ML20214H167
| ML20214H167 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/20/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8705270296 | |
| Download: ML20214H167 (54) | |
Text
MAY 2 01961 i
e In Reply Refer To:
Docket: 50-267 Public Service Company of Colorado ATTN:
Robert 0. Williams, Jr.
Vice President, Nuclear Operations P. O. Box 840 Denver, Colorado 80201-0840 Gentlemen:
This fomards an assessment of your licensee event reports (LERs) covering the period April 1, 1986, through April 30, 1987.
This assessment was prepared by our Office for Analysis and Evaluation of Operational Data.
It is provided for your information, and a reply is not requested.
If you have any questions, we shall be glad to assist you.
Sincerely,
' < ocs a wa d c
e' u.u.
J. E. Gagliardo, Chief Reactor Projects Branch
Enclosure:
As stated cc w/ enclosure:
Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19)
Platteville, Colorado 80651 P. Tomlinson, Manager, Quality Assurance Division (sameaddress)
Colorado Radiation Control Program Director Colorado Public utilities Commission 0705270296 070520 EDR ADOCK 05000267 bcc to DMB (IE29) 3 PDR bcc distrib. by RIV:
RPB DRSP RRI R. D. Martin, RA SectionChief(RPB/A)
RSB SectionChief(RSB/ES)
Project Inspector, RPB RPSB D. Weiss, RM/ALF k}g MIS System R. Hall RSTS Operator RIV ile 7)/
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LICENSEE EVENT REPORT (LER)
QUALITY EVALUATION FOR FORT ST. VRAIN -
DURING THE PERIOD FROM APRIL 1 1986 TO MAY 7 1987
's
SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Fort St. Vrain during the pertod from April 1, 1986 to April 30, 1987 was performed using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.
This is the second time the fort St. Vrain LERs have been evaluated using this methodology.
The results of this evaluation indicate that the fort St. Vrain LERs have improved and now have an overall average score of 8.6 out of a possible 10 points compared to a previous score of 8.0 and a current industry average of 8.3 (Note:
The current industry average is the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).
Some significant weaknesses identified in the fort St. Vrain LERs involve the requirements to adequately provide: 1) the dates and times of major occurrences, 2) the manufacturer and model number of failed components, 3) informaticn concerning previous similar events, and 4) the plant conditions prior to the event.
Two strong points for the fort St. Vrain LERs are the discussions concerning the assessment of the safety consequences of the event and the failure mode, mechanism, and effect of failed components.
B LER QUALITY EVALUATION FOR FORT ST. VRAIN INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Fort St. Vrain during the period from April 1, 1986 to April 30, 1987, a sample of the unit's LERs were evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.
The sample consists of a total of 14 LERs, which was the total number of LERs available at the time of evaluation.
See Appendix A for a list of the LER numbers in the sample.
It was necessary to start the evaluation before the end of the assessment period because the input was due such a short time after the end of the assessment period. Therefore, all of the LERs prepared by the unit during the assessment period were not available for selection.
METH000 LOGY 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. I and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the LERs. 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 these 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 consments specific to l
the content and presentation of each LER.
The second part consists of deiermining 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 evaluated. Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms how the analysts perceived the content of tie 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).
i 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 0, 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
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narrative statements concerning the contents of each LER (Appendix D).
When referring to Appendix D, 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 have flexibility to consider the magnitude of a deficiency when assigning scores (e.g., the analysts sometimes make comments relative to a requirement without deducting points for that requirement).
RESULTS i
l A discussion of the analysts' conclusions concerning LER quality is i
presented below. These conclusions are based solely on the results of the i
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evaluation of the contents of the LERs selected for review and as_such l
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.
Figure 1 is updated each month to reflect any
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changes in this distribution resulting from the inclusion of data for those j.
units / stations that have not been previously evaluated or those that have been reevaluated.
(Note: The previous score for those units / stations that are reevaluated is replaced with the score from the latest evaluation).
Table 2 and Appendix Table B-1 provide a summary of the information that is f '
average score for the text of the LERs that were evaluated is 8.5 out of a the basis for the average scores in Table 1.
For example, Fort St. Vrain's 4
i 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 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 j
indication of how well each text requirement was addressed by the unit for the 14 LERs that were evaluated.
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Specific Deficiencies and Observations I
A review of the percentage scores presented in Table 2 will quickly l
point out where the unit is experiencing the most difficulty in preparing l
LERs.
For example, requirement percentage scores of less than 75 indicate I
that the unit probably needs additional guidance concerning these j
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 5
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- TABLE 1.
SUMMARY
OF SCORES FOR FORT ST VRAIN Average High Low Text 8.5 9.4 7.0 Abstract 8.8 10.0 5.6 Coded Fields 8.7 9.2 7.5 Overall 8.6 9.5 7.5 c.
