ML20197A792
| ML20197A792 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/16/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8610270394 | |
| Download: ML20197A792 (57) | |
Text
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Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 Virgini lectric and Power Company AT
- r. W. L. Stewart, Vice President, Nuclear Operations P. O. Box 26666 Richmond, VA 23261 Gentlemen:
The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AE00) has recently completed an assessment of your Licensee Event Reports (LERs) for Surry 1 and 2 as a part of the NRC's Systematic Assessment of Licensee Performance (SALP) program.
In general, AEOD found your submittals to be of above average quality based on the requirements contained in 10 CFR 50.73. We are forwarding a copy of AEOD's assessment prior to the issuance of the Surry SALP Board Report (50-280/86-23, 50-281/86-23) in an effort to provide useful information for preparation of future submittals.
Please let us know if you have any questions.
Sincerely, Original Signed by Luis A. Reyes /for Roger D. Walker, Director Division of Reactor Projects
Enclosure:
AEOD SALP Input for Surry 1 and 2 -
Operations (LER Quality) for the Assessment Period of 1 March 1985 to 31 August 1986
,ccy / encl:
W. F Saunders, Station Manager
. J. Hardwick, Manager - Nuclear Programs and Licensing bcc w/ encl:
(See Page 2) 7
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October 16, 1986
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OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF 1 MARCH 1985 TO 31 AUGUST 1986 e
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee' Event Reports (LERs) submitted by Surry 1 and 2 during the March 1, 1985 to August 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in a report entitled "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT),"
NUREG/CR-4178, March 1985. The results of this evaluation indicate that the Surry LERs have an overall average score of 8.5 out of a possible 10 points, compared to a current industry average of 7.9 (i.e., the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).
The principle weakness identified in the Surry LERs, in terms of safety significance, involves the requirement to adequately identify failed components in the text.
The failure to adequately identify each component that fails prompts concern that possible generic problems may go unnoticed by others in the industry for too long a time period.
A strong point for the Surry LERs is that the discussions concerning 4
the root cause; the assessment of the safety consequences; the failure mode, mechanism, and effect of failed components; personnel errors; and
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safety system responses were well written in most of the LERs that were evaluated.
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4-AE00 INPUT TO SALP REVIEW FOR SURRY 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Surry 1 and 2 during the March 1, 1985 to August 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178.
The sample consists of a total of 17 LERs (i.e., 9 LERs for Surry 1 and 8 for Surry 2), which is half of the LERs on file at the time the sample was selected.
The Surry LERs were evaluated as one sample for this SALP period because it was determined that their LERs are both written and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in the sample.
It was necessary to start the evaluation before the end of the SALP -
assessment period because the input was due such a short time after the end of the SALP period.
Therefore, all of the LERs prepared during the SALP assessment period were not available for review.
fe, Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet i
3 the requirements of 10 CFR 50.73(b), NUREG-1022, and Supplements 1 and 2 to NUREG-1022.
The evaluation process for each LER is divided into two parts. The first part of the evaluation consists of documenting comments specific to the content and presentation of each LER.
The second part consists of determining a score (0-10 points) for the text, abstract, and coded fields I
of each LER.
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The LER specific comments serve two purposes:
(1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was reviewed.
Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score - overall LER score).
The results of the LER quality evaluation are divided into two categories:
(1) detailed information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix 8), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).
When referring to these appendices,-the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER 4
scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.
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Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the station's performance (on a scale I
of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b). Again, Surry LERs were evaluated as one sample, rather than two separate samples (by unit), because it was determined that the Surry LERs are both written and formally reviewed at the station, rather than the unit, level.
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t Table 1 presents the average scores for the sample of LERs evaluated for the station. 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 1 in perspective, the distribution of the overall average score for all licensees that have been evaluated using the current methodology is provided on Figure 1.
Additional scores are added to Figure 1 each month as other licensees are evaluated. Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1.
For example, Surry's average score for the text of the LERs that were evaluated is 8.7 out of a possible 10 points.
From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation. The percentage scores in the text sununary section of Table 2 provide an indication of how well each text requirement was addressed by the station for the 17 LERs that were evaluated.
Discussion of Specific Deficle'cies n
4 A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in
, reparing LERs.
For example, requirement percentage scores of less than 75 p
indicate that the station probably needs additional guidance concerning l
these requirements.
Scores of 75 or above, but less than 100, indicate l
that the station probably understands the basic requirement but has either:
(1) excluded certain less significant information from most of the discussions concerning that requirement or (2) totally failed to address i
the requirement in one or two of the selected LERs.
The station should review the LER specific comments presented in Appendix D in order to I
determine why it received less than a perfect score for certain requirements.
The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of l
importance.
In addition, the primary deficiencies in the abstract and I
coded fields are discussed.
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TA8LE 1.
$UMARY OF SCORES
- FOR SURRY 1, 2 A_verage High Low Text 8.7 9.4 7.5 Abstract 7.9 9.9 4.4 Coded Fields 8.7 9.3 7.2 Overall 8.5 9.5 7.4 a.
