ML20212B210
| ML20212B210 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/19/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kingsley O MISSISSIPPI POWER & LIGHT CO. |
| References | |
| NUDOCS 8612290197 | |
| Download: ML20212B210 (52) | |
See also: IR 05000416/1986035
Text
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December 19, 1986
Docket No. 50-416
License No. NPF-29
Mississji pi Power and Light Company
ATTN: Ar. O. D. Kingsley, Jr.
Vice President, Nuclear Operations
P. O. Box 23054
Jackson, MS 39205
Gentlemen:
The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of
Operational Data (AE00) has recently completed an assessment of your Licensee
Event Reports (LERs) for Grand Gulf 1 as a part of the NRC's Systematic Assessment
of Licensee Performance (SALP) program.
In general, AE00 found your submittals to be slightly above average quality
based on the requirements contained in 10 CFR 50.73. The principal weakness, in
- terms of safety significance, was not adequately identifying failed components
in the text. A strong point was providing the failure mode, mechanism, and
effect of each failed component.
We are providing you a copy of AE0D's assessment prior to the issuance of the
SALP 50-416/86-35, 50-417/86-05 Board Report, for Grand Gulf 1 and 2,
respectively, so that you are aware of their findings and may use the
information to pattern future submittals.
We appreciate your cooperation with us. Please let us know if you have any
questions.
Sincerely,
Original Signed by
Roger D. Walker
Roger D. Walker, Director
Division of Reactor Projects
Enclosure:
AE00 Input to SALP Review for
Grand Gulf I
cc w/ encl: (see page 2)
,
8612290197
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Mississippi Power and 2 December 19, 1986
Light Company
- c w/ encl:
-
. H. Cloninger, Vice President, Nuclear
-
Engineering and Support
. E. Cross, GGNS Site Director
. R. Hutchinson, GGNS General Manager
L. F. Dale, Director, Nuclear Licensing
and Safety
R. T..Lally, Manager of Quality Assurance
.l Middle South Services, Inc.
J R. B. McGehee, Esquire
Wise, Carter, Child, Steen and Caraway
jN.S.Reynolds,. Esquire
Bishop, Liberman, Cook, Purcell
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& Reynolds
J R. W. Jackson,' Project Engineer
/bcc w/ encl:
JNRC Resident Inspector
Document Control Desk
State of Mississippi
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ENCLOSURE
4
AE00 SALP INPUT FOR
GRAND GULF 1
OPERATIONS (LER QUALITV) FOR
THE ASSESSMENT PERIOD OF
May 1,1985 to October 31, 1986
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SUMMARY
An evaluation of the content and quality of a representative sample of
the Licensee Event Reporis (LERs) submitted by Grand Gulf I during the
May 1, 1985 to October 31, 1986 Systerr.atic Assessment of Licensee
Fer f orrr.ance (SAL F ) period was per f orme using a refinert.ent of the basic
methodology presented in NUREG-1022. Supplement No. 2. The results of this
evaluation indicate that Grand Gulf LERs have an overall average LER score
of 8.4 out of a possible 10 points, compared to a current industry average
score of 8.1 for those unit / stations that have been evaluated to date using
this methodology.
The principle weakness identified in the Grand Gulf LERs, in terms of
safety significance, involves the requirement to adequately identify failed
components in the text.
The failure to adequately identify each component
that fails prompts concern that possible generic problems may go unnoticed
for too long a time period by others in the industry.
A strong point for the Grand Gulf LERs is the requirement to provide
the failure mode, mechanism, and effeet of each failed component discussed
in the text.
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e e
AE00 INPUT TO SALP REVIEW FOR
GRAND GULF 1
Introduction
in order te evaluate the overall quality of the contents of the
Licensee Event Reports (LERs) submitted by Grand Gulf 1 during the
May 1, 1985 to October 31, 1986 Systematic Assessment of Licensee
Performance (SALP) assessment period, a representative sample of the unit's
LERs was evaluated using a refinement of the basic methodology presented in
NORE6/1022 Supplement No. 2.I The sample consists of 15 LERs, which is
considered to be the maximum number of LERs necessary to have a
representative sample (see Appendix A for a list of the LER numbers in the
sample).
It was necessary to start the evaluation before the end of the 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, abstracts, and coded fields
meet the criteria of 10 CFR 50.73(b). In addition, each selected LER is
campared to the guidance for preparation of LERs presented in NUREG-1022
and Supplements No. 1 and 2 to NUREG-1022; based on this comparison,
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suggestions were developed for improving the quality of the reports. The
purpose of this evaluation is to provide feedback to improve the quality of
LERs. It is not intended to increase the requirements concerning the
" content" of reports beyond the current requirements of 10 CFR 50.73(b).
Therefore, statements in this evaluation that specify measures that should
be taken are not intended to increase requirements and should be viewed in
1
that light. However, the obvious minimum requirements of the regulation
,
must be met.
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The evaluation process for each LER is divided into two parts. The
irst part of the evaluation consists of documenting comments specific to
- ne content and presentation of each LER. The second part consists of
tetermining a score (0-10 points) for the text, abstract, and coded fields
each LER.
The LER specific comments serve two purposes: (1) they point out what
.ne analysts considered to be the specific deficiencies or observations
. :oncerning the information pertaining to the event, and (2) they provide a
- Lasis for a count of general deficiencies for the overall sample of LERs
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u nat was reviewed. Likewise, the scores serve two purposes: (1) they
---terve to illustrate in numerical terms how the analysts perceived the
. .__...
rontent of the information that was presented, and (2) they provide a basis
or determining an overall score for each LER. The overall score for each
_iR is the result of combining the scores for the text, abstract, and coded
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- ields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields
...._. _.... tore - overall LER score).
The results of the LER quality evaluation are divided into two
-
_ategories: (1) detailed information and (2) summary information. The
_. - --~-- etailed information, presented in Appendices A through D, consists of LER
le information ( Appendix A), a table of the scores for each sample LER
.. . .c_:.2nopendix 8), tables of the number of deficiencies and observations for the
- : ext, abstract and coded fields ( Appendix C), and connent sheets containing
...__.~~arrative statements concerning the contents of each LER (Appendix D).