See Appendix B for a summary of scores for each LER that was evaluated.
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Figure 1. Distribution of overall average LER scores 14
....i....i....i....i....i....i....
13 -
12 -
g 11 -
i 10 -
E 9-Fort St. Vra' 3
8-
'g 7_
6-
-o g
5-y 4-y 3-1 2-a..a..i...i.i...I.a.s.s.i.s.i.l..i....z.....
0 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average scores
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TABLE 2.
LER REQUIREMENT PERCENTAGE SCORES FOR FORT ST VRAIN i
TEXT I
Percentage a
Requirements (50.73(b)] - Descriptions Scores ( )
j-(2)(ii)(A)
- - Plant condition prior to event 64 (14)
- Inoperable equipment that contributed b
(2)(ii)(B)
(2)(ii)(C)
- Date(s) and approximate time (s) 61 (14)
(2)(ii)(D)
- - Root cause and intermediate cause(s) 94 (14)
(2)(ii)(E)
- - Mode, mechanism, and effect 100 ( 4)
- EIIS codes 0 (14)
(2)(ii)(F) 1 l-(2)(ii)(G)
- - Secondary function affected b
(2)(ii)(H)
- - Estimate of unavailability 100 ( 1)
(2)(ii)(I)
- - Method of discovery 89 (14)
(2)(ii)(J)(1) - Operator actions affecting course 100 ( 2)
(2)(ii)(J)(2) - Personnel error (procedural deficiency) 84 (10) l (2)(ii)(K)
- - Safety system responses 100 ( 5)
(2)(ii)(L)
- - Manufacturer and model no. information 50 ( 5)
(3) - - - - - - Assessment of safety consequences 09 (14)
(4) - - - - - - Corrective actions 91 (14)
(5) - - - - - - Previous similar event information 7 (14)
(2)(1)
- - - - Text presentation 91 (14)
ABSTRACT ii j
Percentage a
l Requirements [50.73(b)(1)] - Descriptions Scores ( )
4 j
- Major occurrences (immediate cause/effect) 100 (14)
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- Plant / system / component / personnel responses 100 ( 4) 1
- Root cause information 86 (14)
- Corrective action information 80 (14)
- Abstract presentation 82 (14)
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. TABLE 2.
(continusd)
. CODED FIELDS Percentage a
Item Number (s) - Descriptions Scores ( )
1, 2, and 3 -
Plant name(unit #), docket #,
page #s 100 (14) 4------
Title 54 (14) 5, 6, and 7 -
Event date, LER no.,
report data 98 (14) 8------
Other facilities involved 100 (14) 9 and 10 Operating mode and power level 100 (14)
Reporting requirements 06 (14) 11 Licensee contact information 100 (14) 12 13 Coded component failure information 99 (14) 14 and 15 - -
Supplemental report information 96 (14) c.
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 cpplicable, b.
A percentage score for this requirement is meaningleds as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER.
It is always given 100%
if it in provided and is always considered "not applicable" when it is not.
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the LER specific connents presented in Appendix 0 to determine why the unit 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 as are the primary deficiencies in the abstract and coded fields sections.
Text Deficiencies and Observations The requirement to provide dates and approximate times of occurrences, Requirement 50.73(b)(2)(11)(C), was considered deficient in eight of the 14 LERs. There is obviously not one set of rules concerning what dates and times to include; in some LERs, providing only the date of a discovery is sufficient, while others require times in seconds to adequately describe the time history of the various occurrences in the event. Prior to submitting an LER, the reviewers should review the text for obvious places l
where the addition of a date and/or time would provide meaningful information.
The requirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(11)(L), was considered to be deficient in three of the five LERs involving a failed component.
In most cases this requirement can be met by simply providing the manufacturer and model number for each failed component, for certain components (e.g., pipes, fitting, etc.) the material and size of the failed component would be more appropriate information. Whatever information is provided, it should be specific enough to allow the reader to determine if the component is the same as one that is at another facility, in addition, there are instances where information that identifies components (even though these components didn't fall) could be important to the reader. For example, if the design of a component contributes to the event, it would be helpful to provide information that would enable others to specifically identify the component. An example of such a component would be a valve that opens with a clockwise turn of its handle and thus leads to an improper valve line-up due to a personnel error while operating the valves.
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The text requirement to adequately discuss personnel and procedural error, Requirement 50.73(b)(2)(11)(J)(2), has a marginally acceptable score but is mentioned here because six out of the ten LERs involving a personnel error had a deficiency.
The primary deficiency is that the discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, or other uttitty personnel) was not included in the LER.
i plant operating conditions prior to the event, Requirement 50.73(b)(2)(11)(A), were not included in the text for five of the 14 LERs.