See Appendix 8 for a summary of scores for each LER that was evaluated.
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LER REQUIREMENT PERCENTAGE SCORES FOR SURRY 1, 2 TEKT Percentage a
Reautrements ISO.73fb)1 - Descriptions Scores ( 1 (2)(ii)(A) - - Plant condition prior to event 8'8 (17)
(2)(11)(B) - - Inoperable equipment that contributed b
(2)(11)(C) - - Date(s) and approximate times 66 (17)
(2)(11)(D) - - Root cause and intermediate cause(s) 93 (17)
(2)(11)(E) - - Mode, mechanism, and effect 100 ( 7)
(2)(ii)(F) - - EIIS Codes 3L (17)
(2)(11)(G) - - Secondary function affected b
(2)(ii)(H) - - Estimate of unavailability 58 (6)
(2)(11)(I) - - Method of discovery 85 (17)
(2)(ii)(J)(1) - Operator actions affecting course 100 (10)
(2)(11)(J)(2) - Personnel error (procedural deficiency) 93 (7)
(2)(ii)(K) - - Safety system responses 100 (10)
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(2)(ii)(L) - - Manufacturer and model no. information 50 (6)
Assessment of safety consequences 94 (17)
(3)
Corrective actions 91 (17)
(4)
Previous similar event information 41 (17)
(5)
(2)(1) - - - - Text presentation 89 (17) 4 ABSTRACT Percentage.
a Reautrements ISO.73(b)(111 - Descriptions Scores ( l
- Major occurrences (Immediate cause and effect 93 (17) information)
- Description of plant, system, component, and/or 82 (10) personnel responses
- Root cause information 77 (17)
- Corrective Action information 75 (17)
- Abstract presentation 73 (17)
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TABLE 2.
(continued)
CODED FIELOS Percentage Ites Number (s) - Description Scores ( l' 1, 2, and 3 - Facility name (unit no.), docket no. and 100 (17) page number (s) 4 - - - - - - Title 55 (17) 5, 6, and 7 - Event date, LER No., and report date 100 (17) 8 - - - - - - Other facilities involved 94 (17) 9 and 10 - - Operating mode and power level 96 (17) 11 - - - - - Reporting requirements 99 (17) 12 - - - - - Licensee contact information 100 (17)
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13 - - - - - Coded component failure information 87 (17) 14 and 15 - - Supplemental report information 94,(17) a.
Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all LERs; therefore, the b
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.
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The corrective action discussions are considered worth mentioning even though the overall score for this requirement is 91 because six of the 17 LERs failed to provide sufficient details concerning those actions necessary to prevent recurrence of the event. See Appendix D for the specific comments involving Requirement 50.73(b)(4) for these six LERs.
The requirement to provide dates and approximate times for occurrences discussed in the text, Requirement 50.73(b)(2)(ii)(C), is considered inadequate in that twelve of the 17 LERs lacked a date or time for one of the major occurrences of the event (e.g., the time the unit was placed in a safe and stable condition, the time a safety system was taken out of service, or the time a major component was returned to an operable status). This deficiency contributed to another requirement being deficient, Requirement 50.73(b)(2)(ii)(H). This latter requirement requires that an estimate of the total time that a train of a safety system is inoperable be included in the text.
This requirement was not met for three of the six events involving train unavailability. Had the requirement to provide adequate dates and times been satisfied for all LERs, Requirement 50.73(b)(2)(11)(H) would probably have been satisfied also as an estimate could have,been made by noting the difference between two times such as an "out-of-service" and "back-in-service" time.
4 The manufacturer and/or model number (or other unique identification) ~
was not provided in the text of four of the six LERs that involve a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail should be identified in the text so that others in the industry are made aware of potential problems. An event at one station can often lead to the identification of a generic problem that can be corrected at other plants or stations before they experience a similar event. Likewise, although not specifically required by the current regulation, components whose design contributes to an event should also be identified.
Requirement 50.73(b)(5), the requirement to provide a reference to any known previous similar events at the same plant (station) in the text, is
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it can be an indicator of recurring problems and can lead to the possible identification of generic problems in the industry.
Thirteen of the 17 LERs did not include the Energy Industry Identification System (EIIS) codes for each system and component referred to in the text, Requirement 50.73(b)(11)(F).
The structured outline format used to present the Surry LER text discussions was a major contributor to the good text presentation score (89%) and the above average LER text score (8.7).
One comment concerning the outline format is that the purpose of Section 7 " Generic Implications" is not clear. There is no one requirement in the present regulation that specifically addresses generic implications. This type of information is presently obtained from a number of different requirements; primarily, those involving cause, personel error, corrective actions, previous similar events, and manufacturer'/model of failed components. Of these requirements, only " previous similar events" and " manufacturer /model number" information is not covered by the present outline. The addition of these requirements to the outline in 4
place of " Generic Implications" is suggested.
It would then be up to the reader to determine for himself whether or not the event h'ad possible
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generic implications.
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4 The primary deficiency concerning the abstracts is the lack of information due to their brevity. While there are no specific requirements concerning an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, summarize the following information from the text:
1.
