ML20211N343

Forwards AEOD Assessment of Plant LERs as Part of SALP Program.Lers Generally Above Average in Quality.Weakness Re Safety Assessment Discussed

ML20211N343
Person / Time
Site:	Monticello
Issue date:	06/27/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Larson C NORTHERN STATES POWER CO.
References
NUDOCS 8607030071
Download: ML20211N343 (47)

Text

^'~~~~

DMS I

JUN 3 71986 Docket No. 50-263

- Northern States Power Company ATTN: Mr. C. E. Larson Director of Nuclear Generation '

414'Nicollet Mall Minneapolis, MN 55401 Gentlemen:

The NRC's Office for Analysis and Evaluation _ of Operational Data (AE00) has recently completed an assessment of your Licensee Event Reports (LERs) from Monticello as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Program.

In general, AE00 found your submittals to be of above average quality based on the requirements contained in 10 CFR 50.73. Some weaknesses were identified j involving the requirement to provide an adequate safety assessment. The  ;

safety assessment is needed to assess the possible consequences of events and l has not been routinely provided.  :

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 their findings and use the information to pattern future submittals.

We appreciate your cooperation with us. Please let us know if you have any r questions.

Sincerely, t 0607030071 860627 f, ginal Mgned h E. G. keenman" PDR ADOCK 05000263 s PDR ^

Charles E. Norelius, Director  !

Division of Reactor Projects {

Enclosure:

AE0D Assessment

{

cc w/ enclosure: '

W. A. Shamla, Plant Manager j DCS/RSB (RIDS) 1 Licensing Fee Management Branch Resident Inspector,-RIII Monticello l

}

Resident Inspector, RIII Prairie

• Island John W. Ferman, Ph.D.,  !

Nuclear Engineer, MPCA h RIII RIII RIIIy RII Pear /mj Schweibinz Boyd No el 6 94 % , ; 3sfo 1

L

l AIOD INPU1 10 SALP REVIEW FOR MON 11 CELLO Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Monticello during the December 1, 1984 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178. The sample consists of 13 LERs, which is half of the LERs which were on file at the time that the sample was selected. 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, not all of the LERs prepared during the SALP assessment period were available for review.

, Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the requirements of NUREG-1022 , and Supplements 1 and 2 to huREG-1022.

i 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.

l The L[R specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the infornetion pertaining to the event, and (2) they provide a Attachr.ent B

. l l

basis f or a count of general deficiencies f or 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 information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER sample infornation, ( Appendix A), a table of the scores for each sample LER (Appendix B), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER ( Appendix D).

When referring to these appendices, the reader is cautioned not to try to directly correlate the number of connents on a comment sheet with the LER scores, as the 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 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 50.13(b).

Table 1 presents the average scores for the sample of LERs evaluated for Monticello. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.

In order to place the scores provided in Table 1 in perspective, the

distribution of the overall average score for all licensees that have been evaluated using the current methodology is provided on figure 1.

Additional scores are added to Figure 1 each month as other licensees 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, Monticello's average score for the text of the LERs that were evaluated is 8.3 out of a possible 10 points. From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(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 13 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the station 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 from most of the discussion concerning that requirement or (2) totally f ailed to address the requirement in one'or two of the selected LERs. The station should review the LER specific consnents 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 less than 75 are discussed below in their order of importance. In addition, the primary deficiencies in the abstract and coded fields are discussed.

1 Nine of the ten LERs evaluated were considered to be deficient in the area of providing an assessment of the saf ety consequences and implications of the event, Requirement 50.73(b)(3). Every LER is required to contain a discussion of the safety assessment that should be performed af ter every

a l ABli 1.

SUMMARY

Of SCORE S FOR MONilC[LLO Average High b

Text 8.3 9.6 6.9 Abstract 8.3 10.0 6.1 Coded Fields 8.6 9.3 7.2 Overall 8.3b 9.7 7.0

a. See Appendix 8 for a sunenary of scores for each LER that was evaluated.

b. Overall Average - 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.

l .

Figure 1. Distribution of overall average LER scores 15 , , , , ,, , , .

