ML20214H220

Forwards AEOD Assessment of LERs for Dec 1985 - May 1986 as Part of SALP Program.Weakness Identified Involving Failure to Provide Adequate Safety Assessment.Lers of Average Quality Based on Requirements in 10CFR50.73

ML20214H220
Person / Time
Site:	Browns Ferry, Sequoyah, 05000000
Issue date:	07/29/1986
From:	Zech G NRC
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8608130046
Download: ML20214H220 (86)

Text

_ _ -

\C. CO JUL 2 91986 Docket Nos. 50-259, 260, 296, 327, 328 License Nos. DPR-33, 52, 68, 77, 79 Tennessee Valley Authority ATTN: Mr. S. A. White Manager of Nuclear Power 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:

SUBJECT:

EVALUATI0t! 0F LICENSEE EVENT REPORTS - TVA The NRC's Office for Analysis and Evaluation of Operational Data (AE00) has recently completed an assessment of your Licensee Event Reports (LERs) from Browns Ferry and Sequoyah as part of the NRC's Systematic Assessment of Licensee Performance (SALP) Program.

In General, AE00 found your submit +als to be of above average quality based on the requirements contained in 10 CFR 50.73. Some weaknesses were identified involving the requirement to provide an adequate safety assessment (Browns Ferry and Sequoyah). The safety assessment is needed to assess the possible consequences of events and has not been routinely provided. Failure to provide the manufacturer and model number (or other appropriate identification) for those components that failed or whose design contributed to the event (Browns Ferry) was also identified.

We are providing you a copy of AEOD's assessment so that you are aware of their findings and can use the information to pattern future submittals.

We appreciate your cooperation with us. Please let us know if you have any questions.

Sincerely,

\ ORIGINAL SIGNED BY

'g GARY G. ZECH

'\

. Gary G. Zech, Director N TVA Projects

Enclosures:

1. AE00 Assessment Browns Ferry

2. AE00 Assessment Sequoyah cc w/encis:

H. P. Pomrehn, Browns Ferry Nuclear Plant Site Director H. L. Abercrombie, Sequoyah Nuclear Plant Site Director 8608130046 860729 [ 8IO h PDR ADOCK 05000259 O PDR gg

?*

Tennessee Valley Authority 2 M29 W bcc w/o encis:

J. N. Grace

-.R. D. Walker H. R. Denton, NRR -

H. L. Thompson, NRR J. M. Taylor, IE B. B. Hayes, 01 S. R. Connelly, 0IA R. J. Clark, Licensing Project Manager, NRR M. Grotenhuis, Project Manager, NRR C. R. Stahle, Project Manager, NRR .

S. P. Weise F. S. Cantrell B. T. Debs NRC Resident Inspector State of Alabama Document Control Desk State of Tennessee l

l w

.y 4

RII RII RII ' RII /

y'& 7 4,. gj]

AJohnson:saj FCantrell BDebs SNeise 7//)./86 7/jfs/86 7y//86 7/Zh/86

'O

~

$NClosun_g j SUMARY i  !

l An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Browns Ferry 1, 2, and 3 during the December 1, 1985 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the i basic methodology presented in NUREG/CR-4178.1 This is the second time that the Browns Ferry LERs have been evaluated using this methodology. The j results of this evaluation indicate that the Browns Ferry 1, 2, and 3 LERs now have an overall average score of 8.6 out of a possible 10 points,

{ compared to their previous overall average score of 7.7 and a current industry average of 7.8 (i.e., the average of the latest overall average LER score for each unit / station that has been evaluated to date using this ,

methodology).

Two weaknesses that still remain in the LERs, in terms of' safety significance, involve the requirements to provide an adequate safety assessment, and to provide the manufacturer and model number (or other appropriate identification) for those components that fail or whose design contributes to the event. The failure to provide an adequate safety assessment discussion prompts concern that possibl.e consequences of the event, for example, consequences that could have occurred had the plant . ~ )

been in a different configuration, may not be recognized and/or addressed. l The failure to provide information concerning the identification of failed components prompts concern that others in the industry may not obtain i information that might enable them to identify and correct generic problems prior to having a similar failure at their facility. In addition, the station should again consider the use of an outline format for their lERs such as the one recommended in Appendix C of NUREG-1022, Suppleraent Na. 2.

A strong point for the Browns Ferry LERs is that inforstation concerning root cause and corrective actions was well written for the LERs that were evaluated.

i Attachment A A

AE00 INPUT TO SALP REVIEW FOR BROWNS FERRY 1, 2, AND 3 Introduction in order to evaluate the overall cuality of the contents of the Licensee Event Reports (LERs) submitted by Browns Ferry 1, 2, and 3 during the December 1,1985 to May 31,1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CP-4178.I The sample consists of a total of 10 LERs (i.e., 4 LERs for Browns Ferry 1, 2 for Browns Ferry 2, and 4 for Browns Ferry 3). At the time the sample was selected there were only 10 LERs in the file for Browns Ferry. The Browns Ferry LERs were evaluated as one sample for this SALP period because it was determined that tneir LERs are botn written and formally reviewed at the station, rather than unit, level. See Appenoix A for a list of the LER numbers in the sample.

It was necessary to start the evaluation before tne end of the SALP assessment perico because the input was oue such a short time af ter the eno of the SALP perico. Therefore, not all of the LERs prepareo during the SAtP assessment perioo 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 3 4 tne reoutrements of NUREG-10222 , and Supplements 1 and 2 to NUREG-1022.

Tne evaluation process for each LER is divided into two parts. The first part of the evaluation consists of documenting comments specific to l

\ Attachment 8 m

01 1

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', ano (2) they provide a basis for a count of general deficiencies for the overall sample 'Rs tnat was reviewed. Likewise, the scores serve two purposes: (1) they l serve to illustrate in numerical terms how tne analysts perceived the l 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 fielas (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields I score = overall LER score).

The results of the LER ouality evaluation are divided into two categories: (1) detailed information and (2) sumary 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 ano 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 coments on a conunent sheet with the LER scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.

Discussion of Resul'.s A discussion of the analysts' conclusiens concerning LER ouality is presentea below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review ano as such represent tne analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the reautrements of

10 CFR 50.73(b). Again, Browns Ferry LERs were' evaluated as one sample, ratner than three separate samples (by unit), because it was determined that the Browns Ferry LERs are both written and f ormally reviewed at the station, rather than the unit, level.

Table 1 presents the average scores for the sample of LERs evaluated f or tne station. Tne reader is cautioned that the scores resulting from the meth00 ology used for this evaluation are not directly Comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.

In order to place the scores provided in Table 1 in perspective, the distribution of the overall average score for all licensees that have been evaluated using the current methodology is provided on Figure 1.

Ado 1tional scores are added to Figure 1 each month as other licensees are evaluatea. Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the averaga scores in Table 1. For example, Browns Ferry's average score for th! text of the LERs that were evaluated is 8.6 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 aifferent reautrements ranging f rom the dir.cussion 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 reautrement was aaoressed by the station for the 10 LERs that were evaluateo. .

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will auickly point out where the station is experiencing the nost difficulty in preparing LERs. For example, reautrement percentage scores of less tnan 75 indicate that the station probably needs additional guidance Concerning these reauirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic reouirement but has either: (1) excluded certain less significant information from most of the discussion concerning that reauirement or (2) totally failed to address the reautrement in one or two of the selected LERs. The station should review m

a TABLE 1.

SUMMARY

OF SCORES FOR BROWNS FERRY 1, 2, 3 Average High low Text 8.6 9.3 6.3 Abstract 8.5 9.8 6.1 Coded Fields 9.0 10.0 8.0 Overall 8.6D 9.3 6.7

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

D. Overall Average = 60% Text Average + 30% Abstract Average + 10% Coced Fields Average.

I

Figure 1. Distribu": ion of overaII average LER scores 15 ,, , , ,, , , , ,,,,,,,,,,,,,,,,,,,,,,. ..

14 - _

13 -

g -

.g 12 - -

2 11 - ~

g 10 - -

g 9- -

1

@ 8- -

._9 7- -

O 5- Browns Ferry -

- 5- -

.$ 4- -

E 7 z a a 3-0 ,, , ,

3, , 3, , , ,

3, , u, , ,,,5,,,,,,3,,,,3,,,,,,,,

7.0 6.5 6.0 9.0 8.5 8.0 7.5 9.5 .