Cause/Effect What happened that made this event reportable.
2.
Responses Major plant, system, and personnel responses as a result of the event.
3.
Root / Intermediate The underlying cause of the event. What Causes caused the component and/or system
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failure and the personnel errors.
4.
Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent
' recurrence.
b There is no requirement to provide the reporting requirement or to summarize the safety assessment in an abstract; therefore, this as well as ~
other information may be excluded when space becomes a consideration.
Of the four items above, only No. 1 and 2 were adequately addressed in the 17 LERs that were evaluated.
Over one-third of the abstracts lacked adequate information concerning cause and corrective actions. Expansion of the abstracts to more fully utilize the 1400 space limit will improve their quality. The score for abstract presentation (73%) is the result of the brevity of the abstracts.
The main deficiency in the area of coded ficids involves the title, Item (4). All of the titles failed to provide adequate root cause information, two failed to include the result (i.e., why the event was
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required to be reported), and five failed to include information concerning the link between the cause and the result. While result is considered the 11 m
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4 unst important part of the title, cause information (and link, if necessary) must be included to make a title complete. An example of a title that only addresses the result might be " Reactor Scram." This is inadequate in that the cause and link are not provided, a more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram." From this title, the reader knows the cause was either personnel or procedural and that surveillance testing was the link between the cause and the result.
Table 3 provides a summary of the major areas that need improvement for the Surry LERs.
For more specific information concerning additional deficiencies, the reader should refer to the information presented in Appendices C and D.
General guidance concerning requirements can be found in NUREG-1022, Supplement No. I and 2.
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AREAS MOST NEEDING IMPROVEMENT FOR THE SURRY LERs Area Comments Corrective ac'tions Corrective action discussions must include information involving those taken or planned to try to prevent recurrence of the event.
Date and approximate time Sufficient dates and times should be information and safety included in the text to enable the system unavailability reader,to have a time history of the various occurrences and to permit an estimate of the length of time that safety system trains are out of service.
Manufacturer and model number Component identification information information should be included in the text whenever a component fails or (although not specifically required by the current regulation) is suspected of contributing to the event because of its design.
Previous similar events Previous similar events should be referenced (e.g., by LER Number) or, if none are identified, the text should so state.
EIIS codes EIIS codes should be provided in
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the text for all system and components discussed in the text.
Text presentation The present outline could be modified in include " Previous Similar Events" and
" Manufacturer /Model No." headings.
Abstracts Root cause and corrective action infornation should be included in each abstract.
The abstract discussions should utilize more of the 1400 spaces available.
Coded fields a.
Titles Titles should be written such that they better describe the event.
In particular, the root cause of the event should be included in each title.
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4 REFERENCES 1.
B. S. Anderson, C. F. Miller, 8. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.
2.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.
3.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 1. U.S. Nuclear Regulatory Commission, February 1984.
4.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Commission, September 1985.
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4 APPENDIX A LER SAMPLE SELECTION INFORMATION FOR SURRY 1, 2 B
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II TABLE A-l.
LER SAMPLE SELECTION FOR SURRY 1. 2 Sample Number Unit Number LER Number Comments 1
1 85-008-00 2
1 85-013-00 3
1 85-019-00 4
1 85-022-01 ESF 5
1 86-001-00 Scram 6
1 86-003-00 Scram 7
1 86-008-00 ESF 8
1 86-010-00 Scram 9
1 86-012-00 Scram 10 2
85-004-01 11 2
85-007-00 ESF 12 2
85-009-01
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85-013-00 Scram 14 2
86-001-00 ESF 4
15 2
86-002-00 16 2
86-003-00 Scram 17 2
86-004-00 1
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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR SURRY 1, 2 o
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TABLE E-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR SURRY 1, 2 9
a LER Sample Number 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 Text 8.6 8.9 8.4 8.4 9.4 9.0 9.1 9.3 7.5 8.0 9.3 8.8 9.4 8.2 8.1 8.4 Abstract 5.2 9.8 5.0 9.4 9.9 7.0 9.1 8.5 7.2 9.1 7.2 4.4 9.8 6.7 8.7 9.0 Coded Fields 6.9 8.9 8.2 9.0 8.9 8.3 9.0 9.0 9.0 7.2 8.7 8.4 9.3 8.5 9.0 8.2 Overall 7.6 9.2 7.4 8.7 9.5 8.4 9.1 9.0 7.6 8.3 8.6 7.4 9.5 7.8 8.4 8.6 a
LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE 8.7 Text 9.1 7.9 i
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.L Coded 8.7 Fields 8.9 8.5 Overall 8.8 See Appendix A for a list of the corresponding LER numbers.
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TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR SURRY 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Totals
- Totals (
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Descriotion of Deficiencies and Observations 50.73(b)(2)(ii)(A)--Plant operating 1 (17) conditions before the event were not included or were inadequate.
0 (5) 50.73(b)(2)(ii)(B)--Discussion of the status 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 12 (17) sufficient date and/or time information.
a.
Date information was insufficient.
4 b.