14--

l L 13 - -

$ 12 - -

h 11 -

"""'* ~

10 - -

9- -

8 8- -

9 7- -

"o 6- -

g 5- -

g 4 -- ,

a 3- -

E 2- r v -

0 ,- r- i i 1 ,

, , , , i' , , r r r-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 MONTICELLO TEXT Percentage Requirements f50.73(b)1 - Descriptions Scores ( )#

(2)(11)(A) - - Plant condition prior to event 81 (13)

(?)(ii)(B) - - Inoperable equipment that contributed b (2)(11)(C) - - Date(s) and approximate times 77 (13)

(2)(ii)(D) - - Root cause and intermediate cause(s) 92 (13)

(2)(ii)(E) - - Mode, mechanism, and effect 100 (4) l (2)(11)(F) - - EIIS Codes 96 (13)

(2)(11)(G) - - Secondary function affected b

(?)(ii)(H) - - Estimate of unavailability 67 (6)

(2)(11)(I) - - Method of discovery 88 (13)

(2)(ii)(J)(1) - Operator actions affecting course 100 (2)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 93 (9)

(2)(ii)(K) - - Safety system responses 93 (9)

(2)(li)(L) - - Manufacturer and model no. information 75 (4)

(3) -----

Assessment of safety consequences 68 (13)

(4) -----

Corrective actions 83 (13)

(5) -----

Previous similar event information 92 (13)

(2)(i) - - - - Text presentation 77 (13)

ABSTRACT Percentage Requirements ISO.73(b)(111 - Descriptions Scores ( )#

- Major occurrences (Imediate cause and ef fect 96 (13) information)

- Description of plant, system, component, and/or 79 (6) personnel responses

- Root cause information 77 (13)

- Corrective Action inforr.ation 89 (13)

- Abstract presentation 72 (13) l

R l

TA8LE 2A. (continued)

CODEO FiltOS Percentage item Numberts) - Description Scores ( )

1, 2, and 3 - Facility name (unit no.), docket no. and 100 (13) page number (s) 4 - - - - - - Title 58 (13) 5, 6, and 7 - Event date, LER No., and report date 98 (13) 8 - - - - - - Other facilities involved 100 (13) 9 and 10 - - Operating mode and power level 92 (13) 11 - - - - - Reporting requirements 92 (13) 12 - - - - - Licensee contact information 100 (13) 13 - - - - - Coded component failure information 85 (13) 14 and 15 - - Supplemental report information 92 (13)

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

(hote: Some requirements are not applicable to all LERs; therefore, the -

number of points possible was adjusted accordingly.) The number in i

parenthesis applicable.

is the number of LERs for which the requirement was considered

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.

event. If the conclusion of this discussion is that "there were no safety consequences", suf ficient details must be provided to allow the reader to determine how this conclusion was reached. for example, if it was concluded that there were no consequences because there were other systems (or means) available to mitigate the consequences of the event, these systems or means should be discussed in the text. In addition, each discussion should include information as to whether or not the occurrence could have happened under a set of initial conditions that would have made consequences more severe. .If the occurrence could not have occurred under a more severe set of conditions, the text should so state.

While only one of four LERs failed to provide identification of a f ailed component, this brought the score for Requirement 50.73(b)(2)(11)(L) down to a marginally acceptable value of 75%. A component that needs to be repaired usually implies a failure and, therefore, should be identified.

If the f ailed component is too small to have its own model number, then the smallest uniquely identifiable component which contains the failed part should be identified. Still some items, such as broken pipe, cannot be identified by model number. For an item such as a pipe, the pipe auterial, pipe size, and system of which it is a part should be provided.

Identification of failed components allows others in the industry to become aware of problems that might turn out to be generic within the industry.

Requirement 50.73(b)(2)(ii)(C), dates and time's, (Score 77%,

marginally acceptable) and Requirement 50.73(b)(2)(ii)(H), unavailability of safety trains, (Score = 67%) are discussed t'gether because of their close relationship to each other. Adequate dat- and times are needed in the text to aid the reader in visual 1 ring the sequence of occurrences for an event. The time a safety system to unavailable is important because this infornetton becomes part of the generic data necessary to perform probabilistic risk assessments. Adequate attention paid to providing date and tirae information f or Requirement 50.73(b,(2)(ii)(C) will usually ensure that Requirement 50.73(b)(2)(ii)(H) is met.

4 The text presentations received an overall score of 77%. This score can be improved upon by the use of a consistent text outline (see NUREG-1022, Supplement No. 2, Appendices C and D). For example, every text should include outline headings such as: Event Description, Reportability, Cause, Safety Assessment, Corrective Actions, and Similar Occurrences. If applicable, other headings such as: Background, Time Sequences, Plant and/or System Responses, System Descriptions or Generic Implications can be added. The text presentations also need to be longer. While longer does not always mean better (there are no length limitation requirements), a longer text discussion is more likely to contain all the required information.

