ML20212G854

Forwards AEOD SALP 6 Input Re Lers.Assessment Indicates Improvement in Quality from 6.8 Rating Received During Last Assessment to Current 8.8 Rating.Assessment Period Covers Oct 1985 - Nov 1986

ML20212G854
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/09/1987
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8701210207
Download: ML20212G854 (54)

Text

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]Ah JAN 0 91987 Docket No. 50-295 Docket No. 50-304 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

The NRC's Office for Analysis and Evaluation of Operational Data (AE00) has recently completed an assessment of Zion 1 and 2 Licensee Event Reports (LERs) as part of the NRC's Systematic Assessment of Licensee Performance (SALP). The Zion LER assessment indicated a significant improvement in the quality of the reports with a current rating of 8.8 compared to the 6.8 received during the previous assessment and a current industry average of 8.1.

We are providing you a copy of AE0D's assessment prior to the issuance of the SALP 6 Board Report so that you are aware of its findings.

If you have any questions, please contact Mr. E. G. Greenman (312/790-5575).

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

Enclosure:

AE0D Assessment cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing G. J. Pliml, Station Manager ,.

Jan Norris, Project Manager, NRR DCS/RSB (RIDS)

Licensing Fee Management Branch

, Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division Mayor, City of Zion

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b AE00 SALP INPUT FOR ZION 1, 2 -

OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF October 1, 1985 to November 30, 1986 4

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Zion 1 and 2 during the October 1, 1985 to November 30, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic nethodology presented in NUREG-1022, Supplement No. 2. This is the second time that the Zion LERs have been evaluated using this methodology. The results of this evaluation indicate that the Zion LERs now have an overall average score of 8.8 out of a possible 10 points, compared to their previous overall average score of 6.8 and a currer.1 industry average of 8.1 (i.e., the current industry average is the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).

One weakness that still remains in the Zion LERs, in terms of safety significance, involves the requirement to provide the manufacturer and model number (or other appropriate identification) in the text for those component that fail. The failure to provide information concerning the identification of failed components prompts concern that others in the industry may not obtain information in a timely panner that might enable them to identify and correct generic problems prior to having a similar failure at their station.

A strong point for the Zion LERs is that information concerning the mode, mechanism, and effect of failed component was well written for the LERs that were evaluated.

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AEOD INPUT TO SALP REVIEW FOR ZION 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Zion 1 and 2 during the October 1, 1985'to November 30, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2. The sample consists of a total of 15 LERs (i.e., 9 LERs for Zion 1 and 6 for Zion 2). The Zion LERs were evaluated as one sample for this SALP period because it has been determined that their LERs are both written and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in the sample.

It was necessary to start the evaluation before the end of the SALP assessment period because the input was due such a short time after the end of the SALP period. Therefore, all of the LERs prepared during the SALP assessment period were not available for review.

Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields nmet the criteria of 10 CFR 50.73(b). In addition, each selected LER is compared to the guidance for preparation of LERs presented in NUREG-1022 and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the reports. The purpose of this evluation is to provide feedback to improve the quality of LERs. It is not intended to increase the requirements concerninng the

" content" of reports beyond the current requirements of 10 CFR 50.73(b).

Therefore, statements in this evaluation that su0 gest measures be taken are 1

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

However, the minimum requirements of the regulation most be met.

The evaluation process for each LER is divided into two parts. The first part of the evaluation consists of documenting comments specific to the cor. tent and presentation of each LER. The second part consists of determining a score (0-10 points) for the text, abstract, and coded fields i of each LER.

1 The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) thsy provide a basis for a count of general deficiencies for the overall sample of LERs that was reviewed. Likewise, the scores serve two purposes: (1) they serve to illustrate in numerical terms how the analysts perceived the-content of the infornetton that was presented, and (2) they provide a basis for determining an oserall score for each LER. The overall score for each LER is the result of canbining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score - overall LER score).

I The results of the LER quality evaluation are divided into two i

categories: (1) detailed infornation and (2) summary information. The 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 l text, abstract and coded fields ( Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER l scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.

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'1 Discussion of Results A discussion of the analysts' .onclusions concerning LER quality is ,

presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b) and the guidance presented in NUREG-1022 and its supplements.

