ML20203N249
| ML20203N249 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/16/1986 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| NUDOCS 8609230243 | |
| Download: ML20203N249 (50) | |
Text
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SEP 161986 Docket / License: 50-213/DPR-61 Connecticut Yankee Atomic Power Company.
ATTN: Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06101 Gentlemen:
Subject:
LER Assessment The purpose of this letter is to forward an NRC evaluation of Haddam Neck Licensee Event Reports (LERs) to you for consideration in regard to improving LERs.
Attach-ment A is a brief summary of results of the evaluation, while Attachment B is a detailed assessment of the Haddam Neck LERs.
No violations of NRC requirements have been cited based on the LER evaluation and no reply to this letter is required.
The evaluation was performed by the NRC Office for Analysis and Evaluation of Operational Data (AE00), and was an input to the last NRC Systematic Assessment of Licensee Performance (SALP) for Haddam Neck.
The AE0D report indicates that
'LERs are acceptable overall, with room for improvement in the discussion of the safety significance of events.
Descriptions of the AE0D findings are included in the enclosed summary and evaluation report.
Sincerely, Origina1 Signes g,
y Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects Attachments:
A.
AE0D Summary of LER Report B.
AE0D Report on LERs cc w/encls:
R. Graves, Plant Superintendent D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilitie's Licensing E. J. Mroczka, Vice President, Nuclear Operations y
Gerald Garfield, Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut t l 8609230243 860916 i
f PDR ADOCK 05000213 f
S PDR
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i Connecticut' Yankee Atomic Power Company 2 bec w/ enc 1:
' Region I~ Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP M. McBride, RI, Pilgrim
.J. Shedlosky, SRI, Millstone 1&2 T. Rebelowski, SRI, Millstone 3 J. Akstulewicz, LPM, NRR Robert J. Bores, DRSS RI:DRP RI:DRP R
r'a Mc be g7(ier We e m,e os OF ICIAL RECORD COPY
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SUMMARY
An evaluation of the content and ouality of a representative sample of the Licensee Event Reports (LERs) submitted by Haddam Neck during the March 1,1985 to February 28, 1986 Systematic Assessment of Licensee Performance (SALP) period was' performed using a refinement of the basic I
methodology presented in NUREG/CR-4178. The results of this evaluation indicate that Haddam Neck has an overall average LER sccre of 8.0 out of a 1
possible 10 points, thus ranking it 20th out of the 49 units (i.e.,
licensees) that have been evaluated to date using this methodology.
The principle weakness identified, in terms of plant safety significance, involves the safety consecuence discussions. Deficiencies in
.the safety consecuence discussion prompts concern as to whether or not events are being evaluated such that the possible consecuences of the event, had it occurred under a different set of initial conditions, are identified.
4 A strong point for the Haddam Neck LERs is the corrective action discussions [ Requirement 50.73(b)(2)(ii)(0)]. Most LERs adequately addressed recurrence prevention.
l Some general observations resulting from the evaluation involve:
(1) possible differences in the level of training or review, (2) an apparent high percentage of LERs involving component failures, and (3) a j
problem with the LER numbering process.
i
'l It appears that the level of training for the large number of personnel responsible for writing LERs and/or the consistency of the review process may not be adeauate to ensure that the licensee's overall LER score is consistent with his potential, O
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.1 Seven of the _ ten LERs involve component failure but the possible 1,
significance of this (if any) cannot be ascertained from the number of LERs reviewed.-
It was also noted that two LERs concerning entirely different events were submitted under the same LER number (i.e., 85-009-00).
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.1 AE0D INPUT TO SALP REVIEW FOR HADDAM NECK Introduction In. order to evaluate the overall Quality of the contents of'the Licensee Event Reports (LERs) submitted by Haddam Neck during the March 1,1985 to February 28, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the licensee's LERs was evaluated using a refinement of'the basic methodology I
presented in NUREG/CR-4178. The sample consists of a total of 10 LERs for the unit, which represents 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. Th ore, 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 2
the requirements of NUREG-1022, and Supplements 13 and 24 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 l
determining a score (0-10 points) for the text, abstract, and coded fields i
of each LER.
The LER specific comments serve two purposes:
(1) they point out what the analysts considered to be the specific deficiencies or observations
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concerning the information pertaining to the event, and (2) they provide a l
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1 basis for a count of general deficiencies for the overall sample of LERs that was reviewed. Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for the overall score detemined 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 auality evaluation are divided into two categories:
(1) detailed information and (2) summary inforrr.ation. 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 tas flexibility to consider the magnitude of a deficiency when assigning scores.
