ML20215M611
| ML20215M611 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/23/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8611030064 | |
| Download: ML20215M611 (56) | |
Text
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r In Reply Refer To: _
Docket: 50-298/86-08 Nebraska Public Power District ATTN:
J. M. Pilant, Manager, Technical Staff - Nuclear Power Group P. O. Box 499 Columbus, Nebraska 68601 Gentlemen:
This forwards an analysis of your LERs for the SALP period which ended July 31, 1986.
It is forwarded for your information and to provide you with
, data which you may wish to use for training or improvement in your event reporting process.
No response to this letter is requested.
Sincerely, Driginal Signed By
- 3. E. Gagliardo J. E. Gagliardo, Chief Reactor Projects Branch
Enclosure:
as stated cc w/ enclosure:
Guy Horn, Division Manager of Nuclear Operations Cooper Nuclear Station P. O. Box 98 Brownville, Nebraska 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bec distrib. by RIV:
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Even Reports (LERs) submitted by Cooper,during the February 1, 1985 to July 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 Cooper has an overall average LER score of 7.7 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 LERs, in terms of safety significance, involve the requirements to provide an adequate safety assessment and the identification of failed components.
Deficiencies in the safety consequence discussion prompts concern as to whether or not events are being evaluated such that the possible consequences of the event, had it occurred under a different set of initial conditions, are identified.
The failure to adequately identify the manufacturer and model number of the components that fail prompts concern that others in the industry will not have immediate access to information involving possible generic problems.
A strong point for the Cooper LERs is that information concerning the mode, mechanism, and effect of failed components is discussed very well.
i s-AE00 INPUT TO SALP REVIEW FOR COOPER 1
Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Cooper during the February 1, 1985 to July 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the licensee's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178.
The sample consists of 15 LERs, which is half of the LERs that were on file at the time the evaluation was started.
See Appendix A for a list of the LER numbers in the sample.
It was necessary to start the evaluation before the end of the SALP assessment period because the input was'due such a short time after the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for review.
I Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the requirements of 10 CFR 50.73(b), NUREG-1022, and Supplements 1 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 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 of each LER.
The LEP specific comments serve two purposes:
(1) tSey 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.
l
L 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 the overall score determined 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 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 detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER (Appendix B), tables of the number of deficiencies and observations for the text, abstract and coded fields (Appendix C), and comment sheets containing 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 analyst has flexibility to consider the magnitude of a deficiency when assigning scores.
Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of each units performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b).
Table 1 presents the average scores for the sample of LERs evaluated for Cooper. 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.
In order to place the scores provided in Table 1 in perspective, the distribution of the overall score for all licensees that have been evaluated using the current methodology is provided in Figure 1.
Additional scores are added to Figure 1 each month as other licensees are evaluated. 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, Cooper's average score for the text of the LERs that were evaluated was 7.6 out of a possible 10 points.
From Table 2 it can be seen that the text score actually resulted from the review and evaluation of 17 different requirements ranging from the discussio; 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 licensee for the 15 LERs that were evaluated.
Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the licensee is experiencing the most difficulty in preparing LERs.
For example, requirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these requirements.
Scores of 75 or above, but less than 100, indicate that the licensee probably understands the basic requirement but has either:
(1) excluded certain less significant information from a large number of the discussions concerning that requirement or (2) totally failed to address a requirement in one or two of the selected LERs. The licensee should review the LER specific comments presented in Appendix 0 in order to determine why he 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 COOPER Average Hiah low Text 7.6 8.8 6.3 Abstract 7.7 9.8 5.5 Coded Fields 8.7 9.5 7.8 Overall 7.7 9.0 6.3 a.
See Appendix B for a summary of scores for each LER that was evaluated.
Figure 1. Distribution of overall average LER scores 15 14 -
13 -
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h 11 -
Cooper 9-g 8-
_9 7-E 6-g 5-4-
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0 9.5
' 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average scores
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TABLE 2.
