ML20211N472
| ML20211N472 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/27/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8607030112 | |
| Download: ML20211N472 (43) | |
Text
-
3rn8
'Jbw 2 71986 Docket No. 50-483 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:
The NRC's Office for Analys and Evaluation of Operational Data (AE00) has recently completed an assessant of your Licensee Event Reports (LERs) from Callaway 1 as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Program.
In general, AE0D found your submittals to be of a very high quality based on the requirements contained in 10 CFR 50.73, and demonstrate an apparent commitment on your part to provide NRC with LERs which consistently meet these requirements. I also note that of the 66 licensees (units) evaluated your LERs had the highest overall scores.
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.
We appreciate your cooperation with us. Please let us know if you have any questions.
Sincerely, 3 " Original Signed By E. G. Greenman" 7oggego$ gn S for Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
AE00 Assessment See Attached Distribution fi %s RIII RIII RIII RIII on/mj Schweibinz LO)
Forney Pe Norel 4 (73b-86 /
I[ IS L. .1
e --
Union Electric Company _ 2 jgN g 7 jgg@
Disfribution cc w/ enclosure:
A. P. Neuhalfen, Manager Quality Assurance S. E. Miltenberger, General Manager, Nuclear Operations DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Region IV Resident Inspector, Wolf Creek K. Drey Chris R. Rogers, P.E.
Utility Division, Missouri Public Service Commission SNUPPS
?
k' L 2_ 1
- AE0u 1RP01 TO'bALP REVIEW FUR CALLAWAY l Introduction In oroer to evaluate the overall cuality of the contents of the g
Licensee Event Reports (LERs) submitted by Callaway 1 during the June 30, 1985 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the licensee's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178. The sample consists of 11 LERs, which is half of the LERs that were on file at the time the evaluation was started. See Appendix A for a list of the LER numbers in the sample.
It was necessary to start the evaluation before the eno of the SALP asssessment period because'the input was due such a short time af ter tne eno of the SALP perioo. Therefore, not all of the LERs prepared during the SALP assessment perica were available for review.
Methodology Tne evaluation consists of a detailed review of each selecteo LER to
/
determine how well the content of its text, abstract, and coded fields meet 2 3 4 the reouirements of NUREG 1022 , and Supplements 1 and 2 to NUREG-1022.
The evaluation process for each LER is divided into two parts. Tne 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 cons *lered to be the specific deficiencies or observations concerning tre infomation pertdiriing to the event, ano (2) they provide a Attachnent B I
P
^
Oasis f or a count'or general ceticiencies for the overall sample of LERs.
Likewise, the scores serve two purposes: (1) they serve to illustrate in ,
numerical terms how the analysts perceived the Content of the information that was presented, and (2) they provide a basis for the overall score determined 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.,
4 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score = overall LER score).
The results of the LER ouality evaluation are divided into two The categories: (1) detailed information and (2) summary information.
detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER
( Appendix B), tables of the number of deficiencies and observations for the text, abstract and coded fielos (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER ( Appendix D).
When referring to these appendices, the reader is Cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analyst has flexibility to consioer the magnitude of a deficiency when assigning scores.
Discussion of Results A discussion of the analysts' conclusions concerning LER ouality is presenteo below. These conclusions are based solely on the results of the evaluatim of the contents of the LERs selected for review ano as sucn represent the analysts' assessment of each units performance (on a scale of 0 to 10) in submitting LERs that meet the recuirements of 10 CFR 50.73(b).
Table 1 presents the average scores for the sample of LERs evaluated f or Callaway 1. Tne reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in hUREG/CR-4178 cue to refinements in the methodology.
In order to place tnt scores provided in Table 1 in perspective, the distribution of the overall score for all licensees that have been i
evaluated using the current methodology is provided in 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, Callaway l's average score for the text of the LERs that were evaluated was 9.0 out of a possible 10 points. From Table 2 it can be seen a that the text score actually resulted from the review and evaluation of 17 different requirements ranging from the discussion of plant operating g
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 licensee for the 11 LERs that were evaluated.
Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point cut where the licensee is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the licensee probably understands the basic requirement but has either: (1) excluded certain less significant information from a large number of the discussions concerning that requirement or (2) totally failed to address a requirement in one or two of the selected LERs. The licensee should review the LER specific comments presented in Appendix D in order to determine why he received less than a perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance. In addition, the prinary deficiencies in the abstract and coded fields are discussed.
The corrective action discussions were considered inadequate in seven LERs, Requirement 50.73(b)(4), even though the overall score for this requirement was 81%. The most consistent deficiency concerning this requirement was that sufficient details were not always provided concerning actions taken to prevent recurrence of the event.
? -- . . - - - - - - - - . .
I l
a TABLE 1.
SUMMARY
OF SCORES FOR CALLAWAY l Averaae Hiah low Text 9.0 9.9 8.3 Abstract 9.1 9.6 8.1 Coded Fields 8.9 9.5 8.5 Overall 9.0b 9.7 8.4
- a. See Appendix B for a sunmary of scores for each LER that was evaluated.
- b. Overall Average = 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.
i I
i
Figure 1. Distribution of overal! average LER scores
,i,,,,,, ,,,,,,,,
15 ,, , , ,,,,,,,,,,,, ,,
14 - _
g 13 - -
12 -
.] -
a 11 - ~
m 10 - -
g 9- -
@ 8- -
9 7- -
E 6- -
y 5- .
Callaway r 4_
E a 3-Z 2- -
o s,h,,,,,a,,,,,,s,ll,,,,s,,,,s,,,,,,,, 6.0 8.5 8.0 7.5 7.0 6.5 9.5 9.0 Overall average scores
e T Aeti. 2. Gk RI.QUIREMENTVERCthlAbt SCORES FOR CALLAWAY l Percentage Reauirements (50.73(b)] - Descriptions Scores ( )a (2)(ii)(A) - - Plant condition prior to event 82 (11)
(2)(ii)(B) - - Inoperable eauipment that Contributed b i (2)(ii)(C) - - Date(s) and approximate times 95 (11) i 94 )
(2)(ii)(D) - - Root cause and intermediate cause(s) 100 (2)(ti)(E) - - Mode, mechanism, and effect !
(2)(ii)(F) - - EIIS Cooes 91 (11)
(2)(ii)(G) - - Seconaary function affectea b (2)(ii)(H) - - Estimate of unavailability 60(5)
(2)(ii)(1) - - Methoo of discovery 100 (11)
(2)(ii)(J)(1) - Operator actions affecting course 100 (7)
(2)(ii)(J)(2) - Personnel error (procedural ceficiency) 92 (6)
(2)(ii)(K) - - Safety system responses 100(7)
(2)(ii)(L) - - Manufacturer and model no. information 90 (5)
(3) ----- Assessment of safety consecuences 94 (11)
(4) ----- Corrective actions 81 (11)
(5) ----- Previous similar event information 95 (11)
(2)(i) - - - - Text presentation 85 (11)
ABSTRACT Percentage Reauirements [50.73(b)(1)] - Descriptions Scores ( )*
- Major occurrences (Immediate cause and effect 100 (11) information)
- Description of plant, system, component, ana/or 97 (9) personnel responses
- Root cause information 86 (11)
- Corrective Action information 85 (11)
- Abstract presentation 85 (11)
1 l
TABLE 2. (continued)
CODED FIELDS Percentage l Item Number (s) - Description Scores ( )#
l 1, 2, and 3 - Facility name (unit no.), docket no, and 100 (11) page number (s) 4 - - - - - - Title 59 (11) 5, 6, and 7 - Event date, LER No., and report date 100 (11) 8 - - - - - - Other facilities involved 100 (11) 9 and 10 - - Operating mode and power level 100 (11) 11 - - - - - Reporting requirements 95 (11) 12 - - - - - Licensee contact information 100 (11)
~
13 - - - - - Coded component failure information 100 (11)
~
14 and 15 - - Supplemental report information 100 (11) i
- a. Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.
- b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100%
if it is provided and is always considered "not applicable" when it is not.
