ML20203F139
| ML20203F139 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/16/1986 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 8604250042 | |
| Download: ML20203F139 (52) | |
Text
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16 APR 1986 Docket No. 50-333 Power Authority of the State of New York James A. FitzPatrick Nuclear Power Plant ATTN: Mr. Radford J. Converse Resident Manager P. O. Box 41 Lycoming, New York 13093 Gentlemen:
Subject:
Assessment of the Quality of Licensee Event Reports (LERs) -
J. A. FitzPatrick As part of the SALP process, the NRC Office for Analysis and Evaluation of Operational Data (AE00) evaluated LERs submitted during the recent SALP assess-ment period for the J. A. FitzPatrick Nuclear Power Plant. The assessments (portions attached) were performed using a methodology similar to that des-cribed in NUREG/CR-4178, "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73."
The NRC considers it important to achieve uniform, high quality LERs from all operating power reactors to enable licensees and AE00 to effectively identify
" precursor events" and emerging trends or patterns of potential safety signif-icance. Generic studies triggered by events reported at specific units can lead to improvements in the level of reactor safety only if the available data-base is uniform and of high quality.
Based on a limited sample, AEOD concludes that the FitzPatrick LERs sampled were generally of marginally acceptable quality.
I invite you to review the attached analyses and be prepared to discuss the evaluation and potential improvements to your event reporting system at the SALP management meeting scheduled for April 25, 1986.
giginal Signed by:
William F. Kane, Deputy Director Division of Reactor Projects
Enclosure:
As Stated P604250042 860416
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W. Sinclair, President J. P. Bayne, First Executive Vice President and Chief Operations Officer A. Klausmann, Vice President - Quality Assurance and Reliability R. L. Patch, Quality Assurance Superintendent George M. Wilverding, Chairman, Safety Review Committee Gerald C.~Goldstein, Assistant General Counsel NRC Licensing Project Manager Dept. of Public Service, State of New York Public Document Room (PDR)
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o AEOD INPUT TO SALP REVIEW f0R FITZPATRICK Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Fitzpatrick during the July 1, 1984 to November 30, 1985 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 15 LERs, which represents more than half of the 29 LERs on file at the time the evaluation was started.
See Appendix A for the 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-1022, and Supplem qts 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 of each LER.
The LER specific comments serve two purposes: (1,) they point out what the analyst considered to be the specific deficienci,es 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 i
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r that were reviewed. Likewise, the text, abstract, and coded fields scores serve two purposes; (1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for tne 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 secre).
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 connents 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 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
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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).
Although the purpose of this evaluation was to assess the quality of the contents of the individual LERs selected for review, the analysts often make other observations that they believe should be brought to the attention of the licensee. The following discussion addresses sose general observations that were noticed for Fitzpatrick during the evaluation of that unit's LERs.
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All eight of the LERs involving a component failure do not provide information in the text that would allow the reader to adequately identify the component. The manufacturer and model number (or other appropriate identification) should be included in the text of every LER involving component failure or any time that the design of a component is suspected to have contributed to the event (Requirement 50.73(b)(2)(11)(L)].
Plant operating conditions prior to the event are not included in the text of over half of the selected LERs. Mode of operation and power level (if applicable) or other appropriate information should be provided even though it may sometimes be difficult to see how this information is applicable to the event being discussed.
The safety system train unavailability time is not provided for six of the nine LERs involving safety system failure.
This deficiency could pos-ibly have been avoided had adequate dates and times been provided throughout the text.
Information concerning previous similar events is not provided in any of the evaluated LERs. The LER number of previous similar events should be provided or the text should indicate that there have been no previous similar events.
Energy Industry Identification System (EIIS) component function identifier and/or system codes are not provided in the text of the evaluated LERs.
The text presentations can be improved by adopting the use of an outline format as is suggested in NUREG-1022, Supplement 2 and defining all but the most common acronyms in the text.
Plant specific designators 1
should always be defined.
1 Ttt root cause information in the abstract is marginal even though this same information received a high (89%) score in the text.
