ML20212Q957

Forwards AEOD SALP Input Re LERs for Jul 1985 - Dec 1986. Improvement Found in LERs After Outline Format Put Into Use. Principal Weaknesses Identified Involve Requirements to Discuss Safety Consequences of Event & Personnel Error

ML20212Q957
Person / Time
Site:	Hatch
Issue date:	01/20/1987
From:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	James O'Reilly GEORGIA POWER CO.
References
NUDOCS 8702020431
Download: ML20212Q957 (55)

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January 20, 1987 Docket Nos. 50-321, 50-366 License Nos. DPR-57, NPF-5 Georgia Power Company ATTN: Mr. James P. O'Reilly Senior Vice President-Nuclear Operations P. O. Box 4545 Atlanta, GA 30302 Gentlemen:

The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AE0D) has recently completed an assessment of your Licensee Event Reports (LERs) for Hatch 1 and 2 as a part of the NRC's Systematic Assess-ment of Licensee Performance (SALP) program. This assessment was performed to support a SALP period of July 1,1985, to December 31, 1986, and is being forwarded at this time for your use and information in order to pattern future -

submittals.

In general, AE0D found an improvemant in the Hatch LERs after an outline format was put into use. A strong point for the Hatch LERs is that information concerning the failure mode, mechanism, and effect of failed components is discussed very well. The principal weaknesses identified in the Hatch LERs involve the requirements to discuss the safety consequences of the event, to discuss personnel error, and to adequately identify failed components in the text. These findings are based on the requirements contained in 10 CFR 50.73.

Please let us know if you have any questions.

Sincerely, Original Signed by Luis A. Reyes /for Roger D. Walker, Director Division of Retetor Projects

Enclosure:

AE00 SALP Input for Hatch 1 and 2 cc w/ encl:

J. T. Beckham, Vice President, Plant Hatch H. C. Nix, Site Operations General Manager A. Fraser, Acting Site QA Supervisor L. Gucwa, Manager, Nuclear Safety and Licensing ,

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bec w/ encl: (see page 2) lM" Ben Egeg,J PDR IE H o

,s Georgia Power Company 2 January 20, 1987 bcc w/ encl:

NRC Resident Inspector Hugh S. Jordan, Executive Secretary Document Control Desk State of Georgia R. Croteau, DRP bcc w/o encl:

F. S. Cantrell C. J. Paulk R RII (_ RII CPaulk KL n is FCantrell 01/si/87 01/ \1 87 01/J/87

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ENCLOSURE AE00 SALP INPUT FOR HATCH 1,2 OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF July 1,1985 to December 31. 1986*

SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Hatch 1 and 2 during the July 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. The results of this evaluation indicate that the Hatch LERs have an overall average LER score of 8.5 out of a possible 10 points, compared to a current industry average

score of 8.2 for those unit / stations that have been evaluated to date using this methodology.

The principle weakness identified in the Hatch LERs involve the i requirements to discuss the safety consequences of the event

! [ Requirement 50.73(b)(3)], to discuss personnel error [ Requirement 50.73(b)(2)(11)(J)(2)] and to adequately identify failed components in the text [ Requirement 50.73(b)(2)(ii)(L)]. Deficiencies in the safety assessment discussions prompt concern about whether or not the potential consequences of each event are being identified and evaluated. The failure to discuss personnel error prompts concern about whether or not sufficient investigation into the cause is being made to ensure implementation of adequate corrective actions. The failure to adequately identify each component that fails prompts concern that possible generic problems may not be identified in a timely manner.

A strong point for the Hatch LERs is that the information concerning I the failure mode, mechanism, and effect of failed components is discussed very well. In addition, it should be noted that Hatch started submitting LERs using an outline format early in 1986, and those LERs submitted using j the outline have an overall average that is approximately a full point higher than those LERs submitted early in the SALP period (i.e., 8.9 vs. 7.8).

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AE00 INPUT TO SALP REVIEW f0R HATCH 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Hatch 1 and 2 during the July 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. The sample consists of 15 LERs (i.e.,

9 LERs for Hatch 1 and 6 for Hatch 2). The Hatch LERs were evaluated as one sample for this SALP period because it was determined that their LERs are both written and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in the sample.

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

Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the 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.

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

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

Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such 2

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l represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of '

10 CFR 50.73(b) and the guidance presented in NUREG-1022 and its

, supplements. Again,, Hatch LERs were evaluated as one sample, rather than two separate samples (by units), because it was determined that the Hatch ,

LERs are both written and formally reviewed at the station, rather than the unit, level. '

Table 1 presents the average scores for the sample of LERs evaluated for the station. In order to place the scores provided in Table 1 in perspective, the distribution of the overall average score for all units / stations that have been evaluated using the current methodology is provided in Figure 1. Additional scores are added to figure i 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, Hatch's average score for the text of the LERs that were evaluated is 8.2 out of a possible 10 points. From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation. The percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the station for the 15 LERs that were evaluated.

