ML20214L060

Forwards AEOD SALP Input for Facilities Operations (LER Quality) for Oct 1985 - Sept 1986.LERs Sampled of Very High Quality

ML20214L060
Person / Time
Site:	Salem
Issue date:	11/19/1986
From:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil Public Service Enterprise Group
References
NUDOCS 8612020558
Download: ML20214L060 (44)

Text

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19 NOV 1988 Docket Nos. 50-272 50-311 Public Service Electric and Gas Company ATTN: Mr. Corbin A. McNeill, Jr.

Vice President - Nuclear P. O. Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:

Subject:

Assessment of the Quality of Licensee Event Reports (LERs) - Salem Generating Station As part of the SALP process, the NRC Office for Analysis and Evaluation of Operation Cata (AE00) evaluated LERs submitted during the recent SALP assessment period for the Salem Generating Station. The assessments (portions enclosed) were performed using a methodology similar to that described in NUREG/CR-4178, "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73."

The NRC considers it important to achieve uniform, high quality LERs from all operating power reactors to enable licensees and AE00 to effectively identify

" precursor events" and emerging trends or patterns of potential safety significance. Generic studies triggered by events reported at specific units can lead to improvements in the level of reactor safety only if the available data-base is uniform and of high quality.

Based on a limited sample, AEOD concludes that the Salem Generating Station LERs sampled were of a very high quality as compared to other licensees that  ;

have been evaluated using this methodology. I invite you to review the enclosed analyses and to discuss the evaluation and any planned improvements to your event reporting system at the forthcoming NRC SALP management meeting.

l Sincerely, l EQ&issedbys,

! William F. Kane, Director l Division of Reactor Projects l

Enclosure:

As stated i

l l OFFICIAL RECORD COPY 3 SUMMERS 11/7/86 - 0001.0.0 11/12/86

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V T Public Service Electric 2 and Gas Company 19 NOV 1986 cc w/ encl:

J. M. Zupko, Jr., General Manager - Salem Operations B. A. Preston, Manager, Licensing and Regulation C. P. Johnson, Manager - Quality Assurance Nuclear Operations

!. . General Manager - Nuclear Safety Review M. J. Wetterhahn, Esquire R. Fryling, Jr., Esquire Public Document Room (POR)

, Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief Robert J. Bores, DRSS 1

RP C R [

Summers /rhl Norrholm e

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0FFICIAL RECORD COPY 3 SUMMERS 11/7/86 - 0002.0.0 l 11/07/86 l

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S AEOD SALP INPUT FOR SALEM 1, 2 OPERATIONS (LER QUALITY) FOR THE ASSESSMENT PERIOD OF 1 OCTOBER 1985 TO 30 SEPTEMBER 1986

SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Salem 1 and 2 during the October 1, 1985 to September 30, 1986 Systematic Assessment of Licensee Performance {SALP) period was performed using a refinement of the basic methodology presented in a report entitled "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT)",

NUREG/CR-4178, March 1985. This is the second time that the Salem LERs have been evaluated using this methodology. The results of this evaluation indicate that the Salem LERs now have an overall average score of 9.3 out of a possible 10 points, compared to their previous overall average score of 8.9 and a current industry average score of 8.0 (i.e., the average of the lastest overall average LER score for each unit / station that has been evaluated to date using this methodology).

The principal weakness identified in the Salem LERs, in terms of safety significance, involve the requirement to adequately identify failed components in the text. The failure to adequately identify each component that fails prompts concern that possil.le generic problems may go unnoticed for too long a time period by otheru in the industry.

Strong points for the Salem LERs is that the discussions concerning the root cause, the safety consequences, the corrective actions, personnel errors, and the failure mode, mechanism, and effect of failed components were well written in most of the LERs involving these requirement.

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o AE0D INPUT TO SALP REVIEW FOR

[ SALEM 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Salem 1 and 2 during the October 1, 1985 to September 30, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178. The sample consists of a total of 10 LERs (i.e., 7 LERs for Salem 1 and 3 for Salem 2), which is over half of the LERs on file at the time the sample was selected. The Salem LERs were evaluated as one sample for this SALP period because it was determined that their LERs are both w/itten and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in the sample.

