ML20215L045
| ML20215L045 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/16/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8610280440 | |
| Download: ML20215L045 (54) | |
Text
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October 16, 1986 d
Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7 Virginia lectric and Power Company ATTN.
- r. W. L. Stewart, Vice President, Nuclear Operations P. O. Box 26666 g
Richmond, VA 23261 Gentlemen:
The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AE0D) has recently completed an assessment of your Licensee Event Reports (LERs) for North Anna 1 and 2 as a part of the NRC's Systematic Assessment of Licensee Performance (SALP) program.
In general, AE00 found the LER submittals to be of average quality based on the requirements contained in 10 CFR 50.73.
We are forwarding a copy of AEOD's assessment prior to the issuance of the North Anna SALP Board Report (50-338/86-22, 50-339/86-22) in an effort to provide useful information for preparation of future submittals.
Please let us know if you have any questions.
Sincerely, Original Signed by Luis A. Reyes /for Roger D. Walker, Director Division of Reactor Projects
Enclosure:
AE00 SALP Input for North Anna 1 and 2 - Operations (LER Quality) for the Assessment Period of 1 March 1985 to 31 August 1986 cc / encl:
. W. Harrell, Station Manager J. Hardwick, Manager - Nuclear Programs and Licensing bec w/ encl:
(See Page 2) 8610280440 861016 PDR ADOCK 0D000338 G
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ENCLOSURE t
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AE00 SALP INPUT FOR NORTH ANNA 1, 2 -
OPERATIONS (LER QUALITY) FOR l
THE ASSESSMENT PERIOD OF 3
l 1 MARCH 1985 TO 31 AUGUST 1986 N
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by North Anna 1 and 2 during the March 1, 1985 to August 31, 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. The results of this evaluation indicate that the North Anna LERs have an overall average score of 8.1 out of a possible 10 points, compared to a current industry average score of 7.9 for those units / stations that have been evaluated to date using this methodology.
The principle weaknesses identified in the North Anna LERs, in terms of safety significance, involve the requirement to provide an assessment of the safety consequences of the event and the requirement to identify failed j
components in the text.
Deficiencies in the safety consequence discussion prompts concern as to whether or not each event is being evaluated such j
that the potential consequences of the event, had it occurred under a I
different set of initial conditions, are being identified. The failure to adequately identify each compo'nent that fails prompts concern that possible 4
generic problems may go unnoticed by others in the industry for too long a time period.
A strong point for the North Anna LERs is that the discussion concerning the failure mode, mechanism, and effect of failed components were well written in most of the LERs involving this requirement.
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.s AE00 INPUT TO SALP REVIEW FOR NORTH ANNA 1 AND 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by North Anna 1 and 2 during the March 1, 1985 to August 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology 7
presented in NUREG/CR-4178.
The sample consists of a total of 15 LERs (i.e., 9 LERs for North Anna 1 and 6 for North Anna 2), which is half of the LERs on file at the time the sample was selected. The North Anna LERs were evaluated as one sample for this SALP period because it was determined that their LERs are both written and formally reviewed at the station, rather than unit, level. See Appendix A for a list of the LER numbers in
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the sample.
.It was necessary to start the evaluation before the end of the SALP i
I 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 4
assessment period were not available for review.
Methodology i
The evaluation consists of a detailed review of each selected LER to
,i determine how well'the content of its text, abstract, and coded fields meet 3
the requirements of 10 CFR 50.73(b), NUREG-1022, and Supplements 1 f
and 2 to NUREG-1022.
The evaluation process for each LER is divided into two parts.
The first part of the evaluation consists of documenting comments specific to I
the content and presentation of each LER. The second part consists of l
determining a score (0-10 points) for the text, abstract, and coded fields
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of each LER.
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i The LER specific comments ssrve two purpsses:
(1) they point cut what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was reviewed. Likewise, the scores serve two purposes:
(1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded j
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 l
categories:
(1) detailed information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix 8), tables of the number of deficiencies and observations for the 4
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 4
deficiency when assigning scores.
Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such 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, North Anna LERs were evaluated as one sample.
i rather than two separate samples (by unit), because it was determined that l
the North Anna LERs are both written and fornelly reviewed at the station,
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rather than the unit, level.
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Table 1 presents th2 averaga 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, i
In order to place the scores provided in Table 1 in perspective, the distribution of the overall average score for all licensees that have been l
evaluated using the current methodology is provided on Figure 1.
