ML20155A195
| ML20155A195 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/03/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| NUDOCS 8604080318 | |
| Download: ML20155A195 (120) | |
Text
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.,q ff ? tf7 APR - 3 1906 Docket No. 50 315 Docket No. 50-316 American Electric Power Service Corporation Indiana and Michigan Electric Company ATTN:
Mr. John E. Dolan Vice Chairman Engineering and Construction 1 Riverside Plaza Columbus, OH 43216 Gentlemen:
The NRC's Office for Analysis and Evaluation of Operational Data (AE00) has completed an assessment of D. C. Cook Nuclear Plant, Unit Nos. I and 2, Licensee Event Reports (LERs) (Unit 1 - 24 LERs; Unit 2 - 18 LERs) as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Report. The report was mailed to you on January 13, 1986.
Enclosed (Attachment C) is the assessment of the LERs from D. C. Cook Units 1 and 2.
In general, AEOD found these LERs to be of marganally acceptable quality based on the requirements contained in 10 CFR 50.73. The enclosed report provides the basis for this finding.
In addition, AEOD completed a study (AEOD/P504) of unplanned reactor trips that occurred in 1984. A summary table of reactor trip frequencies from the study is provided in Attachment A.
Finally, AE00 also completed a study (AE0D/P503) of ESF actuations that occurred during the first half of 1984. Several summary tables from that study are provided in Attachment B.
As part of the study of ESF actuations, AE00 noted the following specific problems associated with D. C. Cook.
1.
Nine units, including D. C. Cook 2, were of potential concern because they appear to have been experiencing repeated unresolved actuations which could ultimately challenge continued equipment operability and proper personnel response.
2.
Six units, including D. C. Cook 2, had a relatively high number of false actuations of radiation monitors.
The actuations were primarily associated with radiation monitor software problems which led to isolation of containment purge. This software problem did not appear to be generic to the other units studied.
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APR - 3 1986 Corporation 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 matter.
If you have any questions, please contact W. G. Guldemond (312/790-5574).
Sincerely,
'Ortgtnat Sfgned by E.G. Greenman" Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
AE00 Assessment cc w/ enclosure:
W. G. Smith, Jr., Plant Manager DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office Nuclear Facilities and Environmental Monitoring Section
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APPENDIX A 1984.RtsCTOR TRIP RATES MANUAL AUfo LESS THAN GREATER CRITICAL TRIP RATE PER HEAN TIME NOME MATIC OR EQUAL THAN HOURS 1000 HOURS BETWEEN TRIPS 15% POWER 15% POWER POWER OT 15 POWER Of 15%
BRUFSWICK 1 0
7 2
5 7023.8 0.71 1404.3 4
1 0
5 7531.0 0.66 1506.2 DALISADES 0
1 0
1 1550.5 0.84 1550.5 CALVERT CL!rfS I PEACH BOTTOM 3 1
4 0
5 7757.7 0.84 1551.5 CUA0 CITIES I i
3 0
3 4766.9 0.83 1589.0 0
6 2
4 6319.8 0.83 1579.9 BROWNS FERRY I 4
4 3
5 8087.4 0.62 1813.5 DEAVER VALLEY l 1
6 0
4 8478.3 0.82 1819.1 210N 1 OCONEE 3 0
4 0
4 6520.7 0.81 1830.2 MAINE YANKEE 1
7 3
4 6688.8 0.60 1872.2 SAN ONOFRE 2 1
4 2
3 5272.4 0.57 1757.5 FIT 2 PATRICK 0
4 0
4 7087.2 0.56 1771.8 QRKANSAS 1 0
3 0
3 6222.4 0.48 2074.1 ORESDEN 2 0
3 0
3 6511.4 0.46 2170.5 INDIAN POINT 2 1
5 2
2 4718.4 0.42 2359.2 OCONEE 1 0
3 0
3 7452.4 0.40 2484,1 0.C.C00K 1 0
3 0
3 8085.9 0.37 2895.3 PRAIRIE ISLAND 1 0
4 1
3 8321.3 0.36 2773.8 BROWNS FERRY 2 0
3 0
2 5895.7 0.34 2947.9 COOPER 0
3 1
2 5952.6 0.'34 2978.3 NORTH ANNA 2 1
4 2
2 6136.0 0.33 3068.0 ZION 2 2
6 5
2 6285.2 0.32 3142.6 HADDAM NECK 1
3 1
2 6515.6 0.31 3257.8 CALVERT CLIFFS 2 0
2 0
2 6630.2 0.30 2315.1 QUAD CITIES 2 1
4 0
2 6988.6 0.29 3494.3 VERMONT' YANKEE 0
2 0
2 7115.2 0.28 3557.6 v
REWAUNEE O
5 1
2 7570.5 0.26 3785.3 CRYSTAL RIVER 3 0
2 0
2 8346.5 0.24 4173.3 MILLSTONE 2 1
2 1
2 8596.8 0.23 4293.4 FORT CALHOUN 1
'O 1
0 1
5386.3 0.19 5336.3 R.E.OlHNA 0
1 0
1 6848.7 0.15 8848.7 FARLEY 1 0
2 1
1 7005.8 0.14 7005.I B10 ROCK POINT 0
3 3
0 6981.9 0.00 SAN ONOFRE 1 0
0 0
0-888.6 0.00 0YSTER CREEK 0
2 2
0 1700.0 0.00 NINE MILE POINT 1 0
1 1
0 6414.0 0.00 MILLSTONE 1 0
0 0
0 8990.2 0.00 N B, ROBINSON O
1 0
0 616.1 0.00 1
i
1 APPENDIX A 1984 REACTOR TRIP RATES MANUAL AUTO LESS THAN GREAftR CRITICAL TRIP RATE PER MEAN f!ME NAME MATIC OR EQUAL THAN HOURS 1000 HOURS DETWEEN TRIPS POWER Of 15 POWER of 15%
15% POWER 15% POWER 4
20 7
17 2983.0 5.70 175.5 CALLAWAY 1 1
13 6
6 1131.5 5.30 188.8 GRAND QULF 1 2
6 3
4 1010.0 3.96 252.5 WPPSS 2 SUSOUEHANNA 2 2
8 1
7 2145.9 3.28 308.8 SALEM 1 0
10 3
7 2672.3 2.62 381.3 MCGUIRE 2 5
13 0
16 6138.3 2.61 383.8 0
10 2
8 3386.0 2.38 423.3 0
7 0
7 3108.7 2.25 444.1 OIABLO CANYON 1 0
7 3
2 967.1 2.07 483.8 SALEM 2 LASALLE 2 3
8 2
9 4469.8 2.01 488.8 HATCH 2 SURRY 2 2
13 2
12 7435.3 1.61 819.8 BT.0WNS FERRY 3 2
0 1
1 700,7 1,43 700.7 LASALLE 1 0
9 0
9 8280.0 1,43 697.8 SEQUOYAH 2 0
10 0
9 6334.0 1,42 703.8 NOJTH ANNA 1 2
7 2
6 4759.9 1.26 793.3 ST.LUCIE 7 1
9 0
9 7379.2 1.22 819.9 TURKEY POINT 4 0
11 3
6 5079.8 1.18 846.8 SURRY 1 1
7 2
6 5293.7 1.13 882.3 0.C. COOK 2 2
6 1
6 5294.8 1.13 882.5 SEQUOYAH 1 1
12 4
7 6206.1 1.13 886.6 0
12 5
6 5553.4 1.08 925.8 SUSOUEHANNA 1 1
6 0
7 6549.3 1.07 935.6 SUMMER DRESDEN 3 0'
9 4
4 3889.0 1.03 972.3 TROJAN O
7 2
5 4895.4 1.02 979.1 INDIAN POINT 3 0
9 0
7 6941.6 1.01 991.7 TURKEY POINT 3 1
8 1
7 7366.6 0.95 1052.4 LA CROSSE 1
8 0
7 7437.0 0.94 1062.4 St.LUCIE 1 2-4 1
5 5555.2 0.90 1111.0 HATCH 1 3
7 3
5 5638.7 0.89 1127.7 l
MCGUIRE 1 0
5 0
5 6090.8 0.82 1218.2 SAN ONOFRE 3 0
9 3
4 5070.7 0.79 1267.7 ARKANSAS 2 0
15 6
6 7631.9 0.79 1272.0 YANKEE ROwE 2
3 0
5 6398.6 0.78 1279.7 RANCNO SECO 1 0
4 0
4 5338.8 0.75 1334.7 BRUNSWICK 2 0
3 1
2 2650.1 0.75 1325.1 OUANE ARNOLO O
6 1
5 6627.1 0.75 1325.4 OAVIS-BESSE 1 1
4 0
4 5929.0 0.72 1382.3 FARLEY 2 1
5 0
8 8375.7 0.72 1396.0 I
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APPEN0!x A toss. react 0R TRIP RATES NAME MANUAL AUfo LESS THAN OREATER CRtf1 CAL TRIP RATE PER MEAN 7!ME i
MATIC OR EQUAL THAN HOURS 1000 HOURS BETWEEN TRIPS 15% POWER 15% POWER POWER OT 15 POWER 07 15%
MON 7! CELLO O
O O
O 810.6 0
POINT BEACH 1 1
1 0
0 8420.1 0
OCCHEE 2 0
0 0
0 8784.0 0
PEACH 80ff0H 2 0
0 0
0 2583.9 0
PILGRIM 0
0 0
0 170.3 0
POINT BEACH 2 0
1 0
0 7544.2 0
pro!Rit ISLAND 2 0
0 0
0 7844.0 0
+
BYRON 1 2
0 0
0 0.0 o
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1 APPENDIX B 1984 REACTOR TRIP RATES NAME MANUAL AUTO LESS THAN GREATER CRITICAL TRIP RATE PER MEAN TIME MATIC OR EQUAL THAN HOURS 1000 HOURS BETWEEN TRIPS 15% POWER 15% POWER POWER GT 15 POWER GT.15%
WPPSS 2 4
20 7
17 2983.0 5.70 175.5 CALLAWAY 1 1.
13 6
6 1131.5 5.30 188.6 GRAND GULF 1 2'
6 3
4 1010.0 3.96 252.5 SUSOUEHANNA 2 2
8 1
7 2145.9 3.26 306.6 SALEM 1 0
10 3
7 2672.3 2.62 381.8 MCGUIRE 2 5
13 0
16 6138.3 2.61 383.6 SALEM 2 0
10 2
8 3386.0 2.36 423.3 HATCH 2 0
7 0
7 3108.7 2.25 444.1 DIABLO CANYCN 1 0
7 3
2 967.1 2.07 483.6 LASALLE 2 3
8 2
9 4469.8 2.01 496.6 SURRY 2 2
13 2
12 7435.3 1.61 619.6 BROWNS FERRY 3 2
0 1
1 700.7 1.43 700.7 LASALLE 1 0
9 0
9 6280.0 1.43 697.8 SEQUOYAH 2 0
10 0
9 6334.0 1.42 703.8 NORTH ANNA 1 2
7 2
6 4759.9 1.26 793.3 ST.LUCIE 2 1
9 0
9 7379.2 1.22 819.9 TURKEY POINT 4 0
11 3
6 5079.8 1.18 846.6 SURRY 1 1
7 2
6 5293.7 1.13 882.3 D.C. COOK 2 2.
