ML20211G291

Forwards AEOD Assessment of LERs as Part of Salp.Significant Improvement in Quality of Repts W/Current Rating of 8.9 Noted

ML20211G291
Person / Time
Site:	Dresden
Issue date:	02/17/1987
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8702250334
Download: ML20211G291 (50)

Text

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FEB 171987 Docket No. 50-237 Docket No. 50-249 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 Dresden 2 and 3 Licensee Event Reports (LERs) as part of the NRC's Systematic Assessment of Licensee Performance (SALP). The Dresden LER assessment indicated a significant improvement in the quality of the reports with a current rating of 8.9 compared to the 7.2 received during the previous assessment and a current industry average of 8.2.

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.

If you have any questions, please contact Mr. R. F. Warnick (312/790-5575).

Sincerely, Charles E. Norelius, Director Division of Reactor Projects

Enclosure:

AE0D Assessment cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing J. Eenigenburg, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division hs RIII

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR ORESDEN 2,3

i i TABLE A-1. LER SAMPLE SELECTION FOR DRESDEN 2, 3 (237, 249)

LER Number Unit Number LER Number Comments 1 2 85-041-00 SCRAM 2 2 85-043-00 ESF 3 2 85-044-00 4 2 86-001-00 SCRAM 5 2 86-004-01 6 2 86-009-00 7 2 86-017-00 SCRAM,ESF 8 2 86-021-00 9 2 86-023-00 ESF 10 3 85-023-00 SCRAM 11 3 86-002-00 ESF 12 3 86-004-00 13 '3 86-007-00 ESF 14 3 86-014-00 15 3 86-016-01 SCRAM A-1

APPENDIX 8 EVALUATION SCORES OF INDIVIDUAL LERS FOR DRESDEN 2,3 l

l

e I TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR DRESDEN 2,3 a

LER Sample Number 1 2 3 4 5 6 7

____-_______--___-__________-_______-___________-_____________-_________8 _-_

Toxt 7.9 9.6 9.6 8.4 7.9 9.0 8.8 9.2 Abstract 8.8 9.0 9.7 9.1 9.7 9.2 9.0 9.8 Coded Fields 8.8 9.4 10.0 9.4 9.5 7.5 9.7 9.5 Ovarall 8.2 9.4 9.7 8.7 8.6 8.9 8.9 9.4 a

LER Sample Number 9 10 11 12 13 14 15 Avera

--_---_-__-_-__-____-_--__--_--_----_-___-_-----_-_-____---___-_---_----ge -_

Text 9.6 8.9 9.6 7.5 8.8 6.6 8.5 8.7 Abatract 10.0 9.1 9.5 9.4 9.2 8.0 9.6 9.3 Coded Fields 10.0 8.5 9.2 8.5 9.8 10.0 9.3 9.3 Overall 9.8 8.9 9.5 8.2 9.0 7.4 8.9 8.9

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

B-1

APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR DRESDEN 2,3

i TABLE C-1, TEXT DEFICIENCIES AND OBSERVATIONS FOR DRESDEN 2,3 (237, 249)

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

50.73(b)(2)(ii)(A)--Plant operating 2 (15) conditions before the event were not included of were inadequate.

50.73(b)(2)(11)(B)--Discussion of the status 0 ( 1) of the structures, components, or systems that we'e inoperable at the start of the event and that contributed to the event was not included or was inadequate.

50.73(b)(2)(ii)(C)--Fa11ure to include 7 (15) sufficient date and/or time information.

1

a. Date information was insufficient. 7

b. Time information was insufficient. 4 50.73(b)(2)(11)(D)--The root cause and/or 3 (15) intermediate failure, system failure, or personnel error was not included or was inadequate,

a. Cause of component failure was not 3 included or was inadequate

b. Cause of system failure was not 0 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, 1 (10) 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 a inadequate

b. Mechanism (irmediate cause) was not 0 included or was inadequate

c. Effect (consequence) was not included 1 or was inadequate.

i C-1 l

6 .. _ - ._- - _ _ . - , . _ , , _ _ -

..p .

