ML20204G783
| ML20204G783 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/23/1987 |
| From: | Frank Akstulewicz Office of Nuclear Reactor Regulation |
| To: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| NUDOCS 8703260462 | |
| Download: ML20204G783 (61) | |
Text
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March 23, 1987 Docket No.: 50-213 Mr. Edward J. Mroczka, Senior Vice President Nuclear Engineering and Operations
~ Connecticut Yankee Atomic Power Company Post Office Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
SUBJECT:
EVALUATION OF LICENSEE EVENT REPORTS AT THE HADDAM NECK PLANT Enclosed is an evaluation by the staff's contractor (DOE /INEL) of the quality of the Haddam Neck Plant licensee event reports (LERs) for the period March 1,1986 to March 31,198/. The evaluation does not attempt to make a determination or to comment whether or not the regulation is met, but rather it presents specific suggestions to improve the quality of' the reports and, in that light, a copy of the entire evaluation should be given to the manager responsible for preparing LERs.
In summary, the results of this evaluation indicate that the Haddam Neck LERs have an overall average score of 8.0 out of a possible 10 points, which is slightly below the industry overall average of 8.2.
Some weak-nesses identified in the ;iaddam Neck LERs involve the requirements to ade-quately provide: 1) the dates and times of major occurrences, 2) the manu-facturer and model number of failed components, 3) infonnation concerning previous similar events, and 4) abstracts that summarize cause and cor-rective action information.
The staff has received positive comments from other licensees on the use-fulness of this report and has observed improvements in overall LER quality.
Should you have any questions concerning this report, please contact me at 301-492-4790.
Sincerely, (Original signed by)
Francis M. Akstulewicz, Jr.
Integrated Safety Assessment Project Directorate Division of PWR Licensing-B
Enclosure:
DISTRIBUTION As stated Docket File PDR ISAPD File LPDR cc: See next page PAnderson FAkstulewicz CThomas ISAPD Id S
FAkstulewicz:cm par' bn 3/to /87 3/ld/87 7
8703260462 870323 PDR ADOCK 05000213 S
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NUCLEAR REGULATORY COMMISSION 7.
- j WASHINGTON, D. C. 20555 t,
p March 23, 1987 Docket No.:
50-213 Mr. Edward J. Mroczka, Senior Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Mroczka:
SUBJECT:
EVALUATION OF LICENSEE EVENT REPORTS AT THE HADDAM NECK PLANT Enclosed is an evaluation by the staff's contractor (DOE /INEL) of the quality of the Haddam Neck Plant licensee event reports (LERs) for the period March 1, 1986 to March 31, 1987. The evaluation does not attempt to make a determination or to comment whether or not the regulation is met, but rather it presents specific suggestions to improve the quality of the reports and, in that light, a copy of the entire evaluation should be given to the manager responsible for preparing LERs.
In sumary, the results of this evaluation indicate that the Haddam Neck LERs have an overall average score of 8.0 out of a possible 10 points, which is slightly below the industry overall average of 8.2.
Some weak-nesses identified in the Haddam Neck LERs involve the requirements to ade-quately provide: 1) the dates and times of major occurrences, 2),the manu-facturer and model number of failed components, 3) information concerning previous similar events, and 4) abstracts that summarize cause and cor-rective action information.
The staff has received positive comments from other licensees on the use-fulness of this report and has observed improvements in overall LER quality.
Should you have er.y questions concerning this report, please contact me at 301-492-4790.
Sincerely, f
Francis M. Akstulewicz,
.d Integrated Safety Assessment Project Directorate Division of PWR Licensing-B l
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Enclosure:
i As stated cc: See next page l
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s Mr. Edward J. Mroczka Connecticut Yankee Atomic Power Company Haddam Neck Plant cc:
Gerald Garfield, Esquire Kevin McCarthy, Director Day, Berry & Howard Radiation Control Unit Counselors at Law Department of Environmental City Place Protection Hartford, Connecticut 06103-3499 State Office Building Hartford, Connecticut 06106 Superintendent Haddam Neck Plant Richard M. Kacich, Manager RFD #1 Generation Facilities Licensing Post Office Box 127E Northeast Utilities Service Company East Hampton, Connecticut 06424 Post Office Box 270 Hartford, Connecticut 06141-0270 Wayne D. Romberg Vice President, Nuclear Operations Northeast Utilities Service Company Post Office Box 270 Hartford, Connecticut 06141-0270 Board of Selectmen Town Hall Haddam, Connecticut 06103 State of Connecticut Office of Policy and Management ATTN: Under Secretary Energy Division 80 Washington Street Hartford, Connecticut 06106 Resident Inspector Haddam Neck Nuclear Power Station c/o U.S. NRC P. O. Box 116 East Haddam Post Office East Haddam, Connecticut 06423 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 i
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1 AE00 SALP INPUT FOR HADDAM NECK-OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD Of 1 MARCH 1986 TO 31 MARCH 1987 t
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Haddam Neck during the period from March 1, 1986 to March 31, 1987 was performed using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.
This is the second time the Haddam Neck LERs have been evaluated using this methodology.
The results of this evaluation indicr'.e that the Haddam Neck LERs have the same overall average score, 8.0 sut of a possible 10 points.
It should be noted that the average text s. ore did improve from 7.8 to 8.3 (primarily due to better safety consequ'ence discussions), but the average abstract score went from 8.2 to 7.2, which rasulted in the overall average score remaining at 8.0.
Some weaknesses identified in the Haddam Neck LERs involve the requirements to adequately provide: 1) the dates and times of major occurrences, 2) the manufacturer and model number of failed components,
- 3) information concerning previous similar events, and 4) abstracts _that summarize cause and corrective action information, j
Two strong points for the Yankee L'ERs are the discussions concerning the assessment of the safety consequences of the event and the I
failure mode, mechanism, and effect of failed components.
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LER QUALITY EVALUATION 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 period from March 1,1986 to March 31, 1907, a sample of the unit's LERs were evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.
The sample consists of a total of 15 LERs, which is considered to be the maximum number of LERs required to be selected to have a representative sample. 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 assessment period because the input was due such a short time after the end of the assessent period.
Therefore, all of the LERs prepared by the unit during the assessment period were not available for selection.
Methodology i
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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 criteria of 10 CFR 50.73(b).
In addition, each selected LER is compared to the guidance for preparation of LERs presented in NUREG-1022 3
and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the LERs.