6 1
6 5294.8 1.13 882.5 SEQUOYAH 1 1
12 4
7 6206.1 1.13 386.6 SUMMER 0
12 5
6 5553.4 1.08 925.6 SUSQUEHANNA 1 1
6 0
7 6549.3 1.07 935.6 DRESDEN 3 0
9 4
4 3889.0 1.03 972.3 TROJAN O
7 2
5 4895.4 1.02 979.1 TNDIAN POINT 3 0
9 0
7 6941.6 1.01 991.7 VURKEY POINT 3 1
8 1
7 7366.6 0.95 1052.4 La CROSSE 1
8 0
7 7437.0 0.94 106?.4 ST.LUCIE 1 2
4 1
5 5555.2 0,90 1111.0 HATCH 1 3
7 3
5 5638.7 0.89 1127.7 MCOUIRE 1 0
5 0
5 6090.8 0.82 1218.2 SAN ONOFRE 3 0
9 3
4 5070.7 0.79 1267.7 ARKANSAS 2 0
15 6
6 7631.9 0.79 1272.0 YANKEE ROWE 2
3 C
5 6398.6 0.78 1279.7 RANCHO SECO 1 0
4 0
4 5338.8 0.75 1334.7 BRUNSWICK 2 0
3 1
2 2650.1 0.75 1325.1 00ANE ARNOLO O
6 1
5 6527.1 0.75 1325.4 DAVIS-BESSE 1 1
4 0
4 5529.0 0.72 1382.3 FARLEY 2 1
5 0
6 8375.7 0.72 1396.0 9
0
APPENDIX 8 1984_ REACTOR TRIP RATES NAME MANUAL AUTO LESS THAN GREATER CRITICAL TRIP RATE PER MEAN TIME MATIC OR EQUAL THAN HOURS 1000 HOURS 3ETWEEN TRIPS 15% POWER 15% POWER POWER OT 15 POWER GT 15%
BRUNSJICK 1 0
7 2
5 7023.8 0.71 1404.8 CALVERT CLIFFS I 4
1 0
5 7531.0 0.66 1506.2 PALISADES 0
1 0
1 1550.5 0.64 1550.5 PEACH BO7 TOM 3 1
4 0
5 7757.7 0.64 1551.5 QUAD CITIES 1 1
3 0
3 4766.9 0.63 1589.0 ZION 1 0
6 2
4 6319.8 0.63 1579.9 BROWNS FERRY I 4
4 3
5 8067.4 0.62 1613.5 BEAVER VALLEY 1 1
6 0
4 6476.3 0.62 1619.1 OCONEE 3 0
4 0
4 6520.7 0.61 1630.2 MAINE YANKEE 1
7 3
4 6688.8 0.60 1672.2 SAN ONOFRE 2 1
4 2
3 5272.4 0.57 1757.5 FITZPATRICK 0
4 0
4 7087.2 0.56 1771.8 ARKANSAS 1 0
3 0
3 6222.4 0.48 2074.1 DRESDEN 2 0
3 0
3 6511.4 0.46 2170.5 INDIAN POINT 2 1
5 2
2 4718.4 0.42 2359.2 OCONEE 1 0
3 0
3 7452.4 0.40 2484.1 0.C. COOK 1 0
3 0
3 8085.9 0.37 2695.3 PRAIRIE ISLAND 1 0
4 1
3 8321.3 0.36 2773.8 BROWNS FERRY 2 0
3 0
2 5895.7 0.34 2947.9 COOPER 0
3 1
2 5952.6 0.34 2976.3 NORTH ANNA 2 1
4 2
2 6136.0 0.33 3068.0 ZION 2 2
6 5
2 6285.2 0.32 3142.6 HADDAM NECK 1
3 1
2 6515.6 0.31 3257.8 CALVERT CLIFFS 2 0
2 0
2 6630.2 0.30 3315.1 QUAD CITIES 2 1
4 0
2 6988.6 0.29 3494.3 VERMONT YANKEE O
2 0
2 7115.2 0.28 3557.6 KEWAUNEE O
5 2
2 7570.5 0.26 3785.3 CRYSTAL RIVER 3 0
2 0
2 8346.5 0.24 4173.3 MILLSTONE 2 1
2 1
2 8596.8 0.23 4298.4 FORT CALHOUN 1 0
1 0
1 5386.3 0.19 5346.3 R.E.GINNA 0
1 0
1 6848.7 0.15 6848.7 FARLEY 1 0
2 1
1 7005.8 0.14 7005.8 BIG ROCK POINT 0
3 3
0 6981.9 0.00 SAN ONOFRE 1 0
0 0
0 888.6 0.00 OYSTER CREEK 0
2 2
0 1700.0 P.00 NINE MILE POINT 1 0
1 1
0 6414.0 0.00 MILLSTONE 1 0
0 0
0 6990.2 0.00 H.8 ROBINSON O
1 0
0 616.1 0.00
....~
7
. APPENDIX 8 1984. REACTOR TRIP RATES i
i j
NAME MANUAL AUTO LESS THAN GREATER CRITICAL TRIP RATE PER MEAN TIME MATIC OR EQUAL THAN HOURS 1000 HOURS BETWEEN TRIPS 15% POWER 15% POWER POWER GT 15 POWER GT 15%.-
MONTICELLO O
O 0
0 810.6 0
POINT BEACH 1 1
1 0
0 6420.1 0
OCCNEE 2 0
0 0
0 8784.0 0
PEACH ROITOM 2 0
0 0
0 258.1.9 0
PILGRIM 0
0 0
0 1 170.3 0
POINT BEACH 2 0
1 0
0 7544.2 0
GRAIRIE ISLAND 2 0
0
'O O
7844.0 0
4 BYRON 1 2
0 0
0 0.0 i
i s-a e
1 6
6 4
5 I
T i
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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 ESF UNIT ACTUATIONS UNIT ACTUATIONS SAN ONOFRE 2 82 ARKANSAS NUCLEAR ONE 1 1
SEQUOYAH 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 1
LA SALLE 2 20 E.
I.
HATCH 2 1
FORT CALHOUN 20 NORTH ANNA 1 1
GRAND GULF 1 19 OYSTER CREEK 1
LA SALLE 1 17 POINT BEACH 2 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 O
MAINE YANKEE 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 0
TROJAN 3
NORTH ANNA 2 O
TURKEY POINT 3 3
OCONEE 1 0
TURKEY POINT 4 3
OCONEE 2 O
YANKEE ROWE 3
OCONEE 3 O
BEAVER VALLEY 2
PEACH BOTTON 3 O
BROWNS FERRY 2 2
PILGRIM 1 0
CALLAWAY 2
POINT BEACH 1 O
FITZPATRICK 2
PRAIRIE ISLAND 1 O
INDIAN POINT 3 2
QUAD 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 O
SUSQUEHANNA 2 2
ZION 2 O
THREE MILE ISLAND 1 2
VERMONT YANKEE 2
l ZION 1 2
l t-
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.
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y 79 89 99 j
l SM ON[FRE 2
' IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII SEQlt)YM 1 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII WASHIMIT(N MILEAR 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII N0KliCE110 IIIIIIIIIIIIIIIIIIIIIIIIII D. C. COOK 2 IIIIIIIIIIIIIIIIIIIIIIIII DlME arf (JLD IIIIIIII!!!IIIIIIIIIIIIII SEQUDYAH 2 IIIIIIIIIIIIIIIIIIIII
.LA SALLE 2 IIIIIIIIIIIIIIIIIIII F E T CALM)lN IIIIIIIIIIIIIIIIIIII
-GAND GLA F 1 IIIIIIIIIIIIIIIIIII LA SALLE 1 IIIIIIIIIIIIIIIII SAN ONOFRE 3 IIIIIIIIIIIIII 1RtNSWICK 1 IIIIIIIIII SUSQlemtNA 1 IIIIIIIIII l
DIABLO CANYON 1 IIIIIIIII MC0UIRE 1 IIIIIII l
BRLMSWICK 2 IIIIII KEWALKE IIIIII MIE YREE IIIIII PtLISADCS IIIIII SlfMR 1
. IIIIII feMNSAS MJCif/41 (NE 2 IIIII IR0lNS FERRY I IIII FTACH BOTTON 2
, IIII U BR0lNS FERRY 3 III N
D. C. (110K 1 III I GYSTAL RIVER 3 III T TP(LIAN III TlRKEY POINT 3 III N TIRKEY POINT 4 III A YrMEE ROE III M BEAVG VALLEY II E BR0lNS FERRY 2 II S CALIAWAY II FITZPATRICK II I@:M POINT 3 II LA RISSE II MLLSTOPE 2 II h!NE MILE POINT II LNITS EPORTING NO ESF ACTlMTIONS:
SALDI 1 II S/N ONCO E 1 II CALVERT CLIFFS 1 OCDEE 2 SU N R G E 7 II GMECTICUT YAPEEE OCONEE 3 TWJ: CILE' ISLAND 1 II DRESDEN 2 PEiol BOTTON 3 VEF:-'WT YTMEE II DRESDEN 3 PIL@lM 1 ZIL.1 II FARLEY 1 POINT BEACH 1 fir #SAS MJCLEAR ONE 1 I
FARLEY 2 FRAIRIE IS1ND 1 BIG I;1CX POINI I
E. I. MTCH 1 GUAD CITIES 1 CALVOIT CLIFFS 2 I
HlMBOLDT BAY SftIM 2 CD0PER I
INDIAN POINT 2 ST. LlE!E 1 DAVIS BESSE 1 I
MC0UIRE 2 ST. LlEIE 2 FT. ST. VRAIN I
MILLSTOE 1 SURRY 2 GIINA I
NCRTH AN M 2 THREE MILE ISLIND 2 E. I. HATDI 2 I
OCOPE 1 ZION 2 NORTH ANNA 1 I
OYSTB CREEX X
FVINT BEACH 2 I
FRAIRIE IRMD 2 I
OUAD CITIES 2 I
RfNCHO SECD I
ROBINSON 2 I
SURRY I I
0 to 20 30 40 50 60 70 80 90 NJtBER OF ESF ACTlmTIONS Figure 1:
Unit Distribution of Engineered Safety Features Actuations (January - June 1984)
0 10 20 30 40 50 60 i
SEQUOY411 IIIIII MCGJIRE I II UN NA MONTIGlLO II I M TE GRAND Cltf I I
SAN ON0FRE I I
0 10 20 30 40 50 60 NLMBER OF V4.ID ESF ACRATIONS (DESIGN BASIS) 0 10 20 30 40 50 60 SAN DURE 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII ;
. SEQUOYMi 1 IIIIIIIIIIIII D. C. COOK 2 IIIIIIIIIII FORT CAL 10)N IIIIIIIIIII LA SALLE 1 IIIIIII LA SALLE 2 IIIIIII U
CRAND CRF 1 IIIII N
WPSS 2 IIII I
BRtNSWIM 1 III T
FITZPATRICK II SUSQE}WM 1 II N
ZION 1 II
.A BROW 6 FERRY 2 I
M ERtNSWICK 2 I
E D. C. COOK 1 I
NIE MILE POINT I
l SEQUOYAH 2 I
StftER 1 1
TlEKEY POINT 4 I
Y M EE R0WE I
0 10 20 30 40 50 60 NLMBER 0F VALID ESF ACTUATIONS (NON-DESIGN BASIS)
Figure 3: Unit Distribution of Valid ESF Actuations
(
l 0
10 20 30 40 50 WPSS 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII RGUOYM i IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII SM ONOFRE 2 IIIIIIIIIIIIIIIIIIIIIIIIII REE ARNCLD IIIIIIIIIIIIIIIIIIIIIIIII twilELLO IIIIIIIIIIIIIIIIIIIIIIII j
EDV0YAH 2 IIIIIIIIIIIIIIIIIIII D. C. COOK 2 IIIIIIIIIIIIII SM ONOFRE 3 IIIIIIII!!!III GRMDGlLE I IIIIIIIIIIIII
- LA SALLE 2 IIIIIIIIIIIII LA SALIE 1 IIIIIIIIII DIABLO CMYCN IIIIIIIII FCRT CALHOLN IIIIIIIII BFttNSWICK 1 IIIIIIII SUS 0lO Wed 1 IIIIIIII EWGEE IIIIII P1AIT YM IE IIIIII PALISADES IIIIII trW NSAS 2 IIIII EtNSWICX 2 IIIII PCGJIRE I IIIII StrKR 1 IIIII IROWNS FBRY I IIII Fif01 BOTTON 2 IIII
- U IROW G FERRY 3 III N
CRYSTAL RIVER 3 III I
TROJM III T
TLRKEY POINT 3 III BEAVER WLLEY II N
CitLAWAY II A
D. C. C00C 1 II P1 INDIM POINT 3 II E
LACROSSE II MILLSTOE 2 II STLD11 II SUSalEHArea 2 II TMI 1 II TURKEY POINT 4 II
~-
VERMONT YMKEE II YWIE R0WE II ARVlNSAS 1 I
BIG ROCK POINT I
BROW 6 FERRY 2 I
I CALVERT Q.lFFS 2 I
COEFER I
DAVIS K SE I I
FT. ST. YRAIN I
G!tta I
E. I. HATCH 2 I
NINE ?!Ilf POINT I
l l
NORTH Ated 1 I
I OYSTER CREEX I
I POINT BEACH 2 I
FRAIRIE ISLMD 2 I
l QLAD CiilES 2 I
Rt>O O SECO I
ROBINSON 2 I
SM ONCFRE 1 I
9JRRY I I
0 10 20 30 40 50 KJttBER OF FftSE ESF ACTluTI0tG l
Figure 8: Unit Distribution of False ESF Actuations
____-___r,
-. _,. + - -
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ATIACHMENT C a
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L
ENCLOSURE AE00 INPUT TO SALP REVIEW FOR D. C. COOK 1 AND 2 Introduction in order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by D. C. Cook I and D. C. Cook 2 during the April 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 methodology presented in I
NUREG/CR-4178. The sample consisted of 24 LERs for D. C. Cook 1 and 18 LERs for D. C. Cook 2, which represents fif ty percent of the LERs that were available for each unit 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 af ter the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for review.
Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields met 2
3 the requirements of 10 CFR 50.73(b), NUREG-1022, and Supplements 1 4
and 2 to NUREG-1022.
The evaluation process for each LER was divided inte two parts. The first part of the evaluation consists of documenting comments specific to the content and presentation of each LER. The second part consists of determining a score (0-10 points) for the text, abstract, and coded fields of each LER.
1
The LER specific comments serve two purposes; (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that were reviewed. Likewise, the text, abstract, and coded fields 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, 6bstract. and coded fields (i.e. 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score = overall LER score).
Evaluation Results No attempt is made at this time to explain differences between results for multiple Units beyond providing genef al conments, when applicable, in the Discussion of R6sul~s. 'However, as data is collected, scores for the t
units that have been eva'luated will.be presented for comparison purposes.
The results Of the evaluation are presented by unit and are divided into two categories:
(1) detailed inforniation and (2) summary information. The detailed infermation, presented in Appendices A through D, consists of LfR sample information (Appendix A), a table of the specific sceres for each saniple LiR (Appendit B), tables of the number of deficiencies and observation for the text, abstract and coded fields (Appendix C), and conc.ent sheets for each LER (Appendiz D).
When referring to these appendices, tne reader is cautioned not to try to directly l
correlate the number of comments on an individual c6mment sheel with the assigned scores, as the analyst has flexibility to consider the magnitude of a defittency when assigning scores.
I In ths case where multiple units are evaluated, the results dre submitted in one enclosure and the suramary tables are assigned an i
alphabetic character so that the dif ferent unitt can referente the same l
l 2
.e
~ -
- p v
y 3
g g
9
table numbers.
For example in this enclosure, the letters A and 3 assigned to a table number correspond to D. C. Cook 1 and 2, respectively.
Discussion of Results A discussion of the analysts' conclusions are presented below.
These conclusions are based solely on the results of the evaluation of the LERs selected for review and as such represent the analysts' opinion of each unit's performance (on a scale of 0 to 10) in preparing LERs that meet the necessary requirements concerning contents.
The analysts made no attempt to assess differences in scores or the number of deficiencies between D. C. Cook 1 and D. C. Cook 2 because sufficient information is not available concerning how LERs are prepared or reviewed at each unit.
Evaluation Results for D. C. Cook 1 Table 1A presents the average scores for the sample of LERs evaluated for D. C. Cook 1.
The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.
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.
Additional units will be added to Table 2 as they are evaluated. Table 3A and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1A.
For example, D. C. Cook l's average score for the text of the LERs that were evaluated is 6.4 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 3
~..,_.
a i
TABLE lA. St# MARY OF SCORES FOR D.C. COOK 1 Average High low Text 6.4 8.6
- 2. 8 Abstract 8.3 10.0 3.4 Coded Fields 8.4 9.3
- 5. 8 Overall 7.2b 8.8 3.3 l
a.
See Appendix 8 for a summary of scores for each LER that was evaluated.
b.
Overall Average = 60% Text Average + 30% Abetract Average + 10% Codeo Fielos Average.
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+
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4 1
TABLE 2, COMPARISON Of AVERAGE SCORES FROM OTHER UNITS Overall Coded End SALP Text Abstract Fields verage a
Unit Name Period Average Average Average
(
)b 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)
Beaver Valley 1 9-30-85 7.2 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)
J 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.
e k
. - - - - -.., _ - - -, - -... ~ _... - - -,, - -
TABLE 3A. LER REQUIREMENT PERCENTAGE SCORES FOR 0.C. COOK 1
~
TEXT Percentage Requirements [50.73(b)] - Descriptions lcores()#
(2)(ii)(A) - - Plant condition prior to event 86 (24)
(2)(li)(B) - -
Inoperable equipment that contributed b
(2)(ii)(C) - - Date(s) and approximate times 81 (24)
(2)(ii)(D) - - Root cause and intermediate cause(s) 69(24)
(2)(ii)(E) - - Mode, mechanism, and effect 70 (10)
(2)(ii)(F) - - EIIS Codes 39 (23)
(2)(ii)(G) - - Secondary fur.ction affected b
(2)(ii)(H) - - Estimate of unavailability 50 (12)
(2)(ii)(I) - - Method of discovery 60 (24 )
(2)(ii)(J)(1) - Operator actions affecting course 82 (15)
(2)(ii)(J)(2) - Personnel error (procedural deficiency) 64 (18)
(2)(ii)(K) - - Safety system responses 100 (7)
(2)(ii)(L) - - Manufacturer and model no. information 43 (7)
Assessment of safety consequences 38(24)
(3)
Corrective actions 76 (24 )
(4)
Previous similar event information 21 (24)
(5)
(2)(i) - - - - Text presentation 74 (24)
ABSTRACT Percent age Requirements [50.73(b)(1)] - Descriptions Scores ( )a
- Majo,r occurrences (Immediate cause and effect 95 (24) information)
- Description of plant, system, component, and/or 78 (17) personnel responses
- Root cause information 69(24)
- Corrective Action information 88 (24 )
- Abstrcct presentation 81 (24)
[
r
' TABLE 3A.
(continued)
CODED flELDS Percentage item Number (s) - Description Scores.( )#
1, 2, and 3 - Facility name (unit no.), docket no. and 100 (24) page number (s) 4 - - - - - - Title 52 (24) 5, 6, and 7 - Lyent date, LER No., and report d6te 9 7 (74 )
8 - - -
- - Other facilities involved 93 (24) 9 and 10 - - Operating m;de and power level 100 (24) 11 - - - - - Reporting requirer.ents 94 (24) 12 - - -
- Licensee contact information 97 (24 )
13 - + - - - Soded component failure information 85 (24) 14 and 15 -
- Supplemental report information 92 (24 )
Percentage scores are the result of dividing the total points for a a.
requirement by the number of poin'ts possible for that requirement.
(Note: Some requirements are not applicable to all LERs, therefore, tne number of points possible was adjusted accordingly.) The humber in parenthesis is the number of LERs for which the requirement was cor.sidered applicable, b.
A percentage score for this requirement is meaningless as it is not possible to determine f rom 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" phen it is not.
P 1
T
pr esentat ion. The percent scores in the text summary section of Table 3A
. provide an indication of how well each text requirement was addressed by the licensee for the 24 LERs that were evaluated.
Discussion of Specific Deficiencies A review of the percentage scores presented in Table 3A will quickly point out those areas where the licensee is experiencing the most difficulty in preparing LERs. For example, the licensee's percentage score for recairement 50.73(b)(2)(ii)(D), (i e., cause information for occurrences) is only 69%. Thirteen of the 24 LERs failed to provide adequate root cause information. Root cause information it very useful to the analyst who uses LER data for the purpose of looking for generic problems but rect cause information is even more important to the licensee that has experienced the event.
It is only through adequate determination cf root causes that implementation of the necessary corrective actions can be sccomplished, thereby preventing recurrence of the Event or similar cvents. The remsining deficiencies will be discussed in their relative order of importance.
The D. C. Cook 1 LERs were generally deficient in the area of assessing the safety consequences of the event. Eighteen of the 24 LERs did not contain or did not adequately discuss safety consequences ano implications. Sofety consequences were addressed in mott of the LERs but not in sufficient detail. Stating that "the consequences were minimal because f.he problem was quickly identified and corrected" is not adequate.
The discussion shnuld indicate what could have happened had the problen not been identif!ed and corrected quickly or indicate what other systems, components, and/or procedures were availaole to mitigate the consequences.
Likewise, it is inadequate to state that "there were no safety cnnsequences because tne teactor wus shutdown" if it is possible to have the same scenario happen during power operatinn.
4
%A g -
4 For certain events, such as the unscheduled actuation of the Reactor Protection System (RPS) or an Engineered safety Feature (ESF) System, it may be enough to state that "the actuation placed the plant in a more conservative condition relative to plant safety", provided, of course, that there were no increased safety consequences as a result of the actuation.
Fourteen of the 18 LERs involving personnel error were deficient.
In half of these, personnel error was not explicitly given as a cause but had to be inferred from other discussions (e.g., corrective actions). Another common aeficiency in this area was failure to state whether the personnel error was cognitive or involved a procedural error. Often the type (i.e.,
licensed operater, maintenance supervisor, etc.) of personnel involved was not stated.
Five of the 10 LERs involving a component f ailure were deficient in that they did not provide failure mode, failure mechanism (immediate cause), and/or f ailure effect information. Such information can of ten be inferred from other areas of the LER but this requires certain assumptions on the part of the reader. Failure mode, mechanism, and effect information should be provided for each component failure and, in some cases, fault.
For example, if an operator inadvertently shuts a safety related valve, the reader would like to know precisely how this occurrence affected the plant (e.g., "no boron injection was possible from train A as a result of the valve being closed").
Another deficiency related to components involved requirement 50.73(b)(2)(ii)(L). Four of the LERs involving component failure dio not provide manufacturer and model number information in the text. This, or other identification information, should be provided whenever a component f ailure or a component design problem contributes to an event.
Although the corrective actions requirement percentage score is not below average, a large number (11 of 24) of LERs failed to provide all the necessary information concerning corrective actions.
It is not enough to i
f 5
discuss only the immediate corrective actions.
Those actions necessary to prevent recurrence of the event or similar events must also be discussed.
The success of these long-term corrective actions is obviously a function of how well the cause of each occurrence is determined. Without determining the root cause of each occurrence, adequate long-term corrective actions can not be planned.
Six of'the 12 LERs involving safety system trains did not provide adequate dates or times so that the unavailability time of the train could be determined. This kind of information is required as it becomes part of the generic data necessary to perform probabilistic risk assessments (PRAs).
Nine of the 24 LERs failed to provide the method of discovery for each Such component or system failure and/or procedural or personnel error.
information is required as it provides the reader with the details as to This what particular activity was in progress that led to a discovery.
kind of information may prompt others to implenent some of these same activities (e.g., semi-annual reviews, post-test walkdowns, etc.) at their facility.
Previous similar event information was not provided in 15 of the 24 LERs. The determination of whether or not any previous similar events have occurred at your unit (or units)'can aid in identifying recurring problems or trends.
If no previous similar events are found, the text should so state.
Energy Industry Identification System (Ells) component function identifier and/or system name codes were not provided in two-thirds of the LERs for D. C. Cook 1.
The text presentation was lower than average for three reasons:
- 1) information was not consistent as it was not presented in a structured fornet, 2) the text (and abstract) were presented in all capital letters which made it more difficglt to identify information that is normally capitalized (e.g., component designators, system names, modes, and 6
position titles), and 3) ma.ny of the " text presentations" consisted of only an abstract. Over half of the D. C. Cook's LERs (13 of 24) were abstracts with no text.
This is permissible, but when it is done, the abstract must contain all the information that is required to be in a text. This is often difficult to accomplish in the space available for an abstract and probably accounts for the lower than average overall text scores.
The abstracts were generally deficient in the areas of root cause, which is a reflection of the text deficiency in this same area.
In the coded field area, all the titles were deficient.
They all lacked infonnation concerning root cause and over half lacked a linking phrase. Most titles provided the result of the event, (i.e., why the event had to be reported). An adequate title should contain three elements:
root cause, result, and a phrase or words tht make it possible for the reader to understand how the two elements are linked. For example, a title such as " personnel error causes scram" contains root cause and result but does not tell the reader anythin about the intermediate details. This intermediate information (link) is useful for the reader who uses titles to select categories of LERs from a hardcopy file. The other items in the coded fields were generally good.
Evaluation Results for D. C. Cook 2 Tables 18 and 38 provide a summary of the D. C. Cook 2 evaluation.
See Table 2, in order to place the D. C. Cook 2 scores in perspective.
A review of Table 3B indicates that D. C. Cook 2 has essentially the same deficiencies as D. C. Cook l and therefore, a separate discussion of specific D. C. Cook 2 deficiencies is not required.
Table 4 provides a summary of the areas that require improvement for D. C. Cook LERs.
Table 4 is applicable to both D. C. Cook 1 and D. C. Cook 2.
7
a TABLE 18.
SUMMARY
OF. SCORES FOR D.C. COOK 2 Average High Low Text 6.7 9.3 5.0 Abstract 8.3 10.0 6.0 Coded Fields 8.4 9.9 6.3 Overall 7.3b 9.3 6.1 a.
See Appendix B for a summary of scores for each LER that was evaluated.
b.
Overall Average = 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.