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)(F)--The Energy Industry 15 (15)

Identification System component function identifier for each component or system was not included.

50.73(b)(2)(ii)(G)--For a . failure of a -- ( 0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

50.73(b)(2)(ii)(H)--For a failure that 0 ( 3) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

50.73(b)(2)(ii)(I)--The method of discovery 0 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

a. Method of discovery fo. each component failure was not included or was inadequate

b. Method of discovery for each system I

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, t

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)(11)(J)(1)--Operator actions that 1 ( 5) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(b)(2)(ii)(J)(2)--The discussion of 3 ( 8) each personnel error was not included or was inadequate.

a. OBSERVATION: A personnel error was 1 l implied by the text, but was not j explicitly stated,

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

c. 50.73(b)(2)(ii)(J)(2)(111--Discussion 0 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. 50.73(b)(2)(11)(J)(2)(tii)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.

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

2 4

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i 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 2 ( 9) safety system responses were not included or were inadequate.

50.73(b)(2)(ti)(L)--The manufacturer and/or 5 (10) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 0 (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)(4)--A discussion of any corrective 7 (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.

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 2 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 2 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 1 (15) similar events was not included or was inadequate.

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C-5 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)(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 2 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 4

i 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 1; the number of LERs for which the requirement was considered applicable.

4 4

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TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR ORESDEN 2,3 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals # Totals ( )

A summary of occurrences (immediate cause 0 (15) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 0 ( 9) 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 2 (15) was not included or was inadequate.

A summary of the corrective actions taken or 4 (15) planned as a result of the event was not included or was inadequate.

C-7

TABLE C-2. (continued)

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

Abstract presentation inadequacies 9 (15)

a. OBSERVATION: The abstract contains 0 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 9 1400 characters

c. The abstract contains undefined 0 acronyms and/or plant specific designators,

d. The abstract contains other specific 0 deficiencies (i.e., poor summarization, contradictions, etc.)

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, 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.

1 C-8

TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR DRESDEN 2,3 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 8 (15)

a. Root cause was not given in title 7

b. Result (effect) was not given in title 1

c. Link was not given in title 2 Event Date 0 (15)

a. Date not included or was incorrect.

b. Discovery date given instead of event date.

LER Number was not included or was incorrect 0 (15)

Report Date 0 (15)

a. Date not included

b. OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).

Other Facilities information in field is 1 (15) inconsistent with text and/or abstract.

Operating Mode was not included or was 0 (15) inconsistent with text or abstract.

C-9 I

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. . j TABLE C-3. (continued)

Number of LERs with I 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 m.ay have been nore appropriate to report the event under a different paragraph.

c. OBSERVATION: It may have been appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 2 (15)

a. Field left blank 0

b. Position title was not included 2

c. Name was not included 0

d. Phone number was not included. O Coded Component failure Information 4 (15)

a. One or more component failure 0 sub-fields were left blank,

b. Cause, system, and/or component code 1 is inconsistent with text.

c. Component failure field contains data 3 when no component failure occurred,

d. Component failure occurred but entire 0 field left blank.

C-10

TABLE C-3. (continued)

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

Supplemental Report 0 (15)

a. Neither "Yes"/"No" block of the supplemental report field was checked.

b. The block checked was inconsistent with the text.

Expected submission date information is 1 (15) inconsistent with the block checked in Item (14).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.

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

C-ll

APPENDIX D LER SAMPLE SELECTION INFORMATION FOR DRESDEN 2,3

.p t TABLE D-1. SPECIFIC LER COMMENTS f0R DRESDEN 2 (237)

Section Comments

1. LER Number: 85-041-00 Scores: Text = 7.9 Abstract = 8.8 Coded Fields - 8.8 Overall = 8.2 Text 1. 50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event is inadequate. The power l- level before the scram was not included.

2. 50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name code of each componer.t or system referred to in the LER is not  ;

included. I i

, 3. 50.73(b)(2)(ii)(J)(2)--A discussion was not included as to whether or not the EA was following an approved procedure when the ATWS occurred (e.g., Are the gate valves opened before or after the instrument manifold valves?).