Time information was insufficient.
10 50.73(b)(2)(11)(D)--The root cause and/or
.6-(17).
intermediate failure, system failure, or personnel error was not included or was
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a.
Cause of component failure was not 5
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included or was inadequate i
b.
Cause of system failure was not l
included or was inadequate Cause of personnel error was not 0
c.
included or was inadequate.
0 ( 7) 50.73(b)(2)(ii)(E)--The f ailure mode, mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode was not included or was inadequate b.
Mechanism (immediate cause) was not included or was inadequate Effect (consequence) was not included c.
or was inadequate.
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Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(11)(F)--The Energy Industry 13 (17)
Identification System component function identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a failure of a
-- (0) 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 3 (6) rendered a train of a safety system
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inoperable, the estimate of elapsed time j
from the discovery of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(I)--The method of discovery 3 (17) of each component failure, sy.s, tem failure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each 0
i component failure was not included i
or was inadequate I
b.
Method of discovery for each system 2
failure was not included or was inadequate c.
Method of discovery for each 1
personnel error was not included or was inadequate d.
Method of discovery for each 0
procedural error was not included or was inadequate.
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(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(11)(J)(11--Operator actions that 0 (10) 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 1
(7) each personnel error was not included or was inadequate.
a.
OBSERVATION: A personnel error was 0
implied by the text, but was not explicitly stated.
b.
50.73(b)(2)(ii)(J)(2)(i)--Discussion 1
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 0
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 4
with an activity or task that was not covered by an approved procedure was not included or was inadequate.
d.
50.73(b)(2)(ti)(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 i
inadequate.
e.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1
l 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.
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(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals (
)
50.73(b)(2)(ii)(K)--Automatic and/or manual 0 (10) safety system responses were not included or were inadequate.
4 (6) 50.73(b)(2)(ii)(L)--The manufacturer and/or model number of each failed component was not included or was inadequate.
50.73(b)(31--An assessment of the safety 3 (17) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION: The availability of 0
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.
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b.
OBSERVATION: The consequences 0
of the event had it occurred under more severe conditions were not discussed.
If the event occurred 4
under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 6 (17) 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.
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TA8LE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
a.
A discussion of actions required to 1
correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not include) or was inadequate.
b.
A discussion of actions required to 5
reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c.
OBSERVATION: A discussion of actions 0
required to prevent similar failures r_
in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information concerning previous 10 (17) similar events was not included or was inadequate.
4 N.
C-5
.,._--._,-,-,-,,w-,-,..
,,,,,n-e...,
m
-,--,,-a
db TABLE C-1.
(centinued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(1)--Text presentation 4 (17) inadequacies.
a.
OBSERVATION:
A diagram would have 0
aided in understanding the text discussion, b.
Text contained undefined acronyms 1
and/or plant specific designators, c.
The text contains other specific 3
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.
~
The " paragraph total" is the number of LERs that have one or more b.
i requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.
e mr C-6
--m r
w-y,e g
eeLwm---------yy,ww-
-,gp----
y-wi,--s ww--+--m----------------------v c
4 TA8LE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR SURRY 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Par'agraph Description of Deficiencies and Observations Totals' Totals (
)
A summary of. occurrences (immediate cause 4 (17) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 3 (10) 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 3
included or was inadequate.
c.
Summary of personnel responses was not 0
included or was inadequate.
A summary of the root cause of the event 7 (17) was not included or was inadequate.
A summary of the corrective actions taken or 6 (17) planned as a result of the event was not included or was inadequate.
4
==s.
C-7
--r--
r-
=
wp 7
- - - +
-TT-w w---v
---'-w
^
=
fI TABLE C-2.
(centinued)
Number of LERs with Deficiencies and Observations Sub-paragraph Par'agraph Description of Deficiencies and Observations Totals' Totals (
)D Abstract presentation inadequacies 8 (17) e 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 was greater than 0
1400 characters c.
The abstract contains undefined 2
acronyms and/or plant specific designators.
d.
The abstract contains other specific 6
deficiencies (i.e., poor summarization, contradictions, etc.)
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or
~
observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not 4,
necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
l i
C-6
-.,.,,,-%-.,.c.
3,.
--.7-
--w
w-------w---
a
.,----m.-%--.
--y w
k L, Y t
TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SURRY 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
0 (17)
Facility Name 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 (17) incorrect.
0 (17)
Page Number was not included or was
=-
incorrect.
Title was left blank or was inadequate 17 (17) a.
Root cause was not given in title 17 b.
Result (effect) was not given in title 2
c.
Link was not given in title 5
0 (17)
Event Date a.
Date not included or was incorrect.
l b.
Discovery date given instead of event date.
-LER Number uas not included or was incorrect 0 (17) 0 (17)
Report Date 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 1 (17) inconsistent with text and/or abstract.
0 (17)
Operating Mode was not included or was inconsistent with text or abstract.
C-9 t
)
s
- g TABLE C-3.
(continuid)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
Power level was not included or was 1 (17) inconsistent with text or abstract 2 (17)
Reporting Requirements a.