- ~ Ah estimate of sne elapsea time of the unavailability of a failed safety system was not provided in two of five LERS in which this
=
reouirement was applicable [50.73(b)(2)(ii)(H)]. Generally, if sufficient cate and time information is provided for all ma,Jor occurrences of the event, it is sufficient to satisfy this reouirement as the duration of the train f ailure can then ne calculated.
B Overall, the LER text ouality is very good. Tne high scores for most of the text reouirements indicate that the licensee has put forth a lot of g effort to ensure tnat the reouirements of 10 CFR 50.73(b) are met.
i Tne abstracts are deficient in two major areas; namely, the summarization of cause ano corrective action information. Six LERs f ailed to adeouately summarize the cause information, and five LERs failed to adeouately sumar;ize the Corrective actions. These are two discussions that must be summarized in every abstract for the abstract to be considereo complete.
The main deficiency in the area of coded fields involves the title, Item (4). None of the titles indicated the root Cause and three failed to include the link (i.e., Circumstances or Conditions which tie the root cause to the result). While result is considered the most important part of the title, Cause ano link must be included to make a title complete. An example of a title that only addresses the result might be " Reactor Scram". Tnis is inaaecuste in that the cause and link are not provided. A more appropriate title mignt be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Cat,ses Reactor Scram". From this title, the reader knows the cause was either personnel or procedural and surveillance testing was the link between the Cause and the result.
Table 3 provides a sumnory of the areas that need improvement for the Callaway 1 LERs. For adoitional and more specific information concerning aeficiencies, the reader should refer to the information presented in Appendices C and D. General guidance concerning these reouirements can be found in NUREG-1022, Supplement No. 2.
l J
- 7Ab& 3. EthMUSl NEEDlhG TMPROVEMENT FOR CALLAWAY l LERs Areas Comments Corrective actions Each LER should include sufficient detail to permit the reader to understand what corrective actions were taken or planned that will i prevent recurrence of the event.
Safety train unavailability Sufficient dates and times should be !
included in the text to enable the reader to determine the length of time that safety system trains or components were out of service (unless this time period is explicitly provided).
Abstracts Cause ano corrective actions information was often inadeauate.
Abstracts should summarize the cause and corrective action information that is oiscussed in the text.
Coaed fields
- a. Titles Titles should be written such that they better describe the event, in particular, the root cause of the event should be included in the title.
l
TEt LRihttS
- 1. B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of = '
Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.
- 2. Office for Analysis end 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. g
- 4. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulator;"
Counission, September 1985.
I
- - -r --- - e
l f
APPENDIX A LER SAMPLE SELECTION INFORMATION FOR CALLAWAY l
7A~oit.'a-i. th SAWLt. SELI.C110h FOR CALLAWAY l Sample Number LER Number Comments 1 85-033-00 2 85-037-00 85-039-00 SCRAM 1 3 4 85-042-00 SCRAM g 5 85-043-00 6 85-047-00 f
85-050-00 ESF 7
8 85-051-00 SCRAM 9 85-052-00 SCRAM 10 85-053-00 11 85-054-00 SCRAM i
k
_ . , , _ , ~ . _ . , _ _ ,
I um E
e APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR CALLAWAY l 9
m M
T ABL E B-1. EVALUATION SCORES OF IN0lVIDUAL LERs FOR CALLAWAY l 4
LER Sample Number' 8 9 10 11 12 13 14 15 16_
1 2 3 4 5 6 7 8.5 9.8 8.6 9.2 9.4 8.3 9.2 9.1 8.6 9.9 8.7 -- -- -- --
Text 9.4 8. 8 9.6 9.6 8.5 9.4 8.9 8.1 9.6 8.5 -- -- -- --
Abstract 9.2 Coded 9.5 -- --
9.1 9.0 8.5 8.9 8.7 8.5 8.9 8.5 9.5 9.1 -- -- --
F iolds 9.6 8.7 9.3 9.4 8.4 9.2 9.0 8.5 9.7 8.7 -- -- -- --
Overall 8.8 LER Sample Number
- 23 24 25 76 27 28 29 30 AVERAGE 17 18 19 20 21 22
-- -- -- -- -- -- -- -- -- -- -- 9.0 Text -- -- --
-- -- -- -- -- -- -- -- 9.1 Abstract -- -- -- -- -- --
l Coded -- -- -- -- -- -- -- -- -- -- -- 8.9 Iields --
-- -- -- -- -- -- -- -- -- -- - 4.0
, Ov27all -- --
i
- a. See Appendix A for a list of the corresponding LER numbers.