4. 50.73(b)(2)(11)(L)--Identificatiog (e.g.,

! manufacturer and model no.) of the failed j component (s) discussed in the text is not included.

T

5. 50.73(b)(4)--The text states that the EA used caution

, in opening the gate valve. It would, therefore, be helpful to be more specific about the correct procedure which will be discussed in the next operator training session (see text comment 3).

6. Some ideas are not presented clearly (hard to follow)

(see text comment 3).

Abstract 1. The abstract contains greater than 1400 spaces.

i 1 Coded Fields 1. Item (4)--Title: Root cause (valve failure) is not

) included. A more appropriate title might be

" Erroneous High Water Level (Turbine Stop V11ve Closure) Scram Due to a Failed Level Instrument Manifold Valve",

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i 0-1 l

TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

1. LER Number: 85-041-00 (continued)

2. Item (12)--Position title is not included.

3. Item (13)--The first line is appropriate but no data is necessary in the second line.

D-2  ;

l i._._.-_-_._... _ . _ _ _ _ _ _ . , , _ _ _ _ _ _ . _ _ _ _ _ _ _ . .

. t TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

2. LER Number: 85-043-00 Scores: Text - 9.6 Abstract - 9.0 Coded fields - 9.4 Overall - 9.4 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function identifier codes are not provided in the text.

Abstract 1. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.

Counselling all personnel involved is not discussed.

2. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: Link (open breaker) is not included. A better title might be: " Procedural Inadequacy Allows Unit 3 DC Breaker to be Opened Resulting in Loss of Power to Turbine Building DC Reserve Buses".

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

D-3

TA8LE 0-1. SPECIFIC LER COMMENTS FOR ORESDEN 2 (237)

Section Comments

3. LER Number: 85-044-00 Scores: Text - 9.6 Abstract - 9.7 Coded Fields - 10.0 Overall - 9.7 Text 1. 50.73(b)(2)(ii)(D)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function identifier codes are not provided.

Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. No comments.

D-4

e c .

l TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

4. LER Number: 86-001-00 Scores: Text - 8.4 Abstract - 9.1 Coded Fields - 9.4 Overall - 8.7 Text 1. 50.73(b)(2)(ii)(C)--Approximate completion dates for the corrective actions would be helpful.

2. 50.73(b)(2)(11)(D)--The cause of the manifold valve seat wear was not included. Is it also attributed to age?

3. 50.73(b)(2)(11)(F1--The Energy Industry Identification System identifier for each component referred to in the text were not involved.

4. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The systems isolated by a Group J isolation were not listed.

5. 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.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The fact that the manifolds will be replaced in both units was not mentioned.

2. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (14)--It would be helpful if the text explained when ar.d why the supplemental report will be submitted.

D-5

TABLE 0-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

5. LER Number: 86-004-00 Scores: Text - 7.9 Abstract = 9.7 Coded Fields - 9.5 Overall - 8.6 Text 1. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the flow transmitter miscalibration is inadequate. The discussion is not clear whether the installation of a protective barrier around the feedwater transmitter alludes to the root cause for the miscalibration being a bump from personnel in the area. Is the transmitter physically located such that it could be bumped easily?

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function codes are not provided in the text.

3. 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.

4. 50.73(b)(4)--To help prevent recurrence of the event, were other transmitters examined for susceptability to bumping by personnel?

5. The use of vertical bars in the margin would be helpful to identify changes in the revised report.

Abstract 1. See text comment number 4.

2. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: Root cause (personnel bumping or calibration drift) is not included.

D-6

TABLE 0-1. SPECIFIC LER COMMENTS FOR ORESDEN 2 (237)

Section Comments

6. LER Number: 86-009-00 Scores: Text - 9.0 Abstract - 9.2 Coded Fields - 7.5 Overall - 8.9 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function code (s) are not provided (e.g., CAB).

2. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate. Which licensee organization was responsible for the initial anchorage inspections?

3. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Why were braces needed for the 923-5 panel and not the other panels?

