ML20203B110

From kanterella
Jump to navigation Jump to search
Forwards Assessment of Lers,Including Results for Input Into SALP Rept for Feb 1985 - Jan 1986.LERs of Above Average Quality
ML20203B110
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/13/1986
From: Hebdon F
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20203B101 List:
References
NUDOCS 8607180019
Download: ML20203B110 (57)
v • d • e


Text

_. ._

[

DESIG! LATED ORIGIllAL 0 5""'4g M ~tw M d 7 gg, j NUCLEAR REG L T RY COMMIS bhifi d W b DYJ WASHINGTON, D. C. 20S55 O (

t /

l

'+4 * * * < * /

I233 # " i!; I? 2' ' I* f pyg 79. M6 WL.-

MEMORANDUM FOR: Dennis Kirsch, Deputy Director Division of Reactor Safety and Projects Region V FROM: Frederick J. Hebdon, Deputy Director Office for Analysis and Evaluation of Operational Data

SUBJECT:

SALP ASSESSMENT INPUT FOR WASHINGTON NUCLEAR 2 In his memos dated July 1,1985 and July 24, 1985, Jack Heltemes described a new methodology that we are using to assess the- quality of LERs submitted by licensees.

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

Enclosed (Attachment B) is the assessment of the LERs from Washington Nuclear 2.

Attachment A is a brief summary of the rbsults of this assessment. You may find

, this summary-useful as a. direct input into the SALP report.

In general, we find these LERs to be of above average quality based on the -

requirements contained in 10 CFR 50.73. The enclosed report provides the basis for this finding. We believe that it would be helpful if a copy of the enclosed report were provided to the licensee so that the specific deficiencies noted can be corrected in future LERs.

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

t - -

M LQ. {

Frederick J. He6 don, Deputy Director Office for Analysis and Evaluation of Operational Data

Enclosures:

As Stated cc: P. Qualls, RV i C. Miller, INEL (w/o encl.)

8607180019 860702

~

PDR ADOCK 05000397 >

G PDR

SUMMARY

An evaluation of the content and quality of a representative sampie of the Licensee Event Reports (LERs) submitted by Washington Nuclear 2 (WNP-2) during the February 1,1985 to January 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performance using a refinement of the basic methodology presented in NUREG/CR-4178. fhe results of this evaluation indicate that WNP-2 has an overall average LER score of 8.0 of a possible 10 points, thus ranking it 4th out of the 35 units that have been evaluated to date using this methodology.

Only one weakness was identified that could possibly be significant. The lack of details for those discussions involving personnel error, prompts concern as to whether or not the corrective actions address the root cause of the personnel or procedural errors.

Overall, the WNP-2 LERs are very good. They are presented in an excellent outline format similar to the one recommended in NUREG-1022, Supplement No. 2 and most of the text requirements are adequately addressed. Had the abstracts contained more information, the WNP-2 LERs would have received an even higher overall average score.

f Attachment A l

i

AE0D INPUT TO SALP REVIEW FOR WASHINGTON NUCLEAR 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Washington Nuclear 2 during the February 1, 1985 to January 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the unit's LERs was evaluated using a refinement of the basic methodology presented in I

NUREG/CR-4178 . The sample consists of 21 LERs for Washington Nuclear 2, which is half of the LERs that were on file at the time the evaluation was started. See Appendix A for a list of the LER numbers in the sample.

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

Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the requirements of NUREG-10222 , and Supplements 13 and 2 4 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 of each LER.

(YTVICW t 16MT 8 -

The LER specific comments serve two purposes: (1) they point out what i

the analysts considered to be the specific deficiencies or o.bservations ~

concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that were reviewed. Likewise, the scores serve two purposes: (1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for the overall score determined for each LER. The overall score for each ~

LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields 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 B), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

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

deficiency when assigning scores.

Discussion of Results -

l A discussion of the analysts' conclusions concerning LER quality are presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of each units performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b).

Table 1 presents the average scores for the sample of LERs evaluated

, for Washington Nuclear 2. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directl,y. l 9

- - - .- , , , - - - _ . - - . _ _ _ v., - - , , , , . . _--

t 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 scores from other units that have been evaluated using this methodology are provided in Table 2. Additional units will be added to Table 2 as they are evaluated. Table 3 and Appendix Table B-1 provide a.

summary of the information that is the basis for the average scores in Table 1. For example, Washington Nuclear 2's average score for the text of the LERs that were evaluated was 8.9 out of a possible 10 points. From _

Table 3 it can be seen that a text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation. The percentage scores in the text summary section of Table 3 provide an indication of how well each text requirement was addressed by the licensee for the 21 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 3 will quickly point out where the licensee is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate T

that the licensee 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 -

the requirement in one or two of the selected LERs. The licensee should review the LER specific comments presented in Appendix D in order to determine why he received less than a aerfect score for certain requirements. The text requirements with a score of less than 75 are discussed below in their order of importance. In addition, the deficiencies in the abstracts and coded fields are discussed.

I The first requirement to be discussed [ Requirement 50.73(b)(2)(ii)(J)(2)]

actually had an acceptable score of 75%. This requirement, however, is one of the more important and is discussed because the score is at .

_ .-._m..

l 4

a TABLE 1.

SUMMARY

OF SCORES FOR WASHINGTON NUCLEAR 2 .