LER REQUIREMENT PERCENTAGE SCORES FOR COOPER TEXf Percentage Reauirements ISO.73(b)1 - Descriptions
_ Scores (_l'_,
(2)(ii)(A) - - Plant condition prior to event 87 (15)
(2)(ii)(B) - - Inoperable equipment that contributed b
(2)(ii)(C) - - Date(s) and approxinate times 83 (15)
(2)(ii)(D) - - Root cause and intermediate cause(s) 94 (15)
(2)(ii)(E) - - Mode, mechanism, and effect 100 (6)
(2)(ii)(F) - - EIIS Codes 13 (15)
(2)(ii)(G) - - Secondary function affected b
(2)(11)(H) - - Estimate of unavailability 88 (4)
(2)(1))(1) - - Method of discovery 90 (15)
(2)(11)(J)(1) - Operator actions affecting course 78 (6)
(2)(ii)(J)(2) - Personnel error (procedural deficiency) 85 (9)
(2)(ii)(K) - - Safety system responses 89 (6)
(2)(11)(L) - - Manufacturer and model no. Information 68 (7)
(3) ----- Assessment of safety consequences 49 (15)
Corrective actions 84 (15)
(4)
(5) ----- Previous similar event information 30 (15)
(2)(i) - - - - Text presentation 75 (15)
ABSTRACT Percentage Requirements f50.73(b)(111 - Descriptions Scores ( )#
- Major occurrences (Immediate cause and effect 97 (15) information)
- Description of plant, system, component, and/or 92 (10) personnel responses
- Root cause information 77 (15)
- Corrective Action information 52 (15)
- Abstract presentation 72 (15)
o TABLE 2.
(continued)
CODED FIELOS Percentage Item Number (s) - Description Scores ( )'
1, 2, and 3 - facility name (unit no.), docket no. and 100 (15) page number (s) 4 - - - - - - Title 54 (15) 5, 6, and 7 - Event date, LER No., and report date 95 (15) 8 - - - - - - Other facilities involved 100 (15) 9 and 10 - - Operating mode and power level 98 (15) 11 - - - - - Reporting requirements 99 (15) 12 - - - - - Licensee contact information 100 (15) 13 - - - - - Coded component failure information 100 (15) 14 and 15 - - Supplemental report information 100 (15) a.
Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
(Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.
b.
A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER.
It is always given 100%
if it is provided and is always considered "not applicable" when it is not.
The safety assessments for eleven of the LERE were found to be deficient or not included, Requirement 50.73(b)(3). A detailed safety assessment is required in all LERs and should include information such as follows:
1.
An assessment of the consequences and implications of the event including specifics as to why it was concluded that there were no safety consequences, if applicable.
It is inadequate to state "this event had not safety consequences or implications" without explaining how that conclusion was reached.
2.
A safety assessment should discuss whether the event could have occurred under a different set of conditions where the safety implications would have been more severe.
If the conditions during the event are considered the worst probable, the LER should state so.
3.
Finally, a safety assessment should name other systems (if any) that were available to perform the function of the safety system that was unavailable during the event.
The corrective actions discussions were considered inadequate in nine LERs, Requirement 50.73(b)(4).
The most conanon deficiency concerning this requirement was that sufficient details were not always provided concerning actions taken to prevent recurrence of the event.
Sufficient time information was not included in five of the LERs, Requirement 50.73(b)(2)(ii)(C). Times should be provided for all major occurrences during the event so that readers of the LERs can visualize the time history of the sequence of occurrences.
The manufacturer and/or model number (or other unique identification) was not provided in the text of four of the seven LERs that involved a l
I component failure, Requirement 50.73(b)(2)(11)(L).
Components that fail should be identified in the text so that others in the industry can be made
v aware of potential problems.
Likewise, while not specifically required by the current regulations, components whose design contributes to an event should also be identified. 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 problem.
Nine of the fifteen LERs reviewed failed to mention previous similar events or state that there were none, Requirement 50.73(b)(5).
Previous similar events should be referenced appropriately (LER number if possible),
and if there are none, the text should so state.
Energy Industry Identification System (EIIS) component function identifier and/or system name codes were not provided in fourteen of the fifteen LERs reviewed, Requirement 50.73(b)(2)(ii)(F).
The text presentations received an overall score of 76%. This score can be improved upon by the use of a consistent text outline (see NUREG-1022, Supplement No. 2, Appendices C and D).
For example, it is recommended that every text include outline headings such as:
Event Description, Reportability, Cause, Safety Assessment, Corrective Actions, and Similar Occurrences.
If applicable, other headings such as: Background, Time Sequences, Plant and/or System Responses, System Descriptions or Generic Implications can be added.
Once a basic outline is adopted by all those responsible for writing LERs, the overall quality of the reports should improve, based simply on the fact that every LER will contain at least the minimum information concerning the major elements of each event.
The main deficiencies in the abstract areas were the summary of the root cause and corrective actions. While the root cause discussions were very good in the text (94%), seven of the abstracts failed to adequately summarize this information, resulting in a marginal score of 77%.
The summary of the corrective actions were considered inadequate in nine of the abstracts, while three others failed to provide any corrective action information.
J
o While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, summarize the following information from the text:
1.
Cause/Effect What happened that made the event reportable.
2.
Responses Major plant, system, and personnel responses as a result of the event.
3.
Root / Intermediate The underlying cause of the event. What Causes caused the component and/or system failure or the personnel error.
