(b)(2)(ii)(E)--The mechanism discussion of each failed component was not included (i.e., mechanism of the tripped CPU).
- 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 was not included.
- 4. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate (i.e., parsonnel response after the scram).
- 5. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses was inadequate.
- 6. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
- 8. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate (i.e., counseling personnel, CPU repair).
- 9. 50.73(b)(5)--Information concerning previous similar events was not included.
- 10. 50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of personnel / system responses was inadequate.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) i Section Comments
- 17. LER Number: 85-005-00(continued)
- 3. 50.73(b)(1)--Summary of root cause was inadequate.
- 4. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate.
Coded Fields 1. Item (4)--Title: Root cause and link were not included.
- 2. Item (12)--Position title was not included.
9 1 i l
TABLE D-1. 'PECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 18. LER Number: 85-010-00 Scores: Text = 5.1 Abstract = 6.5 Coded Fields = 7.3 Overall = 5.7 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant cperating conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(C)--Date and time information for occurrences was 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 was not included.
- 4. 60.73(b)(2)(ii)(I)--Discussion of tha method of discovery of the defeated switch was not included.
- 5. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was inadequate.
- 6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed. If no other systems or components were available, the text should so state.
- 7. 50.73(b)(5)--Information concerning previous similar events was not included.
- 8. 50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) was inadequate.
- 2. 50.73(b)(1)--Summary of root cause was inadequate.
- 3. Abstract does not adequately summarize the text.
Additional space was available, within the abstract field to provide the necessary information but it was , not utilized. i l Coded Fields 1. Item (4)--Title: Root cause and result were not ! included. 'l l I
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 18. LER Number: 85-010-00(continued)
- 2. Item (8)--Information in field is inconsistent with text and/or abstract. Text does not indicate Unit 2
, Involvement.
- 3. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
- 4. Item (12)--Position title was not included.
- 5. Item (13)--Component failure field contains data when no component failure occurred.
i G J r- - - -- -- - - --
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 19. LER Number: 85-011-00 Scores: Text = 7.0 Abstract = 8.6 Coded Fields = 8.1 Overall = 7.6 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(B)--Discussion of the status of structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included.
- 3. 50.73(b)(2)(ii)(C)--Date and time information for occurrences was not included.
- 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 was not included.
- 5. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error was implied but was not explicitly stated in the text.
- 6. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was not included.
- 7. 50.73(b)(2)(ii)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural was not included.
- 8. 50.73(b)(2)(ii)(J)(2)(11)--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.
- 9. 50.73(b)(5)--Information concerning previous similar events was not included.
- 10. Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73(b)(1)--Summary of root cause was inadequate.
- 2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate.
1
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 19. LER Number: 85-011-00 (continued)
- 3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included.
- 3. Item (12)--Position title was not included.
o E l + t I
. -- ---,,,,,.,_-_,,.,-,,_,--.,,,c.---.r.-,,.,,,,~w-,----. - - . . . _ _ . -
--.-r- , - - _ , --- - - --, m- y
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 20. LER Number: 85-015-00 Scores: Text = 4.8 Abstract = 8.5 Coded Fields = 8.0 Overall = 6.2 Text 1. 50.73(b)(2)(ii)(C)--Date and approximate time information for occurrences was not included.
- 2. 50.73(b)(2)(ti)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER was 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 was not included.
- 4. 50.73(b)(2)(ii)(J)(2)--Two personnel errors appear to have occurred. One is the improper setting of the nozzle rings and the second was during the hydrostatic test. Each error should be discussed.
- 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 an activity or task that was not covered by an approved procedure was not included.
- 6. 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.
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included. !
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what were considered the most severe conditions, the text should so state. l
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 20. LER Number: 85-015-00(continued)
- 8. 50.73(b)(4)--The corrective actions such as updating the hydrostatic test procedure were not included.
- 9. A logical transition does not exist betwebn all ideas. Some ideas were not presented clearly (hard to follow). Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. The abstract presents the facts more clearly than the text. The root cause however, should be explicitly stated as personnel error.