The purpose of this evaluation is to provide feedback to improve the quality of LERs.
It is not intended to increase the requirements concerning the
" content" of these reports beyond the current requirements of 10 CFR 50.73(b). Therefore, statements in this evaluation that suggest measures be taken are not intended to increase requirements and should be viewed in that light.
However, the minimum requirements of the regulation 1
must be met.
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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 analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was evaluated.
Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms-how-the analysts perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER.
The overall score for each LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x code 1 fields score - overall LER score).
The results of the LER quality evaluation are divided into two l
categories:
(1) detailed information and (2) summary information.
The detailed information, presented in Appendices A through 0, 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 Appendix 0, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores (e.g., the analysts sometimes make comments relative to a requirement without deducting points for that requirement).
Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below.
These conclusions are based solely on the results of the 2
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evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the unit's performance (on a scale of 0 to 10) in submitting LERs that meet the criteria of 10 CfR 50.73(b) and the guidance present in NUREG-1022 and its supplements.
Table 1 presents the average scores for the sample of LERs evaluated for the unit.
In order to place the scores provided'in Table 1 in perspective, the distribution of the overall average score for all units / stations that have been evaluated using the current methodology is provided on Figure 1.
Figure 1 is updated each month to reflect any changes in this distribution resulting from the inclusion of data for those units / stations that have not been previously evaluated or those that have ~ ~ ~
j been reevaluated.
(Note:
Previous scores for those units / stations that are reevaluated are replaced with scores from the latest evaluation).
Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1.
For example, Haddam Neck's average score for the text of the LERs that were evaluated is 8.3 out of a possible 10 points.
From Table 2 it can be seen that the text score-actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions prior to the event [10 CFR 50.73(b)(2)(11)(A)] to text presentation.
The
(
percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the unit for the 15 LERs that were evaluated.
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Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the unit is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the unit probably needs additional guidance concerning these requirements.
Scores of 75 or above, but less than 100, indicate that the unit probably understands the basic requirement but has either:
(1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs.
The unit should review 3
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T.ABLE 1.
SUMMARY
OF SCORES FOR HADDAM NECK l
Average High Low Text
- 8.3 10.0 6.4 Abstract 7.2 9.9 4.0 Coded Fields 8.6 9.5 7.0 Overall 8.0 9.5 6.3 e.
See Appendix B for a summary of scores for each LER that was evaluated.
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5 Figure 1. ' Distribution of overall average LER scores 12
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h Haddam Neck
.9 9-y 8-3 7-k 6-o 5-4-
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i 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average scores
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LER REQUIREMENT PERCENTAGE SCORES FOR HADDAM NECK l
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Percentage f_
Requirements [50.73(b1] - Descriptions Scores ( )
a (2)(ii)(A)
- - Plant condition prior to event 80 (15)
(2)(ii)(B)
- - Inoperable equipment that contributed b
(2)(ii)(C)
- - Date(s) and approximate time (s) 73 (15)
(2)(ii)(D)
- - Root cause.and intermediate cause(s) 87 (15)
(2)(ii)(E)
- - Mode, mechanism, and effect 93 ( 9)
(2)(ii)(F)
- - EIIS codes 60 (15)
(2)(ii)(G)
- - Secondary function affected b
(2)(ii)(H)
- - Estimate of unavailability 33 ( 6)
(2)(ii)(I)
- - Method of discovery 100 t15)^~
(2)(ii)(J)(1) - Operator actions affecting course 100 ( 4)
( 2)*(ii) (J ) ( 2) - Personnel error (procedural deficiency) 83 ( 6)
(2)(ii)(K)
- - Safety system responses 81 ( 7)
(2)(ii)(L)
- - Manufacturer and model no. information 36 ( 9)
(3) - - - - - - Assessment of safety consequences 97 (15)
(4) - - - - - - Corrective actions 83 (15)
(5) - - - - - - Previous similar event information 33 (15)
(2)(i)
- - - - Text presentation 87 (15)
ABSTRACT Percentage a
Requirements [50.73(b)(1)] - Descriptions Scores ( )
- Major occurrences (immediate cause/effect) 98 (15)
- Plant / system / component / personnel responses 95 ( 8)
- Root cause information 52 (15)
- Corrective action information 59 (15)
- Abstract presentation 69 (15) 6
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TABLE 2.
-(continusd)
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CODEL FIELDS Percentage a
Item Number (s) - Descriptions Scores ( )
1, 2, and 3 -
Plant name(unit #), docket #,
page #s 100 (15) -
Title 56 (15) 5, 6, and 7 -
Event date, LER no.,
report date 98 (15) 8 Other facilities involved 100 (15) 9 and 10 Operating mode and power level 100 (15)
- Reporting requirements 100 (15) 11 Licensee contact information 100 (15)
- 12 Coded component failure information 71 (15) 13 14 and 15 - -
Supplemental report information 90 (15) i a.
Fercentage 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%
is provided and is always considered "not applicable" when it is not.
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the LER specific comments presented in Appendix 0 in order to determine why it received less than a perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance.
In addition, the primary deficiencies in the abstracts and coded fields are discussed.
The requirement to provide dates and approximate times of occurrences, Requirement 50.73(b)(2)(11)(C), was considered deficient in nine of the 15 LERs.
In addition, the requjrement to provide an estimate of the total time that a safety system train was unavailable, Requirement 50.73(b)(2)(ii)(H), was considered deficient in four of the six LERs that--
involved failures of a safety train.
One way of satisfying this latter requirement is to provide the total (estimated) elapsed time from the time the safety train was known (or believed) to have become inoperable until the time that it was returned to an operable status.
In practice, however, this requirement is usually met by simply providing adequate dates and/or times for.the major occurrences discussed in the LER. For example,- when the date that a failure is discovered is provided, an estimate of when the failure actually occurred is also appropriate; this information along with the date/ time of repair and of the system being returned to operation is adequate to allow the reader to calculate total train unavailability.
There is obviously not one set of rules concerning date's and times; in some LERs, providing only the date of a discovery is suf ficient while others require times in seconds to adequately describe the time history of the event. Prior to submitting an LER, the reviewers should review the text for obvious places where the addition of a date and/or time would j
provide meaningful information.
The requirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was considered to be deficient in six of the nine LERs involving a failed component.