The reason for checking the "0THER" 0
requirement was not specified in the abstract and/or text.
b.
OBSERVATION:
It may have been more 0
appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It may have been 2
appropriate to report this event under an additional unchecked paragraph.
0 (17)
Licensee Contact a.
Field left blank b.
Position title was not included c.
Name was not included d.
Phone number was not included'.
Coded Component Failure Information 5 (17)
,s a.
One or more component failure 0
sub-fields were left blank.
b.
Cause, system, and/or component code 1
is inconsistent with text.
Component failure field contains data 3
c.
when no component failure occurred.
I d.
Component failure occurred but entire 1
field left blank.
l l
l l
l 1
l C-10 1
n.....
4 Ef b; -; '
TA8LE C-3.
(contin 30d) 4 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
1 (17)
Supplemental Report a.
Neither "Yes"/"No" block of the 0
supplemental report field was checked.
b.
The block checked was inconsistent I
with the text.
0 (17)
Expected submission date information is inconsistent with the block checked in item (14).
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, the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
4 6
~
i l
W.
C-ll
,. _. ~ _ -.. _.
-,,--.-,m
...m
.--._.__,.-z
r 3
APPENDIX 0 LER COMMENT SHEETS FOR SURRY 1, 2 O
9 i
, b. !
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 1.
LER Number: 85-008-00 Scores: Text - 8.6 Abstract - 5.2 Coded Fields - 8.9 Overall - 7.6 1
Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions.before the event is not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(3)--The discussion should be more specific as to the other systems that were available to mitigate the possible consequences of the event.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The personnel error should be mentioned.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
l Coded Fields 1.
Item (4)--Title: Root cause (personnel error) and l
4 link (construction activities) are not included. A more appropriate title might be " Operator Error During Construction Activities Resulted in Erroneous Lockout of Auto CO2 System".
D-1
' a t :. ;.
h j.yfa TA8LE 0-1.
SPECIFIC LER COMMENTS FOR SURRY l (280)
Section Comments 2.
LER Number:
85-013-00 Scores: Text - 8.9 Abstract - 9.8 Coded Fields - 8.8 Overall - 9.2 Text 1.
50.73(b)(2)(11)(Cl--Date and time information for major occurrences is inadequate.
The text states that the total '.ime Unit 1 containment exceeded 120' was 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
However, dates and approximate times of occurrences are required. The text does not contain a date. Times should be provided for when 1-CD-REF-1A tripped and was restarted. A time or date if applicable, should be provided for when the three unit service water tubes were cleaned.
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 !?cluded. A code is provided for Chiller (CHV), but codes should also be provided for the other systems and components identified in the text (service water, condenser etc.).
i 3.
50.73(b)(3)--Discussion of the assessment of the
~
safety consequences and implications of the event is excellent, b
4.
50.73(b)(5)--Information concerning previous similar l
events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
No comment Coded Fields 1.
Item (4)--Title:
Root cause is not included. A more appropriate title might be "High Containment Temperature due to Loss of a Component Cooling Water Chiller Unit".
2.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
D-2 7-,r^----
---"==*=-r
"-w--------'--a
--v^-
-'-*'w'--w---
i'**
="--'-w-
l~
~
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 3.
LER Number: 85-019-00 Scores: Text = 8.4 Abstract = 5.0 Coded Fields - 8.2 Overall - 7.4 Text 1.
50.73(b)(2)(ii)(C)--At what time was Rod D-4 declared inoperable?
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the IRPI is inadequate.
Why, given this system is stated to provide spurious incorrect indication, did both events involve precisely the same two rods?
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
=
4.
50.73(b)(2)(ii)(I)--Discussion of the method of
~~
j discovery of the incorrect indication for Rod D-12 is not included.
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What was needed (performed) to return at least one IRPI to service
~
within two hours for both events?
b 6.
50.73(b)(5)--Information concerning previous similar events is inadequate.
The text implies such events -
have happened before.
If they have occurred at Surry, they should be referenced by LER number (s).
~
7.
Some ideas are not presented clearly (hard to follow).
It is not obvious from the text why this i
event is reportable.
Abstract 1.
50.73(b)(1)--Summary of root cause information is not included.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. Why is no action required at this time to prevent recurrence?
l D-3
-,,--,---,a--
,.,,------,,.-m.
--m--_,---
.,-,_my
,__---.,_,,.____---__.-.y
f;,~',
O TA8LE D-1.
SPECIFIC LER COMMENTS FOR SURRY l (280)
Section Comments 3.
LER Number:
(continued) 3.
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 (Second sentence of first paragraph of abstract).
4.
Abstract does not adequately summarize the text. The safety assessment is not as important in the abstract as is information concerning cause and corrective actions.
Coded Fields 1.
Item (4)--Title:
Root cause and result information is not included.
A better title might be " Inoperable (Degraded) Individual Rod Position Indication for Two Rods in One Goup - Technical Specification Violation". Even this title does not tell the reader that this may be a generic problem.
2.
Item (13)--Component failure field contains data when
~
no component failure occurred. The text does not indicate a component " failure" occurred.
