ML20207P255
| ML20207P255 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/31/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8701150314 | |
| Download: ML20207P255 (50) | |
Text
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)/k DEC 31 1986 Docket No. 50-454 Docket No. 50-455 Comonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
The NRC's Office for Analysis and Evaluation of Operational Data (AE0D) has recently completed an assessment of your Licensee Event Reports (LERs) from Byron Unit 1 for the pariod of November 1, 1985, to October 31, 1986, as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Program.
The results of this evaluation indicated a major improvement in the quality of your LERs since the last evaluation sent to you on November 19, 1985. AE0D has now rated you with the highest overall average score of all facilities that have been evaluated to date.
This demonstrates an apparent commitment on your part to provide the NRC with LERs which consistently meet the requirements contained in 10 CFR 50.73.
We are providing you a copy of AE0D's assessment prior to the issuance of the SALP 6 Board Report so that you are aware of its findings.
We appreciate your cooperation with us.
Please let us know if you have any questions.
Sincerely,
" Original Signed by C. E. Norolius" Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
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,s DEC 31 1988 Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
The NRC's Office for Analysis and Evaluation of Operational Data (AE0D) has recently completed an assessment of your Licensee Event Reports (LERs) from Byron Unit 1 for the period of November 1,1985, to October 31, 1986, as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Program.
The results of this evaluation indicated a major improvement in the quality of your LERs since the last evaluation sent to you on November 19, 1985. AE0D has now rated you with the highest overall average score of all facilities that have been evaluated to date.
This demonstrated an apparent commitment on your part to provide the NRC with LERs which consistently meet the requirements contained in 10 CFR 50.73.
We are providing you a copy of AE0D's assessment prior to the issuance of the SALP 6 Board Report so that you are aware of its findings.
We appreciate your cooperation with us. Please let us know if you have any questions.
Sincerely, G.
ler a Admi trator
Enclosure:
AE0D Assessment cc w/
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DEC 31 1986 Commonwealth Edison Company Distribution cc w/ enclosure:
D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Plant Manager DCS/RSB(RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
Diane Chavez, DAARE/ SAFE Steve Lewis, 0GC H. S. Taylor, Quality Assurance Division cc w/o enclosure:
L. Olshan, NRR LPM
.f J
AE00 SALP IEPUT FOR SYRON 1 -
OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF 1 NOVEM8ER 1985 TO 31 OCTOBER 1986
AEOD INPUT TO SALP REVIEW FOR BYRON 1 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Byron 1 during the November 1, 1985 to October 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the unit's LERs was evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.
The sample consists of a total of 15 LERs.
(Note: No LERs have been submitted by Byron 2 to date). 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 af ter the end i
of the SALP period.
Therefore, all of the LERs prepared during the SALP t
assessment period were not available for review.
Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstracts, 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 and Supplements 1 and 2 to NURE6-1022; based on this comparison, suggestions were developed for improving the quality of the reports. The purpose of this evaluation is to provide feedback to improve the quality of LERs. The evaluation is not intended to increase the requirements concerning the " content" of reports beyond the current requirements of 10 CFR 50.73(b). Therefore, statements in this evaluation that specify measures that should be taken are not intended to increase requirements and should be viewed in that light.
However, the obvious minimum requirements of the regulation must be met.
1
SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Byron 1 during the November 1, 1985 to October 31, 1986 Systematic Assessment of Licensee
(
Performance (SALP) period was performed using a refinement of the basic l
methodology presented in NUREG-1022. Supplement No. 2.
This is the second tioe that the Byron LERs have been evaluated using this methodology.
The results of this evaluation indicate a major improvement in that the Byron l
LERs now have an overall average score of 9.4 out of a possible 10 points, compared to their previous overall average score of 7.5 and a current industry average score of 8.1 (i.e., the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).
Byron's 9.4 is the highest over'all average score I
of all units / stations that have been evaluated to date, which makes their current LERs a model for the industry.
l The only concern identified in the Byron LERs, in terms of safety significance, involves the requirement to adequately discuss corrective actions in the text.
The failure to adequately discuss corrective actions prompts concern as to whether all reasonable actions necessary to try to prevent recurrence of events are being taken.