Additional scores are added to Figure i each month as other 11cersees are evaluated. Table 2 and Appendix Table B-1 provide a summary of the I
information that is the basis for the average scores in Table 1.
For example, North Anna's average score for the text of the LERs that were evaluated is 7.7 out of a possible 10 points.
From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event (10 CFR 50.73(b)(2)(ii)(A)) to text presentation. The percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the station for the 15 LERs that were evaluated.
Discussion of Specific Deficiencies
,4 A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most diffic,ulty in preparing LERs.
For example, requirement 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 l
either:
(1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address l
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.
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TABLE 1.
SUMMARY
OF SCORES' FOR NORTH ANNA 1, 2 Average Hiah Low Text 7.7 9.3 6.5 Abstract 8.6 10.0 5.7 Coded Fields 9.2 10.0 8.3 Overall 8.1 9.6 6.9 See Appendix B for a sununary of scores for each LER that was evaluated.
a.
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l Figure 1. Distribution of overall average LER scores i
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v 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average. scores j
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TA8LE 2.
LER REQUIREMENT PERCENTAGE SCORES FOR NORTH ANNA 1, 2 TEXT Percentage Reauirements ISO.73(b)1 - Descr1Dtions Scores ( )
(2)(ii)(A) - - Plant condition prior to event 3
100 (15)
(2)(ii)(B) - - Inoperable equipment that contributed b
(2)(ii)(C) - - Date(s) and approximate times 87 (15)
(2)(ii)(D) - - Root cause and intermediate cause(s) 85 (15)
(2)(ii)(E) - - Mode, mechanism, and effect 95 (10)
(2)(ii)(F) - - EIIS Codes 80 (15)
(2)(it)(G) - - Secondary function affected b
(2)(ii)(H) - - Estimate of unavailability 100 (3)
(2)(11)(I) - - Method of discovery 100 (15) 95 (7)
(2)(11)(J)(1) - Operator actions affecting course (2)(11)(J)(2) - Personnel error (procedural deficiency) 90 (5) 69 (6)
(2)(11)(K) - - Safety system responses (2)(ii)(L) - - Manufacturer and model no. information 70 (10)
Assessment of safety consequences 38 (15)
(3)
Corrective actions 81 (15)
(4)
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Previous similar event information 20 (15)
(5)
(2)(1) - - - - Text presentation 80 (15) 4 ABSTRACT
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Percentage ~
Reautrements ISO.73(b)(111 - Descriptions Scores ( l'
- Major occurrences (Immediate cause and effect 100 (15) information)
- Description of plant, system, component, and/or 92 (9) personnel responses I
- Root cause information 86 (15)
- Corrective Action information 75 (15) j
- Abstract presentation 80 (15) 1 i
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TABLE 2.
(continued)
CODED flELOS Percentage Ites Number (s) - Description Scores ( )'
1, 2, and 3 - Facility name (unit no.), docket no, and 100 (15) page number (s) 4 - - - - - - Title 73 (15) 5, 6, and 7 - Event date, LER No., and report date 98 (15) 8 - - - - - - Other factitties involved 100 (15) 9 and 10 - - Operating mode and power level 100 (15) 11 - - - - - Reporting requirements 100 (15) 12 - - - - - Licensee contact information 97 (15) 13 - - - - - Coded component failure information 93 (15) 14 and 15 - - Supplemental report information 93 (15) a.
Fercentage scores are the result of dividing the total points for a
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requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all LERs; therefore, the 4
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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4 Eleven of the 15 LERs evaluated were cc sid: rcd to b2 dificicnt in tha area of providing an assessment of the safety consequences and implications of the event, Requirement 50.73(b)(3).
Eight of the LERs did not contain any discussion concerning safety consequences and three others lacked certain details necessary to a complete discussion.
Every LER is required to contain a discussion of the safety assessment that should be performed after the event.
If the conclusion of this discussion is that "there were no safety consequences", sufficient details must be provided to allow the reader to determine how this conclusion was reached.
For example, if it was concluded that there were no consequences because there were other systems (or means) available to mitigate the consequences of the safety In system failure, these systems or means should be discussed in the text.
addition, each discussion should include information as to whether or not the occurrence could have happened under a set of initial conditions that would have made the consequences more severe.
If the occurrence could not have occurred under a more severe set of conditions, the text should so state.
I Adequate information was not provided in four of the six LERs involving safety system actuations. As a minimum the text of the LER must list all safety systems that either initiated automatically or had to be 4
manually initiated as a result of the event.