Even if the degraded,IRPI was considered to be a failed component, the cause code of "E" does not appear to be correct. From the information in the text it 4,
appears that "B" would be a more appropriate cause code.
ee.
D-4 e
--q-
-w g
w e__,.
i
.c TA8LE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 4.
LER Number:
85-022-01 Scores: Text = 8.4 Abstract = 9.4 Coded Fields = 9.0 Overall = 8.7 Text 1.
50.73(b)(2)(11)(c)--Time information for major occurrences is inadequate.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the misadjusted hot gas bypass valve is not included.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifiers of each component referred to in the text are not included.
4.
50.73(b)(4)--Section 6 should indicate whether or not actions are needed to prevent the valve from becoming
=
misadjusted again (i.e., actions needed to correct
~~
the root cause, see text comment ?).
Abstract 1.
No comment Coded Fields 1.
Item (4)--Title: Cause (misadjusted valve) and link (low instrument air pressure) are not included. A more appropriate title might be, " Ice Formation Due to Improperly Adjusted Hot Gas Bypass Valve Results 4
in Drop in Instrument Air Pressure and Various ESF Actuations".
~-
D-5
,,_y-__
r e
TA8tE 0-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 5.
LER Numbe'r: 86-001-00 Scores: Text = 9.4 Abstract - 9.9 Coded fields - 8.9 Overall - 9.5 Text 1.
50.73(b)(2)(11)(C)--Time information for major occurrences is inadequate. Times should be provided for when the plant was " returned to a stable condition", when the Instrument Air System was restored to normal, and when the affected components and systems were operational.
2.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
See text comment 1.
Abstract 1.
No comment Coded Fields 1.
Item (4)--Title:
Root cause is not included.
e Y
u.
D-6
,,,----,,-,-.,--rm.--
,------,.-_-,,,,-o.
l
+
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 6.
LER Number:
86-003-00 Scores: Text - 9.0 Abstract - 7.0 Coded Fields - 8.3 Overall - 8.4 Text 1.
50.73(b)(2)(ii)(Al--What was the power level at the time of the manual trip (i.e. 1256 hours0.0145 days <br />0.349 hours <br />0.00208 weeks <br />4.77908e-4 months <br />)?
2.
50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the installed jumper that slipped off is inadequate. Was there a problem with this jumper or did an external force such as vibration cause it to come off?
3.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. Why did the operator initiate emergency boron rather than immediately tripping the reactor?
r.
4.
50.75(b)(2)(11)(K)--Did any safety systems actuate
~~
after the reactor was manually tripped? If so, they should be named.
5.
50.73(b)(3)--D* cussion of the assessment of the safety conseqe. aces and implications of the event is inadequate. Which core safety limits were in danger of being exceeded? Why didn't the reactor trip on a negative rate when the four rods dropped?
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was anything done to try and prevent the slipping of jumpers from their contacts in the future?
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate.
The urgent failure 6ad the emergency boration should have been mentioned.
2.
50.73(b)(1)--Summary of root cause is inadequate.
Personnel error can be inferred from the last sentence of the abstract.
3.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should mention that Abnormal Procedure 1.4 was changed to instruct the operators to trip the
~-
reactor if two or more rods drop.
D-7 l
i TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Comments Section 6.
LER Number:
(continued) 4.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not ut1112ed.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included. A better title might be, " Reactor Scram Initiated After Four Rods Drop As a Result of a Short in the Control Rod Logic Cabinet".
2.
Item (13)--Cause, system, and/or component code is inconsistent with text.
It is not apparent why "E" is given as the cause code.
=.
m a
e s
T N,
0-8 1-
I l
TABLE 0-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 7.
LER Number: 86-008-00 Scores: Text - 9.1 Abstract - 9.1 Coded Fields - 9.0 Overall - 9.1 Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate.
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.
3.
Acronym (s) and/or plant specific designator (s) are undefined.
BFD should be defined.
Abstract 1.
50.73(b)(11--Summary of root cause is inadequate.
The increased current and heat due to the accumulation of dust should be mentioned.
2.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
- e
- s D-9
_.. _,. - -, _ _.. ~
m-~
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 8.
LER Number:
86-010-00 Scores: Text - 9.3 Abstract - 8.5 Coded Fields - 9.0 Overall - 9.0 Text 1.
50.73(b)(2)(ti)(c)--Time information for major occurrences is inadequate. A time should be provided for when "the plant was returned to a stable condition".
9 2.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of system responses is inadequate. The abstract should summarize the system responses (i.e., feedwater isolation, auxiliary feedwater start.)
Coded fields 1.
Item (4)--Title: Root cause is not included.
O e
t l
~.
D-10 v v w
T 1
[hb.
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY l (280)
Sectico Comments 9.
LER Number: 86-012-00 Scores: Text = 7.5 Abstract - 7.2 Coded Fields - 9.0 Overall = 7.6 Text 1.
50.73(b)(2)(11)(C)--Time information for major occurrences is inadequate. At what time was the boric acid filter isolated? At what time was the flow path reestablished?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is inadequate.