While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, summarire the following information from the text:

6

1. Cause/Effect What happened that made this event reportable?

t

2. Responses Major plant, system, and personnel responses as a result of the event.

3. Root / Intermediate The underlying cause of the Causes event. What caused the component and/or system failure or the personnel error? l

4. Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence?

Items 1 and 4 above were adequately summarized in the LERs reviewed.

Items 2 and 3 had marginally acceptable scores of 79% and 77%,

respectively. Both of these can be improved by being sure to summartre responses and causes that are discussed in the text.

l l

I 1

Improvement in the abstract presentation (Score . 72%) would aid in f ulf illing the summarization needed f or ]tems 2 and 3, above. first, be sure to define all acronyms. Second, be sure to use more of the 1400 space limit that is available. Seven of the LERs that have an insufficient '

abstract failed to make use of the space that was avail &ble. Finally, be sure that all information that is included in the abstract is discussed in the text. If it is not, the text should be revised so as to include tne information.

The sein deficiency in the area of coded fields involves the title, Item (4). Eleven of the titles fail to indicate root cause and one fails to include the result (i.e., why the event was required to be reported).

While the result is considered to be the most important part of the title, cause information must be included to make a title complete, 1n example of a title that only addresses the result might be " Reactor Scram". This is inadequate in that the cause and link are not provided. A more appropriate titie might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 <

Causes Reactor Scram". From this title the reader knows the cause involved l either personnel or procedures and that testing " linked" the error to the result. In addition, eight LERs had titles that included undefined acronyms. When possible (i.e., when space is not a problem), acronyms should not be used in a title.

Table 3 provides a summary of the areas that need improvement for the Monticello 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.

TABL E 3. arf A5 MOSI Nf! DING IMPROVEMINT FOR MONTICELLO LERs Areas Comments Saf ety assessment inf ormation All LERs should include a detailed safety assessment. The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstances and provide information about backup systems which were available to limit the consequences of the event.

Manufacturer and model number Component identification information information should be included in the text for each component failure or whenever a component is suspected of contributing to the event because of its design.

Dates and times / safety Sufficient dates and times should be train unavailability included in the text to enable the reader to understand the time history of the event and to determine the length of time that safety system trains or components were out of service.

lent presentation Probably need to increase the length of text discussion and use a consistent outline fornat.

Abstracts Response and cause infornation needs to be included. Utiltre the full '

1400 space limit allowed for the abstract.

Coded fields

a. Titles Titles should be written such that they better describe the event. In particular, include the root cause of the event. Avoid use of acronyms in the title.

~

l

i REFERENCES

1. B. S. Anderson, C. f. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAfl), NUREG/CR-4178, March 1985.

2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.

3. Office for Analysis and Evaluation of Operational Cata, licensee Event Report System, NUREG-1022 Supplement No. 1, U.S. Nuclear Regulatory Commission February 1984.

4. Office for Analysis and Evaluation of Operational Data, Licensee Event ,

ReDort System, NUREG-1022 Supplement No. 2, U.S. Nuclear Reg >latory -

Commission, September 1985.

4 S

I APPENDIX A LER SAMPLE SELECTION INFORMATION FOR MONTICELLO c

i

T ABL E A-1. LER SAMPLE SELECTION FOR MONTICELLO i

Sample Number LER Number Comments 1 84-034-00 SCRAM 2 85-002-00 ESF 3 85-004-00 l 4 85-006-00 ESF 1 5 85-008-00 SCRAM 6 85-010-00 SCRAM 7 85-013-00 SCRAM j 8 85-015-00 9 85-018-01 i

10 85-019-00 11 86-002-00 12 86-003-00 ESf 13 95.#ci 'vu ESF

=

I i

l 1

o l

APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR MONTICELLO

)

i l

l

TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERs FOR MONTICELLO .