Averaae Hiah low Text 8.9 9.7 6.7 Abstract 6.2 9.8 2.5 Coded Fields 8.2 9.5 . 6.0 i Overall 8.0b 9.4 6.5

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 i Fields Average.

i l

)

i l

~

1 e

l

)

1 i

O 4

l 6 1

- - . , . --,,,---e- -

,,n.. ,, .--, , ,,, -.,y-, ,w..- --,,g-n- _, , , , - - . ,, - , ,- ,

TABLE 2. COMPARISON OF AVERAGE SCORES FROM OTHER UNITS Coded End SALP Text Abstract Fields Overall Unit Name a Period verage Averaae Averaae Averaae

1. Salem 2 9-30-u 2.9 8.9 8.6 8.9
2. Salem 1 9-30-85 8.6 9.0 8.9 8.8
3. Palisades 10-31-85 8.4 8.3 8.5 8.4 .,
4. Washington Nuclear 2 1-31-86 8.9 6.2 8.2 8.0
5. LaSalle 2 9-30-85 8.0 7.7 8.6 8.0
6. LaSalle 1 9-30-85 7.9 8.1 8.6 8.0
7. Browns Ferry 3 11-30-85 7.8 8.1 8.5 8.0
8. Catawba 1 9-30-85 8.0 7.4 8.6 7.9
9. Trojan 10-31-85 7.8 7.6 8.9 7.8 l 10. Browns Ferry 1 11-30-85 7.8 7.6 8.3 7.8
11. Pilgrim 1 10-31-85 7.6 7.8 8.1 7.7
12. 8eaver Valley 1 9-30-85 7.2 8.3 8.8 7.7 l 13. Kewaunee 12-31-85 7.3 7.8 8.7 7.6
14. Quad Cities 1 9-30-85 7.9 6.5 8.4 7.5
15. Quad Cities 2 9-30-85 7.9 6.4 8.6 7.5 .'
16. Maine Yankee 10-31-85 7.5 7.3 8.5 7.5
17. Byron 1 10-31-85 7.5 7.3 8.3 7.5
18. Browns Ferry 2 11-30-85 7.3 7.7 8.5 7.5
19. Indian Point 3 11-30-85 7.1 7.7 8.5 7.5
20. Brunswick 1 10-31-85 6.8 8.5 8.5 7.5
21. Summer 12-31-85 7.1 7.7 8.3 7.4
22. Sequoyah 1 11-30-85 7.8 5.9 8.3 7.3

TABLE 2. (continued)

' Coded End SALP Text Abstract Fields Overall a

Unit Name Period Averaae Averaae Averaae Averaae

23. Waterford 3 12-31-85 7.8 5.9 8.2 7.3
24. Dresden 3 9-30-85 7.2 7.3 8.0 7.3
25. Palo Verde 1 9-30-85 6.8 7.7 8.4 7.3 ..
26. D. C. Cook 2 9-30-85 6.7 8.3 8.4 7.3
27. D. C. Cook 1 9-30-85 6.4 8.3 8.4 7.2
28. Sequoyah 2 11-30-85 8.0 4.6 8.9 7.1
29. Zion 2 9-30-85 7.2 6.7 8.2 7.1
30. Robinson 2 10-31-85 7.1 6.9 7.8 7.1 I
31. Vermont Yankee 10-18-85 7.0 7.0 8.2 7.1
32. Dresden 2 9-30-85 6.9 7.3 7.9 7.1 l 33. Fitzpatrick 11-30-85 6.2 8.5 8.7 7.1 l 34. Brunswick 2 10-31-85 6.0 7.9 8.8 6.8

't

35. Zion 1 9-30-85 6.0 7.5 7.9 6.6 e
a. Units are ordered by overall average score.

TABLE 3. LER REQUIREMENT PERCENTAGE SCORES FOR WASHINGTON NUCLEAR 2

~

TEXT Percentage Reautrements f50.73(b)1 - Descriptions a Scores ( 1 (2)(ii)(A) - - Plant condition prior to event 95 (21)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 88 (21)

(2)(11)(D) - - Root cause and intermediate cause(s) 90 (21) 4 (2)(11)(E) - - Mode, mechanism, and effect 100 (3) j (2)(11)(F) - - EIIS Codes 57 (21)

(2)(ii)(G) - - Secondary function affected b (2)(11)(H) - - Estimate of unavailability 67 (6)

(2)(ii)(I) - - Method of discovery 83 (21)

(2)(11)(J)(1) - Operator actions affecting course 100 (13)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 75 (14)

(2)(ii)(K) - - Safety system responses 94 (9)

(2)(ii)(L) - - Manufacturer and model no. information 33 (3)

(3) -----

Assessment of safety consequences 89 (21)

(4) -----

Corrective actions 92 (21) i (5) -----

Previous similar event information 100 (21)

(2)(i) - - - - Text presentation 90 (21) i i

j A8STRACT

] Percentage l

Reautrements f50.73(b)(1)1 - Descriptions Scores ( l a

- Major occurrences (Immediate cause and effect 99 (21) -

information)

- Description of plant, system, component, and/or 77 (11) l personnel responses

- Root cause information 58 (21)

- Corrective Action infornation 32 (21)

- Abstract presentation 53 (21) 4 f

s i

l i

TABLE 3. (continued)