Overall average scores 1

0l l

TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR BROWNS FERRY 1, 2. 3 TEXT Percentage Reouirements [50.73(b)) - Descriptions Scores ( )*

(2)(ii)(A) - - Plant condition prior to event 100 (10)

(2)(ii)(B) - - Inoperable eauipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 92 (10)

(2)(ii)(D) - - Root cause and intermeciate cause(s) 100 (10  !

(2)(ii)(E) - - Mode, mechanism, ano effect 100 (1)) l (2)(11)(F) - - EIIS Codes 95 (10)

(2)(ii)(G) - - Secondary function affectea b

. (2)(ii)(H) - - Estimate of unavailability 90 (5)

(2)(11)(I) - - Method of discovery , 90(10)

(2)(ii)(J)(1) - Operator actions affecting course 100 (6)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 80(8)

(2)(ii)(K) - - Safety system responses 100 (6)

(2)(ii)(L) - - Manufacturer and model no. information 0 (1)

(3) ----- Assessment of safety conseauences 65 (10)

(4) -----

Corrective actions 95 (10)

(5) ----- Previous similar event information 100(10)

(2)(i) - - - - Text presentation 78(10)

ABSTRACT Percentage' ' '

Reauirements (50.73(b)(1)] - Descriptions Scores ( )*

. - Major occurrences (Imeaiate cause and effect 95 (10) information)

- Description of plant, system, component, ana/or 90 (6) personnel responses

. Root cause information 81(10)

- Corrective Action information 93 (10)

- Abstract presentation 73 (10)

g TABLE 2. (continued)

C00E0 FIELOS Percentage item Number (s) - Description Scores ( )*

1, 2, ano 3 - Facility name (unit no.), docket no. and 100 (10) page number (s) 4 - - - - - - T itle 71 (10) 5, 6, and 7 - Event date, LER No., and report date 97 (10) 8 - - - - - - Other f acilities involved 60 (10) 9 and 10 - - Operating mode and power level 100 (10) 11 - - - - - Reporting reouirements -

100(10) 12 - - - - - Licensee contact information 100 (10) 13 - - - - - Coded component failure information 90 (10) 14 ano 15 - - Supplemental report information 100 (10)

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

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

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

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

i l

~

the LER specific comments presented in Appendix D in order to determine why it receiveo less than a perfect score for certain recuirements. The text recuirements with a score of less than 75 are discussed below in their order of importance. In addition, the primary deficiencies in the abstract and coded fields are discusseo.

Six of the ten LCRs evaluated are considered to be deficient in the area of providing an assessment of the safety consecuences and implications of the event, Reauirement 50.73(b)(3). One of the LERs did not contain any l

discussion concerning safety consecuences and five others lacked certain details necessary to a complete discussion. Every LER is recuired to  ;

contain a discussion of the safety assessment that should be performed after the event. If the conclusion of this discussion is that,"there were no safety consecuences", sufficient oetails must be provioen to allow the reaaer to determine how this conclusion was reached. For example, if it was concluded that there were no consecuences because there were other l

systems (or means) available to mitigate the consecuences of the safety system f ailure, these systems or means should be discussed in the text. In addition, each discussion should include informction as to whether or not the occurrence could have happened under a set of initial conditions that ,

would have made the Consecuences more severe. If the occurrence Could not E

have occurred under a more severe set of conditions, the text should so state. It is inadeouate to state "there is no insnediate effect on the . .

safety of the plant because the instruments, which were not cualified, are not recuired under the present plant configuration". The implications of losing these instruments during a plant configuration that does recuire the instruments must be discusseo.

Only one LER of the 10 that were evaluated involved a f ailed component (i.e., LER 86-003-00 for Browns Ferry 1). This LER oescribes a phase-to-phase f ault in a cable (2PP97); however, this cable is not ioentified in the text as to manufacturer, size, and insulation material Information concerning this

[see Reauirement 50.73(b)(2)(ii)(L)]. (Note:

cable was also not incluoen in Item 13 of NRC Form 366.) Properly

'. identifying f ailed components is an important aspect of the LER as it can,

in some cases, lead to the ioentification of generic problems. While the cause of the cable f ailure in Browns Ferry 1 has yet to be determined, others in the incustry would certainly like to know the details concerning this cable if it is learned that this cable's insulation does not conform to the manufacturer's specifications.

The text presentation area receiveo a percentage score of 78%. Tnis score would probably inorove if a consistent text outline were used (see NUREG-1022, Supplement No. 2, Appendices C and D). For example, every text should include outline headings such as: Event Description, Reportability, Cause, Safety Assessment, Corrective Actions, and Similar Occurrences. If applicable, other headings such as: Background, Time Secuences, Plant and/or System Responses, System Descriptions or Generic Implications can be added. Once a basic outline is adopted by all tntie responsible for writing LERs, the overall cuality of the reports vill continue to improve, based simply on the fact that every LER should contain at least the minimum informat. ion concerning the recuirements applicable to each event.

In addition to presenting the text in a consistent outline format, two other text changes should De implementeo. Tne use of acronyms and/or plant specific designators and the references to other units that are not directly involved in the event should be celeted. Specifically, the name of the " Responsible Plant Section" should be spelled' out and the only , ,

unit (s) that should be mentioned in the first sentence of the text (i.e.,

in tne sentence that describes the operating conoitions) is the unit or

~

units airectly involved in the event. Likewise, the "Other Facilities Involved" fielo (Item 8 on NRC Form 366) should be left blank unless another unit was directly affected by the occurrence at the named f acility (Item 1); see NUREG-1022 Supplement No. 2, page 34.

The primary deficiency concerning the abstracts is that the information that is provided in the text is not always summarized in the abstract. While there are no specific recuirenents for an abstract, other 4

k

than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, sunenarize the following information from the text:

1. Cause/Effect The details concerning specifically what happened that made the event reportable.

2. Responses Major plant, system, and personnel responses occurring as a result of the event.

3. Root /Interssediate The underlying cause of the event (i.e., what Causes specifically caused the component f ailure, system failure, or personnel erro,r).

4. Correctiva Actions Details concerning those actions taken to restore the plant to a safe and stable condition and what was done or planneo to prevent recurrence of the event.

There is no reouirement to provide the reporting reouirement or to summarize the safety assessment in an abstract; therefore, this, as well as other, information may be excluded when space becomes a consideration. Of .

the four items previously mentioned, the cause information is the one that was most often oeficient for the 10 abstracts that were evaluated.

Expansion of the abstracts to more fully utilize the 1400 space limit will improve the cuality of the abstracts. The score for abstract presentation (73%) is the result of the brevity of some of the abstracts.

The main deficiency in the area of coded fields involves the title, Item (4). Six of the titles failed to indicate root cause, three failed to include the result (i.e., why the event was reouired to be reported), anc one failed to provide the link between the cause and the rasult. While the result is considered to be the most important part of the title, cause ano link information must be included to make a title complete. An example of

~

0:

a title that only addresses the result might be " Reactor Scram". This is l inadeouate in that the cause and link are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 l Causes Reactor Scram". From this title the reader knows the cause involved either personnel or procedures and that testing linked the personnel error and the scram.

Table 3 provides a summary of the areas that still reautre improvement for the Browns Ferry LERs. For additional and more specific information concerning deficiencies, the reader should refer to the specific information presented in Appendix 0. General guidance concerning these requirenents can be found in NUREG-1022, Supplement No. 2.

It should be noted that this is the second time that the Browns Ferry LERs have been evaluated using this same methodology. The previous evaluation, which was reported in December of 1985, was performed on the unit, rather than station, level; however, af ter averaging the individual units scores from the previous evaluation, a direct comparison of scores for both evaluations was made, see Table 4. As can be seen, Browns Ferry LERs have improved significantly since the previous evaluation and are now well above the Current industry overall average of 7.8.

(Note: The industry overall average is the result of averaging the current overall average scores for each unit / station that has been evaluated using -

this methodology.)

TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR BROWNS FERRY 1, 2, 3 LERs Areas Comments Safety assessment information All LERs must 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 about backup systems that were available to limit the consequences of the event.

Failed component identification Componentidentificatjoninformation such as manufacturer and model number, must be included in the text for each component that fails or is suspected of contributing to the event because of its design.

Text presentation Acronyms and plant specific designators should always be defined on first usage. Only the unit or units that are directly involved in the event should be referred to in the text. The use of an outline format would further enhance the overall qua11ty of the LERs.

Abstracts Four major areas of each text should -

be summarized in every abstract: cause/effect, responses, cause information (including root),

and corrective actions. More of the space available (1400 spaces) should be utilized.