In most cases this requirement can be met by simply providing the manufacturer and model h
number for each failed component. For certain components (e.g., pipes, fitting, etc.) the material and size of the failed component would be more 8
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Whatever information is provided, it should be specific enough to allow the reader to determine if the component is the same as one that is at another facility.
In addition, there are instances where information tnat identifies components (even though these components didn't fail) could be important to the reader.
For example, if the design of a component contributes to the event, it would be helpful to provide information that would enable others to specifically identify the i
component. An example of such a component would be a valve that opens with a clockwise turn of its handle and thus leads to an improper valve line-up due to a pe.rsonnel error while operating the valves.
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--- Four text requirements have marginally acceptable scores but are mentioned here because of the high percentage of LERs with a deficiency concerning these requ'irements.
The four requirements are:
1.
Corrective actions, Requirement 50.73(b)(4),
2.
Personnel and procedural error, Requirement 50.73(b)(2)(ti)(J)(2),
3.
Safety system responds, Requirement 50.73(b)(2)(11)(K), and 4.
Operating conditions before the event, Requirement 50.73(b)(2)(11)(A).
Recommendations concerning these requirements can be found in the specific comments presented in Appendix D.
Requirement 50.73(b)(5) was not adequately addressed in ten of the 15 LERs in that their text did not include the necessary information concerning previous similar events. All previous similar events should be appropriately referenced (by LER number, if possible) and the history of the on-going problem should be discussed, if necessary.
If there have been no previous similar events, the text should state this.
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t The Energy Industry Identification System (EIIS) codes were not provided in twelve of the 15 LERs.
System name codes were often provided but many of the component function identifier codes were not.
The text presentations, while adequate, were not presented in a consistent format. The use of a consistent format by all authors (as is suggested in NUREG-1022, Supplement No. 2) might ensure more complete LERs. For example, if the format had a heading entitled " Failed Component Identification", that requirement (when applicable) would probably be addressed.
While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as stated in NUREG-1022, Supplement No. 2, summarize the following information from the text:
1.
Cause/Effect What happened that pude the event reportable.
2.
Responses Major plant, system, and personnel p
responses as a result of the event.
3.
Root / Intermediate The underlying cause of the event. What Cause caused the component and/or system failure or the personnel error.
4.
Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence of the event.
Numbers 1 and 2 above were adequately addressed in the abstracts of the LERs reviewed. However, numbers 3 and 4 had scores of only 52% and 59%
respectively. Both of these items can be improved by ensuring that the cause and corrective action information that is contained in the text is adequately summarized in the abstract.
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a o s In addition, an abstract should not contain information that is not discussed in text (two abstracts introduced new information).
If, when writing the abstract, new information is deemed necessary, the text should be revised so as to discuss this information.
Further improvement in the abstract score could be obtained by using the full space available (i.e.,
the 1400 spaces). Over half of the abstracts that were evaluated failed to adequately utilize the space available.
The main deficiency in the area of coded fields involves the title, Item (4). Thirteen of the 15 titles failed to adequately provide root cause information, four failed to include the result of the event, and five failed to include the link-between-the cause and result. While the result is considered to be the most important part of the title, cause and link information (as suggested in NUREG-1022 Supplement No. 2) must be included to make a title complete. Example titles are presented in Appendix D for many of the LERs which were considered to have poor titles.
Six LERs failed to adequately address Item (13), failed component coded information.
Four LERs failed to provide information in Item (13),
even though a component failure was discussed in the text and two other LERs contained information in this field when no apparent component failure occurred.
The final area of the coded field section that should be discussed is Item (14), Supplemental Report information. While 50.73(c) states that if the Commission requires the licensee to submit supplemental information bevond that required by 50.73(b), this request will be made in writing, the information that is required by 50.73(b) should be submitted in a supplemental report (without a written request) if it is not available at the time the LER is required to be submitted (i.e., within 30 days).
In addition, if the text mentions an "on-going study" or a 'more extensive test will be performed as conditions permit", the results of such studies or tests are reportable if they lead to new information or result in additional corrective actions. Without a connitment to provide a supplement report (when information required by 50.73(b) is not provided),
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the analyst must consider the failure to commit to a supplement to be a deficiency.
Table 3 provides a summary of the areas that need improvement for the Haddam Neck LERs.
For additional and 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 i
found in NUREG-1022, Supplement No. 2.
It should be noted that this is the second time that the Haddam Neck LERs have been evaluated using this same methodology. The previous evaluation was reported in March of 1986. Table 4 provides a comparison of the scores for both evaluations. While the overall text score was slightly better for this evaluation (due to better safety consequence discussions),
the lower overall abstract score kept the overall average LER score at 8.0, which is slightly below the current industry overall average of 8.2.
(Note:
The industry overall average is the result of averaging the latest overall average LER score for each unit / station that has been evaluated using this methodology.)
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a TABLE 3.
AREAS MOST NEEDING IMPROVEMENT FOR HADDAM NECK LERs Areas-Comments Manufacturer and model number Component identification information should information be included in the text for each component failure or, although not specifically required by the current regulation, whenever a component's design is suspected to have contributed to the event.
Date/ time information and Sufficient dates and times should be safety train unavailability included in the text to enable the reader to have a time history of the event (if necessary) and to determine the length of time that safety system trains or components were inoperable.
P+evious similar events Previous similar events should be referenced (e.g., by LER number) or if none are identified, the text should so state.
EIIS todes EIIS codes should be provided in the text for all systems and/or components discussed in the text.
Text presentation A consistent text outline format, used by all personnel writing LERs, would improve both LER content and presentation.
Abstracts Root cause and corrective actions information was very often inadequate or was not included.
Abstracts should summarize the information that is discussed in the text.
If it is necessary to include additional information in the abstract, the text should be revised so as to discuss this new information. The space available (1400 spaces) should be better uttitzed.
Coded fields i
a.
Titles Title 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.
Failed component Only provide information in Item (13) for failed components, but if a component failure is discussed, information is required to be provided in Item (13).
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(continued) 1 Areas Comnents c.
Comnitments to Connit to provide a supplemental report supplemental reports whenever studies are continuing that could identify significant new information concerning the original event (e.g., cause or corrective action information) or whenever all information required in the initial report is not available within 30 days.
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TABLE 4.
COMPARISON OF LER SCORES FROM PREVIOUS EVALUATION Report Date March-86 March-87 Text average 7.8 8.3 Abstract average 8.2 7.2 Coded fields average 8.5 8.6 Overall LER average 8.0 8.0 0
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's REFERENCES
' 1.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Connission, September 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.