Although the purpose of this evaluation was to assess the Content of the individual LERs selected for review, the analysts often make other observations which they believe should be brought to the attention of the licensee. The following discussion addresses a general observation that was noted during the evaluation.
General Observation During the sample selection process, it was noted that there were ten different irdividuals named as licensee contacts for. the twenty LERs available in the file for the SALP period.
(Note: It is assumed for the purpose of this discussion that these licensee contacts were in fact the primary autnors of these LERs.) The number of people assigned to write LERs should be of no conseauence provided that each person has I.he same i
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level of training concerning LER requirements and/or the level of LER review prior to submittal is consistent. Unfortunately, as the number of writer and reviewers increases it apparently becomes more difficult to ensure that each writer or reviewer is trained to the desired level. Past reviews have indicated this trend and dats from this review tends to
. support the hypothesis.
A total of ten LERS written by nine different individuals were evaluated. The average overall score for these LERs was 8.0 out of a possible 10.0; however, a review of the individual scores shows that four of the scores were significantly higher than 8.0 while three others were significantly lower (see Table B-1 in Appendix B). This wide spread in individual scores implies that all writers may not have the same level of understanding concerning the LER requirements and/or the review process may not comoare each LER against a common set of criteria.
Another general observation was noted during the evaluation. Seven of the ten LERs involved component failure. Although this percentage appears high compared to other evaluations, the analysts do not attempt to suggest a possible reason.
A final observation noted is that two LERs, involving different events, were submitted with identical LER numbers (i.e., 85-009-00, LER sample nt.ibers 4 and 5). This can cause problems for those assigned to enter data into the LER computer file.
In the worst case, if it is not noticed that these events are different, data from the first report submitted could possibly be " written over" wnen the second report is entered in the data file.
Discussion of Results A discussion of the analysts' conclusions concerning LER ouality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such
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t represent the analysts' assessment of the licensee's performance (on a S
scale of 0 to 10) in submitting LERs that meet the reauirements of i
Table 1 presents the average scores for the sample of LERs evaluated for Haddam Neck. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.
In order to place the scores provided in Table 1 in perspective, the scores from other licensees that have been evaluated using the current methodology are provided in Table 2.
Additional licensees are added to Table 2 as they are.saluated. 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, Haddam Neck's average score for the text of the LERs that were evaluated is 8.0 out of a possible 10 points. From Table 3, it can be seen that the text score actually results from the review and evaluation of 17 different reouirements 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 reauirement was addressed by the licensee for the 10 LERs that were evaluated.
Discussion of Specific Deficiencies A review of the percentage scores presented in Table 3 will auickly point out where Haddam Neck is experiencing the most difficulty in preparing LERs. For example, reauirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these reauirements. Scores of 75 or above, but less than 100, indicate that the licensee probably understands the basic reauirement but has either: (1) excluded certain less significant information from most of the discussions concerning that reouirement or (2) totally failed to address the reauirement 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 perfect score for certain
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TABLE 1.
SUMMARY
OF SCORES FOR HADDAM NECK ~
Average High tow Text 7.8 9.5 4.6 Abstract 8.2 9.5 5.9 Coded Fields 8.5 9.0 7.8 b
Overall
.8.0 9.0 5.9 a.
See Appendix B for a summary of scores for each LER that was evaluated.
b.
Overall Average = 60% Text Average + 30% Abstract Averag' e + 10% Coded Fields Average.
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TABLE 2:
AVE 3 AGE SCORE COMPARISdX 10 9-g_
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7-7 7
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77
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0 i i i i i i i i i i i i i i i i i iiiiiiiiiiiiiiiiiii 9.5 9.0 B.5 B.O 7.5 7.0 6.5 6.0 GRADB t
- e TABLE 3.