Discussion of Specific Deficiencies l

t l A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in i preparing LERs. For example, requirement percentage scores of less than 75 l

indicate that the station probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic requirement but has either: (1) excluded certain less significant information from most of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The station should review the LER specific comments presented in Appendix D in order to 3

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• a TABLE 1.

SUMMARY

OF SCORES FOR HATCH 1,2 Average High Low Text 8.2 9.7 4.2 Abstract 8.9 10.0 6.2 Coded Fields 9.1 10.0 7.5 Overall 8.5 9.7 4

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

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__-__. . - _ . _ _ . - - __ _--___--__._y.. . . , _ . _ _. . - _ .,--_-.7- . __, ,__,,~,.--.--~w y~. - - . - +

Figure 1. Distribution of overall average LER scores 12 ...,,,..,,,,,,i. ..i...,i... i....

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.O 9- Hatch 1, 2 y

8-3 7-h 6-o 5-4-

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h 3-Z o sl , o, a,, ,,i, , l, , i, , a, , l,,1,l,: 1, ,

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9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 .

Overall average scores i- - - - - - - - - - - - - - - - - - ___ -------_ _ --- _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _

l TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR HATCH 1,2 TEXT Percentage a

Requirements [50.73(b)] - Descriptions Scores ( )

(2)(ii)(A) - - Plant condition prior to event 100 (15)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate time (s) 97 (15)

(2)(ii)(D) - - Root cause and intermediate cause(s) 87 (15)

(2)(ii)(E) - - Mode, mechanism, and effect 94 (10)

(2)(ii)(F) - - EIIS codes 23 (15)

, (2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 100 ( 3)

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

(2)(ii)(J)(1) - Operator actions affecting course 100 ( 3)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 69 ( 4)

(2)(ii)(K) - - Safety system responses 90 (10)

(2)(ii)(L) - - Manufacturer and.model no. information 67 (10)

(3) - - - - - - Assessment of safety consequences 61 (15)

(4) - - - - - - Corrective actions 85 (15)

(5) - - - - - - Previous similar event information 90 (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 (10)

- Root cause information 82 (15)

- Corrective action information 90 (15)

- Abstract presentation 82 (15) 6

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TABLE 2. (continund)

CODED FIELDS l l

Percentage a

Item Number (s) - Descriptions Scores ( )

1, 2, and 3 - Plant name(unit #), docket #, page #s 100 (15) 4------ Title 74 (15) 5, 6, and 7 - Event date, LER no., report date 97 (15) 8------ Other facilities involved 100 (15) 9 and 10 --

Operating mode and power level 100 (15) 11 -----

Reporting requirements 100 (15) 12 -----

Licensee contact information 100 (15) 13 -----

Coded component failure information 87 (15) 14 and 15 - - Supplemental report information 87 (15)

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

(Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.

b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It in always given 100%

if it is provided and is.always considered "not applicable" when it is not.

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determine why it received less than a perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance. In addition, the primary deficiencies in the abstract and coded fields are discussed.

The safety assessments, Requirement 50.73(b)(3), for nine of the LERs were missing or were considered to be inadequate or marginal. A detailed safety assessment is required in all LERs and should include information such as:

1. An assessment of the consequences and implications of the event including specifics as to why it was concluded that there were "no safety consequences", if applicable. It is inadequate to state "this event had no safety consequences or implications" without explaining how that conclusion was reached.

2. A safety assessment should discuss whether the event could have occurred under a different set of conditions where the safety implications would have been more severe. If the conditions q during the event are considered the worst probable, the LER should so state.

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3. Finally, a safety assessment should name other systems (if any) that were available to perform the function of the safety systems that were unavailable during the event.

l Providing information relevant to these three items should ensure that the safety aspects of the event are adequately discussed and will provide justification for the statement made in several LERs that "the health and safety of the public were not affected."

four LERs appear to involve personnel or procedural errors

[ Requirement 50.73(b)(2)(11)(J)(2)] and of these four LERs, three were found to have a deficiency. There were two failures to provide enough detail (i.e., root cause) for the procedural or personnel error and two instances where the type of personnel involved were not adequately 8

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identified. This requirement is closely linked to root cause determination which, if not adequately discussed, makes it difficult to determine whether the corrective actions taken to prevent recurrence are appropriate.