The operating mode number (when applicable) and name should be provided.
I Requirement 50.73(b)(5) was not adequately addressed in 13 of the 14 LERs in that their text did not include the necessary information concerning previous similar events. All previous similar events should be appropriately referenced (by LER number, if possible) and the history of the on-going problem should be discussed, if necessary, if there have been no previous similar events, the text should state this.
The Energy Industry Identification System (Ells) codes were not i
l provided for the systems and components mentioned in any of the 14 LERs.
The text presentations, while adequate, contained undefined acronyms or plant specific designations in eleven of the 14 LERs. All such items should be defined in the text on their first usage, in addition, even though the texts were presented in an outline format, the format used in each LER was not consistent between LERs.
ine use of a consistent format for major headings is suggested.
Subheadings can be tailored to the individual LER.
Ab} tract Deficiencies _and_0bservatigni r
While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as stated in 9
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NUREG-1022, Supplement No. 2 sunuur tre 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 i
Cause caused the component and/or system failure or the personnel error.
4.
Corrective Actions What was done inanedtately to restore the plant to a safe and stable condition and 4
what was done or planned to prevent recurrence of the event.
l Numbers 1, and 3 above were adequately addressed in the abstracts of j
the LERs reviewed. However, number 4 was deficient in seven of the 14 LERs.
This could be improved by ensuring that the corrective action I
j information that is contained in the text gets adequately summartred in the abstract.
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In addition, an abstract should not contain information that is not i
discussed in text (eleven abstracts introduced new information).
If, when writing the abstract, new information is deemed necessary, the text should be revised so as to discuss this information. Further improvement in the abstract score could be obtained by using the full space available (i.e.,
the 1400 spaces).
'1 Coded Fields _ Deficiencies and Observations l
The main deficiency in the area of coded fields involves the titles, i
Item (4).
Twelve of the 14 titles failed to adequately provide root cause j
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b information, five failed to include the result of the event, and eight failed to include the link between the cause and result. While the result is considered to be the most important part of the title, cause and link information (as suggested in NUREG-1022, Supplement No. 2) must be included to make a title complete.
Example titles are presented in Appendix D for many of the LERs which were considered to have poor titles, i
SUMMARY
1 Table 3 provides a summary of the areas that need improvement for the Fort St. Vrain LERs. For additional and more specific information
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concerning deficiencies, the reader should refer to the information presented in Appendices C and D.
General guidance concerning requirements can be found in NUREG-1022, and NUREG-1022 Supplements No. I and 2.
1 It should be noted that this is the second time that the Fort St.
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Vrain LERs have been evaluated using this same methodology.
The previous evaluation was reported in May of 1986.
Table 4 provides a comparison of the scores for both evaluations. While the overall text score was slightly j
higher for this evaluation (due to better safety consequence discussions),
j the higher overall abstract score increased the overall average LER score j
to 8.6, which is above the current industry overall average of 8.3.
(Note: The industry overall average is the result of averaging the latest overall average LER score for each unit / station that has been evaluated
)
using this methodology.)
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TA8LE 3.
AREAS MOST NEEDING IMPROVEMENT f0R f0RT ST VRAIN LERs Areas Comments Plant operating conditions Operating mode number and name should be provided.
Dates / times It would be helpful to include date/ time information such as when the plant reaches a safe and stable condition and when corrective actions are completed.
EIIS code EIIS should be used in the text for each component or system referred to in the text.
Personnel / procedural error Details should be explicitly stated; the cause of personnel error should be discussed, (e.g., whether the error is cognitive or procedural and the type of personnel involved in the error).
Manufacturer and model number Component identification information should be included in the text whenever a component falls.
In addition, (although not specifically required by current regulation) it would be helpful to identify a component if it is suspected of contributing to the event because of its design.
Previous similar events Previous similar events should be referenced (e.g., by LER number) or, as stated in NUREG-1022, Supplement No. 2, if none are identified, the text should so state.
Text presentation Improvement in text presentation would be made by using a consistent outline format.
8e sure to define all acronyms and plant specific designations on their first usage.
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Abstracts Corrective action information was often inadequate or was not included. Abstracts
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should not contain information that is not discussed in the text.
If it is necessary to include such information, the text i
should be revised so as to discuss it.
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TABLE 3.
(Continued)
Areas Comments Coded fields
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Titles Title should be written such that they better describe the event.
In particular, include cause and result information, and the link between them in all titles.
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TABLE 4.
COMPARISON OF LER SCORES FROM PREVIOUS EVALUATION Report Date May-86 May-87 Text average 8.4 8.5 Abstract average 6.8 8.8 Coded fields average 8.8 8.7 Overall LER average 8.0 8.6 s
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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 Eve,nt 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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0, O
e APPEN;!X A LER SAMPLE SELECTION INFORMATION FOR FORT ST. VRAIN I
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.TADLE A-1.
