ML20215L443

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Forwards AEOD Assessment of LERs for Oct 1985 - Mar 1987 as Part of SALP Program.Evaluation Indicated Significant Improvement in Quality of LERs Since Last Evaluation
ML20215L443
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 05/05/1987
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Reed C
COMMONWEALTH EDISON CO.
References
NUDOCS 8705120248
Download: ML20215L443 (51)
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3 MAY 0 51987 Docket No. 50-254 Docket No. 50-265 Commonwealth Edison Company l ATTN: Mr. Cordell Reed Vice President Post Office Box 767 y Chicago, IL 60690 Gentlemen:

The NRC's Office for Analysis and Evaluation of Operational Data (AE0D) has-

<recently completed an assessment of your Licensee Event Reports (LERs) from

- Quad Cities Units 1 and 2.for the period.of October 1,1985,' to March 31, 1987,.

as part of the NRC's' Systematic Assessment of Licensee Performance-(SALP).

Program.

.The results of this evaluation' indicated a significant. improvement in the..

quality of your.LERs since the last evaluation. You have.been rated an overall average LER score 'of 9.2 out of.a possible 10 points, compared to a'

. previous overall average LER score of 7.5 and a current industry average score-of 8.3.- 'A weakness identified during' the AE00 review involved the requirement-

-to identify-failed components in the text. Strong points identified included your discussions of the failure mode, mechanism, and effect of failed components and.the personnel errors / procedural deficiencies.-

This relativel.3 high score, which placed Quad Cities in the top 10% of those assessed, deiranstrates an apparent commitment on your part to provide the NRC with LERs which consistently meet the. requirements contained in 10 CFR 50.73..

Nonetheless, you should also take into account a recent inspection (254/87009; 255/87009) by inspectors from Region III's Quality Assurance Programs Section which (based on a limited sample) reached a different conclusion than the'AE0D assessment. This inspection resulted in two violations related to a lack of a.

documented procedure for LER processing and failure to determine the cause and-take corrective action to preclude repetition of the events. We would expect both of these reports would be used in your determination of areas where your LER. system might be improved.

We are providing you a copy of AE0D's assessment prior to the issuance of the SALP 6 Board Report so that you are aware of its findings.

gol 8705120248 870505 l PDR ADOCK 05000254 G PDR

y-- u Commonwealth Edison Company '

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

_ questions.

Sincerely, Charles E. Norelius, Director Division of Reactor Projects

Enclosure:

AEOD Assessment cc w/ enclosure:

D.' L. Farrar, Director of Nuclear Licensing R. L. Bax, Plant Manager Mark Kooi, Regulatory Assurance Supervisor.

DCS/RSB (RIDS)

Licensing. Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division cc w/o enclosure:

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LICENSEE EVENT REPORT (LER)

QUALITY EVALUATION FOR QUAD CITIES 1,2 -

DURING THE PERIOD FROM OCTO8ER 1, 1985 TO MARCH 31, 1987 R

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Quad Cities 1.2 during the period from October 1, 1985 to March 31, 1987 was performed using a refinement of the basic methodology presented in NURE6-1022, Supplement No. 2. This is the second time that the Quad Cities LERs have been evaluated using this methodology. The results of this evaluation indicate that Quad Cities LERs have improved significantly and now have an overall average LER score of 9.2 out of a possible 10 points, compared to a

previous overall average LER score of 7.5 and a current industry average score of 8.3. The industry overall average is the result of averaging the latest overall average LER score for those unit / stations that have been evaluated to date using this methodology.

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

Strong points for the Quad Cities LERs are the discussions of the failure mode, mechanism, and effect of failed components [ Requirement -

50.73(b)(2)(11)(E)] and the personnel errors / procedural deficiencies

[ Requirement 50.73(b)(2)(11)(J)(2)].

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LER 00ALITY EVALUATION FOR 00A0 CITIES 1.2 INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Quad Cities 1,2 during the period from October 1,1985 to March 31, 1987, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG-1022. Supplement No. 2. The sample consists of a total of 15 LERs (ten LERs from Unit 1 and five LERs from Unit 2), which is considered to be the maximum number of LERs necessary to have a representative sample. The Quad Cities LERs were evaluated as one sample because it has been determined that their LERs are both written and formally reviewed at the station, rather than the unit, level. See Appendix A for a list of the LER numbers in the sample.

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

METH000 LOGY -

The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the criteria of 10 CFR 50.73(b). In addition, each selected LER is compared to the guidance for preparation of LERs presented in NUREG-1022 3

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

The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was 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 for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded

fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score - overall LER score).