Strong points for the Byron LERs is that the discussions concerning personnel errors, and the failure mode, mechanism, and effect of failed components, were very well written in all of the LERs involving these requirements.
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 reviewed.
Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER.
The overall score for each l
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 qua11'ty evaluation are divided into two categories:
(1) detailed information and (2) summary information.
The detailed information, presented in Appendices A Jhrough D, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix 8), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of e&ch LER (Appendix 0).
When referring to these appendices, the reader is cautioned not to try to directly correlate the number of cmanents on a consent sheet with the LER scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.
Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below.
These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such t
represent the analysts' assessment of the station's performance (on a scale 2
r
of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b).
Table 1 presents the average scores for the sample of LERs evaluated for 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.
Additional scores are added to Figure 1 each month as other units / stations are evaluated.
Table 2 and Appendix Table 8-1 l
provide a summary of the information that is the basis for the average scores in Table 1.
For example, Byron's average score for the text of the LERs that were evaluated is 9.4 out of a possible 10 points.
From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(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.
Discussion of Soecific Deficiencies A review of the percentage scores pre'sented in Table 2 will quickly point out where the unit is experiencing th'e most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate l
that the unit probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic requirement but has either:
(1) excluded certain less significant information frce 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 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 3
a TABLE 1.
SUMMARY
OF SCORES FOR SYRON 1 Averaae High hw, Text 9.4 10.0 8.4 Abstract 9.4 10.0 8.2 Coded Fields 9.2 10.0 8.4 Overall 9.4 10.0 8.6 a.
See Appendix 8 for a sunsnary of scores for each LER that was evaluated.
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0 4
l
^
Figure 1. Distribution of overall average LER scores 10
,,,,i,,,,,,,,,,,,,,,,,,,,,,,,i,,,,
9-
'E 8-
'O
' *g 7-7 f
6-5-
4-
- Byron 1, 2 3-2-
o,!f,,h,f.'d,h!@f,1,!,,,!,!,,,,,
o 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average scores
TABLE 2.
LER REQUIREMENT PERCENTAGE SCORES f 0R 8YRON 1 TEXT Percentage Reauirements f 50.73(b)1 - Descr iptions a
Scores ( l (2)(11)(A) - - Plant condition prior to event (2)(11)(B) - - Inoperable equipment that contributed 100 (15) b (2)(ii)(C) - - Date(s) and approximate times 92 (15)
(2)(11)(D) - - Root cause and intermediate cause(s) 91 (15)
(2)(ii)(E) - - Mode, mechanism, and effect (2)(11)(F) - - EIIS Codes 100 ( 9) 90 (15)
(2)(11)(6) - - Secondary function affected b
(2)(11)(H) - - Estimate of unavailability 100 (6)
(2)(11)(I) - - Method of discovery 100 (15)
(2)(ti)(J)(1) - Operator actions affecting course 100 ( 7)
(2)(ii)(J)(2) - Personnel error (procedural deficiency)
- - Safety system responses 99 ( 9)
(2)(ii)(K) 98 ( 9)
(2)(ii)(L) - - Manufacturer and model no. Information 94 ( 9)
(3)
Assessment of safety consequences Corrective actions 94 (15)
(4) 85 (15)
(5)
Previous similar event information (2)(1) - - - - Text presentation 100 (15) 93 (15)
ABSTRACT Percentage Recuirements f50.73(b)(111 - Descriptions a
Scores ( l
- Major occurrences (Immediate cause and effect information) 97 (15)
- Description of plant, system, component, and/or personnel, responses 97 ( 9)
- Root cause information 98 (15)
- Corrective Action information 92 (15)
- Abstract presentation 88 (15) 4 6
TABLE 2.
(continued)
CODED FIELDS Percentage Item Number (s) - Description a
Scores ( l 1, 2, and 3 - Facility name (unit no.), docket no. and 99 (15) page number (s) 4 - - - - - - Title 79 (15) 5, 6, and 7 - Event date, LER No., and report date 92 (15) 8 - - - - - - Other facilities involved 100 (15) 9 and 10 - - Operating mode and power level 100 (15) 11 - - - - - Reporting requirements 100 (15) 12 - - - - - Licensee contact information 100 (15) 13 - - - - - Coded component failure infcreation 89 (15) 14 and 15 - - Supplemental report information 90 (15)
I Percentage scores are the result of dividing the total points for a 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 t.he 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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addition, the primary deficiencies concerning the abstract and coded fields are discussed.
