ML20212N903
| ML20212N903 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/02/1987 |
| From: | Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20212N876 | List: |
| References | |
| 50-271-87-02, 50-271-87-2, IEB-83-07, IEB-83-08, IEB-83-7, IEB-83-8, IEIN-86-106, NUDOCS 8703130199 | |
| Download: ML20212N903 (70) | |
See also: IR 05000271/1987002
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
87-02
Docket No.
50-271
License No. DPR-28
Licensee:
Vermont Yankee Nuclear Power Corporation
RD 5, Box 169, Ferry Road
Brattleboro, Vermont 05301
Facility:
Vermont Yankee Nuclear Power Station
Location:
Vernon, Vermont
Dates:
January 5 - February 2,198
Inspector:
William J
aymond Se 'or Resident Inspector
Approved by:
/
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' Thomas C. Elsasser, 04Wpf, Reactor Projects 3C
Dat'e
Inspection Summary: Inspection 'on JWuary 5
February 2,1987 (Report No.
50-271/87-02)
Areas Inspected:
Routine, unannounced inspection on day time and backshifts by
the resident inspector of: actions on previous inspection findings; physical
security; plant operations; licensee actions in response to IE Bulletins 83-08 and
83-07, and Information Notice 86-106; control rod surveillance testing; maintenance
activities; licensee event reports; plant procedure review status; and, station
battery room temperatures.
The inspection involved 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br />.
Results:
No violations were identified in the nine areas inspected.
Routine re-
views of plant activities identified no conditions adverse to safe plant operations.
Licensee plans to complete feedwater nozzle examinations during the 1987 refueling
outage require further review and approval by the NRC staff (paragraph 5.1).
Lic-
ensee plans to defer core spray nozzle replacenent require further review and
approval by the NRC staff (paragraph 13.0).
The control and surveillance o' bat-
tery room environment requires further licensee and NRC review (paragraph 14.0).
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DETAILS
1.
Persons Contacted
Interviews and discussions were conducted with members of the licensee staff
and management during the report period to obtain information pertinent to
the areas inspected.
Inspection findings were discussed periodically with
the management and supervisory personnel listed below.
Mr. D. LaBarge, Senior Operations Engineer
Mr. D. Taylor, Senior Maintenance Engineer
Mr. D. Legere, Senior Maintenance Engineer
Mr. J. Pelletier, Plant Manager
Mr. G. Johnson, Operations Supervisor
Mr. J. Sinclair,-Security Supervisor
Mr. R. Wanczyk, Technical Services Superintendent
Messrs. R. Bernero, V. Rooney, W. Raymond and Commissioner James Asselstine
attended a meeting of the Vermont State Nuclear Advisory Panel (VSNAP) on
January 21, 1987 in Montpelier, Vermont to discuss general topics involving
nuclear safety issues, NRC and state relations, the status of the reviews of
the Mark I Containment Safety Study completed by the licensee, and the issue
of containment venting. The plans to address containment safety issues with
other Mark I users was also discussed.
The issue of containment venting will
be addressed further in a future meeting of the VSNAP in the Brattleboro,
Vermont area.
2.
Summary of Facility Activities
The plant continued routine operations at rated power during the report period.
A Region I specialist inspector completed an inspection of the radioactive
waste packaging, classification and shipping programs during the period of
January 12-16, 1987 (Inspection Report 87-01).
3.
Status of Previous Inspection Findings
3.1 (0 pen) Unresolved Item 85-40-09: RHR Pump Inspection Schedule. Continued
vendor problems in producing acceptable replacement impellers for the
residual heat removal (RHR) pumps caused the licensee to halt production
of the components.
Licensee and Bingham management met on January 5,
1987 in Portland, Oregon to review the manufacturing process, the cause
for the problems that resulted in eight unacceptable impellers, and the
additional actions that would be taken by the vendor to assure delivery
of acceptable components. The earliest shipping date for four new im-
pellers was February 13, 1987, and, based on this schedule, the licensee
planned to begin the six week RHR pump inspection and refurbishment pro-
gram on February 23, 1987.
The resident inspector will continue to fol-
low the licensee's plans and actions.
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3.2 (0 pen) Unresolved Item 86-10-12: SLC Technical Specifications. By letter
FVY 87-10 dated January 16, 1987, the licensee proposed changes to Tech-
nical Specification 4.4.A (Proposed Change No. 136) that would better
reflect the revised and upgraded standby liquid control (SLC) system
functional test requirements now contained in Revision 8 of CP 4203.
The enhanced specifications now explicitly require insitu functional
testing of a trigger assembly taken from the same manufacturing batch
as those to be used for the subsequent operating cycle. The inspector
noted that the specifications were enhanced by requiring that the SLC
tank sodium penetaborate concentration be verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
make-up to the tank.
No inadequacies were identified.
As dscussed in Inspection 86-10 (Appendix I,Section V), this item re-
mains open pending further quality assurance review of the squib valve
vendor to assure programmatic issues are resolved, and subsequent review
by the NRC.
3.3 (Closed) Follow Item 85-30-03: LER on Spurious Group III Isolations.
LER 85-11 dated November 6,1985 and LER 85-11, Revision 1 dated June
11, 1986, were submitted following spurious Group III isolatior.s that
occurred on October 8, 1985, October 12, 1985 and October 20, 1985. The
inspector reviewed the LERs and noted that they accurately described the
circumstances of the events. The presently installed equipment has
functioned properly since October 20, 1985. The inspector had no further
questions. This item is closed.
3.4 (Closed) Violation 86-08-06: Installation of Defective NAMC0 Contact
Blocks.
Licensee corrective actions for this item were also reviewed
during Inspection 86-10, and were discussed at a management meeting in
NRC Region I on July 29, 1986. The licensee responded to this item by
letter FVY 86-72 dated August 12, 1986, to describe the following cor-
rective actions that addressed the identified programmatic deficiencies.
(1) Detailed inspection criteria were received from NAMCO and were used
for onsite receipt inspection of subsequent orders. The licensee will
apply 100% receipt inspection for NAMCO orders until confidence is ob-
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tained that apparent programmatic deficiencies are resolved. (ii) Visits
were made to the vendor's facilities to perform pre-shipment inspections
of materials, review the manufacturing process, and to complete an
evaluation of materials with defects of the type found at Vermont Yankee.
The vendor planned to make changes to the manufacturing process, includ-
ing the method of attaching the contact assembly to the block.
The licensee concluded that defects found by the inspector in the out-
board main steam isolation valves were caused during installation of the
blocks following the licensee's re-inspection of the switches during the
nonconformance report (NCR) process. The licensee stated that contact
carriers had not been inspected as part of the NCR process since they
did not contain arc suppression barriers and were not considered similar
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parts. The licensee stated that the corrective actions in progress per
the NCR and Part 21 report process during the NRC inspection would have
resulted in appropriate resolution of the matter.
During a discussion with the instrument and controls supervisor on
January 28, 1987, the inspector noted that he was responsible for assur-
ing that the 100% receipt inspection criteria be applied to future NAMC0
orders, but that no formal mechanism had been established to accomplish
the requirement. The licensee stated that a written notice would be
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issued to identify the need to perform 100% inspections until such time
as deemed unnecessary.
The inspector had no further comments on the licensee's response at this
time and the licensee's corrective actions are considered complete. The
licensee's corrective actions process will be reviewed during subsequent
routine NRC inspections.
3.5 (Closed) Unresolved Iten 86-08-05: NAMC0 QC and Final Packaging Controls.
This item was also reviewed during Inspection 86-10. Additional licensee
artions on the item in conjunction with the vendor are discussed in
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paragraph 3.4 above. The licensee's submittal of a Part 21 report on
the defective NAMC0 contact blocks provided notification to the NRC of
the potential generic applicability of this item to other users of the
materials.
The NRC's Vendor Program Branch performed an inspection at
the vendor's facilities in July, 1986 (Report 378/86-01) to review the
equipment qualification process, the QA controls applied by the vendor,
and the vendor followup actions in response to the Part 21 report sub-
mitted by the licensee. The vendor determined that the bakelite mate-
rials in the contact blocks were susceptible to damage from thermal shock,
such as could occur when a package of replacement parts were shipped via
airfreight and subjected to the cold temperatures of upper atmospheric
flight. The Vendor Program Branch will follow additional NAMCO actions
relative to shipping practices and customer notifications of potential
product damage.
This item is closed.
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3.6 (Closed) Unresolved Item 86-10-09: Status of Materials Procured Under
Purchase Orders 1630 and 1631. The licensee completed actions to verify
that all unacceptable materials were sent back to the vendor, and to
verify that materials remaining at the site were acceptable. The ac-
ceptability of remaining materials was demonstrated by acceptable second
receipt inspections of materials returned or issued, and spot checks of
stock items. The results of the review were provided in a memorandum
to the plant services manager dated October 20, 1986, along with attached
receipt inspection checklists. This item is closed.
3.7 (Closed) Unresolved Item 85-40-02: Drywell Epoxy Coating. The licensee
completed actions during the outage to inspect the drywell epoxy coating
and remove the sections of epoxy from those locations where the coating
was peeling away (reference MR 86-0818). The licenseo verified that the
underlying primer was acceptable and capable of providing corrosion pro-
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tection for the drywell skin.
Plans were established to evaluate the
failure mechanism for the epoxy coat, to complete periodic inspections
_of the primer, and to repair it as.necessary during subsequent outages
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to assure corrosion protection of the containment shell is maintained.
No inadequacies were identified. Inis item is closed.
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4.0 .0bservations'of Physical Security
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S_ elected ~ aspects of plant physical security were reviewed during regular and
backshift hours to verify that controls were in accordance with the security
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plan and approved-procedures. This review included the following security '
measures: guard staffing; verification of physical barrier integrity'in the
protected and vital areas; verification that isolation zones were maintained;
and implementation of access controls, including identification, authorization,
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badging, escorting, personnel and vehicle' searches.
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4.1~ Security Events
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On December 30,'1986, a moderate loss of physical -security effectiveness
occurred-due to a hardware failure within the security computer console.
The event was reported via the Emergency Notification System at 5:30 p.m.
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on December 30, 1986, and a written report dated January 6,1987, was
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submitted as Physical Security Event Report 86-07. The inspector re-
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viewed the circumstances involved in .the event, the compensatory actions -
taken,-the corrective actions to prevent recurrence of the hardware-
failure, and the physical security event report.
No-inadequacies were
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identified.
4.2 -On February 3, 1987, the inspector as notified at 3:30 p.m. by the
Vermont State nuclear engineer of a matter having security significance.
The State of Vermont received a letter on January 21, 1987 containing
allegations relating to security at the Vermont Yankee plant. The in-
spector obtained information regarding the substance of the allegation,
and relayed that information to NRC Region I management and appropriate
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security personnel at the plant at 4:00 p.m.