4.
Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence.
By adequately addressing these four areas in each abstract, the abstract presentation score of 72% should improve, as the abstract will be 1
a better summary of the event.
It was also noted that five of the fifteen LER abstracts contained information that was not included in the text. The abstract is intended to be a summary of the text. Any additional information that is discovered to pertain to the event while reviewing the abstract, should be added to the text.
The main deficiency in the area of coded fields involves the title, Item (4). Thirteen of the titles failed to indicate the root cause, five failed to include the link, and six failed to include the result (i.e., why i
l the event was required to be reported). While result is considered the most important part of the title, cause information (and link, if necessary) must be included to make a title complete. An example of a
s title that only addresses the result might be " Reactor Scram".,This is inadequate in that the cause and link are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title, the reader knows the cause was either personnel or procedural and surveillance testing was the link between the cause and the result.
Table 3 provides a summary of the areas that need improvement for the Cooper LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and D.
General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 1 and 2.
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TABLE 3.
AREAS MOST NEEDING IMPROVEMENT FOR COOPER 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 e
occurred under different but probable circumstances and provide information about backup systems which were available to limit the, consequences of the event.
Corrective actions Each LER should include sufficient detail to permit the reader to understand what corrective actions were taken or planned to prevent recurrence of the event.
Date/ time information Major occurrences discussed in the text should be accompanied by appropriate date and/or time infornation.
For example, times should be provided for occurrences such as scrams, actuations, isolations, discoveries, removal of systems from an operable status, completion of repairs, declaring a component operable, and placing the plant in a safe and stable condition.
Manufacturer and model number Component identification information information should be included in the text for each component failure or, although not specifically required by the current regulations, whenever a comoonent 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, as stated in NUREG-1022, Supplenent No. 2, if none are identified, the text should so state.
4 EIIS codes Codes for each component and system referred to in the text should be provided.
r, TABLE 3.
(continued)
Areas Comments Text presentation An outline format is recommended for the text of all LERs. This will help the licensee ensure that the minimum requirements of the regulation are met.
Abstract Corrective actions and root cause information is not being adequately provided in the abstracts.
Each abstract should contain a good summary of the root cause and corrective action information discussed in the text.
Abstract presentation Some abstracts contain information not discussed in the text. The final LER review should include a check for this situation and when identified, the text should be revised to include it.
Coded fields a.
Titles Titles need to be written such that they better describe the event (e.g., by including the root cause and the link between the cause and the result).
S
___7_
8 REFERENCES 1.
B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.
2.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.
3.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 1 U.S. Nuclear Regulatory Commission, February 1984.
4.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2. U.S. Nuclear Regulatory Commission, September 1985.
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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR COOPER I
f t
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e, TABLE A-1.
LER SAMPLE SELECTION FOR COOPER LER Sample Number LER Number Comments 1
85-004-00 2
85-005-01 3
85-006-00 4
85-010-00 ESF 5
85-012-00 6
85-013-00 ESF 7
85-017-00 8
85-019-00 ESF 9
85-021-00 10 86-002-01 11 86-003-00 12 86-004-00 ESF 13 86-005-00 14 86-006-00 SCRAM 15 86-008-00 e
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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR COOPER l
l
TABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR COOPER LER Sample Number
- 1 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 Text 8.0 7.3 8.4 7.5 8.5 6.5 8.8 7.9 7.5 6.3 8.1 7.2 6.5 8.6 6.4 Abstract 8.3 8.2 7.8 8.0 9.8 8.1
.9. 2 8.6 6.0 5.6 8.2 6.1 8.2 7.6 5.5 Coded Fields 8.3 9.5 8.5 8.8 9.2 8.5 9.0 8.5 7.8 9.5 8.0 8.5 9.5 9.0 8.0 Overall 8.1 7.8 8.2 7.8 9.0 7.2 8.9 8.2 7.1 6.4 8.2 7.0 7.3 8.3 6.3 a
LER Sample Number 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text 7.6 Abstract 7.7 Coded Fields 8.7 Overall 7.7 a.
See Appendix A for a list of the corresponding LER numbers, i
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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR COOPER
TABLE C-1.
TEXT DEFICIENCIES AND OBSERVATIONS FOR COOPER Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(11)(A)--Plant operating 3 (15) conditions before the event were not included or were inadequate.
50.73(b)(2)(11)(B)--Discussion of the status 0 (1) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.
50.73(b)(2)(11)(C)--Fa11ure to include 5 (15) sufficient date and/or time information.
a.
Date information was insufficient.
O b.
Time information was insufficient.
5 50.73(b)(2)(ii)(D)--The root cause and/or 3 (15) intermediate failure, system failure, or personnel error was not included or was inadequate.
a.