The total time that the flow path was isolated is not
~
clear; given the statement that "immediately following the isolation it was revealed that the flow path was isolated for approximately 30 minutos." Did it take 30 minutes to determine that the flow path was isolated?
4.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the isolation is inadequate.
Is it normal procedure to "immediately attempt to verify a 4
lineup" after part of a system is isolated?
5.
50.73(b)(2)(11).*J)(2)--Discussion of the personnel
~
error ir inadequate.
50.73(t.j.)(ii)(J)(2)(1)--Discussion as to whether the perV)nnel error was cognitive or procedural is not included.
l 50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of l
personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
Some details concerning the addendum change to the shift orders should have been provided.
0-11
, +. -
,,---.,m
--w
-.e, m,--.-_-w m-
l 4
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 1 (280)
Section Comments 9.
LER Numbe'r:
(continued) 7.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
8.
A logical transition does not exist between all ideas.
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate. The abstract should have men'tioned that the isolation was
" contrary to the Technical Specifications".
2.
50.73(b)(ll--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective actions to prevent recurrence should have been mentioned.
3.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but'it was
~
not utilized.
Coded Fields 1.
Item (4)r-Title: Root cause and link information are not included. A better title mignt be, " Personnel Error During Maintenance Causes Loss of Boric Acid 4
Flow Path - Technical Specification Violation".
1 l
D-12 I
s TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Section Comments
- 10. LER Number: 85-004-01
~
Scores: Text = 8.0 Abstract = 9.1 Coded Fields = 7.2 Overall = 8.3 Text 1.
50.73(b)(2)(11)(C)--Date information for major occurrences is not included. When was the discrepancy noticed and when are repairs expected to be completed?
2.
50.73(b)(2)(11)(D)--Why were the screws being torqued to excessive values?
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)(11)(I)--Discussion of the method of discovery of the transmitter discrepancies is inadequate. What activity led to the discovery of the discrepancies?
5.
50.73(b)(2)(ii)(L)--Is a model number available for the CONAX seal assemblies?
6.
50.73(b)'(3)--The safety assessment should indicate whether or not the function of any safety systems 4
would have been prevented by these failures.
7.
50.73(b)(4)--What will prevent the solid screws from being torqued to an excessive value?
8.
Discussing each problem in order in each section is good and make the LER much more readable.
Abstract 1.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
EQ should be defined.
2.
The fact that Unit I was also affected should be mentioned.
Coded Fields 1.
Item (4)--Title:
Root cause is not included. The use of acronyms in the title should be avoided unless space is a consideration.
~. _
D-13
a TABLE D-1.
SPECIFIC LER COMENTS FOR SURRY 2 (281)
Section Comments
- 10. LER Number:
(continued) 2.
Item (8)--Information in field is inconsistent with text and/or abstract. The text indicates that transmitters in Unit I were also affected.
3.
Item (10)--Power level is not included.
m O
e O
- p D-14 r--e---
p.--n.m----.w,.
,,-w.-
.,-r-e-.v+--
--n----m-----,,.---
+ --,
w
k[
l TABLE 0-1.
SPECIFIC LER COMMENTS FOR SURRY 2.(281)
Section Comments
- 11. LER Number: 85-007-00 Scores: Text - 9.3 Abstract - 7.2 Coded Fields - 8.7 Overall - 8.6 Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. A time should be provided for when the SI signal was cleared.
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. Codes are provided for components, but not the systems referred to in the text (e.g., RHR).
3.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. A summary of the immediate cause of the safety injection should be included.
2.
50.73(b)I1)--Summary of plant and system responses is inadequate. The abstract should state that the core received no flow.
g 3.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract does not provide enough information as to how the procedural inadequacy led to the SI.
4.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (4)--Title: Root cause is not included, l
l l
~-
l l
D-15
,,_,,--.----n a
y
4 TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Section Comments
- 12. LER Number: 85-009-01 Scores: Text = 8.8 Abstract - 4.4 Coded Fields - 8.4 Overall = 7.4 Text 1.
50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
2.
50.73(b)(2)Lii)(I)--Discussion of the method of discovery of the inoperable IRPI is not included.
3.
50.73(b)(5)--Information concerning previous similar events is inadequate.
4.
Its not clear from the text, why this event is reportable. Some detatis concerning the applicable Technical Specification would be appropriate.
5.
The revision removes the statement that the IRPI has no safety function. Removal of this statement implies that the IRPI has a safety function'but this
~
function is not stated in the text.
6.
The use.of revisions bars in the margin to denote the changes is good.
4 Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate. See text comm:nt number 4.
2.
50.73(b)(1)--Summary of the root cause is inadequate. The generic implications of the event should be mentioned in the abstract as should the information under Section 3 of the text.
3.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The information under Sections 4, 5, and 6 of the text should have been mentioned in the abstract.
4.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
1 D-16 l
4
- 1... ;,.
TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Section Comments
- 12. LER Number:
(continued)
Coded Fields 1.