Coded fields

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

l

O TABLE 4. COMPARISON OF LER SCORES FROM PREVIOUS EVALUATIONS Report Date December-85 June-86 Text average 7.6a 6.6 Abstract average 7.7a 8.5 Coded fields average 8.4a 9.0 Overall average 7.7a 8.6

a. These average scores are the result of weight averaging the December-85 scores for the three Browns Ferry units to produce a station, average.

t 0

REFERENCES

1. B. 5. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.

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

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

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

APPENDIX A LER SAMPLE SELECTION INFORMATION FOR BROWNS FERRY 1, 2, AND 3 4

O l

l

tr i

i i

TABLE A 1. LER SAMPLE SELECTION FOR BROWNS FERRY 1, 2, 3 i

Sample Number Unit Number LER Number Comments 1 1 86-001-00 2 1 86-002-00 SCRAM 3 1 86-003-00 4 1 86-006-00 5 2 85-019-00 ESF 6 2 85-020-00 7 3 86-001-00 SCRAM 8 3 86-002-00 ESF 9 3 86-003-00 ESF 10 3 86-004-00 9

1

l

\

W e

APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR BROWNS FERRY 1, 2, AND 3 l

i l

l

TABLE 8-1. EVALUATION SCORES OF INDIVIDUAL LERs FOR BROWNS FERRY 1, 2, 3 i

LER Sample Number a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 15 Test 8.8 8.8 9.0 8.6 9.1 6.3 9.3 9.0 7.8 9.2 -- -- -- -- -- --

Abstract 6.1 9.7 8.5 7. 5 9.4 6.9 9.2 9.4 9. 8 8.8 -- -- -- -- -- --

Coded F 121ds 8.0 9.8 8.0 8.5 9.0 8.2 9.5 10.0 9.5 9.3 -- -- -- -- -- --

! Overall 7.9 9.2 8. 7 8.2 9.2 6.7 9.3 9.2 8. 5 9.1 -- -- -- -- -- --

a LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Test -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.6 Abstract -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.5 Coded

. F 121ds -- -- -- -- -- -- -- -- -- -- -- -- -- -- 9.0 Overall -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.6

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

a c

. APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR BROWNS FERRY 1, 2, AND 3

(

4 8

V TABLE C 1. TEXT DEFICIENCIES AND OBSERVATIONS FOR BROWNS FERRY 1, 2, 3 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )D 50.73(b)(2)(ii)(A)--Plant operating 0 (10) conditions bef ore the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion 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 inadeouate.

50.73(b)(2)(ii)(C)--Failure to include 2 (10) sufficient cate and/or time information.

a. Date information was insufficient. O

b. Time information was insufficient. 2 50.73(b)(2)(ii)(0)--The root cause and/or 0 (10) intermeaiate tailure, system f ailure, or personnel error was not includad or was inadeouate,

a. Cause of component f ailure was not included or was inaaecuate .

b. Cause of system f ailure was not incluaed or was inadeouate

c. Cause of personnel error was not included or was inadeouate.

50.73(b)(2)(ii)(E)--The failure moae, 0 (1) mechanism (immediate cause), and/or effect ,

(conseauence) for each f ailed component was l not incluaed or was inadeauate. I

a. Failure mode was not included or was inadeauate

b. Mechanism (immediate cause) was not included or was inadeauate

c. Effect (consecuence) was not included or was inadeouate.

i

I

\

l T ABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragrapn Description of Deficiencies and Observations Totals a Totals ( )D 50.73(b)(2)(ii)(F)--The Energy Industry 2 (10)

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 (0) component witn multiple functions, a list of systems or secondary functions which .

were also affected was not incluoed or was inaceouate.

50.73(b)(2)(ii)(H)--For a f ailure that 1 (5) renaered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the f ailure until the train was returned to service was not included.

50.73(b)(2)(ii)(1)--The method of discovery 1 (10) of each component f ailure, system f ailure, personnel error, or procedural error was not included or was inadeouate.

a. Method of discovery for each 0 component failure was not included or was inadeouate

b. Method of discovery for each system 0 f ailure was not included or was inadeouate

c. Method of discovery for each 0 personnel error was not included or was inadeouate

d. Methoo of oiscovery for each I procedural error was not included or was inaceouate.

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

TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D 50.73(b)(2)(ti)(J)(1)--Operator actions that 0 (6) aff ected the course of the event including operator errors and/or procedural deficiencies were not included or were inadeouate.

50.73(b)(2)(ii)(J)(2)--The discussion of 2 (8) each personnel error was not included or was .

inadeauate.

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

b. 50.73(b)(2)(ii)(J)(2)(i)--Discussion 0

as to whether the personnel error was

cognitive or procedural was not included or was inadeauate.

c. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 1 g

as to wnetner tne 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 incluaed or was inadecuate.

d. 50.73(b)(2)(11)(J)(2)(iii)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that airectly contributea to the personnel error was not included or was inadeauate.

e. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1 of the type of personnel involved (i.e., contractor personnel, utility

licensea operator, utility nonlicensed ,

operator, other utility personnel) was not included or was inaceouate.

c

U T A8LE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )D 0 (6) 50.73(b)(2)(ii)(K)--Automatic and/or manual

'ssfety system responses were not included or were inadequate.

1 (1) 50.73(b)(2)(ii)(L)--The manuf acturer and/or sodel number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 7 (10) consecuences and implications of the event was not included or was inadeouate.

OBSERVATION: The availability of I a.

other systems or components capable of mitigating the consecuences of the event was not discussed. If no other systems or components were available, the text should state that none

existed.

b. OBSERVATION: The conseauences 6 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 1(10) actions planned as a result of the event including those to reduce the probability of similar events occurring in tne future was not included or was inadeouate.

l l

i l

l D , _ - , - . , , - - , _ , _ _ _ - - - - - _ _ - - - - - - -

l 1

l TABLE C-1. (continued) l Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D

a. A ciscussion of actions reautred to O correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadeouate,

b. A discussion of actions reautred to I reduce the probability of recurrence .

of the problem or similar event (correct the root cause) was not included or was inadeouate.

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

correct the f aulty part in all components with the same manufacturer and model number) was not included or was inadeouate.

50.73(b)(5)--Information concerning previous 0 (10) similar events was not included or was inadeouate.

u TABLE C-1. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )b 50.73(b)(2)(1)--Text presentation 6(10) inadecuacies.

a. OBSERVATION: A diagram would have 1 aided in understanding the text oiscussion.

b. Text contained undefined acronyms 5 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 reautrements. Since an LER can nave more than one deficiency for certain reouirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragr&ph totals do not necessarily add up to the paragraph total.

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

l l

LT TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR BROWNS FERRY 1, 2, 3 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b A summary of occurrences (immediate cause 2 (10) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 1(6) responses was not included or was inadeouate.

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

b. Summary of system responses was not 1 ,

included or was inadequate. I

c. Summary of personnel responses was not 0 incluaed or was inadeouate.

l A summary of the root cause of the event 4 (10) was not included or was inadeouate.

A summary of the corrective actions taken or 2 (10) planned as a result of the event was not included or was inadeouate.

I d

7 TABLE C-2. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )D Abstract presentation inadecuacies 1(10)

a. OBSERVATION: The abstract contains 0 information not included in the text. l The abstract is intended to be a 1 summary of the text, therefore, the text should discuss all information sumarized in the abstract. ,

b. Tne abstract was greater than 0 1400 characters '

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

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

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain reautrements. Since an LER can have more than one deficiency for certain recuirements, (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 aparagraph 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 reautrement was considered applicable.

l l

LT TABLE C-3. CODED FIELOS DEFICIENCIES AND OBSERVATIONS FOR BROWNS FERRY 1, 2, 3 Number of 1.ERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D Facility Name 0 (10)

a. Unit number was not includeo or incorrect.

b. Name was not included or was incorrect.

c. Adottional unit numbers were includeo .

but not required.

Docket Number was not included or was 0(10) incorrect.

Page Number was not included or was 0 (10) incorrect.

Title was lef t blank or was inaaecuate 6(10)

a. Root cause was not given in title 6

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

c. 1. ink was not given in title 1 Event Date 0 (10) .

a. Date not included or was incorrect.

b. Discovery date given instead of event date.

LER Nuniber was not includea or was incorrect 0 (10)

Report Date 1(10)

a. Date not included 0 OBSERVATION: Report date was not I b.

within thirty days of event cote (or discovery cate if appropriate).