LER REQUIREMENT PERCENTAGE SCORES FOR HADDAM NECK TEXT Percentage Reouirements [50.73(b)] - Descriptions Scores ( )a (2)(ii)(A) - - Plant condition prior to event 75 (10)
(2)(ii)(B) - - Inoperable equipment that contributed b
(2)(ii)(C) - - Date(s) and approximate times 82 (10)
(2)(ii)(D) - - Root cause and intermediate cause(s) 79 (10)
(2)(ii)(E) - - Mode, mechanism, and effect 96(7)
(2)(ii)(F) - - EIIS Codes 40(10)
(2)(ii)(G) - - Secondary function affected b
(2)(ii)(H) - - Estimate of unavailability 25(4)
(2)(ii)(I) - - Method of discovery 100(10)
(2)(ii)(J)(1) - Operator actions affecting course 100 (5)
(2)(ii)(J)(2) - Personnel error (procedural deficiency) 75 (2)
(2)(ii)(K) - - Safety system responses 100 (3)
(2)(ii)(L) - - Manufacturer and model no. information 57 (7)
( 3)
Assessment of safety conseauences 56 (10)
(4)
Corrective actions 89(10)
(5)
Previous similar event information 60 (10)
(2)(1) - - - - Text presentation 79(10)
ABSTRACT Percentage Reouirements [50.73(b)(1)] - Descriptions Scores ( )a
- Major occurrences (Immediate cause and effect 97 (10) information)
- Description of plant, system, component, and/or 100(6) personnel responses
- Root cause information 73 (10)
- Corrective Action information 77(10)
- Abstract presentation 73 (10)
o TABLE-3. -(continu:d)
CODED FIELDS Percentage Item Number (s) - Description Scores ( )a 1, 2, and 3 - Facility name (unit no.), docket no. and 100(10) page number (s) 4 -'- - - - -' Title 50 (10) 5, 6, and 7 - Event date, LER No., and report date 100(10) 8 - - - - - - Other facilities involved 100 (10) t 9 and 10 - - Operating mode and power level 99(10) 11-----
Reporting requirements 100 (10) 12 - - - - - Licensee contact information 92(10).
13 - - - - - Coded component failure information 94 (10)
-14 and 15 - - Supplemental report information 80(10) 4 i
i a.
Percentage scores are the result of dividing the total points for a l~
requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all 4
number of points possible was adjusted accordingly.)LERs, therefore, the The number in parenthesis is the number of LERs for which the requirement was considered applicable.
b.
A percentage score for this requirement is meaningless as it is not possible to determine from the information available'to the analyst whether this requirement is applicable to a specific LER.
It is always given 100%
if it is provided and is always considered "not applicable" when it is not.
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e reauirements. The text reauirements with a score of less than 75 are discussed below in their order of importance.
In addition, the primary deficiencies in the abstract and coded fields are discussed.
Five of the ten LERs are considered to have inadeauate safety assessments, reauirement 50.73(b)(3). The nature of the deficient discussions varies from LER to LER but basically takes the form of one or more of the following:
(1) failure to provide sufficient information to allow the reader to concur with the conclusions of the discussion, (2) failure to indicate whether or not the event could have occurred under a worse (yet probable) set of initial conditions, or (3) failure to list other available systems, components, or procedures that could have been used if necessary to mitigate the consecuences of the postulated event. An example of the first deficiency can be found in the " Potential Safety Conseauence" discussion in LER 85-025-00, page 3 of 4.
The release rate is stated to be well within the Technical Specification limit but the % MPC was well over the limit in 10 CFR 50.72. The total discharge is given as 19.7 curies but the reader is not told whether this is within or outside a limit. The final sentence (the conclusion) states that the release did not cause any personnel exposure limits to be exceeded but the reader still doesn't know why. Could it have been because no one was in the immediate area or was the release indeed safe for someone in the immediate area?
l Both of the LERs involving personnel error were considered inaaeauate. For example, in one LER the type of personnel involved in the event was not mentioned, and in another, the nature of the procedural problem could not be determined, reauirements 50.73(b)(2)(ii)(J)(2)(iv) and (ii) respectively.
The manufacturer and model number (or other uniaue identification) was not provided in the text of five of the seven LERs that involved a
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component f ailure, reauirement 50.73(b)(2)(ii)(L). Such information is important in that it can lead to the identification of possible gen,eric problems in the industry.
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b All four of the LERs involving failures in safety system trains did not provide adeauate information such as dates and times so that the unavailability time of the affected train could be determined, requirement 50.73(b)(2)(11)(H). This information is required as it becomes part of tne generic data necessary to perfor.a probabilistic risk assessments (PRAs). Adequately addressing reauirement 50.73(b)(2)(ii)(C),
which requires dates and times of major occurrences discussed in the event, will usually ensure that requirement 50.73(b)(2)(ii)(H) is met. Four of the ten LERs f ailed to provide information concerning the existence of any known similar events at the plant. Reference to similar events should be provided when they are identified (e.g., by LER number).