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

Table 1 presents the average scores for the sample of LERs evaluated for the station. In order to place the scores provided in Table 1 in j perspective, the distribution of the overall average score for all units / stations that have been evaluated using the current methodology is provided on Figure 1. Additional scores are added to Figure 1 each month as other units / stations are evaluated. Table 2 and Appendix Table 8-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Zion's average score for the text of the LERs that were evaluated is 8.8 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 f

j text presentation. The percentage scores in the text summary section of

! Table 2 provide an indication of how well each text requirement was addressed by the station for the 15 LERs that were evaluated.

Discussion of Specific Deficiencies t

A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the station probably needs additional guidance concerning

these requirements. Scores of 75 or above, but less than 100, indicate 3

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TABLE 1.

SUMMARY

OF SCORES FOR ZION 1,2 Average Hiah Low Text 8.8 10.0 6.6 Abstract 8.9 10.0 7.5 Coded Fields 8.8 9.5 8.0 Overall 8.8 9.8 7.3

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

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Figure 1. Distribution of overall average LER scores 10 ....i.... ....,.... .... ....i....

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8.5 8.0 7.5 7.0 6.5 6.0 9.5 9.0 Overall average scores

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1 TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR ZION 1,2 TEXT Percentage 8

Reautrements f50.73(b)1 - Descriptions Scores ( 1 (2)(11)(A) - - Plant condition prior to event 90 (15)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(11)(C) - - Date(s) and approximate times 78 (15)

(2)(ii)(D) - - Root cause and intermediate cause(s) 89 (15)

(2)(ti)(E) - - Mode, mechanism, and effect 96 ( 6)

(2)(11)(F) - - EIIS Codes 47 (15)

(2)(11)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 75 ( 6)

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

(2)(11)(J)(1) - Operator actions affecting course 100 i 5)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 88 (11)

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

(2)(ii)(L) - - Manufacturer and model no. infornation 75 ( 8)

(3) ----- Assessment of safety consequences 93 (15)

(4) ----- Corrective actions 88 (15)

(5) ----- Previous similar event infornetion 70 (15)

(2)(i) - - - - Text presentation 88 (15)

ABSTRACT Percentage a

Reautrements ISO.73(b)(111 - Descriptions Scores ( l

' - Major occurrences (Immediate cause and effect 99 (15) information)

- Description of plant, system, component, and/or 88 ( 6) personnel responses

- Root cause information 88 (15)

- Corrective Action information 86 (15)

- Abstract presentation 84 (15)

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TABLE 2. (continued)

CODED FIELDS '

Percentage 8

Item Number (s) - Description Scores ( 1 1, 2, and 3 - Facility name (unit nr.), s docket no. and 100 (15) page number (s) 4 - - - - - - Title 64 (15) 5, 6, and 7 - Event date, LER No., and report date 97 (15)

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8 - - - - - - Other facilities involved 97 (15) 9 and 10 - - Operating mode and power level 97 (15) 11 - - - - - Reporting requirements 97 (15) 12 - - - - - Licensee contact information 99 (15) 13 - - - - - Coded component failure information 85 (15) 14 and 15 - - Supplemental report information 90 (10)

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.

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

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

The requirement to provide dates and approximate times for various occurrences, Requirement 50.73(b)(2)(ii)(C), received a marginal score of 78%. The analysts considered a date to be lacking in six of the LERs arad a time in five. Dates of discovery are very important as are the date (time) of repairs or the placing of equipment or systems back in service. The time the plant is finally placed in a safe and stable condition following a scrao and/or severe transient is also good information. If adequate dates and times are provided in the text of each LER another requirement, Requirement 50.73(b)(2)(11)(H), will probably be met. (Note that this latter requirement received a score of only 75%, as two of the six LER involving safety train unavailability lacked the necessary information to allow the total length of this unavailablity to be determined.)

Adequate information relevant to previous similar events, Requirement 50.73(b)(5), was missing to five of the LERs. This may not be 8

P a problem with future Zion LERs however, as the outline format that is now being used has a heading entitled " PREVIOUS OCCURRENCES".

The Energy Industry Identification System component function identifier and system name codes were not consistently provided in the text. Five LERs partially provided these codes, and three LERs failed to provide them at all. The EIIS codes are required to be provided for each system and component referred to in the LER, (Requirement 50.73(b)(2)(11)(F)].