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

Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the criteria of 10 CFR 50.73(b). In addition, each selected LER is compared to the guidance for preparation of LERs presented in NUREG-1022 (Ref.2) and Supplements 1 (Ref.3) and 2(Ref.4) to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the reports. The purpose of this evaluation is to provide feedback to improve the quality of LERs. It is not intended to increase the requirements concerning the

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

Therefore, statements in this evaluation that specify measures that should be taken are not intended to. increase requirements and should be viewed in that light.. However, the obvious minimum requirements of the regulation must be met.

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

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

The results of the LER quality evaluation are divided into two categories: (1) detailed infornation and (2) summary information. The detailed information, presented in Appendices A through 0, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix B), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER ,

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

Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results cf the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b). Again, Salem LERs were evaluated as one sample, rather than two separate samples (by unit), because it was determined that their LERs are both written and fornelly reviewed at the station, rather than the unit, level.

O Table 1 presents the average scores for the sample of LERs evaluated for the station. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.

Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Salem's average score for the text of the LERs that were evaluated is 9.2 out of a possible 10 points. From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(11)(A)] to text presentation. The percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the station ,

for the 10 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, r equirement percentage scores of less than 75

. indicate that the station probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic requirement but has either: (1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The station should review the LER specific comments presented in Appendix 0 in order to determine why it received less than a perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance. In addition, the primary deficiencies in the abstract and coded fields are discussed.

a TABLE 1.

SUMMARY

OF SCORES FOR SALEM 1, 2 Average High low Text 9.2 10.0 8.4 Abstract 9.5 10.0 8.4 Coded Fields 8.9 10.0 8.3 Overall 9.3 10.0 8.4

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

-O TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR SALEM 1, 2 TEXT Percentage Reauirements f50.73(b)1 - Descriptions Scores ( )'

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

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 97 (10)

(2)(ii)(D) - - Root cause and intermediate cause(s) 95 (10)

(2)(ii)(E) - - Mode, mechanism, and effect 100 ( 3)

(2)(ii)(F) - - EIIS Codes 75 (10)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 100 ( 1)

(2)(11)(I) - - Method of discovery 95 (10)

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

(2)(11)(J)(2) - Personnel error (procedural deficiency) 93 ( 7)

(2)(ii)(K) - - Safety system responses 100 ( 5)

(2)(ii)(L)'- - Manufacturer and model no. information 67 ( 3)

(3) ----- Assessment of safety consequences 92 (10)

(4) ----- Corrective actions 93 (10) 4 (5) ----- Previous similar event information 45 (10)

(2)(1) - - - - Text presentation 92 (10)

ABSTRACT Percentage Requirements f50.73(b)(1)1 - Descriptions Scores ( l'

- Major occurrences (Inmediate cause and effect 100 (10) information)

- Description of plant, system, component, and/or 96 ( 6) personnel responses

- Root cause information 92 (10)

- Correr.tive Action information 94 (10)

- Abstract presentation 91 (10) 6

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,. TABLE 2. (continued)

CODED FIELDS Percentage Item Number (s) - Description Scores ( l' 1, 2, and 3 - Facility name (unit no.), docket no. and 100 (10) page number (s) 4 - - - - - - Title 67 (10) 5, 6, and 7 - Event date, LER No. and report date 100 (10) 8 - - - - - - Other facilities involved 100 (10) 9 and 10 - - Operating mode and power level 100 (10) 11 - - - - - Reporting requirements 100 (10) 12 - - - - - Licensee contact information 100 (10) 13 - - - - - Coded component failure information 90 (10) 14 and 15 - - Supplemental report infornetton 80 (10)

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

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

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

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

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The manufacturer and/or model number (or other unique identification) was not provided in the text of one of the three LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail must be identified in the text so that others in the industry are made aware of potential problems. An event at one station can often lead to the identification of a generic problem that can be corrected at other plants or stations before they experience a similar event. Likewise, although not specifically required by the current regulation, components whose design contributes to an event should also be identified.

Requirement 50.73(b)(5) was not adequately addressed in five of the ten LERs in that their text did not include the necessary infornation concerning previous similar events. All previous similar events should be appropriately referenced (by LER number, if possible) and the history of the on-going problem should be discussed, if necessary. If there have been no previous similar events, the text should state this. Adding a heading to the present outline entitled " Previous Similar Events" would aid in satisfying this requirement.

