ML20235F436
| ML20235F436 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/22/1987 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8709290121 | |
| Download: ML20235F436 (49) | |
Text
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September 22, 1987
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Docket No. 50-302 Licerse No. DPR-72 Florida Power Corporation J f. W. S. Wilgus Vice President Nuclear Operations d
ATTN:
Manager, Nuclear Licensing
[
P. O. Box 219 tg $
Crystal River, FL 32629
- ,c:
y Gentlemen:
p 4 i
en The Nuclear Regulatory Commission's (NRC) Office for Analysis and EvaluativA of Operational Data (AE00) has recently completed an assessment of your Licensee Event Reports (LERs) for Crystal River 3 as a part of the NRC's SystematTc Assessment of Licensee Performance (SALP) program.
This assessment was performed to support a SALP period of April 1,1986, to August 31, 1987, and is being forwarded at this time for your use and information in order to pattern future submittals.
The summary to the report highlights the findings of the evaluation.
The overall quality scores of the LERs are above the industry average, i.e., scores of 8.9 and 9.0 compared to the industry average score at the time of each evaluation of 7.7 and 8.6, respectively.
The quality of text discussions of personnel error, safety consequences, and corrective actions has improved but were partially offset by declines in the quality of discussions of root cause, mode, mechanism, and effect and operator actions.
The score for the requirement to adequately identify failed components discussed in the text improved from the previous evaluation, but it is still considered to be deficient and should receive additional attention.
Details of the findings are discussed in the body of the report.
Please let us know if you have any questions.
l Sincerely, Original Signed by Virgil L. Brownlee /for Luis A. Reyes, Director Division of Reactor Projects
Enclosure:
l LER Quality Evaluation for Ciystal River 3 cc w/ encl:
pF.McKee, Director,NuclearPlant Operations (VC. Simpson, Director, Nuclear Site Support bec w/ enc 1:
(See page 2)
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ENCLOSURE LICENSEE EVENT REFORP (IER) gmIrrt EVAUWPIN FOR CRYSIAL RIVER 3 DURING 'IHE PERIOD FRN APRIL 1,1986 'IO AUGUST 31, 1987 a_
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Crystal River 3 during the period from April 1, 1986 to August-31, 1987 was performed.
This evaluation provides an overview of the quality of the LERs by comparing their contents to the reporting requirements of 10 CFR 50.73(b) and the guidelines contained in NUREG-1022 and its Supplements No. I and 2.
This is the second time the Crystal River 3 LERs have been evaluated using this methodology.
The results of this evaluation indicate that the overall quality of the Crystal River 3 LERs, for the three areas that are evaluated (i.e., the text, abstract, and coded fields), has improved somewhat since the previous evaluation. The first evaluatior.'s overall average LER score was 8.9, which was well above the industry average (7.7) at that time.
For the current evaluation, Crystal River 3's overall average LER score is 9.0, which is still above the current industry average LER score-(8.5). The quality of text discussions of personnel error, safety consequences, and corrective actions has improved but were partially offset by declines in the quality of discussions of root cause, mode, mechanism, and effect, and operator actions.
The score for the requirement to adequately identify failed components discussed in the text improved from the previous evaluation, but it is still considered to be deficient.
s.
LER QUALITY EVALUAT10N FOR a-CRYSTAL RIVER 3 INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Crystal River 3 during the period from. April 1, 1986 to August 31, 1987, a sample of the unit's LERs was evaluated.
This evaluation was performed by comparing the contents of each LER-to the reporting requirements of-10 CFR 50.73(b) and'the 1
2 guidelines contained in NUREG-1022 and its Supplements No. 1 and 2.3 - The sample consists of a total of 15 LERs, wiiich is considered to be the maximum number of LERs necessary to be evaluated for a unit / station,
-See Appendix A for a-list of the LER numbers in the' sample.
This is the second time that the Crystal River 3 LERs have been evaluated using the same methodology. As before, it was necessary to start the evaluation before the end of the assessment period because the input was due such a short time after the end of the assessment period.
Therefore, those LERs prepared by the unit late in the assessment period i
were not available for selection.
METHODOLOGY The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the criteria of 10 CFR 50.73(b).
In addition, each selected LER is compared to the guidance for preparation of LERs presented in NUREG-1022 and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the LERs. The purpose of this evalu3 tion is to provide feedback to improve the quality of l
LERs.