Three very important requirements received scores of greater than 75%

but are mentioned here because of the number of LERs in which comments were made for these requirements. The text requirements concerning personnel error, corrective actions, and cause have scores of 68%, 88%, and 89%,

respectively; however, five of the eleven LERs involving personnel error lacked certain details in the text as did six discussions concerning corrective actions and four concerning cause. These discussions should be complete so that the reader is not left with any questions. See Appendix 0 for specific comments concerning the deficiencies concerning personnel error, cause, and corrective actions.

The primary concern in the area of the abstracts involves cause and corrective action information. Approximately one-third of the abstracts failed to provide information, which was presented in the text, concerning cause and corrective action. So long as adequate cause and corrective action information is presented in the text and this same information is then adequately summarized in the abstract, this area of concern will no longer exist.

The main deficiency in the area of coded fields involves the title, Item (4). Fifteen of the titles failed to adequately indicate root cause, three failed to include the result, and one failed to include the link between the cause and result. While the result is considered to be the most important part of the title, cause and link information (as suggested in NUREG-1022, Supplement No. 2) must be included to make a title complete. Example titles are presented in Appendix D for some of the LERs which were considered to have poor titles.

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t 9 Item 13 of the coded fields section was completed eleven times even though a component failure was not described in the text. Those fields under Item 13.only need be completed when a. actual component failure has taken place. Information concerning faulted components (i.e., components that could not perform their function through no fault of their own--for example, a valve that was positioned wrong during a lineup) need not be <

included in Item 13.

The final area of the coded field section that should be discussed is Item (14), Supplemental Report information. While 50.73(c) states that if the Commission requires the licensee to submit supplemental information beyond that required by 50.73(b), this request will be made in writing, the information that is required by 50.73(b) should be submitted in a supplemental report (without a written request) if it is not available at the time the LER is required to be submitted (i.e., within 30 days). For example, if the text mentions an "on-going study" or a "more extensive test will be performed as conditions permit", the results of such studies or tests would be reportable if they lead to new information or result in additional corsective actions. Without a commitment to provide a supplement report (when information required by 50.73(b) is not available, the analyst must consider the failure to commit to a supplement to be a deficiency.

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

It should be noted that this is the second time that the Zion LERs have been evaluated using this same methodology. The previous evaluation, which was reported in October of 1985, was performed on the unit, rather than the station, level; however, after averaging the individual units scores from the previous evaluation, a direct comparison of scores for both evaluations can be made, see Table 4. As can be seen, Zion LERs have improved significantly since the previous evaluation and are now well above 10

the current industry overall average of 8.1. (Note: The industry overall average is the result of averaging the latest overall average score for each unit / station that has been evaluated using this methodology.)

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR ZION 1 AND 2 LERs Areas Comments failed component identification Component identification information such as manufacturer and model number, must be included in the text for each component that fails.

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

Date/ time information Sufficient date and time information (Estimate of safety train should be included within the text unavailability) of each LER so as a time history of the najor occurrences discussed is clear. Inclusion of this information should ensure that the time a safety system was unavailable can be determined.

Previous similar events Information concerning similar events that occurred should be provided (if applicable) in every LER (e.g., LER number of such events).

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

Abstract The cause and corrective action i

information from the text should always be presented in the abstract section.

Coded fields ,

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

b. Failed component information Item 13 information need not be included for faulted components.

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TABLE 3. (continued)

Areas Comments

c. Supplemental information A supplemental report may be appropriate whenever all the required information is not reported in the original LER (e.g., due to an on-going study).

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e TA8LE 4. COMPARISON OF LER SCORES FROM PREVIOUS EVALUATIONS Report Date October-85 December-86 Text average 6.4a 8.8 Abstract average 7.2a 8.9 Coded fields average 8.0a 8.8 Overall average 6.8a 8.8

a. These average scores are the. result of weight averaging the October-85 scores for the two Zion units to produce a station average.

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-l REFERENCES

1. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2 U.S. Nuclear Regulatory Commission, September 1985.

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

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

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR ZION 1,2 l .