Augmented security measures
were implemented at the plant commensurate with the allegations, as pre-
sented during a meeting with plant management at 6:40 p.m. on February
3, 1987, and summarized in a memorandum from J. Sinclair to File 6.0/VYSD
87-04 dated February 4, 1987. The inspector reviewed implementation of
the augmented security measures. This matter was referred to the Federal
Bureau of Investigation, for appropriate investigative action by that
agency in'accordance with Section 236 of the Energy Reorganization Act
of 1974. No inadequacies were identified.
5.0 Inspection Tours and Operational Status Reviews
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Plant tours were conducted routinely to review activities in pregress and to
verify compliance with regulatory and administrative requirements. Tours of
accessible plant areas included the control room, reactor building, cable
spreading and switch gear rooms, diesel rooms, turbine building, and grounds
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within the protected area.
Radiation controls were reviewed to verify access
control barriers, postings, and posted radiation levels were appropriate.
Plant housekeeping conditions were verified to be in accordance with the re-
quirements of AP 0042. Shift logs and records were reviewed to determine the
status of plant conditions and changes in operational status.
Items that
received further review are discussed below.
5.1 Reactor Building Ventilation Logic Status
During a review of control room panels at 8:30 a.m. on January 7, 1987,
the inspector noted that the reactor building ventilation system bypass
lamp was lit on panel CRP 9-15.
This indicated that the primary contain-
ment isolation system (PCIS) trip inputs from the Al channel of the re-
fuel floor zone and/or reactor building ventilation radiation monitors
were in a bypassed condition. The inspector noted that the logic bypass
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switch, SW-A, which controls the bypass lamp, was in the OFF position.
The switch is normally used only during logic system surveillances and
there was no testing in progress at the time (testing per OP 4326 was-
last performed during the week of December 29,1986).
The inspector informed the shift supervisor of the item and actions were
taken immediately to investigate the status of the bypass switch contacts
and the PCIS actuation channels. The operators verified that no other
indication existed that a bypass was in effect by verifying that the
keylcck switch was in the OFF position and no annunciators were in effect
on panel CRP 9-5.
The bypass indication cleared at 8:45 a.m. after the
operator cycled the switch from 0FF to its other two operating positions.
Instrument & Control (I&C) personnel completed additional investigations
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of the status of the logic circuit per MR 87-025.
This review confirmed
by 11:25 a.m., based on SW-A contact resistance measurements, that actu-
ation contacts in the K23 and K24 logic channels were not in a bypassed
state.
The SW-A keylock switch has three positions (K50A/0FF/K49A) and was found
in the OFF position. The switch is a compound device using six GE Type
CR2940 control switches stacked and/or ganged together to provide twelve
sets of contacts, eight of which are used for the PCIS bypass function
as follows: two contacts for the bypass indication lamp; two for the CRP
9-5 annunciator circuit; and four contacts used in the logic train for
actuation relays K23 and K24 (two each).
For the bypass lamp to have
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been illuminated, either contacts 17/18 or 23/24 on the stack had to be
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closed with the switch in the 0FF position.
The licensee conciuded that
the lamp contacts had operated improperly in the as-found condition on
January 7,1987. No reason for the malfunction was identified, and the
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failure could not be repeated after cycling the switch several times.
The third bank of contacts for the bypass lamp indication was replaced
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with a new CR2940 control switch on January 30, 1987.
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The inspector reviewed the licensee response and corrective actions, and
identified no inadequacies. The bypass switch is cycled during monthly
surveillances of the PCIS logic channels. The switch bypasses only the
high radiation signal inputs from the ventilation monitors, and does not
block the trip signals from a downscale failure of the monitors. Based
on the arrangement of the switch contacts in the logic channel, the sub-
sequent random failure of any single contact could not defeat the ful-
fillment of the safety function to assure a PCIS isolation following
increased radiation levels either in the reactor building ventilation
exhaust or on the refueling floor, since the. redundant monitors in those
zones would cause the PCIS channel actuation.
The inspector noted that the day shift operators had completed the shift
turnover and their oncoming reviews of the plant status. These reviews
did not detect the potential bypass condition. The inspector noted that
the formal turnover sheets in AP 0150.03 do not include a requirement
that the operator check the stauts of the bypass lamps on panels CRP 9-15
or 9-17.
The inspector discussed this item with the operations super-
visor on January 8,1987, who stated that the matter would be reviewed -
to determine whether a change to the round sheets should be made to in-
clude a periodic check of the back panel safety-related bypass lamps and
keylock switches. The licensee determined that no changes to the round
sheets were necessary, for reasons documented in a memorandum to File
10.0 dated January 16, 1987.
The incident and significance of the bypass
indication were reviewed with operations personnel.
The inspector had no further comments on this item at the present time.
The status of the PCIS actuation channels will be reviewed further during
subsequent routine inspections.
5.2 Feedwater Leak Detection
The inspector reviewed the feedwater sparger leakage detection systen
and the monthly performance summary provided by the licensee in accord-
ance with letter FVY 82-105.
The licensee reported that, based on the
leakage monitoring data reduced as of Cecember 31, 1986, there were no
deviations in excess of 0.10 from the steady-state value of normalized
thermocouple readings, and no failures in the sixteen thermocouples in-
stalled on the four feedwater nozzles. No unacceptable conditions were
identified.
5.3 Safety System Review
The residual heat removal, high pressure coolant injection, residual heat
removal service water, standby liquid control, reactor core isolation
cooling, core spray and standby gas treatment systems were reviewed to
verify the systems were properly aligned and fully operational in the
standby mode. The review included: (1) verification that accessible
major flow path valves were correctly positioned; (2) verification that
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power supplies were energized; and, (3) visual inspection of major com-
ponents for leakage, proper lubrication, cooling water supply, and
general condition. No inadequacies were identified.
5.4 Operation with Inoperable Equipment
Actions taken by plant personnel during periods when equipment was in-
operable were reviewed to verify : Sat: (1) technical specification limits
were met; (2) alternate testing or inspection was completed satisfactorily
per AP 0025; and, (3) equipment return to service upon completion of re-
pairs was proper. The above reviews were completed for the following
items: (1) the B core spray pump, removed from service on January 20,
1987 for balancing of the thrust. bearing; (ii) removal of the A service
water pump on January 13, 1987 for motor adjustments; and (iii) removal
of the A standby gas treatment system on January 13, 1987 for charcoal
replacement.
5.4.1
Loss of "B" Station Air Compressor
The inspector also reviewed the actions taken by operators at
4:50 p.m. on January 17, 1987 when the B air compressor supply
breaker tripped and the compressor discharge check valves
failed open. Operator actions were prompt and effective to
isolate the faulty compressor and restore the air header to
a normal status prior to loss of other plant systems.
air pressure decreased from the normal value of 110 psig to
about 77 psig prior to recovery to normal with the standby air
compressor. The B compressor was released for maintenance.
No inadequacies were identified.
5.4.2
Inoperable Diesel Generator
Plant operators declared the B diesel generator inoperable at
12:15 p.m. on January 7,1987 when the auxiliary operator noted
that relief valve SR72-78 had failed open, causing the compres-
sor to run continuously and overheat.
The compressor was
secured and alternate system testing was begun in accordance
with Technical Specifications 3.10 and 3.5. The diesel air
start tanks were full at the normal pressure of 220 psig, and
thus were capable of starting the diesel upon demand at the
time the condition was discovered. Maintenance personnel
tested and cleaned the relief valve, and found that it lifted
at the proper setpoint of 260 psig.
No specific reason for
the relief valve to open was identified. With the relief valve
installed, the air compressor was retested satisfactorily and
the B diesel generator was declared operable at 2:20 p.m.
The
resident inspector reviewed the licensee's response and cor-
rective actions and identified no inadequacies.
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5.4.3
8 RPS HC Set Failure
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The B reactor protection system (RPS) motor genertor (MG) set
tripped off line at 12:20 p.m. on January 7,1987 while the
reactor was operating at 100% of rated power.
Loss of the B
RPS bus caused a one-half scram condition and a primary con-
tainment Group III isolation to occur. The reactor building
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normal ventilation isolated and the standby gas treatment
system started, as expected.
Control room operators switched
the 8 RPS bus to its alternate supply, reset the scram and
isolation, and returned the reactor building ventilation to
normal conditions by 12:27 p.m.
Subsequent review by mainten-
ance persennel determined that the coil of the K1 relay in the
MG set voltage control circuit had failed, which caused the
MG set output to trip on underfrequency.
The relay was re-
placed and the MG set was retested satisfactorily and returned
to service at 2:20 p.m.
Plant operators reported the ESF
actuation to the NRC headquarters duty officer per 10 CFR 50.72.b(2)(ii) at 1:10 p.m. on January 7, 1987. The licensee
reported this esent as LER 87-01 dated February 6, 1987, which
accurately described the event and corrective actions. The
resident inspector reviewed the licensee's response to the
event and identified no inadequacies.
6.0 Emergency Response Facilities
The inspector met with the plant manager on January 23, 1987 to review license
plans to modify the working spaces within the present administration building
,
to improve the Technical Support Center (TSC) and correct deficiencies iden-
tified by previous licensee and NRC audits. The licensee will modify the
spaces in phases and plans to expand the current " communications" room prior
to the 1987 emergency exercise. The inspector provided input to the licen-
see's planning for the TSC relative to the location of the emergency notifi-
cation phone and the location of NRC personnel who respond to site emergencies.
The inspector identified no inadequacies in the licensee's plans. The in-
spector noted further that the adequacy of the response center will be re-
viewed by the NRC Region I staff during a future emergency facilities inspec-
tion.
7.0 Response to IE Bulletins and Notices
7.1 IE Bulletins
The inspector reviewed the licensee's response to IE Bulletin 83-08 which
was provided by letter FVY 84-31 dated March 30, 1984.
The licensee re-
viewed the information presented in the bulletin and concluded that none
of the electrical circuit breakers in safety related applications have
undervoltage trip attachments, and no plans existed to use such breakers.
No inadequacies were identified.
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The inspector reviewed the licensee's response to IE Bulletin 83-07 which
was provided in letter FVY 84-26 dated March 22, 1984. The licensee
reviewed the vendor files in light of the concerns stated in the bulletin
and concluded that no materials supplied to Vermont Yankee came from
Ray Miller, Inc. The licensee also stated that the procurement program
would be' enhanced by adding criteria to the vendor selection process that
would assess the ability of vendors to prevent fraud and assure authen-
ticity cf products supplied to the facility. No inadequacies were iden-
tified.
7.2 Information Notices
In accordance with NRC Region I Temporary Instruction 87-02, the inspec-
tor reviewed actions taken by the licensee in response to the feedwater
line rupture event at the Surry Nuclear Power Plant.
Information Notice
(IN)86-106 was received at the site and assigned for. licensee review
and followup. Preliminary recommendations to address the concerns in
the notice were provided in a memorandum to the senior operations engi-
neer dated February 4,1987 (File 10.2).
The licensee has had a program in place for several years to monitor for
wall thinning in piping between the turbine, moisture separators, and
reheaters that carry wet steam. The program was instituted as a result
of previous steam. leaks in the piping. The most recent example of a
problem was through wall thinning and leakage in the feedwater minimum
flow line.