-ow-unnumusemen referring to these appendices, the reader is cautioned not to try to
1rectly correlate the number of connents on a consent sheet with the LER
- :: . .: ores, as the analysts has flezibility to consider the magnitude of a
- -----= f ic ienc y when a s s igning stor es .
Discussion of Results
A discussion of the analysts' conclusions concerning LER quality is
. __ rresented below. These conclusions are based solely on the results of the
e---un-
e aluation of the contents of the LERs selected for review and as such
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represent the analysts' assessment of the unit's performance (on a scale of
0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b).
Table 1 presents the average scores for the sample of LERs evaluated
f or Grand Gulf. In order to place the scores provided in Table 1 in
per spec tive, the distribution of the overall average score f or all
units / stations that have been evaluated using the current methodology is
provided in figure 1. Additional scores are added to Figure 1 each month
as other units / stations are evaluated. Table 2 and Appendix Table B-1
provide a summary of the information that is the ba, sis for the average
scores in Table 1. For example, Grand Gulf's average score for the text of
the LERs that were evaluated is 8.4 out of a possible 10 points. From
Table 2 it can be seen that the text score actually results from the review
and evaluation of 17 different requirements ranging from the discussion of
plant operating conditions before the event [10 CFR 50.73(b)(2)(11)(A)] to
text presentation. The percentage scores in the text summary section of ,
Table 2 provide an indication of how well each text requirement was
addressed by the unit for the 15 LERs that were evaluated.
Discussion of Specific Deficiencies
A review of the percentage scores presented in Table 2 will quickly
point out where the unit is experiencing the most difficulty in preparing
LERs. For example, requirement percentage scores of less than 75 indicate
that the unit probably needs additional guidance concerning these
requirements. Scores of 75 or above, but less than 100, indicate that the
unit probably understands the basic requirement but has either:
(1) excluded certain less significant information from 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 unit should review the
LER specific comments presented in Appendix D in order to determine why it
received less than a perfect score for certain requirements. The text
requirements with a score of less than 75 or those with numerous
deficiencies are discussed below in their order of importance. In
addition, the primary deficiencies in the abstract and coded fields are
discussed.
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TABLE 1. SUMMARY OF SCORES FOR GRAND GULF 1
Averace High Low
Text 8.4 9.6 7.4
Abstract 8.4 10.0 3.8
Coded Fields 8.9 10.0 7.5
Overall 8.4 9.5 6.4
a. See Appendix B for a summary of scores for each LER that was evaluated.
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TABLE 2.
LER REQUIREMENT PERr5.NTAGE SCORES f 0R GRAND 6Ulf 1
TiXT
Percentage
Requirements ISO.73(b)1 - Descrirtions 8
Scores ( 1 __
(?)(ii)(A) --
Plant condition prior to event
(?)( ti)(B) - - Inoperable equipment that contributed 97 (15)
b
(2)(11)(C) - - Date(s) and approximate times
95 (15)
(2)(11)(D) - - Root cause and intermediate cause(s) 88 (15)
(2)(ii)(E ) - - Mode, mechanism, and effect
(2)(11)(f) - - EIIS Codes 100 ( 4)
0 (15)
(2)(ii)(G) - - Secondary function affected b
(2)(ii)(H) - - Estimate of unavailability 17 ( 3)
(2)(11)(1) - - Method of discovery 93 (15)
(2)(11)(J)(1) - Operator actions affecting course 100 ( 7)
(2)(11)(J)(2) - Personnel error (procedural deficiency) 80 (11)
(2)(ii)(K) - - Saf ety system responses
100 (12)
(2)(ti)(L) - - Manufacturer and model no. information 38 ( 4)
(3) -----
Assessment of safety consequences
(4) -----
Corrective actions 91 (15)
83 (15)
(5) -----
Previous similar event inforsation
(2)(1) - - - - Text presentation 17 (15)
85 (15)
ABSTRACT
Percentage
Reautrements f 50.73(b)(1)1 - Descriotions , .Secres ( )*
- Major occurrences (Immediate cause and effect
inf orma t ion) 100 (15)
- Description of plant, system, component, and/or 96 (10)
personnel responses
- Root cause it. formation
78 (15)
- Corrective Action information 74 (15)
- Abstract presentation
78 (15)
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TABLE 2. (continued)
CODED FIELOS
Percentage
Item Number (s) - Description a
_ Scores ( 1
1, 2, and 3 - Facility name (unit no. ), docket no. and 100 (15)
page number (s)
4 - - - - - - Title
65 (15)
5, 6, and 7 - Event date, LER No., and report date
98 (15)
8 - - - - - - Other facilities involved 97 (15)
9 and 10 - - Operating mode and power level
100 (15)
11 - - - - - Repor ting requirements
97 (15)
12 - - - - - Licensee contact information 97 (15)
13 - - - - - Coded component failure informstion
93 (15)
14 and 15 - - Supplemental report information
07 (15)
a. Percentage sco os are the result of dividing the total points for a
requirement by the number of points pcssible for that requirement.
(Note: Some regelrements 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 f rom the information available to the analyst whether
this requirement is applicable to a specif'.c LER. It is always given 100%
if it is provided and is always consid? red 'nct applicable' when it is not.
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The manufacturer and/or model number (or other unique identification)
was not provided in the text of three of the four LERs that involve a
component f ailure, Requirement 50.73(b)(2)(11)(L). Components that fail
should be identified in the text so that others in the industry tan be made
a.are of potential problems. An event at ene station can often lead to the
identificat tor. of a generic problem that can be corrected at other plarts '
or stations bef ore they experience a sistlar problem. In addi tiory '
although not specifically required by the current regulation it would be
helpf ul to identify components whose design contr ibutes to an event. '
Although date and time information was considered adequate in all of ,
the LERs, Requirement 50.73(b)(2)(11)(H) which is closely related to
Requirement 50.73(b)(2)(ii)(C) reciesed a score of only 17%. The't:me a
safety system train is unavailable is important because this information is
necessary to the performance of probabilistic risk assessments. Additional
attention paid to providing date and time information for major occurrences
(50.73(b)(2)(11)(C)) will ensure that the unavailability time requirement w
is met. ,
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Requirement 50.73(b)(5) was not adequately addressed in thirteen of '
the fifteen LERs in that their text did not include tne necessary (
information concerning previous similar events. All previous sia11ar s
events should be appropriately referenced (by LER number, if possible) and
the history of the on-gcing problem should be discussed, if necessary. If
there have been no previous similar events, the text should state this.