g - - -
I E e
l APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR CALLAWAY l
l TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR CALLAWAY 1 Number of LERs with Deficiencies and Observations Paragraph 8 Sub-paragraph Description of Deficiencies and Observations Totals # Totals ( )
50.73(b)(2 Hi;)'?d Plant operating 2 (11) I conditions before the event were not included or were inadequate.
50.73(b)(2)(ii)(B)--Discussion of the status 0 (5) cf the structures, components, or systems that were inoperable at the start of the Gwent and that contributed to the event was not included or was inadequate.
50.73(b)(2)(11)(C)--Failure to include 0 (11) 4 suf ficient date and/or time infornetion.
- a. Date information was insufficient.
- b. Time information was insuf ficient.
50.73(b)(2)(ii)(D)--The root cause at 1/or 2 (11) intermediate failure, system failure, or personnel error was not included or was inadequate.
- a. Cause of component failure was not 1 included or was inadequate
- b. Cause of system failure was not 1 included or was inadequate
- c. Cause of personnel error was not 0 included or was inadequate.
50.73(b)(2)(11)(E l--The f ailure mode. 0 (5) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate,
- a. Failure mode was not included or was inadequate l
- b. Mechanism (immediate cause) was not I included or was inadequate j
- c. Effect (consequence) was not included or w&s inadequate. ;
_ . . - - - - . _ _ . _ _ , - _ . _ . . _ , . - . _ - . - .. .___.r-- , _ _ _ . . , _ . - - . - - . _ _ . -- _ _ _ _ -
TABLE C-1. (continued)
Number of LERs with Deficiencies and !
Observations j I
Sub-paragraph Paragraph a
' Description of Deficiencies and Observations Totals Totals ( )
50.73(b)(2)(ii)(F1--The Energy Industry 2 (11) l Identification System component function identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a f ailure of a 0 (0) 7 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 2 (5)
! 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 (11) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
- a. Method of discovery for each component failure was not included or was inadequate
- b. Method of discovery for each system failure was not included or was inadequate
- c. Method of discovery for each personnel error was not included or was inadequate
- d. Method of discovery for each procedural error was not included or was inadequate.
l
TABLE C-1. =
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals" Totals ( )
50.73(b)(2)(ii)(J)(1)--Operator actions that 0 (7) I 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)(21--The discussion of 4 (6) each personnel error was not included or was inadequate.
- a. OBSERVATION: A personnel error was 2 implied by the text, but was not explicitly stated.
- b. 50.73(b)(2)(ii)(3)(2)(1)--Discussion 3 as to whether the personnel error was cognitive or procedural was not included or was inadequate,
- c. 50.73(b)(2)(ii)(J)(2)(ii)--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)(ii)(J)(2)(iii)--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 0 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)(11)(K)--Automatic and/or manual 0 (7) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 1 (5) model number of each failed component was not included or was inadequate.
50.73(b)(3)--An assessment of the safety 3 (11) consequences and implications of the event was not included or was inadequate.
- a. OBSERVATION: The availability of 0 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 1 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 7 (11) 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.
l
l I
TABLE C-1. (continued)
Number of LERs with Deficiencies and Observations l I
Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )
- a. A discussion of actions required to 0 l 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 4 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 0 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 (11) similar events was not included or was inadequate.
_ , m - - , -. -
1 J l TABLE C-1. (continued)
Number of LERs with l Deficiencies and 1 Observations l Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )
4 50.73(b)(21[11--Text presentation 3 (11) I inadequacies, i
- a. OBSERVATION: A diagram would have 0 aided in understanding the text discussion.