The results of the LER quality evaluation are divided into two categories: (1) detailed information and (2) summary information. The i

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

  • text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to Appendix D, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analysts 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) .

l 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 2

1.

rspresent 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. Again. Quad Cities LERs were evaluated as one sample, rather than two separate samples (by unit) because it was determined that the Quad Cities LERs are both written and formally reviewed at the station, ather than the unit, level.

Table 1 presents the average scores for the sample of LERs evaluated for Quad Cities. In order to place the scores provided in Table 1 in perspective, the distribution of the latest overall average score for all unit / stations that have been evaluated using the current methodology is provided on Figure 1. Figure 1 is 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).

Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Quad Cities' average score for the text of the LERs that were evaluated is 9.1 out of a possible 10 points. From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different.

requirements ranging from the discussion of plant operating conditions before the event (10 CFR 50.73(b)(2)(11)(A)] to text presentation. The ,

percentage scores in the text sununary 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.

Soecific Deficiencies and Observations A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, 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 either: (1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address 3 i

' o TABLE 1.

SUMMARY

OF SCORES FOR QUAD CITIES 1,2 Average High Low Text 9.1 9.9 8.0 Abstract 9.5 10.0 7.7 Coded Fields 9.0 9.7 8.1 Overall 9.2 9.8 8.0

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

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', TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR QUAD CITIES 1,2 TEXT Percentage a

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

(2)(ii)(A) - - Plant condition prior to event 97 (15)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate time (s) 92 (15)

(2)(ii)(D) -- - Root cause and intermediate cause(s) 89 (15)

(2)(ii)(E) - - Mode, mechanism, and effect 100 (10)

(2)(ii)(F) - - EIIS codes 47 (15)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 100 ( 5)

(2)($1)(I) - - Method of discovery 100 (15)

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

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 100 ( 6)

(2)(ii)(K) - - Safety system responses 96 ( 8)

(2)(ii)(L) - - Manufacturer and model no. information 65 (10)

(3) - - - - - - Assessment of safety consequences 93 (15)

(4) - - - - - - Corrective actions 95 (15)

(5) - - - - - - Previous similar event information 93 (15)

(2)(i) - - - - Text presentation 90 (15)

ABSTRACT Percentage a

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

- Major occurrences (immediate cause/effect) 99 (15)

- Plant / system / component / personnel responses 99 ( 7)

- Root cause information 95 (15)

- Corrective action information 90 (15)

- Abstract presentation 92 (15) 6 i

.- TABLE 2. (continusd)

CODED FIELDS Percentage a

Item Number (s) - Descriptions Scores ( )

1, 2, and 3 - Plant name(unit #), docket #, page #s 100 (15).

4------- Title 73 (15) 5, 6, and 7 - Event date, LER no., report date 96 (15) 8------ Other facilities involved 100 (15)

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Operating mode and power level 95 (15) 89 (15) 11 -----

Reporting requirements 12 -----

Licensee contact information 100 (15) 13 -----

Coded component failure information 92 (15) l 14 cnd 15 - - Supplemental report information 97 (15)

a. Percentage scores are the result of dividing the total points for a t 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 p2ranthesis is the number of LERs for which the requirement was considered cyplicable,

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

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

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the requirement in one or two of the selected LERs. Those responsible for preparing LERs should review the LER specific comments presented in Appendix 0 in order to determine why the station 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) was not provided in the text of four of the ten LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail must be identified in the text so that others in the industry can be made aware of potential problems. An event at one unit / station can of ten 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 component does not actually fail.

Energy Industry Identification System (EIIS) component function identif ter codes were not provided in the text of any of the 15 LERs.

Requirement 50.73(b)(2)(11)(F), although system name codes were generally -

provide.

The text presentations, wMle acceptable, could be improved by making some minor changes. One suggestion wovid'be to have all those who prepare LERs use the same outline format (e.g., the format used for LER 86-002-01) with two changes. First, under " IDENTIFICATION 0F OCCURRENCE", there could be an Event Date as well as a 01scovery and Report Date, as the discovery and event dates are not always the same. Second, the heading " FAILURE DATA' could be changed to " PREVIOUS SIMILAR EVENT DATA" as it appears that this is the caly information being provided under this heading. The heading " FAILURE DATA" could be interpreted to be the heading under which failed component manufacturer and model number should appear.