The Energy Industry Identification System (EIIS) component function and system name codes were inadequate for six of the 10 LERS. Each system or component referred to in the text discussion should have a code assigned to it.

l The primary deficiencies concerning the abstracts involves root cause and corrective action information. Four of the abstracts failed to adequately summarize root cause information that was presented in the text. Similarly, three abstracts failed to provide adequate information enncerning corrective actions.

The main deficiency in the area of coded fields involves the title, Item (4). Nine of the titles failed to indicate root cause and one failed to include the result. While the result is considered to be the most important part of the title, cause and link information must be included to make a title complete. Examples of titles that the analysts considered

! would better describe the event are presented in Appendix D under the

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Coded Fields section for certain LERs. While these titles are typically long, there is space for two type written lines in the title field.

Another area of the coded fields that should be discussed is the Supplemental Report field (Item 14). None of the LERs that were evaluated committed to a supplemental report event though three of the LERs stated that either a cause or corrective action was still under investigation; in two of these LERs the manufacturer had been asked to examine the failed component so as to determine root cause and/or corrective actions to prevent recurrence. Whenever a cause or corrective action has not yet been determined by the time the LER is submitted, a commitment should be made to provide the appropriate information when it is determined.

Table 3 provides a summary of the areas that need improvement for the Salem LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendix D. General guidance concerning these requirements can be found in -

NUREG-1022, Supplement No. 2.

It should be noted that this is the second time that the Salem LERs have been evaluated using this same methodology. The previous evaluation, which was reported in October of 1985, was performed on the unit, rather than station, level; however, after 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, Salem LERs have improved since the previous evaluation and remain well above the current industry overall average of 8.0. (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.)

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR SALEM 1,2 LERs Areas Comments Manufacturer and model number Component identification information should be included in the text whenever a component fails or (although not specifically required by current regulation) is suspected of contributing to the event because of its design.

Previous similar events Previous similar events should be referenced (e.g., by LER number) or if none are '

identified, the text should so state.

EIIS Codes should be included in the text for each component or system referred to in the LER.

Text presentation Adding a heading entitled " Previous Similar Events" to the present outline is suggested.

Abstracts Cause and corrective action information from the text should be summarized in the abstract.

Coded fields

a. Titles Titles should be written such that they better describe the event. In particular, include root cause and result information in each title.

b. Supplemental reports Whenever a cause or corrective action is still under investigation when an LER is submitted, a commitment to provide any new information would be appropriate.

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. TABLE 4. COMPARIS0N OF LER SCORES FROM PREVIOUS EVALUATION Report Date October-85 October-26 Text average 8.8a 9,2 Abstract average 9.0a 9.5 Coded fields average 8.8a 8.9 Overall average 8.9a 9.3

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

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.' 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.

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r APPENDIX A LER SAMPLE SELECTION INFORMATION FOR SALEM 1, 2 i

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. TABLE A-1. LER SAMPLE SELECTION FOR SALEM 1, 2 Sample Number Unit number LER Number Comments 1 1 85-013-00 2 1 86-002-00 3 1 86-004-00 4 1 86-007-00 5 1 86-010-00 SCRAM 6 1 86-012-00 SCRAM 7 1 86-013-00 SCRAM 8 2 85-022-00 SCRAM 9 2 86-001-00 10 2 86-003-00 SCRAM /ESF i

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APPENDIX B EVALUATION SCORES Of INDIVIDUAL LERS FOR SALEM 1, 2 1

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TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERs FOR SALEM 1, 2 ,

LER Sample Number a _j 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 l

Text 8.7 10.0 9.1 9.4 9.5 8.9 8.4 9.7 9.5 8.8 -- -- -- -- -- --

Abstract 9.1 10.0 10.0 8.9 9.9 9.8 8.4 9.9 10.0 8.9 -- -- -- -- -- --

Coded Fields 9.1 10.0 9.2 9.0 8.5 9.0 8.3 9.4 8.5 8.3 -- -- -- -- -- --

)

Overall 8.9 10.0 9.6 9.2 9.5 9.2 8.4 9.8 9.5 8.8 -- -- - -- -- --

a LER Sample Number l7 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text -- -- -- -- -- -- -- -- -- -- -- -- -- -- 9.2 cm Abstract -- -- -- -- -- -- -- -- -- -- -- -- -- -- 9.5 1.,

Coded Fields -- -- -- -- -- -- -- -- -- -- -- -- -- -- 8.9 Overall -- -- -- -- -- -- -- -- -- -- -- -- -- -- 9.3

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

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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR SALEM 1, 2

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

50.73(b)(2)(ii)(Al--Plant operating 0 (10) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 3) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.