Corrective actions to repair susceptible piping were taken
during the 1984 and 1985 outages. As part of this existing program, 100
susceptible areas were identified for followup and a sample of 30 repre-
sentative areas were selected for measurement during the 1987 outage.
As a result of the information notice, the licensee plans to modify the
measurements program during the 1987 outage to include portions of the
feedw&ter system piping.
Limited licensee and NRC observations of the
low pressure water piping during periods when valves or pumps were apart
for repair have not shown evidence of erosion, corrosion or wall thinning
in the feedwater/ condensate streams.
The 1987 inspection program was under development as of this inspection.
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The selection criteria to be used to identify piping areas for examina-
tion were contained in the February 4th memorandum. The inspector noted
that the selection criteria did not include the following: (1) piping
runs that contain fittings less than 10 pipe diameters apart; and,
(ii) oxygen concentration in the process fluid. The inspector noted that
oxygen levels less than 10 parts per billion could cause piping materials
to be more susceptible to erosion and corrosion due to interference with
the formation and maintenance of the protective magnetite coating.
The
licensee stated that these items would be considered for inclusion in
the pipe selection criteria.
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The inspector noted further that the licensee uses a system to inject
oxygen into the condensate-feedwater stream at a point just downstream
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of the condensate pumps. The oxygen injection system is used during.
reactor startups to control oxygen within the desired levels.
The inspect'or had no further comments in this f arca at the present time.
No inadequacies were identified.
8.0 Control Rod Scram Time Test. Requirements
The inspector met with the technical services superintendent and the reactor
engineer on January 21, 1987 to discuss the requirements for control rod scram'
-testing contained in. Technical Specification 4.3.C.1.
The licensee's position
regarding the testing requirements were contained in a File.13.1 memorandum
.from J.C. Brooks to R.J. Wanczyk dated January 21, 1987, with~ attachments.
--Specification 4.3.C.2 requires that "during or-following a controlled shutdown
-of.the reactor, but not more frequently than 16 weeks nor less frequently than-
32 weeks," 50% of the control rods shall be scram time tested. -All control
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rods shall be tested each year. All control rods were scram time tested prior
to the reactor startup from the outage in July,1986 (per specification
4.3.C.1), and scram time measurements were obtained on at least 50% of the
rods during the inadvertent scram on October 4, 1986, 14 weeks after the
startup from the outage. The licensee reviewed this matter with the NSSS
vendor to determine whether he could take credit for this rod time data even
though-it fell outside the 16-week interval. The licensee could identify no
' basis for the-maximum frequency limit of 16 weeks, other than to preclude
excessive rod testing in conjunction with frequent plant shutdowns. Based
on the above, the licensee took credit for the October rod data, and will
complete scram time measurements on the remaining 50% of the rods within 32
weeks of the October measurements.
The licensee's position was discussed with NRC Region I management and with
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the NRR project manager.
No inadequacies were identified.
9.0 Extended Work Hours
The inspector reviewed operations department shift staffing and overtime re-
ports for the period from January,1986 to January,1987 to verify the use
of overtime was maintained within the administrative limits of AP 0036, Re-
vision 5.
Department staffing was sufficient to man six shifts, resulting
in the occasional use of overtime during normal power operations.
Five shif ts
were used during the outage, with a moderate use of overtime. Use of overtime
during the outage was within the guidelines. No instances were identified
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where overtime in excess of the guidelines was required.
No inadequacies were identified.
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_ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _
.
.
,
12
e
10.0 Maintenance Activities
Selected maintenance activities in progress during the inspection were re-
viewed to determine the scope and nature of work done on safety-related
equipment. The review confirmed: (1) the repair of safety-related equipment
received priority attention; (2) technical specification limiting conditions
'
for operation were met while components were out of service; and, (3) perform-
ance of alternate safety-related systems was not impaired.
Maintenance activities associated with the following items were reviewed to
verify (where applicable) correct procedure compliance and equipment return
to service, including operability testing.
10.1 MR 87-079, B Core Spray Pump Salancing - The licensee removed the B core
spray pump from service on January 20-21, 1987 to balance the motor shaft
by the addition of weights on the outboard (thrust bearing) end.
Pump
vibrations at the thrust bearing improved as a result of the balanced
-
shaft, but remained in the " rough" range. The pump was declared operable
at 2:50 p.m. on January 21, 1987. The licensee is planning additional
balancing of the shaft at a later time. No inadequacies were identified.
1
'
10.2 MR 86-2265, B Emergency Core Cooling System Battery Ground - During a
discussion with I&C personnel on January 15, 1987, the inspector noted
that the licensee had isolated a ground on the B battery system for the
analog trip system. The ground was located in the printed circuit board
for reactor pressure transmitter PT 2-3-56A(M). The initial results of
the licensee's investigation were that the ground was caused by a faulty
filter capacitor in the 24-volt power supply for the analog trip card.
The trip card is a Rosemount 71000 Series Analog trip system component.
The licensee has noted failures in the filter capacitors on three cards
during the last operating cycle and on two cards during the present
operating cycle. The 710-series units have been in service since about
1984, when they were installed as replacements for Rosemount 510-series
units, as p'.*t of a change to assure operability in potentially harsh
environments, as determined by the environmental qualification program.
No inadequacies were identified.
10.3 MR 87-025, RBV Logic Bypass Switch.
See paragraph 5.1 above for further
discussion of this item.
No inadequacies were identified.
11.0 Review of LERs
The licensee event reports (LERs) listed in Attachment I were reviewed to
verify the reports were submitted in accordance with the requirements of 10 CFR 50.73.
For each report, the inspector verified that (1) the LER accu-
rately described the event; and, (ii) the root cause was identified and ac-
tions taken or planned were appropriate to prevent recurrence.
_
..:
6
13
Additionally, on January 16, 1987 the inspector provided the licensee Attach-
ment II, a detailed evaluation of LER quality made by the NRC Office of
Analysis and Evaluation of Operational Data (AE00) using the basic methodology
presented in NUREG 1022, Supplement 2.
In general, the LERS were found to
be above the average in quality.
LER quality especially improved in the later
half of 1986 following the use of new licensee procedures developed in re-
sponse to. the previous set of AE00 comments.
No inadequacies were identified, except as noted below.
11.1 Report Timeliness
The inspector noted that seven LERs were not submitted within the 30-day
period required by 10 CFR 50.73. The subject LERs are listed below,
along with the number of days late: LER 86-14 (80 days), 86-09 (3 days),
86-08 (3 days), 86-04 (1 day), 86-03 (2 days), 85-13 (9 days), and, 85-07
(2 days). Of these seven reports, two were notably late at 9 and 80 days.
LER 86-14 was submitted in response to Inspection Report 86-15 issued
on September 16, 1986 due to the licensee's initial disagreement that
the missed SLC surveillance constituted a technical specification viola-
tion. The licensee's response to the event was reviewed and found ac-
ceptable as discussed further in section 11.3 below.
Inspector concerns regarding the timeliness of LER submittals were dis-
cussed with licensee personnel. The inspector stated that this matter
should receive further management attention to assure that reports are
submitted within the 30-day period. This matter will be reviewed further
during subsequent inspections (UNR 87-02-01).
11.2 LER 86-12, MOV Failure
The inspector noted, based on information from the NRC Office of AE00,
that conflicting information was provided by the licensee in LER 86-12,
that described a potentially generic concern with Limitorque motor
operators. The original LER 86-l'2 dated July 10, 1986 stated that Mobil
EP-1 grease was installed in 40 valves during the outage as part of the
vendor's recommendation for routine preventive maintenance (PM).
LER 86-12, Revision 1, dated August 22, 1986 stated that Mobil EP-0
grease was used. The grease actually used during PM on the 40 valves
was Exxon Nebula EP-0 grease. The less viscous grease leaked past the
spring peak seal and effectively increased the torque setpoint.
The 40 valves rebuilt during the outage included those in the drywell,
the steam tunnel and elsewhere in the plant. The drywell and steam
tunnel valves would potentially be subjected to the more severe environ-
mental conditions during postulated accidents.
The Limitorque manufac-
turer recommends only two greases for use in the valve operators, Exxon
Nebula EP-0 or SUN 0CO 50 EP, and specifically, only Nebula EP-0 is con-
.
..
14
sidered acceptable for valves used in safety-related applications for
which environmental qualification is required.
There are 162 safety-
related and non nuclear safety motor operated valves in the plant.
The
licensee's preventive maintenance program addresses roughly one-third
of all the remaining valves during each outage.
The inspector noted that
for the remaining 122 valves in the plant, the licensee's past maintenance
practices have included adding Mobil Mobilux EP grease with the Exxon
Nebula EP grease supplied in the operators by the manufacturer.
The inspector reviewed the qualification documentation by the licensee
in Section 13.1 of the Environmental Qualifications Manual governing
motor operated valves to determine whether safety related valves with
mixed greases were environmentally qualified.
The licensee's qu111 fica-
tion program specifically addressed the adequacy of motor operators that
used a mixture of Mobil and Exxon EP-0 greases.
Based on an engineering
evaluation provided in a letter from an Electric Power Research Institute
(EPRI) staff consultant dated February 18, 1986, the licensee determined
that the valves with the mixed greases were not susceptible to short term
degradation, and were therefore environmentally qualified, particularly
for valves in relatively low dose areas outside the primary containment.
However, the licensee engineering organization did recommesid that the
grease in the subject operators be changed out to Exxon EP-0 grease on
a phased basis over tiie course of subsequent outages, with priority given
to valves showing signs of lubricant leakage.
The inspector noted, based
on discussions with maintenance personnel, that plans were in progress
to complete OP 5220 inspections on 18 valves, and change the grease on
24 additional valves during the 1987 outage.
The inspector had no further questions regarding the status of Limitorque
motor operators at Vermont Yankee and the licensee's program to install
Exxon Nebula EP-0 grease.
However, the erroneous information supplied
by the licensee in LER 86-12 and LER 86-12, Revision 1 should be cor-
rected to identify to other Limitorque users that the vendor-recommended
EP-0 grease can cause torque switch setting problems because of its
viscosity.
This item is unresolved pending sut,mittal of a revised LER
86-12, and subsequent review by the NRC (UNR 50-271/87-02-02).
11.3 LER 86-14, SLC Surveillance
,
NRC review of this LER identified two items that were inaccurate.
The
licensee's summary of the event stated that the need to sample the tank
following the water addition was provided in the " turnover" briefing with
the following shift.
The inspector noted that NRC review of the event
determined that the sample request was not included in the turnover.
Additionally, the licensee reported this event under the "other" category
of the 10 CFR 50.73 requirements.
The inspector noted that the incident
could have been reported under section 50.73(A)(2)(1)(b), as an operation
or condition prohibited by the technical specifications.
The violation
of the technical specification surveillance requirement was addressed
in Inspection 86-15.
The licensee's response to the violation was de-
.
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15
scribed in letter FVY 86-96 and found acceptable in Inspection 86-22.
The above items were discussed with the licensee. The accuracy of in-
formation will be reviewed further during subsequent inspections.