This indicates that the root cause information from the text is not being adequately summarized in the abstract.
r General Observations A review of the 29 LERs that were on file at the time the evaluation started indicated two facts:
(1) seven of the 29 LERs consisted of an abstract with no text and one author (licensee contact) wrote five of these, and (2) there were 12 reports involving a reactor trip and 15 reports involving component failure for a period of approximately 15 months. No conclusions are drawn from this information other than to say that LERs consisting of only an abstract should be limited to those events that are extremely simple and which involve only a few of the requirements.
It is very difficult to adequately discuss the average event in the space available for an abstract.
Discussion of Specific Deficiencies Table 1 presents the average scores for the sample of LERs evaluated for Fitzpatrick.
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.
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, Fitzpatrick's average scores for the text of the LERs that were evaluated is 6.2 out of a possible 10 points.
From Table 3 it can be seen that the text score actually resulted from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(11)(A)] to text presentation. The percent scores in the text summary section of Table 3 provide an indication of how well each text requirement was addressed by the licensee for the 15 LERs that were evaluated.
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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
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o indicate that the licenset probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the licensee probably understands the basic requirement but has either (1) excluded certain less significant information from most of the LERs concerning that requirement and/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 0 in order to determine why he received less than a perfect 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 most significant deficiencies in the abstract and coded fields are discussed.
Fourteen of the 15 LERs failed to include a discussion of the safety consequences or implications of the event [ Requirement 50.73(b)(3)].
Each LER should include information that answers the following questions:
(1) Could this event have occurred under a more severe set of initial conditions, conditions that could have made the consequences worse?
(2) What other systems and/or procedures were available to mitigate the possible consequences of the event?
Simply stating that there were not safety consequences is not adequate.
Information must be provided indicating how such a conclusion was reached.
Dates and times are considered to be inadequate for 12 of the 15 LERs evaluat'ed.
The text should include dates and times for all najor occurrences discussed in the LER, occurrences such as discovertes, scrams, safety system actuations, safety syster.s being secured, components or systems being declared inoperable anc being placed back in service, and the
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plant being placed in a safe and strole condition. M'any events take place over a long time period and only by providing dates'and/or times can the reader adequately understand the overall event, t
Two of the abstracts contain information that is not in the text. All information deemed necessary in an abstract should be discussed in the text.
Four abstracts contain undefined acronyms or plant specific designators.
The main deficiency in the area of coded fields involves the title, Item (4). None of the titles indicate the root cause. Most titles do include the result of the event (i.e., why the event was required to be reported). An example of a title that only addressed result might be
" Reactor Scram".
This is inadequate in thtt the cause and link are not provided. A more appropriate title might be "Inadvertant Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title the reader knows the cause was either personnel or procedural and testing was the link between the cause and result.
Table 4 provides a summary of the areas that need improvement for the Fitzpatrick LERs.
For more specific information concerning deficiencies the reader should refer t: the information presented in Appendices C and D.
General guidance corterning these requirements can be found in NUREG-1022, Supplement so. 2.
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TABLE 1.
SUMMARY
OF SCORES FOR FITZPATRICK Averaae Hiah low Text 6.2 7.8 3.2 Abstract 8.5 9.6 6.2 Coded Fields 8.7 9.1 7.4 Overall 7.lb 8.2 4.7 a.
See Appendix B for a summary of scores for each LER that was evaluated.
b.
Overall Average - 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.
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j TABLE 3.