LER SAMPLE SELECTION FOR FORT ST. VRAIN Eample Number LER Number Comments 1
86-017-00 SCRAM 2
86-018-00 SCRAM 3
86-019-00 4
86-020-00 5
86-021-01 6
86-022-00 7
86-023-00 8
86-024-00 9
86-025-00 10 86-026-00 11 86-027-00 12 86-028-00 SCRAM 13 86-029-00 SCRAM 14 86-030-00 A-1
e APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR FORT ST. VRAIN I
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' 7ABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERS FOR FORT ST VRAIN a
LER Sample Number 1
2 3
4 5
6 7
8 Text 8.8 8.6 8.2 8.6 7.0 8.4 8.3 9.1
' Abstract 9.2 9.5 8.9 9.6 8.6 8.1 9.1 7.5 Coded Fields 9.2 8.5 8.7 9.1 7.5 8.0 9.1 8.5 Overall 8.9 8.9 8.5 8.9 7.5 8.3 8.6 8.5 a
LER Sample Number 9
10 11 12 13 14 15 Average Text' 8.1 8.1 8.9 9.4 8.2 8.9 8.5 Abstract 8.1 8.8 5.6 9.8 10.0 9.6 8.8 Coded Fields 9.0 8.9 8.5 8.9 9.2 9.2 8.7 Overall 8.2 8.4 7.9 9.5 8.9 9.1 8.6 r
a.
See Appendix A for a list of the corresponding LER numbers.
B-1
e APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR FORT ST. VRAIN
TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR FORT ST. VRAIN Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)b 50.73(b)(2)(11)(A)--Plant operating 5 (14) conditions before the event were not included or were inadequate.
50.73(b)(2)(it)(8)--01scussion of the status 0 ( 2) 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 8 (14) sufficient date and/or time information.
a.
Date information was insufficient.
8 b.
Time information was insufficient.
4 50.73(b)(2)(11)(0)--The root and/or 3 (14) intermediate cause of the component or system failure 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.
50.73(b)(2)(11)(E)--The failure mode, 0 ( 4) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode was not included or was inadequate.
b.
Mechanism (immediate cause) was not included or was inadequate.
c.
Effect (consequence) was not included or was inadequate.
C-1
TA8LE 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 14 (14)
Identif$ cation System component function identifier for each component or system was not included.
50.73(b)(2)(11)(G)--For a failure of a
-- ( 0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.
50.73(b)(2)(11)(H)--for a failure that 0 ( 1) rendered a train of a safety system inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(I)--The method of discovery 2 (14) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each I
component failure was not included or was inadequate.
b.
Method of discovery for each system 0
failure was not included or was inadequatv.
c.
Method of discovery for each 1
personnel error was not included or was inadequate, d.
Method of discovery for each 0
procedural error was not included or was inadequate.
C-2
e, 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)(J)(1)--Operator actions that 0 ( 2) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
50.73(b)(2)(11)(J)(2)--The discussion of 6 (10) 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)(11)(J)(2)(1)--Discussion 1
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(11)(J)(2)(11)--Discussion 0
as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate.
d.
50.73(b)(2)(ii)(J)(2)(111)--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)(11)(J)(2)(iv)--Discussion 5
l of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was l
not included or was inadequate.
1 C-3
TABLE C-1.
-(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
50.73(b)(2)(11)(K)--Automatic and/or manual 0 ( 5) safety system responses were not included or were inadequate.
50.73(b)(2)(11)(L)--The manufacturer and/or 3 ( 5) model number of each failed component was not included or was inadequate.
50.73(b)(3)--An assessment of the safety 1 (14) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION:
The availability of 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 of the event had it occurred under more severe conditions were not discussed.
If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 5 (14) actions planned as a result of the event
. including those to reduce the probability of siellar events occurring in the future was not included or was inadeouate.
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TA8LE 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 2
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 I
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 13 (14) similar events was not included or was inadequate.
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C-5 I
TA8tE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Descript1on of Deficiencies and Observations Totals #
Totals (
)
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50.73(b)(2)(1)--Text presentation 11 (14) inadequacies.
4.
08SERVATION: A diagram would have 0
aided in understanding the text discussion, b.
Text contained undefined acronyms 11 and/or plant specific designators.
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.
C-6
TA8LE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR FORT ST. VRAIN 1
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
A summary of occurrences (immediate cause 0 (14) and effect) was not included or was inadequate.
A summary of plant, system, and/or personnel 1 ( 4) responses was not included or was inadequate.
a.
Summary of plant responses was not 0
included or was inadequate, b.
Summary of system responses was not 0
included or was inadequate.
c.