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Finally, undefined acrcnyms sh:uld be avoided in the text. Seven of the 15 LERs contained undefined acronyms.

Abstract Deficiencies and Observatiqnt Quad Cities abstracts are generally very good; however, the corrective action information was considered inadequate or was not included in four of the fifteen LERs. This problem can be avoided if the corrective actions l that are discussed in the text are mentioned in the abstract.  ;

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Coded Field Deficiencies and Observations i

l The main deficiency in the area of coded fields involves the title.

l Item (4). Eight of the titles failed to provide adequate cause Information, two failed to adequately indicate the result (i.e., why the event was required to be reported), and five 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 Appendix 0 (Coded Fields Section) for most of the titles that are considered to be deficient.

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A number of other minor deficiencies appear in the Coded Fields, most .

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of which probably could have been avoided had the final review of page one j of each report been more thorough. In defense of the reviewer however, the form that the station uses for most of the LERs in the sample is somewhat hard to read because the information being typed on the form is the same size and style as that of the form itself. One suggestion would be to use a larger (and possibly a different) font for the information being provided on the form.

SUMMARY

Table 3 provides a summary of the areas that need improvement for the Quad Cities LERs. For additional and more specific information g

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l concerning deficiencies, the reader should refer to the information presented in Appendices C and D. General guidance concerning requirements can be found in NURE6-1022, and NURE6-1022 Supplements No. I and 2.

, It should be noted that this is the second time that the Quad Cities l LERs have been evaluated using the same methodology. The previous evaluation was reported in October of 1985. Table 4 provides a comparison of the scores for the two evaluations. As can be seen, the Quad Cities i

LERs have improved significantly since the original evaluation and are presently well above the current industry overall average of 8.3. (Note:

! The industry overall average is the result of averaging the latest overall average score for each unit / station that has been evaluated using this i

methodology).

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR QUAD CITIES 1,2 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.

EIIS information An EIIS code should be provided for each component, as well as system, referred to in the text.

Text presentation Use of a consistent outline is suggested.

All acronyms and plant specific designations should be defined on first usage in the text.

Abstract presentation Corrective action information from the text should be mentioned in the abstract.

Coded fields

a. Titles Titles should include cause information, result, and the link between them, when necessary. See NUREG-1022, Supplement No. 2, pages 29 and 30.

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TABLE 4. COMPARISON OF LER SCORES FROM PREVIOUS EVALUATION

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Report Date October-85 Apr11-87 Text average 7.9 9.1 Abstract average 6.5 9.5 Coded fields average 8.4 9.0 Overall average 7.5 9.2 l

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REFERENCES

1. Office for Analysis and Evaluation of Operational Data, licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Commission, September 1985.
2. Office for Analysis and Evaluation of Operational Data, Licensee Eve _nt Report System, NURE6-1022, U.S. Nuclear Regulatory Connission, September 1983.
3. Office for Analysis and Evaluation of Operational Data, Licensee Event Reoort System, NUREG-1022 Supplement No.1. U.S. Nuclear Regulatory Commission, February 1984.

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< APPENDJX A y t LER SAMPLE SELECTION '

INFORMATION , ,

4 FOR QUAD CITIES 1,2 . s'  !

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TABLE A-1. LER SAMPLE SELECTION FOR QUA0 CITIES 1,2 Sample Number Unit Number LER Number Comments 1 1 85-019-00 2 1 86-002-01 3 1 86-008-00 ESF 4 1 86-015-00 SCRAM 5 1 86-017-00 SCRAM 6 1 86-023-00 7 1 86-026-00 SCRAM 8 1 86-031-00 ESF 9 1 86-034-00 10 1 86-037-00 11 2 85-021-00 SCRAM 12 2 86-002-00 13 2 86-008-01 l

14 2 86-011-00

! 15 2 86-017-00 .

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APPENDIX 8 EVALUATION SCORES OF IN0lV10UAL LERS FOR QUA0 CITIES 1,2 l

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-TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR QUAD CITIES 1,2 a

LER Sample Number 1 2 3 4 5 8 7 8 Tsxt 8.8 8.9 9.3 9.2 9.7 9.3 8.9 9.6 Abatract 8.9 9.9 10.0 10.0 9.9 9.7 9.9 9.9 Ceded Fields 8.1 8.5 9.7 8.9 9.0 9.0 9.5 9.3 Ovarall 8.7 9.2 9.6 9.4 9.7 9.4 9.3 9.7 a

LER Sample Number 9 10 11 12 13 14 15 Average Text 8.9 9.6 8.0 8.0 9.2 9.9 9.3 9.1

~ Abstract 8.6 9.8 8.1 7.7 9.4 9.9 10.0 9.5 Coded Fields 9.5 9.3 8.7 8.4 8.7 9.0 9.0 9.0 Ovarall 8.9 9.6 8.1 8.0 9.2 9.8 9.5 9.2

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

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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR QUAD CITIES 1.2 l

TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR QUAD CITIES 1,2 Number of LfRs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals

  • Totals ( )

50.73(b)(2)(11)(Al--Plant operating 2 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(11)(B)--Discussion of the status 0 ( 2) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.

