ML20215K003

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SALP Rept for Mar 1987
ML20215K003
Person / Time
Site: River Bend Entergy icon.png
Issue date: 03/31/1987
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215J990 List:
References
NUDOCS 8705110024
Download: ML20215K003 (55)
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Text

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.Lr LICENSEE EVENT REPORT (LER)

QUALITY EVALUATION FOR RIVER BEND -

DURING THE PERIOD FROM FEBRUARY 1, 1986 TO MARCH 31, 1987 870511002487%g k>?RADOCK 050 PDR 458

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by River Send during the period from February 1, 1986 to March 31, 1987 was performed using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2. The results of this evaluation indicate that River 8end LERs have an overall average LER score of 8.1 out of a possible 10 points, compared to a current industry average score of 8.3 for those unit / stations that have been

, evaluated to date using this methodology.

The principle weakness identified in the River Bend LERs involves the

requirement to adequately identify failed components in the text (Requirement 50.73(b)(2)(11)(L)]. The failure to adequately identify each component that fails prompts concern that possible generic problems may not be identified in a timely manner by others in the industry.

A strong point for the River Bend LERs is the discussion of the fat 1Lre mode, mechanism, and ef fect of failed component [ Requirement i

50.73(b)(2)(11)(E)].

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5-LER OUALITY EVALUATION FOR RIVER 8END INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by River Bend during the period from February 1, 1986 to March 31, 1987, a representative sample of the unit's LERs was evaluated using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2.1 The sample consists of a

total of 15 LERs, which is considered to be the maximum number of LERs 3

necessary to have a representative sample. See Appendix A for a list of the LER numbers in the sample.

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

METHODOLOGY The evaluation consists of a detailed review of each selected LER to j 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 2

. 3 i and Supplements No. 1 and 2 to NUREG-1022; based on this comparison,

suggestions were developed for improving the quality of the reports. The purpose of this evaluation is to provide feedback to improve the quality of LERs. It is not intended to increase the requirements concerning the

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

Therefore, statements in this evaluation that suggest measures be taken are

!. not intended to increase requirements and should be viewed in that light.

However, the minimum requirements of the regulation must be met.

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l ,- t 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 j that was evaluated. Likewise, the scores serve two purposes: (1) they

{ serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis l

i 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).

j The results of the LER quality evaluation are divided into two j categories: (1) detailed information and (2) summary information. The j detailed information, presented in Appendices A through D, consists of LER l sample information (Appendix A), a table of the scores for each sample LER I

(Appendix B), tables of the number of deficiencies and observations for the j text, abstract and coded fields (Appendix C), and connent sheets containing  ;

i narrative statements concerning the contents of each LER (Appendix D). I When referring to Appendix 0, the reader is cautioned not to try to l directly correlate the number of comments on a comment sheet with the LER

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scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores (e.g., the analysts sometimes make comments relative to a requirement without deducting points for that requirement).

i RESULTS i 1 l

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

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represent the analysts' assessment of the unit's performance (on a scale of 0 to 10) in submitting LERs that meet the criteria of 10 CFR 50.73(b) and the guidance presented in NUREG-1022 and its supplements. -

Table 1 presents the average scores for the sample of LERs evaluated j for River Bend. In order to place the scores provided in Table 1 in i.

perspective, the distribution of the latest overall average score for all j unit / stations that have been evaluated using the current methodology is  !

provided on Figure 1. Figure 1 1s updated each month to reflect any '

changes in this distribution resulting from the inclusion of data for those

units / stations that have not been previously evaluated or those that have

{ been reevaluated. (Note: Previous scores for those units / stations that are reevaluated are replaced with the score from the latest evaluation). l Table 2 and Appendix Table 8-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, River Bend's  !

average score for the text of the LERs that were evaluated is 7.9 out of a

! possible 10 points. Fran Table 2 it can be seen that the text score l actually results from the review and evaluation of 17 different

! requirements ranging from the discussion of plant operating conditions l 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 l Indication of how well each text requirement was addressed by the unit for

{ the 15 LERs that were evaluated.

] Discussion of Soecific Deficiencies and Observations A review of the percentage scores presented in Table 2 will quickly

! point out where the unit is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the unit probably needs additional guidance concerning these j requirements. Scores of 75 or above, but less than 100, indicate that the unit probably understands the hasic requ1rement but has j either: (1) excluded certain less significant information from many of the i discussions concerning that requirement or (2) totally failed to address 4 the requirement in one or two of the selected LERs. The unit should review f the LER specific comments presented in Appendix D in order to determine why I

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O l TABLE 1.

SUMMARY

OF SCORES FOR RIVER BEND l _--________-______ ___________________________________________________

l Average High Low l Text 7.9 9.5 6.4 L

l Abstract 8.3 9.7 6.4 i

Coded Fields 8.8 9.7 7.5 Overall 8.1 9.2 7.1

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

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

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River Bend y 8- -

3 7- -

$ 6- -

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E 3- -

z 2- E o

9.6 k

b 4....

9.1 8.6

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i 8.1 7.6 6....h....

i 7.1 6.6 6.1 .