This information is important because it can aid a licensee in determining
if there is a recurring problem and whether or not his corrective actions
sre effective.
None of the LERs included the Energy Industry Identification System
(E!!S) codes. Requirement 50.73(b)(2)(1%)(F) requires inclusion of the
appropriate EIIS code for each system and component referred to in the text.
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While there are no specific reoutrements for an abstract, other than
those given in 10 CFR '50.13(b)(1), an abstract should, as a minimum,
sununar tre the following informa tion fiom the, text:
s
1. Causq/Effeet What happened that made' the
, event reportable.
A
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Major plant, systea, and
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, - , personncl responses as a result
s
, , of the event,
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3. Root / Intermediate The underlying cause of the
Causes ,
event. What caused the
, '
,
component and/or system failure
,
or the personnel error.
4. Corrective Actions What was done insnediately to '
'
restore the plant to a safe and
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' stable condition and what was
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done or olanned to prevent
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recurrence.
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Grand Gulf had good discussions of item numbers 1 and 2. Item
?,
numbers 3 and 4 could use some improvement, however. Abstract scores for
these items should improve if the root cause and corrective action
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information contained in the text is sunenarized in the abstract.
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Thc main deficiency in the area of coded fields involves the title.
Item (4). Ten of the titles failed to indicate the root cause, six failed
to indicate the result (i.e., why the event was required to be reported),
and one f ailed to include the link between the cause and the result. While
result is considered the most important part of tne title, cause
information (and link, )1 necessary) must be~ included to make a title
.
complete.
An 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 title might be " Inadvertent Relay Actuation
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During Surveillance Test LOF-1 Causes 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. Example titles are
provided in Appendir 0,(Coded fields section), for some of the titles that
are considered to be deficient.
Tatie 3 provides a summary of the major areas that need improvement
for the Grand ou r lf (ERs. For more specific information concerning
additional deficiencies, the reader should ref er to the information
presenteo in Appendices C and D. General guidance concerning requirements
can be found in NUREG-1022, Supplement No.1 and 2.
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TABLE 3. ARE AS MOST NEEDING IMPROVEn[NT FOR GRAND GULF LERs
,
Areas Comments
,
' Manufacturer and model number Component identification inf ormation
inf orma t ion
should be included in the text
whenever a component fails.
L ik e.ise (althcagt not
specifically required by the
current regulation) it would also
be helpful to provide
identification information whenever
a component is suspected of
contributing to the event because
of its design.
Saf ety train unavailability Sufficient dates and times should
be included to enable the reader to
determine the length of time that
safety system trains or components
were out cf service.
Ells codes Codes for each component and system
referred to in the text should be
provided.
Abstract Root cause and corrective action
information discussed in the text
should be summarized in the
abstracts.
Coded fields
a. Titles Titles need to be written such that
they better describe the even,t.
This can be accomplished by
including the root cause, result,
and the link between them in each
title.
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REFERENCES
1. Office for Analysis and Evaluation of Operational Data Licensee Event
Report System, NUREG-1022 Supplement No. 2 U.S. Nuclear Regulatory
Commission, September 1985.
2. Office for Analysis and Evaluation of Operational Data. Licensee Event
Report System, NURIG-1022, U.S. Nuclear Regulatory Commi:sion,
Septemte- 1983.
3. Of fice for Analysis and Evaluation of Operational Data, Licensee Event
Report System, NURFG-1022 Supplement No. 1. U.S. Nuclear Regulatory
Commission, February 1984.
.
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APPENDIX A
LER SAMPLE SELECTION
INFORMATION
FOR GRAND GULF 1
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TA8LE A-1. LER SAMPLE SELECTION FOR GRAND GULF 1 (416)
J
Sample Number LER Number Comments
1 85-019-00 ESF
2 85-020-00 SCRAM
3 85-022-02 E ST
4 85-033-01
5 85-038-01 ESF
6 85-039-00
7 85-047-00 ESF
8 85-048-00 ESF
9 85-050-01 SCRAM /ESF
10 86-001-00 SCRAM
11 86-003-00 SCRAM
12 86-007-00 ESF
13 86-013-01 ESF
14 86.-019-00
15 86-022-00
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A-1
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APPCNDIX B
EVALUATION SCORES OF
INDIVIDUAL LERS FOR GRAhD GULF 1
__
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TA8LE 8-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR GRAND GULF 1 (416)
LER Sample Number
1 2 3 4 5 6 7 8
Text 7.4 8.1 8.8 7.9 9.1 7.6 8.5 9.4
Abstract 3.8 7.5 9.1 8.4 10.0 8.5 8.9 10.0
Coced 7.8 7.5 9.0 9.0 10.0 9.5 9.2 8.9
Fields
Overall 6.4 7.9 8.9 8.2 9.4 8.1 8.7 9.5
.
LER Sample Number
9 10 11 12 13 14 15 Averace
Text 8.0 8.3 8.5 8.0 8.2 9.6 7.9 8.4
Abstract 8.2 9.3 7.8 8.7 8.9 8.1 9.1 8.4
Coded 8.5 9.8 9.0 8.2 9.2 8.0 9.5 8.9
Fields
Overall 8.1 8.7 8.3 8.2 8.5 9.0 8.4 8.4
4. See Appendix A for a list of the corresponding LER numbers.
B-1
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APPENDIX C
DEFICIENCY AND OBSERVATION
COUNTS FOR GRAND GULF 1
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TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR GRAND GULF 1 (416)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph Paragraph
Description of Deficiencies and Observations Totals' Jotals ( )
SC.73(b)(?)(ii)( A)--Plant operating
conditions before the event were not 1 (15)
included or were inadequate.
50.73(b)(?)(11)(B)--Discussion of the status 0 ( 3)
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)(?)(ii)(C)--Failure to include 3 (15)
suf ficient date and/or time inf ormation.
a. Date information was insuf ficient. 2
b. Time information was insuf ficient. 1
50.73(b)(2)(11)(D)--The root cause and/or 9 (15)
intermediate f ailure, system failure, or
personnel error was not included or was
inadequate,
a. Cause of component failure was not 7
included or was inadequate
b. Cause of system failure was not 1
included or was inadequate
c. Cause of personnel error was not 1
included or was inadequate.