Since its previous evaluation, Byron has improved its LERs to the point that every percentage score on Table 2 is greater than 75% and most are greater than 90%. This is a significant accomplishment, and one for which they should be commended.
Byron's LERs are, at this time, the model towards which the industry should strive.
As good as the Byron LERs are, a few deficiencies were noted during the evaluation. Specific comments concerning these deficiencies are contained in Appendix D.
The primary text requirements that could be improved upon are the requirements to discuss root cause and corrective actions, j
Requirements 50.73(b)(2)(11)(D) and 50.73(b)(4), respectively. Both of these requirements were considered to be lacking in nearly half of the fif teen selected LERs.
Root cause information was not always as detailed as the analyst would prefer. For example, if a " motherboard" in a l
microprocessor is believed to have caused channel spiking (either due to the board being bad or a bad edge connector), the analyst would like to know whether this was considered to be a random failure, or a possible l
generic jroblem, or a possible result of poor maintenance practices (during removal and insertion of the board).
Only by knowing this type information can the analyst evaluate whether or not the corrective action discussion is complete, relative to those actions necessary to prevent recurrence of the event.
It follows then, that the deficiencies noted concerning corrective actions is that the discussions do not always adequately address those actions taken or planned to reduce the probability of stellar events occurring in the future.
For example, some corrective action discussions were not complete enough to allow the reader to determine whether action such as the counselling of others that were not directly involved in the event (but who might be required to perform the same or similar task) was performed.
The abstracts are generally good; however many could be better had more of the 1400 spaces available been utilized to provide some of the 8
details provided in the text.
Cause and corrective action information is important in the abstract, as it is in the text, and more details in these areas would enhance the overall abstract.
One deficiency in the area of coded fields involves the title, Item (14). Eight of the titles failed to provide adequate root cause information and four failed to adequately indicate the result of the event. While the result is considered to be the most important part of the title, cause and link information must be included to make a title complete.
For some of the titles, an example title is provided that indicates the type of information that the analysts feel would be appropriate. See Appendix D, under the Coded Fields section. Note that most of the example titles are long; however there is space available in the title field for two lines.
Another area of the coded fields is not being completed as intended.
Item (13), the Component Failure field is only required to be completed when a component fails.
Information concerning faulted components, such as a valve that is placed in the wrong position or a pump that does not have power because a breaker is open, does not have to be included in this field. providing information in this fie-1d for other than failed components may mislead those who may select a population of LERs to review based on this field containing data (i.e., an analyst that is performing an analysis of failed components).
The final area of the coded field section that should be discussed is Item (14), Supplemental Report information. While 50.73(c) 1s clear in stating that if the Commission requires the licensee to submit supplemental information beyond that required by 50.73(b), this request will be sede 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).
Without a commitment to provide a supplemental report (when inforsetton required by 50.73(b) is not provided), the analyst most consider the failure to commit to a supplement to be a deficiency.
9
Table 3 provides a suunary of the areas that need improvement for the Byron 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 found in NUREG-1022, Supplement No. 2.
As was noted, this is the second time that the Byron LERs have been evaluated using this same methodology.
The previous evaluation was reported in November of 1985. Table 4 provides a comparison of the scores for both evaluations. As can be seen, the Byron LERs have improved significantly since the previous evaluation and are now well above the current industry overall average of 8.1.
(Note: The industry overall average is the result of averaging the. latest overall average score for each unit / station that has been evaluated using this methodology.)
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TABLE 3.
AREAS MOST NEEDING IMPROVEMENT FOR BYRON 1 LERs Areas Comments Root cause and corrective Root cause and corrective action discussion should contain sufficient information to allow the reader to see a logical relationship between the cause and corrective action taken.
Corrective actions must include those planned or taken to reduce the probability of similar events occurring in the future.
Abstracts More details concerning cause and corrective action information could be included. More of the space available in the abstract field should be utilized.
Coded fields a.
Titles Titles should be written such that they better describe the event.