Cause of component failure was not 3
included or was inadequate b.
Cause of system failure was not 0
included or was inadequate c.
Cause of personnel error was not 0
included or was inadequate.
50.73(b)(2)(ii1LEl--The failure mode, 0 (6) mechanism (innediate cause), and/or ef fect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode was not included or was inadequate b.
Mechanism (immediate cause) was not included or was inadequate c.
Effect (consequence) was not included or was inadequate.
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals #
Totals (
)
50.73(b)(2)(ii)(F)--The Energy Industry 14 (15)
Identification System component function identifier for each component or system was not included.
50.73(b)(2)(11)(G)--For a failure of a 0 (0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.
50.73(b)(2)(ii)(H)--For a failure that 1 (4) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(I)--The method of discovery 2 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each 1
component failure was not included or was inadequate b.
Method of discovery for each system 0
failure was not included or was inadequate c.
Method of discovery for each 0
personnel error was not included or was inadequate d.
Method of discovery for each 1
procedural error was not included or was inadequate.
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c.
4 TABLE C-1.
(continued) i Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals #
Totals (
)
50.73(b)(2)(ii)(J)(11--Operator actions that 3 (6) affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
50.73(b)(2)(11)(J)(2)--The discussion of 3 (9) each personnel error was not included or was inadequate.
I a.
OBSERVATION: A personnel error was 1
implied by the text, but was not explicitly stated.
b.
50.73(b)(2)(11)(J)(2)(i)--Discussion 1
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(11)(J)(2)(ii)--Discussion 0
as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was
+
not included or was inadequate.
d.
50.73(b)(2)(ii)(J)(2)(111)--Discussion 1
of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
e.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1
of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(ii)(K)--Automatic and/cr manual 2 (6) safety system responses were not included or were inadequate.
50.73(b)(2)(11)(L)--The manufacturer and/or 4 (7) 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 3
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 3
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 l
state.
50.73(b)(4)--A discussion of any corrective 9 (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.
1 I
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _
Totals #
Totals (
)
a.
A discussion of actions required to 2
correct the problen (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.
b.
A discussion of actions required to 3
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 i
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information concerning previous 9 (15) 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 (
)
50.73(b)(2)(1)--Text presentation 6 (15) inadequacies, a.
OBSERVATION: A diagram would have 1
aided in understanding the text discussion.
b.
Text contained undefined acronyms 3
and/or plant specific designators.
c.
The text contains other specific 3
deficiencies relating to the readability.
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.
The number in parenthesis is the number of LERs for which the requirement was considered applicable.
TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR COOPER 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 2 (10) responses was not included or was inadequate.
a.
Summary of plant responses was not 0
included or was inadequate.
b.
Summary of system responses was not 0
included or was inadequate.
c.
Summary of personnel responses was not 2
included or was inadequate.
A summary of the root cause of the event 8 (15) was not included or was inadequate.
A summary of the corrective actions taken or 12 (15) planned as a result of the event was not included or was inadequate.
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TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)
Abstract presentation inadequacies 6 (15) a.
OBSERVATION: The abstract contains 5
information not included in the text.
The abstract is intended to be a summary of the text, therefore, the text should discuss all infornation summarized in the abstract, b.
The abstract was greater than 0
1400 characters c.
The abstract contains undefined 0
acronyms and/or plant specific designators.
d.
The abstract contains other specific 4
deficiencies (i.e., poor summarization, contradictions, etc.)
a.
The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.
Lince 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.
TABLE C-3.
CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR COOPER Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _ Totals' Totals (
)
Facility Name 0 (15) a.
Unit number was not included or incorrect.
b.
Name was not included or was incorrect.
c.
Additional unit numbers were included but not required.
Docket Number was not included or was 0 (15) incorrect.
Page Number was not included or was 0 (15) incorrect.
Title was left blank or was inadequate 15 (15) a.
Root cause was not given in title 13 b.
Result (effect) was not given in title 6
c.
Link was not given in title 5
Event Date 1 (15) a.
Date not included or was incorrect.
O b.
Discovery date given instead of event i
date.
LER Number was not included or was incorrect 0 (15)
Report Date 1 (15) a.
Date not included 0
b.
OBSERVATION:
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 1 (15) inconsistent with text or abstract.
TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
Power level was not included or was 0 (15) inconsistent with text or abstract Reporting Requiremer.ts 1 (15) a.
The reason for checking the "0THER" 0
requirement was not specified in the abstract and/or text.
b.
OBSERVATION:
It may have been more 0
appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It may have been 1
appropriate to report this event under an additional unchecked paragraph.
Licensee Contact 0 (15) a.
Field left blank b.