LER REQUIREMENT PERCENTAGE SCORES FOR FITZPATRICK TEXT Percentage Recutrements f50.73(b)1 - Descriptions Scores ( )#
1 (2)(ii)(A) - - Plant condition prior to event 47 (15) j (2)(ii)(B) - - Inoperable equipment that contributed b
i (2)(ii)(C) - - Date(s) and approximate times 38 (15) l (2)(ii)(D) - - Root cause and intermediate cause(s) 89 (15) i (2)(11)(E) - - Mode, mechanism, and effect 95 (8)
(2)(ii)(F) - - EIIS Codes 7 (15)
(2)(ii)(G) - - Secondary function affected b
(2)(11)(H) - - Estimate of unavailability 39 (9)
[
(2)(11)(1) - - Method of discovery 80 (15)-
(2)(11)(J)(1) - Operator actions affecting course 100 (9) l (2)(ii)(J)(2) - Personnel error (procedural deficiency) 85 (6) l-(2)(11)(K) - - Safety system responses 86 (7)
(2)(11)(L) - - Manufacturer and model no. information 9 (8)
(3)
Assessment of safety consequences 11 (15) l (4)
Corrective actions 85 (15)
(5)
Previous similar event information 0 (15)
(2)(1) - - - - Text presentation 64 (15)
ABSTRACT Percentage a
Requirements f50.73(b)(111 - Descriptions
_ Scores ( l
- Major occurrences (Immediate cause and effect 100 (15) informatien)
- Description of plant, system, component, and/or 99 (12)
I personnel responses
- Root cause information 77 (15) t
- Corrective Action information 82 (15)
- Abstract presentation 70 (15)
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TABLE 3.
(continued)
CODED FIELOS Percentage Item Number (s) - Description Scores ( )
1, 2, and 3 - Fartlity name (unit no.), docket no. and 100 (15) page number (s) 4 - - - - - - Title 57 (15) 5, 6, and 7 - Event date, LER No., and report date 97 (15) 8 - - - - - - Other facilities involved 100 (15) 9 and 10 - - Operating mode and power level 98 (15)
I 11 - - - - - Reporting requirements 97 (15) 12 - - - - - Licensee contact information 96 (15) 13 - - - - - Coded component f ailure infornetton 100 (15) 14 and 15 - - Supplemental report information 93 (15)
I a.
Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all LERs, therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.
b.
A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER.
It is always given 100%
if it is provided and is always considered "not applicable" when it is not, t
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TABLE 4.
AREAS MOST NEEDING IMPROVEMENT FOR FITZPATRICK LERS 1
Areas Comments Safety assessment The main deficiency is the failure to include any safety assessment.
All LERs should have safety assessments which address the consequences of the event occurring under more severe conditions (if possible) and the availability of other systems to mitigate the consequences of the event.
Date and approximate times Inclusion of dates and approximate times is needed in all LERs to aid the reader in following the progression of the event.
Manufacturer and model number Component identification information information should be included in the text whenever a component fails or is suspected to have contributed to the event because of the design.
Opera itions Details such as power levels, mode prior ts
'nt names and in some cases temperature and pressure are required in the text.
Safety train ui allability Sufficient dates and times should be included in the text to enable the
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reader to determine the length of time that a safety system train or component was out of service.
Previous similar events Previous similar events should be referenced (LER number) or the text should state that there are none.
EIIS codes Codes for each component or system referred to in the text should be provided.
Text presentation The use of an outline format would aid in presenting the information in a clear understandable manner.
Acronyms should be defined.
TA8LE 4.
(continued)
Areas Comments i-Abstracts Root cause information from the text should be better summarized.
Abstracts should summarize only that information that is discussed in the text.
If additional information is deemed necessary in an abstract, it should be included in the text.
Coded Fields a.
Titles Titles should be written such that they better describe the event.
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particular, include the root cause of the event in the title.
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REFERENCES 1.
- 8. S. Anderson, C. F. Miller, 8. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 10 RAFT), 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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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR FITZPATRICK
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TABLE A-1.