50.73(b)(2)(ii)(C)--Failure to include 1 (10) sufficient date and/or time information.

a. Date information was insufficient. 1

b. Time information was insufficient. O

_50.73(b)(2)(ii)(D)--The root cause and/or 1 (10) intermediate failure, system failure, or personnel error was not included or was inadequate.

a. Cause of component failure was not 1 included or was inadequate

b. Cause of system failure was not 0 included or was inadequate

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

50.73(b)(2)(ii)(E)--The failure mode, 0 ( 3) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.

a. Failure mode was not included or was inadequate

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

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

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TABLE C-1. (continued)

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

50.73(b)(2)(ii)(F_l--The Energy Industry 6 (10)

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

_5_0.73(b)(2)(ii)(G?--For a failure of a 0 ( 2) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

50.73(b)(2)'iil(H)--For a failure that 0 ( 1) rendered a ;ra9n of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

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

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

b. Method of discovery fcr each system 0 failure was not included or was inadequate

c. Method of discovery for each 1 personnel error was not included or was inadequate

d. Method of discovery for each 0 procedural error was not included or was inadequate.

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TABLE C-1. (continued)

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

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

50.73(b)(2)(ii)(J)(2)--The discussion of 2 ( 7) each personnel error was not included or was inadequate.

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

b. 50.73(b)(2)(ii)(J)(2)(1)--Discussion 0 as to whether the personnel error was cognitive or procedural was not included or was inadequate.

c. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 1 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate.

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

e. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1 of the type of personnel involved i (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.

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• TABLE C-1. (continued)

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

50.73(b)(2)(ii)(K) -Automatic and/or manual 0 ( 5) safety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 1 ( 3) model number of each failed component was not included or was inadequate.

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

a. OBSERVATION: The availability of 2 other systems or components capable of mitigating the consequences of the event was not discussed. If no other -

systems or components were available, i

the text should state that none existed.

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

50.73(b)(4)--A discussion of any corrective 2 (10) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.

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TABLE C-1. (continued)

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

a. A discussion of actions required to 0 correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not inicluded or was inadequate.

b. A discussion of actions required to 2 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.

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

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

50.73(b)(5)--Information concerning previous 6 (10) similar events was not included or was inadequate.

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TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph 8

Description of Deficiencies and Observations Totals Totals ( )

50.73(b)(2)(1)--Text presentation 2 (10) inadequacies.

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

b. Text contained undefined acronyms 2 and/or plant specific designators.

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

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

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

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

A summary of occurrences (immediate cause 0 (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 inadequate.

a. Summary of plant responses was not 1 included or was inadequate.

b. Summary of system responses was not 0 included or was inadequate.

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

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

A summary of the corrective actions taken or 3 (10) planned as a result of the event was not included or was inadequate.

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TABLE C-2. (continued)

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

Description of Deficiencies and Observations Totals Totals ( )

Abstract presentation inadequacies 2 (10)

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

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

b. The abstract was greater than 2 1400 characters

c. The abstract contains undefined 1 acronyms and/or plant specific designators.

d. The abstract contains other specific 0 deficiencies (i.e., poor summarization, contradictions, etc.)

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

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

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r TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SALEM 1, 2 Number of LERs with a

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

Facility Name s 0 (10)

a. Unit number was not included or '

incorrect. .

b. Name was not included or was incorrect.

c. Additional unit numbers were included but not required.

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

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

Title was left blank or was' inadequate s 9 (10)

a. Root cause was not given in title 9

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

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

a. Date not included or was incorrect.

b. Discovery date given instead of event date.

LER Number was not-included or was incorrect 0 (10)

Report Date 0 (10)

a. Date not included

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

Other Facilities intornetton in field is 0 (10) inconsistent with text and/or abstract.

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

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h-TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph

't a

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

a. The reason for checking the "0THER" requirement 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 apprnpriate 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 1 (10)

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

b. Cause, system, and/or component code 0 is inconsistent with text.