50.73(b)(2)(11)(C)--Fa11ure to include 3 (15) suf ficient date and/or time information,

a. Date information was insufficient. 2

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b. Time information was insufficient. 3 50.73(b)(2)(ii)(D)--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 4 included or was inadequate, ~
b. Cause of system failure was not 2 included or was inadequate.

50.73(b)(2)(11)(E)--The failure mode, 0 (10) 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 tricluded or was inadequate.

C-1

. TA8LE C-1. (centinued)

Number of LERs with Deficiencies and Observations l

Sub-paragraph Paragraph l

Description of Deficiencies and Observations Totals

  • Totals ( )

50.73fb?(21L11)(F1--The Energy Industry 15 (15)

Ident1f' cathon System component function

identifier for each component or system was i not included.

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l. 50.73(b)(2)(ii)(6L--For a failure of a -- ( 0) l component with mu' tiple functions, a list l of systems or secondary functions which l

were also affected was not included or was inadequate.

50.73(b)(2)(11)(H)--For a failure that 0 ( 5) rendered a train of a safety system

inoperable, the estimate of elapsed time from the time of the failure until the l train was returned to service was not j 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 procedural error was not included or was inadequate.

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TA8LE C-1. (continrsd) ,,

Number of LERs with Deficiencies and Observations <

Sub-paragraph Paragraph Descriotion of Deficiencies and Observations Totals' Totals ( )

50.73(b)(2)(ii)(J)(11--Operator actions that 0 ( 1) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(b)(2)(ii)(J)(21--The discussion of 0 ( 6) each personnel error was not included or was inadequate,

a. 08SERVATION: A personnel and/or procedural error was implied by the text, but was not explicitly stated.
b. 50.73(b)(2)(ii)(J)(2)(il--Discussion as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c. 50.73(b)(2)(11)(J)(2)(iil--Discussion as to whether the personnel error was contrary to an approved procedure, was i & direct result of an error in an approved procedure, or was associated l

with an activity or task that was not I

covered by an approved procedure was ,

I not included or was inadequate.

d. 50.73(b)(2)(11)(J)(2)ft111--Discussion of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate,
e. 50.73(b)(2)(11)(J)(2)(ivi--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility non11 censed operator, other utility personnel) was not included or was inadequate.

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. TA8LE C-1. (contin :d)

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

50.73(b)(2)(11)(K)--Automatic and/or manual 1 ( 8) safety system responses were not included or were inadequate.

50.73(b)(2)(11)(L)--The manufacturer and/or 4 (10) ,

model number of each failed component was not included or was inadequate.

50.73(b)(31--An assessment of the safety 3 (15) consequences and implications of the event was not included or was inadequate.

a. 08SERVATION: The availability of I
other systems or components capable of mitigating the consequencer 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 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)(41--A discussion of any corrective 4 (15) actions planned as a result of the event

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including those to reduce the probability of sin 11ar events occurring in the future was not included or was inadequate.

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TABLE C-1. (continuod) ,

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

a. A discussion of actions required to O correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate. o
b. A discussion of actions required to 2 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c. OBSERVATION: A discussion of actions 0 ,

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

r correct the faulty part in all components with the same manufacture- }

and model number) was not included or was inadequate.

50.73(b)(51--Information concerning previous 1 (15) similar events was not included or was inadequate.

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TA8tE C-1. (continued)

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

50.73(b)(2)(11--Text presentation 9 (15) inadequacies.

a. 08SERVATION: A diagram would have 0 aided in understanding the text discussion.
b. Text contained undefined acronyms 7 and/or plant specific designators.
c. The text contains other specific 2 deficiencies relating to the readability,
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph tetrie oo not necessarily add up to the paragraph total.
b. Tne " 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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C-6

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

TABLE C-2. A8STRACT DEFICIENCIES AND OBSERVATIONS FOR QUAD CITIES 102 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

A summary of occurrences (immediate cause 1 (15) and effect) was not included or was inadequate.