The manufacturer and/or model number (or other unique identification) was not provided in the text of four of the ten LERs that involved a component failure, Requirement 50.73(b)(2)(11)(L). Components that fail should be identified in the text so that others in the industry will be aware of potential problems. An event at one station can of ten lead to the identification of a generic problem that can be corrected at other units or l stations before they experience a similar problem. In addition, although

! not specifically required by the current regulation, it would be helpful to identify components whose design contributed to the event even though the component did not actually fail. .

Thirteen of the LERs did not include all of the required Energy

Industry Identification System (EIIS) codes. Requirement 50.73(b)(2)(11)(F) requires inclusion of the appropriate EIIS code for each system and component referred to in the text. Some of the Hatch LERs included the EIIS codes for the systems but did not include the code for each component.

While the corrective action discussion, Requirement 50.73(b)(4), had an acceptable score (85%), it was noticed that eight of the LERs had some sort of deficiency. Of these eight, five failed to adequately discuss actions needed to prevent recurrence of the event. The text presentation score (82%) was also acceptable, but five of the LERs contained acronyms that were either undefined or were not defined on their first usage.

Additional attention to these two areas could further improve LER scores for Hatch (See Appendix D for specific consents in these areas). It was l also noticed that Hatch started using an outline format for the text discussion part way through the SALF period. This resulted in a significant improvement in LER quality; however, the full effect of this improvement will not be seen until the next SALP period when all the LERs selected for review are expected to use the outline format.

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While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), the guidance presented in NUREG-1022, i Supplement No. 2 says 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 Causes 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.

Hatch had average or above scores for all of the above items. Two items, however, could be improved by more thoroughly summarizing the text discussion; the root cause for eight LERs and the corrective actions for six LERs were not adquately sununarized in the abstract.

l The main deficiency in the area of coded fields involves the title, Item (4). Ten of the titles failed to indicate the root cause, four failed

! to adequately indicate the result (i.e., why the event was required to be reported), and three failed to include the link between the cause and the result. While the result is conidered the most important part of the title, the lack of cause information (and link, if necessary) results in an incomplete title. An example of a title that only addresses the result might be " Reactor Scram". This is inadequate in that the cause and link r

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1 are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title, the reader knows the cause was either personnel or procedural and surveillance testing was the link between the cause and the result.

Example titles are provided in Appendix 0 (Coded Fields section) for some of the titles that are considered to be deficient.

Table 3 provides a summary of the major areas that eed improvement for the Hatch LERs. For more specific information concerning additional deficiencies, the reader should refer to the information presented in Appendices C and D. General guidance concerning requirements can be found in NUREG-1022, Supplement No. I and 2.

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR HATCH LERs Areas Comments Safety assessment information All LERs should include a detailed safety assessment. The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstances and provide information as to which backup systems were available to limit the consequences of the event.

Personnel error All LERs should include a complete discussion of personnel and/or procedural errors and the type of personnel involved.

Manufacturer and model number Component identification information information should be included in the text whenever a component fails.

Likewise, (although not l

specifically required by the current regulation) it would also be helpful to provide identification information whenever a component is suspected of contributing to the event because of its design.

EIIS codes Codes for each component and system referred to in the text should be provided.

Coded fields

a. Titles Titles need to be written such that they better describe the event.

This can be accomplished by including the root cause, result.

and the link between them in each title.

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REFERENCES

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

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

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

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR HATCH 1,2

TABLE A-1. LER SAMPLE SELECTION FOR HATCH 1,2 Sample Number Unit Number LER Number Comments 1 1 85-027-00 SCRAM 2 1 85-045-00 3 1 85-046-01 ESF 4 1 86-009-00 ESF 5 1 86-014-00 6 1 86-019-00 7 1 86-023-00 SCRAM 8 1 86-033-00 SCRAM 9 1 86-038-00 10 2 85-020-01 ESF 11 2 85-030-00 SCRAM /ESF 12 2 86-006-00 13 2 86-010-00 SCRAM 14 2 86-017-00 ESF 15 2 86-020-00 i

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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR HATCH 1,2

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1 TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR HATCH 1,2 a

LER Sample Number 1 2 3 4 5 6 8

________________________________________________________________7 ___________

Text 7.6 4.2 8.7 7.7 9.6 9.2 8.1 9.7 Abstract 8.2 6.2 8.5 9.1 10.0 9.7 9.0 9.3 Coded Fields 8.3 7.8 9.0 9.4 10.0 9.0 S.2 9.5 Overall 7.9 5.2 8.7 8.3 9.7 9.3 8.5 9.6 a

LER Sample Number 9 10 11 12 13 14

_________________________________________________________________________ge15 Avera Toxt 8.8 7.5 8.8 7.5 8.8 9.6 6.8 8.2 Abstract 9.2 8.8 8.7 7.6 9.3 9.6 9.5 8.9 Coded Fields 8.9 7.5 9.0 9.5 9.7 9.7 9.7 9.1 Overall 8.9 7.9 8.8 7.7 9.1 9.6 7.9 8.5

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

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l APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR HATCH 1,2

TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR HATCH 1,2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations. b Totals # Totals ( l 50.73(b)(2)(ii)(A)--Plant operating 0 (15) conditions before the event were not included or were inadequate.