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TA8LE A-1. LER SAMPLE SELECTION FOR ZION 1, 2 (295, 304)

LER Number Uait Number LER Number Comments 1 1 85-037-01 2 1 85-045-00 ESF 3 1 85-046-00 1

4 1 86-003-00 5 1 86-008-01 6 1 86-012-00 SCRAM 7 1 86-022-00 ESF 8 1 86-025-00 9 1 86-030-00 10 2 85-026-01 11 2 85-028-00 12 2 86-010-01 13 2 86-011-00 SCRAM 14 2 86-013-00 15 2 86-016-00 SCRAM e

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.l APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR ZION 1,2

TABLE B-1. EVALUATION SCORES OF INDIVIOUAL LERs FOR ZION 1,2 (295, .'04)

LER Sample Number' 1 2 3 4 5 6 7 8 Text 6.6 8.3 8.3 8.4 8.7 8.9 9.3 10.0 Abstract 8.4 8.5 9.0 8.5 9.7 9.9 10.0 10.0 Coded 8.9 8.5 8.0 8.9 8.9 8.3 9.2 8.2 Fields Overall 7.3 8.4 8.5 8.5 9.0 9.1 9.5 9.8 LER Sample Number

• 9 10 11 12 13 14 15 Average

-Text 8.3 8.0 10.0 9.5 9.1 9.4 8.8 8.8 Abstract 7.5 9.1 8.2 7.6 8.8 9 . '7 8.9 8.9 Coded 8.9 8.7 9.3 8.6 8.3 9.2 9.5 8.8 Fields Overall 8.1 8.4 9.4 8.8 8.9 9.5 8.9 8.8

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

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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR ZION 1,2 r

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TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR ZION 1,2 (295, 304)

Number of LERs with '

Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )D 50.73(b)(2)(ti)(A)--Plant operating 1 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(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)(2)(ii)(C)--Failure to include 9 (15) sufficient date and/or time information,

a. Date information was insufficient. 6

b. Time information was insufficient. 5 50.73(b)(2)(ii)(D)--The root cause and/or 4 (15) intermediate failure, system failure, or personnel error was not included or was inadequate,

a. Cause of component failure was not 4 included or was inadequate

b. Cause of system failure was not 0 included or was inadequ;te

c. Cause of personnel error was not 0 included or was inadequate.

I 50.73(b)(2)(11)(E)--The failure mode, 1 ( 6) l 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 0 inadequate

b. 0 Mechanism (immediate cause) was not I

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

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-l TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of De'iciencies and Observations Totals Totals ( )

50.73(b)(2)(ii1[F1--The Energy Industry 10 (15)

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

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

50.73(b)(2)(11)(H)--For a failure that 2 ( 6) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

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

a. Method of discovery 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.

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-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 ( 5) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(b)(2)(11)(J)(21--The discussion of 5 (11) each personnel error was not included or was inadequate,

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

b. 50. 73 ( b ) ( 2 ) ( i i ) ( J ) ( 2 ) ( i )--D i s c u s s i on 2 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 l directly contributed to the personnel ,

error was not included or was inadequate.

e. 50.73(b)(2)(ii)(J)(2)(iv)--Discassion 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.

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-l TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b 50.73(b)(2)(11)(K)--Automatic and/or manual 2 ( 9) safety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 2 ( 8) model number of each failed component was not included or was inadequate.

50.73(b)(31--An assessment of the safety 4 (15) consequences and implications of the event was not included or was inadequate.

a. 083ERVATION: The availability of 1 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 i severe conditions, the text should so state. [

50.73(b)(4)--A discussion of any corrective 6 (15) actions planned as a result of the event

! including those to reduce the, probability of similar events occurring in the future was not included or was inadequate.

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l TABLE C-1. (continued) l Number of LERs with Deficiencies and j Observations <

Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

• Totals ( )

a. A discussion of actions required to 2 correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.

b. A discussion of actions required to 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 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 5 (15) similar events was not included or was inadequate.

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TABLE C-1. (continued)

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

50.73(b)(2)(il--Text presentation 3 (15) inadequacies.

a. OBSERVATION: A diagram would have 0 aided in understanding the text discussion,

b. Text contained undefined acronyms 3 and/or plant specific designators.

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

i a. The "sub-paragraph total" is a tabulation of specific deficiencies or -

i observations within certain requirements. Since an LER can have more than 4

one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time infornetion), 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.

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-l TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR ZION 1,2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals __

Totals ( )

A summary of occurrences (immediate cause 1 (15) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 3 ( 6) responses was not included or was inadequate.

a. Summary of plant responses was not 0 included or was inadequate.

b. Summary of system responses was not 1 included or was inadequate.

c. Summary of personnel responses was not 3 included or was inadequate.

A summary of the root cause of the event 5 (15) was not included or was inadequate.

A summary of the corrective actions taken er 7 (15) planned as a result of the event was not included or was inadequate.