a ,

LER Sample Number 1 7 3 4 5 6 7 8 9 10 11 12 13 14 15 16_

Text 8.7 8.1 7.9 9.0 6.9 9.3 7.4 8.4 7. 2 8.5 8.4 9.6 8.2 -- - --

Abstrac t R.1 9.0 8. 8 8.4 6.7 7.1 7. 7 6.1 9.3 4.4 0.4 10.0 7. 9 -- -- --

Coded ifelds 9.0 9.0 8.5 8.8 8.7 8.7 9.3 8.0 7.5 n.7 8.8 9.0 7.2 -- -- --

Overall 8.6 8.4 8.2 8. 8 7.0 8.6 7. 7 7. 7 7. 9 R.8 8.8 9. 7 8.0 -- -- --

LER Sample Number

• 17 18 19 20 21 22 73 24 25 76 27 28 29 30 AVERAGE Tcxt -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.1 Abstract -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.3 Coded Fields -- -- -- -- -- -- -- -- -- -- -- -- -- -- 9.6 Overall -- -- -- -- -- -- -- -- -- -- -- -- -- -- n. ]

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

L P

J 4 e

APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR MONTICELLO i

1 s

~

TABLE C-1. TEXT DIFICIENCIES AND OBSERVATIONS FOR MONTICELLO Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

50.73(b)(2)(ii)(Al--Plant operating 4 (13) conditions before the event were not included or were inadequate.

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

50.73(b)(2)(11)(C)--Failure to include 7 (13) sufficient date and/or time infornation.

a. Oate infornetion was insufficient. O

b. Time inf ormation was insuf ficient. 7 50.73(b)(2)(11)(D)--The root cause and/or 4 (13) intermediate failure, system failure, or personnel error was not included or was inadequate.

a. Cause of component f ailure was not 2 included or was inadequate

b. Cause of system f ailure was not 0 included or was inadequate

c. Cause of personnel error was not 2 included or was inadequate.

50.73(b)(2)(ii)(E )--The f ailure mode. 0 (4) mechanism (innediate 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. Ef f ect (consequence) was not included or was inadequate.

1ABLE C-1. (continued)

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

50.73 'b?(2)J11)(F )--The Energy Industry Identlf' catlon System component function 0 (13) identifier for each component or system was not included.

50.73(b)(2)(ii)(G)--For a failure of a 0 (0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate. 1 50.73(b)(2)(ii)(H)--For a failure that 2 (6) 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 2 (13) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

a. Method of discovery for each 0 component f ailure was not included or was inadequate

b. Method of discovery for each system 0 failure was not included or was inadequate

c. Method of discovery for each 1 personnel error was not included or was inadequate

d. Method of discovery for each 1 procedural error was not included or was inadequate.

TABL E C-1. (continued)

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

50.73 'b)(2)(11)(J)(1)--Operator actions that 0 (2) affec",ed the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(b)(2)(11)(J)(2)--The discussion of 2 (9) each personnel error was not included or was inadequate,

a. CBSERVATION: A personnel error was 0 implied by the text, but was not explicitly stated.

b. 50. 73( b ) ( 2 ) ( 11 ) ( J ) ( 2 ) ( 1 )--D i s c u s s i on 0 as to whether the personnel error was cognitive or procedural was not included or was inadequate.

c. 50.73(b ) ( 2 ) ( 11 ) ( J ) ( 2 ) ( i i )--Di s c u s s i on 1 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate.

d. 50. 73(b )( 2 )( i i )( J )( 2)( i i i )--Di s c us s i on 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included cr was' inadequate.

e. 50. 73(b ) ( 2 ) ( i i ) ( J ) ( 2 ) ( i v )--D i s c u s s i on 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.

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)(ii)(L )--The manufacturer and/or 1 (4) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety consequences and implications of the event 9 (13) was not included or was inadequate.

a. OBSERVATION: The availability of 2 other systems or components capable of mitigating the consequences of the event was not discussed. If no other systems or components were available, the text should state that none existed.

b. OBSERVATION: The consequences 3 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should so state.

50.73(b)(4)--A discussion of any corrective actions planned as a result of the event 8 (13) including those to reduce the probability of similar events occurring in the future was not included or was inadequate.

TABLE C-1. (continued)

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

• Totals ( )

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 manuf acturer and model number) was not included or was inadequate.  ;

50.73(b)(5)--Information concerning previous similar events was not included or was 1 (13) inadequate.

l

)

l l

TABLE C-1. (continued)

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

50.73(t-)(?)(11--Text presentation inadequacies. 6 (13)

a. OBSERVATION: A diagram would have 1 aided in understanding the text discussion,

b. Text contained undefined acronyms 5 and/or plant specific designators.

c. The text contains other specific 1 deficiencies relating to the readability.

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.

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

J

TABLE C-?.