A summary of plant, system, and/or personnel 1 ( 7) responses was not included or was i 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 included or was inadequate.

A summary of the root cause of the event 2 (15) was not included or was inadequate.

A summary of the corrective actions taken or 4 (15) planned as a result of the event was not included or was inadequate.

C-7

. TA8LE C-2. (centinued)

Number of LERs with Deficiencies and

_, Observations Sub-paragraph Paragraph Descriotion of Deficiencies and Observations Totals" Totals ( )

Abstract presentation inadequacies. 2 (15)

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

l 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 1 deficleccles (i.e., poor summartration, contradictions, etc.).

a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
b. The " paragraph total" is the number of LERs that have one or more
deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

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I C-8 t

TA8tE C-3. CODEC FIELDS DEFICIENCIES AND 08SERVATIONS FOR QUAD CITIES 1,2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Descriotion 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 incorrtet. -i
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 lef t blank or was inadequate. 13 (15)

a. Root cause was not given or was 8 inadequate,
b. Result (effect) was not given or was 2 inadequate.
c. Link was not given or was 5 inadequate.

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. 1 (15)

Report Date 1 (15)

a. Date not included or was incorrect. O
b. 08SERVATION: Report date was not 1 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

. TA8tf C-3. (continr:d) s.

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

Power level was not included or was 2 (15) inconsistent with text or abstract.

Reporting Requirements 1 (15)

a. The reason for checking the 'OTHER" 0 requirement was not specified in the abstract and/or text.
b. 08SERVATION: It may have been more 0 appropriate to report the event under a different paragraph.
c. CBSERVATION: It may have been 0 appropriate to report this event under an additional unchecked paragraph.
d. No requirement was checked. 1 Licensee Contact 0 (15)
a. Field left blank.

, b. Position title was not included,

c. Name was not included.

I d. Phone number was not included.

l Coded Component failure Information 4 (15) ,

a. One or more component failure 2 sub-fields were left blank.
b. Cause, system, and/or component code 1 is inconsistent with text,
c. Component failure field contains data. 2 when no component failure occurred.
d. Component failure occurred but entire O field left blank.

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C-10 l

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

. TABLE C-3. (contined)

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

  • Totals ( )

Supplemental Report 0 (15)

a. Neither "Yes"/"No" block of the supplemental report field was checked.
b. The block checked was inconsistent o 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 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.

p C-11

6' APPENDIX D LER COMENT SHEETS FOR QUAD CITIES 1,2 l

l

'. TABLE D-1.

SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section Comments

1. LER Number: 85-019-00 Scores: Text - 8.8 Abstract - 8.9 Coded Fields - 8.1 Overall - 8.7 Text 1. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the failed components is inadequate. The source of the wood in the RHR pump impe11ers and why the breaker contacts were dirty is not discussed.
2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component .

referred to in the text were not included.

3. 50.73(b)(4)--Without a more detailed root cause discussion (see text comment 1) it is not clear if the corrective actions taken are adequate to prevent recurrence. What will prevent additional wood from entering the pump and the contacts from becoming dirty again?
4. Acronym (s) and/or plant specific designator (s) are undefined. GSEP was not defined.

Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: The root cause is inadequate. A more appropriate title might be " Shutdown (Required by Technical Specifications) Because Diesel Generator (Dirty Breaker Contents) and Residual Heat Removal System (Wood in Pump Impeller) Were Inoperable". The use of acronyms in the title should be avoided unless space is a problem.

2. Item (10)--The power level in this field differs from the information in the text or abstract. The text and abstract indicate that the initial power was 84 percent.

D-1

I. ,

TABLE 0-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section Comments

2. LER Number: 86-002-01 Scores: Text - 8.9 Abstract - 9.9 Coded Fields - 8.5 Overall - 9.2 Text 1. 50.73(b)(2)(11)(C)--Date/ time of the return to service of the MSIV's is not included.
2. 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.
3. 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.

Abstract No comments.

Coded Fields 1. Item (4)--Title: Root cause (normal operational -

wear) and link (during testing) are not included. A better title might be " Main Steam Isolation Valves Found During Testing to Have Excess Leak Rate Caused by Dirt and Pitting on Valve Internals From Normal Operation--Technical Specification Violation".

2. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).