SD.73(b)(2)(ti)(E)--The failure mode. 0 ( 4)
mechanism (immediate cause), and/or effect
(consequence) for each failed component was
not included or was inadequate.
a. Failure mode was not included or was
inadequate
b. Mechanism (immediate cause) was not
included or was inadequate
c. Effect (consequence) was not included
or was inadequate.
C-1
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TABLE C-1. (continued)
Number of LERs with
Deficiencies and
Observations
Sut-paragraph Paragraph
Descriptior. of Deficien:tes and Otsersations Totals' Totals ( )D
50.73(b)(2)(ti)(F )--The Energy Indus try
Identification System component function 15 (15)
identifier for each component or system was
not included.
50.73(b)(?)(11)(G)--for a failure of a --
( 0)
component with multiple functions, a list
of systems or secondary functions which
were also affected was not included or was
ina dequa t e.
50.73(b)(2)(li)(H)--For a failure tha t 2 ( 3)
rendered a train of a safety system
inoperable, the estimate of elapsed time
from the discovery of the failure until the
train was returned to service was not
included.
50.73(b)(2)(11)(I)--The method of discovery 1 (15)
of each component f ailure, 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 oiscovery for each system 0
failure was not included or was
ina dequa te
c. Methac of discovery for each 1
'
personnel error was not included or
was inadequate
d. Method of discovery for each 0
procedural error was not included or
was inadequate.
.
C-2
_
, , ._ _ _ _ _ _
_
. .
TABLE C-1. (continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph Paragraph
tescription cf Leficiencies anc Observations Totals' Totals ( )
50.73(b)(2)(ti)(3)(1)--Operator actions that
affected the course of the event including 0 ( 7)
operator errors and/or procedural
deficiencies were not included or were
inadequate.
50.73(b)(2)(ii)(J)(2)--The discussion of 6 (11)
each personnel error was not included or was
inadequate,
a. OBSERVATION: A personnel error.was 0
implied by the text, but was not
explicitly stated.
b. 50.73(b)(2)(ii)(J)(2)(1)--Discussion 1
as to whether the personnel error was
cognitive or procedural was not
incibded or was inadequate.
c. 50.73(b)(2)(11)(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 1
of aray 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)(ti)(J)(2)(iv)--Discussion 2
of the type of personnel involved
(i.e. , contractor personnel, utility
licensed operator, utility nonlicensed
operator, other utility personnel) was
not included or was inadequate.
C-3
. -_. _ - - - . _ _ _ _ . _ _ - - - - - _ - - - -
. .
TABLE C-1. (continued)
Number of LERs with
Deficiencies and
Observations
Sut. paragraph Paragraph
De s: M t ior. of Lef ic iencies anc Otser va t ter.s Totals # Totals ( )
50.73(b)(2)(ii)(K)--Automatic and/or manual 0 (12)
safety system responses were not included or
were inadequate.
50.73(b)(2)(ii)(L )--The manuf ac turer and/or 3 ( 4)
model number of each f ailed component was
not included or was inadequate.
50.73(b)(31--An assessment of the safety
consequences and implications of the event 6 (15)
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 2
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 (15)
including these to reduce the probability
of similar ever.ts occurring in the future
was not included or was inadequate.
C-4
_ _ _ _ . _ _ _ _ _ - . _ _. _ _ _ _
_
. .
2
TABLE C-1. (continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph Parag ap*
De s: r ip t io*. of Deficier. ies an: 0:scrvations Totals' Totals ( )'
a. A discussion of actions required to 4
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 3
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 O
required to prevent similar f;ilures
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 13 (15)
stellar events was not included or was
inadequate.
C-5
-- - , . _ - .- - - _ -
!
. .
TABLE C-1. (continued)
l
!
!
Number of LERs with
Deficiencies and ;
Observations
Sub-paragraph Parag aph
Descriptior, of Deficier,:ies ar< Otse vations Totals # Totals ( )
50.73(b)(?)(il--Text presentation
inadequacies. 3 (15)
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 tabulatton 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.
.
I
t
e
C-6
. _. . -. _ _ - _ _ - - _ _ _
-
_ _ _ _ _ _ . _ _ _ _ _ _ .
. .
TABLE C-2.
A8STRACT DEFICIENCIES AND OBSERVATIONS FOR GRAND GULF 1 (416)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph Paragrapt
De;;r t;t ion of Deficien:les anc Otserva tions Totals' Jotals ( )
A summary of occurrences (immediate cause
and ef fect) was not included or was 0 (15)
inadequate
A summary of plant, system, and/or personnel 0 (10)
responses was not included or was
ina dequa t e.
a. Summary of plant responses was not
included or was inadequate.
b. Summary of system responses was not
included or was inadequate.
c. Summary of personnel responses was not
included or was inadequate.
A summary of the root cause of the event
was not included or was inadequate. 6 (15)
A summary of the corrective actions taken or
9 (15)
planned as a result of the event was not
included or was inadequate.
.
s
C-7
- '
, .
TASLE C-2. (continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph pa agraph
Descrirttor. of Deftetencies anc Observations Totals' lotals ( )
Abstract presentation inadequacies 4 (15)
a. OBSERVATION: The abstract contains 0
information not included in the text.
The abstract is intended to be a
summary of the text, therefore, the
text should discuss all information
summarized in the abstract.
b. The abstract was greater than 1
1400 characters
c. The abstract contains undefined 0
acronyms and/or plant specific
designators.
d. The abstract contains other specific 3
deficiencies (i.e., poor
summarization, contradictions, etc.)
a. The "sub-paragraph total" is a tabulation of specific deficiencies or
observations within certain requirements. Since an LER can have more than
one deficiency for certain requirements, the sub-paragraph totals do not
necessarily add up to the paragraph total.
b. The "pa-ag*aph total' is the nu.iber of LERs that have one or acre
ceficiency or observation. The number in parenthesis is the number of LERs
for which a certain requirement was considered applicable.
4
C-8
-. . -. . . _ _
. _ . _ _ _ . - _-
. .