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

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

C-10

. TA8LE C-3. (continued)

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

Description of Deficiencies and Observations Totals' Tptals ( )

Supplemental Report , 3 (10)

a. Neither "Yes"/"No" block of the 0 supplemental report field was checked.

b. The block checked was inconsistent 3 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 requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.

b. The " paragraph total" ',5 the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

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C-11

I APPENDIX D LER COMMENT SHEETS FOR SALEM 1. 2

)

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

1. LER Number: 85-013-00 Scores: Text = 8.7 Abstract = 9.1 Coded Fields = 9.1 Overall = 8.9 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifiers for each component referred to in the text were not included.

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

OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed. If no other systems or components are available, the text should so state.

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

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

The cause should be more specific than personnel error (i.e., inattention by the operator not reading the equipment tags carefully).

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The i color coding of tags should be mentioned.

l Coded Fields 1. Item (4)--Title: Root cause (personnel error) is not l included. A more appropriate title might be i " Inadvertent Loss of Two Emergency Core Cooling Subsystems Due To Inattention By An Equipment Operator".

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_~ _ . . _ . __ . _

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

2. LER Namber: 86-002-00 Scores: Text - 10.0 Abstract - 10.0 Coded Fields - 10.0 Overall - 10.0 Text 1. The contents of this LER meet all of the applicable requirements of 50.73(b).

Abstract 1. No comments.

Coded Fields 1. No comments.

0-2

w TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comn ents

3. LER Number: 86-004-00 Scores: Text = 9.4 Abstract = 10.0 Coded Fields = 9.2 Overall = 9.6 Text 1. 50.73(b)(2)(ii)(A)--What was the power level on February 9, 19867 Had the oil leak been repaired and the power raised back up by then?

2. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the missed surveillance is inadequate.

What prompted the " subsequent investigation" that revealed the problem?

3. 50.73(b)(4)--A supplemental report describing the

" mechanisms" selected to prevent future scheduling problems would be appropriate. Others could possible implement such mechanisms at their facility.

4. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comments.

Coded Fields 2. Item (4)--Title: Root cause is not included. A better title might be, " Poor Communications and Lack of a Scheduling Mechanisms Results in Plant Vent Sample Not Being Obtained - Violation of Entironmental Technical Specification".

Acronyms should be avoided in titles unless space is a consideration. Two lines can be typed into the space in Item (4).

2. Item (14)--See text comment number 3.

D-3

_ _ _ _ ~

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

4. LER Number: 86-007-00 Scores: Text - 9.4 Abstract - 8.9 Coded Fields = 9.0 Overall - 9.2 Text 1. 50.73(b)(2)(11)(C)--Date information for major occurrences is inadequate. The discovery date for each item is given but an estimate of tne dates from which the various EQ problems existed were not included.

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifiers for each component referred to in the text were not included.

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

In the case of the CCW outlet valves from the RHR -

heat exchanger, two questions arise:

1. Is radiation the only way the brake could fail and block valve operation?

2. If the answer to question 1 is no, what would the effect be of the valves failing before they l performed their function?

4. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

5. Acronym (s) and/or plant specific designator (s) are undefined. Be sure to define the acronym on the first usage and to put the acronyms close enough to the definitions so that the acronym and definition are associated with each other.

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

The deficiency in DCPs should be mentioned.

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

l D-4

. TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272) t Section Comments

4. LER Number: 86-007-00 (continued) i 3. Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. PSE&G should be ,

defined or left out.

4. This is a complicated event to summarize in only 1400 characters. This limit was exceeded slightly, so in order to comply with abstract comments 1 through 3 references to specifics such as requirement numbers

(e.g., 10 CFR 50.49) and the sentence which discusses notification of the resident inspector and the NRC could be left out. Summary of the safety

, consequences is not needed in an abstract either and could also be left out.

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

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D-5 l

a TABLE D-1.

SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

5. LER Number: 86-010-00 Scores: Text - 9.5 Abstract - 9.9 Coded Fields - 8.5 Overall - 9.5 Text 1. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included. The text states the limit switch was defective. The text also states the manual restraining device utilized to maintain the

" closed" limit on 1BF65 failed. In the case of the limit switch, the manufacturer and model number should be provided. In the case of the manual restraining device, a description of it would meet this requirement.