I Other Facilities information in field is 4(10) i inconsistent with text and/or abstract. ,

- Operating Mode was not included or was 0(10) inconsistent with text or abstract.

s - - - - -

g TABLE C-3. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )D Power level was not included or was 0 (10) inconsistent with text or abstract Reporting Reauirements 0 (10)

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

b. OBSERVATION: It may have been more ,

appropriate to report the event under a different paragraph.

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

Licensee Contact 0(10)

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 ,

I(10)

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

D. Cause, system, ana/or component code 0 is inconsistent with text,

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

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

l

r TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D Supplemental Report 0 (10)

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

b. The block checked was inconsistent

- with the text.

Expected submission date information is 0 (10) inconsistent with the block checked in item (14).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain reautrenents. Since an LER can have more than one deficiency for certain reoutrements, (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 LER$ that have one or more reautrement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain reouirement was considered applicable, ,

. .. ... g

- APPENDIX 0 LER COMMENT SHEETS FOR BROWNS FERRY 1, 2, AND 3 l

l

TABLE D-1. SPECIFIC LER COMENTS FOR BROWNS FERRY l (259) l

\

Section Comments

1. LER Number: 86-001-00

Overall = 7.9 Scores: Text = 8.8 Abstract = 6.1 Coded F ields = 8.0 )

l Text 1. 50.73(b)(2)(11)(1)--Discussion of the method of discovery of tne technical specification violation is not included.

2. 50.73(b)(4)--A discussion of actions reouired to reouce the probability of recurrence (i.e, correction ,

of the root cause) is not includeo or is inadeouate.

The present employees were counseled, but the text should discuss what could be done to ensure that future employees properly coordinate similar situations.

3. Acronym (s) and/or plant specific designator (s) are undefined, Abstract 1. It is not clear from the abstract that a partially operable channel represents a technical specification violation, nor is it clear that tnis violation lasted 6 minutes.

t

2. 50.73(b)(1)--Summary of root cause is not included.

The abstract should indicate that the technical specification violation occurred because of poor communications between the unit operators and support. ,

personnel.

l, 3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeauate. The abstract should inoicate that personnel were

! counseleo.

Coded Fielas 1. Item (4)--Title: Root cause (persnnnel error) ana .

result (technical specification violation) are not incluaea.

2. Item (7)--0BSERVAT10N: Report date is not within

' tntrty oays of event date (or ciscovery oate if appropriate).

4 t

I

l TABLE D 1. SPECIFIC LER COMMENTS FOR BROWNS FERRY l (259)

Section Comments

2. LER Number: 85-002-00 Abstract = 9.7 Coded Fielos = 9.8 Overall = 9.2 Scores: Text = 8.8 50.73(b)(2)(11)(C)--What was the approximate time l Text 1.

when the isolated systems were returned to normal l during the January 24th event?

)

2. 50.73(b)(2)(ii)(H)--A time estimate of tne )

unavailability of the failed system is inadeouate

)

(see comment 1). 1

3. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of tbe event is inadeouate.

OBSERVATION: The consecuences of the event had it occurred under more severe conditions should be discussed. If the event occorred under what are considered the most severe conditions, the text should so state.

Abstract 1. No comments.

'8 Codeo Fields 1. No connents.

G e 4

.O.

e

'l TABLE D-1. SPECIFIC LER COMMENTS FOR BROWNS FERRY 1 (259)

Section Comments

3. LER Number: 86-003-00 Abstract = 8.5 Coded Fields = 8.0 Overall = 8.7 Scores: Text = 9.0 Text 1. 50.73(b)(2)(ii)(D)--0BSERVATION: Scores for this reautrement are based on the assumption that tne supplemental report will contain all the necessary information.

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

3. 50.73(b)(2)(ii)(L)--Identification (e.g.'manuf acturer and model no.) of the failea component (s) discussed in the text is not included. Information on the faulty cable such as manufacturer, size, rating, ano insulation type should have been provided.

4. 50.73(b)(4)--0BSERVATION: Scores for this reouirement are baseo on the assumption that the supplemental report will contain all the necessary information.

• 5. Acronym (s) and/or plant specific designator (s) are undefined. The functional name for breakers 1232 and 1622 should have been provided.

6. It is not clear from the text discussion how Unit 2 and 3 were airectly affected by this event.

- 7. OBSERVATION: A diagram or figure would aid in understanding the event.

Abstract 1. 50.73(b)(1)--Summary of system (component) responses is not included.

2. The discussion of tne function of cable 2PP97 is clear in the abstract but is not as clear in the text.

f Coded Fields 1. Item (4)--Title: Root cause (unknown) and result (safety system actuations) are not includea. ,

1

2. Item (8)--See text comment number 6.

y 3. Item (13)--Component f ailure occurred but entire .

1 field is blank.

TABLE D-1. SPECIFIC LER COENTS FOR BROWNS FERRY l (259)

Comments Section

4. LER Number: 86-006-00 Abstract = 7.5 Coded Fields = 8.5 Overall = 8.2 Scores: Text = 8.6 Text 1. 50.73(b)(2)(ii)(J)(2)--Tne discussion of the "interf ace problem" appears to be inadeouate. The text should discuss why the proper communication did not occur.

2. 50.73(b)(3)--Discussion of the assessment of the safety consecaences and implications of the event is inadeouate. The assessment should evaluate the

' consecuences had a missile destroyed one of these fans. For example, the discussion should indicate whether or not adeouate backup capacity exists in another system.

3. Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1. 50.73(bl(l)--Summary of occurrences (immediate cause(s? and effects (s)) is inadeouate. The abstract should indicate that the eauipment is considered safety related and is needed for safe shutdown.

- 2. 50.73(b)(1)--Summary of root cause is inadeouate.

The oiscussion should indicate that the eauipment was originally not considered safe,ty related, and, af ter oetermining that it was, a communication error '-

occurred.

Coced Fields 1. Item (4)--Title: Result (possible loss of essential ventilation) and root cause (personnel error) are not included.

ee 1

a TABLE D-1. SPECIFIC LER COMNTS FOR BROWNS FERRY 2 (260)

Section Comments

5. LER Number: 85-019-00 Scores: Text = 9.1 Abstract = 9.4 Coded Fields = 9.0 Overall = 9.2 Text 1. 50.73(b)(3)--Discussion of the assessment of the safety consecuences ano implications of the event is inadeouate. ,

OBSERVATION: The consecuences of the event hao it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state. .

Abstract 1. No coments.

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

6 l

l

TABLE D-1. SPECIFIC LER COMENTS FOR BROWNS FERRY 2 (260)  !

l Section Conments

6. LER Number: 85-020-00 Scores: Text 6.3 Abstract - 6.9 Coded Fields - 8.2 Overall - 6.7 Text 1. 50.73(b)(2)(iil(J)(2)--01scussion of the personnel error is inadequate. l 50.73(b)(2)(ii)(J)(2)(11)--Discussion 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 is not included. ,

i 50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of l personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

Was there a configuration control program in place at the time of construction turnover and, if so, who was )

in charge of using it?

2. 50.73(b)(31--Discussion of the assessment of the l

. safety consequences and implications of the event is h inadequate. What is meant by the phrase 'in the present plant configuration' in the discussion l describing when the technica,1 specifications do not l require the instrumentation in the panel to be  !

operable (last sentence of second paragraph)? 1 OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state.

3. Why is the " Responsible Plant Section" given as NA j (assumed to be-Not Applicable)? Wasn't some plant j section responsible for the configuration control program? (See text consent number 1).

4. Why is Unit 2 given as the "only unit affected by this event" when it appears that Unit I has not yet (

been analyzed and may also require corrective actions prior to restart.

l 1

TABLE D-1. SPECIFIC LER COMENTS FOR 8ROWNS FERRY 2 (260)

Section Connents

6. LER Number: 85-020-00 (continued)

Abstract 1. 50.73(b)(1)--Summary of root cause is not incluoed.

2. Abstract does not adeouately sunnarize the text.

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

Coded Fields 1. Item (4)--Title: Root cause ana link (seismic oualification) are not included.

2. Item (8)--While it appears that Unit I could be af fecteo (see text consent 4), inclusion of Units 1 and 3 in this field contradicts the last sentence of paragraph 1 in the text.

o b

I t

b l

l

TABLE D-1. SPECIFIC LER COMNTS FOR BROWNS FERRY 3 (296)

Section Comments

7. LER Number: 86-001-00 Scores: Text = 9.3 Abstract = 9.2 Coded Fields = 9.5 Overall = 9.3 Text 1. 50.73(b)(2)(ii)(K)--Listing the affected systems is good.