TABLE C-3. CODED FIELOS DEFICIENCIES AND OBSERVATIONS FOR GRAND GULF 1
(416)
Number of LERs with
Deficiencies and
Observations
Sut-pa ag at' Fa'agraph
Description of De+1ciencies and Observations Totals' Totals ( )
Facility Name
0 (15)
a. Unit number was not included or
incorrect.
b. Name was not included or was
incorrect.
c. Acditianal unit numbers were included
but not required.
Docket Nunter was not included or was 0 (15)
incorrect.
Page Number was not included or was 0 (15)
incorrect. '
Title was lef t blank or was inadequate 13 (15) 1
a. Root cause was not given in title 10
b. Result (effect) was not given in title 1
c. Link was not given in title 6
Event Date 0 (15)
a. Date not in:luded or was incorrect,
b. Discovery date given instead of event
date. '
LER Number was not included or was incorrect 0 (15)
Report Date 1 (15)
a. Date not included 1
b. OBSERVATIOh: Report date was not 0
within thirty days of event date (or
discovery date if appropriate).
Other Facilities information in field is 1 (15)
inconsistent with text and/or abstract.
Operating Mode was not included or was 0 (15)
inconsistent with text or abstract.
C-9
. - _ _ _ . . . _-__ ___ __ ._
. .
TABLE C-3. (continued)
Number of LERs with
Deficiencies and
_ Observations
Sub-paragraph Faragraph
Desc r ipt ior, c' De' icier,: tes and Obser va t ions Totals Totals ( )
Power level was not included or was 0 (15)
inconsistent with text or abstract
Reporting Requirements 1 (15)
a. The reason for checking the 'OTHER" 0
requirement was not specified in the
abstract and/or text.
b. OBSERVAT10h: It may have been more 1
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 2 (15)
a. Field left blank 0
b. Position title was not included 2
c. Name was not included 0
d. Phone number was not included. O
Coded Component f ailure Information 1 (15)
a. One or more component f ailure O
sub-fields were left blank,
b. Cause, system, anc/or component code 0
is inconsistent with text.
c. Component failure field contains data 0
when nc component f ailure occurred.
d. Componer.1 f ailure occurred but entire 1
field left blant.
C-10
-- - _ _ _ _ - _ _
. .
TABLE C-3. (continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph Paragraph
Ce>c r iption of Def tciencies anc Observations Totals # Totals ( )
Sup;. iemental Repor t 3 (15)
a. Neither "Yes*/*No" block of the 0
supplemental report field was
checked,
b. The block checked was inconsistent 3
with the text.
Expected submission date information is 0 (15)
inconsistent with the block checked in
Ites (14),
a. The "sub-paragraph total" is a tabulation of specific deficiencies or
observations within certain requirements. Since an LER can have more than
one deficiency for certain requirements, the sub-paragraph totals do not i
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 requireacnt was considered applicable.
.
$
C-11
4 9
e
APPENDIX 0
LER COMENTS SHEETS FOR
GRAND GULF 1
.
' - -- --- r - ~ ~ ~--,w e +--v--- --
. .
TABLE D-1.
SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Commen t s
1. LER Number: 85-019-00
Scores: Text = 7.4 Abstract 3.8 Coded fields 7.8 Overall - 6.4
Test 1. The events reported in this LER should have been
reportec in separate LERs. If events are similar
(e.g., similar root cause), one LER may be
appropriate.
When events are not similar (even
though they occur in the same system) separate LERs
should be written. A minimum of three LERs appear to
be needed in this case. One for the events on May 17
and 18, since it appears that these may be similar;
and one LER for each of the other events.
2. 50.73(b)(2)(iilfD)--Although the root cause of the
events on May 17 and 18 could not be found, the
actions
discussed. taken to determine the root cause should be
3. 50.73(b)(2)(ii)(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.
4. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel
error is inadequate. Why did the operators in the
June 4 event fail to remove one RWCU filter and pump
at 100 psig as required?
5. 50.73(b)(4)--A supplemental report appears to be
needed to describe the results~of the Maintenance
Work Order issued on May 18. It appears that
investigations into the May 17 and 18 events lead to
the conclusion that the differential flow meters
could be faulty. Without a commitment to submit a
supplemental report, this LER mcst be considered
inc omp le t e .
6. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of root cause is not included.
2. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is not included.
D-1
_ _ _ _
.
-
___ _ _ _ _
a .
TABLE 0-1. SPECIf!C LER COMMENTS FOR GRAND SULF 1 (416)
Section Comments
1. LER Number: 85-019-00 (continued)
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 (unknown or personnel
error ) and link (high dif ferential flow) are not
included. The use of acronyms should be avoided in a
title unless title length is a consideration. A more
appropriate title might be " Multiple High
Dif ferential Flow 15*;1ations of the Reactor Kater
Cleanup System - Cause (Unknown or Personnel
Error)*. Although a complete title tends to be long,
the space for the title on form 366 is sufficient for
two type written lines.
2. Ites (14)--The block checked is inconsistent with
information in the text (see text connent 5).
.
l
l
1
0-2
1
_ _ _ . _ . _ _ _ _ _ _ - . __ .-- -- - - - - - - - -- --- - - - - - - - - - - - - - - - - - - - - - - -
, .
TASLE 0-1. SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Comments
2. LER Number: 85-020-00
Scores: Text - 8.1 Abstract = 7.5 Coded Fields - 7.5 Overall - 7.9
Text 1. 50.73(b)(2)(ii)(Fj--The Ene gy Industry
Icentif ica t tor, Sys ten component f unc tior.
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
2. 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.
3. 50.73(b)(31--Discussion of the assessment of the
safety consequences and implications of the event is
inadequate. What effect would leakage of the 8 lube
water pump discharge check valve have on continued
operation until the next outage of sufficient
duration? What will prevent low condenser vacuum in
the interim?
4. 50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate. A discussion of actions
required to correct the problem (e.g., return the
component or system to an operational state or
correct the personnel error) is not included or is
inadequate. A supplementary report would be
appropriate describing the " appropriate action" taken
during the next outage of sufficient duration.
5. 50.73(b )(5)--Inf orma ticr. cor.:erning pr e.tous similar
events is not included. If no previous similar
events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of root causes are inadequate.
A discussior, of tr.e procedural deficien:y anc the
leaking check valve shoulc be included.
2. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
change to the procedure and action to prevent
recurrence of the check valve leakage should be
discussed.
3. Abstract does not adequately summarize the text.
Additional space is available within the abstract
field to provide the necessary information but it was
not utilized.
0-3
_ _ _ _ _ _ - _ _ _ _ - _ _ - _ _ - . _ _ - . _ . _ .
o. .
TASLE 0-1. SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Comments
2. LER Number: 85-020-00 (continued)
Coded fielos 1. Iten (4)--11tle: Root cause (protecure erro-) is nc
inclucec.
2. Item (13)--Component failure occurred but entire
field is blank.
3. Item (141--The block checked is inconsistent with
inf orma tion in the text.
.
D-4
.__ . - _ - _ . - . - - - _ - . . . ._ _ - - ___ _ _ - -
. .
TABLE 0-1. SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Comments
3. LER Number: 85-022-02
Scores: Text 8.8 Abstract . 9.1 Coded Fields 9.0 0.erail = 8.9
lext 1. 50.73(b)(2)(ii)(D)--Tne root anc/or in t ermedia t e
cause discussion concerning the shield wire
termination and shield wire "touching the condult" is
not included. Did these problems exist since
original installation (i.e., construction / installation
deficiences)?
2. 50.73(b)(2)(11)(F )--The Energy Indus try
Identification System component function
identifier (s) and/or system name of each component
or system referred to in the LER is not included.
3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel
error is inadequate.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of
personnel involved (i.e., contractor persennel,
utility licensed operator, utility nonlicensed
operator, other utility personnel) is not included.
Who (by title) was responsible for the shield wire
termination and ground problem? See text comment
number 1.
4. 50.73(b)(4)--Does the potential exist for other
-
(like) shield wires to be terminated incorrectly?
5. 50.73(b)(5)--Information concerning previous similar
events is inadequate. A reference to other previous
events (e.g., an LER number) should be provided.
6. Neither the original report nct su;;1emer.! numte-
one to 85-022-00, comnit tee to a supplemental
report. Information provided in the text of both
indicate a supplemental report would have been
appropriate.
7. The use of " revision bars' to denote new information
is good.
Abstract 1. No c omment s .
Coded fields 1. Item (4)--Title: Root cause and link information is
not included. A better title might be, " Improperly
Terminated and Grounded Shield Wire The Apparent
Cause of Spurious Reactor Water Cleanup Isolations
While Checking Temperature Indication".
D-5
. _ _ _ . _ - . _
.. --- _ . _ _ _ .
. .
TASLE D-1.
SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Commen t s
4. LER Number: 85-033-01
Scores: Text = 7.9 Abstract = 8.4 Coded Fields 9.0 Overall , 8.?
les: 1. 50.73(b)(2)(ii)(C )--Date inf orma tion f or major
occurrences is inadequate. When were the walkdowns
performed?
2. 50.73(b)(2)(ii)(D)--The root and/or intermediate
cause discussion concerning the piping missing in the
release package is not included.
3. 50.73(b)(2)(ii)(F 1--The Energy Indus try
Identification System component function
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
4. 50.73(b)(3)--Discussion of the assessment of the
safety consequences and implications of the event is
inadequate. Specifies as to why there were no
unanalyzed conditions should be provided.
5. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
fact that the pipir,g is now controlled by Unit 1
personnel shculd be stated.
Coded Fields 1. I_ tem (4)--Title: Root cause is not included.
2. Item (8)--It would be appropriate to include Unit 2
in this field.
C-6
. . . _ _ - . _ _ - . _ ___ __ _
. .
TABLE 0-1.
SPECIFIC LER COMMENTS FOR GRAND SULF 1,(416)
l
Section Comments
5. LER Number: 85-038-01 '
,
Scores: Text = 9.1 Abstract 10.0 Coded Fields 10.0 Overall - 9.4
lest 1. 50.73(b)(2)f ti)(f 1--The E nergy Indus try '
Identification System component function
identifier (s) and/cr system name of each component or
,
system referred to in the LER is not included.
2. 50.73(b)(2)(ii)(L )--Identification (e.g.,
manufacturer and model no.) of the failed
component (s) discussed in the text is inadequate.
Inf ormation concerning the f ailed transf ormer should
be included.
3. 50.73(b)(3)--Discussion of the assessment of the
safety consequences and implications of the event is
barely adequate and could include a discussion of
what could happen to any liquid in the drywell sump
if the sump pump discharge valves leak through.
4. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should so state, t
.,
Abstract 1. No c omment s . 1
Coded Fields 2. No comments.
'
'
N
N
.
\
k
.
%
0-7
. ._. - __. - - -- . _ _ __. . . - . - . . - .
~
. s
- '
O, '
J
m[*e\, e
.
o
g ,
y g
7A8(E'D-1. SPECIFJC LER C054ENTS FOR GRAND GULF 1 (416)
e _ '_ .. .
T 6
'
.
Section _
_
' '
Conrnen t s
6. LER Number: 85-039-00 ,s
1, ' .
Scores: Text - 7.6 Abstract - 8,5/
.
Coded Fields 9.5 Overall = 8.1
- '
Test s '1.
-
SL' . 7 3(r1( 2 ) ( i i ) ( 0 )--T@? roet and/or 1r.t e r:ned ia t e
h-
'
N
cause discussior, Concerning the deenergized rela) in
the RPS logic is not included. Is this relay
norn. ally de, energized under these conditions? (Does
'
the isolation signal always seal-in?)
2. 50.73(b)[?)(ii)(F )b-The Energy Industry
identif15ation Sys tem component f unction
identif te'r(5 ) and/or system name of each component or
,{ system ref er' red to in 'the LEE is not included.
$
3 50.73(b)(2)( ti!Rf1--A time estimate of the
(- ,
,
unavailability ci the f ailed train / system is not
included. For how long a period was the SDC function
,
lost?
4. 50.73(b)(3)--Discussix of the assessment of the
- s safety consequences and implications of the event is
inadequate. The reader does not have immediate
, 'I accessibility to the GGN3 FSAR. The necessary
-
information concerning a loss 'of SDC and a loss of AC
power, under more severe coaditions, should have been
ce suntnar i zed . See last two sutences of page 4 of the
,
LER.