Sunnary of personnel responses was not 1
included or was inadequate.
A summary of the root cause of the event 5 (14) was not included or was inadequate.
A summary of the corrective actions taken or 7 (14) planned as a result of the event was not included or was inadequate.
C-7
_~_
Th8LEC-2.
(continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
Abstract presentation inadequacies.
13 (14) a.
OBSERVATION: The abstract contains 11 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 4
1400 spaces.
c.
The abstract contains undefined 0
acronyms and/or plant specific designators, d.
The abstract contains other specific 0
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
TABLE C-3.
CODED FIELOS DEFICIENCIES AND OBSERVATIONS FOR FORT ST. 'vRAIN Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals #
Totals (
)
Facility Name 0 (14) a.
Unit number was not included or incorrect, b.
Name was not included or was incorrect.
c.
Additional unit numbers were included but not required.
Docket Number was not included or was 0 (14) incorrect.
Page Number was not included or was 0 (14) incorrect.
Title was left blank or was inadequate.
14 (14) a.
Root cause was not given or was 12 inadequate.
b.
Result (effect) was not given or 5
was inadequate.
c.
Link was not given or was 8
inadequate.
Event Date 1 (14) a.
Date not included or was incorrect.
O b.
Discovery date given instead of event 1
date.
LER Number was not included or was incorrect.
0 (14)
Report Date 0 (14) a.
Date not included.
b.
OBSERVATION:
Report date was not within thirty days of event date (or discovery date if appropriate).
Other Facilities information in field is 0 (14) inconsistent with text and/or abstract.
Operating Mode was not included or was 0 (14) inconsistent with text or abstract.
C-9
TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
b Description of Deficiencies and Observations Totals Totals (
l Power level was not included or was 0 (14) inconsistent with text or abstract.
Reporting Requirements 1 (14) a.
The reason for checking the "0THER" 0
requirement was not sracified in the abstract and/or text.
b.
OBSERVATION:
It may have been more 0
appropriate to report the event under a different paragraph, c.
OBSERVATION:
It may have been 1
appropriate to report this event under an additional unchecked paragraph.
Licensee Contact 0 (14) 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 1 (14) a.
One or more compos.ent failure 0
sub-fields were left blank.
b.
Cause, system, and/or component code 1
is inconsistent with text, c.
Component failure field contains data 0
when no component failure occurred.
d.
Component failure occurred but entire 0
field left blank.
t
}
C-10
o, TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)D Supplemental Report 1 (14) a.
Neither "Yes"/"No" block of the 0
supplemental report field was checked.
b.
The block checked was inconsistent I
with the text.
Expected submission date information is 0 (14) inconsistent with the block checked in Item (14).
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total, b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
C-11
O O,
O APPENDIX D LER COMMENT SHEETS FOR FORT ST. VRAIN
~.
TABLE _D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 1.
LER Number:
86-017-00
' Scores: Text - 8.8 Abstract - 9.2 Coded fields - 9.2 Overall - 8.9 Text 1.
50.73(b)(2)(ii)(01--A supplemental report would be appropriate to describe the results of the shutdown seal testing if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.
2.
50.73(b)(2)(ti)(F1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
i 3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The original report implies that more testing was necessary, which is acceptable. Further testing, however, usually implies the need for a supplemental LER.
The information presented in the letter from J. W. Gahm to H. N. Berkow dated December 19, 1986 would be appropriate to present in a supplemental LER.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
5.
PRPA should be defined on its first usage in the text, i
Abstract 1.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text most include all information summarized in the abstract. This abstract contains information that was not included in the text. The date that the reactor was returned 4
to power was not provided in the text.
I Coded fields 1.
Item (4)--Title: Link (offsite power supply fluctuations) is not included. A more appropriate title might be "Offsite Power Fluctuations due to a
{
Severe Snow Storm Result in Loop Shutdown Actuations and Subsequent Manual Scram".
2.
Item (141--The block checked appears to be inconsistent with information provided in the text; see text comment numbers 1 and 3.
0-1 i
~~
l e.
- a TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (261)
Section Comments 2.
LER Number:
86-018-00 Scores: Text = 8.6 Abstract - 9.5 Coded Fields - 8.5 Overall = 8.9 Text 1.
50.73(b)(2)(11)(C)--Dates and times for the repair completion and reactor startup are not included.
2.
50.73(b)(2)(it)(f)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(ii)(L)--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is slot included.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
5.
The use of figures to aid the text presentation is encouraged.
Abstract 1.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that.as not included in the text. The approval date for reactor startup is not included in the text.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included. A better title might be:
" Loose Connection in Circulator Inlet Temperature Circuitry in Conjunction with Primary Coolant Pressure Scram Test Causes Scram".
D-2
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 3.