In particular, try to include the root cause and result in each title.
b.
Supplemental reports A commitment to a supplemental report is appropriate whenever tne results of an investigation into some aspect of an event are pending.
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TABLE 4.
COMPARISON OF LER SCORES FROM PREVIOUS EVALUATION Report Date November-85 November-86 Text average 7.5 9.4 Abstract average 7.3 9.4 Coded fields average 8.3 9.2 Overall average 7.5 9.4 e
G O
e 0
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REFERENCES 1.
Office for Analysis and Evaluation of Operational Data Licensee Event Reoort System, NURE6-1022 Supplement 'No. 2. U.S. Nuclear Regulatory Connission, September 1985.
2.
Office for Analysis and Evaluation of Operational Data Licensee Event Reoort System, NUREG-1022, U.S. Nuclear Regulatory Commission.
September 1983.
3.
Office for Analysis and Evaluation of Operational Data Licensee Event Report System, NURE6-1022 Supplement No.1. U.S. Nuclear Regulatory e
Coram1ssion. February 1984.
9 l
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APPENDIX A LER SANPLE SELECTION INFORMATION FOR BYRON 1
TABLE A-1.
LER SAMPLE SELECTION FOR 8YRON 1 (454)
Sample Number Unit number LER Number Comments 1
1 85-096-00 I
2 1
85-097-00 ESF 3
1 85-099-01 ESF 4
1 85-101-00 SCRAM 5
1 86-001-00 SCRAM 6
1 86-002-01 ESF 7
1 86-003-00 SCRAM 8
1 86-004-01 ESF 9
1 86-005-00 10 1
86-008-00 SCRAM 11 1
86-012-00 12 1
86-015-00 13 1
86-017-00 14 1
86-020-00 15 1
86-022-00 4
A-1
APPENDIX 8 EVALUATION SCORES OF INDIVIDUAL LERS FOR BYRON 1
TABLE B-1.
EVALUAT]DN SCORES OF INDIVIDUAL LERs FOR BYRON 1 (454)
LER Sampie Number
- 1 2
3 4
5 6
7 8
Text 8.8 10.0 9.1 9.3 10.0 9.1 9.0 8.9 Abstract 9.1 9.8 9.2 8.2 10.0 9.2 9.5 9.3 Coded 8.8 9.7 9.0 9.3 9.9 9.0 8.7 9.0 Fields Overall 8.9 9.9 9.1 9.0 10.0 9.1 9.1 9.0 LER Sample Number
- 9 10 11 12 13 14 15 Averaae Text 10.0 9.7 9.9 9.6 9.4 8.4 9.6 9.4 Abstract 9.4 10.0 9.9 9.4 9.5 9.2 9.1 9.4 Coded 9.4 10.0 9.4 8.8 9.3 8.4 8.7 9.2 Fields Overall
,9.8 9.8 9.8 9.4 9.4 8.6 9.4 9.4 See Appendix A for a list of the corresponding LER numbers.
a.
8-1
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0 APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR BYRON 1 bi ii sii um
TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR BYRON 1 (454)
Number of LERs with 1
Deficiencies and Observations Sub-paragraph Paragraph Bescription of Deficiencies and Observations Totals' Totals (
l b 50.73(b)(2)(11)(Al--Plant operating 0 (15) conditions before the event were not included or were inadequate.
50.73(b)'2)(11)(81--Discussion of the status 0 ( 7) 4 of the s",ructures, 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)(11)(C)--Fa11ure to include suf ficient date and/or time information.
5 (15) a.
Date information was insufficient.
3 b.
Time information was insufficient.
2 50.73(b)(2)(11)(D)--The root cause and/or 6 (15) intermediate failure, system failure, or personnel error was not included or was inadequate.
a.
Cause of component failure was not 6
included or was inadequate b.
Cause of system failure was not 0
l included or was inadequate c.
Cause of personnel error was not 0
included or was inadequate.
50.73(b)(2)(11)(El--The failure mode.
0 ( 9) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode was not included or was inadequate b.
Mechanism (immediate cause) was not included or was inadequate c.
Effect (consequence) was not included or was inadequate.
l C-1
t TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(11)(F)--The Energy Industry 4 (15')
Identification System component function identifier for each component or system was i
not included.