- b. Text contained undefined acronyms 0 and/or plant specific designators.
- c. The text contains other specific 3 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 LIRs 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.
I f
- --.-- ,- , - , --. - , , , y . -..
TABLE C-2. ABSTRAtl DEFICIENCIES AND OBSERVATIONS FOR CALLAWAi 1 Number of LERs with Deficiencies and Observations 8
Sub-paragraph Paragraph 8
Description of Deficiencies and Observations Totals ' Totals ( )
0 (11) g A summary of occurrences (immediate cause and effect) was not included or was inadequate A summary of plant, system, and/or personnel 1 (9) responses was not included or was inadequate.
Summary of plant responses was not 0 a.
included or was inadequate.
1
- b. Summary of system'~ responses was not included or was inadequate.
- c. Summary of personnel responses was not 1
included or was inadequate.
A summary of the root cause of the event 6 (11) was not included or was inadequate.
A summary of the corrective actions taken or 5 (11) planned as a result of the event was not included or was inadequate.
f TABLE C-2. (continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )
Abstract presentation inadequacies 1 (11)
- 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 0 l
1400 characters I
- c. The abstract contains undefined 0 acronyms and/or plant specific designators.
- d. The abstract contains other specific 1 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, (e.g., an LER can be deficient in the area of both date and time infornation), 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 considereo applicable. l i
i i
(
TABi! C-;. COXDTIELEDUit1EhtitS ANu OBSERVATIONS FOR CALLAWAY l Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies ano Observations Totals Totals ( )D Facility Name 0 (11)
- a. Unit number was not included or incorrect.
. b. Name was not included or was incorrect.
- c. Adaitional unit numbers were included but not reautred.
Docket Number was not inclucea or was 0 (11) incorrect.
Page Number was not included or was 0 (11) incorrect. .,
Title was lef t blank or was inadeouate 10 (11)
- a. Root cause was not given.in title 10
- b. Result (effect) was not given in title 0
- c. Link was not given in title 3 Event Date 0 (11)
- a. Date not included or was incorrect.
- b. Discovery date given instead of event cate.
LER Number was not included or was incorrect 0 (11)
Report Date 0 (11)
- a. Date not included
- b. OBSERVATION: Report date was not within thirty days of event date (or discovery cate if appropriate).
Otner Facilities information in fielo is 0 (11) inconsistent with text ana/or abstract.
Operating Mode was not includeo or was 0 (11) inconsistent with text or abstract.
l
TABLE C-3. (continued) ,
Number of LERs with Deficiencies and Observations I
Sub-paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals ( )
Power level was not included or was 0 (11) l inconsistent with text or abstract Reporting Requirements 0 (11)
- a. The reason for checking the "0THER" requirement was not specified in the abstract and/or text.
- b. OBSERVATION: It may have been more appropriate to report the event under a different paragraph.
- c. OBSERVATION: It may have been appropriate to report this event under an additional unchecked paragraph.
Licensee Contact 0 (11)
- a. Field left blank
- b. Position title was not included
- c. Name was not included
- d. Phone number was not included.
Coded Component Failure Information 0 (11)
- a. One or more component failure sub-fields were left blank.
- b. Cause, system, and/or component code l is inconsistent with text.
- c. Component failure field contains data wher,no component failure occurred.
- d. Component failure occurred but entire field left blank.
1 TABLE C-3. (continued)
Number of LERs with Deficiencies and Observations I
Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals ( )
Supplemental Report 0 (11) l
- 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 0 (11) 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, (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.
.e a m- n-- - -- e -- ., ._e.. .e n - - -
1 1
=
B E
APPENDIX D LER COMMENT SHEETS FOR CALLAWAY l
.e
TAbtED't. TPEllflC~ LEK EOMMENTS FOR CALLAWAY (483)
Section Comments
- 1. LER Number: 85-033-00 a:
Scores: Text = 8.c Abstract = 9.2 Coded Fields = 9.1 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions Detore the event is not included.
- 2. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadecoate. The text should be more specific as to how the building not being contiguous to the power block caused the problem. For example, was the review process inaaecuate?