ABSTRACT DEFIC]ENCIES 'AND OBSERVATIONS FOR MON 1] CELLO Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

• Totals ( )

A summary of occurrences (immediate cause and effect) was not included or was 1 (13) inadequate i

A summary of plant, system, and/or personnel responses was not included or was 4 (6) inadequate.

a. Summary of plant responses was not 1 included or was inadequate.

b. Summary of system responses was not 2 included or was inadequate.

c. Summary of personnel responses was not 2 included or was inadequate.

A summary of the root cause of the event was not included or was inadequate. 7 (13)

A summary of the corrective actions taken or planned as a result of the event was not 4 (13) included or was inadequate.

t a

TABLE C-2. (continued)

Number of LERs with Deficiencies and 1 Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

• Totals ( )

Abstract presentation inadequacies 9 (13)

a. OBSERVATION: The abstract contains 3 information not included in the text.

The abstract is intended to be a summary of the text, therefore, the text should discuss all information summarized in the abstract.

b. The abstract was greater than 0 1400 characters

c. Tha abstract contains undefined 4 acronyms and/or plant specific designators.

d. The abstract contains other specific 7 deficiencies (i.e., poor summarization, contradictions, etc.)

a. The "sub-paragraph total" is a tabulation of spt:ific 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 inforretion), the sub-paragraph totals do not necessarily add up to the paragraph total.

I

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

l l

TABL E C-3. CODID FIEL DS DEilCIENCl[S AND OBS[RVATIONS FOR MONTICELLO Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

• Totals ( l b

Facility Name 0 (13)

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 (13) incorrect.

Page Number was not included or was incorrect. 0 (13)

Title was left blank or was inadequate 11 (13) To

a. Root cause was not given in title 11

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

c. Link was not given in title O Event Date 1 (13)

a. Date not included or was incorrect. O

b. Discovery date given instead of event 1 date.

LER Number was not included or was incorrect 0 (13)

Report Date 0 (13)

a. Date not included

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

Other Facilities infornation in field is 0 (13) inconsistent with text and/or abstract.

Operating Mode was not included or was 3 (13) inconsistent with text or abstract.

TABLE C-3. (continued)

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

Power level was not included or was 0 (13) inconsistent with text or abstract Reporting Requirements 1 (13)

a. The reason for checking the "0THER" 0 requirement was not specified in the abstract and/or text.

b. OBSERVATION: It may have been more 0 appropriate to report the event under a different paragraph.

c. OBSERVATION: It may have been 0 appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 0 (13)

a. Field lef t blank

b. Position title was not included

c. Name was not included

d. Phone number was not included.

Coded Component failure Infornation 2 (13)

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 0 when no component failure occurred.

d. Component f ailure occurred but entire 2 field lef t blank.

l

~

. l l

TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph DescriDtion of Deficiencies and Observations Totals

• Totals ( )

Supplemental Report 1 (13)

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

b. The block checked was inconsistent I with the text.

Expected submission date information is inconsistent with the block checked in 0 (13)

Item (14).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within cer tain requirements. Since an LER can have more than one deficiency for certain requirements (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.

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

4 e

APPENDIX D LER COMMENT SHEETS FOR MONTICELLO j

O TABLE D-1.

SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

1. LER Number: 84-034-00 Scores: Text - 8.7 Abstract - 8.1 Coded Fields - 9.0 Overall - 8.6 Text 1. 50.73(b)(31--The safety assessment should be specific as to why there were no significant effects on the vessel or core temperature. For example, were backup systems used to cool the core or was a one hour failure too short to cause a problem?

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.

2. Acronym (s) and/or plant specific designator (s) are undefined. RHR should be defined.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The j

reduction in the isolation setpoint of 18 psi should be mentioned, as well as, mentioning the pressurization of the Residual Heat Removal system through the reactor head vent.

2. 50.73(b)(1)--Summary of root cause is inadequate.

The failure of the procedure to allow bypassing of the trip during the ILRT procedure should be mentioned. This will help a reader to better understand the corrective actions taken.

3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.

Coded Fields 1. Item (4)--Title: Root cause is not included. The use of acronyms should be avoided in a title.

a

l l

T ABL E 0-1. SPEClf l0 Lf R COMMENTS f 0R MONTICEll0 (263) i Section Comments

2. LER Number: 85-002-00 Scores: Text , 8.1 Abstract - 9.0 Coded Fields - 9.0 Overall 8.4 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for major occurrences is inadequate. When was the emergency safeguard bus restored to it's normal power source and the systems reset?