50.73(b)(2)(11)(G)--For a failure of a
-- ( 0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.
50.73(b)(2)(11)(H)--For a failure that 0 (6) i 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)(11)(I)--The method of discovery 0 (15) 4 of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
1 4.
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 t
personnel error was not included or was inadequate d.
Method of discovery for each procedural error was not included or was inadequate.
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9 C-2
. -. ~
TABLE 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)(11)(J)(11--Operator actions that 0 ( 7) i i
affected the course of the event including operator errors and/or procedural deficiencies were not included or we,re inadequate.
50.73(b)(2)(11)(J)(2)--The discussion of 1 ( 9) each personnel error was not included or was inadequate.
a.
08SERVATION:
A personnel error was implied by the text, but was not,
explicitly stated.
b.
50.73(b)(2)(11)fJ)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(iilfJ)(2)(11)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure.was not included or was inadequate.
d.
Sp.73(b)(2)(ii)(J)(2)(iii)--Discussion l
of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
e.
50.73(b)(2)(11)fJ)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility non11 censed operator, other utility personnel) was not included or was inadequate.
C-3
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)(K)--Automatic and/or manual 1 ( 9) safety system responses were not included or were inadequate.
50.73(b)(2)(111(L)--The manufacturer and/or 2 ( 9) model number of each failed component was not included or was inadequate.
50.73(b)(31--An assessment of the safety 3 (15) consequences and implications of the event I
was not included or was inadequate.
i a.
O8SERVATION: The availability of 0
other systems or components capable l
of mitigating the consequences of the j
event was not discussed.
If no other l
systems or components were available, the text should state that none existed.
b.
08SERVATION: The consequences 1
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 7 (15) actions planned as a result of the event including those to reduce the probability of siellar events occurring in the future was not included or was inadequate.
C-4
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 2
reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c.
OBSERVATION: A discussion of actions 1
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information concerning previous 0 (15) similar events was not included or was inadequate.
C-5
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph 1
Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(1)--Text presentation 1 (15) inadequacies.
a.
OBSERVATION: A diagram would have 0
aided in understanding the text discussion.
b.
Text contained undefined acronyms 1
and/or plant specific designators.
c.
The text contains other specific 0
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 requirenent deficiencies or observations.
The number in parenthesis is the number of LERs for which the requirement was considered applicable.
I f
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c-6
TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR 8YRON 1 (454)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
A summary of occurrences (immediate cause 2 (15) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 1 ( 9) responses was not included or was inadequate.
a.
Summary of plant responses was not 0
included or was inadequate.
b.
Suanary of system responses was not 0
included or was inadequate.
c.
Sumnery of personnel responses was not 1
included or was inadequate.
A summary of the root cause of the event 2 (15) was not included or was inadequate.
A summary of the corrective actions taken or 3 (15) planned as a result of the event was not included or was inadequate.
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C-7
TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Descriotion of Deficiencies and Observations Totals' Totals (
)
Abstract presentation inadequacies 4 (15) a.
OBSERVATION: The abstract contains 1
information not included in the text.
The abstract is intended to be a summary of the text, therefore, the i
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 3
deficiencies (i.e., poor summarization, contradictions, etc.)
i a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.
Since an LER can have more than
. one deficiency for certain requirements, 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 i
for which a certain requirement was considered applicable.
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C-8
~.
TABLE C-3.
C00E0 FIELDS DEFICIENCIES AND OBSERVATIONS FOR BYRON 1 (454)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
facility Name 0 (15) i 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.
Paga Number was not included or was 1 (15) lacorrect.
Title was left blank or was inadequate 11 (15) i a.
Root cause was not given in title 8
i b.
Result (effect) was not given in title 4
c.
Link was not given in title O
Event Date 2 (15) a.
Date not included or was incorrect.
1 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 1
l b.
08SERVATION:
Report date was not 0
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.
l C-9
TA8tE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph b
Description of Deficiencies and Observations Totals
- Totals (
l 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" 4
requirement was not specified in the abstract and/or text.
b.
OBSERVATION:
It may have been more appropriate to report the event under i
a different paragraph.
c.
OBSERVATION:
It may have 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 Comp 6nent Failure Information 8 (15) a.