If there are no known previous events, the text should so state.
The Energy Industry Identification System component function identifier and system name codes were not provided in the text of six of the ten LERs that were evaluated.
The cause reautrement, [50.73(b)(2)(ii)(D)], received a percentage score'of 79% but was still considered to be marginal for five of the ten LERs in that the root and/or intermediate cause of component failures were not adeauately discussed.
The text presentations received an overall score of 79% but can be improved with some minor changes. The basic improvement that is needed is the use of a consistent basic text outline. All but one of the ten LERs used an outline format-but the various section headings differed in nearly
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every LER.
In most instances these differences appeared to be the result of the authors view of what needed to be provided for that one event. For example, some events had a " background" section, others a " time seauence" section, and another had a " generic implication" section. All of these sections were good and applicable to the event being reported; however, the problem is that all events did not Contain a basic set of consistently named sections which is considered to be a minimum reauirement (see NUREG-1022, Appendices C and D). For example, every outline must have
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sections such as: event description, reportability, cause, safety
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assessment, corrective actions, and similar occurrences.
If applicable, other sections such-as: background, time secuences, plant and/or system responses, system descriptions or generic implications can be added.
Once a basic outline is adopted by all those responsible for writing LERs, the overall cuality of the reports will improve based simply on the fact that every LER will contain at least the minimum information concerning the major elements of each event.
The use of diagrams and figures such as were provided in LERs 85-017-00 and 85-025-00 is good and is encouraged whenever appropriate.
The primary deficiencies for the abstract involve the summary of root cause and corrective action information. While the texts contained this information, the abstracts were generally deficient in these areas. Six of the LER abstracts were considered to be deficient in summarizing the cause of the event and four did not adeouately summarize the corrective actions discussed in the text. Both cause and corrective action information should be summarized in every abstract.
The abstracts were also considered marginal in the area of presentation in that four abstracts were very brief and failed to contain the necessary information even though space was available for more details.
In addition, three abstracts contained information that was not discussed in the text. This should be looked for during the licensee's final review process and, when found, the text should be revised to include such information.
The main deficiency in the area of coded fields involves the title, Item (4). None of the ten titles indicate root cause, three fail to include the link (i.e., circumstances or conditions which tie tne root cause to the result), and four failed to provide information concerning the result of the event (i.e., why the event was required to be reported).
While result is considered the most important part of the title, cause and link must be included to make the title complete. An example oY a title
that only addresses the result might be " Reactor Scram". This is inadeouate in that the cause and link are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP 1 Causes Reactor Scram". From this title the reader knows the cause involved either personnel or procedures and testing contributed to the event.
One LER (LER 85-009-00, event date 9/10/85) does not commit to a supplemental report, Item (14), even though the " exact cause of the malfunction" had not been determined by the time the original report was submitted. Supplemental reports are appropriate and should be submitted whenever new or revised information becomes available concerning an event, especially information as important as cause and corrective actions.
The position title of the licensee contact, Item (12), was not provided in four of the ten LERs that were evaluated (see NUREG-1022, page 24).
The final deficiency in the area of coded fields involves Item (13)--Failed Component Information. Two LERs contained information in this field even though no actual failure had occurred.
(Note: Component faults need not be coded in this field.)
In addition, one LER failed to provide system information in Item 13.
Table 4 provides a summary of the areas that need improvement for Haddam Neck 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 4
NUREG-1022, Supplement No. 2.
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TABLE 4.
AREAS MOST NEEDING IMPROVEMENT FOR HADDAM NECK LERs Areas Comments Safety assessment information Each LER should include a safety assessment that has sufficient detail to permit the reader to understand how the general conclusion was reached. The text should discuss whether or not the event could be worse under different circumstances and provide information about backup systems which could limit the consecuences of the event.
Personnel error discussions All aspects of the personnel error should be discussed; specifically, the Cause of personnel error should be provided (e.g., cognitive or procedural), as well as the position title for all personnel involved.
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 components were out of service.
Previous similar events Previous similar events should be referenced (e.g., by LER number) or if none are identified, the text should so state.
EIIS codes EIIS codes should be provided in the text for all systems and/or components discussed in the text.
Text presentation A consistent basic outline format should be used by all personnel writing LERs at the plant station.
TABLE 4.
(continued)
Areas Connents Abstracts Root cause and corrective actions information was very often inadeauate or was not included.