2. 50.73(b)(3)--0BSERVATION: The consecuences of the event had it occurred under more severe conditions should be discussed. If the event occurrea under what are considered the most severe conditions, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of corrective actions l taken or planned as a result of the event is inadeouate. The counseling of the responsible operator should be mentioned.

Cooed Fields 1. Item (8)--Information in field is inconsistent with text and/or abstract. The first paragraph of the text implies that Units 1 and 2 were also involved.

l T

l l

TABLE D-1. SPECIFIC LER COPMENTS FOR BROWNS FERRY 3 (296)

Section Connents

8. LER Number: 86-002-00 Scores: Text = 9.0 Abstract = 9.4 Coded Fielos = 10.0 Overall = 9.2 Text 1. 50.73(b)(2)(ii)(C)--Approximate time information for major occurrences is inadeouate. When was switch 14A-5159 returned to normal and the diesel generators secured?

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

3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadecuate. It is not clear why both the f electricians and the operators responsible for

, verification overlooked the step.

4. 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 inadeauate. Is the " assistant shift engineer" the sane person as the

" operator" that did not verify the misseo step?

Aostract 1. No comments.

Coded Fields 1. No comments. .

l

)

TABLE D-1. SPECIFIC LER COMNTS FOR BROWNS FERRY 3 (296)

Section Comments

9. LER Number: 86-003-00 Scores: Text = 7.8 Abstract = 9.8 Coaed Fields = 9.5 Overall = 8.5 Text 1. 50.73(b)(2)(11)(C)--Time information for major occurrences is inadeouate. At what time were the affected systems returned to their nornial alignment?

l

2. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is ,

not included. l 3

3. 50.73(b)(4)--What was wrong with tr.e SI (SI 4.2.A-10) I that reautred a general rewrite to be initiated? l

4. Acronym (s) and/or plant specific designator (s) are undefined. The "IM" after Responsible Plant Section should be defined. l l

Abstract 1. No comments.

Coded Fields 1. Item (8)--Information in field is inconsistent with text and/or abstract. From the information in the text and abstract it appears that Units 1 and 2 are  ;

not directly involved in the event and therefore, should not have been included in Item (8). ,

i i

e

• t TABLE D-1. SPECIFIC LER COMMENTS FOR BROWNS FERRY 3 (296) l Section Comments f 10. LER Number: 86-004-00 l

Abstract = 8.8 Overall = 9.1 Scores: Text = 9.2 Coded Fields = 9.3

( Text 1. 50.73(b)(2)(ii)(F)--The EIIS component code for the pump shoulo be included.

2. 50.73(b)(3)--0BSERVATION: The consecuences of the

{ event had it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the

. text should so state.

3. Acronym (s) and/or plant specific designator (s) are unaefined.

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

The complexity of the recuirements and the oversight by shif t personnel should be mentioned.

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

1 i.

1

- 1 EN CLo S u d 6 A. -

SLNWIARY l An evaluation of the content and quality of a representative sample of j the Licensee Event Reports (LERs) submitted by Sequoyah 1 and 2 during the

. December 1, 1985 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in NUREG/CR-4178. This is the second time that the Sequoyah LERs have been evaluated using this methodology. The results of this evaluation indicate that Sequoyah station now has an overall l average LER score of 8.5 out of a possible 10 points, compared to their previous overall average score of 7.2 and a current industry average score of 7.8 for those units / stations that have been evaluated to date using this methodology. )

The principle weakness identified in the LERs, in terms of safety significance, involves the requirement to assess the safety consequences and tap 11 cations of the event. Deficiencies in the safety consequence discussion prompts concern as to whether or not events are being evaluated such that the possible consequences of the event, had it occurred under a i different set of initial conditions, are being identified.

A strong point for the Sequoyah LERs is that.'the root cause and corrective action discussions are generally well written. The mode, mechanism, and effect, and the identification of failed components are also presented very well.

^

l l

1 l

~

Attachment A l m

- - - ew

AE00 INPUT TO SALP REVIEW FOR SEQUOYAH 1 AND 2 Introduction In order to evaluate the overall cuality of the contents of the Licensee Event Reports (LERs) submitted oy Seouoyah I and 2 during the December 1, 1985 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presentea in NUREG/CR-4178. The sample consists of a total of 7 LERs for the station (i.e., 6 LERs for Seouoyah 1 and I for Seouoyah 2), which represents all of the LERs that were on file at the time the evaluation was started. Seouoyah's LERs were evaluated as one sample because it was deter 1nineo that their LERs are both written and formally reviewea at the station, rather tnan unit, level. See Appenoix A for a list of the LER numbers in the sample.

g it was necessary to start the evaluation before the end of the SALP assessment period because ti.e input was due such a short time after the end j of the SALP period. Therefore, not all of the LERs preparec 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, ano coded fields meet the recuirements of NUREG-10222 , and Supplements 1 3 and 2 to NUREG-1022.

The evaluation process for each LER is divided into two parts. The first part of tne 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.

Attachment B l

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 fcr a count of general deficiencies for the overall sample of LERs

'tnat 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 presentea, ano (2) they provide a basis for the determination of 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 fielos (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 ouality 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 e

narrative statements concerning the contents of each LER (Appendix D).

When referring to Appendix 0, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER' --

scores, as the analyst has flexibility to consider the magnitude of a deficiency when assigning scores.

Discussion of Results A discussion of the analysts' conclusions concerning LER ouality is presented below. These conclusions are basea solely on the results of tne ,

evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b). Again, Seouoyah 1 ana 2 were evaluated as a station, ratner than two separate units, because it was determined that the u

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

r .. -

Table 1 presents the average scores for the sample of LERs evaluatea f or Seouoyah. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the l scores contained in NUREG/CR-4178 cue to refinements in the methodology.

'In oraer to place the scores provided in Table 1 in perspective, the distribution of the overall score for all licensees that have been evaluated using the Current methodology are provided in Figure 1.

Additional scores are added to Figure I each month as other licensees are evaluated. Table 2 and Appendix Table 8-1 provide a sumary of the information that is the basis for the average scores in Table 1. For example, Secuoyah's average score for the text of the LERs that were  !

evaluated is 8.6 out of a possible 10 points. From Table 2 it 'can be seen that the text score actually results from the review ano evaluation of 17 different reauirements 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 recuirement was addressed by )

the station for the 7 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will cuickly l point out where Seou0yah station is experiencing the most difficulty in preparing LERs. For example, reouirement percentage scores of less than 75 indicate that the station probably needs additional guidance concerning these reauirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic recuirement but has f either: (1) excluaed certain less significant information from most of the discussions concerning that reauirement or (2) totally failed to address the recuirement in one or two of the selected LERs. Tne station should review the LER specific comments presented in Appendix D in order to determine why it received less tnan a perfect score for certain

)

reouirements. The text reouirements with a score of less than 75 are discussed below in their order of importance. In addition, the primary deficiencies concerning the abstracts and coaed fields are presented.

l a

TABLE 1. SU R RY OF SCORES FOR SEQUOYAH 1, 2 l Average High low Text 8.6 9.6 7.0 Abstract 8.1 9.1 6.9 Coded Fields 8.8 9.3 8.0 Overall 8.5b 9.3 7.1 l

\

a. See Appendix 8 for a summary of scores for each LER that was evaluated. .

b. Overall Average = 60% Text Average + 30% Abstract Average + 10% Coded Fields Average.

O e ,

O

.1.__,__. . _ . _ . _ . . _ . . .

Figure t. Distribution of overa 1 average LER scores 15 ... .

i

i. .iii .. i....ii...i....

14 -

g 13 -

12 -

.] 11 -

2 10 -

g -

@ 9-

@ 8-

._9 7-Sequoyah1.2 _

o g 5-4-

3-

~

a 7 7 7 7 7

.. . . i. . i . . ..

. . i . .i i 9.5 9.0 8.5 [ 8.0 7.5 7.0 6.5 6.0 Overall average scores

l TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR SEQUOYAH 1, 2  !