- 2. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1. Item (4)--Title: Root cause and link were not included.
- 2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(vii).
yy ., _,c..--
- - - - , -.. ,. -,,. - , _ .y ,,,..
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 21. LER Number: 85-019-00 Scores: Text = 6.5 Abstract = 9.0 Coded Fields = 8.8 Overall = 7.5 Text 1. 50.73(b)(2)(ii)(C)--Dates and approximate time information for occurrences was not included. When were corrective actions performed?
- 2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure was inadequate.
- 3. 50.73(b)(2)(ii)(F)--The Energy Industry Identitication System component function identifier (s) and/or system name of each component or system referred to in the LER was not included.
- 4. 50.73(b)(2)(ti)(I)--Discussion of the method of discovery of the component failure was not included (i.e., how did the search for a noise problem come about?).
- 5. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
- 7. 50.73(b)(5)--Information concerning previous similar events was not included.
- 8. 50.73(b)(5)--If no previous similar events are known, the text should so state.
Austract 1. 50.73(b)(1)--Summary of root cause was inadequate. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (12)--Position title was not included.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295) Section Comments
- 22. LER Number: 85-021-00 Scores: Text = 6.6 Abstract = 9.0 Coded Fields = 9.2 Overall = 7.6 Text 1. 50.73(b)(2)(ii)(C)--Date and time information for occurrences was not 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 was not included.
- 3. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error was inadequate. '
- 4. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was inadequate.
- 5. 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.
- 6. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses was inadequate. Was the component cooling pump the only component expected to start?
- 7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what were considered the most severe conditions, the text should so state.
- 8. 50.73(b)(5)--Information concerning previous similar events was inadequate.
- 9. 50.73(b)(5)--If no previous similar events are known, the text should so state.
- 10. Acronym (s) and/or plant specific designator (s) are undefined.
TABLE D-1. SPECIFIC LER COMMENTS FOR ZION I (295) Section Comments _
- 22. LER Number: 85-021-00(continued)
Abstract 1. 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. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. Coded Fields 1. Item (1)--Unit number was not included.
- 2. Item (4)--Title: Link between implied cause and result was not included.
- 3. Item (12)--Position title was not included.
- 4. Item (13)--Component failure field contains data when no component failure occurred.
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 1. LER Number: 85-019-00 Scores: Text = 7.2 Abstract = 8.3 Coded Fields = 8.2 Overall = 7.6 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 was not included.
- 2. 50.73(b)(2)(ii)(G)--The list of systems or secondary functions that were also affected by the failed multi-function component was 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 was not included.
- 4. 50.73(b)(2)(ii)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural was not included.
- 5. 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.
E. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included. Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of root cause was inadequate.
- 3. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions -
that affected the course of the event was inadequate. I e
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments ,
- 1. LER Number: 85-019-00 (continued)
Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included.
4 P I e f S a
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 2. LER Number: 85-020-00 Scores: Text = 8.0 Abstract = 9.3 Coded Fields = 8.3 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(A)--The text should include the power level.
- 2. 50.73(b)(2)(11)(C)--Date and approximate time infonnation for occurrences was 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 was not included.
. 4. 50.73(b)(4)--The volume weight temperature, to be meaningful, would have been made with approximately the same temperature distribution in the containment and observed on August 14, 1984. This was not addressed in the text.
Abstract 1. No comments. , Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (121--Positiontitlewasnotincluded.
- 3. Item (13)--Component failure field contains data when no component failure occurred.
TABLE 0-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 3. LER Number: 84-021-01 Scores: Text = 8.8 Abstract = 5.0 Coded Fields = 8.7 Overall = 7.7 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 was not included.
- 2. 50.73(b)(2)(11)(I)--Discussion of the method of discovery of the personnel error was not included.
- 3. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate. What actions were taken after the discovery of the error in regards to restoring a sample range channel to operation?
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of personnel responses was inadequate. -
- 3. 50.73(b)(1)--Summary of root cause was inadequate.
- 4. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event was inadequate. Not all included.
Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
- 3. Item (12)--Position title was not included.