12.0 Plant Procedure Review Status
The inspector reviewed the status of procedures in the biennial review cycle
to determine the current status of the procedure reviews and the number of
procedures that were overdue in review.
The status was summarized in a Pro-
cedure Follow Statistics List dated January 16, 1987.
Plant actions were
successful prior to the 1985 outage in essentially eliminating the backlog
of plant procedures that were overdue in the biennial review cycle. Based
on the success of the existing PORC review methods, no further action was
taken to use subcommittees for procedure reviews. To address regulatory con-
l
cerns on assuring PORC reviews of procedures within two years, the review
process was revised to assure standing procedures were acceptable for con-
tinued use pending issuance of the new revisions.
However, the number of overdue procedures increased during the 10-month re-
circulation pipe replacement outage and reached a total of 70 by August, 1986.
Licensee efforts were successful in reducing the total procedures past due
in review to 58 as of January 1987, and of these, 34 reviewed by the PORC and
21 required final review by the Manager of Operations. Of the 58 overdue
procedures, 28 were overdue by less than 3 months, 17 were 3 months past due,
and 13 were 6 months past due. All procedures that were either 3 or 6 months
past due had been reviewed by the PORC to verify whether the procedures were
acceptable for continued use "as is" pending issuance of the new revision,
or should not be used until revised.
The continued review of routine procedures at the corporate level is assuring
continued overall quality of plant procedures. The corporate reviews appeared
to be timely and did not contribute to the backlog.
Continued licensee efforts in this area should eliminate the backlog and
assure reviews of plant procedures are completed in a timely manner.
No inadequacies were identified.
!
13.0 Core Spray Safe-End Replacement
!
By letter FVY 87-07 dated January 12, 1987, the licensee submitted for NRC:NRR
approval the proposed plans to address the core spray nozzle safe ends. The
nozzle-to-safe-end welds on both core spray nozzles were found cracked during
i
inspections completed in 1986. By letter dated June 16, 1986, NRC:NRR ap-
proved the weld overlay design and repair methodology, approved interim plant
operation with the overlays, and recommended that the safe ends be replaced
during the 1987 refueling outage.
-
.
.
16
In the January 12, 1987 letter, the licensee provided the basis for the de-
terminations that the repaired nozzles were acceptable for continued, interim
service through the end of the next operating cycle (Cycle 13), and proposed
deferral of the nozzle replacement until a subsequent outage. The licensee
committed to inspecting the overlay repairs in accordance with EPRI/NRC weld
inspection criteria, and to provide the detailed plans for inspecting the
overlays in May,1987. This item is unresolved pending NRC:NRR acceptance
of the licensee's proposed plans, and further review of the licensee's actions
during a subsequent inspection (UNR 87-02-03).
14.0 Battery Temperature Limits
The inspector reviewed licensee controls for battery room and electrolyte
temperature in response to a request for information from NRC Region I on
January 30, 1987!. Based on a review of operating, maintenance and surveil-
lance procedures, the inspector determined that no procedural controls exist
~
to monitor battery room temperatures, establish temperature limits for battery
environments, or to otherwise control room temperatures within prescribed
limits. Procedure OP 4210 is used to complete weekly surveillance on bat-
teries at the facility and does incorporate requirements to apply a tempera-
ture correction to specific gravity readings. The temperature readings are
obtained from the monitored battery pilot cells and are used to correct
specific gravity readings relative to the reference temperature of 77 degrees
F.
The acceptance criteria for assuring operability of batteries monitored
per OP 4210 is that battery cell voltage be greater than 2.13 volts and
specific gravity be greater than 1.19 corrected to 77 degrees F.
The inspector reviewed available vendor information for Exide and C&D bat-
teries for information regarding battery temperatures limits. Both manuals
indicated battery room temperatures within the range of 60 to 90 degrees F
were acceptable. The inspector reviewed OP 4210.01 data recorded during the
,
surveillance period of October,1986 to February,1987, for batteries associ-
ated with the rain station DC system, the UPS system, the ECCS system, the
emergency lighting diesel generator, the fire water pump diesel generator,
the reactor protection system, the relay house-switchyard system, the RCIC
alternate supply, and the A emergency diesel generator. The te ;t data showed
that minimum voltage and specific gravity limits were met for all temperature
conditions for each battery. Electrolyte temperatures for each test were
found within the 60 to 90 degree F range on all batteries, except as noted
below.
The electrolyte temperature was outside the range of 60 to 90 degrees F as
follows: (i) emergency lighting diesel generator: temperature within the range
of 50 to 60 degrees from October 20 until January 19, 1987, with a low of 47
degrees F January 26, 1987; (ii) AS2-A diesel generator room: temperature of
59 and 54 degrees on January 19th and 26th, respectively.
Several other bat-
teries had measured electrolyte temperatures in the range of 60 to 70 degrees
F.
The inspector noted that, based on the OP 4210 acceptance criteria, the
batteries were considered operable.
f
a
.
.
.
17
This matter was referred to the licensee for further review and followup to
address the following concerns expressed by the inspector: (1) the effects
of low room temperatures on battery capacity - C&D vendor information suggests
that battery capacity can be reduced by up to 9.8% for temperatures as . low
as 62 degrees F; (2) what were the battery environmental conditions specified
in the battery design specifications supplied to the battery vendor, or
otherwise stated, what is the limit on temperature range to establish an
operability envelope for the battery; and, (3) what actions should be done
to monitor battery room temperatures to assure batteries remain within the
established range. This item is unresolved pending completion of licensee
actions to review this matter and subsequent review by the inspector (UNR
50-271/87-02-04).
15.0 Management Meetinar
Preliminary inspection findings were discussed with licensee management peri-
odically during the inspection. A summary of findings for the report period
was also discussed at.the conclusion of the inspection and prior to report
issuance.
.
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_ _ _ - _ .
_ _ _ _ _
_ _ _ _ _ _
.
.
ATTACHMENT I
LER SUMMARY
LER Number
Summary Description
85-007
While performing type C rate testing, several (9) valves were found
Revision 1
to have seat leakage above that permitted by TS 3.7.A.4
85-008
Personnel discovered an error in the offsite dose rate calculations
procedure, which did not correspond to TS Section 3.8.E
85-009
A full scram signal was received from the scram circuit while im-
plementing a design change in the RPS system
85-010
Conductors installed in contact with the sharp edge of the end of
the electrical penetration assembly sleeve
85-011
Spurious signals on refuel floor zone radiation monitor resulted
in isolation of the RB ventilation system and activation of the SGTS85-012
Freon was released in the vicinity of the CR air intake duct while
servicing the air conditioners which activated the CR habitability
system
86-001
Containment valves missing from Appendix J 1eak rate test program
86-002
Calculational error discovered in the Environmental Qualification
Program which underpredicted the postulated radiation exposure for
parts in the H2/02 analyzer system
86-003
Two main steam relief valves actuation pressures were above the
setpoints86-004
The "A" SLC squib valve failed to fire during performance of annual
surveillance
86-005
Ultrasonic indications of intergranular stress corrosion cracking
(IGSCC) were detected in inconel 182 weld butter of both spray
nozzles86-006
Unanticipated scram signal during LPRM cable testing / troubleshooting
86-007
1985/86 Appendix J Type A test failure due to penetration leakage
86-008
Unanticipated scram during mode switch movement
86-009
"C" SRV accumulator failed leak test due to check valve seat leak
_
_ _ - - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
.
.
,
Attachment I
2
LER Number
Summary Description
86-010
Inadvertent reactor scram signal on loss of RPS caused by broken
relay armature
86-012
Motor operator failure due to torque switch hydraulic lockup
86-013
Reactor scram during startup due to inoperable intermediate range
monitors86-014
Failure to sample SLC tank after water addition
86-015
High flux reactor scram in hot standby due to cold feedw.ter in-
jection
86-016
Missed Appendix J leak test due to personnel error
87-001
Isolation, Half Scram and SBGT Initiation due to RPS MG Set relay
failure.
1
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9
ATTACHMENT II
J
AE00 SALP INPUT FOR
,
i
-VERMONT YANKEE-
!
OPERATIONS (LER QUALITY) FOR
THE ASSESSMENT PERIOD OF
,
1 OCTOBER 1985 TO 31 DECEMBER 1986
,
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_ - _ _ _ _ _ _ _ _ _ .
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t
SUMMARY
' An evaluation of the content and quality of a representative sample of
the Licensee Event Reports (LERs) submitted by Vermont Yankee during the
October 1, 1985 to December 31, 1986 Systematic Assessment of Licensee
Performance (SALP) period was performed using a refinement of the basic
methodology presented in NUREG-1022, Supplement No. 2.
This is the second
time the Vermont Yankee LERs have been evaluated using this methodology.
The results of this evaluation indicate improvement in that the
Vermont Yankee LERs now have an overall average score of 8.3 out of a
possible 10 points, compared to their previous overall average score of 7.1
and a current industry average score of 8.2 (i.e., the average of the
latest overall average LER score for each unit / station that has been
evaluated to date using this methodology).
One weakness identified in the Vermont Yankee LERs involves the
requirement to adequately discuss personnel error (Requirement
50.73(b)(2)(ii)(J)(2)].
Two strong points for the Vermont Yankee LERs are the discussions
concerning the safety assessments (Requirement 50.73(b)(3)] and the failure
mode, mechanism, and effect of failed components (Requirement 50.73(b)(2)(11)(E)].
1
..
.
.
..
'
t
AE00 INPUT TO SALP REVIEW FOR
VERMONT YANKEE
Introduction
.
In order.to evaluate the overall quality of the contents of the
Licensee Event Reports (LERs) submitted by Vermont Yankee during the
October 1, 1985 to December 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
NUREG-1022, Supplement No. 2.1
The sample consists of a total 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 befo.e the end of the SALP
assessnent 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
i
determine how well the content of its text, abstract, and coded fields meet
the criteria of 10 CFR 50.73(b).
In addition, each selected LER is
compared to the guidance for preparation of LERs presented in NUREG-1022
and Supplements No. 1 and 2 to NUREG-1022; based on this comparison,
suggestions were developed for improving the quality of the reports. The
purpose of this evaluation is to provide feedback to improve the quality of
LERs.
It is not intended to increase the requirements concerning the
" content" of reports beyond the current requirements of 10 CFR 50.73(b).
Therefore, statements in this evaluation that suggest measures be taken are
not intended to increase requirements and should be viewed in that light.
However, the minimum requirements of the regulation must be met.
1
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. _ - _ _ _ _ - - - ~ _ - _ _ _ - - _ .
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The evaluation process for each LER is divided into two parts.
The
'
first part of the evaluation consists of documenting comments specific to
the content and presentation of each LER.
The second part consists of
determining a score (0-10 points) for the text, abstract, and coded fields
of each LER.
The LER specific comments serve two purposes:
(1) they point out what
the analysts considered to be the specific deficiencies or observations
concerning the information pertaining to the event, and (2) they provide a
basis for a count of general deficiencies for the overall sample of LERs
that was reviewed. Likewise, the scores serve two purposes:
(1) they
serve to illustrate in numerical terms how the analysts perceived the
content of the information that was presented, and (2) they provide a basis
for determining an overall score for each LER.