. i l

CODED FIELOS Percentage Item Number (s) - DescriDtion Scores ( ) l 1, 2, and 3 - Facility name (unit no.), docket no. and 94 (21) page number (s) 4 - - - - - - Title 50 (21) 4 5, 6, and 7 - Event date, LER No., and report date 96 (21) 8 - - - - - - Other facilities involved 100 (21) 9 and 10 - - Operating mode and power level 86 (21) 11 - - - - - Reporting requirements 82 (21) 12 - - - - - Licensee contact information 100 (21) 13 - - - - - Coded component failure information 83 (21) 14 and 15 - - Supplemental report information 100 (21)

a. Percentage scores are the result of dividing the total points for a j

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.

l e'

l l

. the low end of the accepted range. The problem does not appear to be the failure to identify and mention personnel error, but the failure to fully ,

discuss all aspects of the error as required. Fourteen LERs appeared to involve personnel error and nine of these were found to be deficient. Of these nine LERs, four LERs failed to indicate if the personnel error was cognitive or procedural (Requirement 50.73(b)(2)(11)(J)(2)(1)); four LERs failed to discuss whether the error was the result of a procedural error, was contrary to a procedure, or was not covered by a procedure

[ Requirement 50.73(b)(2)(ii)(J)(2)(ii)]; and three LERs failed to indicate '

the type of personnel involved in the error

[ Requirement 50.73(b)(2)(ii)(J)(2)(iv)]. When personnel error is involved,  ;

be sure to discuss all aspects of the error as required by the rule. l Two LERs of the three involving component failures, failed to identify the failed component in the text [ Requirement 50.73(b)(2)(ii)(L)).

Adequate identification usually consists of manufacturer's name and a model i number. This information is important for the identification of possible generic problems throughout the nuclear industry.

Two of the six LERs involving safety system trains did not provide adequate dates and/or times in the text so that the unavailability time of the train could be determined [ Requirement 50.73(b)(2)(ii)(H)]. This kind of information is required as it becomes part of the generic data necessary to perform probabilistic risk assessments (PRAs). Adequate attention paid to Requirement 50.73(b)(2)(ii)(C), which requires dates and times of _-

occurrences, will usually ensure that this requirement is met.

Nine of the twenty-one Washington Nuclear 2 LERs failed to include the Energy Industry Identification System (EIIS) codes for each system or component referred to in the text. These codes are required by Requirement 50.73(b)(2)(ii)(F). It did appear that most of these omissions occurred early in the SALP period, and that later in the period this error was corrected.

w J

l The abstract's root cause and corrective action summaries were i unacceptable with scores of 58% and 32%, respectively. While the abstract

  • is not supposed to be as detailed as the text, root cause and corrective actions are important and should be included in every abstract. These low scores appear to be caused by not fully using the space available for the

! abstract (1400 character limit). The abstract presentation cf 53% also I

reflects the failure to fully use the abstract field (found in 3 LERs).

Although some LERs did not fully use the abstract field, three LERs y mentioned information in the abstract that was not discussed in the text. l Since an abstract is a summary, any information in the abstract should be i

discussed in the text. Washington Nuclear 2 has a good overall average '

score, but a look at Table 2 shows that the score would have been even

~~

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

Item (4). Twenty LER titles did not indicate root cause, nine failed to in'lude e the link (i.e., circumstances or conditions which tie the root cause to the result), and seven failed to provide information concerning

! the result of the event (i.e., why the event was required to ae reported).

l The result is considered to be the most important part or the title and should always be included. However, the link and root cause are nearly as j

important and should also be included to provide an adequate title for the readers. 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 i

provided. A more appropriate title might be " Inadvertent Relay Actuation -

f During Surveillance Test LOP-1 Causes Reactor Scram". From this title the reader knows the cause was either personnel or procedural and testing contributed to the event.

Table 4 provides a summary of the areas that need improvement for Washington Nuclear 2 LERs. For more specific information concerning deficiencies the reader should refer to the information presented in Appendices C and D. General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 2.

l y 1 1

TABLE 4. AREAS MOST NEEDING IMPROVEMENT FOR WASHINGTON NUCLEAR 2 LERS Areas Comments Personnel error While the score was adequate, all details of the error should be discussed.

Manufacturer and model number Component identification information  ;

information should be included in the text for each component failure or whenever a component is suspected of contributing to the event because of its design.

Safety train unavailability Sufficient dates and times should be included in the text to enable the reader to determine the length of time that safety system trains or 1 components were out of service.

EIIS codes Codes for each component and system involved in the event should be provided. Improvement was noted later in the SALP period.

Abstracts Root cause and corrective action information was often inadequate or was not included. Abstracts should not contain information which was .

not discussed in the text. Use the full field to provide the needed information.

1 Coded fields

a. Titles Titles should be written such that they better describe the event. In particular, include the root cause of the event.

4 e* l l

l

- .=

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 (URAtl), NURtG/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.