Overall average scores e -

O TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR RIVER BEND TEXT Percentage a

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

(2)(ii)(A) - - Plant condition prior to event 87 (15)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate time (s) 78 (15)

(2)(ii)(D) - - Root cause and intermediate cause(s) 85 (15)

> (2)(ii)(E) - - Mode, mechanism, and effect 100 ( 9) i (2)(ii)(F) - - EIIS codes 3 (15)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 30 ( 5)

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

(2)(ii)(J)(1) - Operator actions affecting course 100 ( 3) l (2)(ii)(J)(2) - Personnel error (procedural deficiency) 86 ( 7)

(2)(ii)(K) - - Safety system responses 91 (11)

! (2)(ii)(L) - - Manufacturer and model no, information 31 ( 9) i (3) - - - - - - Assessment of safety consequences 85 (15)

(4) - - - - - - Corrective actions 79 (15)

, (5) - - - - - - Previous similar event information 17 (15) i (2)(1) - - - - Text presentation 82 (15) i l ABSTRACT Percentage a

, Requirements (50.73(b)(1)] - Descriptions Scores ( )

! - Major occurrences (immediate cause/effect) 100 (15)

- Plant / system / component / personnel responses 98 (11)

- Root cause information 79 (15) j - Corrective action information 64 (15) j - Abstract presentation 78 (15)

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I TABLE 2. (continued)

CODED FIELDS Percentage a

Item Number (s) - Descriptions Scores ( )

1, 2, and 3 - Plant name(unit d), docket #, page #s 100 (15) 4------ Title 60 (15) 5, 6, and 7 - Event date, LER no., report date 98 (15) 8------ Other facilities involved 100 (15) 9 and 10 --

Operating mode and power level 98 (15) 11 -----

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

Licensee contact information 99 (15) 13 -----

Coded component failure information 95 (15) 14 and 15 - - Supplemental report information 93 (15)

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

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

b. A porcentage 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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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 as are the primary deficiencies in the abstracts and coded fields sections.

Text Deficiencies and Observations The manufacturer and/or model number (or other unique identification) was1not provided in the text of eight of the nine LERs that involved a component failure, Requirement 50.73(b)(2)(11)(L). Components that fall must be identified in the text so that others in the industry can be 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 units or stations before they experience a similar event. In addition, although not specifically required by the current regulation, it would be helpful to identify components whose design contributes to an event even though the J

component does not actually fall.

Four of the five LERs involving a safety system / train failure, Requirement 5073(b)(2)(11)(H), did not provide adequate information (e.g.,

dates and times) to allow the reader to estimate the elapsed time from date of the failure until the system was returned to an operable status.

Whenever a safety system / train is discovered inoperable, an estimate of the time (date) that the system / train actually became inoperable would be

! appropriate (e.g. the date when the system / train was last verified to be operable would satisfy this concern). Likewise, the date/ time that the l

Inoperable system / train is returned to an operable status should be provided.

Information concerning previous similar events was not provided in thirteen of the fifteen LERs. If the unit has experienced any previous similar events, the LER number for these events should be provided in the text of the LER (if these events were reported). If the event being reported is unique, it is suggested that this information be provided. See NUREG-1022 Supplement No. 2, page 0-4.

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. None of the fifteen LERs contained the required Energy Industry Identification System (EIIS) component function identifier or system name codes. A code is required, Requirement 50.73(b)(2)(11)(F), for each component or system referred to in an LER.

Abstract Deficienctis and Observations The primary concern regarding the abstracts involve a general lack of

, cause and corrective action information. While there are no specific l

requirements for an abstract, other than those given in 10 CFR 50.73(b)(1),

an abstract should, as a minimum, summarize the following information from the text: ,

1. Cause/Effect What happened that made this event reportable.
2. Responses Major plant, system, and personnel responses as a result of the event, p
3. Root / Intermediate The underlying cause of the event. What 4

. Causes caused the component and/or system failure or the personnel errors.

4. Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence.

Items 3 and 4 were considered to be lacking because many of the

. abstracts failed to mention cause and corrective action information that was provided in the text.

The abstract presentation score would have been higher had the abstracts been somewhat longer. Six of the abstracts were considered to be short compared to the 1400 spaces allowed for the abstract field. In addition, five abstracts contained information that was not included in the text. . This concern is in reality a text concern because the additional l information provided in the abstract generally added.to the readers i

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perception of the event. If, when reviewing a final report, it is noted that the abstract includes relevant information that is not presented in

~ the text,-the text should be revised to include this information.

, Coded Field Deficiencies and Observations The main deficiency in the area of coded fields involves the title,  ;

Item (4). Thirteen of the titles failed to include adequate cause '

information, three failed to adequately indicate the result (i.e., why the event was required to be reported), and seven failed to include the link between the cause and the result. While the result is considered the most important part of the title, the lack of cause information (and link, if necessary) results in an incomplete title. Example titles are provided in l Appendix D (Coded Fields Section), for some of the titles that are l

considered to be deficient.

Information concerning other deficiencies involving the Coded Fields can be found by reviewing the information in Table C-3 in Appendix C and the Coded Fields Section of the Appendix D comments.

Table 3 provides a summary of the areas that need improvement for the River Bend 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, and NUREG-1022 Supplements No. 1 and 2.

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT f0R THE RIVER BEND 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.

Safety train unavailability Sufficient dates and times should be included in the text to enable the reader to determine,the length of time that safety system trains or components were inoperable.

Previous similar events Previous similar events should be referenced (e.g., by LER number) or if none 4

are identified, the text should so state.

EIIS codes EIIS codes should be provided in the text for all systems and/or components discussed in the text.