C-7

-l TABLE C-2. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of' Deficiencies and Observations Totals Totals ( )D Abstract presentation inadequacies 3 (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 0 1400 characters

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

d. The abstract contains other specific 3 deficiencies (i.e., poor j

summarization, contradictions, etc.)

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

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

l C-8 i

i

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o

-l TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR ZION 1,2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )

Facility Name 0 (15)

a. Unit number was not included or incorrect,

b. Name was not included or was incorrect.

c. Additional unit numbers were included but not required.

Docket Number was not included or was 0 (15) incorrect.

Page Number was not included or was 0 (15) incorrect.

Title was left blank or was inadequate 15 (15)

a. Root cause was not given in title 15

b. Result (effect) was not given in title 3

c. Link was not given in title 1 Event Date 1 (15)

a. Date not included or was incorrect. 1

b. Discovery date given instead of event 0 date.

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

Report Date l'(15)

a. Date not included 1

b. OBSERVATION: Report date was not 0 within thirty days of event date (or discovery date if appropriate).

Other Facilities information in field is 2 (15) inconsistent with text and/or abstract.

Operating Mode was not included or was 1 (15) inconsistent with text or abstract.

C-9

TABLE C-3. (continued) 4 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

Power level was not included or was 0 (15) inconsistent with text or abstract Reporting Requirements 2 (15)

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

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

c. OBSERVATION: It may have been 2 appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 1 (15)

a. Field left blank 0

b. Position title was not included 1

c. Name was not included 0

d. Phone number was not included. O Coded Component Failure Information 11 (15)

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

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

c. Component failure field contains data 11 when no component failure occurred.

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

C-10

TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )

Supplemental Report 2 (15)

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

b. The block checked was inconsistent 2 with the text.

Expected submission date information is 0 (15) inconsistent with the block checked in Item (14).

~

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

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

I l

l C-11

n .

l APPENDIX D LER COMMENT SHEETS FOR ZION 1,2 l

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

1. LER Number: 85-037-01 Scores: Text - 6.6 Abstract - 8.4 Coded Fields - 8.9 Overall - 7.3 I

Text 1. 50.73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. When was the isolation valve closed and when were the corrective actions completed?

3. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the event is inadequate.

First, a discussion of why the detector tube failed was not included. Second, even though the cause of the valve failure couldn't be found, it would be helpful to list all actions taken to try to determine the cause.

4. 50.73(b)(2)(ii)(F)--The Energy Indus<,ry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included.

5. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included (see text comment 2).

6. 50.73(b)(2)(ii)(J)(2)(1)--Discussion as to whether the personnel error was cognitive or procedural is inadequate. Were the operators correctly following a procedure when the check source was broken from its I cable? ,

7. 50.73(b)(2)(ti)(L)--Identification (e.g.,

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

1 l

l D-1

.. s TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

1. LER Number: 85-037-01 (continued)

8. 50.73(b1[31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Since the isolation valve failed, the possibility existed for a discharge of excessive radioactive material. Tte safety assessment should discuss the consequences if the failure had occurred under more severe conditions and should discuss any backup systems which could help prevent excessive release.

9. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Will anything be done to prevent loosing the check source in the future (see text comment 6)? Without knowing the root cause of the detector tube failure, it is not clear whether or not replacement of the tube is adequate.

10. Acronym (s) and/or plant specific designator (s) are undefined. It is not clear if "0A" and "0B" are train designations or acronyms.

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

The fact that the check source was broken off should also be mentioned.

2. 50.73(b)(1)--Sunerary of corrective actions taken or .

planned as a result of the event is inadequate. The replacement of the detector tube should be mentioned.

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

appropriate title might be " Failure of Discharge Tank Isolation Valve To Close (Cause Unknown) On false High Radiation Alarm Due To A failed Detector". The title is long but there is room for two type written lines on the standard NRC form.

2. Item (13)--The line for the detector is appropriate, but since no failure in the valve could be found this line could be left out.

D-2

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1-(295)

Section Comments

2. LER Number: 85-045-00 Scores: Text - 8.3 Abstract - 8.5 Coded Fields - 8.5 Overall - 8.4 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the bypass valve adjustment is inadequate. Why was the valve out of adjustment?

2. 50.73(b)(41--Discussion of corrective actions taken i

,p or planned is inadequate. Discussion of steps taken I

to prevent recurrence of the bypass valve paladjustment are not included. A supplemental report appears to be needed to describe the instrument air maintenance program.