Item (4)--Title:
Root cause and results are not included. A better title might be, " Inoperable (Degraded) Individual Rod Position Indication for Seven Rods - Technical Specification Violation".
2.
Item (13)--Component failure field contains data when no component failure occurred. The text does not discuss a component failure.
If the IRPI was considered to be a failed component, the cause code "E" does not appear to be appropriate.
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0-17 1
1 TA8LE 0-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Comments Section
- 13. LER Numb'er:
85-013-00 Scores: Text - 9.4 Abstract - 9.8 Coded Fields - 9.3 Overall = 9.5 Text 1.
50.73(b)(2)(ii)(C)--When will the design changes be completed?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System camponent function identifier (s) and/or system name of each component or system referred to in the LER is not included.
Abstract 1.
No comment Coded Fields 1.
Item (4)--Title:
Root cause (personnel error) is not included. The use of acronyms in the title should be avoided unless space is a consideration.
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D-18
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2"7l fin.
TA8tE 0-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Section Comments
- 14. LER Number: 86-001-00 1
Scores: Text - 8.2 Abstract - 6.7 Coded Fields - 8.5 Overall - 7.8 Text 1.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(11)(C)--Time information for major i
occurrences is inadequate. The only time given in the text is the time for the loss of the "E" transfer bus. Times are required for all major occurrences.
3.
50.73(b)(2)(ti)(01--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
4.
50.73(b)(2)(ii)(F1--The Energy Industry
=
Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.,
3 i
5.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included 6.
50.73(b)(41--0BSERVATION: The score for this 4
requirement is based on the assumption that the supplemental report will contain all the necessary information.
7.
50.73(b)(51--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of plant and system responses are inadequate.
Other than the turbine runback and the No. 2 EDG start, the abstract does not mention any other responses (i.e., emergency boration, inability to normally manipulate control rods etc.).
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective actions discussed in the text concerning the rod control problem should be summarized in the abstract.
D-19
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TABLE D-1.
SPECIFIC LER COMENTS FOR SURRY 2 (281)
Section Comments
- 14. LER Number:
(continued) 3.
Abstract does not adequateiy summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
2.
Item (13)--Component failure occurred but entire field is blank.
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ti; TA8LE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
O Section Comments
- 15. LER Number: 86-002-00 Scores: Text = 8.1 Abstract = 8.7 Coded Fields - 9.0 Overall = 8.4 Text 1.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the packing and diaphragm leak is inadequate. Were these failures considered to be normal wear or a maintenance interval problem?
2.
50.73fb?(2)Lii)(F)--The Energy Industry Identlf$catlon 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)(ti)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
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4.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
It is not apparent why there are no actions considered to be required,to prevent recurrence of this kind of event.
See text comment number 1.
5.
50.73(b){5)--Information co.ncerning previous similar events is not included.
If no previous similar events are known, the text should so state.
6.
Some ideas are not presented clearly (hard to j
follow). The distinction between " controlled", and "other than controlled", and " unidentified" sources of leakage is not presented well.
In addition, a reference point (such as the controlled leak prior to the increase) should have been provided.
j Abstract 1.
The abstract should have contained a few more details such as the Technical Specification leakage limits and the fact that no actions were deemed necessary to prevent recurrence of the event.
Coded Fields 1.
Item (4)--Title: Root cause and link information is not included. A better title might be, " Higher Than Allowable Reactor Coolant System Leakage Found During-Leakage Test - Failed Packing and Diaphragm".
D-21
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TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (201) i Section Comments
- 16. LER Number: 86-003-00 Scores: Text - 8.4 Abstract = 9.0 Coded Fields - 8.2 Overall - 8.6 Text 1.
50.73(b)(2)(ii)(C)--Date and time information for major occurrences is inadequate. When was the plant stabilized and when is the engineering review expected to be completed?
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the blocked air pilot relay is not included.
3.
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.
4.
50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed system is not included.
How long was control of the "B" main feedwater bypass valve lost?
5.
50.73(b)(4)--A supplemental report appears to be needed to describe the results of the engineering review. The supplemental report needs to give the 4,
specifics of any changes made to the procedures.
Without a commitment to submit a supplemental report,_
this LER must be considered incomplete.
Abstract 1.
No comment Coded Fields 1.
Item (4)--Title: Root cause (contamination in instrument air) is not included.
2.
Item (13)--Component failure field contains data when l
no component failure occurred.
The valve and air pilot relay did not actually fail, so this field t
could have been left blank.
3.
Item (14)--The block checked is inconsistent with I
information in the text (see text comment 5).
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o' TABLE D-1.
SPECIFIC LER COMMENTS FOR SURRY 2 (281)
Section Comments 4
- 17. LER Number: 86-004-00 Scores: Text - 9.1 Abstract - 8.1 Coded Fields - 8.9 Overall - 8.8 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)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(11--Summary of root cause is inadequate.
The text implies that a contributing factor was poor communications / coordination between the operator performing the valve line-up and the control room l
operator.
Coded Fields 1.
Item (41--Title:
Root cause is not included.
2.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(V).
l 0-23 m._.
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