Abstracts Abstracts should summarize the cause and corrective action information that is discussed in the text. If it is necessary to include additional information in the abstract, the text should be revised so as to discuss this new information. The space available (1400 spaces) should be better utilized.

t Coded fields

a. Titles Titles should be written such that they better describe the event. In particular, include cause information, result of the  ;

event, and the link between them in all titles.

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REFERENCES

1. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory i Commission, September 1985.
2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.
3. Office for Analysis and Evaluation of Operational Data Licensee Event Report System, NUREG-1022 Supplement No. 1 U.S. Nuclear Regulatory Commission February 1984.

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B APPENDIX A LER SAMPLE SELECTION

' INFORMATION FOR RIVER BEND I

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TABLE ~A-1. LER SAMPLE SELECTION FOR RIVER 8END Sample Number Unit Number LER Number Comments 1 1 86-019-00 SCRAM 2 1 86-023-00 3 1 86-024-02 ESF 4 1 86-028-00 5 1 86-035-00 SCRAM 6 1 86-040-01 ESF 7 1 86-045-00 SCRAM 8 1 86-046-00 9 1 86-050-00 ESF 10 1 86-055-00 SCRAM 11 1 86-058-00 ESF 12 1 86-059-01 4 13 1 86-066-00 14 1 86-068-00 ESF  ;

15 1 86-069-00 SCRAM l

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6 APPENDIX 8 EVALUATION SCORES OF INDIVIDUAL LERS FOR RIVER BEND

a - a TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR RIVER BEND a

LER Sample Number 1 2 3 4 5 6 7 8

-Text 6.4 9.5 7.8 7.7 8.7 8.5 7.8 8.0 Abstract 8.6 7.6 8.3 8.9 9.1 9.3 7.0 6.4 Coded Fields 9.3 8.5 9.0 9.1- 9.4 8.0 9.1 9.2 Overall 7.3 8.8 8.1 8.2 8.9 8.7 7.7 7.6 a

LER Sample Number 9 10 11 12 13 14 15 Average Text 7.1 6.6 8.6 8.9 6.4 8.9 8.1 7.9 Abstract 8.0 9.1 7.6 8.9 7.7 9.7 8.2 8.3 Coded Fields 8.8 8.3 8.4 7.5 9.1 9.7 9.0 8.8 Overall 7.5 7.5 8.3 8.7 7.1 9.2 8.2 8.1

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

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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR RIVER BEND l

,. o TA8tE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR RIVER BEND Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph-Description of Deficiencies and Observations Totals # Totals'( )

50.73(b)(2)(11)(Al--Plant operating 4 (15) conditions before the event were not

, included or were inadequate.

50.73(b)(2)(ii)(81--Discussion of the status 0 ( 1) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.

50.73(b)(2)(11)(c)--Fa11ure to include 6 (15) suf ficient date and/or time information.

a. Date information was insufficient. 5
b. Time information was insufficient. 6 50.73(b)(2)(11)(0)--The root and/or 6 (15) intermediate cause of the component or system failure was not included or was inadequate,
a. Cause of component failure was not 6 included or was inadequate,
b. Cause of system failure was not 0 included or was inadequate.

50.73(b)(2)(11)(E)--The failure mode, 0 ( 9) 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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TA8LE.C-1. (continuGd)-

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

50.73(b)(2)(ti)(F)--The Energy Industry 15 (15)

Identification System component function identifier for each component or system was-

not included.

50.73(b)(2)(11)(G)--For a failure of a -- ( 0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

50.73(b)(2)(11)(H)--for a failure that 4 (5) rendered a train of a safety system inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.

50.73(b)(2)(11)(I)--The method of discovery 0 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

a. Method of discovery for each component failure was not included or was inadequate,
b. Method of discovery for each system failure was not included or was inadequate.
c. Method of discovery for each personnel error was not included or was inadequate.
d. Method of discovery for each I

procedural error was not included or was inadequate.

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TA8LE C-1. (continued)

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

50.73(b)(2)(ii)(J)(11--Operator actions that 0 ( 3) affected the course of the event including operator errors and/or procedural 4

deficiencies were not included or were inadequate.

50.73(b)(2)(11)(J)(2)--The discussion of 3 ( 7) each personnel error was not included or was inadequate.

a. OBSERVATION: A personnel and/or 2 procedural error was implied by the text, but was not explicitly stated.

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b. 50.73(b)(2)(ii)(J)(2)(11--Discussion 1 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 0 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate,
d. 50.73(b)(2)(11)(J)(2)(111)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate,
e. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 0 of the type of personnel involved (i.e., contractor personnel, utility
licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.

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TABLE C-1. (continuGd)

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

50.73(b)(2)(11)(K)--Automatic and/or manual 3 (11) safety system responses were not included or were inadequate.

50.73(b)(2)(11)(L)--The manufacturer and/or 8 ( 9) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 3 (15)

! consequences and implications of the event i was not included or was inadequate,

a. OBSERVATION: The availability of 1 other systems or components capable of mitigating the consequences of the event was not discussed. If no other systems or components were available, the text should state that none existed.
b. OBSERVATION: The consequences 0 of the event had it occurred under j more severe conditions were not I discussed. If the event occurred '

under what were considered the most severe conditions, the text should so i state.

1 50.73(b)(41--A discussion of any corrective 8 (15) actions planned as a result of the event including those to reduce the probab111ty 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 2 correct the problem (e.g., return the i component or system to an operational

( condition or correct the personnel j error) was not included or was inadequate.