LER SAMPLE SELECTION FOR FITZPATRICK (333)
LER Sample Number LER Number Comments 1
84-015-00 2
84-018-00 SCRAM 3
84-021-00 4
84-023-00 SCRAM 5
85-001-00 6
85-002-00 7
85-003-00 ESF 8
85-008-00 9
85-013-00 10 85-014-01 11 85-015-00 12 85-017-00 SCRAM 13 85-019-00 SCRAM 14 85-022-00 SCRAM 15 85-023-00 ESF
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a APPENDIX 8 EVALUATION SCORES Of INDIVIDUAL LERS FOR FITZPATRICK
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e TA8tE B-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR FITlPATRICK a
LER Sample Number I
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 Text 5.4 7.2 6.3 6.3 3.2 7.2 6.8 3.3 6.7 6.6 5.0 6.7 7.8 7.2 6.8 Abstract 9.0
- 7. 5 9.4 9.5
- 7. 6 9.5 9.6 6.2
- 7. 0 9.5 8.5 8.5 9.0
- 7. 8 9.5 Coded F ields 9.0 9.0 9.0 8.9 9.0 9.0 8.9 9.0 8.3 7.5 7.4 9.0 8.3 9.1 9.0 Overall 6.8
- 7. 5 7.5 7.5 5.1 8.1 7.9 4.7
- 7. 0 7.6 6.1 7.4 8.2
- 7. 6 7.8 a
LER Sample Number 17 18 19 20 21 22 23 25 26 27 28 29 30 AVERAGE lest 6.2 Abstract 8.5 Coded Fields 8.7 Overall 7.1 See Appendia A for a list of the corresponding LER numbers.
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4 APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR FITZPATRICK i
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TABLI C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR FITZPATRICK Number of LERs with Deficiencies ard Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)D 50.73(b)(2)(11)(A)--Plant operating 10 (15) conditions before the event were not included or were inadequate.
50.73(b)(2)(11)(B)--Discussion of the status 0 (1) of the structures, components, or systems j
that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.
50.73(b)(2)(11)(C)--Failure to include 12 (15) suf ficient date and/or time inforsation, a.
Date information was insufficient.
12 b.
Time information was insufficient.
11 50.73(b)(2)(11)(D)--The root cause and/or 4 (15) 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 1
included or was inadequate c.
Cause of personnel error was not 1
included or was inadequate.
l 50.73(b)(2)(iil(E)--The failure mode, 0 (8) 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 c.
Effect (consequence) was not included or was inadequate.
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73Lbl(2)Lii)(F)--The Energy Industry 14 (15)
Ident1fhcatlon System component function identifier for each component or system was not included.
1 50.73(b)(2)(ii)(G)--for a failure of a 0 (0)
I component with multiple functions, a list of systems or secondary functions which j
i were also affected was not included or was inadequate.
l 50.73(b)(2)(11)(H)--for a failure that 6 (9) l 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.
l 50.73(b)(2)(11)(I)--The method of discovery 2 (15) of each component failure, system failure, f
personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each I
component failure was not included or was inadequate b.
Method of discovery for each system 0
failure was not included or was inadequate c.
Method of discovery for each 1
personnel error was not included or was inadequate d.
Method of discovery for each 0
procedural error was not included or was inadequate.
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e TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph l
Description of Deficiencies and Observations Totals' Totals (
)I 50.73(b)(2)(11)(J)(1)--Operator actions that 0 (9) affected the course of the event including operator errors and/or procedural deficiencies were not included or w2re inadequate.
50.73(b)(2)(ii)(J)(21 -The discussion of 3 (6) t each personnel error was not included or wa l
inadequate.
a.
OBSERVATION: A personnel error was 0
implie by the text, but was not l
explice'iy stated.
l b.
50.73tb):?)(ii)(J)(2)(il--Discussion 2
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as to vne'ber the personnel error was
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cog..itiv? r.7 procedural was not inclede! or was inadequate, c.
50.'<3!91(?)fii)(J)(2)(iil--Discussion 2
as to Jtsther the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate.
d.
50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0
of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
e.
50.73(b)(2)(ti)(J)(2)(iv)--Discussion 1
of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operatcr, other utility personnel) was not included or was inadequate.
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A TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(11)(K)--Automatic and/or manual 1 (7) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 8 (8) model number of each failed component was not included or was inadequate.
50.73(b)(3)--An assessment of the safety 14 (15) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION:
The availability of 2
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 5 (15) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future
.as not included or was inadequate.
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TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)D a.
A discussion of actions required to O
correct the problem (e.g., return the component or system to operation condition or correct the personnel error) was not included or was inadequate, b.
A discussion of actions required to 1
reduce the prcbability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c.