Abstracts should summarize the
'information that is discussed in the text.
If it is necessary to include additional information in tne abstract, the text should be revised so as to discuss it. The space available (1400 spaces) should be better utilized.
Coded fields a.
Titles Titles should be written such that they better describe the event.
In particular, include the root cause and result of the event and the link between them in all titles, b.
Commitments to Commit to provide a supplemental supplemental reports report whenever significant new or revised information concerning the original event is identified (e.g.,
cause or corective action information).
c.
Position titles The position title r,f each licensee contact named in Item 12 should be provided.
d.
Failed component Only provide information in Item 13 information for failed components and ther be sure all the necessary information is provided, e.
LER numbers Each event must be reported under a uniaue secuential report number.
See NUREG-1022, page 23.
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4-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 (UNAFI), 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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d'4 a-0 APPENDIX A LER SAMPLE SELECTION INFORMATION FOR HADDAM NECK i
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TABLE A-1.
LER SAMPLE SELECTION FOR HADDAM NECK (213)
LER Sample Number LER Number
- Comments 1
85-006-00 SCRAM 2-85-007-00 SCRAM 3
85-008-02 4
85-009-00 5
85-009-00a 6
85-010-00 7
85-016-00 8
85-017-00 9
85-019-00 ESF 10 85-025-00 a.
These are two separate events with the same LER number.
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APPENDIX B EVALUATION SCORES OF.
l INDIVIDUAL LERs FOR HADDAM NECK A
.s TABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR HADDAM NECK LER Sample Numbera 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 Text 8.6 9.3 6.9 9.0 4.6 7.4 7.4 9.5 7.6 7.2 Abstract 9.5 8.5 6.9 9.5 7.4 5.9 8.8
- 7. 5 9.1 9.2 Coded Fields 8.4 8.3 8.3
- 7. 8 8.8 9.0 8.1 8.5 8.5 8.9 Overall 8.9 9.0 7.1 9.0 5.9 7.1
- 7. 9 8.8 8.2 8.0 LER Sample Number
- 17 18 19 20 21 22 23 74 25 26 27 28 79 30 AVERAGE Text
- 7. 8 Abstract 8.2 Coded Fields 8.5 Overall
- 8. 0 See Appendix A for a list of the corresponding LER numbers.
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/PPENDIX C DEFICIENCY AND OBSERVATION i,'
' COUNTS FOR HADDAM. NECK a'
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TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR HADDAM NECK Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)D a
50.73(b)(2)(11)(A)--Plant operating 3 (10) conditions before the event were not included or were inadeauate.
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 ever.t was not included or was inadeauate.
50.73(b)(2)(ii)(C)--Failure to include 4 (10) sufficient date and/or time information.
a.
Date information was insufficient.
2 b
Time information was insufficient.
3 50.73(b)(2)(ii)(D)--The root cause and/or 5 (10) intermediate failure, system failure, or personnel error was not included or was inadeauate.
a.
Cause of component f ailure was not 5
included or was inadeauate b.
Cause of system failure was not 0
included or was inadeouate c.
Cause of personnel error was not 0
included or was inadeauate.
50.73(b)(2)(ii)(E)--The failure mode, I (7) mechanism (immediate cause), and/or effect (consecuence) for each failed component was not included or was inadeauate.
a.
Failure mode was not included or was 1
inaceauate b.
Mechanism (immediate cause) was not 0
included or was inadeauate c.
Effect (consecuence) was not included 0
or was inadeauate.
6 TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(11)(F)--The Energy Industry 6 (10)
Identification System component function identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a f ailure of a 0 (1) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadeauate.
50.73(b)(2)(ii)(H)--For a failure that 4 (4) 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 0 (10) of each component failure, system failure, personnel error, or procedural error was not included or was inadeauate.
a.
Method of discovery for each component failure was not included or was inadeauate b.
Method of discovery for each system failu/e was not included or was inadequate c.
Method of discovery for each personnel error was not included or was inadeauate d.
Method of discovery for each procedural error was not included or was inadeauate.
_.,,-.,.n.
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totalsa Totals (
)b 50.73(b)(2)(ii)(J)(1)--Operator actions that 0 (5) affected i+.e course of the event including operatcr errors and/or procedural deficiencies were not included or were inadequate.
50.73(b)(2)(ii)(J)(2)--The discussion of 2 (2) each personnel error was not included or was inadequate.
a.