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

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

a. Date information was insufficient. 1

b. Time-information was insufficient. 1 50.73(b)(2)(11)(0)--The root cause and/or 5 (15) intermediate failure, system failure, or personnel error was not included or was inadequate.

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

b. Cause of system failure was not 1 included or was inadequate

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

50.73(b)(2)(1))(Ei--Tnc failure mode, 1 (10) mechanism (immediate cause), and/or ef fect (consequence) for each failed component was not included or was inadequate.

a. Failure mode was not included or was 1 inadequate

b. Mechanism (immediate cause) was not 0 included or was inadequate

c. Effect (consequence) was not included 0 or was inadequate.

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TABLE C-1. (continued)

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

50.73(b)(2)(11)(F)--The Energy Industry 13 (15)

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

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

50.73(b)(2)(11)(H)--For a failure that 0 ( 3) rendered a train of a safety system inoperable, the estimate of elapsed time ,

4 from the discovery of the failure until the train was returned to service was not included.

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

a. Method of discovery for each component failure was not included or was inadequate

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

c. Method of discovery for each personnel error was not included or 3 was inadequate

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

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TABLE C-1. (continued)

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

50.73(b)(2)(ii)(J)(1)--Operator actions that 0 ( 3) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(b)(2)(ii)(J)(2)--The discussion of 3 ( 4) each personnel error was not included or was inadequate,

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

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

c. 50. 73 ( b ) ( 2 ) ( i i ) ( J ) ( 2 ) ( i i ) --01 s c u s s i on 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 )( i i i )--D i s cus s ion 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 ) ( i i ) ( J ) ( 2 )( i v )--D i s c us s i on 2 of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.

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TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations ,

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

50.73(b)(2)(ii)(K)--Automatic and/or manual 3 (10) safety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 4 (10) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 9 (15) consequences and implications of the event was not included or was inadequate.

a. OBSERVATION: The availability of 0 other systems or components capable of mitigating the consequences of the

! event was not discussed. If no other systems or components were available, the text should state that none existed,

b. OBSERVATION: The consequences 1 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should so state.

50.73(b)(41--A discussion of any corrective 8 (15) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.

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. i TABLE C-1. (continued)

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

a. A discussion of actions required to 1 correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.

b. A discussion of actions required to 5 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.

c. OBSERVATION: A discussion of actions 0 required to prevent similar failures in similar and/or other systems (e.g.,

correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.

50.73(b)(5)--Information concerning previous 3 (15) similar events was not included or was inadequate.

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TABLE C-1. (continued)

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

• Totals ( )

50.73(b)(2)(1)--Text presentation 6 (15) inadequacies,

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

b. Text contained undefined acronyms 4

and/or plant specific designators.

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

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

, observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in

the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.

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

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TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR HOPE CREEK 1 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

A sunnary of occurrences (immediate cause 2 (15) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 4 (10) responses was not included or was inadequate.

a. Summary of plant responses was not 3 included or was inadequate.

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

c. Summary of personnel responses was not 0 included or was inadequate.

4 A summary of the root cause of the event 8 (15) was not included or was inadequate.

A summary of the corrective actions taken or 6 (15) planned as a result of the event was not included or was inadequate.

C-7

I l

l TABLE C-2. (continued)

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

Abstract presentation inadequacies 1 (15)

a. OBSERVATION: The abstract contains 0 information not included in the text.

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

b. The abstract was greater than 0 1400 characters

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

d. The abstract contains other specific 1 deficiencies (i.e., poor summarization, contradictions, etc.)

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

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

C-8

. j TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR HATCH 1,2 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.

t

c. Additional unit numbers were included but not required.

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

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

Title was left blank or was inadequate 13 (15)

a. Root cause was not given in title 10

b. Result (effect) was not given in title 4

c. Link was not given in title 3 Event Date 0 (15)

a. Date not included or was incorrect.

b. Discovery date given instead of event date.

LER Number was not included or was incorrect 1 (15)

Report Date 1 (15)

a. Date not included 1

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

Other Facilities information in field is 0 (15) inconsistent with text and/or abstract.

Operating Mode was not included or was 0 (15) inconsistent with text or abstract.