Abstract 1. See text comment number 2 and 3.

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

l 0-7

s .

TABIE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

7. LER Number: 86-017-00 Scores: Text - 8.8 Abstract - 9.0 Coded Fields - 9.7 Overall - 8.9 Text 1. 50.73(b)(2)(11)(C)--Date/ time information for major occurrences is inadequate. Additional date/ time information for such item: as completion of corrective actions would be helpful.

, 2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System identifiers for each component referred to in the text were not included.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The additional surveillance for two weeks was not mentioned.

2. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (13)--The manufacturer's field in line one was not filled in correctly. Codes for manufacturers not yet assigned a code can be obtained by calling INPO.

k i

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D-8

r , l TABLE 0-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

8. LER Number: 86-021-00 Scores: Text - 9.2 Abstract - 9.8 Coded Fields - 9.5 Overall - 9.4 Text 1. 50.73(b)(2)(11)(C)--Approximate date and time for the return to service of the radiation monitor is not included.

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function codes are not provided in the text.

3. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was an increased surveillance schedule instituted for the mylar screen to prevent possible recurrences of the light leak?

Abstract 1. No comments.

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

D-9

\

TABLE 0-1. SPECIFIC LER COMMENTS FOR DRESDEN 2 (237)

Section Comments

9. LER Number: 86-023-00 Scores: Text - 9.6 Abstract = 10.0 Coded Fields = 10.0 Overall = 9.8 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. The component function identifier code for the power supply (JX) was not provided in the text.

Abstract 1. No comments.

Coded fields 1. No comments.

Note: This is a well written report that could only be improved slightly by presenting the information in an outlined fornet.

0-10

TABLE 0-1. SPECIFIC LER COMMENTS FOR ORESDEN 3 (249)

Section Comments

10. LER Number: 85-023-00 Scores: Text = 8.9 Abstract = 9.1 Coded Fields - 8.5 Overall = 8.9 Text 1. 50.73(b)(2)(11)(c)--Date/ time information for major occurrences is inadequate. What time did the reactor scram and when was it stabilized in a safe and stable condition? When is the change to the procedure expected to be completed?

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included.

Abstract 1. 50.73(b)(11--Summary of root cause is inadequate.

The abstract does not make it clear that an adequate procedure did not exist, nor that the operator had exercised enough caution in evaluating the condition of the system.

2. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: Root cause (personnel error and procedural deficiency) is not included.

2. Item (8)--The text does not explain how Unit 2 was involved.

3. Item (12)--Position title is not included.

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

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0-11 t

e t TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 3 (249)

Section Comments

11. LER Number: 86-002-00 Scores: Text - 9.6 Abstract - 9.5 Coded fields - 9.2 Overall - 9.5 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component function codes are not provided in the text.

Abstract 1. The abstract contains greater than 1400 spaces.

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

0-12

g i 1 TABLE D-1.

SPECIFIC LER COMMENTS FOR ORESDEN 3 (249)

Section Comments

12. LER Number: 86-004-00 Scores: Text - 7.5 Abstract - 9.4 Coded Fields - 8.5 Overall - 8.2 Text 1. 50.73(b)(2)(11)(C)--Date information for major occurrences is inadequate. When will the Radiation Chemistry Technicians be retrained? Given that this sampilng is performed weekly, prompt action towards retraining appears to be appropriate.

2. 50.73(b)(2)(11)(E)--The ef fect discussion of each failed component is inadequate. The effect of a hole being in the filter during the sample period would appear to be an invalid sample count. This idea is somewhat contradicted by the last sentence of the third paragraph unless it is known that the filter was damaged after the sample period (e.g., during removal).

3. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included.

4. 50.73(b)(2)(ti)(J)(2)--Discussion of the personnel error is inadequate. Was the same Radiation Chemistry Technician involved during both weeks that the filter was damaged?

5. 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.

If manufacturer is unknown, the text should state this. Some information concerning filter identification would be helpful.

6. 50.73(b)(31--See text comment number 2.

7. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was anything abnormal noted while periodically monitoring the flow rate during the week of 5/1/86 through 5/8/867 Does the inlet side of the filter need to be supported? Will 4

the retraining involve personnel responsible for l

sampling both units?

0-13

TABLE D-1.

SPECIFIC LER COMMENTS FOR DRESDEN 3 (249)

Section Comments

12. LER Number: 86-004-00 (continued)

8. The first sentence of this report should contain the word " filter".

Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: Root cause and result information is inadequate. A better title might be, " Iodine and Noble Gas Sampling Not Performed As Required By Technical Specification Table 3.2.5 - Probable Personnel Error".

0-14

. <> s TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 3 (249)

Section Comments

13. LER Number: 86-004-00 Scores: Text - 8.8 Abstract - 9.2 Coded Fields - 9.8 Overall - 9.0 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System identifiers for each component referred to in the text were not included.

2. 50.73(b)(4)--Could a change to the review process for out of service requests help prevent recurrence of similar events?

3. Acronym (s) and/or plant specific designator (s) are undefined. SBGT was not defined in the text.

Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. No comment.

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[ TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 3 (249) l l

Section Comments r

14. LER Number: 86-014-00

! Scores: Text = 6.6 Abstract = 8.0 Coded Fields = 10.0 Overall = 7.4 Text , 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.

m 2. 50.73(b)(2)(ii)(C)--Approximate return to service 1

' date and time information for major occurrences is not included.

3, 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the debri; source is inadequate. Was the debris accumulation normally expected?

4. 50.73(b)(2)(ii)(F)--The Energy Industry

Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not

! included. Component function codes are not included

! in the text.

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, 5. 50.73(b)(2)( ti)(L )--Identification (e.g. ,

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manufacturer and model no.) of the failed

component (s) discussed in the text is not included.

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6. 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

! or is inadequate. Perhaps increased surveillance of the screen for debris accumulation would be appropriate.

1 Abstract 1. 50.73(b)(11--Summary of the root cause (debris source) is inadequate. See text consnent number 3.

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2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 6.

Coded Fields 1. No comments.

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> TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 3 (249)

Section Comments

15. LER' Number: 86-016-00 t Scores: Text-8.ii Abstract = 9.6 Coded Fields - 9.3 Overall - 8.9 Text 1. 50.73(b)(2)(ti)(C)--The date of the completion of the repairs would be good information.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) an.d/or system name code of each component or system referred to in the LER is not

' included. Component function identifier codes are

'notiprovided in.the text.

3. ;50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.

Why couldn't the Operating Foreman engage the manual 1 handwheel so as to manually close the valve?

4. 50.73(b)(2)(ti)(K)--Discussion of automatic and/or manual safety system responses is inadequate. All safety systems that actuate or are manually actuated as a result of an event should be named. It is not adequate to simply state that all safety systems functioned as designed.

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5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Are there any other valves

/ of the same type (other than the main condenser flow

! reversing valves) that also need to be inspected?

OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable.

6. 50.73(b)(5)--Information concerning previous similar events is inadequate.. Did any previous similar events involve a similar root cause?

7. The use of a revision bar in the :)ght hand margin of supplemental reports to mark those areas of the original report that have beer, revised is suggested.

Abstract 1. The abstract information cancerning corrective actions could indicate (as did the text) that the actions were applied to both units.

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TABLE D-1. SPECIFIC LER COMMENTS FOR DRESDEN 3 (249)

Section Comments

15. LER Number: 86-016-00 (continued)

Coded Fields 1. Item (4)--Title: . Root cause is not included. A better title might be " Scram On Low Condenser Vacuum When Circ Water flow Reversing Valve Failed Apparently Due To Parts Vibrating Loose".

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AE00 SALP INPUT FOR ORESDEN 2, 3 -

OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF October 1, 1985 to December 31, 1986 l

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Dresden 2 and 3 during the October 1, 1985 to December 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2. This is the second time that the Dresden LERs have been evaluated using this methodology. The {

results of this evaluation indicate that the Dresden LERs now have an overall average score of 8.9 out of a possible 10 points, compared to their previous overall average score of 7.2 and a current industry average of 8.2 (i.e., the current industry average is the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).

t One weakness that still remains in the Dresden LERs involves the requirement to provide the manufacturer and model number (or other appropriate identification) in the text for those components that fail.