OBSERVATION: A personnel error was 0
implied by the text, but was not explicitly stated, b.
50.73(b)(2)(ii)(J)(2)(1)--Discussion 0
as to whether the personnel error was cognitive or procedural was not included or was inadeauate.
c.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion 1
as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadeauate.
d.
50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0
or any unusual cnaracteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadeauate.
e.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion I
of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadeauate.
e
s' TABLE C-1.
(continued)
Number of LERS with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(K)--Automatic and/or manual 0 (3) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 5 (7) model number of each failed component was not included or was inadeauate.
50.73(b)(3)--An assessment of the safety 5 (10) consequences and implications of the event was not included or was inadeauate.
a.
OBSERVATION: The availability of 2
other systems or components capable of mitigating the consecuences of the event was not discussed.
If no other systems or components were available, the text should state that none existed.
b.
OBSERVATION: The conseauences 3
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 4 (10) 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 inadeauate.
l
o TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)D a.
A discussion of actions reauired to 0
correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadeauate, b.
A discussion of actions reauired to 3
reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadeauate.
c.
OBSERVATION: A discussion of actions 0
reauired to prevent similar f ailures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information concerning previous 4(10).
similar events was not included or was inadeauate.
S 3-
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(il--Textpresentation 2 (10) inadeauacies.
a.
OBSERVATION: A diagram would have 0
aided in understanding the text discussion.
b.
Text contained undefined acronyms 1
and/or plant specific designators.
c.
The text contains other specific 1
deficiencies relating to the readability.
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain reauirements. Since an LER can have more than one deficiency for certain reauirements, (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 reauirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.
.7.--
4 0
TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR HADDAM NECK 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(10) and effect) was not included or was inadeauate A summary of plant, system, and/or personnel 2 (6) responses was not included or was inadeauate.
a.
Summary of plant responses was not 1
included or was inadeouate.
b.
Summary of system responses was not 1
included or was inadeauate.
c.
Summary of personnel responses was not 0
included or was inadequate.
A summary of the root cause of the event 6 (10) was not included or was inadeauate.
A summary of the corrective actions taken or 4 (10) planned as a result of the event was not included or was inadeauate.
b 9
I F.-
TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)D a
Abstract presentation inadeauacies 4(10) 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 4
deficiencies (i.e., poor summarization, contradictions,etc.)
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain reauirements. Since an LER can have more than one deficiency for certain reauirements, (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 reauirement was considered applicable.
n TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR HADDAM NECK Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
Facility Name 0(10) 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 (10) incorrect.
Page Number was not included or was 0 (10) incorrect.
Title was left blank or was inadeauate 10(10) a.
Root cause was not given in title 10 b.
Result (effect) was not given in title 4
c.
Link was not given in title 3
Event Date 0(10) a.
Date not included or was incorrect.
b.
Discovery date given instead of event date.
LER Number was not included or was incorrect 0(10)
Report Date 0(10) 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(10) inconsistent with text and/or abstract.
Operating Mode was not included or was 1 (10) inconsisten* with text or abstract.
7--
.r TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations
- Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)D a
Power level was not included or was 0 (10) inconsistent with text or abstract Reporting Reauirements 0 (10) a.
The reason for checking the "0THER" requirement was not specified in the abstract and/or text.
b.
OBSERVATION: It would have been more appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It would have been appropriate to report this event under additional unchecked paragraphs.
Licensee Contact 4 (10) a.
Field left blank 0
b.
Position title was not included 4
c.
Name was not included 0
d.
Phone number was not included.
O Coded Component Failure Information 3(10) a.
One or more component failure i
sub-fields were left blank.
b.
Cause, system, and/or component code 0
is inconsistent with text.
c.
Component f ailure field contains data 2
when no component failure occurred.
d.
Component failure occurred but entire 0
field left blank.
i y
~
'~
TABLE C-3. - (continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies'and Observations Totals Totals (
)b a
Supplemental Report 1(10) a.
Neither "Yes"/"No" block of the 0
supplemental report field was checked.
b.
The block checked was inconsistent I
with the text.
Expected submission date information is 0 (10) 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 reautrements, (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.
D.
The " paragraph total" is the number of LERs that have one or more reouirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain reauirement was considered applicable.
1 f
APPENDIX D LER COMMENT SHEETS FOR HADDAM NECK l
t
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 1.