OBSERVATION: A discussion of actions 3
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same penufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information concerning previous 15 (15) similar events was not included or was inadequate.
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TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(1)--Text presentation 7 (15) inadequacies, a.
OBSERVATION: A diagram would have 0
aided in understanding the text discussion.
b.
Text contained undefined acronyms 6
and/or plant specific designators.
I c.
The text contains other specific 1
deficiencies relating to the readability.
The "sub-paragraph total" is a tabulation of specific deficiencies or a.
observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both r; ate 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.
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f TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR FITZPATRICK Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph b
Description of Deficiencies and Observations Totals' Totals (
l A summary of occurrences (immediate cause 0 (15) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 0 (12) responses was not included or was inadequate.
a.
Summary of plant responses was not included or was inadequate.
b.
Summary of system responses was not included or was inadequate.
c.
Summary of personnel responses was not included or was inadequate.
A summary of the root cause of the event 5 (15) was not included or was inadequate.
A summary of the corrective actions taken or 6 (15) planned as a result of the event was not included or was inadequate.
s
TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph 8
Description of Deficiencies and Observations Totals Totals (
)
Abstract presentation inadequacies 6 (15) a.
OBSERVATION: The abstract contains 2
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 4
acronyms and/or plant specific designators.
d.
The abstract contains other specific 1
deficiencies (i.e., poor summarization, contradictions, etc.)
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
- b.
The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
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TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR FITZPATRICK Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals #
Totals (
l b
Facility Name 0 (15) 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 (15) incorrect.
Page Number was not included or was 0 (15) incorrect.
Title was left blank or was inadequate 15 (15) a.
Root cause was not given in title 15 b.
Result (effect) was not given in title I
c.
Link was not given in title 5
Event Date 1 (15) a.
Date not included or was incorrect.
O b.
Discovery date given instead of event 1
date.
LER Number was not included or was incorrect 0 (15)
Report Date 0 (15) a.
Date not included b.
OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).
Other Facilities information in field is 0 (15) inconsistent with text and/or abstract.
Operating Mode was not included or was 1 (15) inconsistent with text or abstract.
I p_--
y_.
c <
TABLE C-3.
(continued)
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 0 (15) inconsistent with text or abstract Reporting Requirements 2 (15) a.
The reason for checking the "0THER" 0
requirement was not specified in the abstract and/or text.
b.
OBSERVATION:
It would have been more 0
appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It would have been 2
appropriate to report this event under additional unchecked paragraphs.
' Licensee Contact 3 (15) 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 0 (15) a.
One or more component failure sub-fields were left blank.
b.
Cause, system, and/or component code is inconsistent with text.
c.
Component failure field contains data when no component failure occurred.
d.
Component failure occurred but entire field left blank.
TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations __ Totals Totals (
)
Supplemental Report 1 (15) a.
Neither "Yes"/"No" block of the O
supplemental report field was checked.
b.
The block checked was inconsistent 1
with the text.
Expected submission date information is 0 (15) inconsistent with the block checked in Item (14).
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
0
/
e
.r
.)
4 e
APPENDIX 0 LER COMMENT SHEETS FOR FITZPATRICK
/
a.
-.7
TABLE 0-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 1.
LER Number: 84-015-00 l
Scores: Text - 5.4 Abstract - 9.0 Coded Fields - 9.0 Overall - 6.8 Text 1.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(C)--Date and approximate time l
information for occurrences is inadequate.
3.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function l
identifie-(s) and/or system name of each component or l
system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
l 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.
l 6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
L OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
7.
50.73(b)(51--Information concerning previous similar events is not included.
8.
50.73(b)(5)--If no previous similar events are known, the text should so state.
l 9.
Acronym (s) and/or plant specific designator (s) are l
undefined.
Abstract 1.
Abstract contains acronym (s) an'd/or plant sp~ecific designator (s) which are undefined.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
1 l
l l
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Commerts 2.
LER Number: 84-018-00 Scores: Text = 7.2 Abstract - 7.5 Coded Fields 9.0 Overall = 7.5 Text 1.