The overall score for each
LER is the result of combining the scores for the text, abstract, and coded
fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields
score - overall LER score).
The results of the LER quality evaluation are divided into two
categories:
(1) detailed information and (2) sumnary information. The
detailed information, presented in Appendices A through 0, consists of LER
sample information (Appendix A), a table of the scores for each sample LER
(Appendix 8), tables of the number of deficiencies and observations for the
text, abstract and coded fields (Appendix C), and comment sheets containing
narrative statements concerning the contents of each LER (Appendix D).
-
When referring to these appendices, the reader is cautioned not to try to
directly correlate the number of comments on a comment sheet with the LER
scores, as the analysts has flexibility to consider the magnitude of a
deficiency when assigning scores.
Discussion of Results
A discussion of the analysts' conclusions concerning LER quality is
presented below. These conclusions are based solely on the results of the
evaluation of the contents of the LERs selected for review and as such
2
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1
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ .
.
.
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i
represent the analysts' assessment of the unit's performance (on a scale of
0 to 10) in submitting LERs that meet the criteria of 10 CFR 50.73(b) and
the guidance present in NUREG-1022 and its supplements.
Table 1 presents the average scores for the sample of LERs evaluated
for the unit.
In order to place the scores provided in Table 1 in
perspective, the distribution of the overall average score for all
units / stations that have been evaluated using the current methodology is
provided on Figure 1.
Additional scores are added to Figure 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 basis for the average
scores in Table 1.
For example, Vermont Yankees'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 evaluution of 17 different requirements ranging from the
discussion of plant operating conditions prior to 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 many of the
discussions concerning that requirement or (2) totally failed 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
3
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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_ _ _ _ _ - _ _ _ _ _ _ _ _ .
.
.
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TABLE 1.
SUMMARY OF SCORES
FOR VERMONT YANKEE
l
______________________________________________________________________
Average
High
Low
_______
____
___
Text
8.4
9.7
7.1
Abstract
7.9
10.0
6.3
Coded Fields
8.8
9.9
7.6
Overall
8.3
9.7
7.1
c.
See Appendix B for a summary of scores for each LER that was evaluated.
___________________________________________________________________________
4
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TABLE 2.
LER REQUIREMENT PERCENTAGE SCORES FOR VERMONT YANKEE
4
_____________________..___________________________________________________
+
TEXT
____
Percentage
a
Requirements [50.73(b)] - Descriptions
Scores ( )
_____________
______________________________________________________
(2)(ii)(A)
- - Plant condition prior to event
90 (15)
(2)(ii)(B)
- - Inoperable equipment that contributed
b
(2)(ii)(C)
- - Date(s) and approximate time (s)
77 (15)
(2)(ii)(D)
- - Root cause and intermediate cause(s)
89 (15)
(2)(ii)(E)
- - Mode, mechanism, and effect
100 ( 8)
(2)(ii)(F)
- - EIIS codes
0 (15)
(2)(ii)(G)
- - Secondary function affected
b
(2)(ii)(H)
- - Estimate of unavailability
100 ( 1)
(2)(ii)(I)
- - Method of discovery
93 (15)
(2)(ii)(J)(1) - Operator actions affecting cou.se
75 ( 2)
(2)(ii)(J)(2) - Personnel error (procedural deficiency)
79 ( 7)
(2)(ii)(K)
- - Safety system responses
92 ( 6)
,
(2)(ii)(L)
- - Manufacturer and model no. information
88 ( 8)
(3) - - - - - - Assessment of safety consequences
91 (15)
(4) - - - - - - Corrective actions
89 (15)
(5) - - - - - - Previous similar event information
93 (15)
(2)(1)
- - - - Text presentation
82 (15)
ABSTRACT
________
Percentage
a
Requirements [50.73(b)(1)] - Descriptions
Scores ( )
_____________
______________________________________________________
- Major occurrences (immediate cause/effect)
97 (15)
- Plant / system / component / personnel responses
91 ( 8)
- Root cause information
76 (15)
- Corrective action information
68 (15)
,
- Abstract presentation
71 (15)
i
6
--
. _ _ - _.
.--
.- -
. . -
. -
. - - . _ _ . - - - .
.
--
.
.
'
TABLE 2.
(continu:d)
_ _ _ _ ' _ _ _ - - - _ _ - _ _ - - _ _ _ _ - - _ _ - - _ - _ - _ _ - _ - _ _ - - - _ _ _ _
i
_
' CODED FIELDS
-__--__--__-
Percentage
a
Item Number (s) - Descriptions
Scores ( )
_----_____--____-_-__-___-_-----___ -_____--__-----___
---__________
1,
2, and 3 -
Plant name(unit #), docket #,
page #s
99 (15)
4------
Title
64 (15)
5,
6, and 7 -
Event date, LER no.,
report date
96 (15)
8---
--
Other facilities involved
100 (15)
9 and 10
- -
Operating mode and power level
98 (15)
Reporting requirements
97 (15)
11
Licensee contact information
97 (15)
12
Coded component failure information
93 (15)
13
14 and 15 - -
Supplemental report information
90 (15)
____-__--____-----_-__ --___
o.
Percentage scores are the result of dividing the total points for a
rcquirement 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
cpplicable.
b.
A percentage score for this requirement is meaningless as it is not
possible to determine from the information available to the analyst whether
,
l
this requirement is applicable to a specific LER.
It is always given 100%
i
if it is provided and is always considered "not applicable" when it is not.
l
- - - - - _ _ _ - _ - - _ - _ _ _ - - - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - - _ - _ _ - _ _ - - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
l
l
!
!
!
i
7
l
l
I
,r.
.- .
. - - ,
-
,,-
- - - - - -
- - - - - - .
, , ,
, . . . - . - , , _ - -
1
~
.
.
.g
l
requirements with a score of less than 75 or those with numerous
i
deficiencies are discussed below in their order of importance.
In
addition, the primary deficiencies in the abstracts and coded fields are
discussed.
Three text requirements have marginally acceptable scores but are
mentioned here because of the high percentage of LERs with a problem
concerning these requirements. The three requirements are:
,
}
.
1.
Dates and times, Requirement 50.73(b)(2)(11)(C),
2.
Operator actions affecting the event,
Requirement 50.73(b)(2)(ii)(J)(1), and
3.
Personnel and procedural error, Requirement 50.73(b)(2)(ii)(J)(2).
i
Date/ time information was considered deficient in seven of the LERs.
In
particular, date/ time information was not included to indicate when the
plant was returned to a safe and stable condition and when corrective
i
actions were completed. The score for Requirement 50.73(b)(2)(ii)(J)(1)
was reduced because one of the two LERs for which this requirement was
'
considered appropriate failed to discuss the operator actions in the text
although the actions were discussed in the abstrat see Appendix D, LER
,
Sample No. 12). As a reminder, the abstract is supposed to be a summary of
the text; therefore, the t;at should discuss all information presented in
!
the abstract. Finally, the score for Requirement 50.73(b)(2)(11)(J)(2)
{
could be improved b) ensuring that all aspects of the requirement are
discussed once personnel or procedural error is identified.
See Appendix 0
i
for specific comments concerning these deficiencies.
,
All fifteen LERs failed to provide the Energy Industry Identification
System (EIIS) codes for each component and system referred to in the text,
j
Requirement 50.73(b)(2)(11)(F).
!
8
.
.
6
,
While there are no specific requirements for an abstract, other than
those given in 10 CFR 50.73(b)(1), an abstract should as a minimum,
summarize the following information from the text:
1.
Cause/Effect
What happened that made the event
reportable.
2.
Responses
Major plant, system, and personnel
responses as a result of the event.
3.
Root / Intermediate
The underlying cause of the event. What
caused the component and/or system
failure or the personnel error.
4.
Corrective Actions
What was done immediately to restore the
plant to a safe and stable condition and
what was done or planned to prevent
recurrence.
Numbers 1 and 2 above were adequately summarized in the abstracts of
the LERs reviewed.
Number 3 had a marginally acceptable score of 76% and
Number 4 had a score of 68%.
Both of these can be improved by ensuring
that the cause and corrective action information that is contained in the
text is adequately summarized in the abstract.
Again, the abstract should not contain information that is not
discussed in text (i.e., don't introduce new information in the abstract).
If, when writing the abstract, new information is deemed necessary, the
text should be revised so as to discuss this information.
Note that the
!
average abstract score (7.9) is lower than the text score which indicates
that text information is not being adequately summarized in abstract.
Further improvement in the abstract score could be obtained by using the
full space available (i.e., the 1400 spaces).
I
The main deficiency in the area of coded fields involves the title.
Item (4). Twelve of the titles failed to adequately indicate root cause,
seven failed to include the result, and two failed to include the link
l
'
9
l
1
.
.
'
.
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.
Table 3 provides a summary of the areas that need improvement for the
Vermont Yankee LERs. For additional and more specific information
concerning deficiencies, the reader should refer to the information
presented in Appendices C and D.
General guidance concerning these
requirements can be found in NUREG-1022, Supplement No. 2.
It should be noted that this is the second time that the
Vermont Yankee LERs have been evaluated using this same methodology.
The
previous evaluation was reported in November of 1985. Table 4 provides a
comparison of the scores for both evaluations. As can be seen, the
Vermont Yankee LERs have improved since the previous evaluation and are now
above the current industry overall average of 8.2.
(Note:
The industry
overall average is the result of averaging the latest overall average score
for each unit / station that has been evaluated using this methodology.)
10
.
.
'
.
TABLE 3.
AREAS MOST NEEDING IMPROVEMENT f0R VERMONT YANKEE LERs
Areas
Comments
Dates / times
It would be helpful to include date/ time
information for when the plant is in a safe
and stable condition and for when the
corrective actions are completed.
Operator actions
Be sure to discuss operator actions that
affect the course of the event in the text.
Personnel / procedural error
Discuss all required aspects of
personnel / procedural error.
ElIS code
EIIS codes should be provided for each
component or system referred to in the text.
Abstracts
Cause and corrective action information from
the text should be mentioned in the
abstract. Discuss all information in the
text that is summarized in the abstract.
Be sure to use the full space available.
Coded fields
a.
Titles
Titles should be written such that they
better describe the event.
In particular,
the root cause and result should be
provided in each title.
/
11
..
.
.
TABLE 4.
COMPARISON OF LER SCORES FROM PREVIOUS EVALUATION
Report Date
N_ovember-85
January-86
Text average
7.0
8.4
Abstract average
7.0
7.9
Coded fields average
8.2
8.8
Overall average
7.1
8.3
.
12
.
.
'
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.
1
I
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13
L
9
s
APPENDIX A
LER SAMPLE SELECTION
INFORMATION
FOR VERMONT YANKEE
l
l
I
_ _
.
'
TABLE A-1.