4 4
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-7 m
y
TABLE 38. LER REQUIREMENT PERCENTAGE SCORES FOR D.C. COOK 2 TEXT Percentage Requirements [50.73(b)] - Descriptions Scores ( )a (2)(ii)(A) - - Plant condition prior to event 89 (18)
(2)(ii)(B) - -
Inoperable equipment that contributed b
(2)(ii)(C)
- Date(s) and approximate times 94 (18)
(2)(ii)(D) - - Root cause and intermediate cause(s) 78 (18)
(2)(ii)(E) - - Mode, mechanism, and effect 95 (5)
(2)(ii)(r) - - Ells Codes 29 (17)
(2)(ii)(G) - - Secondary function affected b
(2)(ii)(H) - - Estimate of unavailability 83 (6)
(2)(ii)(I) - - Method of discovery 69 (18)
(2)(ii)(J)(1) - Operator actions affecting course 82 (11)
(2)(ii)(J)(2) - Personnel error (procedural deficiency) 58 (12)
(2)(ii)(X)
- - Safety system responses 74 (7)
(2)(ii)(L) - - Manuf acturer and model no. information 0(3)
Assessment of safety consequences 26 (18)
(3)
Corrective actions 83 (18)
(4)
Previous similar event information 33 (18)
(5)
(2)(i) - - - - Text presentation 67(18)
ABSTRACT Percentage Requirements [50.73(b)(1)] - Descriptions Scores ( )#
- Major occurrences (Immediate cause and effect 93(18) information)
- Description of plant, system, component, and/or 85 (14) personnel responses
- Root cause information 65 (18)
- Corrective Action information 90 (18)
- Austract presentation 82 (18)
TABLE 38.
(continued)
CODED FIELDS Percentage item Number (s) - Description Scores ( Ja 1, 2, and 3 - Facility name (unit no.), docket no. and 100 (18) page number (s) 4 - - - - - - Title 49 (18) 5, 6, and 7 - Event date, LER No., and report date 100 (18) 8 - - - - - - Other f acilities involved 100(18) 9 and 10 - - Onerating mode and power level 94 (18) 11 - - - - - Reporting requirements 100 (18) 12 - - - - - Licensee contact information 98 (18) 13 - - - - - Coded component failure information 87 (18) 14 and 15 - - Supplemental report information 100(18)
Percentage scores are the result of dividing the total points for a 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.
TABLE 4.
AREAS MOST NEEDING IMPROVEMENT FOR D. C. COOK 1 AND 2 LERS Areas Comments Personnel error discussions Details should be explicitly stated; the cause of personnel error should be discussed, (e.g., cognitive or procedural). Contributing factors should be provided when appropriate.
Safety assessment information Statements involving consequences or implication were often missing or boiler plate statements such as,
" minimal safety significance because all system functioned as designed".
More effort should be placed on providing a discussion of the safety implications or justification for the boiler plate statements.
Root cause information More details should be provided.
Root cause can sometimes only be inferred from the corrective actions.
Corrective action information Long-term corrective actions necessary to prevent recurrence and similar events should be discussed in each LER.
Failure mode, mechanism, Details concerning all three aspects and effect information of every component f ailure should be provided. While mode and mechanism are of ten provided, the reader is of ten unf amiliar with the precise effect that a specific component failure will have on a system and/or the plant.
Manuf acturer and model number Component identification information information should be included in the text whenever a component f ails or is suspected to have contributed to the event because of its design.
TABLE 4.
(continued)
Areas Comments Safety train unavailability Sufficient dates and times should be included in the text to enable the reader to determination of the length of time that safety system trains or components were out of service.
Previous similar Previous similar events should be events reference (LER Number) or the text should state there are none.
Method of discovery Information concerning what activity led to the discovery of each occurrence discussed in the text should be provided.
Ells codes Codes for each component and system involved in the event should be provided.
Text presentation and The practice of providing an abstract readability with no text should be avoided except for very minor and easily explained events. An outline format is recommended; the use of all capital letters is not.
Abstract Root cause information was of ten inadequate.
Coded Fields a.
Titles Titles need to be written such that they better describe the essence of the event.
l i
i REFERENCES 1.
B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.
2.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report S. stem, 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, Februar', 1984.
4.
Office for Analysis and Evaluat?on of Operational Data, Licenseee Event Report System, NUREG-1022 Jupplement No. 2 U.S. Nuclear Regulatory Commission, September 1985.
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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR D. C. COOK 1 AND 2 9
l
TABLE A-l.
LER SAMPLE SELECTION FOR D.C. COOK 1 (315)
LER Sample Number LER Number Connents 1
84-004-00 2
84-008-00 SCRAM 3
84-011-00 SCRAM 4
84-014-00 5
84-015-00 6
84-016-00 7
84-017-00 SCRAM 8
84-022-00 9
84-023-00 10 84-024-00 11 84-025-00 12 84-030-00 13 84-031-00 14 84-032-00 15 85-002-00 16 85-003-00 17 85-006-00 18 85-013-00 19 85-016-00 20 85-019-00 21.
85-020-00 4
i
y.
k TABLE A-1.
-(continued)
LER Sample Number LER Number Comments 22 85-021-00 23 85-022-00 SCRAM 24 85-025-00
TABLE A-2.
LER SAMPLE SELECTION FOR 0. C. COOK 2 (316)
LER Sample Number LER Number Comments 1
84-011-00 SCRAM 2
84-012-00 SCRAM 3
84-015-00 4
84-016-00 5
84-017-00 6
84-018-00 7
84-019-01 8
84-021-00 9
84-027-00 10 84-028-00 11 84-030-00 SCRAM 12-84-032-00 SCRAM 13 84-033-00 14 84-034-00 SCRAM 15 85-003-00 SCRAM 16 85-009-00 17 85-010-00 18 85-011-00
e APPENDIX B EVALUATION SCORES OF INDIVIOUAL LERs FOR D. C. COOK 1 AND 2 10
TABLE B-1.
EVALUATION SCONES OF INDIVIOUAL LERs FOR D. C. COOK 1 a
.LER Sample Number 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 Text 6.6 6.9 7.4 6.8 6.6 4.5 7.8 7.3 -
5.5 8.0 7.2 3.6 4.1 5.4 1.1 6.3 Abstract 9.8 8.8 10.0 9.0 9.0
- 7. 0 10.0 9.1 6.3 8.5 9.3 9.4 7.3 9.0 7.5
- 9. 0 Coded Fields 8.8 8.4 8.3 7.9 9.1 7.6 7.8 9.3 8.3 7.9 8.4 8.3 8.7 8.9 7.9 8.6 Overall 7.8
- 7. 6 8.3 7.6
- 7. 6 5.6 8.5 8.0 6.0 8.1 8.0
- 5. 8 5.5 6.8 7.3
- 7. 3 LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text 8.6 8.2
- 7. 0 2.8 7.9 3.8 8.0 6.4 6.4 Abstract 6.9 10.0 8.5 3.4 8.6 6.5 8.5 7.0 8.3 Coded Fields 9.3 8.9 7.8 5.8 9.2 8.9 7.8 8.4 8.4 overall 8.2 8.8
- 7. 5 3.3 8.2 5.1 8.1 6.8 7.2 See Appendix A for a Itst of the corresponding LER numbers.
a.
S
TABLE 8-2.
EVALUATION SCORES OF INDIVIDUAL LERs FOR 0. C. COOK 2 a
LER Sample Number 1
2 3
4 5
6 7
8 9
10 11 12-13 14 15 16 Text 5.7 7.3
- 7.1 6.0 5.4 6.8 7.1 6.4 7.6 5.0 7.0 7.4 6.6 5.6 7.6 9.3 Abstract
- 7. 0
- 7. 0 8.5
- 6. 0 8.6
- 7. 5 10.0 9.6 8.9
- 7. 5 9.0 8.9
- 9. 0
- 7. 5 8.5 9.8 Coded Iields 8.4 8.9 9.4 6.3 8.7 8.4 8.3 7.9 9.2 8.9 7.8 8.2 -
9.9 3.4 7.7
-8.1 overall 6.4 7.4
- 7. 8 6.1 6.7 7.2 8.1 7.5 8.2 6.1
- 7. 7 '
7.9
- 7. 7 6.5 7.9 9.3 LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text 6.1
- 6. 0 6.7 Abstract 8.4 7.2 8.3 Coded Fields 8.8 8.3 8.4 Overall 7.1 6.6 7.3 See Appendix A for a list of the corresponding LER numbers.
a.
-e-e
~~
e APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR D. C. COOK 1 AND 2 11
TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR D. C. COOK 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(A)--Plant operating 6 (24 )
conditions before the event were not included or were inadequate.
50.73(b)(2)(ii)(B)--Discussion of the status 0 (6) 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 8 (24) sufficient date and/or time information.
a.
Date information was insufficient.
3 b.
Time information was insufficient.
7 50.73(b)(2)(ii)(D)--The root cause and/or 13(24) intermediate f ailure, system f ailure, or personnel error was not included or was inadequate.
a.
Cause of component failure was not 4
included or was inadequate b.
Cause of system failure was not 6
included or was inadequate c.
Cause of personnel error was not 7
included or was inadequate.
50.73(b)(1)(ii)(E)--The failure mode, 5(10) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate, a.
Failure mode was not included er was 2
inadequate b.
Mechanism (immediate cause) was not 4
included or was inadequate c.
Effect (consequence) was not included-0 or was inadequate.
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(F)--The Energy Industry 16 (23)
Identilicallon bystem component function identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a failure of a 0 (2) component with multiple functions, a list of systems or seconaary functions which were also affected was not included or was inadequate.
50.73(b)(2)(ii)(H)--For a failure that 6 (12) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(I)--The method of discovery 9 (24) of each component f ailure, system f ailure, personnel error, or procedural error was not included or was inadequate, a.
Method of discovery for each I
component failure was not included or was inadequate b.
Method of discovery for each system 3
f ailure was not included or was inadequate c.
Method of discovery for each 9
personnel error was not included or was inadequate d.
Method of discovery for each 2
procedural error 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 a
50.73(b)(2)(ii)(J)(1)--Dperator actions that 4 (15) 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 14 (18) each personnel error was not included or was inadequate.
a.
OBSERVATION: A personnel error was 7
implied by the text, but was not explicitly stated.
b.
50.73(b)(2)(ii)(J)(2)(i)--Discussion 7
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(ii)(J)(2)(ii)--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)(ii)(J)(2)(iv)--Discussion 5
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.
o TABLE C-1.
(continued)
Number of (ERs with Deficiencies and Observstions Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(K)--Automatic and/or manual 0 (7) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 4 (7) model number of each f ailed component was not included or was inadequcte.
50.73(b)(3)--An assessment of the safety 18 (24) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION: The availability of 3
other systems or components capable of mitigating the consequences of the event was not discussed.
If no other systems or components were available the text should state that none existed.
b.
OBSERVATION: The consequences 5
of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 11 (24) 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-1.
(continued)
=
. Number pf LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
a.
A discussion of actions required to I
correct the problem (e.g., return the component or sy+ tem to operation condition or ccrrect the personnel error) was not included or was inadequate.
b.
A discussion of actions required to 4
reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate, c.
003ERVATION: A discussion of actions 5
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manuf acturer and model number) was not included or was inadequate.
I 50.73(b)(5)--Information concerning previous 15 (24) similar events was not included or was inadequate.
I i
a t
_-_..-,_..,_,___--,--.~._m
J TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
$0.73(b)(2)(i)--Text presentation 5 (24) inaaequacies.
a, OBSERVATION: A diagram would have 0
aided in understanding the text discussion.
b.
Text contained undefined acronyms 0
and/or plant specific designators.
c.
The text contains other specific 5
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.
t
TABLE C-2.
ABSTRACT OEFICIENCIES AND OBSERVATIONS FOR 0 C. COOK 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b i
A summary of occurrences (immediate cause 2(24) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 7 (17) responses was not included or was inadequate.
a.
Summary of plant responses was not 3
included or was inadequate.
b.
Summary of system responses was not 0
included or was inadequate.
c.
Summary of personnel responses was not 4
included or was inadequate.
A sunnary of the root cause of the event 12 (24) was not included or was inadequate.
A summary of the corrective actions taken or 7(24) planned as a result of the event was not in:1uded or was inadequate.
TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observ_ations_
Totals Totals (
)b a
Abstract presentation inadequacies 6 (24 )
a.
OBSERVATI0ft: The abstract contains I
information not included in the text.
The abstract is intended to be a sunrnary of the text, therefore, the text should discuss all information summarized in the abstract.
b.
The abstract was greater than 4
1400 characters c.
The abstract contains undefined 0
acronyms and/or plant specific designators.
d.
The abstract contains other specific 5
deficiencies (i.e., poor summarization, contradictions,etc.)