One or more component failure 0
sub-fields were left blank.
b.
Cause, system, and/or component code 0
is inconsistent with text.
c.
Component failure field contains data 8
when no component failure occurred.
d.
Component failure occurred but entire 0
field left blank.
l C-10
I TA8LE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Bescriotion of Deficiencies and Observations Totals' Totals (
)
Supplemental Report 2 (15) a.
Neither "Yes"/"No" block of the 0
supplemental report field was checked.
b.
The block checked was inconsistent 2
with the text.
Expected submission date information is 0 (15) i inconsistent with the block checked in 1
Item (14).
l a.
The "sub-paragraph total" is a tabulation of specific deficiencies or l
observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not 1
necessarily add up to the paragraph total.
l b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the i
nua6er of LERs for which a certain requirement bas considered applicable.
f C-11 i
9 9
9 9
9 9
6 APPENDIX D LER COMENTS SHEETS FOR BYRON 1 l
l i
,----.,-----r.--,
nw,,,--
TA8LE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 1.
LER Number:
85-090-00 Scores:
Text - 8.8 Abstract - 9.1 Coded Fields - 8.8 Overall = 8.9 Text 1.
50.73(b)(2)(it)(J)(21--Discussion of the personnel error is inadequate. An explanation of how the misinterpretation occurred would be useful.
2.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Were there any other systems available as backup had the instruments been out of calibration? If no other systems or instruments were available, the text should so state.
3.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. Were other Technical Specification sections reviewed to see if a similar misinterpretation involving other instruments or j
. systems could occur?
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--The result is vague. A more appropriate title might be " Incorrect Containment Pressure Loops Utilized to Fulfill Post Accident Monitoring Requirements (Technical Specification Violation) Due l
to Misinterpretation of the Technical Specifications".
2.
Item (51--The date given as the event date is never discussed in the text.
3.
Item (13)--Component failure field contains data when no component failure occurred.
D-1
TABLE 0-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 2.
LER Number:
85-097-00 Scores: Text - 10.0 Abstract - 9.8 Coded Fields - 9.7 0' era 11 - 9.9 v
Text 1.
This is a well-organized presentation.
Abstract 1.
No comments.
Coded Fields 1.
Item (41--Title:
Root cause (" Personnel Error Caused - ")
2.
Item (13)--Component failure field contains data when no component failure occurred.
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O D-2
TA8LE 0-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 3.
LER Number: 85-099-01 Scores: Text - 9.1 Abstract = 9.2 Coded Fields - 9.0 Overall - 9.1 Text 1.
50.73(b)(?)(11)(C)--Date information for major occurrences is inadequate. When was the motherboard for OPR31J replaced? This date is needed to tell the reader approximately how long the channel has gone without spiking.
2.
50.73(b)(2)(ii)(D)--The root 2nd/or intermediate cause discussion concerning the failed motherboard is not included. Was this considered to be a random failure?
3.
50.73(b)(41--Discussion of corrective actions taken or planrad is inadequate. Are any actions planned to try to prevent such problems in.the future (if the problem was not considered to be a random failure)?
4.
Acronym (s) and/or plant specific designator (s) are undefined.
(Section F, '08" and "M/U".)
5.
The use of " revision bars" is good.
Abstract 1.
There is additional space in the abstract field to supply more details from the text.
Coded Fields 1.
Item (41--Title: Root cause is not included.
The phrase " Caused By A Failed Motherboard In The Monitor" should be added to the title.
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1 0-3
TABLE D-1.
SPECIFIC LER COMMENTS FOR SYRON 1 (454)
Section Comments 4.
LER Number:
85-101-00 Scores: Text - 9.3 Abstract - 8.2 Coded Fields - 9.3 Overall - 9.0 Text 1.
50.73(b)(2)(111'C)--The date in the third paragraph in Section "B" appears to be a typographical error.
2.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the inoperable transmitter is not included.
3.
50.73(b)(2)(11)(F1--The EIIS codes for the steam generator were not included.
4.
50.73(b)(41--Was the transmitter successfully repaired?
Abstract 1.
50.73(b)(11--Summary of occurrences [1mmediate i
cause(s) and effects (s)) is inaaequate.