0-2

. TA8tE D-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

,- Section Comments i

3. LER Number: 86-008-00 Scores: Text - 9.3 Abstract - 10.0 Coded Fields - 9.7 Overall - 9.6 Text 1. 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.

Component function identifier codes are not provided.

2. 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is a inadequate. Stating that the consequences were minimal implies there were consequences, but they are not provided. Was the fact that the D/G ran in an unloaded condition considered a consequence? If so, how long did it run in this condition and was the D/6 thoroughly checked out af ter the occurrence?
3. It appears that " Discovery Date" is always used under the heading " IDENTIFICATION OF OCCURRENCE *; for some events both a discovery and an event date are ~

appropriate.

Abstract No comments.

Coded Fields 1. Item (4)--Title: Link and cause are inadequate. The fact that the cause was " personnel error while blocking a relay" would add to the title.

D-3

~

TABLE D-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section Comments

4. LER Number: 86-015-00 Scores: Text - 9.2 Abstract - 10.0 Coded Fields - 8.9 Overall - 9.4 Text 1. 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component referred to in the *. ext were 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. )
3. Acronym (s) and/or plant specific designator (s) are undefined. MG was not defined on first usage.

Abstract 1. No comment.

=

Coded Fields 1. Item (4)--The use of acronyms in the title should be avoided unless space is a problem.

2. Item (111--None of the boxes were checked.

D-4 l

TA8LE 0-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 1 (254)

Section Comments

5. LER Number: 86-017-00 Scores: Text - 9.7 Abstract - 9.9 Coded Fields - 9.0 Overall - 9.7 Text 1. 50.73(b)(2)(11)(F1--Ine Energy Industry Identification System code for each component and/or system referred to in the text is not included. The component function identifiers are not included.

Abstract No comments.

Coded Fields 1. Item (41--Title: Result (anticipated transient without scram trip) is not included. A better title might be: " Anticipated Transient Without Scram Trip Results From Isolation of Instrument Root Valves Due to Cognitive Personnel Error While Performing Valve Checklist."

2. Itea (111--08SERVATION: It appears a typographical error occurred in checking paragraph 50.73(a)(2)(1) instead of paragraph 50.73(a)(2)(11) as cited in the text and abstract.

l O-5

TABLE D-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section ,__ Comments

6. LER Number: 86-023-00 Scores: Text - 9.3 Abstract = 9.7 Coded Fields - 9.0 Overall = 9.4 Text 1. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning why the mechanical linkage was out of adjustment is not included. Was this condition caused by wear or did it result due to personnel error during a previous linkage adjustment?
2. 50.73(b?(2)(11)(F1--The Energy Industry Identif$ cation System code for each component and/or system referred to in the text is not included.

Component function identifier codes are not included.

3. 50.73(b)(2)(11)(H)--The RCIC system may have been inoperable for sometime prior to May 5; the reader is left to assume that the system tested satisfactorily S during the previous operability test.
4. Acronym (s) and/or plant specific designator (s) are undefined. ENS should be defined on first usage.
5. The attached drawing is good; the LER number could be included on the diagram in case it became separated from the LER.

Abstract 1. 50.73(b)(11--Summary of cause information is inadequate. See text comment number 1. .

Coded Fields 1. Item (41--Title: Cause information is not provided and 11nk is inadequate. A better title might be "During Testing, The Linkage Cn RCIC Turbine Overspeed Trip Mechanism Was Discovered Out of Adjustment--System Declared Inoperable".

D-6

-_--_-----------_-------j

. TABLE 0-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 1 (254)

Section Comments

7. LER Number: 86-026-00 Scores: Text - 8.9 Abstract - 9.9 Coded Fields - 9.5 Overall 9.3 Text 1. 50.73(b)(2)(11)(C)--Additional dates / times (e.g.,

date and/or time that corrective actions were performed) would be helpful.

2. 50.73(b)(2)f11)(D)--The root cause of the cable butt splice problem was not discussed.
3. 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component referred to in the text were not included.

, 4. 50.73(b)(2)(11)(L)--Identification (e.g.,

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

1

5. Acronym (s) and/or plant specific designator (s) are undefined. APRM and RBM were not defined and MSIV was not defined on its first usage.

1 Abstract No comment.

Coded Fields 1. Item (4)--The use of acronyms should be avoided in a title unless space is a problem. The title for this 4

LER is a good example. The title is actually good but very few people will know the meaning of "QOS-250-l'. For this title, it would be more ,

informative to replace the number with text such as "A Monthly Valve Closure Test".