50.73(b)(2)(11)(C)--Dates and approximate times information for occurrences is not included.
2.
50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
5.
50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
/
e 4
y
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 3.
LER Number: 84-021-00 Scores: Text = 6.3 Abstract = 9.4 Coded Fields - 9.0 Overall = 7.5 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract that was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadequate.
I 3.
50.73(b)(2)(11)(C)--Date and time information for occurrences is not included.
4.
50.73(b)(2){it)(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.
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
If a pipe joint did fail, what would be the consequences and what systems would be available to mitigate these consequences?
6.
50.73(b)(5)--Information concerning previous similar events is not included.
7.
50.73(b)(5)--If no previous similar events are known, the text should 50 state.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included.
i
=
---.-,w
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Ccmments 4.
LER Number: 84-023-00 Scores: Text = 6.3 Abstract = 9.5 Coded Fields - 8.9 Overall = 7.5 Text 1.
50.73(b)(2)(11)(C)--Date and approximate time information for occurrences is not included.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
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.
50.73(b)(5)--Information concerning previous similar events is not included.
6.
50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1.
No comment.
Coded Fields 1.
Item (12)--Position title is not included.
2.
Item (4)--Title:
Root cause is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 5.
LER Number: 85-001-00 Scores:
Text - 3.2 Abstract - 7.6 Coded Fields - 9.0 Overall - 5.1 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters.
The following comments apply to the abstract that was evaluated as if it were a text.
2.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
3.
_50.73(b)(2)(11)(C)--Date and approximate time information for occurrences is not included.
4.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion for each component failure is inadequate.
The text should indicate the reason why the DC coil failed.
5.
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.
6.
50.73(b)(2)(ii)(L )--Identificat tor (e.g. manuf acturer and model no.) of the failed component (s) discussed in the text is not included.
7.
50.73(b)(31--01scussion of the assessment of the safety consequences and implications of the event is inadequate.
The text should be specific as to how the ADS and RCIC would prevent serious consequences.
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.
8.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
The replacement of the coil was only implied from the statement thal the system had to be de-energized for repairs.
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 5.
LER Number: 85-001-00 (continued) 9.
A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.
10.
50.73(b)(5)--Information concerning previous similar events is not included, 11.
50.73(b)(5)--If no previous similar events are known, the text should so state.
f
- 12. Acronym (s) and/or plant specific designator (s) are undefined.
I Abstract 1.
The root cause and corrective action summary are deficient for the same reasons as the text.
-t 2.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
/
=
- - - ~ ~
+n.n
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 6.
LER Number:
85-002-00 Scores:
Text = 7.2 Abstract - 9.5 Coded Fields = 9.0 Overall - 8.1 Text 1.
50.73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the personnel error is not included.
3.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
5.
_50.73(b)(5)--If no previous similar events are known, the text should so state.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
O e
f
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 7.
LER Number: 85-003-00 Scores: Text = 6.8 Abstract - 9.6 Coded Fields = 8.9 Overall = 7.9 Text 1.
50.73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event should include the power level.
2.
50.73(b)(2)(11)(C)--Date and time information for occurrences is inadequate.
3.
50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed system is not included.
When were EDGD and ESW Pump B declared operable?
4.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
5.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is inadequate.
Information concerning the manufacturer and model number of the phase overcurrent trip device should have been provided.
6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The safety consequences are not discussed.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
8.
50.73(b)(5)--If no previous similar events are known, the text should so state.
+
9.
Acronym (s) and/or plant specific designator (s) are undef ir;ed.
Abstract 1.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.
~
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
2.
Item (12)--Position title is not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 8.
LER Number:
85-008-00 Scores: Text - 3.3 Abstract = 6.2 Coded Fields - 9.0 Overall - 4.7 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters.
The following comments apply to the abstract that was evaluated as if it were a text.
2.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
3.
50.73(b)(2)(ii)(C)--Date and approximate time information for occurrences is not included.
4.
50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion for each component failure is not included.
5.
_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.
6.
50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is not included.
7.