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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR HADDAM NECK
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TABLE A-1.
LER SAMPLE SELECTION TOR HADDAM NECK Sample Number LER Number Coments 1
86-013-01 2
86-014-00 3
8b-O'5-01 4
86-017-00 5
86-022-00 ESF 6
86-023-00 ESF 7-86-024-00 ESF 8
86-026-00 SCRAM 9
86-027-00 SCRAM 10 86-031-00 11 86-032-01 12 86-035-00 13 86-037-00 14 86-038-0J 15 86-041-00 SCRAM A-1
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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR HADDAM NECK f
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TABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERS FOR HADDAM NECK a
LER Sample Number 1
2 3
4 5
6 7
8 Text 8.9 7.6 6.6 6.4 7.4 8.3 8.8 9.2 Abstract 4.0 7.1 5.2 6.0 5.0 7.5 7.7 7.8 Coded Fields 8.7 8.0 7.3 9.3 8.5 8.5 9.1 9.5 Overall 7.4 7.5 6.3 6.6 6.8 8.1 8.5 8.8 a
LER Sample Number 9-10 11 12 13 14 15 Average Text 7.3 8.4 8.3 8.8 9.1 9.4 10.0 8.3 Abstract 8.5 7.0 9.6 6.9 7.7 9.9 8.2 7.2 Coded Fields 8.5 8.7 9.5 7.0 8.2 9.0 9.5 8.6 Overall 7.8 8.0 8.8 8.0 8.6 9.5 9.4 8.0 e.
See Appendix A for a list of the corresponding LER numbers.
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9 APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR HADDAM NECX 6
- 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 (
)
50.73(b)(2)(it)(Al--Plant operating 4 (15) conditions before the event were not included or were inadequate.
50.73(b)(2)(li)(B)--Discussion of the status 0 ( 5) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.
50.73(b)(2)(iil101--Fa11ure to include 9 (15) sufficient date and/or time information.
a.
Date information was insufficient.
6 b.
Time information was insufficient.
8 50.73(b)(2)(11)(D)--The r oot and/or 5 (15) intermediate cause of the component or system failure was not included or was inadequate.
a.
Cause of component failure was not 5
included or was inadequate, b.
Cause of system failure was not 0
included or was inadequate, i
50.73(b)(2)(ti)(E)--The failure mode, 2 ( 7) mechanism (innediate cause), and/or ef f ect (consequence) for each failed component was not included or was inadequate.
i a.
Failure mode was not included or was 1
inadequate, b.
Mechanism (immediate cause) was not 1
included or was inadequate.
c.
Effect (consequence) was not included 2
or was inadequate.
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- i 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)(11)(F)--The Energy Industry 12 (15)
Identification System component function
' identifier for each component or system was not included.
50.73(b)(2)(11)(GD--For a failure of a
-- ( 0)
. component with mu'.tiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.
_50.73(b)(2)(ii)(H)--For a failure that 4 (6) rendered a train of a safety system inoperable, the estimate of elapsed time from the time of the failure untti the train was returned to service was not included.
~
50.73(b)(2)(11)(I)--The method of discovery 0 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each component failure was not included or was inadequate, b.
Method of discovery for each system failure was not included or was inadequate.
c.
Method of discovery for each personnel error was not included or was inadequate.
d.
Method of discovery for each procedural error was not included or was inadequate.
C-2
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)(ii)(J)(11--Operator actions that 0 ( 4) af fected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
50.73(b)(2)(11)(J)(2)--The discussion of 2 ( 6) 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)(11--01scussion 1
as to whether the personnel error was i
cognitive or procedural was not included or was inadequate.
~
2 c.
50.73(b)(2)(ti)(J)(2)(11)--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 i
not included or was inadequate.
d.
50.73(b)(2)(11)(J)(2)(111)--Discussion 0
of any unusual characteristics of the t
work location (e.g., heat, noise) that i
directly contributed to the personnel error was nct included or was inadequate.
e.
50.73(b)(2)(11)(J)(2)(iv)--Discussion 1
of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed 4
operator, other utility personnel) was not included or was inadequate.
C-3
TA8LE C-1.
(continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(ti)(K)--Automatic and/or manual 3 ( 7) safety system responses were not included or were inadequate.
50.73(b)(2)(it)(L)--The manufacturer and/or 6 ( 9) model number of each failed component was not included or was inadequate.
50.73(b)(31--An assessment of the safety 1 (15) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION:
The availability of 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 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)(41--A discussion of any corrective 9 (15) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.
i 0
C-4
'g a
' TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph-Paragraph Description of Deficiencies and Observations Totals #
Totals (
)
a.
A discussion of actions required to 1
correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate, b.
A discussion of actions required to 5
reduce the~ probability of~ rec ~urrence of the problem or similar event (correct the root cause) was not included or was inadequate.
i c.
08SERVATION: A discussion of actions 0
required to prevent similar failures in sistlar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or
~
i was inadequate.
50.73(b)(5)--Information concerning previous 10 (15) similar events was not included or was inadequate.
~
f C-5
~
Y(;
TA8tE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(11--Text presentation 5 (15) taadequacies.
a.
OBSERVATION: A diagram would have 1
aided in understanding the text discussion.
b.
Text contained undefined acronyms 3
and/or plant specific ~designators.
c.
The text contains other specific 1
deficiencies relating to the readability.
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total, b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the number of LERs for which the requirement was considered applicable.
1 l
l 1
C-6 I
j.
t TA8LE C-2.
A8STRACT DEFICIENCIES AND OBSERVATIONS FOR HADDAM NECK Number of LERs with Deficiencies and Observations y;
Sub-paragraph Paragraph 3
Description _of Deficiencies and Observations Totals' Totals (
)
A summary of occurrences (immediate cause 1 (15) l and effect) was not included or was i
inadequate.
A summary of plant, system, and/or personnel 2 ( 8) 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 12 (15) was not included or was inadequate.
~
A summary of the corrective actions taken or 13 (15) planned as a result of the event was not included or was inadequate.
1 4
C-7 4
'6 d
TABLE C-2.
(continued)
Number of LERs wi.th Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
Abstract presentation inadequacies.
7 (15) a.
CBSERVATION: 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 spaces.
c.
The abstract contains undefined 0
acronyms and/or plant specific designators.
d.