It is not sufficient to simply state "all major equipment responded as designed".
The manufacturer and/or model number (or other unique identification) was not provided in the text of five of the ten LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail I
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.
l Requirement 50.73(b)(5) was not adequately addressed in twelve of the fif teen LERs in that their text did not include the necessary information I
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.s concerning previous similar events. All previcus si;ilar evsnts sh:uld be appropriately referenced (by LER number, if possible) and the history of If there have been i
the on-going problem should be discussed, if necessary.
no previous similar events, the text should state this.
The root cause and corrective action discussions are considered marginal even though the overall score for these requirements are 85% and 81%, respectively.
Six of the fifteen LERs failed to provide sufficient details cuncerning the cause of the event and eight LERs failed to provide the necessary information concerning what was done to fix the problem or to prevent the problem from recurring.
The text presentation score would probably have been higher had the text been presented in an outline format such as the one suggested in NUREG-1022, Supplement No. 2.
An outline format not only makes it easier for the reader to understand the significance of various statements but also makes it easier for the writer to ensure that he has gathered and presented information pertinent to all the requirements.
The primary deficiencies concerning the abstracts involves root cause and corrective action information. Eight of the abstracts failed to adequately summarize root cause information that was presented in the 4
text.
Similarly, eight abstracts failed to provide adequate information concerning corrective actions.
Three abstracts provided information that had not been previously i
presented in the text. During the licensee's final review, the reviewer should look for this situation and revise the text such that it includes the necessary details.
The main deficiency in the area of coded fields involves the title, Item (4).
Twelve of the titles failed to indicate root cause and three While the failed to include the link between the cause and the result.
result is considered to be the most important part of the title, cause and link information must be included to make a title complete.
An example of
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l This is a title that only addresses the result might be " Reactor Scram".
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j inadequate in that the cause and link are not provided. A more appropriate title might be ' tadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor,,. ram".
From this title, the reader knows the cause involved either personnel or procedures and testing contributed to the event.
Table 3 provides a summary of the areas that need improvement for the North Anna 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, Suppleme9t No. 2.
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AREAS MOST NEEDING IMPROVEMENT FOR NORTH ANNA 1, 2 LERs Areas Comments Safety assessment information All LERs should include a detailed safety assessment. The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstances and provide information about backup systems that were available to limit the consequences of the event.
Automatic / manual safety All safety system that actuate automatically system responses or that must be manually initiated as a result of the event should be named in the text.
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.
Text presentation
. The use of a consistent outline format is suggested.
4 Abstracts Cause and corrective action information needs to be included.
The text should include all information contained in the abstract.
- Coded fields a.
Titles Titles should be written such that they better describe the event.
In particular, include the root cause and the link in each title.
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l 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 Repor t System, NUREG-1022, U.S. Nuclear Regulatory Connission, September 1983.
3.
Office for Analysis and Evaluation of Operational Data, Licensee Event Ry ort System, NUREG-1022 Supplement No. 1. U.S. Nuclear Regulatory Commission, f ebruary 1984.
4.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Comnission, September 1985.
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- 9 APPENDIX A LER SAMPLE SELECTION INFORMATION
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FOR NORTH ANNA 1, 2 9
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A TA8LE A-1.
LER SAMPLE SELECTION FOR NORTH ANNA 1, 2 Sample Number Unit Number LER Number Comments 1
I 85-007-00 2
1 85-017-01 Scram 3
1 85-020-00 4
1 85-022-00 5
1 85-023-00 ESF 6
1 85-027-01 7
1 85-029-00 8
1 86-001-00 Scram 9
1 86-002-00 Scram
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10 2
85-005-01 Scram 11 2
85-008-00 12 2
86-001-00 13 2
86-003-00 14 2
86-006-00 15 2
86-008-00 Scram
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I A-1
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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERS FOR NORTH ANNA 1, 2 e
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TABLE B-1.
EVALUATION SCORES OF IIIDIVIOUAL LERs FOR IIORTH AfflA 1, 2 X
LER Sample Number *
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1 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 I~
Text 8.1 7.9 6.9 7.0 7.9 7.3 6.5 7.5 7.5 6.9 7.8 8.9 8.6 9.3 7.3 Abstract 9.8 9.6 9.7 9.2 6.9 8.1 8.5 8.0 8.6 8.8 8.6 9.5 8.6 10.0 5.7 Coded Fleids 9.2 9.5 9.0 9.3 10.0 9.1 9.0 9.0 9.5 7.9 9.5 9.5 8.8 10.0 8.3 Overall 8.7
- 8. 6.