- 3. 50.73(o)(4)--A aiscussion of actions reautrea to reduce the probaDility of recurrence (i.e, Correction of the root Cause) is not included or is inadeauate.
If a problem did exist in the review process, then
- responsible personnel should be notifiea and steps s taken to prevent recurrence.
Abstract 1. No comments.
Coded Fields 1. Item (4)--Title: Root cause is not included.
l i
TABLEO 1. - SKCIFIC LC COPENTL FOR EALLAWA) 1483)
Section Comments
- 2. LER Number: 85-037-00 Scores: Text = 9.9, Abstract = 9.4 Codeo Fielos = 9.0 Overall = 9.6 Text 1. Tnis is an excellent LER. All the reautrements of i
10 CFR 50.73(b) are met. The text includes detailed information that is well presented.
Abstract 1. 50.73(b)(1)--Summary of root cause is inaceouate.
The abstract should mention that a contributing f actor was a less than desirable alarm inoication of the AFD cumulative penalty deviation time.
! Cooea Fields 1. Item (4)--Title: Root cause is not included.
- 2. Uncefined acronyms snould not be used in the title.
4 1
r _. _ _
~
, TAELL.C L' SDL;!F10 25 COPPENikT0h CALLAWAY (483)
'Section Comments
- 3. LER Number: 85-039-00 J
l Scores: Text = 8.6 Anstract = 8.8 Coded Fields = 8.5 Overall = 8.7 Text 1. 50.73(b)(2)(ii)(0)--The root and/or intermediate i cause discussion concerning the stuck check valve (AFV-160) is not included.
l 2. 56.73(b)(2)(ii)(J)(2)--Discussion of the personnel l error is inadeouate.
{
I 50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether l tne personnel error was cognitive or procedural is 1
not incluaed. How were the operators supposea to 4
recognize the ADV-0267 was still closed?
- 3. 50.73(b)(3)--Discussion of the assessment of the safety conseauences and implications of the event is iaaaeauate. Wny is it alright not to " work" AFV-160 until tne (next?) refueling outage?
- 4. 50.73(b)(4)--Discussion of corrective actions taken or plannea is inadecuate. It is not clear from the text whether or not AFV-160 was reopenea; if it was, wn6t will prevent it from sticking shut again prior to the time it is " worked"?
Is there a need for a proceaure to ensure that valves that have been repositioned, but are not tagged, will ot placed back to their normal line-up at the end of the maintenance process? (See third sentence of r
second paragraph in the Background Section.)
i 5. The text appears to contradict itself. The first
! sentence unaer " Action to Prevent Recurrence"
! indicates there may have been some previous events but "none" is listed under the heaaing previous occurrences.
4
- 6. A supplemental report may be appropriate if the cause of AFV-160 sticking is a generic problem.
! Abstract 1. 50.73(b)(1)--Summary of root cause information 1 4
concerning AFV-160 is not incluaea. ;
l I
hbd D-i. '3PECIf1C 1.E LC19ltt;100n CALLAMAN (483)
Comments J Section
- 3. LER Number: 85-039-00 tcontinueo)
- 2. The atstract appears to contraoict the text in the area of corrective actions. Tne abstract says the I AFV-160 was freed but that is not stateo in tne text.
Cooed Fielas 1. Item (4)--Title: Root cause ano link (maintenance) [
- are not included.
s I
4
) 4 1
l l
I
TABLE D-1. SPECIFIC LER COMMENTS FOR CALLAWAY (483)
Section Comments
- 4. LER Number: 85-042-00 Scores: Text = 9.2 Abstract = 9.6 Coded Fields = 8.9 Overall = 9.3 Text 1. 50.73(b)(2)(ii)(D)--The text should clarify how an abnormal reading cou d occur from a procedural error.
l-
- 2. 50.73(b)(2)(ii)(K)--pistingthesystemswhich actuated as a resulv of the trip is good.
- 3. 50.73(b)(4)--The text should be specific as to what was changed in the procedure.
ADstract 1. No comments.