~
5. 50.73(b)(4)--Discussion of corrective actions taken
'-
or piar.r.ec is ir. adequate. Wr.a; was dor.e to restore
the SDC function?
6. 50.73(b)(5)--Information concerning previous similar
p '
events is not included. If no previous simila-
events ar e knoc., the text shecid st state.
).\'
~
L 7. Some ideas are not presented clearly (hard to follow).
Abstract 1. 50.73(b)(11--Suntmary 'lof root cause is inadequa te.
The abstract should' state that t!e error was a
cognitive personnel error on the part of the
w
electrician (s).
'
,
, ,
1., .,
' N Coded: Fields 1. Link is not included. A better
i\ '
Ites (4)--Title:
title might be, " Personnel Error While Removing Relay
for Calibration'Caus'es Loss of A11' Power To The
Division 2 ESF Bu's'. ' -
,
> ,
D-8
\_
I
.- - . - . . . -__. . _ - - - - -
c
. .
TABLE 0-1. 6
SPECIFIC LER COMMENTS FOR GRAND Gull l (416)
Section Comments
7. LER Number: 85-047-00
Scores: 7 ext 8.5 Abstract - 8.9 Coded fields 9.2 Overall = 8.7
lest 1.
50.73(b)(2)(ii)(D)--Wnen a root cause cannot be
determined it is helpful to the reader if the LER
includes a discusston of actions taken to try to
determine the cause.
2. 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.
Abstract 1. No c omment s .
4
Coded Fields 1. Item (41--Title: Root cause is not included.
4
D-9
__
- ._ _. __ .._ __ _ _ _ ,
- L.<.
+
1 :
TASTE 0-1.
SPECIFIC LER COMMENTS'FOR GRAND GULF 1 (416)
_ Section Comments
8. LER Number: 85-048-00
Scores: Text - 9.4 Abstract = 10.0 Coded Fields . 8.9 Overall 9.5
Text 1. 50.73(b)(2)(ii)(F )--The Energy Indus try
Identification System component f unction
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
2. 50.73(b)(5)--Inf ormation concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
Abstract 1. No comments.
Coded Fields 1. Item (4)--Title: Root cause is not included.
,
2. Item (12)--Position title is not included.
i
s
l
D-10
-_ -_
t
. .
T A8L E D-1.
SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Comments
9. LER Number: 85-050-01
Scores: lest . 6.0 Abstract 8.2 Coded Fields - 8.5 Overall 8.1
Test 1. 50.73(b)(2)(11 )(C )--Da t e inf ormat ion f or maj or
occurrences is inadequate. When was the "recent loss
of water column in the hotwell level transmitter
reference leg"?
2. 50.73(b)(2)(ii)(0)--The root and/or intermediate
cause discussion concerning the defective relay base
is inadequate. Given that the corrective action
pertaining to the 10 CFR 21 concerns in 1963 was to
" replace defective bases", it is not clear why. the
relay base f ailed.
3. 50.73(b)(2)(ii)(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.
4. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel
error 's inadequate.
.
50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether
the personnel error was cognitive or procedural is
not included.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of
personnel invcived (i.e., contrac tor personnel,
utility licensed operator, utility nonlicensed
operator, other utility personnel) is not included.
5. 50.73(b)(3)--Discussion of the assessment of the
safety consequences and im;lications of the event is
inadequate. Is a 50 second delay in HPCS injection
significant, had HPCS actually been required? Could
this delay have been even longer under a different
operator stress level?
The minimum reactor water level discussed (i.e.,
72.5 inches below instrument zero) is somewhat plant
specific. The significance of such a level should be
explained in more general terms (e.g., "The level of
72.5 inches below instrument zero was not significant
because it is xx inches above the top of the active
fuel.')
.
0-11
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TA8tE 0-1. SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416) !
Section Comments
l
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9. LER Number: 85-050-01 (continued) t
6. 50.73(b)(4)--Discussior. of corrective a:ticr.s take-
or plannec is inaceauate. Was this specific failec
relay base replaced in 1983? What will the operator
use as level indication when manually restoring the
IP condenser hotwell level (as a result of the
revisions to 04-1-02-lH13-P680)?
7. 50.73(b){ S)--Inf ormation concerning previous similar
events is not included. If no previous similar
events are known. the text should so state.
8. Some ideas are not presented clearly (hard to
follow). What is the significance of the last
sentence in the second paragraph under Section D?
Abstract 1. 50.73(b)(1)--Summary of cause information is
inadequate. The abstract should stete explicitly
that a personnel error while manually controlling the
hotwell level resulted in the trip of all condensate
and feedwater pumps and a reactor scram.
2. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
corrective actions taken to prevent recurrence of the
occurrences described in the event should be
mentioned in the abstract.
3. Abstract does not adequately summarize the text.
Coded Fields 1. Ites (4)--Title: Root cause information is not
included. A better title might be ' Personnel Error
Wr.ile Manually Con:rciling Hotwell Level Resuits in
Reactor Scran - HPCS Injection Valve Fails tc Open
Automatically Due to Failed Relay Base'.
2. Ites (ll)--0BSERVATI0h: It appears it would have
been more appropriate to report this event under
paragraph (s) 50.73(a)(2)(iv) and 'Other" - Special
Report. One report, with both of these boxes
checked, would have been adequate to satisfy both the
requirements of the LER and the Special Report. A
revision was not necessary.
D-12
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TABLE 0-1. SPECIFIC LER COMENTS FOR GRAND GULF 1 (416)
Section Conynen t s
9. LER Number: 85-050-01 (continued)
3. Item (14)--The block checkec is incorsistert with
-
inf orir.a t ion in the tex t . A Suppleraental Report ir.ay
be appropriate to provide information concerning how
the reliability of the hotwell level instrumentation
was enht,nced.
D-13
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- _ . - _ - -
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TA8LE D-1. SPECIFIC LER COMMENTS FOR GRAND GULF 1 (416)
Section Comments
10. LER Number: 86-001-00
Scores: Text 8.3 Abstract = 9.3 Coded Fields 9.6 Overall , 8.7
lext 1. 50.73(b)(2)( ti)(D)--The cause discussior, f or the
f ailed recorder pen was not included.
2. 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.
3. 50.73(b)(2)(11)(L )--Identification (e.g.,
manuf acturer and model no.) of the f ailed
component (s) discussed in the text is not included.