TEXT Percentage Reouirements [50.73(b)] - Descriptions Scores ( )*

(2)(ii)(A) - - Plant condition prior to event 79 (7)

(2)(ii)(B) - - Inoperable eouipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 93(7)

(2)(ii)(D) - - Root cause and intermediate cause(s) 100 (7)

(2)(ii)(E) - - Mode, mechanism, and effect 100 (1)

(2)(ii)(F) - - Ells Codes 29 (7)

(2)(ii)(G) - - Secondary function affectea b (2)(ii)(H) - - Estimate of unavailability . 100 (3)

(2)(11)(1) - - Method of discovery 93(7)

(2)(ii)(J)(1) - Operator actions affecting course (0) 1 (2)(ii)(J)(2) - Personnel error (procedural deficiency) 83(6) l (2)(ii)(K) - - Safety system responses 100 (1)

(2)(ii)(L) - - Manufacturer and model no. information 100(1)

(3) -----

Assessment of safety consecuences 74 (7)

(4) -----

Corrective actions 94(7)

(5) ----- Previous similar event information 93 (7)

(2)(i) - - - - Text presentation 84 (7)

ABSTRACT Percentage Reouirements [50.73(b)(1)] - Descriptions Scores ( )a

- Major occurrences (Immediate cause and effect 90(7) information)

- Description of plant, system, component, and/or (0) personnel responses

- Root cause information 71 (7)

- Corrective Action information 89 (7)

- Abstract presentation 72(7) i

TABLE 2. (continued)

CODED FIELDS Percentage Item Number (s) - Description Scores ( )a 1, 2, and 3 - Facility name (unit no.), docket no. and 100 (7) J page numoer(s) 4 - - - - - - T itle 63 (7) 5, 6, and 7 - Event date, LER No., and report date 100 (7) l I

8 - - - - - - Other f acilities involved 51 (7) -

9 and 10 - - Operating mode and power level 100 (7) 11----- Reporting reauirements 100 (7) 12 - - - - - Licensee contact information 100 (7) 13 - - - - - Coded component f ailure information 100 (7) 14 and 15 - - Supplemental report information 100 (7)

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

(Note: Some reouirements 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 whicn the reauirement was considereo applicable,

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

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

1 i

The safety assessments for three of the LERs were found to be deficient. A detailed safety assessment is required in all LERs and should include three items as follows:

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 during the event are co'nsidered the worst probable, the LER should state so.

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

The Energy Industry Identification System component function identifier and system name codes were not provided'in the text of five of ..

the seven LERs that were evaluated.

- The text presentations were generally good. The use of a consistent outline format aided in the understanding of the event, and allowed the analysts to more easily identify specific requirements.

The primary deficiency for the abstracts involved the root cause information. While the text identified the root cause of each event very well, six abstracts did not adequately summarize this information. In addition, the abstracts were considered marginal in the area of presentation. Two abstracts were so brief that they failed to contain the necessary information even though space was available to present the required details. One abstract also contained information that was not

discussed in the text. This should be checked for during the final review process and when found, the text should be revised to include the information.

The main deficiency in the area of coded fields involves the title, Item (4). Six of the 7 titles do not indicate root cause, one failed to include the link (i.e., circumstances or conditions which tie the root cause to the result), and one failed to provide information concerning the result of the event (i.e., why the event was required to be reported). An

~

example of a title which gives little indication of the event is

" Administrative Control of High Radiation Areas", (see LER 327-85-047). it is not apparent from reading this title what the problem is. , " Inadequate Administration Control of High Radiation Areas" is a better title, as the result is now more definitive. While the result is considered the most important part of the title, cause and link must be included to make the title complete. " Inadequate Administrative Control of High Radiation Areas Caused by use of Improper Padlocks" is a more complete title, as the cause and link are now included. While this may not be a perfect title for this event, it basically describes the idea of result, cause, and link. ,

i e l Another deficiency in the area of coded fields was that the Other facilities Involved, Item 8, was filled in for four LERs, while the text did not indicate how the other facility was involved. This block need only be filled in when the event is common to, or directly affects the other unit. If this is the case, the text should include a description of specifically how the other unit was affected.

Table 3 provides a sunenary of the areas that need improvement for the station's LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and D. General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 2.

1 I

1 1

I -

)

1 It should be noted that this is the second tire that the SeCuoyah LERs l have been evaluated using this same methodology. The previous evaluation, which was reported in December of 1985, was performed on the unit, rather than the station level; however, after averaging the individual units l Scores f rom the previous evaluation, a direct comparison of scores for both  ;

evaluations can be made, see Table 4. As can be seen, Seouoyah LERs have improved significantly since the previous evaluation, due in part to the use of an outline format, and are now well above the current industry overall average of 7.8. (Note: The industry overall average is the result of averaging the current overall average scores for each unit / station that has been evaluated using this methodology.)

I 1

)

l l

\

l

'9 l

l TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR SEQUOYAH 1, 2 LERs 1

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 about backup systems which were available to limit the l consecuences of the event.

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

Abstracts A more complete summary of the root I cause information is needed. Some i abstracts did not utilize the space )

available to include this information. Also, any information that is included in the abstract must also be included in the text.

Coded fields

a. Title Titles that provide the result, root cause, and the link between them ,

should be used, j

b. Other facilities Only when the event is Common to or directly affcts other units should this block (Item 8) be filled in.

When another unit is directly affected, the text of the LER should provide information detailing how the other unit was involved.

1 i

I l

TABLE 4. COMPARISDN OF LER SCORES FROM PREVIOUS EVALUATIONS December-85 June-86 Text average 7.8a 8.6 Abstract average 5.6a 8.1 Cooea fields average 8.Sa 8.8 Overall average 7.2^ 8.5

a. These average scores are the result of weight averaging the December-85 scores for the two Sequoyah units to produce a station average ,

P e

0

REFERENCES

1. B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73

{ DRAFT), NUREG/CR-4178, March 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.

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

l l

, 9 APPENDIX A LER SAMPLE SELECTION INFORMATION FOR SEQUOYAH I AND 2 N

g TABLE A-1. LER SAMPLE SELECTION FOR SEQUOYAH 1, 2 1

ISample Number Unit Number LER Number Consnents 1 1 85-047-00 2 1 85-048-00 3 1 85-049-00 4 1 85-050-00 ESF 5 1 85-051-00 ,

6 1 86-007-000 7 2 85-012-00 i

.:l h

w

0 APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR SEQUOYAH 1 AND 2 l

l sO

TA8LE 8-1. EVALUATION SCORES OF INDIVIOUAL LERs FOR SEQUOVAH 1, 2 ,

LER Sample Number

• 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1 6__

l Tcut 7.0 9.3 8.8 9.3 7. 2 9.3 9. 6 -- -- -- -- -- -- -- -- --

Abstract 6.9 7. 9 7. 5 8. 8 7. 7 9.1 8. 6 -- -- -- -- -- -- -- -- --

Coded F121ds 8.0 9.0 8.5 0.8 9.2 9.1 9.3 -- -- -- -- -- -- -- -- --

Overall 7.1 8. 8 8.3 9.1 7. 6 9.2 9.3 -- -- -- -- -- -- -- -- --

LER Sample Number a 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8. 6 Abstract -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.1 Coded F121ds -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.a

, Overall -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8. 5

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

~.

O 4

d

tJ k

N APPENDIX C DEFICIENCY AND OBSERVATION

< COUNTS FOR SEQUOYAH I AND 2 P'

C 4

e

.memm omew ,.-- . , . . , . . .

.t #

TEXT DEFICIENCIES AND OBSERVATIONS FOR SEQUOYAH 1, 2 TABLE C 1.

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Totals a Totals ( )b Description of Deficiencies and Observations _ 2 (7) 50.73(b)(2)(ii)(A)_--Plant operating conditions before the event were not included or were inadeouate.

0 (1) 50.73(b)(2)(ii)(B)--Discussion of the status 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 inadeouate.

-1 (7) 50.73(b)(2)(ii)(C)--Failure to include suf ficient date and/or time information.

I

a. Date information was insufficient. 0

b. Time information was insufficient.

0 (7) 50.73(b)(2)(ii)(0)--The root cause and/or intermediate f ailure, system f ailure, or personnel error was not included or was inaaeouate,

a. Cause of component f ailure was not - '.

included or was inadeouate

b. Cause of system f ailure was not included or was inaceouate

c. Cause of personnel error was not included or was inadeouate.

0 (1) 50.73(b)(2)(ii)(E)--The f ailure mode, mecnanism (inrnediate cause), and/or effect (consecuence) for each f ailed component was not included or was inaceouate.

a. Failure mooe was not included or was inadeouate

b. Mechanism (innediate cause) was not included or was inadeouate

c. Effect (consecuence) was not included or was inadeouate.

o

y TABLE C-1. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )D 50.73(b)(2)(ii)(F)--The Energy Industry 5 (7)

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

50.73(b)(2)(ii)(G?--For a f ailure of a 0 (0) cc:nponent with nuLtiple functions, a list

• of systems or secondary functions which were also affected was not included or was inadeouate.