I b. A discussion of actions required to 6 reduce the probability of recurrence of the problem or similar event l (correct the root cause) was not included or was inadequate.

c. OBSERVATION: A discussion of actions 0 l

required to prevent similar failures in sin 11ar and/or other systems (e.g.,

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

50.73(b)(5)--Information concerning previous 13 (15) similar events was not included or was i inadequate.

l C-5

TA8LE C-1. (continued)

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

, 50.73(b)(2)(1)--Text presentation 3 (15)

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

b. Text contained undefined acronyms 1 and/or plant specific designators.
c. The text contains other specific 2 4 deficiencies relating to the 2

readability.

a. The "sub-paragraph total" is a tabulation of specific deficiencies or-i observations within certain requirements. Since an LER can have more than i

one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do l not necessarily add up to the paragraph total.

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

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

A summary of occurrences (immediate cause 0 (15) and effect) was not included or was inadequate.

A summary of plant, system, and/or personnel 0 (11) responses was not included or was inadequate,

a. Summary of plant responses was not included or was inadequate.
b. Summary of system responses was not included or was inadequate,
c. Summary of personnel responses was not i

included or was inadequate.

A summary of the root cause of the event 9 (15) was not included or was inadequate.

A summary of the corrective actions taken or 11 (15) planned as a result of the event was not included or was inadequate.

C-7

. TABLE C-2. (continued)

Number of LERs with Deficiencies and Observations i

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

Abstract presentation inadequacies. 11 (15)

a. 08SERVATION: The abstract contains 5 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 1 1400 spaces.
c. The abstract contains undefined 0 acronyms and/or plant specific designators.
d. The abstract contains other specific 7 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 j for which a certain requirement was considered ~ applicable.

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TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR RIVER BEND Number of~LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

  • Totals ( )

Facility Name 0 (15)

a. Unit number was not included or incorrect,
b. Name was not included or was incorrect.
c. Additional unit numbers were included but not required.

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

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

Title was left blank or was inadequate. 15 (15)

a. Root cause was not given or was 13 inadequate.
b. Result (effect) was not given or was 3 inadequate.
c. Link was not given or was 7 inadequate.

Event Date 0 (15)

a. Date not included or was incorrect,
b. Discovery date given instead of event date.

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

Report Date 2 (15) 1

a. Date not included. O
b. OBSERVATION: Report date was not 2 within thirty days of event date (or discovery date if appropriate).

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

Operating Mode was not included or was 1 (15) inconsistent with text or abstract. ,

C-9

- TABLE C-3. (centinusd)

Number of LERs with Deficiencies and

-Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

  • Totals ( )

Power level was not included or was 0 (15) inconsistent with text or abstract.

Reporting Requirements 0 (15)

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 appropriate to report this. event under an l additional unchecked paragraph. -

Licensee Contact 1 (15)

a. Field left blank. O
b. Position title was not included. 1 i
c. Name was not included. O
d. Phone number was not included. O Coded Component failure Information 3 (15)
a. One or more component failure 1 sub-fields were left blank.
b. Cause, system, and/or component code 2 is inconsistent with text.
c. Component failure field contains data 0 when no component failure occurred.
d. Component failure occurred but entire O field left blank.

1 C-10

TABLE C-3. (continued)

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

  • Totals ( )

Supplemental Report 1 (15)

a. Neither "Yes"/"No" block of the O supplemental report field was checked.
b. The block checked was inconsistent 1 with the text.

Expected submission date information is 0 (15) 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 t'otal.
b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

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APPENDIX D LER COMMENT SHEETS FOR  :

RIVER BEND 1

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section- Comments

1. LER Number: 86-019-00 Scores: Text - 6.4 Abstract - 8.6 ' Coded Fields - 9.3 Overall - 7.3 Text 1. 50.73(b)(2)(ii)(C)--Date/ time information for the corrective actions is not included.
2. 50.73(b)(2)(11)(D)--The root and/or intermediate

, cause discussion concerning the compentni failure is

! inadequate. An explanation was not included as to j-why the level controllers were not tuned and had incorrect setpoints. The reason the normal drain valve was not open after an automatic isolation of

the drain line was not given. The reason for the i controller reset arm being disconnected on valve 1DSM-LV78A was not discussed. Finally, how clogged instrument lines were put in. service without being discovered or properly flushed was'not discussed.

I

3. 50.73(b)(2)(ii)(F1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

50.73(b)(2)(ii)(J)(2)--The cause of problems listed 4.

in Text Comment No. 2 above all appear to be personnel error but the requirements of 50.73(b)(2)(11)(J)(2) are not addressed in the text discussion.

5. SC.73(b)(2)(ii)(L)--Identification (e.g.,

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

6. 50.73(b)(4)--Without an adequate root cause discussion (see text comment 2), it is not apparent if the corrective action discussion adequately addresses recurrence prevention.
7. 50.73(b)(51--Information concerning previous similar events is not included. If no previous similar
events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.

Instead of stating that " corrective actions have been taken", the abstract should provide a brief summary i

of the actions taken.

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TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

1. LER Number: 86-019-00 (Continued)
2. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--The root cause is too vague. A more appropriate title might be "High Water Level in Moisture Separator Due to Multiple Component Faults Results in Turbine and Reactor Trip".