Position title was not included c.
Name was not included d.
Phone number was not included.
Coded Component Failure Information 0 (15) a.
One or more component failure sub-fields were left blank.
b.
Cause, system, and/or component code es inconsistent with text.
c.
Component failure field contains data when no component failure occurred.
d.
Component failure occurred but entire field left blank.
l
TABLE C-3.
(continued)
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 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.
l t
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APPENDIX D LER COMMENT SHEETS FOR COOPER
o o.
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 1.
LER Number: 85-004-00 Scores:
Text - 8.0 Abstract - 8.3 Coded Fields - 8.3 Overall = 8.1 Text 1.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event 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.
Is an independent source, such as a birth certificate, presently required by the Personnel Department to verify age?
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. TLD should be defined.
Abstract 1.
The root cause and corrective action summaries are deficient for the same reasons given in text comment number 1.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
The result is vague. A more appropriate title might be
" Radiation Overexposure of an Individual Under Eighteen due to Falsification of Birthday".
2.
Item (5)--Discovery date is given instead of event date. A more appropriate event date would probably l
be the end date of the first quarter of overexposure (June 30, 1982).
l l
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TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 2.
LER Number: 85-005-01 Scores: Text - 7.3 Abstract - 8.2 Coded Fields - 9.5 Overall - 7.8 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the failed components is inadequate. Most of the components listed do not include a cause for their failure.
If a cau:e is not known, any information that is suspected of causing the failure should be included.
Since some components may have failed from use or age, the time when the component's seals, gaskets, etc., were installed would be helpful.
Valves MS-M074 and MS-M077 (X-8) have failed the LLRT " frequently";
information defining " frequently" should be included.
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is excellent.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is l
inadequate.
Information explaining why, with the "as found" leakage almost four times that allowed by the Tecnnical Specifications, there were "no significant occurrences or adverse effects to public health or safety" should be provided. Also, "significant" should be defined or deleted.
i 5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The immediate corrective l
actions discussions are very good.
I!owever, more I
information should be provided concerning the l
preventive maintenance and trending. Will the LLRT be performed more frequently? Will preventive maintenance be performed more often or will a more comprehensive inspection and parts replacement program be incorporated for some of these components?
e.
.t TABLE D-1.
SPECIFIC LER' COMMENTS FOR COOPER (298)
Section Comments 2.
LER Number:
85-005-01 (continued) 6.
The acronyms CNS, IGSCC, CRD, RCIC/RWCV, RHR, HPCI, while fairly common or easy to figure out based on the context in which they are used, should be defined on their first usage in the text.
Abstract 1.
50.73(b)(1)--Summary of root cause of the failed components is not included.
See text comment 1.
2.
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.
The abstract defines type B and type C penetrations but the text does not.
4 Coded Fields 1.
Item (4)--Title:
Root cause is not included.
l
.s
\\
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 3.
LER Number: 85-006-00 Scores: Text = 8.4 Abstract = 7.8 Coded Fields - 8.5 Overall = 8.2 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the "misadju;ted torque switch" is inadequate.
Possible (suspected) reasons for the torque switch being out of adjustment should have been provided.
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)(I)--Discussion of the method of discovery of the failed motor is inadequate. At what point during testing did the operations personnel realize there was a problen with the motor operator?
4.
5_0.73(b)(2)(11)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
The actions necessary to prevent damage to the motor operator during testing of the valve after replacement of the motor should have been discussed.
5.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. What actions were necessary (if any) as a result of the valve jamming into its seat?
If any changes in station procedures or practices result from their reevaluation pursuant to the recommendation in INP0 SOER 83-09, these changes should be provided in a supplemental report.
Abstract 1.
50.73(b)(1)--Summary of personnel responses during the testing after replacement of the motor is not included.
See text comment number 4.
2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The reevaluation of station procedures and practices in light of INP0 SOER 83-09 should have been mentioned.
s TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments l
3.
LER Number: 85-006-00 (continued) 3.
Abstract does not adequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (4)--Title: Root cause (torque switch problem) and link (during stroke test to demonstrate operability) are not included.
A better title might be, " Misadjusted Torque Switch Causes Motor Operator Failure and Subsequent High Pressure Coolant Injection System Inoperability".
2.
Item (91--The Operating Mode number (i.e.,"1") does not agree with what is presented in other LERs in this same sample (i.e.,"N").
l l
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 4.
LER Number: 85-010-00 Scores: Text = 7.5 Abstract - 8.0 Coded Fields - 8.8 Overall = 7.8 Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is not included.
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 not included. Specific information as to why there were no safety implications should be included (e.g.,
--because systems X, Y, and Z operated as designed- ").
4.