8.0 7.9 7.8 7.7 7.3 7.8 8.0 7.6 8.2 9.2 8.6 9.6 6.9 LER Sample plumber' 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE 7*
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Abstract Coded Fields 0*I
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Overall a.
See Appendix A for a list of the corresponding LER numbers.
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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR NORTH ANNA 1, 2 e
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TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR NORTH ANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)D a
50.73(b)(2)(11)(A)--Plant operating 0 (15) conditions before the event were not included or were inadequate.
50.73(b)(2)(ii)(B)--Discussion of the status 0 (5) 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 5 (15) sufficient date and/or time information.
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a.
Date information was insufficient.
2 b.
Time information was insufficient.
3 50.73(b)(2)(11)(0)--The root cause and/or 6(15) intermediate tailure, system failure, or personnel error 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 c.
Cause of personnel error was not 0
included or was inadequate.
50.73(b)(21(11)(E)--The failure mode, 2 (10) mechanism L immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode was not included or was 0
inadequate b.
Mechanism (immediate cause) was not 0
l included or was inadequate c.
Effect (consequence) was not included 2
or was inadequate.
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TA8LE C-1.
(ccatinu:d)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph 2
Description of' Deficiencies and Observations Totals
- Totals (
)
3 (15) 50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier for each component or system was not included.
50.73(b)(2)(ii)(G)--For a failure of a 0 (0) component with multiple functions, a list j
of systems or secondary functions which were also affected was not included or was l
inadequate.
0 (3) 50.73(b)(2)(ii)(H)--For a failure that rendered a train of a safety system i
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inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.
i 50.73(b)(2)(ii)(I)--The method of discovery 0 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
4
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a.
Method of discovery for each
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component failure was not included or was inadequate l
b.
Method of discovery for each system failure was not included or was 1
l inadequate c.
Method of discovery for each personnel error was not included or i
was inadequate d.
Method of discovery for each procedural error was not included or l
was inadequate.
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(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Totals' Totals (
)
Description of Deficiencies and Observations 1 (7) 50.73(b)(2)(ii)(J)(1)--Operator actions that affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
1 (5) 50.73(b)(2)(11)(J)(21--The discussion of 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.
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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.
50.73(b)(2)(ti)(J)(2)(ti)--Discussion 0
c.
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 g
with an activity or task that was not covered by an approved procedure was not included or was inadequate.
d.
50.73(b)(2)(ti)(J)(2)(iiil--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, 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1
e.
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.
C-3
,h. C g.:* k TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)D 50.73(b)(2)(ii)(K)--Automatic and/or manual 4 (6) safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 5 (10) model number of each failed component was not included or was inadequate.
50.73(b)(31--An assessment of the safety 11 (15) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION: The availability of 0
other systems or components capable of mitigating the consequences of the event was not discussed.
If no other systems or components were available, the text should state that none existed.
b.
OBSERVATION: The consequences 2
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 8 (15) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.
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(ctntinued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Totals Totals (
)b a
Description of Deficiencies and Observations A discussion of actions required to 2
a.
correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.
4 b.
A discussion of actions required to 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.
12 (15) 50.73(b)(5)--Information concerning previous similar events was not included or was inadequate.
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TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations __ Totals' Totals (
)D 50.73(b)(2)(1)--Text presentation 3 (15) inadequacies, a.
OBSERVATION: A diagram would have 1
aided in understanding the text discussion, b.
Text contained undefined acrnnyms 0
and/or plant specific designators.
c.
The text contains other specific 2
deficiencies relating to the readability.
The "sub-paragraph total" is a tabulation of specific deficiencies or a.observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be defici'ent in
~
the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs~that have one or more
(
requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.
O N.
C-6
'"w w'
wW w
k!
TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR NORTH ANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Totals Totals (
)D a
Description of Deficiencies and Observations 0 (15)
A summary of occurrences (immediate cause and effect) was not included or was inadequate 1
(9)
A summary of plant, system, and/or personnel responses was not included or was inadequate.
1 Summary of plant responses was not a.
included or was inadequate.
1 b.
Summary of system responses was not included or was inadequate.
1 Summary of personnel responses was not c.
1.
included or was inadequate.
8 (15)
A summary of the root cause of the event was not included or was inadequate.
8 (15)
~
A summary of the corrective actions taken or planned as a result of the event was not included or was inadequate.
4 I
C-7 1
l
~-
5
,7..
t TABLE C-2.