50.73(b)(2)(11)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
8.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
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.
9.
50.73(b)(41--Discussion of corr'ective actions taken or planned is inadequate. What repairs were-performed on the valve? What was done to prevent recurrence?
10.
50.73(b)(5)--Information concerning previous similar events is not included.
r TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 8.
LER Number: 85-008-00 (continued) 11.
50.73(b)(51--If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
2.
50.73(b)(ll--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment number 10 above.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
/
o
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments 9.
LER Number: 85-013-00 Scores: Text = 6.7 Abstract = 7.0 Coded Fields - 8.3 Overall = 7.0 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)92)(ii)(C)--The dates should be more specific.
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)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
5.
50.73(b)(2)J11)(I)--Discussion of the method of discovery of the component failure is not included.
6.
50.73(b)(2)(ii)(L)--A model number or some other unique identification is needed to adequately identify the failed component.
7.
50.73(b)(31--0BSERVATION: 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.
8.
50.73(b)(4)--0BSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.
9.
50.73(b)(5)--Information concerning previous similar events is not included.
10.
50.73(b)(5)--If no previous similar events are known, the text should so state.
11.
Acronym (s) and/or plant specift.c designator (s) are undefined.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
i
=
t TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333) l Section Comments l
9.
LER Number:
85-013-00 (continued)
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.
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.
l 2.
Item (5)--A more appropriate event date would be the date the valves were removed (i.e.,
October ??, 1985). The 30 day clock would not start until March 4, 1985 (discovery date) since this is i
when the technical specification violation was discovered.
l l
l-1
TABLE 0-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 10. LER Number:
85-014-01 Scores: Text = 6.6 Abstract = 9.5 Coded Fields 7.5 Overall - 7.6 Text 1.
50.73(b)(2)(11)(C)--Dates information for occurrences is inadequate.
2.
50.73(b)(2)(ii)(C)--Approximate times information for occurrences is not included.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system namt of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(H)--A time estinate of the unavailability of the failed system is not included.
5.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
6.
50.73(b)(31--Discussion of the assessment of the l
safety consequences and implications of the event is not included.
7.
50.73(b)(4)--0BSERVATION:
Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.
8.
50.73(b,)151--Information concerning previous similar events is not included.
9.
50.73(b)(5)--If no previous similar events are known, the text should so state.
C
/
o i
,,,--m
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZFATRICK (333)
Section Comments
- 10. LER Number: 85-014-01 (continued)
Abstract 4.
No comment.
' Coded Fields 1.
Item (4)--It is not clear why the word " Generic" appears in the title, based on the discussion provided in the text and abstract.
2.
Item (4)--Title:
Link and result are not included.
3.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
/
e
TABLE 0-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 11. LER Number: 85-015-00 Scores: Text = 5.0 Abstract = 8.5 Coded Fields - 7.4 Overall = 6.3 Text 1.
50.73(b)(2)(ii)(Al--01scussion of plant operating conditions before the event is inadequate.
Power level should have been given in the text.
2.
50.73(b)(2)(11)(C)--Date and time information for occurrences is inadequate.
3.
50.73(b)(2)(11)(D)--Root cause is implied to be setpoint drift but is not discussed.
4.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
5.
50.73(b)(3)--01scussion of the assessment of the i
safety consequences and implications of the event is not included.
6.
Was the setpoint band change (last sentences) a procedure change and/or a Technical Specification change?
7.
50.73(b)(5)--Information concerning previous similar events is not included.
8.
50.73(b)(51--If no previous similar events are known, the text should so state.
9.
Some conclusions reached are inconsistent with the facts presented. The presentation leaves the reader with a number of unanswered questions. For example, "Is tne established band given in T.S. Table 3.2-3?",
"How was the nine hour figure, in the next to last sentence, determined when three days later the D and F channels were found out of tolerance high?", and "If the out of tolerance time with the mode switch in RUN was a concern, why wasn't tpe surveillance done prior to going to RUN7".
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 11. LER Number: 85-015-00 (continued)
Abstract 1.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.
Coded Fields 1.