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D-2

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TA8LE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

2. LER Number: 86-023-00 Scores: Text - 9.5 Abstract - 7.6 Coded Fields - 8.5 Overall - 8.8 Text 1. 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component and/or j system referred to in the text is not included. The emergency diesel generator system code is not included.
2. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous stallar events are known, the text should so state.

Abstract 1. 50.73(b)(11--Summary of the root cause (improper implementation of administration procedure) is not included.

1

! 2. 50.73(b)(11--Summary of corrective actions taken or i

i planned as a result of the event is inadequate. A more complete summary of the procedure changes, the

inspection of other plant equipment with similar potential problems, the scribing of valve handles, and the maintenance worker training should be included.
3. Additional space is available within the abstract field to provide the necessary information but it was
not utilized. The abstract could be single spaced to allow the use of up to 1400 spaces, i l

Coded Fields 1. Item (4)--Title: The root cause (improper procedure

! usage) and the link (during testing) are not  ;

i included, and the result (Technical Specification '

l violation) is inadequate. A more suitable title might be: "

During Testing, A Diesel Generator Fuel  ;

011 Valve Misalignment Caused by Improper Procedure 1 4

Implementation Was Discovered Which Resulted in an I

, Inoperable Diesel Generator - Technical Specification Violation".

(

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l l D-3 i

i

,-----w.-.e-me-- -m--em-.--w w-.--ggs,<-- wm ey- ggm .mg- 9 ,w9.-ep ,y y7-w-.y,-- g -- ,---.--.--4 --,,-y y- m., ._.-, - .,m s.. -,em-ym-.-,.-s-e,g -- -y-,w--, -v,---9

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Commerts

3. LER Number: 86-024-02 Scores: Text - 7.8 Abstract - 8.3 - Coded Fields - 9.0 Overall - 8.1 General The information concerning the December 24th EPA breaker Comment trip should not have been provided in a supplemental report to another event even though the events were sin 11ar. The December 24th breaker trip should have been reported as a new (i.e., separate) LER. See NUREG-1022, i Supplement No. 1, page 24, question nos. 14.13 and 14.14.

Text 1. 50.73(b)(2)(11)(0)--As an aid to better understanding the details of the logic card problem, more

, information concerning the phrases " depending upon the at-rest state of certain circuit components" and

" dependent upon the specific chip parameters" would be helpful (e.g., what certain components and what parameters?).

What is the suspected cause of the December 24th trip?

I

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or

{ system referred to in the text is not included.

3. 50.73(b)(2)(11)(K)--Did a different EPA breaker trip on December 24th?

i 4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The corrective actions

, relative to the reworking of the logic card should provide the reader with details as opposed to saying 2

reworked "per design". '

t In addition, simply stating that the purpose of Nodification Request 87-0008 is to make logic card circuit improvements is inadequate. What specific improvements are planned? Were they suggested by the vendor?

i 5. Unrelated events are reported in the LER.

4

- Abstract 1. 50.73(b)(1)--Summary of cause information is ,

] inadequate. The logic card should have been  ;

j mentioned. The suspected cause of the December 24th l

trip should have been mentioned. I l

D-4 4

1 l l

.TA8LE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

3. LER Number: 86-024-02 (Continued)
2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. Both Modification Requests should have been mentioned.
3. Abstract contradicts the text. Abstracts states "the breaker" was reworked while the text states "the logic card" was reworked.

Coded Fields 1. Item (4)--Title: Cause of the breaker trip (logic card problems) is not included.

2. Item (5)--Event date is not correct for the December 24th event. See the general comment. ,
3. Item (9) and (10)--Mode and power level are not correct for the December 24th event. See the general  !

comment, r

t-i D-5 1

1 TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

4. LER Number: 86-028-00 Scores: Text = 7.7 Abstract - 8.9 Coded Fields = 9.1 Overall - 8.2 '

Text 1. 50.73(b)(2)(ii)(Al--Technically the operating conditions prior to the event are required to be ,

given in the text, although the operating conditions )

before this event are not very meaningful to the event. It could be helpful to some readers, however, to indicate the most severe operating conditions that existed while the transformer taps were incorrect. .

Since operating mode numbers are not standardized, a brief description of each number (as in the first sentence of the abstract) would be helpful.

l

2. 50.73(b)(2)(11)(F)--The Energy Industry j Identification System code for each component and/or  ;

system referred to in the text is not included.

3. 50.73(b)(2)(ii)(J)(2)--An explanation was not included as to why the EPRI program was not implemented in time. Is there a possible procedural deficiency in following design changes?
4. 50.73(b)(31--What are the implications of not having the correct tap setting? Would safety system operation be affected? l S. 50.73(b)(4)--Is any action needed to insure that future actions are implemented as required (see text comment 3)?
6. 50.73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.
7. Acronym (s) and/or plant specific designator (s) are undefined. GSU should be defined.

Abstract 1. 50.73(b)(1)--Summary of root cause is inadequate. I The fact that the calculations were completed in time, but missed being implemented is not stated in-the abstract.

I D-6 I

\_ _ _ . _ _ . . _ - _ _- , ., ,

=

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458) 1 Section Comments

4. LER Number: 86-028-00 (Continued)
2. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text most include all information summarized in the abstract. This abstract gives the operating conditions before the event but this information is not given in text (see ,

text comment 1). '

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

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/

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458) l Section Comments

5. LER Number: 86-035-00 l Scores: Text = 8.7 Abstract = 9.1 Coded Fields = 9.4 Overall - 8.9 Text 1. .50.73(b)(2)(11)(F)--The Energy Industry  !