I

2. Item (131--One or more component failure sub-fields

! are blank. A complete line for the relay should be l filled in.

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0-7 i

~

i . .

TABLE D-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254) i Section Comments

8. LER Number: 86-031-00 Scores: Text - 9.6 Abstract - 9.9 Coded Fields - 1.1 Overall - 9.7 Text 1. 50.73(b)(2)(11)(F1--The Energy Industry i

Identification System code for each component and/or i system referred to in the text is not included. The component function identifiers are not included.

2. Some ideas are not presented clearly (hard to follow). The use of "XX' for reactor power and "XXX"
for unit load in the conditions prior to occurrence
15 confusing.

Abstract No comments.

Coded Fields 1. Item (41--Title: Link (during attempt to disable autostart for switchyard maintenance) is not included.

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D-8

. TABLE 0-1.

SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section Comments

9. LER Number: 86-034-00 Scores: Text - 8.9 Abstract - 8.6 Coded Fields - 9.5 overall - 8.9 Text 1. It appears from the text discussion (although not explicitly stated) that all active components of the automatic pressure relief [S8] subsystems were not proven operable. Given that this is true, was this known prior to or af ter the discovery of the packing leak?
2. 50.73(b)(2)(11)(Al--Under " CONDITIONS PRIOR TO OCCURRENCE", the fact that a shutdown was in progress should have been stated.

I

3. 50.73(b)(2)(11)(D)--What was the problem with the automatic pressure relief subsystem (or what caused the unit to have to be shutdown due to HPCI inoperability)? When was the packing last changed in this valve? '

[ 4. 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.

Component function identifier codes are not provided.

5. 50.73(b)(4)--What was done to repair the automatic pressure relief subsystem?
6. Some ideas are not presented clearly (hard to follow; e.g., second paragraph of ' ANALYSIS OF OCCURRENCE").

Abstract 1. 50.73(b)(11--Tnere is no mention of the shutdown that was in progress or the problem with the automatic pressure relief subsystems.

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

i l Coded Fields 1. Item (41--Title: Root cause (normal wear) is not included.

l D-9 l

TA8tf 0-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 1 (254)

Section Comments

10. LER Number: 86-037-00 Scores: Text = 9.6 Abstract = 9.8 Coded Fields - 9.3 Overall - 9.6 Text 1. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component referred to in the text were not included. '
2. Acronym (s) and/or plant specific designator (s) are undefined. APRM and RBM were not defined on first usage.

Abstract 1. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The continuing inspections were not mentioned.

Coded Fields 1. Item (6)--The revision number on page one appears to be a typographical error.

D-10 l_.__ _ _ _ . _ - - . , _ ._ _ .-._ ...-._ . _ ._ _ _

L', . i TABLE 0-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 2 (265)

Section Comments

11. LER Number: 85-021-00 Scores: Text = 8.0 Abstract - 8.1 Coded Fields - 8.7 Overall = 8.1 Text 1. 50.73(b)(2)(11)(C)--Approximate time that the plant was returned to a safe and stable condition is not included.
2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the instrument isolation valve leakage is not included.
3. 50.73(b)l2)(11)(F1--The Energy Industry i

Identification System code for each component and/or system referred to in the text is not included. The component function identifiers and the ESF system codes are not included.

4. 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 2

(i.e., the leaking isolation valve).

5. 50.73(b)(4)--01scussion 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 inadequate for the leaking isolation valve.

Abstract 1. 50.73(b)(11--Summary of system responses to the scram is inadequate. Did any safety system actuate as a result of the scram?

2. 50.73tb)(1)--Summary of root cause of the leaking isolation valve is inadequate. See text comment number 2.
3. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.

Replacement or repair of the isolation valve and the upgrading of the diaphram-type instruments with l analog devices are not mentioned.

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l D-11 '

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, TABLE D-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 2 (265)

Section Comments

11. LER Number: 85-021-00 (Continued)

Coded Fields 1. Item (4)--Title: Cause information (leaking valve and personnel error) are not included. A better title migtt be " Cognizant Personnel Error While Attempting to Correct Leaking Instrument Valve During Testing Results in Containment Isolation and Scram From Low Water Level Indication".

2. Item (13)--The component identifier and manufacturer sub-fields for the isolation valve failure are blank.
3. Item (13)--Cause, system, and/or component code appears inconsistent with information provided in the text. The cause code "A" is not appropriate for the failed (leaking) valve.