The recorder should be identified.
4. 50.73(b)(2)(ii)(J)(2)--Discussion of the personrel
error is inadequate. The discussion should indicate
why the operator failed to raise the feedwater
pressure enough to overcome system pressure.
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
specifics (operators required to use all available
level instrumentation) of the instruction change
should be given.
Coded Field: 1. N c omr.en t .
D-14
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TABLE 0-1. SPECIFIC LER COMMENTS FOR GRAND SULF 1 (416)
Section Comments
11. LER Number: 86-003-00
Sec es: Text 8.5 Abstract - 7.8 Coded Fields 9.0 Overall = 8.3
Test 1. 50. 73( b)( 2 )(ii)(C )-- Appr oxima te t ime inf orma ticn f or
major occurrences is inadequate. Time at which open
breaker alarms actuated is missing.
2. 50.73(b)(2)(ii)(D)--The root and/or intermediate
cause discussion concerning the breakers 524G and
5248 is inadequate. State why these breakers were
open.
3. 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.
4. 50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate. A discussion of actions
required to correct the problem (e.g., return the
component or system to an operational state or
correct the personnel error) is not included or is
inadequate. Discuss whether any grid phase
differential still existed when the plant was
reconnected to the grid.
5. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should se state.
Abstract 1. 50.73(b)(1)--Summary of root cause is inadequate.
See text comment number 2.
2. 50. 73(t )(1 )--Summa y of correcta vc a:tiors taken or
plannec as a result of tne event is inaceavate. See
text comment number 4. ho mer.tior of supplement
expected.
Coced Fields 1. Item (4)--Title: Root cause is not included.
D-15
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TABLE D-1.
SPECIFIC LER COMMENTS FOR GRANO SULF 1 (416)
Section Comments
12. LER Number: 86-007-00
Scores: Test . 8.0 Abstract . 8., Coded Fields = 8.2 Overall = 8.2
Test 1. 50.73(t)(2)(11)(F )--The Energy Industry
identification System component function
identifier (s) and/or system name of each component or
systes referred to in the LER is not included.
2. 50.75(b)(2)(ii)(J)(2)--Discussion of the personnel
error is inadequate. The discussion of the personnel
errors should provide a few more details. It is not
clear to the reader how two people could both make
two mistakes. Is there a diagram of the terminal
locations of the relay in the procedure? Was the
lighting in the work location inadequate?
3. 50.73(b)(31--The fact that the SSW pump start was of
no (apparent) consequence should have been mentioned.
4. 50.73(b)(41--Discussion of corrective actions taken
or planned is inadequate. What was or will be done
to prevent other personnel from making this same
error?
5. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken o-
planned as a result of the event is inadequate. The
fact that the utility electrical technician was
counseled should have been mentioned. In addition,
see text comment number 4.
Code: Fleids 1. _Ites (41--Title: Cause and link inf orma t ion
(" Personnel Errors During Functional Test Caused - ')
is not included.
i
2. Item (12)--Position title is not included.
D-16
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TABLE D-1. SPECIFIC LER COMMENTS FOR GRADO GULF 1 (416)
Section Comments
13. LER Number: 86-013-01
Scores: Text 8.2 Abstract 8.9 Coded Fields - 9.2 Overall 8.5
Text 1. 50.73(c)(2)(11)(D)--The r oct and/or in ter me dia t e
cause discussion concerning the alarm failure is not
included.
2. 50.73(b)(2)(ii)(F1--The Encrgy Industry
Identification System component function
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
3. 50.73(b)(2)f11)(H)--A time estimate of the
unavailability of the failed train / system is not
included. How long had the chlorine monitor been
operating with insufficient ~ sample flow?
4. 50.73(b)(2)(11)(J)(21--Discussion of the personnel
error is inadequate. Was the technician following an
approved procedure when the SFAU actuation occurred
on April 217 Was the alarm repaired?
5. 50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate. Is any action needed to
prevent future accidental actuations of the SFAU (see
, text comment 3).
6. 50.73(b)(5)--Inf ormation concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
7. The use of the simiplified sketch was good.
Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
rerouting of the sample line should be mentioned.
2. The abstract contains greater than 1400 spaces. This
is a hard event to summarize in 1400 characters and
still discuss the important points, therefore,
references to such things as Technical Specification
numbers could be left out and more concise sentences
used.
Coded Fields 1. Ites (4)--The result is incomplete. The SFAU
actuation should also be mentioned.
D-17
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TABLE D-1. SPECIFIC LER COMMENTS FOR GRA89 GULF 1 (416)
Section Commen t s
14. LER Number: 86-019-00
Scores: Text 9.6 Atstract 8.1 Coded Fields - 8.0 Overall - 9.0
Text 1. SC.73(t)(?)( t i)(f 1--The Energy Inoustry
Identification System component function
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
Abstract 1. 50.73(bifl)--Summary of root cause is not includea.
Coded Fields 1. Itee (41--Title: Root cause and link are not
included.
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TABLE D-1.
SPECIFIC LER COMMENTS FOR GR$)B GULF 1 (416)
Section Comments
15. LER Number: 86-022 00
Scores: Text . 7.9 ADstract - 9.1 Coded fields - 9.5 Overall 8.4
lest 1. SC.73tc)(2)(11)( A)--01scussion of plant operating
conditions before the event is inadequate. The
operating conditions prior to the event date (i.e.,
March 29, 1986) should be provided. The real concern
involving operating conditions for this event is,
"was the plant in a condition that might require the
ADS?'
2. 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.
3. 50.73(b)(2)(ii)(I)--Discussion of the method of
discovery of the missed monthly surveillance is not
included.
4. 50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate. The improvements in the '
surveillance package checks (Section E) should be
listed.
5. 50.73(b)(5)--Information concerning previous similar
events is not included. If no previous similar
events are known, the text should so state.
6. If the "B" surveillance package was attached to this
task card, was the "A" surveillance package attached
to another task Lard?
Abstract 1. 50.73(b)(ll--Sumr.ary of corrective actions taken or
planned as a result of the event is inadequate. See
text connent number 4.
Coded fields 1. Ites (4)--The title could say " Technical
Specification Monthly ADS Surveillance Not Performed
Due to Personnel Error".
)
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D-19
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