Abstract 1. 50.73(b)(1)--Summary of root cause information is inadequate. See text comment number 1. 1

2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.

Coded Fields 1. Item (41--Title: Root cause (condensate trap bypass valve maladjustment) is not included.

2. Item (141--A supplemental report might be warranted to discuss the results of the maintenance program to prevent recurrence of intercooler condensation.

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D-3 l

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

3. LER Number: 85-046-00 Scores: Text = 8.3 Abstract - 9.0 Coded Fields - 8.0 Overall = 8.5 Text 1. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time were the results of the boron sample available?

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

3. 50.73(b)(2)(11)(L)--Identification (e.g.,

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

4. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Under what conditions is a boron concentration of 550 ppm sufficient to provide a 1%

shutdown nergin?

5. 50.73(b)f5)--Information concerning previous similar events is inadequate.

6. It appears that the first sentence of the text should indicate that the unit tripped while in "Startup".

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective actions concerning the new cables and connectors should also be mentioned in the abstract.

2. The abstract appears to contradict the text. (First sentence of the third paragraph in the abstract.)

Coded Fields 1. Item (4)--Title: Root cause and result information are not includea. A better title might be

" Preamp 11fier Problems Cause Both Source Range Channels To Fail Following Reactor Trip--Emergency Beration Initiated".

2. Item (5)--The event date appears to be incorrect; text and abstract say 12-06-85.

I 0-4

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Coments

3. LER Number: 85-046-00(continueb)

3. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(iv) (Due to the manual initiation of the Emergency Boron System).

9 O

D-5

TA8LE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

4. LER Number: 86-003-00 Scores: Text = 8.4 Abstract = 8.5 Coded Fields - 8.9 Overall = 8.5 Text 1. 50.73(b)(2)(11)(C)--The discovery date (assumed to be 2/14/86) should be given in the text.

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

3. 50.73(b)(2)(ii)(J)(2)(iv)--Disc'ussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

It would be helpful to indicate the type of personnel who were' responsible for the oversight and the type who caught the oversight.

4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included. A particular concern that needs to be addressed is whether or not the PORV is a safety related valve. In either case justification should be provided as to why the PORV can be isolated (e.g.,

sufficient relief capacity is provided by other relief valves).

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.

Upgrading of the entire IST program should be mentioned.

Coded Fields 1. Item (41--Title: Root cause is not included.

2. Item (8)--Neither the text nor the abstract indicate how Unit 2 was involved.

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

'4 D-6

_,e l TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

P>ection Comments

5. LER Number: 86-008-01 Scores: Text - Abstract - Coded Fields - Overall =

Text 1. 50.13(b)(2)(ii)(C)--Approximate time information for sajor cccurrences is not included.

2. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

3. Acronym (s) and/or plant specific designator (s) are undefined; "pcm" should be defined.

4. Some ideas are not presented clearly (hard to follow). The ti.ird paragraph discussion of the rod drop accident is not clear.

5. Vertical bars in the margin would be helpful to delineate the text revisions.

Abstract 1. No comments.

Coded Fields 1. Item (4)--Title: Root cause (personnel error of calibration) is not included. Acronyms should not be used in the title except when space is limited.

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

D-7

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TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

6. LER Number: 86-012-00 Scores: Text = 8.9 Abstract - 9.9 Coded Fields - 8.3 Overall = 9.1 i

Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component code for breaker was not provided.

2. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. It is not' apparent from the l

discussion whether or not breaker installation is i done using a procedure.

3. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. .Those

" safety systems" that performed correctly (as a result of the scram) should be named.

4. 50.73(b)(2)(ti)(L)--0BSERVATION: Although the breaker did not fail, it is good to provide information in the text concerning the breaker as it (and its latching design) contributed to the event.

Section D indicates that

5. 50.73(b)(31--08SERVATION:

the cell switch experienced a failure when in fact a personnel error (procedural deficiency) caused the problem that resulted in the trip.

6. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was the right side latch marked (painted) so as to be more visible?

Abstract 1. No comments, f

Coded Fields 1. Item (4)--Title: Root cause and link are not included. A bet +tr title would be " Operator Failed To Completely Rack In And Latch A Reactor Trip Breaker Thus Resulting In A Reactor Trip From Power During A Breaker Performance Test".