LER SAMPLE SELECTION FOR VERMONT YANKEE
Sample Number
LER Number
Comments
1
85-009-00
2
85-010-00
3
85-012-00
4
86-001-00
5
86-002-00
6
86-003-00
7
86-004-00
8
86-005-00
9
86-007-00
10
86-008-00
11
86-009-00
12
86-010-00
13
86-011-00
14
86-012-01
'
15
86-013-00
A-1
i
6
APPENDIX B
EVALUATION SCORES Of
INDIVIDUAL LERS FOR VERMONT YANKEE
. _ .
.
.
..
_ _ _ _
_ _ _
.
, - _ _ _ _ _ _ _ _
..
-
TABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERS FOR VERMONT YANKEE
.
. -___________ _________...........____..________.._____________ __________
a
LER Sample Number
1
2
3
4
_______________....
_______....-________________5
6
7
8
__ ......._____.___________
Text
7.1
7.6
7.6
9.3
9.3
9.3
9.2
8.9
Ab0 tract
6.6
8.8
8.2
9.5
6.5
8.6
6.7
6.9
Coded Fields
8.3
8.5
8.5
8.9
9.0
9.0
7.6
8.5
Ovarall
7.1
8.0
7.9
9.3
8.4
9.1
8.3
8.3
_____________________________.__ .. ____________________________.._________
a
LER Sample Number
9
10
11
12
13
_______________..___ ..___...._________. __.____________14
15
Average
____...____________
Tcxt
7.6
7.6
9.1
7.6
7.6
9.2
9.7
8.4
Abstract
6.3
7.0
8.1
7.8
8.1
9.8
10.0
7.9
C:ded Fields
9.7
8.9
8.0
9.8
8.3
9.9
9.2
8.8
Ovarall
7.4
7.6
8.7
7.9
7.8
9.5
9.7
8.3
.._________...______..____
See Appendix A for a list of the corresponding LER numbers.
o.
_____._____.....________......_____....__....__.....__.... ___________...
B-1
_ _ _ _ _ - _ _ - . - _ _ _ _ _
a
APPENDIX C
DEFICIENCY AND OBSERVATION
COUNTS FOR VERMONT YANKEE
-
- -
-
.
,_
.
.
'
TABLE C-1.
TEXT DEFICIENCIES AND O8SERVATIONS FOR VERMONT YANKEE
-
Number of LERs with
Deficiencies and
Observations
_
_
- , ,
Sub-paragraph
Paragraph
Description of Deficiencies and Observations
Totals'
Totals (
)
a
50.73(b)(2)(11)( Al--Plant operating
3 (15)
conditions before the event were not
included or were inadequate.
50.73(b)(2)fli)(B)--Discussion of the status
0 ( 1)
of the structures, components, or systems
that were inoperable at the start of the
event and that contributed to the event was
not included or was inadequate.
50.73(b)(2)(11)(C)--Fa11ure to include
7 (15)
sufficient date and/or time information.
a.
Date information was insufficient.
7
b.
Time information was insufficient.
5
50.73(b)(2)(11)[0,1--The root cause ana/or
5 (15)
intermediate fatiure, system failure, or
personnel error was not included or was
inadequate.
a.
Cause of component failure was not
2
included or was inadequate
b.
Cause of system failure was not
1
included or was inadequate
c.
Cause of personnel error was not
2
included or was inadequate.
50.73(b)(2)(ii)(E_)--The failure mode,
0 ( 8)
mechanism (insnediate cause), and/or effect
(consequence) for each failed component was
not included or was inadequate.
4.
Failure mode was not included or was
inadequate
b.
Mechanism (insnediate cause) was not
included or was inadequate
c.
Effect (consequence) was not included
or was inadequate.
C-1
-
-
-
-
-
.
-
- -
.
.
'
TA8tE C-1.
(continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph
Paragraph
Description of Deficiencies and Observations
Totals'
Totals (
)
50.73(b)(2)(tilf f)--The Energy Industry
15 (15)
Identification System component function
identifier for each component or system ws
not included.
50.73(b) 2)J11)(G:--For a failure of a
0 ( I)
i
componen", with mu'tiple functions, a list
of systems or secondary functions which
were also affected was not included or was
inadequate,
t
50.73(b)(2)(ti)(H)--For a failure that
0 ( 1)
renderer' a train of a safety system
,
inoperable, the estimate of elapsed time
from the discovery of the failure untti the
train w s returned to service was not
included.
50.73(b)(2)(11)(Il--The method of discovery
1 (15)
of each component failure, system failure,
i
personnel error, or procedural error ws not
included or w s inadequate.
.
!
4.
Method of discovery for each
I
component failure was not included
or was inadequate
i
b.
Method of discovery for each system
0
failure was not included or was
'
inadequate
c.
Method of discovery for each
0
.
personnel error w s not included or
4
l
w s inadequate
'
d.
Method of discovery for each
0
procedural error ws not included or
was inadequate.
C-2
. _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ . _
- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - - - _ _
.
.
'
TABLE C-1.
(continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph
Paragraph
Des:riation of Deficiencies and Observations
Totals'
Totals (
)
50.73 :b)(2)(ill(J)(11--Operator actions that
1 ( 2)
. affec",ed the course of the event including
operator errors and/or procedural
deficiencies were not included or were
inadequate.
30.73(b)(2)(it)(J)(21--The discussion of
4 ( 7)
each personnel error was not included or was
J
inadequate,
a.
OBSERVATION: A personnel error was
1
implied by the text, but was not
expitcitly stated,
b.
50.73(b)(2)(ii)(J)(2)(11--Olscussion
2
as to whether the personnel error was
cognitive or procedural was not
included or was inadequate,
c.
50.73(b)(2)(11)(J)(2)(111--Discussion
0
as to whether the personnel error was
contrary to an approved procedure, was
a direct result of an error in an
approved procedure, or was associated
with an activity or task that was not
covered by an approved procedure was
not included or was inadequate.
d.
50.73(b)(2)(11)(J)(2)(tiil--Discussion
0
of any unusual characteristics of the
work location (e.g., heat, noise) that
directly contributed to the personnel
error was not included or was
inadequate.
e.
50.73(b)(2)flil(J)(2)(lvi--01scussion
1
of the type of personnel involved
(i.e., contractor personnel, utility
licensed operator, utility non11 censed
operator, other utility personnel) was
not included or was inadequate.
C-3
_
_
_
_ _ _ _ _ _ _ - _ _ - - -
.
.
'
TA8LE C-1.
(continued)
Nutrber of LERs with
Deficiencies and
Observations
_
Sub-paragraph
Paragraph
Description of Deficiencies and Observations _
Totals *
Totals (
)
50.73(b)(2)(11)(K)--Automatic and/or manual
1 ( 6)
safety system responses were not included or
were inadequate.
50.73(b)(2)(11?(L)--The manufacturer and/or
2 ( 8)
model number of each failed component was
not included or was inadequate.
. . ,
10.73(b)(31 -An assessment of the safety
4 (15)
consequences and implications of the event
was not included or was inadequate.
a.
08 SERVAT!0N: The availability of
0
ether 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.
CBSERVATION:
The consequences
3
'
-
of the event had it occurred under
more severe conditions were not
discussed.
If the event occurred
under what were considered the most
severe conditions, the text should so
state.
50.73(b)(41--A discussion of any corrective
4 (15)
actions planned as a result of the event
including those to reduce the probability
of sistlar events occurring in the future
was not included or was inadequate.
C-4
.
.
'
TABLE C-1.
(continued)
'
Number of LERs with
Deficiencies and
Observations
Sub-paragraph
Paragraph
Description of Deficiencies and Observations
Totals *
Totals (
)
a.
A discussion of actions required to
I
correct the problem (e.g., return the
component or system to an operational
condition or correct the personnel
error) was not included or was
inadequate,
b.
A discussion of actions required to
4
reduce the probability of recurrence
of the problem or similar event
(correct the root cause) was not
included or was inadequate,
c.
OBSERVATION: A discussion of actions
0
required to prevent similar failures
in similar and/or other systems (e.g.,
correct the faulty part in all
components with the same manufacturer
and model number) was not included or
was inadequate.
50.73(blf51--Information concerning previous
1 (15)
similar events was not included or was
inadequate.
C-5
.
.
'
'
TASLE C-1.
(continued)
Number of LER$ with
Deficiencies and
Observations
Sub-paragraph
Paragraph
Desertotton of Deficiencies and Observations
Totals'
Totals (
)
50.73(b)(2)(il--Text presentation
'5 (15)
inadequacies,
a.
OBSERVATION: A diagram would have
0
aided in understanding the text
discussion.
b.
Text contained undefined acronyms
2
and/or plant specific designators,
c.
The text contains other specific
3
deficiencies relating to the
readability.
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or
observations within certain requirements.
Since an LER can have more than
one deficiency for cortain 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.
C-6
..-.
-
_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - -
.
. '
'
TABLE C-2.
A8STRACT DEFICIENCIES AND OBSERVATIONS FOR VERM0NT YANKEE
Number of LERs with
Deficiencies and
Observations
Sub-paragraph
Paragraph
gggrlotion of Deficiencies and Observatic.ni
Totals'
Totals (
)
A summary of occurrences (insnediate cause
1 (15)
and effect) was not included or was
inadequate
A summary of plant, system, and/or personnel
3 ( 8)
responses was not included or was
inadequate.
a.
Summary of plant responses was not
0
included or was inadequate.
b.
Summary of system responses w s not
1
included or ws inadequate.
c.
Summary of personnel responses w s not
2
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 or
10 (15)
planned as a result of the event was not
included or w s inadequate.
C-7
_ _ _ _ _ _ _ _ _ _ _ _ _
- _ __
.
'
'
TASLE C-2.
(continued)
(
4
'
Number of LERs with
Deficiencies and
Observations
'
Sub-paragraph
Paragraph
f
Description of Deficiencies and Observations
Totals *
_ Totals (
)
Abstract presentation inadequacies
10 (15)
,
a.
085ERVATION: The abstract contains
3
inforr.ation not included in the text.
2
The abstract is intended to be a
,
summary of the text, therefore, the
text should discuss all information
,
'
4
summarized in the abstract.
t
b.
The abstract was greater than
0
4
1400 characters
c.
The abstract contains undefined
0
acronyms and/or plant specific
designators.
d.
The abstract contains other specific
9
,
i
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
j
necessarily add up to the paragraph total,
i
b.
The " paragraph total" is the number of LERs that have one or more
'
"
deficiency or observation.
The number in parenthesis is the number of LERs
,
for which a certain requirement was considered applicable.
I
i
'
1
!
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!
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I
i
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l
1
I
I
C-8
i
!
t
1
.
-
- - -
-
-
-
-
.
.
_
.
.
'
TABLE C-3.
C00E0 FIELOS Off!CIENCIES AND 08SERVATIONS FOR VERN0NT YAMEE
Number of LERs with
,
Deficiencies and
,_
Observations
Sub-paragraph
Paragraph
Description of Deficiencies and Observations
Totals *
Totals (
)
facility Name
0 (15)
a.
Unit number was not included or
incorrect.
b.
Name was not included or was
incorrect.
c.
Additional unit numbers were included
i
but not required.
Docket Number was not included or was
0 (15)
incorrect.