(continusd)
Number of LERs with 8
Deficiencies and Observations Sub-paragraph Paragraph a
Totals Totals (
)
Description of Deficiencies and Observations 4 (15)
Abstract presentation inadequacies a.
OBSERVATION: The abstract contaties 3
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.
0 b.
The abstract was greater than 1400 characters 0
The abstract contains undefined c.
acronyms and/or plant specific designators.
1 d.
The abstract contains other specific deficiencies (i.e., poor summarization, contradictions, etc.)
4 The "sub-paragraph total" is a tabulation of specific deficiencies or Since an LER can have more than a.observations within certain requirements.
one deficiency for certain requirements, the sub-paragraph totals do not b
necessarily add up to the paragraph total.
The " paragraph total" is the number of LERs that have one or moreThe number b.deficiency or observation.
~
for which a certain requirement was considered applicable.
i l
C-8 w
--.._._,_y, r
,-,,.m,
,,,.m
.,m,.
J' 1
TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR NORTH ANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
b Description of Deficiencies and Observations _ Totals Totals (
l 0 (15)
Facility Name 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 12 (15) a.
Root cause was not given in title 12 b.
Result (effect) was not given in title 0
c.
Link was not given in title 3
4 Event Date 1 (15) a.
Date not included or was incorrect.
O
~
b.
Discovery date given instead of event 1
date.
LER Number was not included or was incorrect 0 (15) 0 (15) l Report Date l
a.
Date not included b.
OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).
Other Facilities information in field is 0 (15) inconsistent with text and/or abstract.
Operating Mode was not included or was 0 (15) inconsistent with text or abstract.
~-
C-9 l
i
.. s TABLE C-3.
(continued}
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _ Totals' Totals (
)D 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 m.
additional unchecked paragraph.
Licensee Contact 2 (15) a.
Field left blank 0
~
b.
Position title was not included 2
c.
Name was not included O
d.
Phone number was not included.
0 E
Coded Component Failure Information 2 (15) a.
One or more component failure 1
sub-fields were left blank.
b.
Cause, system, and/or component code 0
is inconsistent with text.
c.
Component failure field contains data 1
when no component failure occurred.
d.
Component failure occurred but entire i
field left blank.
~._
C-10
~
I
.w p---.-
1 TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
1 (15)
Supplemental Report a.
Neither "Yes"/"No" block of the 0
supplemental report field was
- checked, b.
The block checked was inconsistent I
with the text.
0 (15)
Expected submission date information is inconsistent with the block checked in Item (14).
The "sub-paragraph total" is a tabulation of specific deficiencies or a.observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do.not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
4 d
2 l
m C-11
?
,4
APPENDIX D LER COMMENT SHEETS FOR NORTH ANNA 1, 2 e
e t
Y e
D 5
M.
, ;8 -
t
- n TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 1.
LER Number: 85-007-00 Scores: Text = 8.1 Abstract = 9.8 Coded Fields = 9.2 Overall = 8.7 Text 1.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
2.
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 comment Coded Fields 1.
Item (4)--Title:
Root cause is not included. A more appropriate title might be, " Fire Barrier Penetration Lef t Unsealed Without Fire Watch - Personnel Error".
2.
Item (12)--Position title is not included.
- t 9
i MF D-1
,--i-,
__,y
i 1
TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 2.
LER Number: 85-017-01 Scores: Text - 7.9 Abstract - 9.6 Coded Fields - 9.5 Overall - 8.6 Text 1.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. Any safety systems that responded as a result of the reactor trip should be listed. The statement "All plant parameters responded normally." is inadequate.
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. This discussion should include the implications of the initial rod misalignment, the reactor trip, and the subsequent operation with three of the four alarm circuit cards not functioning properly.
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.
Abstract 1.
No comments Coded Fields 1.
Item (4)--The title should indicate the cause of the dropped rods.
D-2
i i;
. i i f? :
8 TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 3.
LER Number: 85-020-00 Scores: Text - 6.9 Abstract = 9.7 Coded Fields = 9.0 Overall - 8.0 Text 1.
50.73(b)(2)(ii)(C)--Date information for major occurrences is not included.
Dates for occurrences such as 1) when the "C" S/G tubes were found defective, 2) when the "A and B" S/G tubes were inspected, and 3) when the last S/G tube inspection was performed (e.g. during the previous refueling outage) would be appropriate.
2.
50.73(b)(2)(ii)(D)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
3.