The abstract contains other specific 5
deficiencies (i.e., poor summarization, contradictions, etc.).
a.
The "sub-paragraph total" is a tabulation of specifte defictancies or observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more deficiency or observation.
The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
l I
C-8
l 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 (
)
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.
14 (15) a.
Root cause was not given or was 13 inadequate.
b.
Result (effect) was not given or 4
was inadequate.
c.
Link was not given or was 5
inadequate.
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 1 (15) a.
Date not included.
O b.
OBSERVATION: Repurt date was not I
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 0 (15) inconsistent with text or abstract.
C-9
c*
TA8LE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
Power level was not included or was 0 (15) inconsistent with text or abstract.
Reporting Requirements 0 (15) a.
The reason for checking the "0THER" requirement was not specified in the abstract and/or text.
~~
b.
OBSERVATION:
It may have been more appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It may hive been appropriate to report this event under an additional unchecked paragraph.
(
Licensee Contact 0_(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 6 (15) a.
One or more component failure O
sub-fields were left blank, b.
Cause, system, and/or component code 0
is inconsistent with text.
c.
Component failure field contains data 2
when no component failure occurred.
d.
Component failure occurred but entire 4
field left blank.
C-10
- /
1 TABLE C-3.
(continued) l Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals (
)
-Supplemental Report 3 (15) a.
Neither "Yes"/"No" block of the-1 supplemental report field was checked.
b.
The block checked was inconsistent 2
with the text.
Expected submission date information is 0 (15) inconsistent with the block checked in Item (14).
The "sub-paragraph total" is a tabulation of specific deficiencies or a.
observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals d5 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.
l 1
l C-11 i
I
e APPENDIX 0 LER COMMENT SHEETS FOR FOR HADDAM NECK t
-~,
,,v y
TABLE D-1, SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 1.
LER Number: 86-013-01 Scores:
Text - 8.9 Abstract - 4.0 Coded Fields, 8.7 Overall - 7.4 Text 1,
50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes for each component referred to in the text were not included.
2.
50.73(b)(3)--Were the peak fuel and cladding temperatures calculated?
If so, it would be helpful to provide this information to show the reader the possible severity of the event.
3, 50.73(b)(4)--0BSERVATION:
The score for this requirement is based on the assumption that ths
)
supplemental report will contain all the necessary infornation.
4.
Acronym (s) and/or plant specific designator (s) are undefined. Although LOCA and RCS are fairly common acronyms, it would be helpful if they were defined on their first usage.
Abstract 1.
The abstract lists the various sections contained in the text as opposed to summarizing the details in these sections.
The abstract is intended to b3 a summary; therefore, specific root cause and corrective action information should be included in the abstract as opposed to stating that the*
information is discussed in the text.
Coded Fields 1.
Item (4)--The result is vsJue and the root cause is not included. A more appropriate title might be "Possible Core Uncovery Postulated During a Small Primary System Coolant Break due to Inadequate Small Break Analysis".
0-1
's a
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 2.
LER Number:
86-014-00 Scores:
Text - 7.6 Abstract - 7.1 Coded Fields - 8.0 Overall - 7.5 Text 1.
50.73(b)(2)(ii)(Al--Information concerning the plant operating conditions before the event is not included.
2.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the worn pump wear rings is inadequate.
Was the wear considered normal wear or were other causes investigated? The paragraph under " Background" mentions rebuilding of the pump and motor; however, no cause information is presented for the motor.
3 50.73(b)(2)(11)(F1--The Energy Industry Identification System codes for each component and/or system referred to in the text is not included.
4.
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.
5.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstrs-t 1.
50.73(b)(1)--Summary of the root cause (worn pump wear rings and motor failure) is not included.
2.
50.73(b)(1)--Sumnery of corrective actions taken or planned as a result of the event is inadequate.
The only corrective action mentioned is " repairs" of the fire pump.
0-2
j, a
TABLE D-1.
SPECIFIC lek COMMENTS FOR HADDAM NECK (213)
Section Coments 2.
LER Number:
86-014-00 (continued)
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included. A better title might be: " Electric Fire Pump Fails During Surveillance Test Due to Worn Wear Rings and Motor failure - Technical Specification Violation".
2.
Item (13)--Component failure occurred but entire field is blank.
es 5
0 0-3
. _ _ _ - - - __ =
's TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 3.
LER Number:
86-016-01 1
Scores:
Text - 6.6 Abstract 5.2 Coded Fields. 7.3 Overall - 6.3
~
Text 1.
50.73(b)(2)(11)(Al--Information concerning the plant operating conditions before the event is inadequate.
The fact that the unit was shutdown for refueling at 3
the time of discovery would be appropriate information.
2.
50.73(b)(2)(11)(C)--Time information for discovery, when the system was removed from service, and when the system was placed back into service is not included.
3.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the fan contactor.
selector, and abort switches is not included.
4.
50.73(b)(2)(11)(El--The immediate cause, mode, and effect discussion of each failed component is not included.
No information is provided concerning the selector and abort switches and the effect of the fan contactor " hanging up" is not stated.
5.
50.73(b)(2)(11)(F)--The Energy Industry Identification System codes for each component and/or system referred to in the text is not included.
6.
50.73(b)(2)(11)(H)--A time estimate of the I
unavailability of the failed train / system is inadequate.
7.
50.73(b)(2)(11)(L)--Identification (e.g.,
manufacturer and model no.) of the failed I
component (s) discussed in the text is not included.
8.
50.73(b)(31--can the ventilation fans be shutdown manually at the scene (given a fire in the area)?
)
9.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
The last two sentences on 4
page 4 of 4 are only adequate if there is a commitment to provide a supplemental report, which will describe specifically what was done to prevent 4
4 D-4 I
,. k
- s j
a TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
)
Section Comments 3.
LER Number: 86-016-01 (continued) i recurrence of this (and possibly similar) event (s)
(e.g., provide the new surveillance frequency and/or the specifics of the design change).
10.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
11.
Some ideas are not presented clearly (hard to fpliow).
See the first sentence under "REPORTABILITY".
12.
The term " electric loops" should probably be described in more detail.
13.
It would be good practice to use revision bars in the right margin to indicate all new information in a supplemental report.
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate.
Information as to why the system was inoperable should be provided.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The abstract should summarize what was done to restore the system to an operable status and what is planned to prevent recurrence of the event.
3.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
4.