1

,e" s

l g

APPENDIX A LER SAMPLE SELECTION INFORMATION '

FOR WASHINGTON NUCLEAR 2 a

. . . . . - . ~ . . . . . - . . ~ . .. . . . ..

l

'. 'i l

TABLE A-1. LER SAMPLE SELECTION FOR WASHINGTON NUCLEAR 2 LER Sample Number LER Number Comments 1 85-012-00 ESF 2 85-013-00 SCRAM 3 85-016-00 SCRAM

__. 4 85-019-00 +

5 85-021-00 ESF 6 85-022-00 7 85-023-02 8 85-027-00 ESF 9 85-028-00 l 10 85-031-00 SCRAM i

11 , 85-034-00 ESF 12 85-037-00 13 85-039-00 14 85-041-00 15 85-043-00 16 85-045-00 ESF 17 85-046-00 SCRAM 18 85-048-00 19 85-051-00 20 85-053-00 SCRAM 21 85-054-00 t

}

9 e4 9

4

- - g APPENDIX 8 EVALUATION SCORES OF INDIVIDUAL LERS FOR WASHINGTON NUCLEAR 2 l

l l

p' s

. . . . . . . . _, . . = _ . _ _. ._. _ - _

TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERs FOR WASHINGTON NUCLEAR 2 '

  • I LER Sample Number a 1 2 3 4 5 6 7 8 9 10 11 12 13' 14 15

~

16_

Text 8.2 9.0 8.5 6.7 9.4 9.0 9.4 9.5 9.7 8.5 9.7 9.7 9.4 9.5 9.0 7.3 Abstract 2.5 6.5 5.5 5.4 9.8 4.4 8.1 5.0 7.5 6.0 9.5 6.3 6.3 6.0 7.5 5.5 Coded i

Fields 8.9 6.9 8.4 8.9 8.4 8.4 8.1 7. 9 7. 5 8.9 6.4 6.0 8.5 8.0 8.5 9.0

, Overall 6.6 8.1 7. 6 6.5 9.4 7. 6 8.9 8.0 8.8 7. 8 9.3 8.3 8.4 8.3 8.5 6.9 a

, LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE  ;

Text 8.7 7.8 8.3 9.1 - 9. 3 '

8.9 Abstract 6.0 7.5 7.0 6.5 2.5 -- -- -- -- -- -- -- -- --

6.2 Coded Fields 8.0 9.0 8.0 9.5 8.5 -- -- -- -- -- -- -- -- --

8.2 Overall 7. 8 7. 8 7.9 8.3 .7.2 -- -- -- -- -- -- -- -- --

8.0

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

i 4

9

- __ _ _ _ _____ v w -

. _ _______u

b k A 5p A

+

4 e

4 APPENDIX C DEFICIENCY AND OBSERVATION I

COUNTS FOR WASHINGTON NUCLEAR 2 4

en g/

6 t __

TABLE C-1.

TEXT DEFICIENCIES AND OBSERVATIONS FOR WASHINGTON NUCLEAR 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( b l

50.73(b)(2)(ii)(Al--Plant operating conditions before the event were not 2 (21) included or were inadequate. 4 50.73(b)(2)(ii)(B)--Discussion of the status 0 (3) 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)(Cl--Failure to include 6 (21) sufficient date and/or time information.

a. Date information was insufficient. 3
b. Time information was insufficient. 4 50.73(b)(2)(ii)(D)--The root cause and/or 7 (21) intermediate failure, system failure, or personnel error was not included or was inadequate.
a. Cause of component failure was not 2 included or was inadequate
b. Cause of system failure was not 0 included or was inadequate
c. Cause of personnel error was not 5 included or was inadequate. '

50.73(b)(2)(ii)(E)--The failure mode, mechanism (immediate cause), and/or effect 0 (3)

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

i l

TABLE C-1. (continued)

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

a '

Description of Deficiencies and Observations Totals Totals ( )b 50.73(b)(2)(ii)(F)--The Energy Industry 9 (21)

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 (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 2 (6) 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 4 (21) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

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

failure was not included or was inadequate

c. Method of discovery for each 1 personnel error was I.ot included or was inadequate
d. Method of discovery for each 0 procedural error was not included or was inadequate.

,e-6

TABLE C-1. (continued)

Number of LERs with -

4 Deficiencies and Observations i Sub-paragraph Paragraph 1 Description of Deficiencies and Observations Totals

  • Totals ( )

50.73?b)(2)(ii)(J)(1)--Operator actions that 0 (13)

), affec"ed the course of the event including i operator errors and/or procedural

  • deficiencies were not included or were

, inadequate.

i l 50.73(b)(2)(ii){J)(2)--The discussion of 9 (14) each personnel error was not included or was inadequate.

a. OBSERVATION: A personnel error was 1 implied by the text, but was not explicitly stated.
b. 50.73(b)(2)(ii)(J)(2)(i)--Discussion 4 1 as to whether the personnel error was cognitive or procedural was not included or was inadequate.

l c. 50.73(b)(2)(ii)(2)(2)(ii)--Discussion 4 as to whether the personnel error was

contrary to an approved procedure, was 1

a direct result of an error in an approved procedure, or was associated

with an activity or task that was not i 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 4

error was not included or was inadequate.

e. 50.73(b)(2)(iilf])(2)(iv)--Discussion 3 of the type of personnel involved
(i.e., contractor personnel, utility j licensed operator, utility nonlicensed i operator, other utility personnel) was
not included or was inadequate.

I

\ s-L

,. - , _ . , - - - . . . . , - , . .-- - . . - _ . . _ - ., . _ _ . - ,. . . , . , - , - _ , _ . . . _ L- -

TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations ,

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

50.73(b)(2)(ii)(K)--Automatic and/or manual 1 (9)

! safety system responses were not included or .*

were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 2 (3) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 6 (21) consequences and implications of the event was not included or was inadequate.  ;

a. OBSERVATION: The availability of 5 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 6 (21) 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.