Identification System code for each component and/or l system referred to in the text is.not included.

2. 50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate. If any safety systems actuated as a result of the scram, they should be listed in the text.
3. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

I Abstract 1. 50.73(b)(1)--Summary of the root cause is I inadequate. The effect on transmitter A of transmitter 8 being valved out of service is not provided.

2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The term, " maintenance activity", should be more specific to reflect the electronic dampening of all the APRM flow transmitters.
3. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

Coded Fields 1. Item (4)--Title: Link (during maintenance work on the flow transmitter) is not included. A better  ;

title might be: " Maintenance Work on "B" Loop Flow l Transmitter Leads to Excessive Noise on the "A" Loop i Resulting in Reactor Scram."

2. Item (12)--Position Title is not included.

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TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments i

6. LER Number: 86-040-01 Scores: Text - 8.5 Abstract - 9.3 Coded Fields - 8.0 Overall - 8.7 Text 1. 50.73(b)(2)(11)(C)--Time that the filtration system automatically initiated and time that it was returned to normal operation was not provided..
2. 50.73(b)(2)(11)(0)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
3. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4. 50.73(b)(2)(11)(L)--Given that the design of the '

radiation monitor, appears to have contributed to this event, the manufacturer and model number of the monitor would be useful information.

5. 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. Given that changing a light bulb on the monitor had been previously shown to cause spurious signals, were other corrective actions tried before this event? What were the specific instructions provided by the operator aid?

OBSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

I 1

6. 50.73(b)(5)--Information concerning previous similar  :

! events is inadequate. l l

7. The use of revision bars in the right hand margin to l denote changes from a previous report are suggested.

l Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The operator aid was not mentioned in the abstract.

l i

, D-9

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

6. LER Number: 86-040-01 (Continued)

Ccded Fields 1. Item (4)--Title: Cause and link information is not included. A better title would be " Changing A Light Bulb on Radiation Monitor RMS-RE138 Results In A Spurious Control Room Charcoal Filtration System Actuation".

2. Item (9)--Mode number is not included.

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D-10

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND'(458) l Section . Comments i

7. LER Number: 86-045-00 Scores: Text - 7.8 Abstract = 7.0 Coded' Fields - 9.1 Overall - 7.7 l l

Text 1. 50.73(b)(2)(11)(C)--Date/ time information for the '

corrective actions is not included.

2. 50.73(b)(2)(11)(D)--The root and/or intermediate

, cause discussion concerning the capacitance probe is not-included. What caused the probe to crack?

3. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
4. 50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed train / system is not included.
5. 50.73(b)(2)(11)(L)--Identification (e.g.,

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

6. 50.73(b)(41--Does anything need to be done to prevent >

the probe from cracking again (see text comment 2)?

t

7. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous.similar events are known, the text should so state.

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

The faulty probe was not mentioned.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event'is not included.
3. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract'. This abstract contains information that was not included in the text.

Coded Fields 1. Item (4?--Title: Cause infnrmation (cracked level ,

probe) ts inadequate, i

2. Item (13)--One or more component failure sub-fields are blank.

i i D-11 i

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

TABLE D-1. "

SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

8. -LER Number: 86-046-00 Scores: Text = 8.0 Abstract - 6.4 Coded Fields - 9.2 Overall - 7.6

, Text 1. 50.73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3. 50.73(b)(2)(ii)(J)(2)--It appears that personnel error and/or procedural deficiency may be involved in this event, but it is not discussed. Who was involved in leaving or turning the WRGM monitor off?

What activity was being performed at the time the monitor was turned off?

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The corrective actions discussion does not explain what was done to reduce the probability of recurrence of the WRGM monitor being inadvertently left off.
5. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. See text comment number 3.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
3. Additional space is available within the abstract field to provide the necessary information but it was not utilized. i Coded Fields 1. Item (4)--Title: Root cause (personnel error) is not included.

f D-12

TABLE,D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments- ,

l

9. LER Number: 86-050-00 j Scores: Text - 7.1 Abstract - 8.0 Coded Fields - 8.8 Overall - 7.5 Text 1. 50.73(b)(2)(11)(D)--The root and/or intermediate i cause discussion concerning failed switches is inadequate. It is stated that the root cause has not t yet been determined and that a supplemental report will not be submitted unless generic corrective-actions are required. How will the reader determine root cause information if a supplemental report is
not provided? Is end-of-life failure to be assumed?
2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text-is not included.

i 3. 50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed train / system is inadequate. Is there an estimate-available for how l long the bypass switch (1E31A-S18) could have been in a failed condition (i.e., the two contacts in the closed position with the switch in the normal position) prior to 0633 on 8/7/867

4. 50.73(b)(2)(ii)(J)(2)--It appears that personnel error and/or procedural deficiency may be involved in this event, but it is not discussed. Given a "RWCU HX ROOM HI TEMP" alarm, is there a procedure that requires verification of tne expected isolation and manual isolation if the automatic isolation did not occur?
5. 50.73(b)(2)(ii)(L)--Identification (e.g.,

penufacturer and model no.) of the failed component (s) discussed in the text is inadequate.

What is the manufacturer ~name and model number for the logic bypass switch? What is the model number of the Riley d/T switch?