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

1 D-8

l 1

1 TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

6. LER Number: 86-012-00 (continued)

I

3. Item (131--Component failure field contains data when i no component failure occurred. Faulted components need not be included in this field.

l l

D-9 l . _. . - __-. . - . _ , _ _ . __ _ - _ _ . - - _ _ _ _ _ _ . - _ _ . - _ _ _ _ _

• E*

a .'

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section __, Comments

7. LER Number: 86-022-00 Scores: Text - 9.3 Abstract - 10.0 Coded Fields - 9.2 Overall - 9.5 Text 1. 50.73(b)(2)(ii)(C)--Date/ time information for major occurrences is inadequate. The inclusion of times during various stages of the event and the expected completion date of the procedural changes would be helpful.

2. 50.73(b)(2)(11)(F1--The Energy Industry Identification System identifier for a pump was not included.

3, 50.73(b)(5)--Information concerning previous similar events is not included. If ro previous similar events are known, the text should so state.

Abstract 1. No comment.

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

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

0 ii D-10

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TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

8. LER Number: 86-025-00 Scores: Text - 10.0 Abstract - 10.0 Coded Fields - 8.2 Overall - 9.8 Text 1. The text is very well outlined and clearly presented.

Abstract 1. No comments.

Coded Fields 1. Item (41--Title: Root cause (personnes error-calibration procedure) is not included.

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

3. Item (13)--Component failure field contains data when no component failure occurred. From information presented in the text, the transmitter discrepancies appear to result from a calibration procedure error, not from a component failure.

O I

D-11

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TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

9. LER Number: 86-030-00 ,

Scores: Text - 8.3 Abstract - 7.5 Coded Fields = 8.9 Overall = 8.1 Text 1. 50.73(b)(2)(ii)(C)--Date information for major occurrences is inadequate. The date of discovery, the date of BTP-9.5-1 Appendix A, and the approximate date of completion of long term corrective actions should be included in the text.

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

50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is inadequate.

Who (by title or organization) failed to identify the presence of the non-fire retardant material as a problem (when the walls were classified as fire barriers per BTP 9.5-1 Appendix A)?

3. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Credit should be taken in Section D for the fact that a continuous fire watch was set. It appears that this section should also state that this fire watch w'11 be maintained until such time as the prob 1cm is corrected (i.e. the completion of the long term corrective actions).

What are the implications of " removing a portion of the non-fire retardant material"? Is it to be replaced with something else; if not, how will this affect the HVAC considerations?

4. 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. The corrective action concerning the " stationing of continuous fire watches" is listed as a "short term" action. Aren't fire watches necessary until the completion of the long term actions? See text comment number 3.

Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. The fact that the problem was not identified when BTP 9.5-1 Appendix A was implemented should have been mentioned.

l D-12

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• s{.

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 1 (295)

Section Comments

9. LER Number: 86-030-00 (continued)

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 4.

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.

Coded Fields 1. Item (4)--Title: Root cause and result are not included. A better title might be " Inadequate Design Review Results In Non-Fire Retardant Material Being Used As A Fire Barrier--Technical Specification Violation".

2. Item (81--Text should be more specific as to how Unit 2 is directly involved in this event.

3. Item (13)--Component failure field contains data when no component failure occurred. As stated in Section G, "there were no failed components".

Faulted components need not be listed in Item (13).

1 f 0-13

gr / #

~:

TAELE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304) l Section Comments l

10. LER Number: 85-026-01 Scores: Text - 8.0 Abstract = 9.1 Coded Fields - 8.7 Overall = 8.4 Text 1, 50.73(b)(2)(ii)(C)--Date information for major occurrences is inadequate. The text should include dates for all major occurrences such as the completion of the repairs.

2. 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the improperly installed check valves is not included. Further discussion also appears to be needed to describe where the standing water in the two RCF's came from if condensation was not considered the source.

4. 50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed train / system is inadequate (see text comment 1).

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. The standing water in two of the RCFS's hot' sings should be mentioned.

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

2. Iten (71--Report date is not included.

3. Item (13)--The valves, although they would not

! perform their intended function, did not fail, so this line did not need to be filled in. In addition, l

the component and NPRDS reportability codes are not i valid codes.

t i

D-14

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• TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304)

Section Comments

11. LER Number: 85-028-00 Scores: Text = 10.0 ' Abstract = 8.2 Coded Fields - 9.3 Overall = 9.4 Text 1. The text is very well outlined and clearly presented. Drawings are useful in that they can help the reader better understand the event.