S

- , . - - .. - ., -, , , . , . , .e ,

1

'. I TABLE C-1. (continued)

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

a. A discussion of actions required to 0 correct the' problem (e.g., return the component or system to operation ,

condition or correct the personnel error) was not included or was inadequate.

b. A discussion of actions required to 3 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c. OBSERVATION: A discussion of actions 1 required to prevent similar failures in similar and/or other systems (e.g.,

correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.

50.73(b)(51--Information concerning previous similar events was not included or was 0 (21) inadequate.

y' -

l

TABLE C-1. (continued)

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

Totals ( )

50.73(b)(2)(i)--Text presentation inadequacies. 6 (21) s

a. OBSERVATION: A diagram would have 1 aided in understanding the text discussion.
b. Text contained undefined acronyms 5 and/or plant specific designators.
c. The text contains other specific 1 deficiencies relating to the readability.
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.

Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total, b.

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

)

TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR WASHINGTON NUCLEAR 2 i

i i

Number of LERs with Deficiencies and Observations  ;

Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b A summary of occurrences (immediate cause 0 (21) and effect) was not included or was inadequate -

A summary of plant, system, and/or personnel 5 (11) responses was not included or was J

inadequate,

a. Summary of plant responses was not 1 inclur'ed 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.

I A summary of the root cause of the event 11 (21) was not included or was inadequate.

A summary of the corrective actions taken or 18 (21) planned as a result of the event was not included or was inadequate.

)

i j

.l y

p/

. l

, 1 1ABLE C-2. (continued) i Number of LERs with Deficiencies and Observations 4

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

Abstract presentation inadequacies 17 (21) ,

4

a. OBSERVATION: The abstract contains 3 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 0 acronyms and/or plant specific '

designators.

d. The abstract contains other specific 17 deficiencies (i.e., poor summarization, contradictions, etc.)
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do <

not necessarily add up to the paragraph total.

l 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, e

a

___.______._______________.______._____________.________________u

[ ..

TA8LE C-3. ~ CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR l WASHINGTON NUCLEAR 2 '

i 4

Number of LERs with Deficiencies and '

l

_ Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

  • Totals ( )
Facility Name - - - -

0 (21) ,

i

a. Unit number was not included or incorrect.

! b. Name was not included or was incorrect.

c. Additional unit numbers were included j but not required.
Docket Number was not included or was incorrect. 0 (21)

l t

i Page Number was not included or was

! incorrect. 1 (21)

Title was left blank or was inadequate 20 (21) 4 i

a. . Root cause was not given in title. 20

) b. Result (effect) was not given in title 7

c. Link was not given in title 9

{ Event Date 0 (21) +

! a. Date not included or was incorrect.

j b. Discovery date given instead of event i date. ,'

i LER Number was not included or was incorrect _

0 (21)

{ Report Date 3 (21)

a. Date not included 0
b. OBSERVATION: Report date was not 3 i within thirty days of event date (or 1

discovery date if appropriate).

I Other Facilities information in field is 0 (21) inconsistent with text and/or abstract.

l l Operating Mode was not included or was

inconsistent with text or abstract, 2 (21) i l

}

\

~,

TABLE C-3. (continued)

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

Power level was not included or was 2 (21) inconsistent with text or abstract Reporting Requirements 7 (21)

a. The reason for checking the "0THER" 4 requirement was not specified in the abstract and/or text.
b. OBSERVATION: It would have been more 1 appropriate to report the event under a different paragraph.
c. OBSERVATION: It would have been 3 appropriate to report this event under additional unchecked paragraphs.

Licensee Contact 0 (21)

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 9 (21) <

a. One or more component failure 0 sub-fields were left blank.
b. Cause, system, and/or component code 0 .'

is inconsistent with text.

c. Component failure field contains data 7 when no component failure occurred.
d. Component failure occurred but entire 2 field left blank.

i l

~.

TABLE C-3. (continued)

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

  • Totals ( )

Supplemental Report 0 (21)

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 (21) inconsistent with the block checked in Item (14).

I

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 4

number of LERs for which a certain requirement was considered applicable.

i e

4 f

pf e

,, ,, . - - - - . - - - . - , , . , , - - w a- -- -

4 S

6 9

l 4

d l

l APPENDIX D  !

LER COMMENT SHEETS FOR WASHINGTON NUCLEAR 2 8

9 pf' s

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

1. LER Number: 85-012-00 '

Scores: Text - 8.2 Abstract = 2.5 Coded Fields - 8.9 Overall = 6.6 i Text 1. 50.73(b)(2)(11)(C)--Date information for occurrences <

is not included. - -

d

2. 50.73(b)(2)(ii)(F)--The Energy Industry identificAtton 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)(2)(ii)--Although the corrective actions indicate that the procedure will be changed, the text does not clarify whether or not the personnel were following an approved procedure at the time.
4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.

OBSERVATION: The availability of cther systems or components capable of mitigating the consecuences of the event should be discussed. If no other systems or components are available, the text should so state.

f 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.

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

Abstract 1. 50.73(b)(1)--Summary of root cause and personnel responses are not included.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
3. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

w' s

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397) 4 Section Comments

1. LER Number: 85-012-00 (continued)

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

2. Item (13)--Component failure field contains data when 1 no component failure occurred.

I i.

1 l

i l

I .