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the procedure inadequacy is inadequate. More information would be helpful to the reader in determining how the restoration process was not adequately addressed. Were steps missing, in the wrong order, were schematics incorrect?

3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The statement "During the event, Tech Spec required systems were operable", is good, however these systems should be listed.

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What will be revised in the degraded and loss of voltage restoration test procedure? See comment 2.

5. The acronym EFT should be defined.

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

See text comment 2.

Coded Fields 1. Item (4)--Title: Root cause is not included. The use of acronyms should be avoided in a title.

TABLE D-1. SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

3. LER Number : 85-004-00 Scores: Text - 7.9 Abstract - 8.8 Coded Fields . 8.5 Overall = 8.2 Text 1. 50.73(b)(2)(11)(C)--Time information for major occurrences is inadequate. At what time was M0-4085A cycled closed?

i

2. 50.73(b)(2)(11)(I)--Discussion of the method of discovery of the technical specification violation is inadequate. Was the 10% increase in reactor power the first indication of a problem?

3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. Details concerning the inadequacies of the procedure should have been provided. The type of personnel involved in the quarterly exercising procedure and those (by title) involved in writing and approving the improper procedure should have been provided.

4. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. What could have been the consequences had the valve (M0-4085A) not been closed in a timely nenner?

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Given that there was no discussion of what was improper with the subject '

procedure, details concerning the revision of the procedure should have been provided.

6. Acronym (s) and/or plant specific designator (s) are undefined.

7. OBSERVATION: A diagram or figure would aid in understanding the event.

Abstract 1. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

2. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.

TABL E D-1. SPECifl0 LER COMMENTS FOR MON 11 Cell 0 (263)

Section Consnent s

3. LER Number: 85-004-00 (continued)

Coded Fields 1. Item (4)--Title: Root cause and result (technical specification violation) are not included The use of acronyms should be avoided in a title.

l 1

i l

l

~ ~

i J .

j l

l l

1 TABLF 0-1. SPf CIFIC LIR COMMf NTS FOR MONTICELLO (263)

Section Comments

4. LER Number: 85-006-00 Scores: Text - 9.0 Abstract - 8.4 Coded Fields - 8.8 Overall - 8.8 Text 1. 50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is inadequate. The text should include the power level at which the plant was operating.

2. 50.73(b)(2)(11)(C)--Date and time infornation for major occurrences is inadequate. When was the EFT system returned to normal operating mode?

3. Acronym (s) and/or plant specific designator (s) are undefined. EFT and HVAC should be defined.

Abstract 1. The root cause sumer.ary should be more specific about the tape defect.

2. The corrective actions summary should indicate that this is considered to be an isolated incident so further action is unnecessary.

3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. EFT and HVAC should be defined.

4. Additional space is available within the abstract field to provide the necessary infornation but it was not utilized.

Coded Fields 1. Item (4)--The use of acronyms should be avoided in a title.

2. Item (13)--Component failure occurred but entire field is blank.

4 l

l l

.e.

TABLE D 1 SPECIIIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

5. LER Number: 85-008-00 Scores: Text - 6.9 Abstract - 6.7 Coded fields - 8.7 Overall - 7.0 Text 1. 50.73(b)(2)(11)(C)--Approximate time information for major occurrences is inadequate. The only time that is mentioned in the text is when the scram occurred.

Sufficient times should be included so that the reader can visualize a time history of the event.

2. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.

The text indicates damage to the bus and bus structure occurred, when was the bus restored to service?

3. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadecuate. What systems responded as a result of the turbine trip and the scram? The text indicates that all transformer source breakers tripped, did any emergency power sources respond as a result of this?

4. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. More detail should be provided to justify the first two sentences of the last paragraph.

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Corrective actions concerning the repair of the bus and bus structure should be provided.

6. This LER contains very good information as to the cause of this event, but it is generally lacking in detail for the reader to reconstruct what occurred as a result of the swings of power on the distribution system. In particular, the text simply states that a scram occurred from 100% power, but no infornation is provided as to how or when the plant was stabilized and in a safe condition. ,

1 Abstract 1. 50.73(b)(1)--Summary of plant and system responses is l inadequate. See text comment 3.

]

l 1

l J

TABLE D-1. SPECIFIC LER COMMENTS FOR MONTICEtt0 (?63)

Section Comments

5. LER Number: 85-008-00 (continued)

2. 50.73(b)(11--Summary of root cause is inadequate.