50.73(b)(5)--Infornetion concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective actions to prevent recurrence should be mentioned.
Coded Fields 1.
Item (4)--Title:
Root cause (personnel error) and link (emergency shutdown) are not included.
i l
[
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l l
c
TABLE 0-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 5.
LER Number: 85-012-00 Scores: Text = 8.5 Abstract = 9.8 Coded Fields = 9.2 Overall = 9.0 Text 1.
50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
2.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The consequences of the event had it occurred under more severe conditions should be discussed. What if the pump had failed when HPCI was required?
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
(
I l
l
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 6.
LER Number: 85-013-00 Scores: Text - 6.5 Abstract - 8.1 Coded Fields - 8.5 Overall - 7.2 Text 1.
50.73(b)(2)(ii)(C)--Time information for major occurrences is not included. At what time did the station operator mistakenly open the wrong feeder breaker? At what time was the feeder breaker reclosed? At what time did the emergency diesel generator get secured and the plant electrical lineup get restored to normal?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
Was there a procedure involved in the discussion between the Shift Supervisor and the control room operators.(i.e., a procedure that addressed the particular problem)? Were the " appropriate actions" mentioned in the next to last sentence of the third paragraph only those described in the last sentence of that paragraph or were other actions taken?
4.
50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate.
Given the breakers are distinctly and properly labeled, what reason did the operator give for his error (e.g., possible poor lighting)? Was the station operator licensed? [See 50.73(b)(2)(ii)(J)(2)(iv).]
5.
50.73(b)(2)(ii)(K)--Were the responses to the feeder breaker reclosure only those listed in the third sentence of the third paragraph or were there other
--conditions presented upon reclosure- "?
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
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.
I
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 6.
LER Number: 85-013-00 (continued)
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate. See text comment number 4.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result cf the event is inadequate.
The corrective actions taken to preclude recurrence should have been mentioned in the abstract.
3.
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 (namely the first half of the first sentence and the last sentence of the abstract).
Coded Fields 1.
Item (4)--Title:
Result (ESF actuation) is not included. A better title might be, " Personnel Error-0pening the Wrong 125 VDS feeder Breaker Results in ESF Actuations".
l l
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.c TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 7.
LER Number:
85-017-00 Scores: Text = 8.8 Abstract = 9.2 Coded Fields - 9.0 Overall = 8.9 Text 1.
50.73(b)(2)(ii)(F)--The Energy Industry Identification Systerp component function identifier (s) and/or' system name of each component or system referred to in the LER is not included.
2.
50_ 73(b)(2)(ii)(L)--A model number for the Gem indicating switch should have been included.
3.
50.73(b)(4)--The text does not discuss whether or not corrective actions were needed to prevent recurrence. A brief explanation should be given if none were felt to be necessary.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Root cause (personnel error) and link (repair outage) are not included.
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 8.
LER Number: 85-019-00 Scores: Text - 7.9 Abstract = 8.6 Coded Fields - 8.5 Overall - 8.2 Text 1.
50.73(b)(2)(11)(C)--Time information for major occurrences is not included.
2.
50.73(b)(2)(11)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
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 the most severe conditions, the text should so state.
4.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
Abstract 1.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The planned revision to.the procedure to prevent recurrence of this event as discussed in the text, should be included in the abstract.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
i
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 9.
LER Number: 85-021-00 Scores: Text = 7.5 Abstract = 6.0 Coded Fields - 7.8 Overall = 7.1 Text 1.
50.73(b)(2)(ii)(Al--The dechanneling process should have been explained, given its involvement in the event.
2.
50.73(b)(2)(11)(C)--Time information for major occurrences is not included. At what time was it noticed that the fuel assembly was not properly i
engaged by the grapple? At what time was the fuel assembly successfully transferred and lowered into a position in the fuel pool storage rack?
3.
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.
4.
50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. Given that the operators l
initially had problems in engaging the fuel grapple l
to the fuel assembly bail, its not apparent from the discussion why extra care was not taken to ensure the engagement was proper (even without a procedural step to visually verify engagement).
\\
5.
50.73(b)(2)(ii)(L)--Given the design of the fuel j
grapple is such that the bail of a dechanneled fuel assembly can catch on an outside corner of the grapple, the grapple should be identified (e.g., by E.anufacturer and model number) so that other plants will be aware of a potential problem if they have the same grapple at their plant.
6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. A discussion of what could have happened had a fuel handling accident occurred should have i
been provided (e.g., " gaseous radioactive releases would have resulted- ").
What were the " appropriate emergency actions" that the control room personnel were prepared to take contingent on the fuel assembly disengagement from the fuel grapple? How was it i
concluded that there were no generic implications to j
the event, given text comment number 57 l
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments 9.