50.73(b)(2)(ii)(E)--The failure effect discussion of each failed component is not included.
It would be appropriate to tell the reader that the effect of a leaking tube is the possible release of radioactive material.
4.
10.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
4 5.
50.73(b)(4)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
7.
OBSERVATION: A diagram or figure would aid in understanding the event (e.g., a cutaway of the steam l
generator).
i 8.
It is not apparent from the text why only the defects identified in the "C" S/G are reportable. This should have been explained as it was in the abstract l
(2nd sentence of the 2nd paragraph of the abstract).
l f
l i
1 0-3
i TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 3.
LER Number:
(continued)
Abstract 1.
OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.
Coded Fields 1.
11_em (4)--Title:
Root and link are not included. A better title might be, " Steam Generator Tube Defects Identified During Refueling Outage Inspections -
Cause Unknown".
O F
D-4
TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments
___ Section 4.
LER Number: 85-022-00 Scores: Text - 7.0 Abstract - 9.2 Coded fields - 9.3 Overall - 7.9 Text 1,
50.73(b)(2)(ii)(J)(2)--Although the employee did not know that the firearm was in his bag, some explanation as to how and why the firearm got into the bag (e.g., employee used bag to transport weapon to shooting range, etc.) would be useful in understanding this event.
2.
50.73(b)(2)(ti)(J)(2)--Discussion of the personnel error is inadequate.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.
^
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
4.
50.73(b)(4)--Justification for reinstating the employee should be explained, for example, by including a discussion of why the firearm was in the bag (see text Comment 1).
-t 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.
No comment Coded Fields 1.
Item (4)--Title:
Root cause (employee negligence) is not included.
I
~.,
l D-5 l
l
I
~ TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338) i Section Comments 5.
LER Number: 85-023-00 Scores: Text - 7.9 Abstract - 6.9 Coded Fields = 10.0 Overall = 7.8 Text 1.
50.73(b)(2)(11)(C)--Time information for major occurrences is inadequate. A time should be provided for the termination of the injection.
2.
50.73(b)(2)(11)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
How was the injection terminated?
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered tha most severe conditions, the text should so stac.
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.
Some ideas are not presented clearly (hard to follow).
E Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract should summarize the test discussion concerning how the event was caused by the lack of information in written or training form.
~
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The abstract should summarize the corrective actions discussed in the text.
3.
OBSERVATION: The abstract contains information not included in the text.
The abstract is intended to De a summary of the text; therefore, the text should I
discuss all information summarized in the abstract.
Coded Fields 1.
No comments l
l
~-
0-6
a
., ~;1 3
TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Section Comments 6.
LER Number: 85-027-01 Scores: Text - 7.3 Abstract - 8.1 Coded Fields - 9.1 Overall - 7.7 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the changed resistance characteristics of the RTD and the disc-stem separation of 1-RC-88 is inadequate. Why did the resistance characteristics of the normal RTD change while the resistance of the installed spare RTD dpparently didn't change? What Caused the disc-stem separation on the 2-inch Rockwell T-58 globe stop valve?
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
=^
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
A discussion of actions required to reduce the' probability of recurrence (i.e correction of the root cause) is not included or is inadequate.
4.
50.73(b)(51--Information concerning previous similar events is not included.
If no previous similar g,
events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate.
Valve 1-RC-88's involvement in the inoperability of Channel III should have been mentioned in the abstract.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The I
replacement of valve 1-RC-88 should have been mentioned in the abstract.
3.
O8SERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract (i.e., the information concerning the 6-hour requirement of TS 3.0.3).
~._
D-7
<y.---
--y-
w,,cw------,-
-,,y-,.. - -,. -
y,
--,.--wn--.w--.------
- - - - - - - - - - - - - + - - -
r
- j TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 6.
LER Number:
(continued)
Coded Fields 1.
Item (4)--Title:
Root cause is not included. A better title might be, "Two Out of Three RPS Instrument Channels Declared Inoperable Due to Component Failures - Shutdown Required By T. S. 3.0.3".
e e
4
~
0 D-8 s
TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Section Comments l
7.
LER Numbe'r:
85-029-00 Scores: Text - 6.5 Abstract = 8.5 Coded Fields - 9.0 Overall = 7.3 Text 1.
50.73(b)(2)(ii)(D)--The root cause discussion for the failed Conoseal was not included. When a cause cannot be determined (i.e., the reason the pipe cracked) then it is helpful to a reader to discuss the actions taken to try to determine the cause.
2.