The last paragraph would read better (be more understandable) if it stated "As it cannot be determined when the system became inoperable, it is conservative to assume that the system was inoperable for a period greater than that allowed by Technical Specification; therefore, this event is being reported per 10 CFR 50.73(a)(2)(1)(8)."
J 0-5
. - -. -. ~. - - -
D a
TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 3.
LER Number:
86-016-01 (continued)
Coded Fields 1.
Item (4)--Title: Cause and link are not included.
The fact that a Technical Specification violation has occurred would be appropriate to mention. A better title might be " Corrosion Due To Weather Exposure Caused Components In The CO2 System To Fail -
System Discovered Inoperable During Test (Technical Specification Violation)".
2.
Item (13)--Component failure occurred but entire field is blank.
3.
Item (14)--The block checked appears to be inconsistent with information provided in the text; see text comment number 9.
D-6
i TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 4.
LER Number: 86-017-00 Scores: Text - 6.4 Abstract = 6.0 Coded Fields = 9.3 Overall - 6.6 Text 1.
50.73(b)(2)(11)(Al--Information concerning the plant operating conditions.before the event is not included.
2.
50.73(b)(2)(11)(C)--Date/ time information concerning how long the barriers could have been inoperable and how this time compared to the Technical Specification limit is not included.
3.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning fire barrier failures is inadequate. What guidance was lacking in the procedure concerning the grout seals and how would the deficiency lead to seal failure? Why was the damming.behind the foam seals missing?
i 4.
50.73(b)(2)(ii)(F1--The Energy Industry Identification System codes for each component and/or system referred to in the text is not included.
5.
50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed train / system is not included (see text comment 2).
6.
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. All of the corrective actions appear to emphasize inspections and procedural changes which are to be performed at the time of installation. What will be done to prevent the newly installed seals from becoming inoperable (e.g., will all seals be examined more often)?
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.
Abstract 1.
50.73(b)(l)--Summary of root cause is not included.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The procedural changes were not summarized.
0-7
r TABLE D-1.
SPECIFIC LER COMMINTS FOR HADDAM NECK (213)
Section Comments 4.
LER Number:
86-017-00 (continued)
Coded Fields' 1.
Item (4)--Title:
Root cause is not included. A more appropriate title might be " Inoperable fire Barrier Penetration Seals Due to Normal Wear and Inadequate Procedural Guidance--Found During 18 Month Surveillance Inspection"..
i i
l I
f i
D-8
a TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 5.
LER Number:
86-022-00 Scores: Text - 7.4 Abstract - 5.0 Coded Fields = 8.5 Overall 6.8 Text 1.
50.73(b)(2)(11)(F)--The Energy Industry Identification System codes for each component and/or system referred to in the text is not included.
2.
50.73(b1(2)(ti)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate.
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. Were any warnings given in the maintenance procedures for adjusting the power range channel?
50.73(b)(2)fli)(J)(2)(iv)--Discussion of the lype of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
3.
50.73(b)(2)(11)(K)--01scussion of automatic and/or manual safety system responses is inadequate. What safety systems, if any, responded to the runback signal? As a minimum provide a list of safety systems that actuated.
4.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included.
Were procedure changes appropriate? Are the other power range channels susceptible to the calibration sensitivity? If so, were they tagged to warn of the potential problems during adjustment?
(
5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
C-9 d
't TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 5.
LER Number: 86-022-00 (continued)
Abstract 1.
50.73(b)(1)--Summary of the safety system responses to the runback signal is not included. See text comment number 3.
2.
50.73(b)(11--Summary of the root cause (personnel error) is not included.
See text comment number 2.
3.
50.73(b)(1)--Sumnery of corrective actions taken or s
planned as a result of the event is inadequate.
See text comment number 4.
4.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (41--Title:
Root cause (personnel error) and link (during setpoint adjustment) are not intluded.
A better title might be:
" Unanticipated Turbine Load Runback During Power Range Setpoint Adjustment Caused by Personnel Adjusting Gain Too Rapidly".
D-10
i TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 6.
LER Number: 86-023-00 Scores:
Text - 8.3 Abstract - 7.5 Coded Fields - 8.5 Overall - 8.1 Text 1.
50.73(b)(2)(11)(C)--Date of the "above normal exercising of the load limiter" is not provided.
Is there a rough time estimate for the completion of the corrective actions?
2.
50.73(b)(2)(11)(01--The root and/or intermediate cause discussion concerning the master cycler is not included. Can the term "above normal" (as it refers to exercising the load limiter) be quantified?
3.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included. For how long a period was the load limiter clutch out of adjustment?
4.
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.
5.
50.73(b)(4)--Discussion of corrective actions taken e
or planned is inadequate.
Was anything changed in the channel 33 (or 34) circuitry to prevent recurrence?
Abstract 1.
50.73(b)(11--Summary of occurrences (immediate cause(s) and effects (s)) is inadequate. A time l
reference for the first three paragraphs would be appropriate. The master cycler problem should have been mentioned, i
2.
50.73(b)(11--Summary of cause information is inadequate. The abstract should indicate that the cause of the spurious actuations is unknown. See the i
first sentence of text comment number 2.
3.
50.73(b)(11--Summary of corrective actions taken or i
planned as a result of the event is inadequate, i
j Current and long-term actions concerning the Nuclear Instrumentation Systems is not mentioned.
i Replacement of the master cycler is not mentioned.
I D-11
8 a
TABLE 0-1.
SPECIFIC LER COMMENTS FOR HAODAM NECK (213)
Section Comments 6.
LER Number: 86-023-00 (continued) 4.
Abstract does not adequately sununarize 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:
Link is not included. A better 1
title might be, " Spurious Dropped Rod-Load Runback Signals During Power Operation Do Not Result In Required ESF Actuation (i.e., load Runback)".
2.
Item (13)--Component failure occurred but entire field is blank.
i i
D-12
q.
TA8LE D-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 7.
LER Number:
86-024-00 Scores:
Text = 8.8 Abstract = 7.7 Coded Fields - 9.1 Overall = 8.5 Text 1.
50.73(b)(2)(11)(C)--Time that the LR8 signal was reset is not included.
2.
50.73(b)(2)(11)(0)--Although the cause could not be found, a brief discussion of actions taken and components tested would be useful.
3, 50.73(b)(2)(11)(F)--The Energy Industry Identification System component identifier codes for the " Rod" and " Turbine" were not included.