LER Number: 85-021-00 (continued) 7.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The corrective actions discussion does not address the training of fuel handling personnel or the possible redesign of the grapple as ways to reduce the possibility of recurrence.
8.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar events are known, the text should so state.
9.
OBSERVATION: A diagram or figure would aid in understanding the event; namely, the dechanneling process.
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The accident potential that existed was not mentioned.
2.
10.73(b)(1)--Summary of actions taken to mitigate the effects of a dropped irradiated assembly is not included.
3.
50.73(b)(1)--Summary of how the procedural deficiency resulted in this event is inadequate.
4.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The fact that the refueling procedure was revised was not mentioned.
Coded Fields 1.
Item (4)--Title:
Cause (procedural inadequacy) and result (the potential for a fuel handling accident) are not included.
l 2.
Item (7)--0BSERVATION:
Report date is not within thirty days of event date (or discovery date if appropriate). The text should explain why this i
l
, occurred.
3.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(x).
l
t TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 10. LER Number:
86-002-01 Scores: Text - 6.3 Abstract = 5.6 Coded Fields - 9.5 Overall = 6.4 Text 1.
All LERs are required to stand alone; therefore, LER revisions should include all unrevised information from the previous LER.
The presentetion of information in this revision is incomplete.
If only the revision had been reviewed for the required information a much lower score would have resulted.
The above scores and following comments are based on how well the combined information in revisions "0" and "1" meets the requirements.
2.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
3.
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.
4.
50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is inadequate. A model number should be provided.
5.
50.73(b)(3)--Discussion of the assessment of the i
safety consequences and implications of the event is inadequate. What would be the consequences of loss of overspeed control and long term HPCI injection?
OBSERVATION:
The availability of other systems or components capable of mitigating the consequences of the event should be discussed.
If no other systems or components are available, the text should so state.
OBSERVATION:
The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
Abstract 1.
The abstract should stand alone (see text comment 1).
4
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 10. LER Numoer: 86-002-01 (continued) 2.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract of revision "1" should mention the manufacturing defect.
3, 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
4.
OBSER'.*ATION: 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.
The plant operating condition is given in the abstract and not the text.
5.
Abstract describes the text as opposed to summarizing it. The abstract in revision "1" tells the reader what will be discussed instead of summarizing important details (see abstract comments 2 and 3).
I Coded Fields 1.
Item (4)--Title:
Link (surveillance testing) is not included.
2.
Item (14)--The commitment to a supplemental report on
]
revision "0" was good.
4 i
i i
,,,,_,,.,,,,,,,.,--,,,--,n,-
TABLE 0-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 11. LER Number: 86-003-00 Scores: Text = 8.1 Abstract = 8.2 Coded Fields = 8.0 Overall = 8.2 Text 1.
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.
2.
50.73(b)(31--An assessment of the safety consequences and implications of not performing the required surveillance needs to be discussed.
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 abstract should mention that the original surveillance test schedule was correctly revised but the working copy of this schedule was not.
2.
50.73(b)(ll--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should mention that in the future, all affected working copies will be destroyed prior to making changes to any original surveillance testing schedule.
Coded Fields 1.
Item (4)--Title:
Result, link, and root cause are not included.
l r
j l
l l
...s TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 12. LER Number: 86-004-00 S: ores: Text - 7.2 Abstract - 6.1 Coded Fields = 8.5 Overall - 7.0 J
Text 1.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
2.
50.73(b)(2)(11)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
The next to last sentence of the first paragraph implies that the operators suspected pump cavitation. They then "immediately opened" a bypass valve to maintain minimum system flow. Number 3 under the " evaluation of these events" indicates that this increased flow then contributed to pump suction 4
saturation conditions. Given this scenario, the text d
should explain why the bypass valve was immediately opened.
Is it required by a procedure?
l 3,
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate.
The i
fact that the Group III isolation was an engineered safety feature should have been provided (as it was in the abstract).
4.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
The text is required to contain a discussion that explains how the conclusion concerning the effect on the public health and safety j
and the generic implications of the event was reached, j
5.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. What was done prior to restoring the RWCU system to service (at 1126) that kept the suction line from again flashing and causing another Group III isolation?
i i
6.
50.73(b)(5)--Information concerning previous similar i
events is not included.
If no previous similar events are known, the text should so state.
The discussion concerning previous plant operating I
experience implies there have been previous similar events.
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 12. LER Number:
86-004-00 (continued) 7.
Some ideas are not presented clearly (hard to follow).
The "less than or equal to 200%" should be defined as a Technical Specification requirement and/or the precise trip setpoint provided.