C-9

.- . I TABLE C-3. (continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )

Power level was not included or was 0 (15) inconsistent with text or abstract Reporting Requirements 1 (15)

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

b. OBSERVATION: It may have been more 1 appropriate to report the event under a different paragraph.

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

Licensee Contact 0 (15)

a. Field left blank

b. Position title was not included

c. Name was not included

d. Phone number was not included.

Coded Component Failure Information 3 (15)

a. One or more component failure 1 sub-fields were left blank,

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

c. Component failure field contains data 0 when no component failure occurred.

d. Component failure occurred but entire 1 field left blank.

i C-10

TABLE C-3. (continued)

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

Supplemental Report 3 (15)

a. Neither "Yes"/"Na" block of the O supplemental report field was checked.

b. The block checkr:d was inconsistent 3 with the text.

l

! Expected submission date information is 1 (15) inconsistent with the block checked in j

Item (14),

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

number of LERs for which a certain requirement was considered applicable.

i I

t 4

l 1

1 I l C-11

- ,--ce-a ve m e m -n - -e -- -

w---+- ,-g- n~ g, - - - -------n.,,--,w-. ,,r- ----,-.-----n. .---c-- -e-, -,n..-1;=r--- ee----nm-~n-p----m--g,

APPENDIX 0 LER COMMENT SHEETS FOR HATCH 1,2

. TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

1. LER Number: 85-027-00 4

Scores: Text = 7.6 Abstract = 8.2 Coded Fields - 8.3 - Overall = 7.9 Text 1. 50.73(b)(2)(ii)(D)--More information about the replaced motor brushes on the "8" M/G set should be

, included (i.e., Was the wear considered to be j normal?). Was the large water level drop after the scram considered normal?

2. 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.

3. 50.73(b)(2)(ii)(J)(21--Since the corrective actions

': include a change in the procedure, a possible procedural deficiency is implied but is not discussed.

4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The safety assessment should include those details necessary to justify the conclusion that the health and safety of the public were not 1

affected.

5. 50.73(b)(4)--Is any action necessary to prevent the l M/G brush failures from recurring (see text comment 1). A supplemental report appears to be needed to describe the investigation into increasing j the valve stem size.

l 6. Acronym (s) and/or plant specific designator (s) are undefined. RCIC, LLRT, and M/G should be defined.

1 Abstract 1. 50.73(b)(11--Summary of plant responses is inadequate. The reactor water level and feed pump

problems should be mentioned.

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

1 The failed M/G brushes should be mentioned.

l' 3. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate (see i

text comment 5).

l l

1 0-1 4

- . _ _ _ _._.___s.___ _.y ,_-_.,7.__,.,_,.-_ _.,,_,_.,___..,____._._.,_m_.___, _ , _ , _ _ , _ . ,,,,_..,_,__7,. _ ,

, ~ , , , _ _ _ . , , ,

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

1. LER Number: 85-027-00 (continued)

Coded Fields 1. Item (4)--Title: Root cause is not included. A more appropriate title might be "A Main Isolation Valve Stem Failure (Unintentional Valve Closure) Results in a Reactor Scram".

2. Item (14)--The block checked is inconsistent with 3

information in the text (see text comment 5).

I l

I l D-2 1

TABLE 0-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

2. LER Number: 85-045-00 Scores: Text - 4.2 Abstract - 6.2 Coded Fields - 7.8 Overall - 5.2 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluated as if it were a text.

2. 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the check valve is not included. What caused the check valve failure?

3. 50.73(b)(2)(11)(E)--The component failure ef fect discussion of each failed component is not included.

4. 50.73(b)(2)(11)(K)--01scussion of automatic and/or manual safety system responses is inadequate. What was the LC0 required by Technical Specification? Was the cold shutdown required?

5. 50.73(b)(2)(ii)(t)--Identification (e.g.,

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

6. 50.73(b)(31--01scussion of the assessment of the safety consequences and implications of the event is not included. It is not evident from the discussion how the component failure could have prevented fulfillment of the safety function of a system to control the release of radioactive material.

7. 50.73(b)(4)--01scussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.

8. An apparent typographical error exists with the use of the acronym, "ECFV".

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequa3e. The effect of the check valve failure is not included, i

1 0-3

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

2. LER Number: 85-045-00 (continued)

2. 50.73(b)(11--Summary of the plant response is inadequate. See text comment number 4.

3. 50.73(b)(1)--Summary of the root cause is not included.

4. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeouate. See text coment number 7.