Coded Fields 1. Item (4)--Title: Root cause ano link are not includea.
I s
i 1
. , , ,.m _ __ _._y_.,. m-. ._ _ ,.
T ABK G- 1. SPE;Ir:0 LU; COMMECS FOR CALLAWi 1483)
Section Comments i
- 5. LER Number: 85-043-00 1 Scores: Text = 9.4 Abstract = 9.6 Coded Fields = 8.7 Overall = 9.4 Text 1. The corrective actions and safety assessment ciscussions are very good.
! Abstract 1. No comments.
Coaec Fields 1. Itee (4)--Title: Root cause is not included.
Acronyms snould not be used in the title unless space is a problem.
l l
1 1
9 9
- - . . . n - -- , -- , - - , - -
7 AbiEG-i.- SFECUTC LG CUMMEhTb FOR CALLAWAY (4B3)
Section Comments
- 6. LER Number: 85-047-00 Scores: Text = 8.3 Abstract = 8.5 Coaea Fields = 8.5 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not includea.
There is no discussion that indicates how long the subject room cooler may have been inoperable prior to the " incidental observation".
- 2. 50.73(b)(2)(ii)(J)(2)--It appears that personnel
< error is involved in this event, but it is not discussea. For example, it appears that the last six month inspection of the room cooler belts may not have been adeauate, given tha statement that the belts do not have a history of failing between normal inspections. If the belt was adeauately inspected at the last inspection and found to have no degradation, it appears the interval for this inspection is too long.
- 3. 50.73(b)(2)(ii)(L)--Identification (e.g. manuf acturer and moael no.) of the failed component (s) discussed in the text is inaaeouate. Information concerning tne fa+1ed belts shoula nave been proviaed.
- 4. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is inaaeouate. If the belts were f ailed for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to being discovered (see comment number 1), what are the safety implications of operating in violation of T/S 3.1.2.4 ana 3.5.2?
- 5. 50.73(o)(4)--Discussion of corrective actions taken or plannea is inadeauate. Was any action taken to ensure that one CCP will not be taken out of service prior to ensuring that the remaining CCP (ano its auxiliary systems) are operable? See the first sentence of comment number 2.
- 6. Some conclusions reached are inconsistent with the facts presented. See comment number 2.
Abstract 1. 50.73(b)(1)--Summary of root cause is inadeauate.
The fact that the belts were considered to have f ailed due to normal wear should have been mentioned in the abstract.
'TA5&T,- :.- SPEZ IL LU.-C3FMEP,n }UKu;LAWAi (4b3)
Section Comments ,
4
- 6. LER Number: 85-047-00 (continued)
I
- 2. 50.73(b)(1)--Summary of corrective actions taken or planneo as a result of the event is inadeauate. See l text comment number 5.
Coded Fields 1. Item (4)--Title: Root cause and link are not l incluoed. Technical Specifications should be s out in the title ratner than abbreviated (T/S) pellea A better title for this LER might be: " Charging Pump i
Removea From Service with Remaining Pump Inoperable--Technical Specification Violation".
I I
.- -TEI L-;. 3FECWWeG CUPPCC', TOK LALLAWAY 1483)
Comments Section
- 7. LER Number: 85-050-00 Abstract = 9.4 Coceo Fielos = 8.9 Overall = 9.2 Sc<res: Text = 9.2 Text 1. 50.73(b)(2)(ii)(A),--Discussion of plant operating I conditions before the event is not included.
- 2. 50.73(D)(2)(ti)(F)--The Ells component code for the breaker (BKR) should be included, g Abstract 1. Tne root cause summary should be expanded to indicate that no unusual activities were found to have taken place simultaneously with the isolations, i
Coded Fields 1. Item (4)--Title: Root cause (unknown) is not included.
- 2. Item (13)--Care should be used when considering a breaker or a fuse to be failed. If the breaker opens or the fuse blows as a result of an overcurrent condition these components have performed their intended function and a failure has not occurreo. A failure of a breaker or fuse occurs only when they operate below their setpoints or f ail to open the circuit when an overcurrent condition exists.