~

s l

i I

i f

I i

4

- , - - -,-,--m-,,---,.,-.-- --.--r-------------,--v-,-- ------.-,-,n . wrr -- - ------- ,-,,- - e-~ ~ - --.-.,---,-,,----w, w- -, ,n n - -

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

' t TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

2. LER Number: 85-013-00 4

Scores: Text - 9.0 Abstract = 6.5 Coded Fields - 6.9 Overall = 8.1 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry i Identification System component function i identifier (s) and/or system name of_each component or l system referred to in the LER is not included.

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

t

3. 50.73(b)(2)(11)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is not included.

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

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

planned as a result of the event is not included.

3. Abstract does not adequately summarize the text.

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

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

t

2. Item (71--0BSERVATION: Report date is not within thirty days of event date (or discovery date if i -

{ appropriate).

j 3. Item (11)--The reason for checking the "other"

) requirement is not specified in the abstract and/or text.

., 4. Item (13)--Component failure field contains data when j

no component failure occurred.

I i

i

\ ><*

l i

1

i l

TABLE D-1.  !

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section _

Comments

3. LER Number: 85-016-00 Scores: Text = 8.5 Abstract - 5.5 Coded Fields - 8.4 Overall = 7.6

, Text 1.

50.73(b)(2)(ii)(C)--Time information for occurrences is inadequate. What were the approximate times for the trip and plant stabilization?. - .. *

2. 50.73Jb)(2)Lii)(F)--TheEnerghIndustry Ident1ficat9on 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)(2)--Discussion of personnel error is inadequate.

4.

50.73(b)(2)(ii)(3)(2)())--Discussion as to whether the personnel error was cognitive or procedural is not included.

5.

50.73(b)(2)(ii)(X)--Discussion of automatic and/or manual safety system responses is inadequate. Which safety systems operated as required?

6.

50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. It appears that some procedural changes are needed to ensure proper valving of differential pressure transmitters. -

7. The informaticn is presented in a good format.

Abstract 1. 50.73(b)(1)--Summary of plant and system responses is

  • inadequate. .
2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
3. Abstract does not adequately summarize the text.

Additional space is available within the abstract

~ field to provide the necessary information but it was not utilized.

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

2. Item (13)--Component failure field contains data when no component failure occurred. Information need not i

be provided in this field for faulted components'.'

i 1

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments 1

4. LER Number: 85-019-00 Scores: Text = 6.7 Abstract = 5.4 Coded Fields - 8.9 Overall = 6.5 Text 1. 50.73(b)(2)(ii)(0)--The text should be more specific as to how the instruction was transferred wrong and it got by approval chains. More information should e i also be given about how the statement "at all times" would not be effective when put in the Step 37 instead of Step 36,
2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function i

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

t P

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)--D)scussion of personnel error is inadequate. As noted in comment 1 above the personnel error (i.e., method for handling deviations) should be discussed further.
5. 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. .

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)(41--Discussion of corrective actions taken or planned is inadequate. For example, immediate corrective action might include establishing the

' temperature monitoring required by the procedure. As  !

noted in comments 1 and 4 above, further investigation of the method of handling deviations may be needed (e.g., change approval or control procedure for deviations).

s

l

. 1 l

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

4. LER Number: 85-019-00 (continued)
7. Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1. 50.73(b)(1)--The root cause summary is. deficient for "

the same reasons as given in the text comments.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.

OBSERVATION: The abstract contains information not

included in the text. The abstract is intended to be l a summary of the text; therefore, the text should discuss all information summarized in the abstract.

The method of discovery of the personnel error (text comment 3) was given in the abstract but not the text.

l 3. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

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

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

.c J

h i

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

5. LER Number: 85-021-00 Scores: Text = 9.4 Abstract = 9.8 Coded Fields = 8.4 Overall = 9.4 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 -4 system referred to in the LER is not included.

Abstract 1. No comments.

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

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

e

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397) --

, Section Comments

6. LER Number: 85-022-00 Scores: Text - 9.0 Abstract - 4.4 Coded Fields - 8.4 Overall = 7.6 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for the Action Statement not being fornelly entered is not included. -- - -

d

2. 50.73fb)(2)Jii)(F)--The Energy Industry Tdentaricat1on 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)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. How was it determined that the backup
systems were operable if the action statement was not entered?
4. 50.73(b)(4)--Discussion of corrective actions taken

' or planned is inadequate. What was done to ensure that actions statements would be entered for future

events?

Abstract 1. 50.73(b)(1)--Sur,amary of root cause is inadequate, l

i 2. 50.73(b)(1)--Summary of corrective actions taken or l planned as a result of the event is not included.

1

3. Abstract does not adequately summarize the text.

j

' Additional space is available within the abstract field to provide the necessary information but it was -

not utilized.

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

2. Item (13)--Component failure field contains data when no component failure occurred. Information need not be provided in this field for faulted components.

)

l

' e I

_ ,__.._.m . - _ _ _ _ _. , _ . _ . - _ - - _ . _ . _ _ - _ _ _ - . _ _ . _ , , . _ _ _ . _ _ _ , _ , _ _ . _ . _ _ _ . . _ _ _ . _ . _ . . . _ _

l r

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)*

Section Comments

7. LER Number: 85-023-02 l Scores: Text = 9.4 Abstract = 8.1 Coded Fields - 8.1 Overall = 8.9 Text 1. 50.73(b)(2)(ii)(C)--Additional dates would help clarify the progression of the event.

j

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

I Abstract 1. 50.73(b)(11--Summary of root cause is inadequate. 4 The abstract should indicate that miscommunication was the main reason for not including some items on the fire watch.