! Coded Fields 1. Item (4)--Title: Root cause (cause of check valve 4

failure) and link (during surveillance are not

! included. -

2. Item (7)--Report date is not included.

l 1

l 9

1 i

l 0-4 l

o TABLE 0-1. SPECIFIC LEA COMMENTS FOR HATCH 1 (321)

Section Comments

3. LER Number: 85-046-01 Scores: Text - 8.7 Abstract - 8.5 Coded Fields - 9.0 Overall - 8.7 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)( ti)(K)--01scussion of automatic and/or manual safety system responses is inadequate. Given that trains "18" and "28" started, its not clear why the Unit 2 reactor building exhaust vent did not close. -

3, 50.73(b)(5)--Information concerning previous sintlar events is inadequate. Given that the cause of the actuation is unknown, more information should have been provided concerning other S86T system actuations (if any).

4. The use of revision bars in the margins is good.

Abstract 1. 50.73(b)(11--The f act that relay 1 A71-KSC was being changed out at the time of the actuation should have been mentioned.

2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should expitcitly state that no corrective actions to prevent recurrence were initiated because the cause could not be determined.

3. Abstract does not adequately summarize the text.

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

Coded Fields 1. Item (41--Title: The fact that the cause was unknown and that the S8GT is an ESF system could have been provided.

0-5

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

3. LER Number: 85-046-01 (continued)

2. Item (14)--It is not apparent from the original reports text or abstract why there was a commitment to a supplemental report.

3. Item (15)--No " expected submission date* was provided in the original report.

1 1

1 1

I 4

0-6 I '

1

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321) ,

Section Comments

4. LER Number: 86-009-00 Scores: Text - 7.7 Abstract = 9.1 Coded Fields = 9.4 Overall - 8.3 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluated as if it were a text.

2. 50.73(b)(2)(11)(D)--When the root cause cannot be found, it is helpful to discuss the actions taken to' i determine the cause.

I

3. 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 j included.

4. 50.73(b)(2)(11)(L)--Although it is not apparent f rom the discussion whether or not the fuse actually failed (a blown fuse due to overcurrent is not a failure since the fuse has performed its intended protection function) it might be helpful to identify the fuse, j

5. 50.73(b)(31--Justification should be given for the conclusion that the health and safety of the public were not affected.

I 6. Acronym (s) and/or plant specific designator (s) are undefined. LOCA should be defined.

Abstract 1. No comment.

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

2. Item (13)--If the fuse actually failed (see text consent 4) this line would be appropriate. Whether

, or not the fuse failed, the system code "80' is not a valid code.

0-7

- ~ . _ _ . _ . - - . . , - - , . - - - . _ . , - - . , , _ , - _ _ , , ,,-

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

5. LER Number: 86-014-00 Scores: Text - 9.6 Abstract - 10.0 Coded Fields - 10.0 Overall 9.7 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. The text is arranged in a well-outlined format.

Discussion of Table 3.7-4 in paragraph 3 of the Corrective Actions section is not clear.

Abstract 1. No comments.

Coded Fields 1. No comments.

D-8

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

6. LER Number: 86-019-00 Scores: Text - 9.2 Abstract - 9.7 Coded fields -9.0 Overall - 9.3 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)(11)(J)(2)--Discussion of the personnel error is inadequate.

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

Who (by title, organization) was responsible for revising and reviewing the procedure.

3. Acronym (s) and/or plant specific designator (s) are undefined. If "LSFT" is going to be used it should be defined (e.g., by placing it in parentheses) after

" CORE SPRAY LOGIC SYSTEM FUNCTIONAL TEST" in the text.

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

See text comment 2.

4 Coded Fields 1. ' Item (4)--Title: Result and link are inadequate. A better title might be, " Inadequate Review of Revised Procedure Could Have Resulted In Two D/Gs Not Automatically Starting, if Required, During Performance of the Procedure".

I D-9

TABLE 0-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

7. LER Number: 86-023-00 Scores: Text - 8.1 Abstract - 9.0 Coded Fields - 9.2 Overall - 8.5 Text 1. 50.73(b)(2)(11)(D)--It is not clear from the discussion if the air trapped in the flow transmitter is normal or not. In other words, is venting done after placing the flow transmitter back in service or had the venting process been done improperly (personnel error)?

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)(31--What are the safety implications of the corrective actions (i.e., having the ATTS high steam flow trip functions disabled while at power)?

4. 50.73(b)(4)--It is not clear from the discussion if disabling the ATTS transmitters is necessary if the flow transmitter which was being brought on line had properly vented (see text comment 1).

5. MSIV should be defined on its first usage.

Abstract 1. No comment.

Coded Fields 1. Item (4)--Title: Root cause (improperly vented flow transmitter) is not included. Unless space is a '

problem, acronyms should be avoided in a title.

2. Items (6) and (71--A typographical error appears to have occurred. The report date (Item 7) started in the last field of the LER number (Item 6).