4.
50.73(b)(4)--The text is not specific as to what equipment was replaced.
Abstract 1.
50.73(b)(11--Summary of root cause is inadequate.
The fact that the root cause could not be foynd was not mentioned.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The abstract does not mention that suspected equipment was replaced.
Coded Fields 1.
Item (4)--Title:
Root cause (unknown) is not included.
2.
Item (131--The text does not indicate that any equipment failed and does not specifically mention an ampitfier.
If the amplifier actually failed, the text should discuss it and if the amplifier did not fall, this field should be left blank.
D-13
.q TA8LE 0-1.
SPECIFIC LER COMMENTS FOR HA00AM NECK (213)
Section Comments 8.
LER Number: 86-026-00 Scores: Text - 9.2 Abstract 7.8 Coded Fields - 9.5 Overall - 8.8 Text 1.
50.73(b)(2)(ii)(C)--Time at which the plant was stabilized in hot shutdown is not included.
2.
50.73f b)(2)(11)(K)--01scussion of automatic and/or manual safety system responses is inadequate. What safety systems responded to the reactor trip? As a minimum, provide a list of all safety systems that actuated.
3.
50.73(b)(2)(ti)(L)--If the foreign material lodged in the relay contact is considered to be a component failure as evidenced by Item (13) containing coded information, the manufacturer and model number of the relay should be given in the text. No points have been deducted for this requirement however, because it appears personnel error 'and procedure error,are involved in this event.
4.
50.73(b?(5)--Information concerning previous similar events $s not included.
1Y no previous similar events are known, the text should so state.
Asstract 1.
50.73(b)(11--Summary of safety system responses to the reactor trip is not included.
2.
50.73(b)(1)--Summary of root cause (foreign material source - personnel error) is inadequate.
3.
50.73(b)(11--Sumary of corrective actions taken or planned as a result of the event is inadequate.
Summaries relating the removal of the foreign material from the relay contact, the inspection of the other control devices for foreign material, the change in the plant procedure for operation with high control room temperatures, and the long term update to solid state control devices are not included.
Coded Fleids 1.
Item (41--Title:
Root cause (personnel error -
procedural inadequacy) is not included.
0-14
TA8LE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 9.
LER Number:
86-027-00 Scores:
Text. 7.3 Abstract 8.5 Coded F1 elds 8.5 Overall 7.8 Text 1.
50.73(b)(2)(11)(C)--Date and/or time information for occurrences such as the plant being manually tripped, the plant being placed in hot standby, and the plant restart (after first manual trip) is not included.
2.
50.73(b)(2)(11)(Dl--It is not clear why an investigation to determine why the coupling failed was not performed after the coupling failed the first time.
3.
50.73(b)(2)(11)(E)--The reason for the rapid increase in RCS pressure (to 2090 psig) is not explained. Was this a problem caused by the manual operation of the level control valve?
4.
50.73(b)(2)(11)(F)--The Energy Industry Identification System codes for each component and/or system referred to in the text is not included.
S.
50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is' inadcquate. All safety systems that " responded as designed" should be named.
6.
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.
7.
50.73(b)(3)--The third sentence of the SAFETY ASSESSMENT is not clear.
Does this sentence mean that set screws will be added to all other valves 'of this type'? Under ROOT CAUSE, on page 2 of 3, it is stated that " set screws were added", presumably to valve CD-LCV-1312A.
8.
50.73(b)(41--If the results of the investigation of similar control valves or the weekly inspection of the coupling for valve CD-LCV-1312A indicate other problems (causes) and/or corrective actions, a supplemental report explaining these causes and/or corrective actions would be appropriate.
0-15 1
t
- '"i TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 9.
LER Number: 86-027-00 (continued) 9.
50.73(b)f S)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(11--Summary of cause information is inadequate. The abstract should state " vibration" and " design deficiency".
(See Item (13) under "CAUSE".)
2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
The abstract should mention the long-term corrective actions planned.
3.
OBSERVATION:
The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract
_This abstract contains information that was not included in the text (i.e., last paragraph of the abstract).
Coded fields 1.
Item (41--Title:
Root cause and results are not included. A better title might be, " Vibration Induced Valve Stem failure Results In Loss of i
feedwater Pumps and Subsequent Reactor Trip".
2.
Item (14)--See text comment number 8.
h
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0-16
TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
___ Section Comments
- 10. LER Number: 86-031-00 Scores:
Text. 8.4 Abstract - 7.0 Coded Fields - 8.7 Overall. 8,0 Text 1.
50.73(b)(2)(11)(F1--The Energy Industry Identification System component identifier codes for each component referred in the text were not included.
2.
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.
3.
50.93(b)(41--Were any repairs to the valve necessary as a result of the threads lodging in the yoke bushing? A supplemental report appears to be needed to describe the results of the investigation into j
other valves which may have the same problem.
4.
50.73(b)(5)--Information concerning previous similar i
events is not included.
If no previous stellar i
events are known, the text should so state.
S.
Acronym (s) and/or plant specific designator (s) are undefined.
RWST and HPSI were not defined on their first usage.
It is not sufficient to define them in 4
the abstract.
i Abstract 1.
50.13f b)(11--Summary of root cause is not included.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The investigation into other valves to check for a stellar problem was not included in the abstract.
Coded Fleids 1.
Jtes :41--Title:
Root cause (procedural deficiency)
Es no", included.
2.
Item (14)--The block checked appears to be inconsistent with information provided in the text; see text consnent number 3.
i i,
0-17
~
- e., - -. - - -. _,,. -,.
-,-n..-..
- -,, --,,-._...--.,,..-.-,,_-...,,,-..,,., yen.
,,,,,-_,,,_.,,.,---,,.-.,,,..-.-.,.-..-_,,,_-__.e.,
y..4 TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments i
11.
LER Number:
86-032-01 Scores:
Text. 8.3 Abstract. 9.6 Coded Fields 9.5 Overall 6.d 4
Text 1.
50.73(b)(2)(11)(C)--The dates and times of installation of the jumper on channel 34 and the recalibration and return to service of the channel 33 are not included.
2.
50.73Lb)(2)Lill(F1--The Energy Industry Identlficatlon System codes for each component and/or system referred to in the text is not included.
3.
50.73(b)(2:lill(H)--A time estimate of the unaval'abt' tty of the failed train / system is not included.
4.