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

Coded Fields 1.

Item (14)--The title does not include the result (missed fire watch) nor the root cause (personnel error).

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

par'agraph(s) 50.73(a)(2)(1).' .

3. Item (13)--Revision 2 did not include any information on failed components as did Revisions 0 and 1; Revision 2 appears to be correct, since no failed components are discussed, t

w

&S

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

8. LER Number: 85-027-00 Scores: Text = 9.5 Abstract - 5.0 Coded Fields - 7.9 Overall = 8.0 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.

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

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
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 (41--Title: Root cause and link are not included.

2. Item (11)--The reason for checking the "other" requirement is not specified in the abstract and/or text.
3. Item (13)--Component failure field contains data when no component failure occurred.

a

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

9. LER Number: 85-028-00 .

Scores: Text = 9.7 Abstract = 7.5 Coded Fields = 7.5 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for the unsealed penetration going unnoticed is not included. . -

2. The text should indicate what information is planned to be provided in the supplemental report.

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

Coded Fields 1. Item (41--Title: Root cause and result (technical specification violation) are not included.

2. Item (91--Operating mode is not included, i
3. Item (101--Power level is not included.

d e

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

10. LER Number: 85-031-00 Scores: Text = 8.5 Abstract = 6.0 Coded Fields - 8.9 Overall = 7.8 Text 1. 50.73(b)(2)(ii)(C)--Date and time information for occurrences is not included.
2. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an dpproved procedure, or Was associated With an activity or task that was not covered by an approved procedure is not included.
3. 50.73(b)(2)(iiL(J)(21(iv)--Discussion of the type of personnel invo'ved (t.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
4. Acronym (s) and/or plant specific designator (s) are 2

undefined. Include a brief description of Range 1 and Range 3.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.

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

03SERVATION: 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.

See text comments 1 and 3.

Coded Fields 1. Item (3)--On page 1 the field should be 1 of 3 not 1 of 2.

2. Item (41--Title: Root cause and link are not included, w*

n

O TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

11. LER Number: 85-034-00 i

Scores: Text - 9.7 Abstract - 9.5 Coded Fields - 6.4 Overall = 9.3 Text 1. No comments.

Abstract 1. No comments. _

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

2. Item (111--The reason for checking the "other" requirement is not specified in the abstract and/or text.
3. Item (13)--Component failure field contains data when no component failure occurred.

4 e

g/

I TABLE 0-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

12. LER Number: 85-037-00 i

Scores: Text = 9.7 Abstract - 6.3 Coded Fields - 6.0 Overall - 8'.3 Text 1. Plant operating modes should be defined for the reader.

d

2. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.

The date and time that both breakers were retested and returned to service should be provided.

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

2. Abstract does not adequately summarize the text.

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

Coded Fields 1. Docket number and page number left off page 1.

2. Item (4)--Title: Root cause and result are not included.
3. Item (9)--Operating mode is not included.
4. Item (101--Power level is not included. <
5. Item (ll)--0BSERVATION: It appears it would have
  • been more appropriate to report this event under paragraph (s) 50.73(a)(2)(v). -

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

13. LER Number: 85-039-00 Scores: Text - 9.4 Abstract = 6.3 Coded Fields - 8.5 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(A)--Including a brief description of the operating mode number on the first reference to the mode number, as done in this LER,.is good. Other .

LERs have had the mode description further down in the text.

Abstract 1. 50.73(b)(1)--The root cause and corrective action summary was inadequate. The abstract should indicate that the review process for modifications was inadequate and summarize the changes made to the review process.

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

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

2. Item (71--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).

n e

1 j

i TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments l

14. LER Number: 85-041-00 Scores: Text = 9.5 Abstract - 6.0 Coded Fields - 8.0 Overall - 8.3 Text 1. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Will the personnel responsible for reconnecting the cable during the start-up test program be notified and counseled?

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

2. 50 73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

Corrective actions beyond the immediate corrective actions was not summarized in the abstract.

3. Abstract does not adequately summarize the text.

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

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

l s

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

15. LER Number: 85-043-00 Scores: Text = 9.0 Abstract - 7.5 Coded Fields - 8.5 Overall = 8.'5 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for the barrier not being installed and not being discovered earlier 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.

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

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.

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

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

_ , - , ~ _ , . . -

TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

16. LER Number: 85-045-00 Scores: Text - 7.3 Abstract = 5.5 Coded Fields = 9.0 Overall = 6.9 Text 1. 50.73(b)(2)(ii)(A)--Include a brief description of the reactor mode number in the Plant Conditions section. _
2. 50.73(b)(2)(ii)(C)--Additional times are needed.
3. 50.73(b)(2)(ii)(I)--How was the air in the line discovered?
4. 50.73(b)(2)(ii)(J)(2)--The next two comments refer to the apparent personnel problem when the air entered the lines.
5. 50.73(b)(2)(ii)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is not included.
6. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
7. _50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What will be done to prevent air from entering the sensing line of the Reactor Water Cleanup system in the future or in ,

another system where a similar filling procedure may be used. .

Abstract 1. 50.73(b)(1)--Summary of system responses is inadequate. The abstract should indicate that the sensing line was found to have air in it.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.

s

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

~.,

TABLE D-1.

, SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

16. LER Number: 85-045-00 (continued) i
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 ab: tract. .

The abstract mentions a decrease in' system pressure not mentioned in the text.