1 0-10

TABLE 0-1. SPECIFIC LER COMMENTS FOR 4ATCH 1 (321)

Section Comments

8. LER Number: 86-033-00 Scores: Text - 9.) Abstract - 9.3 Coded Fields - 9.5 Overall - 9.6 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. The text is arranged in a well-outlined format.

Excellent detail of system responses, component data, etc. is presented.

Abstract 1. 50.73(b)(11--Summary of the relay failure root cause is inadequate. The statement of normal equipment wear-out is not included.

Coded Fields 1. Item (4)--Title: The use of the acronyms (MG, RPS, ESF) is not encouraged unless space is severely limited, i

l 0-11

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH I (321)

, Section Comments

9. LER Number: 86-038-00 Scores: Text - 8.8 Abstract - 9.2 Coded Fields - 8.9 Overall - 8.9 Text 1. 50.73(b)(2)(11)(C)--Time information for major l occurrences is inadequate. At what time (date) was  !

the " valve closed normally" (last sentence of 1 Section C)? l 50.73(b)(2)(11)(D)--The root and/or intermediate 2.

cause discussion concerning the thermal binding is i inadequate. See text comment number 4. l

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. The code for the valve, "ISV", is not in the text.

t

4. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. If, as noted in Section E, the event is not believed to be a common mode failure, why were i the corrective actions extended to all electrically ,

backseated motor operated valves? This is certainly '

a conservative effort, but if "no other valves were noted to have this failure" one could ask why not only worry about Crane Model 776-U gate valves at your facility that are electrically backseated and would not have closed after being cooled down approximately 250'F?

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is unclear. Should number 1 under i Section F say "The valve was manually assisted from i the back seat- "? If the statement is correct as it i is stated, was this a further test to see if the valve would function and was this test performed under the same temperature conditions?

6. 50.73(b)(5)--Given that your final determination is that you have had no previous similar events, the discussion provided in Section G.2 is more than is necessary. It would have been enough to say that two other events were examined (give LER number if you l desire) but that it was determined that these events l l

i l

D-12 '

3 TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 1 (321)

Section Comments

9. LER Number: 86-038-00 (continued) were not similar because the failure mechanisms were different.

It is not correct to say that these events are not similar because they involved different systems (unless these other systems could not experience the cooldown temperatures discussed in this LER).

7. Acronym (s) and/or plant specific designator (s) are undefined. PCIV should be defined in the text on first usage.

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

The magnitude of the cooldown would be good information given 100*F is mentioned in the corrective actions.

Coded Fields 1. Item (4)--Title: Result and link are not clear. A better title might be, " Thermal Sinding Caused Backseated RCIC Isolation Valve To Fail To Close Given An Isolation Signal".

2. Item (ll)--It is not clear why this event was reported under 50.73(a)(2)(iv).

3. Item (13)--Cause, system, and/or component code is inconsistent with text. It appears it would have been more appropriate to have a cause code of "B" or "0" rather than "X".

D-13

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section Comments

10. LER Number: 85-020-01 Scores: Text = 7.5 Abstract = 8.8 Coded Fields - 7.5 Overall = 7.9 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 not included.

3. 50.73(b)(3)--Justification should be given for the conclusion that the safety of the plant and public were not affected.

4. 50.73(b)(4)--An additional supplemental report appears to be needed to describe the results of the investigation into the long term corrective actions for valve 2G31-F126A.

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

The manufacturing error on valve 2G31-F127A and the excessive friction problem on valve 2G31-F126A should be mentioned.

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

Replacement of the adapter plate on valve 2G31-F127A should be mentioned.

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

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

3. Item (14)--The block checked is inconsistent with

, information in the text (see text comment 4).

D-14 ,

l

, - - , _ . - .- - - - , , _ . , , , . _ - _ _ . _. . . _ , _ , _,.,__.._m_, - ,m-_m.,, -- wr.-e-me.- -r._ _,-_%-.---,

TA8LE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section Comments

11. LER Number: 85-030-00 Scores: Text - 8.8 Abstract = 8.7 Coded Fields - 9.0 Overall = 8.8 Text 1. 50.73(b)(2)(11)(K)--01scussion of automatic and/or manual safety system responses is inadequate. A list of the Groups 2 and 5 isolations is not included.

2. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate. Is more frequent surveillance warranted?

Abstract 1. 50.73(b)(1)--Summary of safety system response is inadequate. The RCIC trip and the various ESF actuations are not listed.

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

Coded Fields 1. Item (4)--Title: Root cause (stuck suction valve on condensate booster pump) is not included.