~
TFEL L-..- SPA! it ifW %WiNi5 FDf LALLAWAY (483)
Section Comments ,
- 8. LER Number: 85-051-00
, Scores: Text = 9.1 Abstract = 8.9 Coded Fields = 8.5 Overall = 9.0 50.73(b)(4)--The commitment to provide a supplemental Text 1.
report if the engineering evaluation shows a generic i component flaw is very good; however, because the cause of the LVOT magnetic core seizure is rot given
' in the text, a supplemental report would be appropriate if any information concerning the cause i of failure is oiscovered (i.e., improper installation, inadeauate preventative maintenance, etc.).
Abstract 1. 50.73(b)(1)--The abstract should mention the f ailure of the Main Feed Pump speed control.
i
- 2. 50.73(b)(1)--Summary of corrective actions taken or planneo as a result of the event is not includea.
The abstract should mention the replacement of the Main Feed speed control components.
4 Codeo Fielos 1. Iten (4)--Title: Root cause is not included.
i l
1 i
i
)
l w
l
TABLE D-1. SPECIFIC LER COMMENTS FOR CALLAWAY (483)
Section Comments
- 9. LER Number: 85-052-00 Scores: Text = 8.6 Abstract = 8.1 Coded Fields = 9.5 Overall = 8.5 Text 1. 50.73(b)(2)(ii)(J)(2)--It appears that personnel error is involved in this event, but it is not discussed. Is it procedure to take no action given the MFIVs indicated closed on the ESFAS panel?
- 2. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is inadeauate. What are the implications of this event occurring at 100% power rether than 1%?
- 3. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadeauate. It is not clear from the discussion in the next to last paragraph on page 2 what problem would be fixed when the logic proDiem gets resolvea. Did tnis logic problem result in the f ailure to receive the Feeuwater Isolation Actuation Signal?
- 4. A logical transition does not exist between all ideas.
- 5. Why is the fast close input jumpered to all four MFIVs? Is this still the Case?
Abstract 1. 50.73(b)(1)--Summary of personnel and system responses is inadeauate. The f act that no action was .
taken due to the lack of the Feedwater Isolation Actuation Signal should be mentioned.
- 2. 50.73(b)(1)--Summary of cause information is inadeauate. The logic problem that reauired the modification reauest should have been mentioned.
- 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeouate. The f act that the logic problem is going to be resolved should have been mentioned.
Codea Fields 1. Item (4)--Title: Root cause is not included. l
o
. TABLE sP SPECIFJr -LEP . COMMENTS FOR CALLAWAY (483)
Section Comments
- 10. LER Number: 85-053-00 Scores: Text = 9.9 Abstract = 9.6 Coded Fields = 9.1 Overall = 9.7 Text 1. 50.73(b)(5)--Care should be used in trying to determining if a similar event has occurred, because similar events do not have to be exactly the same.
This LER describes an omission in an Operations Surveillance Procedure that lead to a technical specification violation and is at least the second occurrence of this type (see LER 85-033-00).
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeouate. The f act that the Design Change Program was changed shoula be mentioned.
Codeo fields 1. Item (4)--Title: Root cause is not includea.
i l
-~ - - -. .
.TABir p_i ..SorfJrJr..irp coMMrwTc r0D CALLAWAY (483)
Section Comments ,.
- 11. LER Number: 85-054-00 Scores: Text = 8.7 Abstract = 8.5 Coaea Fields = 9.5 Overall = 8.7 Text 1. 50.73(b)(2)(ii)(H)--A time estimate of the 8 unavailability of the f ailed system is not included.
It is not clear to the reader when the RCS Loop OTDTs were returneo to service.
- 2. 50.73(b)(4)--Discussion of corrective actions taken or planneo is inadeouate. Were the circuit cards replaced on both RCS Loop 1 ana Loop 3 OTDTs?
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeouate. The card replaceme.nts and trencing program should be mentioned in the abstract. ,.
Codeo Fields 1. Item (4)--Undefined acronyms (OT) shoula not be used in the title unless space is a problem.
i 1