50.73(b)(2)(ii)(L)--A model number for the Conoseal should be provided, if possible. The failed reactor vessel seal rings were not identified.
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
4.
50.73(b)(4)--The corrective actions to prevent recurrence were not discussed for the Conoseal.
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.
The root cause and corrective actions summary are deficient.for the same reason as the text (see text 4
Comments 1 and 4).
Coded Fields 1.
Item (4)--The use of acronyms in a title should be avoided unless space is a consideration.
2.
Item 13--The line containing the pipe failure information should be fully filled in. A line should be filled in for the different seal failures.
~ _
D-9 p.----
1 TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Comments Section 8.
LER Number: 86-001-00 Scores: Text - 7.5 Abstract - 8.0 Coded Fields - 9.0 Overall - 7.8 Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. The time the plant reached a stable condition after the reactor trip should be provided.
2.
50.73(b)(2)(ti)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The safety system and major parameter responses to the reactor trip should be listed.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
4 Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The summarization of the problems with the keys (OPC ~
key serial number did not match the OPC keyswitch serial number) is vague.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
It is not clear from the summarization of the root cause (see abstract comment 1), how discarding the original key will solve the problem.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
l l
l
~ _
l i
0-10 i
y f;
TABLE 0-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Section Comments 9.
LER Number: 86-002-00 i
Scores: Text = 7.5 Abstract - 8.6 Coded Fields = 9.5 Overall - 8.0 1
Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time was the plant stabilized at normal no load conditions?
2.
50.73(b)(2)(til[D1--The root and/or intermediate cause discussion concerning the undercompensated intermediate range detectors, the failed source range detector, and the erratic (inoperable) power supplies is not included. Was the undercompensation the result of personnel error? If so Requirement 50.73(b)(2)(11)(J)(2) should have been addressed.
3.
50.73(b)(2)(ii)(K)--While the discussion of safety system responses is generally complete, the other l
necessary systems in which equipment responded satisfactorily (see the last sentence of the second paragraph on page 2 of 3) should be named if they are safety systems.
4.
50.73(b)(2)(ii)(L)--Although the reader could probably determine the manufacturer of the EHC and turbine. control systems on his own, it would be helpful to include this information in the text.
4 5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is '
not included.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.
A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.
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.
l f
D-11
4 TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 1 (338)
Section Comments 9.
LER Number:
(continued)
Abstract 1.
The cause and corrective information presented in the text was not adequately summarized in the abstract.
Coded Fields 1.
Item (4)--Title: Root cause (cause could not be determined) is not included.
O e
a 4
i 4
=te.
l D-12 1
f SF' '.
- TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Section Comments
- 10. LER Number: 85-005-01 Scores: Text - 6.9 Abstract - 8.8 Coded Fields - 7.9 Overall - 7.6 Text 1.
50.73(b)(2)(ii)(D)--The root cause discussion for the faulty indicator problem was not included. A supplemental report appears to be needed to describe the results of the testing on the SDT relays.
Without a commitment to submit a supplemental report, this LER must be considered incomplete.
2.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(Ll--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50.73(b)(4)--A supplemental report appears to be needed to describe the corrective actions taken on the SDT relays, if any, and~to report the changes
(
made in the switchyard, if any. Without a commitment to submit a supplemental report, this LER must be considered incomplete.
6.
Inclusion of a diagram is helpful.
Abstract.
1.
The root cause summary should mention the faulty SDT relays.
2.
The corrective actions sunnary should mention the two i
investigations being conducted.
3.
If the 1400 space limit were to become a limiting factor in including the above abstract items, a good rule to follow would be to include root cause and corrective action information before the plant operating condition information.
i D-13
+
,1-TABLE 0-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Comments Section
- 10. LER Number:
(continued)
Coded Fields 1.
Item (4)--Title: Root cause (faulty relay) and link (fault signal from transformer #5) are not included.
2.
Item (12)--Position title is not included.
3.
Item (14)--The block checked is inconsistent with information in the text (see comments 1 and 5).
e 6
D-14
r 4
TA8LE 0-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Section Comments
- 11. LER Number: 85-008-00 Scores: Text - 7.8 Abstract - 8.6 Coded Fields = 9.5 Overall = 8.2 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the packing leak from 2-RC-6 is inadequate.
If the cause is not known, information should be provided indicating what maintenance was performed to stop the packing leak.
2.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Some information on what specific maintenance was performed to stop the i
packing leak on 2-RC-6 should be provided (see text comment 1 ).