- 4. Item (13)--Component failure field contains data when no component failure occurred.
i
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 4. LER Number: 84-026-00(continued)
- 4. Abstract does not adequately summarize the text.
Adc:itional space was available, within the abstract field to provide the necessary information but it was not utilized. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. Coded Fields 1. Item (4)--Title: Root cause and result were not included.
- 2. Item (12)--Position title was not included.
O
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 5. LER Number: 84-027-00 Scores: Text = 6.9 Abstract = 4.8 Coded Fields = 8.0 Overall = 6.4 Text 1. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error was 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 was not included.
- 3. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate.
- 4. 50.73(b)(2)(11)(J)(2)--0BSERVATION: Personnel error was implied but was not explicitly stated in the text.
- 5. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error was inadequate.
- 6. 50.73(b)(2)(ii)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural was not included.
- 7. 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 j procedure was inadequate.
- 8. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
- 9. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate.
- 10. 50.73(b)(5)--Information concerning previous similar events was not included.
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 5. LER Number: 84-027-00 (continued)
Abstract 1. 50.73(b)(1)--Summary of personnel responses was inadequate. l
- 2. 50.73(b)(1)--Summary of root cause was not included.
- 3. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was not included.
l 4. Abstract does not adequately summarize the text. Additional space was available within the abstract l field to provide the necessary information but it was l not utilized. , 1 Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included. l
- 3. Item (12)--Position title was not included. l
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 6. LER Number: 84-029-00 Scores: Text = 7.9 Abstract = 7.5 Coded Fields = 8.3 Overall = 7.8 Text 1. 50.73(b)(2)(ii)(A)--Include power level in the text. ,
I
- 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 was not included.
- 3. 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. Did the procedure for l break inspection include a warning about the l interlock between the two systems? If not, corrective actions should be taken to update the procedure until the interlock is removed.
- 4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
i OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed. If no other systems or components were available, the text should so state.
- 5. 50.73(b)(4)--See text Comment 3.
- 6. 50.73(b)(5)--Information concerning previous similar events was not included.
Abstract 1. 50.73(b)(11--The summary of corrective actions should be specific about actions taken and planned. Coded Fields 1. Item (4)--Title: Root causes and link were not included.
- 2. Item (8)--Field should be filled in with Not Applicable or NA.
, p TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304)
Section Comments
- 6. LER Number: 84-029-00(continued) t 3. Item,(12)--Position title was not included.
- 4. -Item (73)--Component failure field contains data when no component failure occurred.
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9 4
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 7. LER Number: 84-031-00 Scores: Text = 6.9 Abstract = 7.0 Coded Fields = 8.8 Overall = 7.1 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(C)--Date and approximate time information for occurrences was inadequate.
- 3. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error was inadequate. Why was pushbutton not fully depressed?
- 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 was not included.
- 5. 50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error was implied but was not explicitly stated in the text.
- 6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was not included.
Abstract 1. 50.73(b)(1)--Summary of root cause was not included.
- 2. 50.73(b)(1)--Summary of personnel responses was not included.
Coded Fields 1. Item (4)--Title: Root cause was not included. 1
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 8. LER Number: 85-002-00 Scores: Text = 5.0 Abstract = 5.7 Coded Fields = 7.6 Overall = 5.5 Text 1. 50.73(b)(2\(ii)(C)--Approximate time information for occurrences was inadequate.
- 2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component (tubing) failure was not included.
- 3. 50.73(b)(2)(ii)(E)--The effect (consequence) discussion of each failed component was not included.
- 4. 50.73(b)(2)(11)(F)--The Er.ergy Industry
. Identification System component function identifier (s) and/or system name of each component or system referred to in the LER was 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 was not included.
- 6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
- 7. 50.73(b)(4)--Discussion of corrective actions taken or planned was inadequate. What was done to ensure that the LC0 would be entered if this type of event ever happened again? Was the fractured tubing replaced with copper or steel?
- 8. 50.73(b)(5)--Information concerning previous similar events was inadequate. Other LERs should be referenced (e.g., 85-002-00 for Zion 1). Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate.
- 2. 50.73(b)(1)--Summary of root cause was not included.