50.73(b)(2)(11)(L)--Identification (e.g.,
manufacturer and model no.) of the failed i
component (s) discussed in the text is not included.
S.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. Discussion of the long l
term corrective action to update the system is not j
included (this information was provided in the I
abstract).
Abstract 1.
OBSERVATION:
The abstract is intended to be a summary of the text; therefore, the text must include all information summartzed in the abstract.
This abstract contains information that was not included in the text.
See text comment number 5.
Coded Fields 1.
Item (41--Title: Root cause (temperature changes during channel calibrations) is not included.
l t
D-18 1
TABLE 0-1.
SPECIFIC LER COMMENTS FOR HA00AM NECK (213)
Section Consnents 12.
LER Number: 86-035-00 Scores:
Text 8.8 Abstract - 6.9 Coded Fields - 7.0 Overall 8.0 Text 1.
50.73(b)(2)(11)(Al--Information concerning the plant operating conditions before the event is inadequate.
power level prior to the shutdown would be appropriate to provide in the text.
2.
50.73(b)(2:(11)(C)--Date of sampling the 575 tubes and date of the second analysis to determine interim structural acceptance criteria would be helpful.
3.
50.73(b)(2)(11)(J)(2D--01scussion of the personnel error / procedural defhciency is inadequate. Why did the vendor mistakenly plug two tubes in S.G. #47 4.
50.73(b)(31--What percentage of the total population of tubes does the 575 tubes represent? If a catastrophic tube failure did occur, would it represent an undue risk to public health and' safety?
5.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate.
Under 'Long Term Action' on page 3 of 4. how many tubes will have ECT performed on them each refueling outage?
6.
50.73(b)(51--Information concerning previous similar events is inadequate.
The text implies that this is an on-going problem but no history is provided (e.g.,
previous similar events by LER number).
7.
OBSERVATION: A diagram or figure would aid in understanding the event.
The diagram could indicate the " roll transition zone', the " roll expansion region', the position of the tube suppert plate and anti-vibration bar, etc.
Abstract 1.
50.73(b)(11--Summary of cause is inadequate.
The abstract should mention primary water stress corrosion cracking due to manufacturing defects.
0-19
'i, e.
TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments 12.
LER Number:
86-035-00 (continued) 2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
The long-term corrective actions, discussed in the text, should be mentioned in the abstract.
It would also be good to state the acceptance criterton that was developed.
3.
Abstract does not adequately summartze the text.
Additional space is av.1114ble within the abstract field to provide the ne:essary information but it was not uttilzed.
Coded Fields 1.
'tes L41--Title: Cause and result are not included, a betuer title alght be " Eddy Current Testing Indicates Primary Water Stress Corrosion Cracking of S.G. Tubes (Roll Expanston Region) - Plant Was Shutdown and 126 Tubes Plugged".
2.
' tem (131--Component failure occurred but entire leld is blank.
3.
Item (141--Neither "Yes"/"No" block of the supplemental report field is checked.
I j
I I
a 0-20 L ---.- -
o*
'o TABLE D-1.
SPECIFIC LER COMMENTS FOR HADDAN NECK (213)
Section Coments 13.
LER Number:
86-037-00 Scores:
Text = 9.1 Abstract 7.7 Coded Fields - 8.2 Overall = 8.6 Text 1.
50.73(b?(2)(11)(F1--The Energy Industry Identif 4 cation System component identif ter codes for some components such as the tank and pump were not given.
2.
50.73(b)(51--Information oncerning previous sistlar events is not included.
Is no previous similar events are known, the text should so state.
3, Acronym (s) and/or plant spec 1f te designator (s) are undefined.
FOSA was not defined.
Abstract 1.
50.73(b)(11--Sununary of root cause is inadequate.
The imprecise wording in the procedure was not mentioned.
2.
50.73(b)(11--Summary of corrective actions taEen or planned as a result of the event is inadequate.
Neither the checking of other valves for a similar problem nor the use of a dif ferent recirculation line for testing was mentioned.
Coded fields 1.
Item (4)--The result is vague since the possible loss of containment integrity is not specifically stated and the root cause is not included. A.more approprlate titie might be " Improperly Written Testing procedure for High Pressure Safety Injection Results in Loss of Containment Integrity (Technical Spec 1ficatton Violation".
2.
Itom (71--08 SERVAT!0N: Report date is not within th rty days of event date (or discovery date if appropriate).
3.
Item (131--Component failure field contains data when no component failure occurred.
0-21
g
...e TABLE 0-1.
SPECIFIC LER COMMENTS FOR HADDAM NECK (213)
Section Comments
- 14. LER Number:
86-038-00 Scores:
Text = 9.4 Abstract = 9.9 Coded Fields = 9.0 Overall = 9.5 Text 1.
50.73(b)(2)(11)(C)--The date and time that power ascension was permitted after the offset monitors were recalibrated are not included.
2.
50.73(b)(2)(11)(F1--The Energy Industry Identification System codes for each component and/or
___ system referred to in the text is not included.
3.
50.73(b)(51--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
l 4.
The text is a well-written outlined presentation with an excellent background discussion to help the reader understand the function of the power range channels.
l Abstract 1.
No comments.
Coded Fleids 1.
Item L41--Title:
Root cause (detectors not replaced to orIghnal position) and link (during routine e
maintenance) are not included.
The title should indicate that the out of calibration condition was i
not noted untti operating at high power.
l l
D-22
,..... g,
...a TA8tf D-1.
SPECIFIC LER COMMENTS FOR HA00AM NECK (213) l Section Comments I
- 15. LER Number: 86-041-00 l
Scores:
Text - 10.0 Abstract - 8.2 Coded Fields 9.5 Overall 9.4 Text 1.
This is a very well written text.
The format and h
content are excellent.
2.
60.73(b)(2)(11)(F1--The Energy Industry t
- dentification System codes for each component and/or i
system referred to in the text is not included.
Abstract 1.
50.73(b)(11--It might be better to say " failed fully open", rather than " stuck open", in the first sentence.
L 2.
50 '3(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. All the corrective actions (presented on page 4 of 6 in the text) should be sunnerized in the abstract.
~
Coded Fields 1.
Iten (4)--Title:
Cause is inadequate.
The tltle cou' d read " Reactor Manually Tripped When A Weld failure In A Feedwater Regulating Valve Caused The Valve To fall fully Open".
t
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p i
0-23 i
1
-