The abstract should mention that specific installation and removal of the static electricity grounds that caused this event were not identified in a procedure.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The logging of all grounds installed in the future should be mentioned. Also see text comment 5.

4. OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

The text does not indicate that actions were initiated to return the plant to normal power operation.

5. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized.

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

I I

l J

~0 TABLE D-1.

SPICIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

6. LER Number: 85-010-00 Scores: Text - 9.3 Abstract - 7.1 Coded Fields = 8.7 Overall - 8.6 Text 1. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time were the plant conditions stabilized. How long was the

" delay" that resulted in the technician losing his place in the execution of the procedure?

2. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. It appear ~s that others that might have to perform this procedure should also be made aware of the problems that developed during its execution.

Abstract 1. 50.73(b)(1)--Summary of system (component) responses to the scram is not included. The fact that safety relief valve 4 automatically operated should have been mentioned.

2. 50.73(b)(1)--Summary of root and intermediate cause information is not included. The fact that a cognitive error resulting from a delay in procedure execution caused the scram should have been mentioned.

3. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Root cause is not included. The use of acronyms should be avoided in a title.

2. Item (9)--Operating mode is not included.

s

l TABL E D-1. SPICIF]C LER COMMENTS FOR MON 11 CELLO (263) l Section Comments

7. LER Number: 85-013-00 Scores: Text - 7.4 Abstract 7.7 Coded Fields = 9.3 Overall - 7.7 Text 1. 50.73(b)(2)(ii)(D)--The text should give specific reasons why the procedure was considered inadequate.

The text should also indicate why the brushes had failed.

2. ES.73(b)(2)(ii)(H)--A time estinate of the unavailability of the failed system is not included.

How long was the recirculation motor generator exciter out of service? 1

3. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included. The abstract indicates that the brush and brush holder were repaired. These components or the component containing these parts should be identified.

4. 50.73(b)(3)--A safety assessment should provide specific reasons why the event posed no safety concerns. It is not enough to state that there were no concerns.

5. 50.73(b)(4)--Were the brushes replaced? Repairs were mentioned in the abstract but not the text. Can or will anything be done to prevent the new brushes from

, arcing or sticking? The text should include specifics about the procedural change.

Abstract 1. The root cause summary should mention the specific problems with the brushes, and as needed in the text

-give more detail about the procedural deficiency.

2. The corrective actions summary should be more specific about the procedural changes.

3. OBSERVAT]GN: The abstract contains information not included in the text (see text comment 5). The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

4. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded fielas 1. Item (4)--litle: Root cause is not included.

TABLE D-1. SPECIFIC Lf R COMMENTS FOR MONTICEtt0 (263)

Section Comments

8. LER Number: 85-015-00 Scores: Text = 8.4 Abstract 6.1 Coded Fields 8.0 Overall . 7.7 Text 1. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate, It appears from the text discussion that in the past, the sole method of recognizing Technical Specification changes was to rely on the side bars, If this is the case, could other procedures have not been implemented as a result of undetected Technical Specification changes?

2. 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. The text discussion should give some detail on what will i be revised in the lechnical Specification control procedure.

Abstract 1. 50.73(b)(11--Summary of root cause is not included.

2. Abstract does not adequately sunnerize the text.

Additional space is available within the abstract field to provide the necessary information but it was not utilized. .

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

2. Item (91--Operating made is not included.

W t

9

TABLE D-1. SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

9. LER Number: 85-018-01 Scores: Text - 7.2 Abstract = 9.3 Coded Fields - 7.5 Overall . 7.9 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadequate. The power level should have been provided.

2. 50.73(b)(2)(ii)JC)--Time information for major occurrences is lnadequate. At what time was the test terminated and all trips restored?

3. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the personnel error is inadequate. The second and third sentence of the abstract should have been used as a lead-in to the second paragrah of the text.

4. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the procedural error is not incluoed.

5. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate.

50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of '

personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed .

operator, other utility personnel) is not included.

6. $0.73(b)(3)--01scussion of the assessment of the safety consequences and implications of the event is inadequate. A discussion of the facts that led to the conclusion that the event had no effect on public health or safety should have been provided. *

7. 50.73(b)(M --Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

(Note: Information concerning previous similar events was included in the original LER but was apparently dropped from the revision.)

All LERs 6re required to stand alone; theref ore, LER revisions should include all unrevised information from the previous LER.

TABLE D-1.

SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

9. LER Number: 85-018-01 (continued)

8. The use of a " revision bar" in the right hand margin would help the reader determine the new (changed) information in the revision.