LER. Number: 86-019-00 Scores:
Text - 8.2 Abstract - 8.9 Coded fields - 8.7 Overall - 8.5 Text 1.
50.73(b)(2)(11)(0)--The root and/or intermediate cause discussion concerning the oli leak on HV-2293 and the seat leakage on PV-22129-1 15 not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(11)(J)(21--Discussion of the personnel error / procedural deficiency is inadequate. At the time of the event, were there any special instructions in place concerning what action to take if the power level exceeded 35%? Who (by personnel type or title) was responsible for not providing the necessary administrative controls on plant conditions and operator responses?
l 4.
50.73(b)(2)(11)(L)--Identification (e.g.,
~
nunufacturer and model no.) of the failed component (s) discussed in the text is not included.
5.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. What actions were taken to prevent recurrence of the oil leak and the seat leakage? The third paragraph under the heading
" CORRECTIVE ACTION" is unclear.
Does this mean that blank forms are being reviewed and will be modified, if necessary, to ensure that operations is pude aware j
of those times that pressure control valves are used i
as block valves?
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
7.
Acronym (s) and/or plant specific designator (s) are undefined.
8.
There is no reference in the text to the figures.
i Abstract 1.
50.73(b)(1)--Summary of cause it#ormation is r
inadequate.
The abstract should mention the lack of administrative controls that existed.
f D-3 l
I
TiBLE0-1. SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 3.
LER Number: 86-019-00 (Continued) 2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The abstract should mention the fact that instructions were issued to scram the reactor if the power exceeds 34%.
3.
OBSERVATION:
The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract.
This abstract contains information that was not included in the text (i.e., the reference to 10 CFR 50.73(a)(2)(1)(B)).
Coded fields 1.
Item (4)--Title:
Cause information is not included and the link is inadequate. A better title would be
" Lack of Administrative Controls Results In Reactor Not Being Scrammed When Power Exceeded The Approved 35% Limit."
D-4
_-. ~
l TA8LE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 4.
LER Number: 86-020-00
. Scores:
Text - 8.6 Abstract - 9.6 Coded fields 9.1 Overall - 8.9 t
j Text 1.
50.73(b)(2)(11)(C)--Date information is inadequate.
~
It would be helpful to indicate in the text when the problem was discovered, and when the continuing evaluations of safety and corrective actions are j
expected to be completed.
2, 50.73(b)(2)(11)(F_1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (e.a., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
4.
50.73(b)(31--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary 4
information.
5.
50.73(b)(4)--08SERVATION: The score for this requirement is based on the assumption that the
)
supplemental report will contain all the necessary information.
1 6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
7.
Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1.
08SERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract.
This abstract contains information that was not included in the text. The date of the discovery is given in i
the abstract but not the text (see text comment 1).
The text also does not specifically state that the plant was shutdown as does the abstract.
Coded fields 1.
Item (4)--Title:
Result (plant in unanalyzed condition) is not included.
The use of acronyms in the title should be avoided unless space is a problem.
J 4
1 0-5 1
=_-
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 5.
LER Number: 86-021-01 Scores: Text - 7.0 Abstract - 8.6 Coded fields - 7.5 Overall - 7.5 Text 1.
50.73(b)(2)(11)(Al--Information concerning the plant operating conditions before the event is not included.
2.
50.73(b)(2)(11)(C)--The date of the review of the fire protection system, the date of the discovery of the fourth single failure valve, and the expected date of plant startup are not included.
3.
50.73(b)(2)(11)(f)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4 4.
50.73(b)(2)(11)(I)--Discussion of the method of discovery of the three single failure valves is inadequate. Why was the fire protection system review performed, and by whom?
5.
50.73(h)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is inadequate for the design / installation deficiency.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The text does not state whether or not all other possible single failure valves were reviewed in related safety systems.
7.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
1 8.
Acronym (s) and/or plant specific designator (s) are undefined (PCRV).
9.
The use of the figure to indicate the locations of the single failure valves is encouraged.
Abstract 1.
50.73(b)(11--Summary of the root cause (design / installation deficiency) is inadequate.
See text comment number 5.
I D-6 4
..b i
TA8LE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 5.
LER Number: 86-021-01 (Continued) 2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment number 6.
3.
OBSERVATION:
The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text.
The reportability is not included in the text.
Coded Fields 1.
Item (4)--Title: Root cause is not included and link and result are inadequate. A better title might be:
l
" Undetermined Personnel Design / Installation Error Olscovered During Fire Protection Review Leads to Four Single failure Points in Safe Shutdown Cooling".
2.
Item (5)--Discovery date is given instead of event date.
3.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(ii)(B).
l 0-7
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 6.
LER Number:
86-022-00 Scores: Text - 8.4 Abstract - 8.1 Coded Fields - 8.0 Overall - 8.3 Text 1.