- 3. 50.73(b)(2)(11)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate (LCO entry).
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 8. LER Number: 85-002-00 (continued)
Coded Fields 1. Item (4)--Title: Root cause and result were not included.
- 2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(v).
- 3. Item 112}--Position title was not included.
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 9. LER Number: 85-003-00 Scores: Text = 7.6 Abstract = 9.2 Coded Fields = 8.0 Overall = 8.1 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)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was
. not included.
- 4. 50.73(b)(5)--Information concerning previous similar events was not included.
Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] was inadequate. The abstract contained greater than 1400 characters. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (4)--Title: Link was not included.
- 3. Item (12)--Position title was not included.
1
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 10. LER Number: 85-004-00 Scores: Text = 6.2 Abstract = 1.9 Coded Fields = 8.5 Overall = 5.1 Text 1. 50.73(b)(2)(ii)( A)--Discussion of plant operating conditions before the event was not included.
- 2. 50.73(b)(2)(ii)(D)--The root cause for the rusting of stem was 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 was not included.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer 4. and model no.) of the failed component (s) discussed in the text was not included.
- 5. 50.73(b)(4)--Without proper long term corrective actions the valve stem could rust and stick again.
Abstract 1. The abstract is not a summary of the text. In fact, it is almost all new data not found in the text and the root cause and corrective actions are not even mentioned. Coded Fields 1. Item (4)--Title: Root cause was not included.
- 2. Item (8)--Information in field is inconsistent with text and/or abstract.
. ~ . . - . - -_.
l l TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) i Section Comments
- 11. LER Number: 85-006-00 Scores: Text = 8.3 Abstract = 7.0 Coded Fields = 8.4 Overall = 7.9 Text 1. 50.73(b)(2)(ii)(A)--Discussioa of plant cperating conditions before the event was inadequate.
- 2. 50.73(b)(2)(ii)(C)--Dates and approximate time information for occurrences was inadequate, i.e.,
corrective actions and system returned to service.
- 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 was not included.
- 4. 50.73(b)(2)(11)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
Abstract 1. 50.73(b)(1)--Summary of personnel responses was inadequate.
- 2. 50.73(b)(1)--Summary of root causes was not included.
Coded Fields 1. Item (4)--Title: Root cause and link were not included.
, -- ., , .--+, - -
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 (304) Section Comments
- 12. LER Number: 85-008-01 Scores: Text = 5.3 Abstract = 9.5 Coded Fields = 7.6 Overall = 6.8 Text 1. 50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event was inadequate.
- 2. 50.73(b)(2)(ii)(C)--Date and time information for occurrences was not included.
- 3. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion for each personnel error was inadequate. The text should state that the personnel misinterpreted the drawing (as the abstract does).
- 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 was not included.
- 5. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event was inadequate.
- 6. 50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural was inadequate.
- 7. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses was inadequate. At a minimum, any ESF equipment that actuated should be listed.
- 8. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion for the ground on relay 46G2 was not included.
- 9. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text was not included.
- 10. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event was inadequate.
- 11. Should procedure ZED-3 have been revised to include better information concerning switch locations as well?
TABLE D-2. SPECIFIC LER COMMENTS FOR ZION 2 ,(304) Section Comments
- 12. LER Number: 85-008-01(continued)
- 12. 50.73(b)(5)--Information concerning previous similar events was not included.
- 13. 50.73(b)(5)--If no previous similar events are known, the text should so state.
- 14. A logical transition does not exist between all ideas. Some ideas were not presented clearly (hard to follow).
Abstract 1. OBSERVATION: The abstract contains informatien not included in the text. (For example, " steady state
. power", "HV-4 relay", " mis-interpreted", and " plant responded to the event with no equipment problems".)
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 were not included. An example of a better title is:
" Personnel Error during Ground Detection Procedure caused Reactor Trip from Power".
- 2. Item (12)--Position title was not included.
- 3. Item (13)--It is not clear which relay this field is describing. The relay that was switched off did not fail. The relay with the ground did not fail due to a personnel error, based on the information provided.
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