LER Number: 85-006-00 Scores: Text = 8.6 Abstract = 9.5 Coded Fields = 8.4 Overall = 8.9 Text 1.-
50.73(b)(2)(ii)(C)--When was the pipe repaired?
2.
50.73(b)(2)(ii)(D)--It is not clear why the eroded portion of the pipe was not found by the current inspection program before it broke.
3.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(3)--0BSERVATION: The conseouences 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.
No comment.
Coded Fields 1.
Item (4)--Title: Root cause and result are not included. The title should mention the scram (result) and the erosion in the pipe (root: cause).
2.
Item (12)--Position title is not included.
l l
e I
1 g
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 2.
LER Number: 85-007-00 Scores: Text = 9.3 Abstract = 8.5 Coded Fields = 8.3 Overall = 9.0 Text 1.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function -
identifier (s) and/or system name of each comoonent or system referred to in the LER is not included.
Abstract 2.
50.73(b)(1)--A summary of the reduced capability of the feed and condensate systems should have been included.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included.
2.
Item (9)--Operating mode is not included.
3.
Item (12)--Position title is not included.
T 4
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TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 3.
LER Number: 85-008-02 Scores: Text = 6.9 Abstract = 6.9 Coded Fields = 8.3 Overall = 7.1 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadeauate. Power level and/or mode of operation should be provided in the text for every event even though it may sometimes appear to be irrelavent information.
2.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is inadeauate.
When (date and time) was the exhaust fan rewired correctly?
3.
50.73(b)(2)(ii)(J)(2)--Discussion of personnel error is inadeauate.
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.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
50.73(b)(5)--Information ccacerning previous similar events is not includea.
If no previous similar events are known, the text should so state.
7.
This revision does not contain all the necessary information presented in the early revisions; specifically, the reference to the fact that procedure SUR 5.5-20 is to be revised prior to the next performance of the test under " Corrective Action".
8.
The " Reason for Revision" appears to be information that should be provided in a new LER.
l Abstract 1.
50.73(b)(1)--Summary of intermedir'.e cause i
(misinterpretation of procedure) is not included.
I 2.
50.73(b)(1)--Summary of corrective actions taken or planneo as a result of the event is inadeauate (see text comment No. 7).
1
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 3.
LER Number: 85-008-02(continued) 3.
Abstract does not adeouately 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 and intermediate cause and result are not included.
2.
Item (12)--Position title is not included.
3.
Item (13)--Component failure field contains data when no component failure occurred.
,~..--%
,--,-y--,-
--+-.yy-,
.-v
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 4.
LER Number: 85-009-00 Scores: Text = 9.0 Abstract = 9.5 Coded Fields = 7.8 Overall = 9.0 Text 1.
50.73(b)(2)(ii)(D)--A supplemental report appears to be needed to describe the root cause of the sticky valves when it is found. Without a commitment to submit a supplemental report, this LER must be considered incomplete.
2.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
3.
Acronym (s) and/or plant specific designator (s) are undefined. Don't separate the acronym from its definition (see first paragraph of the text).
4.
The corrective action and safety assessments are very good.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadeauate.
Should indicate that root cause is unknown.
Coded Fields 1.
Item (4)--Title: Root cause and link are not includea.
2.
Item (14)--The block checked is inconsistent with information in the text (see text comment 1).
.n.
~w v. -
--r-
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 5.
LER Number: 85-009-00 Scores: Text =. 4.6 Abstract = 7.4 Coded. Fields = 8.8 Overall = 5.9 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(C)--Time information for occurrences is inadeouate. Be more specific about times (i.e.,
approximate time last shift checked door and approximate time the door was repaired).
- 3..
50.73(b)(2)(ii)(D)--Root cause of the inoperable latching mechanism 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)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not' included.
i
' 6.
50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is not included.
7.
50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadeouate.
8.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of root cause is not included.
2.
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.
s
+
~,,, -,
,,-p.,----
-~,,-,,n,---
,a
,-n-- -,, + -, -., - - -
e TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 5.
LER Number: 85-009-00 (continued)
Coded Fields 1.
Item (4)--Title: Root cause is not included.
2.
Item (12)--Position title is not included.
3.
Item (13)--One or more component failure sub-fields are blank.
l i
=
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 6.
LER Number: 85-010-00 Scores: Text = 7.4 Abstract = 5.9 Coded Fields = 9.0 Overall = 7.1 Text 1.