The "sub-paragraph total" is a tabulation of specific deficiencies or a.
observations within certain requirements. Since an LER can have mere than one deficiency for certain requirements, (e.g., an LER can be deficient in I
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 core deficiency or observation.
The number in parenthesis is the number of LERs for which a certain requirement was applicable.
L
l TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR D. C. COOK 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals yog,j 3 (,
)b a
Facility Name 0 (24) a.
Unit number was not included or inc.orrect.
b.
Namc was not included or was incorrect.
c.
Additional unit numbers were included but pot required.
Docket Number was not included or was 0 ( 24) iricorrect.
Page Number was not included or was 1 (24) incorrect.
11tle was inadequate 24(24) a.
Root cause was not given in title 24 b.
Result (effect)wasnotgivenintitle 3
c.
Link was nnt given in title 13 Event Date 0(21) a.
Date not included or was incorrect.
b.
Discovery date given instead of event date.
LER Number was not included or was ~ incorrect 0(24)
Report Date 3 (24 )
a.
Date not included I
b.
OB3ERVATION: Report date was not 2
within thirty days of event date (or discovery date if appropriate).
Other Facilities information in field is 3(24) inconsistent with text and/or abstract.
Operating Mode was not included or was 0 (24) inconsistent with text or abstract.
TAetE C-1, (ccatinued)
Number of LER$ with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observ3tions, Totais(__,
Totalt (
)D_
Power level was not included or was 0 (74) inconsistent with text or abstract Reporting Requirements 2 (24) a.
The reason for cnecking the "0THER" 0
requirement was not specified in the abstract and/or text.
b.
OBSERVATION:
It would have been more 1
appropriate to report the event under l
a different paragraph.
c.
OBSERVATION:
It would have been 1
appropriate to report this event under ddditional unchecked paragraphs.
d Licensee Contact 0 (24) a.
Field left blank b.
Posjtion title was not included c.
Name was not included d.
Phone number was not included.
Coded Component Failure Information 2 (24) a.
One or more component f ailure 0
i sub-fields were left blank.
b.
Cause, system, and/or component code 2
a is inconsistent with text.
c.
Component f ailure field contains data 0
when no component f ailure occurred.
d.
Component failure occurred but entire O
field left blank.
D P
.v-~
TABLE C-3.
(continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Desc iptio,n of, Deficiencies ar.d Observatior.s, Totals (
[b a
'fotals Supplemental Report 2 (24) a.
Neither "Yes"/"No" block of the 2
supplemental report field was checked.
b.
The block checked was inconsistent with the text.
Expected submission date informatior, is 0(24) inconsistent with the block checked in Item (14)..
r a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirenentc. Sii.ce an LER can have more than one deficiency for certain req 9irements, (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 totai" is the r. umber of LERs that have one or nore reautrement deficier.01es or observations.
The number in parenthesis is the
. number of LERs for which a certain requirenient was applicable.
t
TABLE C-4.
TEXT DEFICIENCIES AND OBSERVATIONS FOR 0. C. COOK 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)( A)--Plant operating 2 (18) conditions before the event were not included or were inadequate.
50.73(b)(2)(ii)(B)--Discussion of the status 0 (4) of structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not I
included or was inadequate.
50.73(b)(2)(ii)(C)--Failure to include 3 (18) sufficient date and/or time information.
a.
Date information was insufficient.
I b.
Time information was insufficient.
3 50.73(b)(2)(ii)(D)--The root cause and/or 7 (18) intermediate f ailure, system f ailure, or personnel error was not included or was inadequate.
a.
Cause of component failure was not 3
included or was inadequate b.
Cause of system failure was not 1
included or was inadequate c.
Cause of personnel error was not 3
included or was inadequate.
50.73(b)(2)(ii)(E)--The failure mode, I (5) mechanism (immediate cause), and/or effect (consequence) for each f ailed component was not included or was inadequate.
a.
Failure mode was not included or was 0
inadequate b.
Mechanism (immediate cause) was not 1
included or was inadequate c.
Effect (consequence) was not included 1
or was inadequate.
TABLE C-4.
(continued)
Number of LERs with
-Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(F)--The Energy Industry 13 (17)
Identification System component function identifier and/or system identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a f ailure of a 0 (0) 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 (6) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the f ailure until the train was returned to service was not included.
50.73(b)(2)(ii)(1)--The method of discovery 6 (18) of each component f ailure, system f ailure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each component 2
f ailure was not included or was inadequate.
b.
Method of discovery for each system 1
failure was not included or was inadequate, c.
Method of discovery for each personnel 3
error was not included or was inadequate.
d.
Method of discovery for each I
procedural error was not included or was inadequate 50.73(b)(2)(ii)(J)(1)--Operator actions that 4 (11) af fected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
TABLE C-4.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(J)(2)--The discussion of 6 (12) each personnel error was not included or was inadequate, a.
OBSERVATION: A personnel error was 4
implied by the text, but was not explicitly) stated.50.73(b)(2 (ii)(J)(2)(i)--Discussion 5
b.
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion 1
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 inadeq)uate.50.73(b)(2)(ii)(J)(2)(iii --Discussion 0
d.
of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
e.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion 2
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.
50.73(b)(2)(ii)(K)--Automatic and/or manual 3 (7) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 3 (3) model number of each f ailed component was not included or was inadequate.
L
TABl.E C-4.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(3)--An assessment of the safety 17 (18) consequences and iglications of the event was not included or was inadeq: tate.
a.
OBSERVATION: The availability of 2
of other systems or co.nponents capable of mitigating the consequences of the event was not discussed.
If no other systems or components were available the text should state that none existed.
b.
OBSERVATION: The consequences of the 1
event had it occurred under more severe conditions were not discussed.
If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 8 (18) 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.
a.
A discussion of actions required to O
correct the problem (e.g., return the component or system to operation or correct the personnel) was not included or was inadequate.
b.
A discussion of actions required to 2
reduce the probability or recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c.
OBSERVATION: A discussion of actions I
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturers and model number) 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 Totals (
)b a
50.73(b)(5)--Information concerning previous 10(18) similar events was not included or was inadequate.
50.73(b)(2)(i)--Text presentation 0(18) inadequacies.
a.
OBSERVATION: A diagram would have aided in understanding the text discussion.
b.
Text contained undefined acronyms and/or plant specific designators.
c.
The text contains other specific deficiencies relating to the readability.
The "sub-paragraph total" is a tabulation of specific deficiencies or a.
observations within certain requirements (i.e., paragraphs). 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 aeficiencies or observations. The number in parenthesis is the number of LERs for which a the requirement was considered applicable.
l TABLE C-5.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR D. C. COOK 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
A summary of occurrences (immediate cause 2(18) and effect) was not included or was inadequate.
A summary of plant, system, and/or personnel 5 (14) 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 2
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 was 11 (18) not included or was inadequate.
A sunnary of the corrective actions taken or 4 (18) planned as a result of the event was not included or was inadequate.
m
TABLE C-5.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
Abstract presentation inadequacies.
2 (18) a.
OBSERVATION: The abstract contains 1
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 contains undefined 0
acronyms and/or plant specific designators.
c.
The abstract contains other specific 2
deficiencies (ie., poor summarization, contradictions etc.)
The "sub paragraph total" is a tabulation of specific deficiencies or a.
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 subtotals do not necessarily add up to the 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.
,m--
, ~.
TABLE C-6.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR D. C. COOK 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
Facility Name 0(18) 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(18) incorrect.
Page Number was not included or was 0 (18) 4 incorrect.
Title was inadequate 17 (18) a.
Root cause was not given in title 17 b.
Result (effect) was not given in title 1
c.
Link was not given in title 9
Event Date 0(18) a.
Date not included or was incorrect.
b.
Discovery date given instead of event date.
LER Number was not included or was incorrect 0(18)
Report Date 0 (18) 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 (18) inconsistent with text and/or abstract.
Operating Mode was not included or was 1 (18) inconsistent with text or abstract.
TABLE C-6.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
Power level was not included or was 1 (18) inconsistent with text or abstract Reporting Requirements 0 (lB) a.
The reason for checking the "0THER" requirerent was not specified in the abstract and/or text.
b.
OBSERVATION:
It would have been more appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It would have been appropriate to report this event under additional unchecked paragraphs.
Licensee Contact 1 (18) a.
Field left blank 0
b.
Position title was not included 1
c.
Name was not included 0
d.
Phone number was not included.
O Coded Component Failure Information 4 (18) a.
One or more component f ailure 1
sub-fields were lef t blank.
b.
Cause, system, and/or component code 0
is inconsistent with text.
c.
Component f ailure field contains data 1
when no component failure occurred.
d.
Component failure occurred but entire 2
field left blank.
TABLE C-6.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
Supplemental Report 0 (18) a.
Neither "Yes"/"No" block of the supplemental report field was checked.
b.
The block checked was inconsistent with the text.
Expected submission date information is 0 (18) 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.
i
i i
APPENDIX 0 LER COMMENT SHEETS FOR D. C. COOK 1 AND 2 e
e l
12
TABLE D-1..
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 1.
LER Number: 84-004-00 Scores: Text = 6.6 Abstract = 9.8 Coded Fields = 8.8 Overall = 7.8 Text 1.
Submittal of an LER without a text is acceptchle; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
3.
50.73(b)(2)(ii)(C)--Dates and approximate times information for occurrences were 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 is not included.
5.
50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the f ailure of a safety system train until the train was returned to service is not included.
6.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
7.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
8.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
No comments.
Coded Fielas 1.
Item (3)--Page number is in. correct. Do not count the cover letter.
2.
Item (4)--Title: Root cause is not included.
,n._.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK-1 (315)
Section Comments l.
LER Number: 84-004-00 (continued) 4 3.
Item (8)--Although nothing was found wrong in Unit 2, it was involved because it was inspected as a result of this report.
4.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(v).
J A
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 2.
LER Number: 84-008-00 Scores:
Text = 6.9 Abstract = 8.8 Coded Fields = 8.4 Overall = 7.6 Text 1.
50.73(b)(2)(ii)(C)--Approximate times information for occurrences is inadequate, i.e., follow-up testing.
2.
50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate, i.e., operator actions in response to the reactor trip and safety injection.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
A logical transition does not exist between all ideas. Some ideas are not presented clearly (hard to follow).
Abstract 1.
50.73(b)(1)--Summary of personnel responses is not included.
Coded Fields 1.
Item (4)--Title: Link and root cause are not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 3.
LER Number: 84-011-00 Scores: Text = 7.4 Abstract = 10.0 Coded Fields = 8.3 Overall = 8.3 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is. inadequate.
The text should tell the reader up front that a test was in progress.
2.
50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(H)--The estimate of the elapsed time f rom the discovery of the f ailure of a safety system train until the train was returned to service is not included.
5.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the system failure (personnel error) is not included.
6.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is inadeqirate.
7.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Would the operator have known to start the other fan?
8.
50.73(b)(5)--Information concerning previous similar events is not included.
9.
50.73(b):51--Ifnoprevioussimilareventsareknown, the text snould so state.
- 10. A logi' cal transition does not exist between all ideas. Some ideas are not presented clearly (hard to follow).
1 TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 3.
LER Number: 84-011-00 (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.
The abstract is well written and straight forward.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included.
4 I
e 4
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 4.
LER Number: 84-014-00 Scores:
Text = 6.8 Abstract = 9.0 Coded Fields = 7.9 Overall = 7.6 Text 1.
50.73(b)(2)(ii)(B)--Discussion of the status of structures, conponents, or systems that were inoperable at the start of the event and that contributed to the event is 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 is not included.
3.
50.73(b)(2)(ii)(G)--A list of systems or secondary functions that were also affected by the failed multi-function component is not included.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
OBSERVATION: Additional corrective actions based on the generic implications of the f ailure or error should have been included.
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.
2.
50.73(b)(1)--Summary of root cause is inadequate.
3.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
Coded Fields 1.
Item (4)--Title: Root cause is not includea.
2.
Item (4)--Title: Link is not included.
3.
Item (13)--One or more component f ailure sub-fields are blank.
4.
Item (14)--Neither "Yes"/"No" block of the supplemental report field is checked.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 5.
LER Number: 84-015-00 Scores: Text = 6.6 Abstract = 9.0 Coded Fields = 9.3 Overall = 7.6 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. -The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(A)--Include a brief description of the operating mode number.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.
5.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error is not included.
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Be specific as to why there were no safety implications.
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 are available the text should so state.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
1 TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 5.
LER Number: 84-015-00 (continued)
Abstract 1.
No comments.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 6.
LER Number: 84-016-00 Scores:
Text = 4.5 Abstract = 7.0 Coded Fields = 7.6 Overall = 5.6 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
The following comments apply to the abstract judged as the text.
2.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadequate.