The failed flow transmitter should be mentioned.
Coded fields 1.
Item (41--Title:
Root cause is not included.
A more appropriate title might be "High Steam Generator Level Reactor Trip During Testing Due To A Procedural Deficiency".
2.
Item (13)--Data is required to be entered in this field only for component failures; therefore, the cause code of "A" in the second line need not be included.
r 0-4
TABLE 0-1.
SPECIFIC LER COMMfMTS FOR BYRON 1 (454)
Section Comments 5.
LER Number:
86-001-00 Scores: Text - 10.0 Abstract - 10.0 Coded Fields - 9.9 Overall - 10.0 Text 1.
No comments.
Abstract 1.
No comments.
Coded Fields 1.
Item (131--Component failure field contains data when no component failure occurred.
I I
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0-5
TABLE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 6.
LER Number:
86-002-01 Scores:
Text - 9.1 Abstract - 9.2 Coded Fields - 9.0 Overall - 9.1 Text 1.
50.73fb)(2)(11)(C)--Date information for major occurrences is inadequate. When was the motherboard for OPR31J replaced? This date is needed to tell the reader approximately how long the channel has gone without spiking.
2.
50.73fb)(2)(11)fD)--The root and/or intermediate cause discussion cor.cerning the failed motherboard is not included.
Was this considered to be a random failure?
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Are any actions planned to try to prevent such problems in the future (if the problem was not considered to be a random failure)?
4.
The use of " revision bars" is good.
Abstract 1.
There is additional space in the abstract field to supply more details from the text.
Coded fields 1.
Item (4)--Title:
Root cause is not included.
The phrase " Caused By A failed Motherboard In The Mcnitor" should be added to the title.
D-6 l
~ TABLE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 7.
LER Number:
86-003-00 Scores:
Text - 9.0 Abstract - 9.5 Coded Fields - 8.7 Overall 9.1 Text 1.
50.73(b)(2)(11)(F)--All the Energy Industry Identification System component identifiers were not included.
2.
50.73(b)(2)(11)(K)--Any safety systems which actuated as a result of the event should be listed.
3.
50.73(b)(41--A supplemental report appears to be needed to describe the results of the investigation into the suitability of the relay contacts. Without a commitment to submit a supplemental report, this LER aust be considered incomplete.
Abstract 1.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should indicate that the limit switch and the SR coil were replaced.
Coded Fields 1.
Item (14)--The block checked is inconsistent with i
information in the text (see text comment 3).
0-7
TABLE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 8.
LER Number:
86-004-01 Scores: Text - 8.9 Abstract = 9.3 Coded Fields - 9.0 Overall - 9.0 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate.
cause discussion concerning the 480 V breaker failure is inade breaker?quate.
Did a failure actually occur with the 2.
50.73(b)(2)(ii)(L)--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is inadequate.
Information concerning the 480 V breaker is not presented.
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
A supplemental report appears to be needed to describe the discussion of the results of maintenance on the 480 V breaker.
Without a commitment to submit a supplemental report, this LER must be considered incomplete.
Abstract 1.
50.73(b)(1)--Summary of personnel responses is not included.
Manual stoppage of the fans is not mentioned.
Coded Fields 1.
Item (4)--Title:
Root casse (personnel error) is not included.
l 2.
Item (14)--The block checked is inconsistent with information in the text.
See text comment number 3.
D-8
TA8LE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 9.
LER Number: 86-005-00 Scores:
Text - 10.0 Abstract - 9.4 Coded Fields - 9.4 Overall - 9.8 Text 1.
This is a well written text!
Abstract 1.
50.73(b)(11--Summary of corrective actions'taken or planned as a result of the event is inadequate.
The fact that the kER was included on the required reading list and a new pump design is being considered should have been included in the abstract.
Coded Fields 1.
Item (41--Title:
Root cause of monitor inoperability (seal failure due to high suspended solids) is not included.
2.
Item (13)--Compone.nt failure field contains data when no component failure occurred.
The second line of the component failure field is not required to be completed.
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D-9
TABLE D-1.
SPECIFIC LER COMMENTS FOR SYRON 1 (454)
Section Conments
- 10. LER Number: 86-008-00 Scores: Text - 9.7 Abstract - 10.0 Coded Fields - 10.0 Overall - 9.8 Text 1.