Page Number was not included or was
1 (15)
incorrect.
Title was left blank or was inadequate
14 (15)
4.
Root cause was not given in title
12
b.
Result (effect) was not given in title
2
c.
Link was not given in title
7
Event Date
1 (15)
4.
Date not included or was incorrect.
O
b.
Olscovery date given instead of event
I
date.
LtR Number was not included or was incorrect
0 (15)
Report Date
1 (15)
4.
Date not included
0
b.
OSSERVATION: Report date was not
I
within thirty days of event date (or
discovery date if appropriate).
Other facilities information in fleid is
0 (15)
inconsistent with text and/or abstract.
Operating Mode was not included or was
1 (15)
inconsistent with text or abstract.
C-9
-
-
-
- -
- - _ - - _ _ _ _ _
.
.
TA8tE C-3.
(continued)
Number of LERs with
Deficiencies and
Observations
Sub-paragraph
Paragraph
Description of Deficiencies and Observations
Totals'
Totals (
l
Power level was not included or was
0 (15)
inconsistent with text or abstract
l
Reporting Requirements
2 (15)
a.
The reason for checking the "0THER"
0
requirement was not specified in the
abstract and/or text.
b.
08SERVATION:
It may have been more
0
appropriate to report the event under
,
a difforent paragraph.
-
1
c.
08SERVATION:
It may have been
2
appropriate to report this event under an
additional unchecked paragraph.
t
e
Licensee Contact
2 (15)
!
'
4.
Fleid left blank
0
.
b.
Position title was not included
2
l
l
c.
Name was not included
0
!
d.
Phone number w,ts not included.
0
l
'
Coded Compor.ent f ailure Information
1 (15)
!
F
f
a.
One or more component failure
0
sub-fields were left blank,
r
b.
Cause, system, and/or component code
0
is inconsistent with text.
c.
Component failure ftold contains data
0
,
when no component failure occurred.
.
!
d.
Component failure occurred but entire
I
t
t
fleid left blank.
,
1
i
!
i.
f
j
I
!
T
C-10
t
l
'
t
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
_____
,
..
.
'
TABLE C-3.
(continued)
l
Number of LERs with
Deficiencies and
l
Observations
.
Sub-paragraph
Paragraph
l
Description of Deficiencies and Observations
Totals'
Totals (
)
Supplemental Report
2 (15)
a.
Neither "Yes"/"No" block of the
0
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
l
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.
l
b.
The " paragraph total" is the number of LERs that have one or more
>
l
requirement deficiencies or observations.
The number in parenthesis is the
number of LERs for which a certain requirement was considered applicable.
!
l
1
l
,
1
,
l
C-11
-.
_ - -
- _ . . . _ - . . - _ _ _ - . _ _ _ _ - - . . - - .
_
- _ - _ _
. -
. . . - - -
-
- - .
- . - -
O
e
e
APPENDIX 0
LER COMMENT SHEETS FOR
VERMONT YANKEE
.
.
.
TA8LE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
1.
LER Number: 85-009-00
Scores: Text - 7.1
Abstract - 6.6
Coded Fields - 8.3
Overall = 7.1
Text
1.
50.73(b)(2)(11)(q1--Date/ time information for major
occurrences is inadequate.
This information needs to
be provided for major occurrences throughout the
event (e.g., times for repairs and return of the
plant to a safe and stable condition).
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)(11)(J)(2)--It appears that personnel
error is involved in this even'., but it is not
discussed. Why were the shorting links removed and
why had the drain valves been left partially open?
4.
50.73(b)(3)--Discussion of the assessmen* of the
safety consequences and implications of the event is
inadequate.
OBSERVATION: The' consequences of the
event had it occurred under more severe conditions
should be discussed.
If the event occurred under
what are considered the most severe conditions, the
text should so state.
5.
50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate. Were the shorting links
reinstalled and the design change completed? Are
actions such as improving the review process,
sufficient to prevent a similar event in the future?
6.
Acronym (s) and/or plant specific designator (s) are
undefined.
RPS, SRM, and HCU should be defined.
Abstract
1.
10.73(b)(11--Summary of root cause is not included.
2.
50.73(b)(11--Summary of corrective actions taken or
planned as a result of the event is inadequate (see
text comment 5).
0-1
.
.
-
..
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
1.
LER Number: 85-009-00 (continued)
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 is not included and the
result is incomplete. A more appropriate title might
be " Inadvertent Scram Signal and Contaminated Water
Leak While Implementing a Design Change Due to
Personnel Error". The personnel error is an
assumption based on the missing shorting links and
partially open valves (see text comment 3).
2.
Item (9)--Operating mode is not included.
,
i
a
i
0-2
,
.
. _.
.
--- .
.
.- ._ _.
_ . _ - . . _ .
____ . _ _ _ _ _
!
.
.
.
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
2.
LER Number: 85-010-00
Scores:
Text - 7.6
Abstract - 8.8
Coded Fields - 8.5
Overall - 8.0
Text
1.
50.73(b)(2)(ii)(C)--Approximate date information for
the return to service of the affected penetrations is
not included.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate
cause discussion concerning the penetration
conduction installation error is inadequate. Was the
error a design error, procedure error, or cognitive
personnel error?
3.
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.
4.
50.73(b)(2)(ti)(J)(2)--Discussion of the personnel
error is inadequate.
50.73(b)(2)(11)(J)(2)(1)--Discussion as to whether
the personnel error was cognitive or procedural is
not included.
5.
50.73(b)(2)(ii)(L)--Identification (e.g.,
manufacturer and model no.) of the failed
component (s) discussed in the text is inadequate.
Abstract
1.
50.73(b)(1)--Summary of root cause (personnel error)
is inadequate.
See text comment numbers 2 and 4.
Coded Fields
1.
Item (4)--Title:
Root cause (personnel error) and
link (inspection) are not included. A more suitable
title might be:
"Drywell Electrical Penetration
Conductors Found During Inspection With Degraded
Insulation Caused by Personnel Installation Errors."
2.
Item (131--Component failure occurred but entire
field is blank.
D-3
.
.
-
.
.
,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
!
,
Section
Comments
3.
LER Number: 85-012-00
Scores: Text - 7.6
Abstract - 8.2
Coded Fields - 8.5
Overall - 7.9
Text
1.
50.73(b)(2)(11)(C)--Time information for major
occurrences is inadequate. When were the Toxic Gas
Monitors and the Control Room Habitability System
reset (e.g. time)?
2.
50.73(b)(2)(11)(D)--The root and/or intermediate
cause discussion concerning the freon being drawn
into the air intake is inadequate. Given that there
have been no similar events, is this the first time
that freon has been purged from the air. conditioning
units or, if not, was there some other condition
(such as a strong wind) that contributed to the event?
3.
50.73(b)(2)(11)(F)--The Energy Industry
Identification System component function
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
4.
50.73(b)(4)--01scussion of corrective actions taken
or planned is inadequate. The corrective measures
that are to be taken to prevent recurrence of this
event are not discussed.
5.
Acronym (s) and/or plant specific designator (s) are
undefined. What is the significance of "(R-22)"?
Abstract
1.
See text comment number 2.
2.
See text consent 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: Cause and link are not included. A
better title would be, " Freon Gas Purged from An Air
Conditioner Enters Control Room Air Intake Resulting
In Control Room Habitability System Actuation Via The
Toxic Gas Monitors".
0-4
.
.
,
a
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
4.
LER Number: 86-001-00
Scores: Text - 9.3
Abstract - 9.5
Coded Fields - 8.9
Overall = 9.3
Text
1.
50.73(b)(2)(11)(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.
.
2.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of
3
personnel involved (i.e., contractor personnel,
utility licensed operator, utility nonlicensed
operator, other utility personnel) is inadequate.
Abstract
1.
No comment.
Coded Fields
1.
Item (31--The page number on the third page is
incorrect.
2.
Item (4)--Title:
Root cause is not included.
'
3.
Item (ll)--0BSERVATION:
It appears it would have
been appropriate to also report this event under
i
paragraph (s) 50.73(a)(2)(i).
!
l
l
l
!
i
,
D-5
-.
.
.
.
,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
5.
LER Number: 86-002-00
Scores:
Text = 9.3
Abstract = 6.5
Coded Fields = 9.0
Overall = 8.4
Text
1.
50.73(b)(2)(11)(A)--Discussion of plant operating
conditions before the event is inadequate. Was the
outage for refueling?
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.
Abstract
1.
50.73(b)(1)--Summary of personnel errors is
inadequate. Which personnel were involved? What was
the reason for the nonconservative calculations?
2.
50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. What
replacement material was planned? When was the
replacement scheduled?
3.
Additional space is available within the abstract
field to provide the necessary information but it was
not utilized.
The discovery date is not included.
Coded Fields
1.
Item (4)--Title:
Root cause (personnel calculation
errors) is not included.
l
l
l
l
l
!
0-6
!
--
.- .
.-
-- -- --, . ---
_. --
. - - _
.
.
!
l
..
.
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
6.
LER Number: 86-003-00
Scores:
Text - 9.3
Abstract - 8.6
Coded Fields - 9.0
Overall - 9.1
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.
2.
50.73(b)(2)(11)(L)--The text does not actually state
that the relief valves are Target Rock valves.
3.
A logical transition does not exist between all
ideas. Some ideas are not presented clearly (hard to
follow).
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 performance of the valves will continue
to be tracked / evaluated was not mentioned in the
abstract.
2.
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:
Cause and link are not included. A
better title might be, "During Technical
Specification (T.S.) Required Test Two Main Steam
Relief Valves Actuated Above Their T.S. Setpoint--
i
Cause Is Steam Cuts On Pilot Disc and Seat".
2.
Item (11)--Given the information provided in the
j
" Analysis of Event", it is not clear why this event
was reported under requirement 50.73(a)(2)(v).
3.
Item (13)--Only one line need have been filled in.
l
l
0-7
i
_
__.
- -_
-
_ _ _
_
.- - - - - -
.
- - - - - - -
.
_
.
.
_ _ _ . _ _ _ .
._
_ _ _ _
.
.
- . ..
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
7.
LER Number: 86-004-00
Scores:
Text - 9.2
Abstract - 6.7
Coded fields - 7.6
Overall - 8.3
Text
1.
50.73(b)(2)(11)(F)--The Energy Industry
Identification System component function
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
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. A
unique identification, such as a model number, was
not given for the Conax trigger assembly.
Abstract
1.
50.73(b)(11--Summary of corrective actions taken or
,
]
planned as a result of the event is not included.
2.
OBSERVATION: The abstract contains information not
included in the text. The abstract is intended to be
a summary of the text; therefore, the text should
discuss all information summarized in the abstract.
The last sentence of the abstract is not mentioned in
the text.
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 (manufacturing error)
and result (inoperable Standby Liquid Control system)
,
are not included.
i
2.
Item (5)--Discovery date is given instead of event
date. A discovery date is only supposed to be given
when the event date is not known. The event was
known to have taken place in August of 1984, so an
estimated event date of August 15, 1984 could be used
or conservatively August 1, 1984.