50.73(b)(2)(ii)( Al--Information concerning the plant operating conditions before the event is not included in the text.
2.
50.73(b)(2)(11)(C)--Date information is lacking.
When was the system originally designed and installed (i.e., how long has the problem existed)?
3, 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4.
50.73(b)(2)(11)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate.
Is the designer a utility personnel? Who (by type of personnel) was responsible for the independent review?
5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
6.
Acronym (s) and/or plant specific designator (s) are undefined (e.g., CN-2191).
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate.
The fact that both the design and the independent review process was deficient should have been mentioned in the abstract.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The facts that 1) both the designer and reviewer were reprimanded and given additional training and 2) the problem will be corrected prior to plant startup should have been mentioned in the abstract.
r f
D-8
Y &
TA8LE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 6.
LER Number:
86-022-00 (Continued)
' 3.
OBSERVATION: The abstract is intended to be a suramary of the text; therefore, the text must include all informaticn' summarized in the abstract. This abstract contains information that was not included in the' text (i.e., the plant status information).
Coded Fields 1.
Item (4)--Title:
Cause and result information is inadequate and the link between them is missing.
A better title would be " Single Failure Problem (Design Deficiency) Discovered During Work Package Preparation--Loss of Bus 1 125V DC Will Inhibit Energizing Undervoltage Relay Logic Schemes of 480 VAC Buses 1 and 2".
1 I
D-9
~~
c-,
,-,-y.
-,, - - - - - - - - - +,
>-,-g
- "TA'8LE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 7.
LER Number: 86-023-00 Scores:
Text - 8.3 Abstract = 9.1 Coded Fields - 9.1 Overall = 8.6 Text 1.
50.73(b)(2)(11)(C)--Additional date information for items such as when the maintenance activity, which affected the monitors, occurred and when corrective actions were performed would be helpful.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(ii)(I)--What activity was being performed that lead to the realization that the monitors where out of calibration?
4.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
6.
Acronym (s) and/or plant specific designator (s) are undefined (ELC0 and ALARA).
ODCM was not defined on its first usage.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract does not clearly state that the root cause was procedural and administrative.
It is also unclear how maintenance activities affected the monitors.
2.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text.
The abstract is more clear than the j
text on how the problem with the monitors was found l
(see text comment 3).
Coded Fields 1.
Item (4)--Title: Root cause is not included.
D-10 i
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 8.
LER Number: 86-024-00 Scores: Text - 9.1 Abstract - 7.5 Coded Fields - 8.5 Overall = 8.5 Text 1.
50.73(b)(2)(11)(C)--The date and time of the discovery of the rupture disc being out of tolerance and the date of the next expected inspection outage are not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(ti)(L)--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is inadequate.
The model number of the rupture disc is not included.
4.
The use of a figure to portray the rupture disc structure is encouraged.
Abstract 1.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is not included other than for the mention of disc disassembly.
2.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text. The statement concerning a supplemental report is not included in the text.
Coded Fields 1.
Item (4)--Title:
Root cause, link, and result are inadequate. The title contains an undefined acronym, PCRV. A better title might be:
" Overpressure Protection System Rupture Disc Found Out of Tolerance During Surveillance Test From Undetermined Causes--Technical Specification Violation".
0-11
TABLE 0-1
-SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 9.
LER Number: 86-025-00 Scores:
Text - 8.1 Abstract - 8.1 Coded fields - 9.0 Overall - 8.2 Text 1.
50.73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not included in the text.
2.
50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the sample flow rate and source of the debris is inadequate. Approximately what was the sample flow rate? Would the debris have gone through the pump without stopping it?
3.
50.73(b)(2)(11)(F1--The Energy Industry
~ Identification System code for each component and/or system referred to in the text is not included.
4.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. How was the sample flow re-established? How long did it take? Is a finer screen needed for the sample line? A supplemental report would be appropriate to describe the results of the evaluation to determine if system modifications are necessary if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.
5.
50.73(b)(51--Information concerning previous similar events is not included.
If no previous similar events are known, the. text should so state.
6.
Acronym (s) and/or plant specific designator (s) are undefined (ELCO).
Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
Planned corrective action is not mentioned in the abstract.
2.
The abstract contains greater than 1400 spaces.
l l
D-12 i
TABLE 0-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 9.
LER Number: 86-025-00 (Continued) 3.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information sumnarized in the abstract. This abstract contains information that was not included in the text.
Coded Fields 1.
Item (4)--Title: -Cause is not included, and the result is inadequate. A better title would be
" Procedural Deficiencies Involving Continuous Sample Flow Rates Result In Sump Release Not Being Continuously Monitored as Required By Technical Specifications".
.i 2.
Item (14)--See text comment number 4.