50.73(b)(2)(ii)(F)--The EIIS system codes were given but all component codes were not included.
Abstract 1.
No comment.
Coded Fields 1.
No comument.
4 0-10
TABLE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454)
Section Comments 11.
LER Number:
86-012-00 Scores: Text - 9.9 Abstract - 9.9 Coded Fields - 9.4 0'verall - 9.8 Text 1.
50.73(b)(2)(11)f C)--Approximate time information for major occurrences is not included.
Only the discovery time is included.
Abstract 1.
No comments.
'Joded Fields 1.
Item (51--01(covery date is given instead of event date. This is alright if the event date is not known.
2.
Item (13)--Component failure field contains data when no component failure occurred.
i k
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D-11
m TASLE D-1.
SPECIFIC LER CONNENTS FOR 8YRON 1 (454)
Section Comments 12.
LER Number: 86-015-00 Scores:
Text - 9.6 Abstract - 9.4 Coded Fields - 8.8 Overall - 9.4 Text 1.
50.73(b)(2)(11)fI)--Why was this problem identified at this time (i.e., May 7, 1986) when it had gone undetected for 12 other times?
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
From the discussion, it is not obvious why, if the test voltage signal is wrong, the actual setpoint was correct.
Abstract 1.
The abstract should indicate that the 8DPS was only
" technically" inoperable.
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.
Namely, the approximate time from the issuance of the Operating License to May 7, 1986.
Coded Fields 1.
Jtem (31--Page number is incorrect (1 of 3, not of 4).
2.
Item (4)--Title:
Result is not included. A better title might be " Incorrect Test Voltage Used To Verify Setpoint of Boron Oilution Protection System -
Procedural Inadequacy".
3.
Item (13)--Component failure field contains data when no component failure occurred.
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l D-12
TABLE D-1.
SPECIFIC LER COMMENTS FOR 8YRON 1 (454)
_Section Comments 13.
LER Number: 86-017-00 Scores: Text = 9.4 Abstract - 9.5 Coded Fields - 9.3 Overall = 9.4 Text 1.
50.73(b)(2)(11)(01--Although the reason for the beat spring was indeterminate, the actions taken to try to discover the cause should be discussed.
2.
50.73(b)(2)(11)(F)--The EIIS system codes were given, but the component codes were not included.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract summary should indicate that the cause of the bent spring could not be determined.
Coded Fields 1.
Item (45--Title:
Root cause (component failures) is not inc',uded.
[
l 0-13
TA8tE D-1.
SPECIFIC LER COMMENTS FOR SYRON 1 (454) l Section Comments
- 14. LER Number:
86-020-00 Scores: Text = 8.4 Abstract = 9.2 Coded Fields - 8.4 Overall = 8.6 Text 1.
50.73(b)(2)(ii)(C)--The approximate time the leak started, if known, could be provided.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the failed diaphragm is inadequate. What caused the diaphragm to fall?
3.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state. What would be the potential consequences of a much larger isolation valve leak or if several such valves leaked?
4.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Were the similar valves i
checked for potential leaks? What was done to minimize recurrence?
Abstract 1.
50.73(b)(11--Summary of root cause is inadequate.
See text comment 2.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment 4.
Coded Fields 1.
Item (4)--Title:
Root cause (diaphragm failure) and result (Technical Specification violation) are l
inadequate.
I 2.
Item (71--Report date is not included.
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l D-14
TABLE D-1.
SPECIFIC LER COMMENTS FOR BYRON 1 (454) 4 Section Comments
- 15. LER Number:
86-022-00 Scores: Text. 9.6 Abstract - 9.1 Coded Fields - 8.7 Overall = 9.4 Text 1.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate.
Was anything done to try to prevent recurrence of such a personnel error by other individuals who might be responsible for ensuring that a special procedure is performed?
Abstract 1.
There is sufficient space remaining in the abstract field for more details concerning this event.
l Coded Fields 1.
Item (41--The title is somewhat unclear as the term
" action response" does not seem to be a standard term for "LC0 actions".
2.
Item (131--Component failure field contains data when no component failure occurred.
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D-15
_