50.73(b)(2)(ii)(C)--Time information for occurrences is inadeouate. The lack of dates for certain occurrences discussed'in this event coupled with the length of time between the initial discovery and the report date, makes it difficult for the reader to determine a time-history for this event. When was this event determined to be reportable? When was the
" extensive valve motor operator preventative maintenance program" implemented?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
4._50.731b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) o rthe failed component (s) discussed in the text is not included.
5...
50.73(b)(3)--Discussion of the assessment of the safety conseouences.and implications of the event is inadeauate. More details are needed concerning the
" flow analysis". To what extent was the ability of the containment air recirc coolers degraded? The availability of other systems, procedures, or components capable of mitigating the consecuences of such a degradation should also be discussed or if none are available, the text should so state.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadeauate. More details are needed concerning the extensive valve motor operator preventative maintenance program.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
'Section Comments 6.
LER Number: 85-010-00(continued)
)
8.
Some ideas are not presented clearly (hard to follow). Specifically, should the first sentence on page 3 of 3 say "-could not be " rather "-has not been "?
Abstract 1.
50.73(b)(1)--Summary of cause information is not included. The fact that a failure occurred has to be inferred from the corrective actions.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeouate.
Those actions taken to prevent recurrence are not summarized.
3.
Abstract does not adeouately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
4.
OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.
The information in the abstract that is not apparent in the text is the fact that both operators were "immediately" repaired and retested satisfactorily.
l Coded Fields 1.
Item (4)--Title: Root cause and result are not included.
i l
l y
m
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 7.
LER Number: 85-016-00 Scores: Text = 7.4 Abstract = 8.8 Coded Fields = 8.1 Overall = 7.9 Text 1.
50.73(b)(2)(ii)(E)--The effect (consecuence) discussion of each failed component is not included.
2.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
When (date and time) was the instrument recalibrated?
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 conseauences and implications of the event is inadequate. What is the potential effect of the high setpoint?
OBSERVATION: The consecuences 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 inadeauate.
Indicate tnat setpoint drift is considered to be the Cause.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
I t
i l
l
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 8.
LER Number: 85-017-00 Scores: Text = 9.5 Abstract = 7.5 Coded Fields '= 8.5 Overall = 8.8 Text 1.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function system ref(erred to in the LER is not included. identifier s) and/or s 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.
Title could be interpreted to mean a LOCA has occurred. Suggested title:
" Potential Post-LOCA Release Paths Outside Containment".
1 l
~
l l
i
' ' ' ~
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 9.
LER Number: 85-019-00 Scores: Text = 7.6 Abstract = 9.1 Coded Fields = 8.5 Overall = 8.2 Text 1.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion for the faulty gain potentiometer is not included. Was this a design problem with all the gain potentiometers or just a normal end of life condition?
2.
50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is not included.
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadeauate. A discussion of actions reauired to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadeauate. See comment No. 1.
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 inadeauate. See text comment No. 3.
Coded Fields 1.
Item (4)--Title: Root cause and link (gain adjustment) are not included.
f e
'I e-.
es g TABLE.D-1. SPECIFIC LER COMMENTS FOR HADDAM NECK (213) i Section Comments
- 10. LER Number: 85-025-00 Scores: Text = 7.2 Abstract = 9.2 Coded Fields = 8.9 Overall = 8.0 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included. This information is included in the abstract, apparently because the text was begun on the abstract page.
2.
50.73(b)(2)(ii)(C)--Date and time information for occurrences is inadeauate. The text should give the
.date and estimate of times for occurrences such as when the eauipment operator opened the valve and when the reactor operator closed the valve.
3.
50.73(b)(2)(ii)(F)--The Energy Industry.
Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
4.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is not included.
5.
50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is inadequate.
OBSERVATION: The availability of other 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.
0BSERVATION: The consecuences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
6.
50.73(b)(4)--Should a permanent warning be placed in the proper procedure to warn future employees?
7.
Inclusion of the diagram is good.
.' ' l * :, :'
g TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213) s Section Comments
- 10. LER Number: 85-025-00 (continued) j.,
Abstract 1.
Thecorrectiveaction.summayyisdeficientforthe j
same' reason..as the ter:t (see text Comment 6).
Coded Fields 1.
Item (4)--Title: Root cause and link are not inciuced. J The personnel error (root cause) and confusing-labels (link) should be included.
2.
Item (13)--Component f&ilure field contains data when no component failure occurred.
l
_1
..