Abstract 1. No comments.

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

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

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s TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

6. LER Number: 86-012-00 Scores: Text = 8.9 Abstract = 9.8 Coded Fields - 9.0 Overall = 9.2 Text 1. 50.73(b)(2)(ii)(D)--A supplemental report appears to be needed to describe the root cause of the failure when determined by the manufacturer. Without a commitment to submit a supplemental report, this LER must be considered incomplete.

2. 50.73(b)(2)(ii)(F1--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. The code for transforner should have been included in the text.

3. 50.73(b)(2)(11)(K)--Aay safety systems that actuated (or were manually initiated) as a result of the transient caused by the reactor trip should be listed in the text.

4. 50.73(b)(3)--The purpose of the APT and why its loss was not a major concern should have been provided in the text.

5. 50.73(b)(4)--Any corrective actions taken to prevent recurrence that results from the manufacturers investigation should be provided in a supplemental report.

6. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comments.

Coded Fields 1. Item (4)--Title: Root cause is not included. A better title might be " Auxiliary Power Transformer l

Failure (Root Cause Under Investigation) Results in

! Main Turbine Trip and Reactor Trip From Full Power".

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. o e

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

7. LER Number: 86-013-00 Scores: Text - 8.4 Abstract - 8.4 Coded Fields - 8.3 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(D)--A supplemental report appears to be needed to describe the root cause of the breaker failure. Without a commitment to submit a supplemental report, this LER must be considered incomplete.

2. 50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifiers for each component referred to in the text were not included.

3. 50.73(b)(2)(11)(J)(2)(ti)--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.

4. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of i personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

5. 50.73(b)(4)--A supplemental report appears to be needed to describe the any corrective actions found necessary to prevent recurrence. Without a commitment to submit a supplemental report, this LER must be considered incomplete.

6. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

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l Abstract 1. 50.73(b)(1)--Summary of plant response is inadequate. The failure of the auxiliary feedwater pump to automatically start should be mentioned.

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

The personnel error should be mentioned.

I D-8 l

s 1 TABLE 0-1. SPECIFIC LER COMMENTS FOR SALEM 1 (272)

Section Comments

7. LER N'mber:u (continued)

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

2. Item (14)--The block checked is inconsistent with information in the text (see text connents 1 and 5).

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0-9

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 2 (311)

Section Comments

8. LER Number: 85-022-00 Scores: Text - 9.7 Abstract = 9.9 Coded Fields - 9.4 Overall - 9.8 Text 1. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comments.

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

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J D-10

's .* .

TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 2 (311)

Section Comments

9. LER Number: 86-001-00 Scores: Text - 9.5 Abstract - 10.0 Coded Fields - 8.5 Overall - 9.5 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. The components mentioned in the text do not have the EIIS code identifier given.

2. 50.73(b)(4)--Shouldn't the operators have been aware of the Technical Specification requirement that the Waste Gas Holdup System be continuously monitored?

Is additional training in this area needed?

Abstract 1. No comment Coded Fields 1. Item (4)--Title: Root cause and result are not included. A better title might be " Procedural Inadequacy Results in Waste Gas Holdup System Not Being Continuously Sampled For Oxygen As Required By Technical Specifications".

D-11 1

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TABLE D-1. SPECIFIC LER COMMENTS FOR SALEM 2 (311)

Section Comments

10. LER Number: 86-003-00 Scores: Text - 8.8 Abstract = 8.9 Coded fields - 8.3 Overall - 8.8 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifiers for each component referred to in the text were not included.

2. 50.73(b)(4)--A supplemental report appears to be needed to describe the corrective actions taken as a result of the investigation into using damped steam flow detectors. Without a commitnent to submit a supplemental report, this LER must be considered incomplete.

3. 50.73(b)(5)--Information concerning previous similar events is inadequate. The text should specifically state whether or not any previous similar events have occurred.

, Abstract 1. The root cause summary implies that opening a breaker caused the safety injection and then the corrective

! actions summary talks about correcting the sensitivity of the steam flow instrumentation. For a person reading the abstract it is not clear how the corrective actions are going to solve the causes

which were discussed.

2. The abstract contains greater than 1400 spaces.

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

2. Item (14)--The block checked is inconsistent with information in the text (see text consent 2).

i D-12