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

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

9 O

b b

. . . - . ,, .. ~ - . , - . . , , ,. , ..,n . - , ,

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section __ Comments

17. LER Number: 85-046-00

~

Scores: Text - 8.7 Abstract = 6.0 Coded Fields = 8.0 Overall - 7.8 Text 1. 50.73(b)(2)(ii)(C)--Apprxoximate times information for occurrences is inadequate. What time was the fire discovered? ---

4

2. 50.73(b)(2)Jii)(I)--Discussion of the method of discovery of the pump fire is not included. How did the Health Phy'ics Technician discover the fire?
3. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. See text comment number 5 and number 6.

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.

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

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

Actions taken to repair the reactor feedwater pump is not included.

3. Abstract does not adequately summarize the text.

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

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

t L

1 l

TABLE 0-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

17. LER Number: 85-046-00 (continued)
2. Iter (ll)--The reason for checking the "other" requirement is not specified in the abstract and/or text.

^ ^ ~ ~ ~ ~ ~~

3. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(iv).
4. Item (13)--Component failure occurred but entire field is blank.

C* s e;{

w M

g/

6

v s 1

TABLE 0-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments I

18. LER Number: 85-048-00 i

Scores: Text - 7.8 Abstract - 7.5 Coded Fields - 9.0 Overall = 7.8 Text 1. 50.73(b)(2)(ii)(H)--A time estimate of the i

unavailability of the failed system is inadequate.

.._____ __ _. .__ Adequate dates and times should have been provided to y allow the reader to know how lon] the transmitters had air entrapped in them (e.g., when were the sensing lines filled after maintenance outage M-37).

t

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate.

cause discussion for the trapped air is inadequate.

3. 50.73(b)(2)(ii)(J)J2)--It appears that personnel error is involved ln this event, but it is not discussed. i
4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is j inadequate.

OBSERVATION: The availability of other systems or components capable of mitigating the consequences of 4

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 i considered the most severe conditions, the text should so state. .'

5. A logicel transition does not exist between all ideas. The first two paragraphs under "Further Corrective Action" appear to be part of the " Event" i discussion rather than corrective actions. I 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)--Summary of root cause is inadequate.

See text comment 2.

i

.- . - - . - - - = - . . - . . - - , - - -, - , . - , , - - . , , - . . . - , , . - . . - - - -

TABLE 0-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

18. LER Number: 85-048-00 (continued)
2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The

" caution signs" should have been mentioned in the

_ , _ _ .. abstract. .._-. -.... - -

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

, Coded Fields 1. Item (4)--Title: Root cause and result (technical specification violation) are not included.

r I e 1

m s

_ _ _ . . . _ _ -. _ , _ , . . . . _ _ _ . - . _ _ . , - - , _ . _ _ ,, .m.. , _ . _ ,

6 TABLE D-1.

SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

19. LER Number: 85-051-00 4

Scores: Text = 8.3 Abstract = 7.0 Coded fields = 8.0 Overall = 7.9 Text 1. 50.73(b)(2)(ii)(A)--Include a brief description of the reactor mode number in the Plant Condition

_ __ ___ _ _.section. -

2. 50.73(b)(2)(ii)(I)--How did the Instrument and Control technicians find the error?

)

3. 50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadequate.
4. 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.

The discussion should indicate the type of personnel who committed the error.

5. 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 compor.ents 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.

6. Acronym (s) and/or plant specific designator (s) are undefined. The acronym RPS (Reactor Protection System) should probably be defined in the text.

i Abstract 1. 50.73(b)(1)--Summary of root cause is inadequate.  !

The summary should indicate that procedural deficiency was a contributing factor.

I

..- i

l TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

19. LER Number: 85-051-00 (continued) ,
2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The summary should give lona term corrective actions

~~-~'~

'(i.~e., further personnel training and procedural -

change). .

3. 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. It is preferable not to use acronyms in the title.

2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(ii) and/or 50.73(a)(2)(v).

e a

l l

TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

20. LER Number: 85-053-00 i

Scores: Text - 9.1 Abstract - 6.5 Coded Fields - 9.5 Overall - 8.3 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for the component failure is not

. - . . - , _ _ .__. included. Why was the instrument isolation valve .<

1 faulty?

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. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.

Coded Fields 1. Item (13)--Component failure occurred but entire field is blank.

t o

o, s .

I TABLE D-1. SPECIFIC LER COMMENTS FOR WASHINGTON NUCLEAR 2 (397)

Section Comments

21. LER Number: 85-054-00 r

Scores: Text = 9.3 Abstract = 2.5 Coded Fields = 8.5 Overall = 7.2 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for the operator not noticing the

-~~~~-~- r ema i n i n g i t ems i s n o t - i n c l u d e d . ~ ~-- - - - - -

2. 50.73(b)(2)(ii)(J)(2)(il--Discussion as to whether the personnel error was cognitive or procedural is not included.
3. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. If it was possible for the operator to overlook the remaining items, should the format of the document be changed to help prevent  ;

recurrence of this problem?

Abstract 1. 50.73(b)(11--Summary of root cause is not included.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
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. One sentence can not adequately summarize the event. <

Coded Fields 1. Item (4)--Title: Root cause and result (technical i specification violation) are not included. .

l t

Retrieved from "https://kanterella.com/w/index.php?title=ML20203B110&oldid=3070103"