3.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
4 Abstract 1.
50.73(b1[1)--Summary of root cause is inadequate.
See text comment 1.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate, i
I 4 Coded Fields 1.
Item (41--Title:
Root cause is not included. The cause of the high RCS leakage should be included.
I i
I i
D-15 i
i
?l A..
TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Section Comments
- 12. LER Nur.ber: 86-001-00 Scores: Text - 8.9 Abstract - 9.5 Coded Fields - 9.5 Overall - 9.2 Text 1.
50.73(b)(2)(ii)(D)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
2.
50.73(b)(2)(ii)(E)--The failure effect discussion of each failed component is inadequate. Even though a supplement is scheduled, which is to provide the results of an analysis of consequences, the text of this LER should provide some information as to the possible consequences of this event. For example, simply stating the concern of 10 CFR 50.73(a)(2)(ii)(A) in words would add to this LER.
3.
50.73(b)(2)(ii)(L1--Identification (e.g. i.anufacturer and model no.) or the failed component (s) discussed in the text is inadequate.
Information concerning the model number (etc.) of the Crosby safety valves is needed.
4.
50.73(b)(3)--0BSERVATION:
The score for this
~
requirement is based on the assumption that the supplemental report will contain all the necessary 4
information.
5.
50.73(b)(4)--0BSERVATION:
The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
7.
Some ideas are not presented clearly (hard to follow).
For example, the second paragraph of page 2 of 3 does not provide valve identification numbers (i.e., 2-MS-SV-XXXA), therefore it is not possible to compare the information in this paragraph with the list of valves presented on page 3 of 3.
Abstract 1.
The abstract should mention that corrective actions
~-
will also be provided in the supplemental report.
D-16
ij TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Section Comments 12.
LER Number:
(continued)
Coded Fields 1.
Item (4)--Title:
Root cause ("Unkown") is not Included. A better title might be, "Eight of Fifteen Main Steam Safety Valves Declared Inoperable - High Lift Setpoints, Cause Under Investigation".
=.
5.
O e
h O
l N.
D-17 l
l l
=
g TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Comments Section
- 13. LER Number: 86-003-00 Scores: Text - 8.6 Abstract - 8.6 Coded Fields - 8.8 Overall = 8.6 Text 1.
50.73(b)(2)(11)(C)--An estimate of the date on which the breach of security occurred was not included.
2.
50.73(b)(4)--How will contract personnel be made aware of security procedures in the future?
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.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The inadvertent removal of the 10 inch valve by contract personnel should be mentioned.
i Coded Fields 1.
Item (4)--Title:
Root cause is not included.
2.
Item (5)--It appears that the discovery date is given instead of the event date (see text comment 1).
e k
~
D-18 e-
-,n.
$4
.J';
a
-w TABLE 0-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
___ Section Comments
- 14. LER Number: 8E '.)6-00 Scores: Text - 9.3 Abstract - 10.0 Coded Fields = 10.0 Overall - 9.6 Text 1.
J0.73(b)(2)(ii)(D)--0BSERVATION: 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 component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
~
3.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is very good.
4.
50.73(b)(4)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
Abstract 1.
No comments Coded Fields 1.
No comments 4
0-19 w-
-n
k
};wgl-TABLE D-1.
SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
Section Comments 15.
LER Number: 86-008-00 Scores:
Text = 7.3 Abstract - 5.7 Coded Fields = 8.3 Overall = 6.9 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the undercompensated intermediate range detectors is not included.
2.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The safeij systems containing the " major equipment (that) responded as designed" should be named.
3.
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.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What corrective actions were taken concerning the undercompensated detectors?
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Abstract 1.
50.73(b)(1)--Summary of system, plant, component, and 4
personnel responses is inadequate. The major equipment responses to the trip, the undercompensation, the cooldown, and the personnel actions after the trip should have been mentioned in the abstract.
2.
50.73(b)(1) -Summary of corrective actions taken or planned as a result of the event is not included.
j 3.
Abstract does not adequately summarize the text. The abstract concentrated too much on the cause of the trip rather than summarizing the overall event.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
A better title might be, " Main Generator Exciters' Permanent Magnet Generator Fails Resulting in Turbine Trip and Reactor Scram".
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SPECIFIC LER COMMENTS FOR NORTH ANNA 2 (339)
_ _ Section Comments
- 15. LER Number:
(continued) 2.
Item (131--Component failure field contains data when no component failure occurred. The text does not indicate that either the intermediate range detector or the temperature indicator " failed".
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