D-12

l I

. TABLE 0-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 2 (265)

Section Comments

12. LER Number: 86-002-00 Scores: Text - 8.0 Abstract - 7.7 Coded Fields - 8.4 Overall - 8.0 Text 1. 50.73(b)(2)(11)( Al--Information concerning the plant operating conditions before the event is inadequate.

Power level is not provided.

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning why the chemists were not able to obtain the sample on the first or second attempt is not included.
3. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included. The code for " TRAP' was not provided.
4. 50.73(b)(3)--01scussion of the assessment of the safety consequences and implications of the event is inadequate. It is not apparent how the numbers in Table 1 can be compared unless the power level history of each unit is also provided.

While not knowing precisely why the sample is required, the reader assumes it to be a measure of reactor coolant system leakage; a condition that could change at any moment. Therefore, it is not apparent why it was considered conservative to use the value from Unit 1.

  • Abstract 1. 50.73(b)(11--See text comment number 2.

I

' 2. 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The actions taken by the Department head were not mentioned. The refrigerated condensation trap should have been specifically mentioned (i.e., rather than say " additional equipment").

Coded fields 1. Item (41--Title: Result (Technical Specification violation) is not included.

0-13

- .- l TA8tf 0-1. SPECIflC LER COMMENTS FOR QUA0 CITIES 1 (265)

Section Comments

12. LER Number: 86-002-00 (Continued)
2. Ltem (5)--Discovery date is given instead of event date.
3. Item (13)--Component failure field contains data when no component failure occurred.

9 i

0-14

a I .

TA8tE 0-1. SPECIFIC LER COMMENTS FOR QUAD CITIES 2 (265)

Section Comments

13. LER Number: 86-008-01 Scores: Text - 9.2 Abstract - 9.4 Coded Fields - 8.7 Overall - 9.2 Text 1. 102 73(b)(2)(11)(Al--The operating conditions were not given in the Conditions Prior to Occurrence section.
2. 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component referred to in the text were not included.
3. 50.73(b)(21--Are the systems listed under the Analysis of Occurrence section sufficient to handle any accident condition without the core spray? If not, what are the safety implications of not having the core spray?
4. 50.73(b)(41--A supplemental report would be appropriate to describe the results of the computer calculations if these results would change the reader's perception of the event or require additional corrective actions.
5. Acronym (s) and/or plant specific designator (s) are undefined. SSEP and CECO were not defined on first usage.

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

computer analysis of operability of the safety systems without room cooling was not mentioned.

Coded Fields 1. Item (71--The report date for Revision "1" should be July 31, 1986, not the report date for Revision '0".

2. Item (13)--The breaker did not fall and therefore should not be reported in this field.
3. Jtem (141--The block checked appears to be unconsistent with information provided in the text; see text comment number 4.

0-15

,4 )

  • ik .

TA8LE D-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 2 (265)

Section Comments

14. LER Number: 86-011-00 Scores: Text 9.9 Abstract - 9.9 Coded Fields - 9.0 Overall - 9.8 Text- 1. 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. The component function identifiers are not included.

i 2. OBSERVATION: The text is very well written in an easy-to-read outlined format.

i Abstract No comments.

Coded Fields 1. Item (41--Title: Cause information (broken tack weld in throttle valve internals) is not included.

Acronyms should be used in the title only when space

] is limited.

2. ' tem (10)--It appears there is a typographical error for the power level field.

9 9

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D-16 i

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5 a

TA8tE 0-1. SPECIFIC LER COMMENTS FOR QUA0 CITIES 2 (265)
Section Comments
15. LER Number: 86-017-00 Scores: Text = 9.3 Abstract = 10.0 Coded fields - 9.0 Overall = 9.5 Text 1. 50.73(b)(2)(11)(D)--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)(F1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included. A system code was provided in the abstract, however codes are required in the text for both system.and component function identifiers.
3. 50.73(b)(2)(11)(L )--Identification (e.g.,

)

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

Pipe and weld material information would be

, appropriate.

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

5. 50.73(b)(4)--08SERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary
l. Information.
6. The crack is categorized as a "11near indication", a-
  • pinhole leak", and a " smell crack" in this report.

Abstract 1. The abstract score is based on the assumption that the supplemental report will contain the necessary information in a revised abstract.

1 Coded fields 1. Item (41--Title: Postulated cause is not included.

A better title might be "Small Through-Wall Crack 01scovered During Inservice Inspection of Reactor Recirculation Piping--Suspect Intergranular Stress Corrosion Cracking".

i 0-17 i

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