6. 50.73(b)(3)--Discussion of the assessment of the i safety consequences and implications of the event is

! inadequate. It appears from the text discussion that the required safety function (the RWCU isolation)

, would not have occurred given a valid isolation signal.

1 i D-13 l

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1 TABLE D-1. SPECIFIC LER CONNENTS FOR RIVER BEND (458)

I Section Comments

9. LER Number: 86-050-00 (Continued) 1
7. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. OBSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information. If no supplemental report is provided, there is no information concerning the prevention of a similar event in the future. See text comment number 1.
8. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.
9. Some conclusions reached are inconsistent with the facts presented.

Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. The fact that the root cause is yet to be determined by an on-going investigation was not i mentioned.

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

There is no mention of any actions to prevent recurrence of the event.

Coded Fields 1. Item (4)--Title: Cause is inadequate and link is not included. A better. title might be " Faulty Bypass Switch (Root Cause Unknown) Results In RWCU Failure To Isolate On A Spurious Differential Temperature Switch Signal."

2. Item (13)--Cause, system, and/or component code appears inconsistent with information provided in the text. The codes "JN", "1", and "GO*0" appear to be wrong.

0-14 i

TA8LE.D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

10. LER Number: 86-055-00 Scores: Text - 6.6 Abstract = 9.1 Coded Fields - 8.3 Overall - 7.5 Text 1. 50.73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not included.
2. 50.73(b)(2)(11)(C)--Date/ time information for the corrective actions is not included.
3. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the failed relay is not included. Why did the coil fail? A supplemental report appears to be needed to describe the results
of the investigation into the transformer failure if these results would change the perspective of the event and/or result in additional corrective actions being implemented.

! 4. 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

5. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included (see text comment 2).
6. 50.73(b)(2)(11)(L)--Identification (e.g.,

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

7. 50.73(b)(4)--A discussion of actions required to j reduce the probability of recurrence () a. correction of the root cause) is not included. Without knowing the root cause (see text comment 3), simply replacing the relays may not prevent the new relay from failing in the same manner. A supplemental report appears to be needed to describe any corrective actions found necessary as a result of the investigation into the transformer failure.
8. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

l 0-15 i

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. TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458) l Section Comments-

10. LER Number: 86-055-00 (Continued) l l

Abstrart 1. The abstract contains greater than 1400 spaces.

2. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text. The power level prior to the event is given in the abstract but not the text.

Coded Fields 1. Item (4)--Title: Link (loss of scram air header pressure) is not included and the cause is incomplete. A more appropriate title might be " Low Water Level Reactor Scram Results from Loss of Scram Air Header Pressure Caused By Failure of a Transformer and a Relay".

2. Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).
3. Item (141--The block checked appears to be inconsistent with information provided in the text; see text comment numbers 3 and 7.

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D-16

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

11. LER Number: 86-058-00 Scores: Text - 8.6 Abstract - 7.6 Coded Fields - 8.4 Overall - 8.3 ,

Text 1. 50.73(b)(2)(11)f C)--Date and time of the return to

'P service of Serv 1ce Water Pump 1A is not included.

2. 50.73Lb?f2)Lii)(F)--The Energy Industry
Ident1f tcatlon System code for each component and/or system referred to in the text is not included.

I '

3. 50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed train / system is not

, included. An estimate of the total time of unavailability of the Service Water train 1A is not given.

4. 50.73(b)(2)(11)(L)--Identification (e.g.,
manufacturer and model no.) of the failed 4

component (s) discussed in the text is not included.

Abstract 1. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is not included.

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

not utilized.

3. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This.

i abstract contains information that was not included in the text. The text does not relate how many' Standby Service Water pumps actuated.

Coded Fields 1. Item (41--Title: Root cause (cognizant' personnel error) and link (during breaker lineup) are not .

, included. A better title might be: "

During Breaker Lineup Operator Mistakenly Deenergized Service Water Pump Resulting in Low Header Pressure Which Autostarted All Standby Service Water Pumps".

l D-17

- - -,.-,,,w,- p , - - . - - . s,,,-~ _--m. , - . - - - - - - , , ,-- e-,,y - - . -y,.y-w, a--- ,--.w-- - - , - ,,-y  % -. -,,,,,-w. --w,,.%.g.,y.--._rg ,-p- g--

TA8tE D-1. ; SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

11. LER Number: 86-058-00 (Continued)
2. 'The cause code, "D"-defective procedure, appears inconsistent with information provided in the text, which implies cognizant personnel error.

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D-18 1

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.- _- - _ _ _ - , - - - - - - - - - . . . . . - . . _ . . .-- - , . - . - , . , _ . . . . . _ , , - _ . . . . _ , , ,. .---,___, .. ., ,_n.,_.. ._

TA8LE D-1. SPECIFIC LER CDMMENTS FOR. RIVER BEND (458)

Section Comments

12. LER Number: 86-059-01 i Scores: Text - 8.9 Abstract - 8.9 Coded Fields - 7.5 Overall - 8.7 Text 1. 50.73(b)(2K11)(F1--The Energy Industry Identificatlon System code for each component and/or system referred to in the text is not included.

, 2. 50.73(b)(31--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary 4

information.

l 3. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar.

events are known, the text should so state.

t

4. The use of revision bars is a good practice.

Abstract 1. 50.73(b)(11--Summary of cause information is j inadequate. Information concerning the problems with construction turn over to operating organizations and

the fact that some construction design changes were l closed out without verification of plant procedure i

updates was not mentioned in the abstract.