In either case,
the text could explain the uncertainty in the date
given.
Further, a more appropriate discovery date
would appear to be February 8, 1986.
i
1
i
D-8
,
--. - -
.. -
- - - - ..
-
_ .- . . _ - - _ - .
_
- _-.
.
_ _ _ .
_
_
.
.
..
, ,
.
,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
7.
LER Number:
86-004-00 (continued)
3.
Item (ll)--0BSERVATION:
It appears it would have
been appropriate to also report this event under
paragraph (s) 50.73(a)(2)(1) and 50.73(a)(2)(vii).
t
II
D-9
I
.
_
.
- -.
,
.
.____ .- _-- .-
.- ..
__-
. - .
-
.
.
..
.
,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
8.
LER Number: 86-005-00
Scores: Text - 8.9
Abstract - 6.9
Coded Fields - 8.5
Overall - 8.3
Text
1.
50.73(b)(2)(ii)(C)-- Approximate date information for
major occurrences is not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry
Identification System component function
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
Abstract
1.
50.73(b)(1)--Summary of occurrences [immediate
cause(s) and effects (s)) is inadequate. Discussion
of the impact of the weld flaws on structural
integrity is not included.
2.
50.75(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate.
Discussion of the planned inspections is not included.
3.
OBSERVATION:
The abstract contains information not
included in the text.
The abstract is intended to be
a summary of the text; therefore, the text should
discuss all information summarized in the abstract.
The NRC Information Notice 84-41 is not mentioned in
the text.
4.
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 (intergranular stress
corrosion cracking) and link (ultrasonic inspection)
are not included.
D-10
.
.-.
-
--
-
.
.
_
--
-
-
-
--
,
.,
.
, . , .
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
9.
LER Number:
86-007-00
Scores: Text = 7.6
Abstract = 6.3
Coded Fields - 9.7
Overall = 7.4
Text
1.
50.73(b)(2)(11)(A)--Discussion of plant operating
conditions before the event is inadequate.
Plant
conditions such as operating mode or reactor
temperature and pressure are not provided.
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)(3)--Discussion of the assessment of the
safety consequences and implications of the event is
inadequate.
It appears that T.S. 4.7.2
(10 CFR 50 Appendix J) and whatever T.S. that allows
reactor operation with leakage up to 0.8 wt. %/ day
L
are in conflict.
If the containment leakage was in
excess of that permitted by T.S. 4.7.2, hcw can there
be no potential adverse effects and how can another
T.S. say reactor operation is allowed with leakage
greater than that permitted by T.S. 4.7.2?
.
4.
50.73(b)(4)--Discussion of corrective actions taken
or planned is inadequate.
If the cause of the manway
bolts loosening is due to thermal expansion / cycling
over time, why is the long term corrective action
(number 2) tied to the removal /re-installation of the
drywell head? Is head removal /re-installation always
performed frequently enough to ensure the manway
bolts will not loosen between head removal?
l
S.
Some ideas are not presented clearly (hard to follow).
l
Abstract
1.
50.73(b)(1)--Summary of local leakage sources (cause)
'
is inadequate. The drywell head manway cover problem
should have been discussed.
2.
50.73(b)(11--Summary of corrective actions taken or
planned as a result of the event is inadequate.
The
corrective actions taken to prevent recurrence are
not presented in the abstract.
D-11
,..
-.
. . . . .
.
.
- - - - -
.
-_
._-
.
--.
. - . -
_
-
i
.
.
.
, . . .
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
9.
LER Number:
86-007-00 (continued)
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.
4.
The last three sentences of the first paragraph of
the abstract are not needed.
Information concerning
the measured leakage would have been appropriate here.
Coded Fields
1.
Item (4)--The title could have indicated that there
were numerous identified leakage paths.
D-12
.
.
,, .
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
10. LER Number: 86-008-00
Scores: Text - 7.6
Abstract - 7.0
Coded Fields - 8.9
Overall - 7.6
Text
1.
50.73(b(2)(11)(0)--Deta11s as to how improper
movement of the mode switch caused the scram were not
included.
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)(ii)(J)(2)(1)--Discussion as to whether
the personnel error was cognitive or procedural is
not included.
4.
50.73(b)(3)--A discussion as to whether or not a
similar response could occur under more severe
conditic,s was not included.
If the event occurred
under what are considered the most severe conditions,
the text should so state.
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 not included.
Coded fields
1.
Item (4)--The root cause is inadequately stated and
the link is not included. A more appropriate title
might be " Unanticipated Scram During Surveillance
Testing Due to Improper Mode Switch Moveinent
l
(Personnel Error)".
l
0-13
.
_
-
-
. _ _ . -
.
,
.
, ..
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YAhXEE (271)
Section
Comments
11. LER Number: 86-009-00
Scores:
Text - 9.1
Abstract - 8.1
Coded fields - 8.0
Overall - 8.7
Text
1.
50.73(b)(2)(11)(C)--Approximate date and time for the
return to service is not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry
Identification System component function
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
3.
50.73(b)(2)(ii)(I)--Discussion of the method of
discovery of the check valve leakage is not included.
4.
Discussion of the function of the steam relief valve
system is excellent. The event is presented in a
well-outlined format.
Abstract
1.
50.73(b)(1)--Summary of the root cause (dirt source)
is not included.
2.
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 (dirt from air supply)
is not included.
An acronym, SRV, is present in the
title.
Acronyms should be avoided in a title unless
space is a problem.
2.
Item (71--0BSERVATION: Report date is not within
thirty days of event date (or discovery date if
appropriate).
3.
Item (ll)--Was the accumulator check valve leakage a
,
!
violation of a Technical Specification?
l
!
D-14
!
_- -
_.
.-.
_
. . - -
.
--.. -.
.
-
.
._
_
. - . . - . . _
_.
_
.
a
. . . .
,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
12.
LER Number: 86-010-00
Scores: Text = 7.6
Abstract - 7.8
Coded fields = 9.8
Overall - 7.9
Text
1.
50.73(b)(2)(11)(A)--Discussion of plant operating
conditions before the event is inadequate.
It would
be helpful to the reader to know more than just "the
plant was shutdown" (e.g., the operating mode).
2.
50.73(b)(2)(11)(D)--The root and/or intermediate
cause discussion concerning the shorted coil is
inadequate. Given that the failure is attributed to
end of coil life, it would be good to provide
infoimation concerning how long the coil has been
installed.
3.
50.73(b)(2)(li)(F)--The Energy Industry
Identification System component function
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
4.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions
t!'at affected the course of the event is inadequate.
It is not explicitly stated in the text how the
electrician's actions (pulling the cover from the
distribution panel) contributed to the event.
The
abstract does present this information, however.
5.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or
manual safety system responses is inadequate. All
safety systems that " functioned as designed" should
be named.
6.
50.73(b)(31--Discussion of the assessment of the
safety consequences and implications of the event is
inadequate. The " Analysis of Event" section states
that there were no adverse safety consequences from
this event since the reactor was in a shutdown
condition at the time of the event. What would have
been the adverse safety consequences had the reactor
not been shutdown? Given that the indications are
that other coils may reach end of life soon is there
any increased risk. Are all coil failures of this
type fail safe?
,
7.
A logical transition does not exist between all ideas.
D-15
--
.
-
-
.
- . -
-
-.
_.
-
- - -
.
o
o
, _ . ,
TABLE D-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
12.
LER Number: 86-010-00 (continued)
Abstract
1.
50.73(b):11--Summary of system response is
inadequa ;e.
If any safety systems actuate this
information would be good to include in the abstract.
2.
50.73(b)(11--Summary of cause information.is
inadequate. The fact that the coil failure was
attributed to end of life should be mentioned.
3.
50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
fact that all similar contactors within the A and B
RPS panels were inspected and found to have no
similar type problems should be mentioned. Are there
other similar contactors in other safety systems, as
well?
4.
OBSERVATION: The abstract contains information not
included in the text.
The abstract is intended to be
a summary of the text; therefore, the text should
discuss all information summarized in the abstract.
See text comment number 4.
5.
The abstract is written in a mach more logical
sequence of ideas than is the text.
Coded Fields
1.
Item (4)--The title should indicate that the broken
armature " caused a relay to drop out".
D-16
-.
-
-.-
__ . .
_
- . _ _ . ._
__
_ . _ _ _ _ _
_
_
~
_ ___ _ . _ .
s
-
,
.. .
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
13. LER Number: 86-011-00
Scores: Text - 7.6
Abstract - 8.1
Coded Fields - 8.3
Overall - 7.8
,
Text
1.
50.73(b)(2)(11)(C)--Date/ time information for major
occurrences is inadequate. When were the immediate
corrective actions taken, and when are the additional
corrective actions expected to be completed?
2.
50.73(b)(2)(ii)(D)--Was the source of the noise in
the IRM circuitry identified?
3.
50.73(b)(2)(11)(F)--The Energy Industry
.
Identification System component function
'
identifier (s) and/or system name code of each
component or system referred to in the LER is not
included.
4.
50.73(b?(4)--Could anything be done to reduce noise
in the LRM circuitry (see text comment 2)? A
supplemental report appears to be needed to describe
the results of the engineering evaluation into the
RPS power supply.
Abstract
1.
50.73(b)(1)--Summary of root cause is inadequate.
The reason for the half scram due to RPS voltage
instability was not included (i.e., the recirculation
pump start causing an undervoltage condition).
2.
50.73(b)(1)--Summary of corrective actions taken or
planned as a result of the event is inadequate. The
engineering evaluation was not mentioned.
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 causes (undervoltage condition
and noise) are not included.
2.
Item (14)--The block checked is inconsistent with
information in the text (see text comment 4).
l
D-17
. - -
-
--
. i , 4
. . .
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
14. LER Number: 86-012-01
Scores: Text = 9.2
Abstract = 9.8
Coded Fields = 9.9
Overall = 9.5
Text
1.
50.73(b)(2)(ii)(C)--Approximate date and time for
return to service information for major occurrences
is not included.
2.
50.73(b)(2)(ti)(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.
3.
Acronym (s) and/or plant specific designator (s) are
undefined.
Abstract
1.
No comments.
Coded Fields
1.
Item (12)--Position title on Revision 1 is not
included.
1
0-18
- .-
-
-
_ _ _
-
.
m
, . . ,
. . .
,
TABLE 0-1.
SPECIFIC LER COMMENTS FOR VERMONT YANKEE (271)
Section
Comments
15. LER Number: 86-013-00
Scores:
Text - 9.7
Abstract - 10.0
Coded Fields - 9.2
Overall - 9.7
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.
2.
50.73(b)(4)--If the results of General Electric's
analysis of cause provide any new information or
result in any additional corrective actions, a
supplemental report should be submitted that provides
this information.
3.
The use of the diagram is a good practice for events
that are difficult to explain.
Abstract
1.
No comments.
Coded Fields
1.
Item (4)--The title could have included the phrase
"during start up".
'
2.
Item (12)--Position title is not included.
3.
Item (14)--The block checked is inconsistent with
information in the text.
See text comment number 2.
,
'
0-19