Item (4)--Title:
Root cause and result are not included. The title should isdicate the type instruments (i.e., APRMs) involved.
2.
Item (91--Operating mode is not included.
3.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
4.
Item (12)--Position title is not included.
/
o l
o TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 12. LER Number: 85-017-00 Scores: Text = 6.7 Abstract = 8.5 Coded Fields = 9.0 Overall = 7.4 Text 1.
50.73(b)(2)(ii)(Dl--The root and/or intermediate cause discussion for the personnel error and the loose wire on the ramp generator is not included.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
_50.73(b)(2)(ti)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is inadequate.
J 4.
50.73(b)(2)(11)(J)(2)(11)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is inadequate.
The text does not state if procedures were violated or incorrect.
5.
Discussion is not adequate (see comment 4) to allow the reader to determine whether or not the corrective actions are appropriate.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
- 7.
50.73(b)f5)--If no previous similar events are known, the text should 50 state.
8.
Acronym (s) and/or plant specific designator (s) are undefined.
t L
- o i
I TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 12. LER Number:
85-017-00 (continued)
Abstract
.l.
50.73(b)(11--Summary of root cause is inadequate (i.e., root cause of the personnel error).
I 2.
50.73(b)(ll--Summary of corrective actions taken or planned as a result of the event is not included.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
)
1 F
'I 4
x
/
o k
4
- e 3
xo
~s V
ts TARiE D-1.
SPECIFIC LER COMMENTS'FOR FITZPATRICK (333)
._,,_S%,$on Comments 13,. LER Number: 85-019-00
- Scores
- Text - 7.8 Abstract - 9.0 Coded Fields - 8.3 Overall - 8.2 3
_ q I
I Text 1.
50.73(b)(2)(11)(A)--The plant operating conditions should be stated explicitly, t
2.
50.73(b)(2)(ii)(Fj.--The Energy Industry
~
Identification System component function s.,,
identifier (s) and/or. system name of each component or
~
system referred to in the LER is not included.
I 3.
50.73(b)(2?(ii)(H)--A time estimate of the i
unavailability of the failed system is not included.
i 4.
50.73(b)(3)--Discussion of the assessment of the safety conseqdences and implications of the event is l
not included.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
Sb.73(b)(5)--Ifnopfevioussimilareventsareknown, L
6.
the text st;ould so state.
Abstract 1.
No comment.
Coded F,1, elds 1.
Item (4)--Title:
Root cause is not included.
i 2.
Item (141--The block' checked is inconsistent with information in the text. The results of the reviews should be repor,1ed'in a supplement.
'l
'4
.,j
\\
w
o
- o TABLE D-1.
SPECIFIC LER COMMENTS FOR FIT 2 PATRICK (333)
Section Comments
- 14. LER Number: 85-022-00 Scores: Text - 7.2 Abstract - 7.8 Coded Fields - 9.1 Overall - 7.6 Text 1.
50.73(b)(2)(ii)(C)--Date and time information for occurrences is inadequate.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed system is not included.
4.
50.73(b)(2)(11)(J)(2)--The discussion of the personnel error is not clear as to whether the maintenance personnel were cognitive of their error or whether they were following approved p edures at the time of the error.
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)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
8.
50.73(b)(5)--If no previous similar events are known, the text should so state.
9.
Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1.
50.73(b)(1)--The root cause should be stated to be personnel error in rewiring the solenoids.
- Likewise, the corrective action should be more specific (i.e.,
do administrative controls constitute a procedural change?).
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
O 1
TABLE D-1.
SPECIFIC LER COMMENTS FOR FITZPATRICK (333)
Section Comments
- 15. LER Number: 85-023-00 Scores: Text = 6.8 Abstract = 9.5 Coded Fields - 9.0 Overall = 7.8 Text 1.
Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 characters. The following comments apply to the abstract that was evaluated as if it were a text.
2.
50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event is not included.
3.
50.73(b)(2)(11)(C)--Dates and approximate times information for occurrences is not included.
4.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
5.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
8.
50.73(b)(5)--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.
.