3.
50.73(b)(2)(ii)(C)--Date and approximate time information for occurrences is not included.
4.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is not included.
5.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
6.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error / procedural error is not included.
7.
50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.
8.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
9.
50.73(b)(5)--Information concerning previous similar events is not included.
10.
50.73(b)(5)--If no previous similar events are known, l
the text should so state.
(~
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 6.
LER Number: 84-016-00 (continued)
- 11. Some idecs are not presented clearly (hard to follow). Additional space is available within the abstract field te provide the necessary information but it was not utilized. A logical transition does not exist between all ideas.
Abstract 1.
Some ideas are not presented clearly. A logical transition does not exist between all ideas, att-Coded Fields 1.
Item (4)--Title.- Root cause and linkjnere not included. The ef ffet/ result was inadequate.
I
-_..~ _ -._,---
e TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 7.
LER Number:
84-017-00 Scores: Text - 7.8 Abstract = 10.0 Coded Fields - 7.8 Overall = 8.5 Text 1.
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 is not included.
2.
50.73(b)(2)(11)(J)(2)(1)--01scussion as to whether the personnel error was cognitive or procedural is not included.
3.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
OBSERVATION: As part of the corrective actions all operators that can ever be responsible for operating the feedwater system should have been made aware of the details of the event.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
5.
50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included. At a minimum, the system that actuated should have been named.
t
-.___,__y
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 8.
LER Number: 84-022-00 Scores: Text = 7.3 Abstract
- 9.1 Coded Fields = 9.3 Overall = 8.0 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is not included.
2.
50.73(b)(2)(ii)(H) -The estimate of the elapsed time from the discovery of the f ailure of a safety system trein until the train was returned to service is not included.
3.
50.73(b)(2)iii)(J)(21 0BSERVATION: Personnel error
.is implied but is not explicitly stated in the text.
4.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is not included.
5.
50.73(b)(2)(ii?(J)(2)(iv)--Discussion of the type of personnel invol ved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Address gaseous releases from the time the program was first used to the present.
7.
50.73(b)(5)--If no previous similar events are knovn, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadegaate.
2.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event it inadequatc.
The abstract contain greater than 1400 characters.
Coaed Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (41--Title: Link is nut included.
3.
Item __[1,21--Position title is not incloced.
4.
Item (13).--One or more component f ailure sub-fields are blanks F
d 1
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Coments 4
9.
LER Number: 84-023-00 Scores: Text = 5.5 Abstract = 6.3 Coded Fields ' 8.3 Overall = 8.0 Text 1.
50.73(b)(2)(ii)(A)--Although the power level indicates steady-state power, it would be desirable to give a brief description of the operating made number.
2.
_50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system failure is inddequate.
Include specific reasons why the blowdown could not be restored.
3.
50.73(b)(2)(ii)(E)--A component failure seems to be implied by the text, but is not discussed.
4.
50.73(b)(2)(ii)(Q--IneEnergyIndustry identification Systera component function identifier (s) and/or system name of ecch component or system referred to in the LER is not included.-
5.
50.73(b)(?1(ii)(H)--Theestimateoftheelapsedtime f rom the discovery of the failure of a safety systein train until the train was returned to service is not included.
6.
50.73Jo)(2)(ii)(J)(1)--The discussion of the drawing of the saaple aces make it clear whether or not the small sample drawn was a personnel error nr contrary to procedure.
7.
50.73(b)(3)--0BSERVAT!0N:
The consequences of the event had it occurred under neore severe conditions should be discussed.
If the event occurred under 4
what are considered the most severe conditions, the text should so state.
.h 8.
50.73(b)(4)--Discussion of corrective actions taken
=>r planned is inadegaate.
If a component failure causeo the loss of the steam generator blodown system this should be discusseo. A question tnat comes to mino, is how future employees will be made aware of this event? In order to prevent recurrence should the co,1 tents of the letter be inenrporated into the procedure or made a permanent part of the training program?
- 'e R,
n a
$.a
' TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 9.
LER Number:
84-023-00 (continued) 9.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
2.
5_0.73(b)(1)--Summary of plant responses is inadequate.
Coded Fields 1.
Item _(4)--Title: Root cause is not included.
2.
Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).
3.
Item (8)--Field should be filled it) with Not Applicable or NA.
P P
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.- ~,
,m
.-_.o--
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 10. LER Number: 84-024-00
$ cores: Text
- 8.0 Abstract = 8.5 Coded Fields = 7.9 Overall = 8.1 Text 1.
50.73(b)(2)(ii)(C)--Approximate time information for occurrences is not included.
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
5.~
50.73(b)(5)--If no previous similar events are known, the text should so state.
2.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
Abstract 1.
50.73(b)(1)--Summary of personnel responses is not included.
2.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Iteo (8)--Information in field is inconsistent with text and/or abstract.
f I
2.
Item (14)--Neither "Yes"/"No" block of the l
supplemental report field is checked.
l 3.
Iten (4)--Title: Root cause is not included (i.e.,
l root cause was unknown therefore the title should say l
something to the effect of "for reasons unknown").
l
\\
l I
I.
i i
I l
I I
I I
i i
- ~
4 TABLE D-1.
SPECIFIL LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 11. LER humber: 84-025-00 Scores: Text = 7.2 Abstract = 9.4 Coded fielas = 8.4 Overall = 8.0 Text 1.
50.73(b)(2)(ii)(0)--Therootand/orintermediate cause discussion for each personnel error is not i
included. Why were both flow and physical piping drawings incorrect? Why were the valves accidentally buried?
2.
50.73(b)(2)(ii)(1)--Discussion of the method of discovery of the procedural error (personnel error) is not included. What prompted the excavation on 10-10-847 3.
50.73(b)(2)(ii)(J)(2)--08SERVATION: Personnel error is implied but is not explicitly stated in the text-4.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is 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) is not included.
l 6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
How was Unit 2 actually involved?
7.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
OBSERVATION: Additional corrective actions based on the generic implications of the f ailure or error should have been included, 8.
50.73(b)(5)--Information concerning previous similar events is not included.
i 9.
50.73(b)(5)--If no previous similar events are known, the text should so state.
e t
. - -,,... -., ~...,,__ _. _ _,. __ -. _ _._, _.
TABLE 0-1 SPEcirlC LER COMMtNTS FOR 0.C. E00K 1 (315)
Section Comments
- 11. LER Number: 84-075-00 (continued)
- 10. A logical transition does not exist between all ideas.
Some ideas are not presented clearly (hard to follow).
The diagram was good but should have been more detailed.
It is not clear what the effect of FP-lil being closed was as the diagram does not indicate anything about the line coming into the valve from the top of the page.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
Coded Fields 1.
It eir. ( 41-,Ti t le: Root cause and link are not included.
2.
Item (81--Information ir, field is inconsistent with Text and/or abstract.
l
~
f e
i i
l
,I
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 12. LER Number: 84-030-00 Scores: Text = 3.6 Abstract = 9.4 Coded Fields = 8.3 Overall = $.8 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(0)--The root ana/or intermediate cause discussion for each system failure is not included.
3.
50.73(b)(2)(ii)(E)--The mechanism (immediate cause) discussion of each failed component is r.ot 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 is not included.
4 5.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and modal no.) of the f ailed coinponent(s) discussed in the text is not included.
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
7.
50.'/3(b)(4)--Discussion of corrective actions taken or' planned is inadequate.
OBSERVATION: Additional corrective actions based on the generic implications of the f ailure or error should have been included.
Abstract 1.
The abstract contain greater than 1400 characters.
Coded Fields 1.
Itein ( 4)--Title: Root cause is not included.
2.
Item (4)--Title: Link is not 1'ncluded.
3.
Itsm (12)--Fosition title is not included.
4.
Item (13)--One or more ccmponent failure suh-fields are blank.
-4.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 13. LER Number: 84-031-00 Scores: Text = 4.1 Abstract = 7.3 Coded Fields = 8.7 Overall = 5.5 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters.
The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(C)--When did the senior operator re-initialize the computer?
3.
50.73(b)(2)(ii)(D)--If re-initializing the computer is the root cause, then the discussion does not make it clear how the 12 minute computer f ailure caused a 13.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> delay in monitoring the alarm.
4.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
5.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cogi:itive or procedural is not included.
6.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is not inclLded.
7.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
8.
50.73(b)(5)--Information concerning previous similar events is not included. Scme ideas are not presented clearly (hard to follow).
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 13. LER Number: 84-031-00 (continued)
Coded Fields 1.
Item (4)--Title: Root cause and link were not included.
2.
Item (8)--The field should be filled in with Not Applicable or NA.
9 4
4 1
A 4
TABLE D-1.
SPECIFIC LER COMMENTS FOR 0.C. COOK 1 (315)
Section Comments
- 14. LER Number: 84-032-00 Scores: Text = 5.4 Abstract = 9.0 Coded Fields = 8.9 Overall = 6.8 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
The f ollowing connents apply to the abstract judged as the text.
2.
50.73(b)(2)(ii)(F)--The Energy Inaustry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(1)--Discussion of the method of discovery of the personnel error / procedural error.is inadequate.
4.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is not included. What were the immediate corrective actions for each event?
5.
50.73(b)(2)(li)(J)(2)--0BSERVATION:
Personnel error is implied but is not explicitly stated in the text.
6.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
7.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is inadequate.
8.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether
.the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is inadequate.
9.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicea d operator, other utility personnel) is inade wate.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 14.
LER Numoer: 84-032-00 (continued)
- 10. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is 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 are available the text should so state.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
- 11. The abstract does not sufficiently meet the requirements of a text. Recommend that this LER be written to include a text since not all of the required information will fit into the abstract field and not exceed the 1400 character limit.
Abstract 1.
50.73(b)(1)--Summary of personnel responses is not included, i.e., responses for each technical specification violation.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 15.
LER Number: 85-002-00 Scores: Text = 7.1 Abstract = 7.5 Coded Fields = 7.9 Overall = 7.3 Text 1.
50.73(b)(2)(ii)(C)--Date information for occurrences is inadequate. When were Amendments 69 and 51 issued?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error is not included.
4.
50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.
5.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
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) is not included.
Who was responsible for identifying the new technical specification requirement?
7.
50.73(b)(3)--Discussion ef the assessment of the safety consequences and implications of the event is inadequate.
It appears that by the time the samples were taken the iodine levels had dropped to normal, but what could they have been earlier?
8.
50.73(b)(5)--Information concerning previous similar events is not included.
9.
50.73(b)('l--If no previous similer events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
i 2.
Abstract does not adequately summarize the text. No mention is provided as to how Unit 2 is involved.
t l
~,.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 15.
LER Number: 85-002-00(continued)
Coded Fields 1.
Item (4)--Title: Root cause and result is not included.
2.
Item (7)--Report day is not included.
a 4
i i
1 A
j
TABLE 0-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 16. LER Number: 85-003-00 Scores: Text = 6.3 Abstract = 9.0 Coded Fields = 8.6 Overall = 7.3 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system f ailure is inadequate.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component f ailure is not included.
3.
50.73(b)(2)(ii)(E)--The f ailure mode discussion of each f ailed component is not included.
4.
50.73(b)(2)(ii)(E)--The mechanism (immediate cause) discussion of each f ailed component is r.at included.
5.
50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
6.
50.73(b)(2)(ii)(G)--A list of systems or secondary functions that were also affected by the failed multi-function component is not included.
7.
50.73(b)(2)(ii)(J)(2)--0BSERVATION: f ersonnel error is implied but is not explicitly stated in the text.
8.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
9.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the f ailed component (s) discussed in the text is not included.
- 10. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
11.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
TABLE D-l.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 16.
LER Number: 85-003-00 (continued)
OBSERVATION: Additional corrective actions based on.
the generic implications of the f ailure or error should have been included.
- 12. 50.73(b)(5)--Information concerning previous similar events is not included.
Abstract
- 1.. 50.73(b)(1)--Summary of root cause is not included.
2.
The abstract contain greater than 1400 characters.
Abstract does not adequately summarize the text.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--litle: Link is not included.
3.
Item (13)--Cause, system, and/or component code is inconsistent with text.
Personnel error of the SRQ is a f actor in this LER and not acknowledged.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 17. LER Number: 85-006-00 Scores: Text = 8.6 Abstract = 6.9 Coded Fields = 9.3 Overall = 8.2 l
Text 1.
50.73(b)(2)(ii)(A)--Include a brief description of operating mode numbers.
3.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
2.
50.73(b)(2)(ii)(D)--More details should be included on the ventilation system malfunction.
4.
50.73(b)(4)--As noted in Comnent 2 above, a ventilation system malfunction caused the problem.
The corrective actions should address how future malfunctions will be handled to prevent future actuations of the damper.