I 0-15

~ '

i i

TABLE 0-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366) l Section Comments

12. LER Number: 86-006-00 Scores: Text - 7.5 Abstract - 7.6 Coded Fields - 9.5 Overall - 7.7 Text 1. 50.73(b)(2)(ii)(C)--Date information for major occurrences is inadequate. Was procedure 52SV-SUV-001-2 performed on 2/26/86 when the snubber was observed to be leaking?

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate '

cause discussion concerning the leaking snubber is not included.

3. 50.73(b)(2)(ii)(El--The failure mode discussion of each failed component is not included. What is the failure mode of the leaking snubber?

4. 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. The code "SNB" is not provided in the text.

5. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. Given that it was known on 2/26/86 that the snubber would require repair or replacement, why wasn't it declared inoperable at that time? Why wasn't T.S. 3.7.4 and 4.7.4 reviewed until 3/20/867 Why didn't QA implement the corrective actions taken for 2-25-028 Rev. 1 until 2/10/86 and 2/13/86 (approximately 5 months later)?

Who (organization) was responsible for not revising 52SV-SUV-001-2 to include the Amendment No. 51 acceptance criteria?

6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. Why were the components supported by the inoperable snubber not adversely affected?

7. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Because it appears that the procedure will not be revised until its next scheduled performance (date?), will the Technical Specification requirement (LCO) be recognized if another snubber is found leaking prior to the revision of the procedure?

0-16

. . l l

l 1

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366) l Section Comments

12. LER Number: 86-006-00 (continued)

8. Some ideas are not presented clearly (hard to follow)

(Section D).

Abstract 1. 50.73(b)(1)--Summdryofoccurrences[immediate cause(s) and effects (s)] is inadequate. The fact that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO was exceeded was not mentioned.

2. 50.73(b)(1)--Summary of cause information is inadequate. See text comment numbers 2 and 5.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. l Those actions taken to strengthen the procedures l addressing T.S. amendments are not mentioned in the abstract.  ;

Coded Fields 1. Item (4)--Title: Cause information is inadequate. A better title might be, " Failure To Revise A Procedure To Reflect An Amendment to the Technical Specifications Results In Non-Compliance With A 72-Hour LC0".

l 0-17

1 TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section Comments

13. LER Number: 86-010-00 Scores: Text - 8.8 Abstract - 9.3 Coded Fields - 9.7 Overall = 9.1 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System identifiers for each component referred to in the text were not included.

2. 50.73(b)(2)(11)(L)--Identification of the failed piping material was good, since unique identification of the failed components was not possible.

3. _50.73(b)(3)--Were there any consequences of the steam leak relative to equipment and personnel safety? In particular, could some plant safety functions have been affected by the leak?

4. 53.73(b)(4)--Should the Ultrasonic Test Inspection program be expanded (more checks) or changed (checks l of more specific areas) to prevent recurrence, given that this leak was not found during the inspection five months earlier?

Abstract 1. 50.73(b)(1)--Summary of plant responses is inadequate. The Group II isoistion should be mentioned.

Coded Fields 1. Item (4)--The cause of the steam leak (wet steam errosion) should be included and the result should ,

mention the Group II isolation.

j D-18 L

1 n . .

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section Comments

14. LER Number: 86-017-00 Scores: Text - 9.6 Abstract - 9.6 Coded Fields - 9.7 Overall - 9.6 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. The text is presented in a well-outlined format.

Abstract 1. No comments.

Coded fields 1. Item (45--Title: The use of acronyms (RCIC, PCIV) in the title is not encouraged unless space is severely limited.

D-19

TABLE D-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section , Comments

15. LER Number: 86-020-00 Scores: Text - 6.8 Abstract - 9.5 Coded Fields - 9.7 Overall - 7.9 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then nwet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluated as if it were a text.

2. 50.73(b)(2)(ii)(D)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

3. 50.73(b)(2)(11)(E)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

4. 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.

5. 50.73(b)(2)(ii)(L )--Identification (e.g. ,

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

6. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.

7. 50.73(b)(4)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

8. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

D-20

1 e ** * ,

TABLE 0-1. SPECIFIC LER COMMENTS FOR HATCH 2 (366)

Section Comments

15. LER Number: 86-020-00 (continued)

9. OBSERVATION: The purpose of a supplemental report is to provide information that has not yet been determined by the time the original report must be submitted (i.e., within 30 days). This information usually involves determination of cause and corrective actions (as you have indicated in the last paragraph). Other information, such as consequences, manufacturer, model number, and previous similar events is usually available (known) at the time of the original report and is required at that time.

Abstract 1. The scores given for cause and corrective action information in the abstract are based on the assumption that the supplemental report will contain the necessary information.

Coded Fields 1. Item (13)--One or more component failure sub-fields are blank. Information, other than cause, was known at the time this report was submitted. See text comment number 9.

D-21

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