The failure to provide information concerning the identification of failed components prompts concern that others in the industry may not obtain information in a timely manner that might enable them to identify and correct generic problems prior to having a similar failure at their station.

Strong points for the Dresden LERs are that discussions concerning the root and intermediate cause, the assessment of the safety consequences and implications of the event, personnel error, and the mode, mechanism, and effect of failed components were well written for the LERs that were evaluated.

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AE00 INPUT TO SALP REVIEW FOR DRESDEN 2 AND 3 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Dresden 2 and 3 during the October 1, 1985 to December 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station'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 (i.e., 9 LERs for Dresden 2 and 6 for Dresden 3). The Dresden LERs were evaluated as one sample for this SALP period because it has been determined that their LERs are both written and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in the sample.

It was necessary to start the evaluation before the end of the SALP assessment period because the input was due such a short time after the end of the SALP period. Therefore, all of the LERs prepared during the SALP 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, 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 reports. 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 reports beyond the current requirements of 10 CFR 50.73(b).

Therefore, statements in this evaluation that suggest measures be taken are 1

, a not intended to increase requirements and should be viewed in that light.

However, the minimum requirements of the regulation must be met. j 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 LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score - overall LER score).

The results of the LER quality evaluation are divided into two categories: (1) detailed infornation 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 these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.

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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 represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR

! 50.73(b) and the guidance presented in NUREG-1022 and its supplements.

i Again, Dresden LERs were evaluated as one sample, rather than two separate samples (by unit),-because it was determined that the Dresden LERs are both written and formally reviewed at the station, rather than the unit, level.

Table 1 presents the average scores for the sample of LERs evaluated for the station. 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 i each month as other units / stations are evaluated. 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, Dresden's average score for the text of the LERs that were evaluated is 8.7 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 station for the 15 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly 3

point out where the station is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 l indicate that the station probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate 3

a TABLE 1.

SUMMARY

OF SCORES FOR DRESDEN 2,3 Average High Low Text 8.7 9.6 6.6 Abstract 9.3 10.0 8.0 Coded Fields 9.3 10.0 7.5 Overall 8.9 9.8 7.4

a. See Appendix B for a summary of scores for each LER that was evaluated.

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av Figure 1. Distribution of overall average LER scores 12 i,,,i, ,,,i,,,,iiiiiiiiii ii,iiii i i i 11 -

g 10 - -

9- -

y 8- -

7_ _

E 6- -

o 5- Dresden 2. 3- -

4_ _

h 3- -

Z 0 ,,,,,,,,,,,,,,,,/,h,$,ii,,,,,,,,,,,,,

l 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 FOR DRESDEN 2,3 TEXT Percentage a

Requirements [50.73(b)] - Descriptions Scores ( )

(2)(ii)(A) - - Plant condition prior to event 90 (15)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate time (s) 83 (15)

-(2)(ii)(D) -- --Root cause and intermediate cause(s)

Mode, mechanism, and effect 91 (15)

(2)(ii)(E) 96 (10)

(2)(ii)(F) - - EIIS codes 57 (15)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 100 ( 3)

(2)(ii)(I) - - Method of discovery 100 (15)

(2)(ii)(J)(1) - Operator actions affecting course 93 ( 5)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 91 ( 8)

(2)(ii)(K) - - Safety system responses 91 ( 9)

(2)(ii)(L) - - Manufacturer and model no. information 50 (10)

(3) - - - - - - Assessment of safety consequences 95 (15)

(4) - - - - - - Corrective actions 85 (15)

(5) - - - - - - Previous similar event information 97 (15)

(2)(1) - - - - Text presentation 81 (15)

ABSTRACT Percentage a

Requirements [50.73(b)(1)] - Descriptions Scores ( )

- Major occurrences (immediate cause/effect) 100 (15)

- Plant / system / component / personnel responses 99 ( 9)