If this is not considered a problem, at least, state this, so that the reader knows that the problem was addressed.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract fails to summarize the ventilation system malfunction.
1 2.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that af fected the course of the event is inadequate.
Corrective actions such as posting a fire watch and repairing and resetting the damper were not included.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
t
TABLE 0-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 18. LER Number: 85-013-00 Scores: Text = 8.2 Abstract = 10.0 Coded Fields = 8.9 Overall = 8.8 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error is not included.
3.
50.73(b)(3)--Discussion of the assessment of the saf ety consequen.es and implications of the event is inadequate.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
5.
50.73(b)(5)--If no previous similar events are known, the text should so state. Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Abstract 1.
No comments.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR 0.C. COOK 1 (315)
Section Comments
- 19. LER Number: 85-016-00 Scores: Text - 7.0 Abstract = 8.5 Coded fields 7.8 Overall = 7.5 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is not included.
2.
50.73(b)(2)(11)(J)(2)--Discussion of personnel error is not included.
3.
50.73(b)(2)(11)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is not included.
4.
50.73(b)(3)--01scussion of the assessment of the safety consequences and implications of the event is inadequate. How would the operator have known to immediately close the valves if the potential accident was not recognized?
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
OBSERVATION:
Additional corrective actions based on the generic implications of the failure or error should have been included.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
7.
50.73(b)(5) -If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR 0.C. COOK 1 (315)
Section Comments
- 20. LER Number: 85-019-00 Scores: Text = 2.8 Abstract = 3.4 Coded Fields = 5.8 Overall = 3.3 Text 1.
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 is not included.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure is not included.
3.
50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion for each system failure is not included.
4.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each personnel error is not included.
5.
50.73(b)(2)(ii)(E)--The mechanism (immediate cause) discussion of each failed component is not included.
6.
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.
7.
50.73(b)(2)(ii)(H)--The estimate of the elapsed time from the discovery of the f ailure of a safety system train until the train was returned to service is not included.
8.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the component f ailure is not included.
9.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the system f ailure is not incluaed.
10.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error is not included,
- 11. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Section Comments 20.
LER Number: 85-019-00 (continued)
- 12. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
OBSERVATION:
The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
Abstract 1.
50.73(b)(1)--Sumery of occurrences [imediate cause(s) and effects (s)] is inadequate.
2.
50.73(b)(1)--Summary of root cause is not included.
3.
50.73(b)(2)(ii)(il)(1)--Discussion of operator actions that affected the course of the event is inadequate.
The abstract contain greater than 1400 characters.
4.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text.and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--Title: Result (effect) is not included.
3.
Item (4)--Title: Link is not included.
4.
Item (ll)--0BSERVATION:
It appears it would have been more appropriate to report this event under paragraph (s) 50.73(a)(2)(v).
5.
Item (13)--Cause, system, and/or component code is inconsistent with text.
6.
Item (8)--Information in field is inconsistent with text and/or abstract.
i I
i f
SPECIFIC LER COMMENTS FOR 0.C. COOK 1 (315)
TABLE D-1.
Comments Section
- 21. LER Number: 85-020-00 Scores: Text = 7.9 Abstract = 8.6 Coded Fields = 9.2 Overall = 8.2 Submittal of an LER without a text is acceptable; Text 1.
however, the abstract must then meet all the requirements of a text and still be less than 1400 The following comments apply to the characters.
abstract which was evaluated as if it were a text.
50.73(b)(2)(ii)(I)--Discussion of the method of 2.
discovery of the personnel error and system f ailure were not included.
50.73(b)(3)--0BSERVAT10N: The availability of other 3.
systems or components capable of mitigating the If no consequences of the event should be discussed.
other systems or components are available the text should so state.
The consequences of the event had it OBSERVATION:
occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
50.73(b)(4)--Text should include a discussion of long 4.
term corrective action to prevent recurrence (e.g.,
additional emphasis in training program).
Abstract 1.
No comments.
Coded Fielos 1.
Item (4)--Title: Root cause is not included.
Item (8)_--The field should be filled in with Not 2.
Applicable or NA.
$l
~_-
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
TABLE D-1.
Comments Section
- 22. LER Number: 85-021-00 Scores: Text = 3.8 Abstract = 6.5 Coded Fields = 8.9 Overall = 5.1 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters.
The following comments apply to the abstract which was evaluated as if it were a text.
50.73(b)(2)(ii)(C) -Approximate time information for 2.
occurrences is inadequate, i.e., what time was the dilution discovered by the NRC resident inspector.
50.73(b)(2)(ii)(D)--The root and/or intermediate 3.
cause discussion f or each personnel error is 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 is net included.
50.73(b)(2)(ii)(1)--Discussion of the method of 5.
discovery of the personnel error is not includeo.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions 6.
that af f ected the course of the event is not included. What immediate actions were taken after the discovery of the dilutions?
7.
50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error is implied but is not explicitly stated in the text.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error 8.
is inadequate.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether 9.
the personnel error was cognitive or procedural is not included.
50.73(b}(3)--Discussion of the assessment of the 10.
safety consequences and implications of the event is inadequate.
(
SPECIFIC LER COMMENTS FOR 0.C. COOK 1 (315)
TABLE D-1.
Comments Section
- 22. LER Number: 85-021-00 (continued)
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be If the event occurred under what are discussed.
considered the most severe conditions, the text should so state.
50.73(b)(4)--Discussion of corrective actions taken 11.
or planned is inadequate.
A discussion of actions required to correct the 12.
problem (e.g., return the component or system to an operational state or correct the personnel error) is not included or is inadequate.
50.73(b)(5)--Information concerning previous similar 13.
events is not included.
50.73(b)(5)--If no previous similar events are known, 14.
_the text should so state.
50.73(b)(1)--Summary of occurrences [immediate Abstract 1.
cause(s) and effects (s)] is inadequate, i.e., the actual effect of the dilution was not included.
50.73(b)(1)--Summary of root cause is inadequate.
2.
50.73(b)(1)--Summary of plant response is not 3.
The resultant dilution in the reactor included.
coolant system was not included.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions 4.
that affected the course of the event is inadequate.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
4 1
4
~ ~ ~ ' *
,--.n...
TABLE D-1.
SPECIFIC LER COMMENTS FOR D.C. COOK 1 (315)
Comments Section
- 23. LER Number: 85-022-00 Scores: Text = 8.0 Abstract = 8.5 Coded Fields = 7.8 Overall = 8.1 Text 1.
50.73(b)(2)(ii)(D)--Not enough discussion was provided to allow the reader not familiar with the system to understand precisely how the setting of the fixed background subtract count rate affects the high level alarm point.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether 2.
the personnel error was cognitive or procedural is inadequate.
50.73(b)(2)(ii)(J)(2)(ii) -Discussion as to whether 3.
the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is not included.
Even though the radiation monitor didn't fail, 4.
information involving manuf acturer and model number would be helpful to others that may have the same equipment but are unaware that they should set the background valve more frequently in certain situations.
Information concerning how the corrective action is 5.
to be implemented (e.g., procedure change) should be provided.
Was Unit 1 informed of the 4-11-85 event at Unit 2 6.
(84-007-00) at the time of that event?
Submittal of an LER without a text is acceptable; 7.
however, the abstract must then meet all the requirements of a text and still be less than 1400 The following comments apply to the characters.
abstract which was evaluated as if it were a text.
Abstract 1.
50.73(b)(1)_--Summary of root cause is inadequate.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions 2.
that af f ected the course of the event is inadequate.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included.
TABLE D-1.
SPECIFIC tER COMMENTS FOR D.C. COOK 1 (315)
Section Comments
- 24. LER humber: 84-025-00 Scores:
Text = 6.4 Abstract = 7.0 Coded Fields = 8.4 Overall = 6.8 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component f ailure is not included.
3.
50.73(b)(2)(ii)(E)--The immediate cause discussion of each failed component is not included.
4.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Corrective actions for the valve were not addressed.
5.
A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate. This statement applies to both the pcrsonnel (lack of) and valve problem.
i 6.
50.73(b)(5)--Information concerning previous similar events is not included.
7.
50.73(b)(5)--If no previous similar events are known, the text should so state.
8.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
Abstract 1.
50.73(b)(1)--Summary of personnel responses is inadequate.
2.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
3.
50.73(b)(1)--Summary of root cause is inadequate.
y
-.enn
SPECIFIC LER COMMENTS FOR D.C. CC0K 1 (315)
TABLE D-1.
Coments Section
- 24. LER Number: 84-025-00 (continued)
Coded Fields 1.
Item (4)--Title: Root cause is not included.
Item (7)--0BSERVATION: Report date is not within 2.
thirty days of event date (or discNery date if appropriate).
i i
TABLE 0-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments 1.
LER Number: 84-011-00 Scores: Text - 5.7 Abstract = 7.0 Coded Fields - 8.4 Overall - 6.4 Text 1.
50.73(b)(2)(11)(A)--Include a brief description of the operating mode number.
2.
50.73(b)(2)(11)(D)--The software problem seems to be addressed adequately, but there appears to be a personnel error (failure to retain clock back to real time) which was not discussed.
3.
50.73(b)(2)(11)(I)--The method of discovery was not included.
4.
50.73(b)92)(11)(J)(2)--As mentioned in Comment 2 above, a personnel error appears to have been committed but was not discussed.
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
50.73(b)(f)--The change to the procedures is appropriate, but furtehr indicates a need for a better discussion of a personnel error as indicated in comments 2 and 4.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
50.73(b)(1)--Repeating the reporting requirement in the abstract is a waste of limited space, especially in this case, since the information is not in the text. The abstract is intended to be a summary of the text and, therefore, should contain no new data not in the text.
2.
50.73(b)(1)--The corrective actions summary addresses the personnel error, but falls to summarize the software corrective actions.
On the other hand the root cause summary addresses the software problem but not the personnel error.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
- - - > - - + - - - - - - - -. -
m e.
v TABLE 0-2.
SPECIFIC LCR COMMENTS FOR D.C. COOK 2 (316)
Section Comments 1.
LER Number: 84-011-G0 (continued) 2.-
Item (8)--The field should be filled in with Not Applicable or NA.
3.
Item (13)--Component f ailure field contains data when no component f ailure occurred. The monitor was f aulted, but did not f ail, so this field need not have been filled in.
I l
1
e TABLE D-2.
SPEClflC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments 2.
LER Nacher: 84-012-00 Scores: Text = 7.3 Abstract = 7.0 Coded fields a 8.9 Overall = 7.4 50,73(bl(,)( ti)(A)--Discussion of lilant operating 2
Text 1
conditions before the event is inadequate (i.e., note description needed).
2.
,50.73(b)(2}[ii)(F)--TheEnergyIndustry Identif ication System compor.ent function identifier (s) and/or systen, nane of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affecteithe course of the event is inadequate.
What was operator response af ter safety injection initiation?
4.
50.73(b)(3)--Discussion of the assessment of the saf ety consequences and implications of the event is not included.
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate, i.e., inmediate corrective actions after safety injection initiation.
Abstract 1.
50.73(b)(1)--Summary of personnel responses is not incluoed.
2.
h0.73{b)(ll--Summaryofrootcauseisnotincluded.
, tem (4)--Title: Root cause is not incJuded.
Coded fields 1.
[
TABLE C 2.
SPECIFIC LER (:0MMEsTS FOR G.C. COOK ? (316)
Section
_ Conwnents 3.
Leis huinber: 84-015-00 Scores:
fed a 7.1 Abstract e 8.5 Coced fields a 94 Overall = 7.8 Text 1.
10.73(b)(2)(ii)(01--The root and/or intermediate cguse discussion for each personnel error is inadequate. A discussion of the "inddequate f<01%up" would nake tne root cause mora understandable.
00.73(b)(?)(i_H FJ--The Energy Industry Toectification s(ystem component function 2.
identifier (s) and/or system name of each component or system eeferred to in the LER is not included.
3.
50.731b)(2)(ii)(I)--Discussior) of tt.e r:ethod of
' discovery of the personnel error is not included.
4.
50.73(bl(2)(ii)(J,)M-Discussion of operator actions that affected the course of the event is inadequate.
5.
50.73(b)(2)(ii)JJ)(2)--Discussion of personnel error is inadeqate.
6.
50.73(b)(2)(ii.)(.J)(2)M--Discussion is to whether the personne) error was cognitive or proceJural is not included.
7.
50.73(b)(3)--Discussion of the assessaient of the saf ety ccnsequences and implications of t.he event is inadequate. What if the error had not been caught as quick as it was? Without thewing the metho!! pf discovery the reader doesn't have a feel for how long the error may have gone undetectad.