50.73(b)(2)(ii)(H)--For a f ailure that 0 (3) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the f ailure until the train was returned to service was not included.

s 50.73(b)(2)(ii)(I)--The method of discovery 1 (7) of each component failure, system f ailure, personnel error, or procedural error was not included or was inaaecuate. .

a. Method of oiscovery for each 0 component failure was not incluoed or was inadeauate

b. Method of discovery for each system 0 failure was not incluaed or was inadeouate

c. Method of discovery for each I personnel error was not included or was inadeouate

c. Method of discovery for each 0 procedural error was not included or was inadeouate.

i l

l

TABLE C l. (continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D 50.73(b)(2)(ii)(J)(1)--Operator actions that 0 (0) ,

af fected the course of the event including l operator errors and/or procedural l deficiencies were not included or were inadeouate.

50.73(b)(2)(ii)(J)(2)--The discussion of 2 (6) ,

each personnel error was not included or was = l inadeouate.

i

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

o. 50. 73( b) ( 2 ) ( i i) ( J) ( 2) ( i )--D iscu s s ion 1 l as to whether the personnel error was l cognitive or procedural was not included or was inadeouate. j

c. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 0 l

. as to wnetner tne personnel error was l contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated i

~

with an activity or task that was not .

)

covered by an approved procedure was not included or was inadeouate.

d. 50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0 I of any unusual characteristics of the l work location (e.g., heat, noise) that directly contributed to the personnel  ;

error was not included or was l inadeouate. 1

e. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 2 of the type of personneI involved (i.e., contractor personnel, utility

, licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadeouate.

1 I

1

. l TABLE C-1. (continued)

Number of LERs witn Deficiencies and i Observations l Sub-paragraph Paragraph Description of Deficiencies ano Observations Totals a Totals ( )b 1

50.73(b)(2)(ii)(Kl--Automaticana/ormanual 0 (1)  ;

safety system responses were not included or j were inadequate. .

50.73(b)(2)(ii)(L)--The manufacturer and/or 0 (1) '

model number of each f ailed component was not included or was inadeauate. .

50.73(b)(3)--An assessment of the safety 3 (7) consecuences and implications of the event was not included or was inadeouate.

a. OBSERVATION: The availability of 2 other systems or components capable of mitigating the consecuences of the

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

b. OBSERVATION: The conseauences I 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 2 (7) actions planned as a result of the event including those to reauce the probability of similar events occurring in the future '

was not included or was inaceauate. l

m l

TABLE C-1. (continued)

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

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

b. A discussion of actions required to O reduce the probability of recurrence

• of the problem or similar event (correct the root cause) was not included or was inadeauate.

c. OBSERVATION: A oiscussion of actions I recuired to prevent similar f ailures in similar and/or other systems (e.g.,

correct the f aulty part in all components with the same manufacturer and model number) was not included or was inaceauate.

50.73(b)(5)--Information concerning previous 1 (7) similar events was not included or was inadeauate. -

l

TABLE C-1. (continued)

Number of LERs with Deficiencies and 00servations Sub-paragrapn Paragraph a

Description of Deficiencies and Observations Totals Totals ( )D i

50.73(b)(2)(1)--Text presentation 1 (7) inaceauacies.

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

discussion. 1

b. Text contained undefined acronyms 1 l

and/or plant specific designators.

c. The text contains other specific 0 l deficiencies relating to the '

readability.

l

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

observations within certain reauirements. Since an LER can have more than (

one deficiency for certain reauirements, (e.g., an LER can be deficient in  ;

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

b. The " paragraph total" is the number of LERs that have one or more reauirement deficiencies or observations. The number in parenthesis is the number of LERs for which the reauirement was c0nsidered applicable. -

m -

e ->

TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR SEQUOYAH 1, 2 l

Number of LERs with Deficiencies and Observations l

l Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

• Totals ( )b A summary of occurrences (immediate cause 3 (7) and effect) was not included or was inadeouate A summary of plant, system, and/or personnel 0 (0) i responses was not ihcluded or was inadeouate.

a. Sunnary of plant responses was not included or was inadeouate.

b. Summary of system responses was not included or was inaceouate.

c. Summary of personnel responses was not incluoed or was inadeouate.

A sunmary of the root cause of the event 6 (7) was not included or was inadeouate. )

A summary of the corrective actions taken or 2 (7)  ;

planned as a result of the event was not included or was inadeouate.

TABLE C-2. (continued)

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

• Totals ( )D Abstract presentation inadeauacies 3 (7)

a. OBSERVATION: The abstract contains 1 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 2

. deficiencies (i.e., poor summarization, contradictions, etc.)

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain reauirements. Since an LER can have more than one deficiency for certain reauirements, (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 deficiency or observation. The number in parenthesis is the number of LERs for which a certain reauireaent was considered applicable.

l 1

1 1

l

TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SEQUOYAH 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )D Facility Name 0 (7)

a. Unit number was not included or incorrect.

b. Name was not included or was incorrect.

c. Additional unit numbers were included but not recuired.

Docket Number was not included or was 0 (7) incorrect.

l Page Number was not included or was 0 (7) incorrect.

Title was lef t blank or was inaaeouate 6 (7) o a. Root cause was not given in title 6

b. Result (effect) was not given in title 1 ,

c. Link was not given in title 1 Event Date 0 (7) .

a. Date not incluoed or was incorrect.

b. Discovery date given instead of event date.

LER Number was not included or was incorrect 0 (7)

Report Date 0 (7)

a. Date not included O. OBSERVATION: Report aate was not )

within thirty days of event date (or j discovery date if appropriate).

Other Facilities information in field is 4 (7) inconsistent with text and/or abstract.

! Operating Mode was not included or was 0 (7) inconsistent with text or abstract.

J* ,

O TABLE C-3. (continued)

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

a j Description of Deficiencies and Observations Totals Totals ( )D Power level was not included or was 0 (7) inconsistent with text or abstract l

Reporting Recuirements 0 (7)

a. The reason for enecking the "0THER" requirement was not specified in the -

)

abstract and/or text.

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

c. OBSERVATION: It may have been appropriate to report this event under an adaitional unchecked paragraph, 1

Licensee Contact 0 (7) l

a. Field left blank a b. Position title was not included

c. Name was not included -

d. Phone number was not included.

Coded Component Failure Information 0*(7)

a. One or more component f ailure sub-fields were left blank.

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

c. Component f ailure field contains data when no component failure occurred.

d. Component f ailure occurreo but entire field left blank.

l l

l 1

A* .

e

TABLE C-3. (continued)

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

• Totals ( )b Supplemental Report 0 (7)

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

b. The block checked was inconsistent with the text.

Expected submission date information is 0 (7) inconsistent with the block checked in Item (14).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain recuirements. Since an LER can have more than one deficiency for certain reouirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals ao not necessarily add up to the paragraph total.

b. The " paragraph total" is the number of LERs that have one or more reouirement aeficiencies or observations. The number in parenthesis is the

number of LERs for which a Certain reouirement was Considered applicable. * . '

I i

i l

l l

l l

1 APPENDIX 0 LER COMMENT SHEETS FOR SEQUOYAH I AND 2 O

l .

,- . a. .:.. . u TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 (327)

Comments Section

1. LER Number: 85-047-00 Coded Fields = 8.0 Overall = 7.1 Scores: Text = 7.0 Abstract = 6.9

1. 50.73(b)(2)(ii)(C)--How long had the ISI Group from Text Browns terry oeen at the plant before the condition was discovered?

2. 50.73(b)(2)(ii)(I)--Discussion of the method of oiscovery or tne extra keys is inadequate. The text i should be specific as to how the extra keys were discovereo.

3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadeouate.

50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is not included.

50.73(b)(2)(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.

4. 50.73(b)(3) -Discussion of the assessment of the safety consecuences and implications of the event is inadeauate. The text should indicate whether or not any violations occurred. One thing that might be consioered in a safety analysis for this event is to assess the probability that any of the people with keys would have entered a restricted area without proper permission, that is, were the personnel aware of the r estricted area (e.g., signs posted on doors) and aware of proper procedures (e.g., given briefings on Seouoyah to highlight the differences, if any, f rom Browns Ferry).