I l 2. The analysis (to determine the effects to the system i had the piping in question been full of air) and the 1

supplemental report were not mentioned in the 3

abstract.

Coded fields 1. Item (41--Title: Cause is inadequate and the link and result are not included. A better title would

be, " Low Pressure Coolant Injection Piping Not j Verified full of Water as Required By Technical l Specifications Due To Use of An Inadequate i Surveillance Test Procedure".

1

2. Item (71--08SERVATION: Report date is not within )

i thirty days of event date (or discovery date if  ;

appropriate) on original report (LER 86-059-00).

i D-19 i

, . . - - - , , , - - - , . - - ---- - , . , , . . - - . - , - - - , . - . , - -,n. , . - - - - - , , , - , - - ,-,---,,,,,n-,n--,- . . . - - --.~.,,--n,-,-n,.-, - - - . - - -

. l TA8LE D-1.. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

13. LER Number: 86-066-00 Scores: Text - 6.4 Abstract - 7.7 Coded Fields - 9.1 Overall - 7.1 Text 1. 50.73(b)(2)(11)(Al--Technically the operating conditions prior to the event are required to be given in the text, although the conditions prior to this event are not very meaningful to the event. It could be helpful to some readers, however, to indicate the most severe operating conditions that existed during the period when the fire watches were missed.
2. 50.73(b)(2)(11)(C)--Date/ time information is essentially not included, since only one date (the expected completion of a corrective action) is given. The text should at least include the date I that the deficiency was discovered.
3. 50.73Lb)(2)L11)(F)--The Energy Industry Identlficatlon System code for each component and/or system referred to in the text is not included.
4. 50.73(b)(31--01scussion of the assessment of the safety consequences and implications of the event is inadequate. It is not sufficient to state that there were no safety consequences because there was no fire or that the equipment was not required to be operable during the time period in question. The possibility existed of missing the surveillances until after the affected equipment was needed or until after a fire had actually occurred. The safety assessment should, therefore, address the implications had the problem not been discovered in time. This assessment should indicate if other systems were available as backup, either to prevent a fire or to backup a system lost l due to a fire.
5. 50.73(b)(41--01scussion of corrective actions taken or planned is inadequate. The text indicates that several temporary measures were taken to correct problems, but does not discuss whether or not permanent changes to procedures were made or whether or not the doors found out of specification were repaired.

{

l 0-20

,o TA8LE 0-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

13. LER Number: 86-066-00 (Continued)
6. 50.73(b)(5)--Information concerning previous siellar events is not included. If no previous sin 11ar events are known, the text should so state.

Abstract 1. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The Temporary Change Notice (to include the two doors in the daily STP) and the Modification Request were not mentioned in the abstract.

2. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text. The discovery date (see text comment 2), the plant conditions prior to the event (see text comment 1), and safety assessment data (see text comment 4) are discussed in the abstract but not the text.

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

I D-21

, TABLE D-1. SPECIFIC LER COMNENTS FOR RIVER 8END (458) j Section Comments

14. LER Number
86-068-00 Scores: Text - 8.9 Abstract - 9.7 Coded Fields - 9.7 Overall - 9.2 Text 1. 50.73(b)(2)(11)(0)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3. 50.73(b)(2)(11)(L)--Identification (e.g.,

senufacturer and model no.) of the failed component (s) discussed in the text is inadequate.

4 The model number of the failed pressure transmitter 1s not included.

I 4. 50.73(b)(41--08SERVATION: The score for this I

requirement is based on the assumption that the supplemental report will contain all the necessary information.

5. 50.73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comments.

l Coded Fields 1. Item (4)--Title: Unless space is a problem, acronyms should not be used in the title.

l i

i 4

D-22 l

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

TABLE 0-1. SPECIFIC LFR COMMENTS FOR RIVER BEND (458)

Section Comments i

15. LER Number: 86-069-00 l Scores: Text - 8.1 Abstract - 8.2 Coded Fields - 9.0 Overall - 8.2 l

Text 1. 50.73(b)(2)(11)(01--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3. 50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate. Any safety systems that actuated or were manually initiated as a result of the scram should be listed.
4. 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.

}'

5. 50.73(b)(4)--What was the surveillance frequency changed from and to?

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

1" Abstract 1. 50.73(b)(11--Summary of cause information is inadequate. The abstract should mention that the  ;

cause of the valve positioner sticking is not known but is under investigation. The temperature switch j setpoint drift should have been mentioned.

J i

2. 50.73(b)(1)--Summary of corrective actions taken or l j planned as a result of the event is inadequate. The j fact that additional corrective actions might result j i from the vendor's investigation and the fact that the ,

J temperature switch surveillance frequency was  !

1 increased should have been mentioned. j I

! 3. Additional space is available within the abstract l field to provide the necessary information but it was not utilized, i

i 4

D-23

\

4 i

TABLE D-1. SPECIFIC LER COMMENTS FOR RIVER BEND (458)

Section Comments

15. LER Number: 86-069-00 (Continued)

Coded fields 1. Item (4)--Title: Root cause as not included. A better title might be " Sticky Cooling Water Valve Positioner (Cause Under Investigation) Causes Main Generator High Stator Temperature and a Subsequent Reactor Scram".

I D-24

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