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

Information concerning what happened to the hold sheet (i.e., it was not found because it adhered to the inside of the file folder) should have been mentioned.

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 second and third sentence of the abstract. See text comment number 3.

Coded Fields 1. Item (4)--Title: Root cause is not included. The use of acronyms should be avoided in a title.

2. Item (91--Operating mode is not included.

3. Item (ll)--Reporting requirement is not included.

(Note: Reporting requirement was checked on the original LER.)

_ _ _ _ _ _ _ _ . J

i TABLE D-1.

SPECIFIC LIR COMM[NIS FOR MONilCELLO (263)

Section Comments

10. LER Number: 85-019-00 Scores: Text = 8.5 Abstract - 9.4 Coded Fields - 8.7 Overall = 8.8 Text 1. 50.13(b)(2)(ii)(D)--The text should give specifics as

, to how the procedure was deficient.

I i

2. 50.73(b)(31--An important part of a safety analyses is to show that there would have been no problem as this LER has done. It is also desirable, however, to speculate on what could have happened if the oil was out of spec. For example, if there are systems available to handle out of spec oil (i.e., filters to trap dirt and water, or heater cables to help prevent gelling), they should be mentioned. i

3. 50.73(b)(4)--The corrective actions should give specifics as to how the procedure will be changed.

Abstract 1. No comments.

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

2. Item (5)--Discovery date is given instead of event date. It appears from the text that a more appropriate event date would be August 5, 1985. The discovery date, however, is used to start the 30 day clock for filing the LER.

1

e 1

I TABLE 0-1.

SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

11. LER Number: 86-002-00 Scores: Text - 8.4 , Abstract = 9.5 Coded Fields - 8.8 Overall - 8.8 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included. The EIIS code (FIC) is given for the flow indicator controller, codes should also be provided for the HPCI and RCIC systems.

2.

50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The "other emergency core cooling systems" that were determined to be operable at the l tine should be listed.

Abstract 1. No comments.

Coded Fields 1. Item (4)--Title: Root cause is not included. The use of acronyms should be avoided in a title.

i l

l l

. - _ _ _ _ _ _ _ _ _ _ _ _ _ - . J

. 1 TABLE D-1. SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Conment s l \

l 12. LER Number: 86-003-00 l Scores: Text - 9.6 Abstract 10.0 Coded Fields - 9.0 Overall . 9.7 Text 1. 50.73(b)(2)(ii)(Al--Discussion of plant operating j conditions before the event is inadequate. The power level at the time of the isolation should have been provided.

Abstract 1. No connents.

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

I

1 TABLE D-1 SPECIFIC LER COMMENTS FOR MONTICELLO (263) s Section Comments

13. LER Number: 86-004-00 Scores: Text - 8.2 Abstract - 7.9 Coded Fields 7.2 Overall = 8.0 !

Text i' l. 50.73(b)(2)(111fA5--Discussion of plant operating '

conditions before the ev'nte is not included.

2. 50.73(b)(2)(ii)(C1--Date and time information for major occurrences is inadequate. When was the EFT system returned to normal operating mode?

3. 50.73thlie)--A supplemental report appears to be needed to report the changes made in equipment. Also the corrective actions should indicate what will be done until the next refueling outage and indicate when the next refueling outage is planned. Finally, the text should clarify how changing the trip logic will improve system reliability.

4. Arronym(s) and/or plant specific designator (s) are undefined. EFT and HVAC should be defined.

Abstract 1. 50.73(b)(1)--Summary of personnel response is inadequate. The summary should indicate that personnel contacted the manufacturer and found that tape reliability could not be improved.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The deficiencies mentioned in text comment 3 also apply to the abstract.

3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. EFT and HVAC should be defined.

4. Additional space is available within the abstract field to provide the necessary infornetion but it was not utilized.

Coded Fields 1. Item (4)--The use of an acronym in a title is not desirable. In the text and abstract the EFT System is described as the Control Room HVAC which is informative but EFT is undefined. For a person searching titles the use of the acronym EFT is meaningless unless they are familiar with the Monticello Plant.

v r .

i l

TABLE D-1. SPECIFIC LER COMMENTS FOR MONTICELLO (263)

Section Comments

13. LER Number: 86-004-00 (continued) l

2. Item (13)--Component failure occurred but entire field is blank.

3. Item (141--The block checked is inconsistent with information in the text (see text comment 3).

i I

- - - -