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadeouate. OBSERVATION: Additional corrective actions based on the generic implications of the failure or error should be considered and discussed if applicable. Are there other controlled access areas of the plant where these type locks coulo be in use?

n - .ye

0 TABLE 0-1. SPECIFIC LER COMMENTS FOR SEQ 00YAH I (327)

Section Comments

1. LER Number: 85-047-00 (continued)

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadeouate. Tne abstract should make it clear that the employees from Browns Ferry were not violating any rules by having these keys and that the key went to locks used by the Browns Ferry personnel for storage eauipment rooms and tools boxes, d

2. 50.73(b)(1)--Summary of root cause is inadeauate.

The abstract should indicate that improper locks (non-security locks) were procured by Seouoyah personnel. This goes along closely with abstract comment 1.

Coded Fields 1. Item (4)--Title: Result (uncontrolled security keys) and root cause (personnel error curing procurement) are not included.

2. Item (8)--The text and abstract shoula indicate how the second unit was affected.

I I

l 1

1

\ l

Ul 1

TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 (327)

Section Comments

2. LER Number: 85-048-00 Scores: Text = 9.3 Abstract = 7.9 Coded Fields = 9.0 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included. This information is reouired to be included in all LERs.

2. Acronym (s) and/or plant specific designator (s) are undefined. SQN personnel.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inaceauate. The abstract should state that the PORC review is reautrea by Technical Specifications.

2. 50.73(b)(1)--Summary of root cause is inadeauate.

The information presented in the "Cause'of the Event" section of the text should be summarized in the abstract.

3. Abstract does not adeauately summarize the text.

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

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

TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 (327)

Section Comments

3. LER Number: 85-049-00 Scores: Text = 8.8 Abstract = 7.5 Coded Fields = 8.5 Overall = 8.3 Text 1. 50.73(b)(2)(ii)(F)--The Energy Incustry identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (1.e., contractor personnel, utility licensed operator, utility nonlicensed operator o Who (title)ther or what utility personnel) group failed toisrecognize not included. the scheduling difficulties?

3. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is inadeouate. What could have been the consecuences had these analyzers been truly inoperable as opposed to " technically" inoperable? LER 85-012-00 for Unit 2 is a good example of the kind of information that should be provided.

g OBSERVATION: The availability of other systems or components capable of mitigating the consecuences of the event should be discusseo. If no otner systems. -

or components are available, the text should so state.

4 50.73(b)(4)--The actions taken concerning corrective

actions were very comprehensive.

5. 50.73(b)(5)--The statement concerning previous occurrences is considered marginal in that the reader is not certain of the definition of "this event" in

! the last sentence of the text (or, likewise, the definition of " occurrences of this type" in the last i sentence of the abstract). If the definition of

{ "this event" is " failure to perform surveillance on the waste gas hydrogen and oxygen analyzers when ,

j required", that definition for a previous occurrence ,

is considered to be too restrictive. A more appropriate definitinn of a previous occurrence of this type might be "any event involving the failure

, .:: to perform any surveillance due to scheduling difficulties". Although not a specific reautrement, l

tr TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 (327) i Section Comments

3. LER Number: 85-049-00 (continued) )

it would help the LER users if the categorization scheme is included in the previous occurrences discussion. For example, instead of simply stating "there were no previous occurrences", it would be better to say "there were no previous occurrences involving missed surveillances due to shceduling difficulties."

Abstract 1. 50.73(b1(1)--Summary of occurrences [imagdiate cause(s? and effects (s)] is inadeauate. It should be clearly stated that a recuired Technical Specification surveillance was missed. .

2. 50.73(b)[1)--Summary of root cause is inadeauate.

The problem of the monthly versus the cuarterly a

extension period should have been mentioned,

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadeauate. The fact that the cuarterly calibration package has been revised should be mentioned.

4 Additional space is available within the abstract field to provide the necessary information but it was -

not utilized.

Coded Fields 1. Item (4)--Title: Root cause is not included. A better title might be " Scheduling Difficulties Result in Failure to Perform Tech Spec Surveillance When Reouired."

2. Item (8)--Information in field is inconsistent with text and/or abstract. It is not clear from the text or abstract how Unit 2 is directly involved in (affected by) this event.

9 TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH I (327)

Section Comments  ;

l

4. LER Number: 85-050-00 Scores: Text = 9.3 Abstract = 8.8 Coded Fields = 8.8 Overall = 9.1 Text 1. 50.73(b)(2)(ti)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referrea to in the LER is not included.

Abstract 1. 50.73(b)(1)--Summary of root cause is inadeouate. i The summary should also indicate that the supply plug I mold and power supply were checked and found to be 1 operable. l l

Coded Fields 1. Item (4)--Title: Root cause (faulty connector pins and/or loss of power) and link (false high radiation signal) are not included, l

e s

9

l l TABLE 0-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 ('327)

Section Comments

5. LER Number: 85-051-00 Scores: Text = 7.2 Abstract = 7.7 Coded Fields = 9.2 Overall = 7.6 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(ii)(J)(2)(iv)--From the information provided concerning the circumstances as to why the fire watches were missed, it appears to the analyst that the decision to discontinue the fire watch was justified. However, the text needs to indicate who was respansible for this decision (i.e., Shif t Supervisor, Health Physics, etc.).

3. 50.73(b)(3)--Discussion of the assessment of the safety consecuences and implications of the event is inadeouate.

OBSERVATION: The availability of otner systems or components capable of mitigating the consecuences of the event should be discussed. If no other systems or components are available, the text should so state (i.e., Fire Detection System).,

OBSERVATION: The consecuences of the event had it "

occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state. If a fire was "noted", how would it be detected?

4. 50.73(b)(4)--Discussion of corrective actions taken '

or planned is inadeouate. Why did it take so long to establish a dedicated fire watch for the contaminated areas. Information such as the unavailability of personnel, if this was the case, should be provided.

5. 50.73(b)(5)--Information concerning previous similar events is inadeouate. Were there any previous occurrences of missed fire watches due to inaccessibility of an area?

1

w TABLE 0-1. SPECIFIC LER C0$91ENTS FOR SEQUOYAH 1 (327)

Section Comments

5. LER Number: 85-051-00 (continued)

Abstract 1. 50.73(o)(1)--Sumary of corrective actions taken or planneo as a result of the event is inadeouate. See text comment 4.

2. OBSERVATION: Tne abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should

discuss all information summarized in the abstract.

Cooed Fields 1. It is not clear to the reader how both units were affected (Items 1 and 8). Are the 2A-S AFW terry turbine room ana the 2A CCP room conunon to both units?

I 1

l

^

= o

. .. 3 -

• • r i

TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 1 (327)

Section Comments

6. LER Number: 86-007-00 Scores: Text = 9.3 ADstract = 9.1 Coded Fields = 9.1 Overall = 9.2 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is inadeouate. The text should briefly describe the operating mode number.

The temperatures given do not allow a reaoer to distinguish between cold shutoown and refueling modes.

2. 50.73(b)(2)(ii)(F)--The Energy Inoustry Identification System component function ,

identifier (s) and/or system name of each component or system referreo to in the LER is not included.

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

The text should inoicate that the cause of the event was a switch that was not included in the surveillance program oue to an unknown problem.

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

2. Item (8)--Information in field is inconsistent with text and/or abstract. The abstract and text do not indicate how Unit 2 was affectea. Tne discussions should it.dicate whether or not'the surveillance procedure is common to both units.

l I

l l

TABLE D-1. SPECIFIC LER COMMENTS FOR SEQUOYAH 2 (328) 1 i

l Section Comments

7. LER Number: 85-012-00 Scores: Text = 9.6 Abstract = 8.6 Cooeo Fields = 9.3 Overall = 9.3 l Text 1. 50.73(b)(2)(ii)(A)--The operating conditions for Unit I are not reouired in the text unless Unit 1 is  !

directly affected by the event. )

1

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

3. 50.73(b)(5)--Instead of simply stating "there are no previous events of this kind", it would be better to state "there have been no previous events l involving- ," in which a definition of the event is provided. Because the reader does not know precisely how the event was categorized, he is not sure whether or not there have been no previous events involving: violations of an LCO, nonseismically cualified systems, personnel errors resulting in LC0 violations, or some combination of these possible definitions for a previous similar event.

Abstract 1. 50.73(b)(1)--Summary of root cause (i.e., the cognitive personnel error) is not includeo. -

Cooeo Fields 1. Item (4)--Title: Root cause is not incluaed. l l

. l I

1 l

3

- l

. . _.