8.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following concents apply to the abstract which was evaluated as if it were a text.
Abstract 1.
50.73(b)(_l)_--Summary of root cause is inadequate.
2.
50.73(b)(1)--Suranary of personnel responses is inadequate.
Coded fields 1.
Item (4)--Title: Root cause is not included.
TABLE D-2.
SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Comments 4.
LER Number: 84-016-00 Scores: Text = 6.0 Abstract = 6.0 Coded Fields = 6.3 Overall = 6.0 Text 1.
50.73(b)(2)(ii)(E)--The mechanicm (immediate cause) discussion of each failed component is not included.
2.
50.73(b)(2)(ii)(E)--The effect (consequence) discussion of each failed component is not included.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(G)--A list of systems or secondary functions that were also affected by the failed multi-function component is not included.
5.
- 50. 73 ( b ) ( 2 ) ( i i ) ( J ) ( 2 ) --0BSERVAT I 0ti : Personnel error is implied but is not eyplicitly stated in the text.
6.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
7.
50.73(b)(2)(ii)(L)--identification (e.g. manuf acturer and model no.) of the failed component (s) discussed in the text is not included.
8.
50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is 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 are available the text should so state.
9.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
TABLE D-2.
SPECiflC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Comments 4.
LER Number: 84-016-00 (continued)
OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should have been included.
Abstract 1.
50.73(b)(1)--Sumnary of occurrences [immediate Cause(s).and effects (s)] is inadequate.
2.
50.73(b)(1)--Summary of root cause is not included.
3.
Abstract does not adequately summarize tt:e text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--fitle: Link is not included.
3.
Item (9)--Mode is not included.
4.
Jtem (10)--Power level is incorrect.
5.
Item (13)--Component f ailure occurred but entire field is blank.
T ABLE D-2.
SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Conenents S.
LER Number: 84-017-00 Scores: Text = 5.4 Abstract = 8.6 Coded Fields = 8.7 Overall = 6.7 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then rneet all the requirements of a text and still be less than 1400 characters. The following conenents apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(C)--Additional dates and times are needed (e.g., when were the surveillances started again and when were the procedures changed?).
3.
50.73(b)(2)(ii){r)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(J)--Be more specific as to how the error was discovered.
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) is not included.
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
7.
50.73(b)(4)--The text should indicate whether or not the surveillance was begun upon discovery of the error.
8.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
No coments.
Coded Fields 1.
Item (4) -Title: Root cause is not included.
2.
Item (8)--The field should be filled in with Not Applicable or NA.
I
TABLE 0-2 SPECIFIC LER COMMENTS f0R D.C. COOK 2 (316)
Section Comments 6.
LER Number: 84-018-00 Scores: Text = 6.8 Abstract = 7.5 Coded Fields - 8.4 Overall 7.2 Text 1.
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 is not included.
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
3.
50.73(b)(5)--Information concerning previous similar events is not included.
4.
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 is not included.
Coded Fields
.l.
Item (4)--Title: Root cause and link are not included.
l l
l l
TABLE D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments 7.
LER Number: 84-019-00 Scores: Text = 7.1 Abstract = 10.0 Coded fields 8.3 Overall = 8.1 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the
. requirements of a text and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(11)(F 1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(11)(I)--Discussion of the method of discovery of the personnel error is not included.
4.
50.73(b)(2)(11)(J)(2)(tv)--01scussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
7.
50.73(b)(5)--If no previous similar events are known, the text should 50 state.
8.
Was the " pump problem" in the first paragraph reportable?
If so, a reference to the LER number would be appropriate.
4 Abstract 1.
No comments.
Coded Fields 1.
l_ tem (4)--Title:
Root cause and result (T.S.
violation) are not included.
(k2
Y TABLE-D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316).
Section Comments 8.
LER Number: 84-021-00 I
Scores: Text = 6.4 Abstract = 9.6 Coded Fields = 7.9 Overall = 7.5 i
Text 1.
50.73(b)(2)(ii)(C)--Approximate time information for occurrences is inadequate.
2.
50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion for each personnel error is inadequate.
3.
50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(J)(2)--0BSERVAT10N:
Personnel error is implied but is not explicitly stated in the text.
1 5.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is not included.
t 6.
50.73(b)(3)--Discussion of the assessment of the r
safety consequences and implications of the event is inadequate.g 4
7.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
OBSERVATION: Corrective actions planned (Taken?)
assume the Unit 1 Tech. Spec. to be correcti.This assumption may be erroneous-but*-one of the Tech.
Spec's. is in error.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
f Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--Title: Link is not included.
3.
Item (12)--Position title is not included.
4 i
1 w
m, n.-
- - -,.-, ~ -,,,,
.w.
.-a
,-,----..-,.,-,-----n-m,
,,n.
. =
i TABLE D-2.
SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Comments 9.
LER Numner: 84-027-00 Scores: Text = 7.6 Abstract = 8.9 Coded Fields = 9.2 Overall = 8.2 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 is not included.
2.
50.73(b)(2)(ii)(J)(2)(i)--The text does not make it clear whether or not the fire watch personnel were cognitive of the required procedure.
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The text should indicate the safety consequences of having to manually actuate the system, and should indicate whether or not other.
systems were available to suppress a fire.
i 4.
50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
How will the new or future contractors be informed of this requirement?
Abstract 1.
50.73(b)(1)--The corrective actions summary is i
deficient for the same reasons, that the text corrective actions are deficient.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (8)--The field should be filled in with Not Applicable or NA.
l t
1 4
.--r-
. _. ~ - -
f.
i.
SPECIFIC LER COMMENTS FOR D.C._ COOK 2 (316)
J TABLE D-2.
s Comments Section
- 10. LER humber: 84-028-00 Scores: Text = 5.0 Abstract = 7.5 Coded Fields = 8.9 Overall = 6.1 i
^
Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion f or each personnel error is not I
included (i.e., input assumptions error).
50.73(b)(2)(ii)(J)(2)--0BSERVATION: Personnel error 2.
is implied but is not explicitly stated in the text.
4 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error 3.
is not included.
50.73(b)(2)--Discussion of the assessment of the i
4.
safety consequences and implications of the event is not included.
i 50.73(b)(5)--Information concerning previous similar 5.
events is not included.
6.
50.73(b)(5)--If no previous similar events are known, the text should so state. All LER's are required to stand alone.
Information in referenced documents should be accompanied with a brief description of what that document contains as applicable to the LER.
2 Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
?
Coded Fields 1.
Item (4)--Title: Root cause is r.ot included.
}
i j
i l
i l
i 4
k i
_ _.. _, ~.. - _, _ _ _,,.. _. _ _.. -, _ _ -.. _.. _. _, _.,
TABLE 0-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments 11.
LER Number: 84-030-00 Scores:
Text = 7.0 Abstract - 9.0 Coded Fields - 7.8 Overall - 7.7 Text 1.
50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate.
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
3.
50.73(b)(5)--Information concerning previous similar events is not included.
4.
50.73(b)(5)--If no previous similar events are known, the text should so state.
5.
What are the root cause an'd corrective actions for the steam leak discussed in paragraph 47 6.
Based on the fact that the root cause could not be determined, it is reasonable not to plan a further investigation.
Increased monitoring of the equipment in question may be appropriate, however.
Abstract 1.
50.73(b)(1)--Summary of system responses after the scram is inadequate.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
~ TABLE D-2.
SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Comments
- 12. LER Number: 84-032-00 Scores: Text = 7.4 Abstract = 8.9 Coded Fields = 8.2 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 is not included.
2.
- 50. 73( b ) ( 2 ) ( i i ) ( J ) ( 2 ) --0BSERVAT 10N : Personnel error is implied but is not explicitly stated in the text.
3.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
4.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is inadequate.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.
2.
50.73(b)(1)--Suamary of root cause is inadequate.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--Title: Link is not included.
-++
s-a-TABLE D-2.
SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
Section Comnents
- 13. LER Number: 84-033-00 Scores: Text = 6.6 Abstract = 9.0 Coded Fields = 9.9 Overall = 7.7 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each system f ailure is inadequate. The text should include a discussion on how the bag got into the system.
2.
50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier for each component referred to in the text was not included.
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed.
If no other systems or components are available the text should so state.
4.
50.73(b)(4)--Without knowing how the bag got into the system (see text Comment 1) the corrective actions planned will only catch a plugged vent after it happens, but will not prevent it.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
50.73(b)(1)--The abstract is a good summary of the text, but the root cause and corrective actions summary are deficient because the text was deficient in these areas.
Coded Fields 1.
Item (8)--The field should be filled in with Not Applicable or NA.
I i
f i
1
TABLE D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments
- 14. LER Number: 84-034-00 Scores:
Text = 5.6 Abstract = 7.5 Coded Fields = 8.4 Overall = 6.5 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component f ailure is not included (i.e., RTD bypass valve).
2.
50.73(b)(2)(ii)(F)--The Energy Industry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the component failure is not included.
4.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate, more description needed.
5.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate, more description needed.
6.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the f ailed component (s) discussed in the text is not included.
7.
50.73(b)(3)--Dircu cion of the assessment of the safety consequeaces and implications of the event is not included.
Aostract 1.
50.73(b)(1)--Summary of root cause is not included.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (13)--One or more component f ailure sub-f ields are blank.
TABLE D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments
- 15. LER Number:
85-003-00 Scores: Text = 7.6 Abstract = 8.5 Coded Fields - 7.7 Overall = 7.9 Text 1.
50.73(b)(2)(11)(C)--When will the inverter design change be implemented?
2.
50.73(b)(2)(11)(H)--The estimate of the elapsed time from the discovery of the failure of a safety system train until the train was returned to service is not included.
3.
50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate.
4.
50.73(b)(2)(11)(L)--Identification (e.g. manuf acturer and model no.) of the failed component (s) discussed in the text is not included.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
Abstract 1.
50.73(b)(1)--Summary of system responses (to the scram) is not included.
Coded fields 1.
Item (4)--Title:
Root cause and link are not included.
2.
Item (13)--Component failure occurred but entire field is blank (trip and throttle valve).
. TABLE D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments
- 16. LER Number: 85-009-00 Scores: Text = 9.3 Abstract = 9.8 Coded Fields = 8.1 Overall = 9.3 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event.is not include's.
2.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is 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 is not included.
4.
Item (8)--Information in field is. inconsistent with text and/or abstract.
l Abstract Codeo Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (4)--Title: Link is not included.
TABLE D-2.
SPECIFIC LER COMMENTS FOR D.C. COOK 2 (316)
Section Comments
- 17. LER Number: 85-010-00 Scores: Text = 6.1 Austract = 8.4 Coded fields = 8.8 Overall = 7.1 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text' and still be less than 1400 characters. The following comments apply to the abstract which was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(F)--The Energy Industry identification System identifier for each system referred to in the text was not included.
3.
50.73(b)(2)(ii)(1)--Discussion of the method of discovery of the personnel error is not included.
4.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is not included.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The discussion should address long term corrective actions (e.g., will training method or procedures be changed to emphasize these points to future employees?).
7.
50.73(b)(5)--Information concerning previous similar events is not included.
Abstract 1.
No comments.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (8)--Field should be filled in with Not Applicable or NA.
l SPECIFIC LER COMMENTS FOR 0.C. COOK 2 (316)
TABLE D-2.
1 Comments j
Section i
- 18. LER Number _: 85-011-00 Scores:
Text = 6.0 Abstract = 7.2 Coded fields 8.3 Overall = 6.6 Submittal of an LER without a text is acceptable; Text 1.
however, the abstract must then meet all the requirements of a text and still be less than 1400 The following comments apply to the characters.
abstract which was evaluated as if it were a text.
The following comments apply to the abstract judged as a text.
50.73(b)(2)(11)(0)--The root and/or intermediate 2.
cause discussion for each component failure is not
- included, i.e., loose vent plug.
50.73(b?(2)(11)(J)(11--01scussion of operator actions 3.
that affected the course of the event is inadequate.
What actions were taken after the vent plug was found loose?
50.73(b)(31--Discussion of the assessment of the 4.
safety consequences and implications of the event is not included.
50.73(b)(41--Discussica of corrective actions taken 5.
or planned is inadequate (i.e., corrective actions for loose vent plug).
50.73(b)(T)--Summary of occurrences [immediate Abstract 1.
cause(s) and effects (s)) is inadequate.
50.73(b)(1)--Summary of personnel responses is 2.
inadequate.
50.73(b)(11--Summary of root cause is not included.
3.
50.73(b)(2)(11)(J)(1)--01scussion of operator actions 4.
that affected the course of the event is inadequate.
Coded Fleids 1.
Item (4)--Title: Root cause and link are not included.
-