- Root cause information 95 (15)

- Corrective action information 91 (15)

- Abstract presentation 82 (15) l 1

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t a TABLE 2. (continued)

CODED FIELDS' Percentage a

Item Number (s) - Descriptions Scores ( )

1, 2, and 3 - Plant name(unit #), docket #, page #s 100 (15) 4------ Title 74 (15) 5, 6, and 7 - Event date, LER no., report date 100 (15) 8------ Other facilities involved 93 (15) 9 cnd 10 --

Operating mode and power level 100 (15) 11 -----

Reporting requirements 100 (15) 12 -----

Licensee contact information 97 (15) 13 -----

Coded component failure information 95 (15) 14 and 15 - - Supplemental report information 99 (15)

c. Percentage scores are the result of dividing the total points for a raquirement by the number of points possible for that requirement.

(Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.

b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100%

if it is provided and is always considered "not applicable" when it is not.

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that the station probably understands the basic requirement but has either: (1) excluded certain less significant infornation from most of the discussion concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The station should review the LER specific comments presented in Appendix D in order to determine why it received less than a perfect score for certain requirements. The text requirements with a score of 75 or less are discussed below in their order of importance. In addition, the primary deficiencies in the abstract and coded fields are discussed.

The manufacturer and/or model number (or other identification) was not provided in the text of five of the ten LERs that involve a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail should be adequately identified in the text so that others in the industry can be made aware of possible generic problems. An event at one station can often lead to the identification of a generic problem that can be corrected at other units or stations before they experience a similar event. It would also be helpful to identify components, which may not have failed, but whose design contributed to the event.

The Energy Industry Identification System component function identifier and system name codes were not consistently provided in the text. Twelve LERs partially provided these codes (usually for systems only), and three LERs failed to provide them at all. The EIIS codes are required to be provided for each system and component referred to in the LER.

One very important requirement received a score of greater than 75%

but is mentioned here because of the number of LERs in which comments were made for this requirement. The text requirement concerning corrective actions, has a score of 85%; however, seven of the fifteen LERs lacked certain details necessary to a complete discussion. All discussions must be complete if the reader is not to be left with questions. See Appendix 0 for specific comments concerning these deficiencies.

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The primary concern in the area of the abstracts involves their length. Nine of the fifteen abstracts were longer than the maximum length specified on the LER form (i.e., 1400 spaces).

l The main deficiency in the area of coded fields involves the title, Item (4). Seven of the titles failed to adequately indicate root cause, one failed to include result, and two 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 some of the LERs that were considered to have poor titles.

Table 3 provides a summary of the areas that require improvement for the Dresden LERs. For additional and more specific information concerning deficiencies, the reader should refer to the specific information presented in Appendix 0. General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 2.

It should be noted that this is the second time that the Dresden LERs have been evaluated using this same methodology. The previous evaluation was reported in October of 1985; see Table 4 for a comparison of scores for both evaluations. As can be seen, Dresden LERs have improved significantly since the previous evaluation and are now well above the current industry overall average of 8.2. (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 ORESDEN 2 AND 3 LERs Areas Comments failed component identification Component identification information such as manufacturer and model number, must be included in the text for each component that fails.

Additionally, it would be helpful to identify components whose design contributed to the event even though the component didn't " fail".

EIIS codes EIIS codes should be provided in the text for all systems and/or components discussed in the text.

Presentation Text presentation probably could be improved by using an outline format.

Abstract Abstract length should be less than 1400 spaces.

Coded fields

a. Titles All titles should include the result of the event (i.e., why the event was reportable) as well as root cause information. The link between the cause and result should be provided when it is not readily apparent how the root cause led to the result.

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TABLE 4. COMPARISON OF LER SCORES FROM PREVIOUS EVALUATIONS Report Date October-85 January-86 Text average 7.0a 8.7 Abstract average 7.3a 9,3 Coded fields average 7.9a 9.3 Overall average 7.2a 8.9

a. These average scores are the result of weight averaging the scores for the two Dresden units from the previous evaluation to produce a station average.

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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 Commission, 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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