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate. The net positive suction head (NPSH) problem should have been mentioned as well as how opening the filter deminerlizer bypass control flow valve contributed to NPSH.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 5.
In addition, the planned change to the appropriate operating procedures should have been mentioned in the abstract.
3.
OBSERVATION:
The abstract contains information not i
included in the text. The abstract is intended to be i
a summary of the text; therefore, the text should discuss all information summarized in the abstract.
4.
Abstract does not adequately summarize the text.
More background information is needed. Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded Fields 1.
Item (4)--Title:
Root cause and result are not included. A-better title might be, " Loss of Net Positive Suctior. Head for the RWCl? Pump Results in an i
Engineered Safety Feature Actuation (RWCU Group III i
Isolation)".
i i
-,. - _. ~. _. _.. - - _ - _ _. _,.
...s i
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 13. LER Number: 86-005-00 Scores: Text - 6.5 Abstract - 8.2 Coded Fields - 9.5 Overall - 7.3 Text 1.
50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the gasket is inadequate. The discussion should indicate the gasket failed (e.g., improper gasket material or head design).
3.
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.
4.
50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
An approximate time that the HPCI system was returned to service should be included.
5.
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.
6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The text should discuss the safety implications of a leaky condenser gasket.
For example, would this render the HPCI system inoperable or not? If the HPCI system were inoperable what other systems are available to take over the f unctions of the HPCI systein.
OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.
If the event occurred under what are considered the most severe conditions, the text should so state.
7.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Specifics should be provided as to the improvements already made. A supplemental report appears to be needed to describe
. '. =,.
TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 13. LER Number: 86-005-00 (continued) whether or not a new condenser design will be installed. Without a commitment to submit a supplemental report, this LER must be considered incomplete.
Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The previous improvements and their result and the possibility of a new condenser should be mentioned.
Coded Fields 1.
Item 4--Title: The result should be more specific (i.e., HPCI declared inoperable).
. a.o TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 14. LER Number: 85-006-00 Scores: Text - 8.6 Abstract - 7.6 Coded Fields - 9.0 Overall - 8.3 Text 1.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
2.
50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate.
50.73(b)(2)(1):(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is inadequate.
Who (type of personnel) was responsible for incorporating the insufficient flow characteristics into Special Procedure 86-0057 3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Some details.concerning the " specific guidance" contained in Special 4
Order 86-01 should be included.
4.
The listing of the sequence of events is excellent.
Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
Coded Fields 1.
Item (4)--Title: Root cause is not included.
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TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 15. LER Number: 86-008-00 Scores: Text = 6.4 Abstract - 5.5 Coded Fields = 8.0 Overall - 6.3 7 ext 1.
50.73(b)(2)(ii)(Al--Power level at the time of the event should have been provided in the text.
2.
50.73(b)(2)(ii)(C)--Time information for major occurrences is not included.
Times should be provided for occurrences such as:
(1) D/G #2 being made inoperable, (2) the discovery that the Technical Specification had been violated, and (3) when the condition was corrected that put the plant back in compliance with 3.12.B.2.
3.
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.
4.
50.73(b)(2)(11)(I)--Discussion of the method of discovery of the Technical Specification violation is not included.
5.
,50.73(b)(3)--Discussion of the assessment of the safety consequences and imp'lications of the event is inadequate.
Information should be provided that would lead the reader to the conclusion that the event had no effect on the public health and safety.
OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed.
If no other systems or components are available, the text should so state.
6.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Why was the training department only directed to review and upgrade, as necessary, only the REC system training material?
Don't other systems interrelate with emergency power j
sources? If the answer to this question is yes, then it might not be correct to state that the event "has no generic implications".
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.
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TABLE D-1.
SPECIFIC LER COMMENTS FOR COOPER (298)
Section Comments
- 15. LER Number:
86-008-00 (continued) 8.
Acronym (s) and/or plant specific designator (s) are undefined.
9.
Some ideas are not presented clearly (hard to follow); namely, the relationship between the REC loops and the specific diesel generator assigned to each loop. Are the A and B REC pumps both in one loop?
Abstract 1.
50.73(b)(1)--Summary of personnel error is inadequate. The abstract should provide information that would indicate that the error was cognitive (e.g., "The shift supervisor failed to recognize th?
1mplications of removing D/G #2 from service while work was being performed on the REC loop associated with D/G #1.").
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
3.
OBSERVATION: The abstract 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.
4.
Abstract does nqgpadequately summarize the text.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
Coded fields 1.
Item (4)--Title:
Result, cause, and link are not included. A better title might be, " Diesel Generator Removed from Service for Surveillance When Required To Be Available To Provide Emergency Power To The Reactor Equipment Cooling Pumps--Technical Specification Violation".
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