Abstract 1. 50.73(b)(1)--Summary of personnel and safety system responses is inadequate. A discussion of how decay heat removal was lost is not included.

2. 50.73(b)(1)--Summary of the problems with the level indication is inadequate.

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

[

i D-15 1

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TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304)

Section Comments

12. LER Number: 86-010-01 Scores: Text - 9.5 Abstract - 7.6 Coded Fields - 8.6 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(El--The effect discussion of each failed component is inadequate. The text should state that the Technical Specifications do not permit two to be inoperable at the same time (although, from the information in Section D, they apparently were not, when all the facts were known).

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

Abstract 1. See text comment number 1.

2. The annunciator problem should be mentioned in the abstract as well as how (personnel observation) it was noticed.

3. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective action concerning the valve handles should have been mentioned in the abstract.

l 4. Abstract does not adequately summarize the text.

l Additional space is available within the abstract i

~

field to provide the necessary information but it was not utilized.

Coded Fielos 1. Item (4:--Title: Root cause and link information are not included. A better title might be " Testing a Partially Closed Fuel Valve and a Defective Relay Result In Concurrent Inoperability of Diesel i Generators 0 and 2A, Respectively".

1

2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).

3. Item (13)--Component failure field contains data when no component failure occurred. The information for

' the valve need not have been provided as this was not a valve failure.

l D-16 1

- - - - - , , , - ,,n..--..n..c.-,,,-n.n_ n. ._,,,,,.,,,--n,-,- , - , - , , _ , , . .------._-, -, __ , , , ,, ,- --,------,-,m-,

r dI ',

~ #; .

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304)

Section Comments

13. LER Number: 86-011-00 Scores: Text - 9.1 Abstract - 8.8 Coded Fields - E.3 Overall - 8.9 Text 1. 50.73(b)(2)(ii)(C)--The text should include additional dates / times for najor occurrences, such as when the reactor was brought to a safe and stable condition and when repairs were completed.

2. 50.73(b)(2)(ti)(D)--The root and/or intermediate cause discussion concerning the control switch failure -is inadequate. The discussion should indicate why the contacts would not stay riosed.

3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System identifiers for each component referred to in the text were not included.

4. 50.73(b)(4)--A supplemental report appears to be -

needed to describe the results of the investigation into the source of the noise which caused the NFRT trip. Without knowing the cause of the failure, it cannot be determined whether or not the replacement switch will also fail.

5. Acronym (s) and/or plant specific designator (s) are undefined. NSO and "SC" should be defined.

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

The failure of the control switch should be mentioned.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The replacement of the control switch should be mentioned.

Coded Fields 1. Item (4)--Title: The root cause of the bus transfer failure is not included.

2. Item (131--The first line is not needed. The line for the control switch is appropriate, but it is not clear from the text if the component code "HS" (hand switch) is correct.

3. Item (14)--The block checked is inconsistent with information in the text (see text comment 4).

i D-17

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u TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304)

Section Comments

14. LER Number: 86-013-00 Scores: Text - 9.4 Abstract - 9.7 Coded Fields - 9.2 Overall - 9.5 Text 1. 50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included.

Abstract 1. No comment.

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

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

D-18

.k a

TABLE D-1. SPECIFIC LER COMMENTS FOR ZION 2 (304)

Stction Comments

15. LER Number: 86-016-00 Scores: Text - 8.8 Abstract - 8.9 Coded Fields - 9.5 Overall - 8.9 Text 1. 50.73(b)(2)(ii)(C)--Date/ time information for major occurrences is inadequate. When was the unit brought to cold shutdown?

2. f0.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name code of each component or system referred to in the LER is not included. Component codes are not providad.

3. 50.73(b)(2)(11)(.1)(2)--It appears that personnel error is involved in this event, but it is not discussed. It appears that had a walkdown of the lightning protection modifications been conducted at the completion of the modifications, the new modifications (and interim measures) could have been implemented earlier, thus possibly preventing this event. Is such a walkdown now required upon completion of modifications?

4. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is not included. Any safety system that actuated automatically (or was manually initiated) as a result of this event should be named.

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Are the two "new" modifications actually new or are they the ones not completed during M22-1 and 2-83-21?

Abstract 1. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The interim measures (i.e., the temporary jumpers) should have been mentioned in the abstract.

Coded Fields 1. Item (41--Title: Additional cause infornation is not included. The fact that deficiencies in the lightning protection system contributed to this event should have been included in the title.

D-19