'l t
4 0-13
TABLE 0-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 10.
LER Number: 86-026-00 Scores: Text - 8.1 Abstract - 8.8 Coded fields - 8.9 Overall = 8.4 Text 1.
50.73(b)(2)(ii)(A)--Although the operating conditions before the event are given in the abstract, they are not given in the text.
2.
50.73(b)(2)(11)(C)--Dates for ma,)or occurrences are not included.
3.
50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4.
50.73(b)(2)(11)(J)(2)(iv)--01scussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
6.
Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The fact that the independent review did not catch the deficiency in the analysis was not mentioned.
2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
The fact that all analyses affected by the erroneous assumption will be reanalyzed was not mentioned.
3.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This
~
abstract contains information that was not included in the text (see text comments 1 and 2).
4.
The abstract contains greater than 1400 spaces.
Coded fields 1.
Item (4)--Title:
Root cause (erroneous analysis assumption) 1: not included.
The use of acronyms in the title should be avoided unless space is a problem.
D-14 i
-,'.?.
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments
- 11. LER Number: 86-027-00 Scores:
Text - 8.9 Abstract - 5.6 Coded Fields - 8.5 Overall - 7.9 i
Text 1,
50.73(b)(2)(11)(Al--Information concerning the plant operating conditions before the event is not included.
l 2.
50.73(b)(2)(ii)(F)--The Energy Industry i
Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
4.
Acronym (s) and/or plant specific designator (s) are undefined (ELC0 and MPC).
Abstract 1.
50.73(b)(1)--Summary of the root cause and intermediate cause information concerning the loose ground wire in the sampler pump breaker cubicle, the failure to close the sampler pump breaker, the inadequate breaker labeling, and the improper training emphasis are not included.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. A summary of the actions taken to correct the root cause is not included.
3.
The abstract contains greater than 1400 spaces. The reportability need not appear in the abstract when space is limited.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included. A better title might be:
" Reactor Building Sump Release Not Continuously Sampled Due to Sampler Pump Breaker Being Mistakenly Left Open--Technical Specification Violation".
D-15
=.
?,
TABLE D-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 12.
LER Number: 86-028-00 Scores: Text - 9.4 Abstract = 9.8 Coded fields = 8.9 Overall = 9.5 Text 1.
50.73(b)(2)(ii)(D)--Is there anything unique about Channel IV that it was not affected by the electrical noise? OBSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
2.
50.73(b)(2)(ii)(E)--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)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4.
50.73(b)(2)(ii)(L)--08SERVATION: The score for this i,
requirement is based on the assumption that the supplemental report will contain all the necessary information.
4 5.
50.73(b)(4)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
4 Abstract 1.
50.73(b)(1)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
2.
OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text.
D-16 4
--w-,-n-
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TABLE 0-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 12.
LER Number:
86-028-00 (Continued)
Coded fields 1.
' Item (4)--Title: Cause information is not included.
Cause information such as " Electrical Noise From Unknown Sources Caused- " should be included in the title.
2.
Item (13)--Cause, system, and/or component code appears inconsistent with information provided in the text.
It is not presently known whether or not an actual component failure has occurred, as the source of the noise is yet to be determined, t
0-17
e6 -0 TA8LE 0-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments
- 13. LER Number: 86-029-00 Scores: -Text --8.2 Abstract = 10.0 Coded Fields = 9.2 Overall -
Text 1.
50.73(b)(2)(11)(C)--Date and time information was not l
included.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(11)(L)--Identifying the components, even though they do not fail, provides additional useful information for others in the industry and is a good practice.
4.
50.73(b)(3)--0BSERVATION:
The consequences of the event had it occurred under more severe conditions were not discussed.
If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text. In particular, could this event have caused a scram while the reactor was operating at power (e.g., are personnel allowed in the area during power operation?)
5.
50.73(b)(41--Are there other locations where radio use should be prohibited?
6.
50.73(bl[ll--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
7.
Acronym (s) and/or plant specific designator (s) are 4
undefined.
J Abstract 1.
No comment.
I Coded Fields 1.
Item (4)--Title:
Cause information (radio frequency interference from hand held transceiver) is not included.
I D-18 i
a ta A TABLE 0-1.
SPECIFIC LER COMMENTS FOR FORT ST. VRAIN (267)
Section Comments 14.
LER Number: 86-030-00 l
Scores:
Text - 8.9 Abstract = 9.6 Coded Fields - 9.2 Overall = 9.1 Text 1.
50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is not included.
2.
50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
4.
Acronym (s) and/or plant specific designator (s) are undefined (HTGR).
Abstract 1.
The abstract contains greater than 1400 spaces.
Coded Fields 1.
Item (4)--Title:
Root cause (personnel error) and link (during review of design change) are not included.
I D-19
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