It is not-intended to increase the requirements concerning the
" content" of these reports beyond the current requirements of 10 CFR 50.73(b).
Therefore, statements in this evaluation that suggest 1
l k_.
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.
4 The evaluation process for each LER is divided into two parts.
The I
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 I
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 ER 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
- ategories: (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 1
narrative statements concerning the contents of each LER (Appendix D).
]
When referring to Appendix D, the reader is cautioned not to try to I
directly correlate the number of comments on a comment sheet with the LER
(
l scores, as the analysts have flexibility to co'1 sider the magnitude of a l
deficiency when assigning scores (e.g., the analysts sometimes make comments relative to a requirement without deducting points for that
)
requirement).
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RESULTS A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the 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 present in NUREG-1022 and its supplements.
Table i presents the average scores for the sample of LERs evaluated for the unit.
In order to place the scores provided in Table 1 in perspective, the distribution of the overall average score for all units / 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 i
been reevaluated.
(Note:
The previous score for those units / stations that are reevaluated is 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, Crystal River 3's average score for the text of the LERs that were evaluated is 9.0 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 prior to the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation.
The resultant percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the unit for the 15 LERs that were evaluated.
Based on similar methodology, the i
percentage scores for the varicus sections of the abstract and the items in the coded fields were also computed and are shown in Table 2.
As indicated in Table 2, certain requirements or areas within the text, abstract, and coded fields are causing the unit difficulty when preparing LERs.
Relatively low percentage scores may indicate that the unit needs additional guidance conc ening these requirements, or it may indicate that the unit understands the basic requirement but has either-i 3
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TA'-LE 1.
SUMMARY
OF SCORES FOR CRYSTAL RIVER 3 Average High Low Text 9.0 9.9 7.3 Abstract 9.1 9.9 8.0 i
Coded Fields 8.9 10.0 7.5 j
Overall 9.0 9.7 7.9 c.
See Appendix B for a summary of scores for each LER that was evaluated.
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LER REQUIREMENT PERCENTAGE SCORES'FCR CRYSTAL RIVER 3 TEF.!
Percentage a
Requirements [50.73(b)]'- Descriptions Scores (
)-
L( 2 ) i :. i ) ( A)
- - Plant condition prior to event 93 (15)
(2)(ii)(B)
Inoperable equipment that contributed b
-(2)(ii)(C)
- - Date(s) and approximate time (s) 90-(15)
(2)(ii)(D) -- - Root cause and intermediate:cause(s) 87 (15)
(2)(ii)(E)
- - Mode, mechanism, and effect 95 ( 5)
(2)(ii)(F)
- - EIIS codes 80 (15).
(2)(ii)(G)
Secondary function affect'ed b
(2)(ii)(H)
- - Estimate of unavailability 100 ( 6)
-(2)(ii)(I)
- - Method of discovery 97 (15)
( 2 )'( ii ) ( J ) ( 1 ) - Operator actions affecting course 92 ( 4)
(2)(ii)(J)(2) - Personnel' error (procedural deficiency) 99 ( 9)
(2)(ii)(K)
- - Safety system responses 92 ( 4)
(2)(ii)(L)
- - Manufacturer and model no. information 40 ( 5)
(3) - - - - - - Assessment of safety consequences 93 (16)
(4)
- - - - - Corrective actions 94 (15)
(5) - - - -
- Previous'similar event information 100 (15).
(2)ti)
-- - - Text presentation 87-(15)'
ABSTRACT Percentage a
Requirements [50.73(b)(1)] - Descriptions Scores ( )
- Major occurrences (immediate cause/effect) 98 (15)
- Plant / system / component / personnel responses 100 ( 4)
- Root cause information 88 (15)
- Corrective action information 91 (15)
- Abstract presentation 85 (15)
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TABLE 2.
(continued)
CODED FIELDS Percentage a
Item Number (s) - Descriptions Scores ( )
1, 2,
and 3 -
Plar.t name(unit #), docket #,
page #s 100 (15) 4--
Title 61 (15) 5, 6, and 7 -
Event date, LER no.,
report date 96 (15) 8------
Other facilities involved 300 (15) 9 and 10 Operating mode and power level 100 (15) 12 Reporting requirements 100 (15) 12 Licensee contact information 99 (15) 13 Coded component failure information 100 (15) 14 and 15 - -
Supplemental report information 100 (15) c.
Fercentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.
I (Note:
Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.,
The number in paren-hesis is the number of LERs for which the requirement was considered applicable.
b.
A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER.
It is always given 100%
if it is provided and is always considered "not applicable" when it is not.
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(1) excluded certain less significant information from a number of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs.
The unit should review the LER specific comments presented in Appendix D to determine why it received less than a perfect score for a requirement.
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Specific Deficiencies and Observations The deficiencies and observations of most concern for the text, abstract, and coded field sections.of the LERs are discussed separately below.
See Appendix D for a list of all deficiencies and observations.
Text Deficiencies and Observations The requirement to provida adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was considered deficient in l
1 three of the five LERs involving a failed component.
In most cases this i
requirement can be met by simply providing the manufacturer and model
]
number for each failed component.
For certain components (e.g., pipes, l
fitting, etc.) the material and size of the failed component may be more l
appropriate information. Whatever information is provided, it should be l
specific enough to allow the reader to determine if the failed component is the same as one that is used at his facility.
In addition, there are instances when component identification can be important to the reader, even though the component did not fail.
For example, if the design of a component contributes to the event, it would be helpful (although not required) to provide information that would enable others to specifically identify that component.
The Energy Industry Identification System (EIIS) component function identifier codes were not provided for all components in five of the 15 LERs. These codes should be provided for all components and systems referred to in the text.
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a Abstract Deficiencies and Observations While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as stated in NUREG-1022, Supplement No. 2, 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 Cause 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 of the event.
Number 3 and 4 could be improved by summarizing all the cause and corrective actions information that is provided in the text.
In addition, five abstracts had minor problems in the area of presentation; see the abstract comments in Appendix D.
Coded Fields Deficiencies and Observations The main deficiency in the area of coded fields involves the titles, Item (4).
Eleven of the 15 titles failed to include adequate cause information, six failed to include an adequate result of the event and seven failed to indicate the link between the cause and the result. While the result is considered to be the most important part of the title, cause and link information (as suggested in NUREG-1022, Supplement No. 2) must be p
9 1
included to make a title complete.
Example titles are presented in j
Appendix D for many of the LERs which were considered to have poor titles.
SUMMARY
Table 3 provides a summary of the areas that need improvement for the Crystal River 3 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 requirements can be found in NUREG-1022, and NUREG-1022 Supplements No I and 2.
As was mentioned earlier, this is the second time that the Crystal River 3 LERs have been evaluated using the same methodology.
The previous evaluation was reported in April of 1986. Table 4 provides a comparison of the scores for both evaluations.
Minor improvements in the information provided concerning corrective actions, safety consequences, and personnel error resulted in only a small improvement in the average text score and the overall average LER score remained virtually unchanged from the previous evaluation.
However, Crystal River 3's overall average LER score (9.0) remains above the current industry overall average of 8.5.
(Note:
The industry overall average is the result of averaging the latest overall average LER score for each unit / station that has been evaluated using this methodology.)
10
i TABLE-3. AREAS MOST NEEDING IMPROVEMENT FOR CRYSTAL RIVER 3.LERs f'
Areas Comments Manufacturer and model number Component identification information should be included in the text whenever a
. component fails.
In addition, (although not specifically required by the current regulation) it would be helpful to identify a component if its design is suspected of contributing to the event.
EIIS codes EIIS codes should be provided in the text for each component and/or system referred to in the text.
Abstracts Cause and corrective action information from the text should be summarized in the abstract.
Coded Fields a.
Titles Titles should be written such that they better describe the event.
In particular, cause and result information and the link
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between them should be included in each
- title, i
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T COMPARISON.0F LER SCORES FOR CRYSTAL RfVER 3 y
y, i-
Report Date
. April-86 September-87 j.
Text average 8.8 9.0
-Abstract average' 8.9 9.1 s
Coded fields average 9.0 8.9-L Overall LER average 8.9 9.0 n
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REFERENCES t
Th 1.~
0ffice for Analys'is and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, 7
September 1983.
I 2.
Office for Analysis and Evaluation of Operational Data, Licensee Event Report-System, NUREG-1022 Supplement No.1., U.S. Nuclear Regulatory Commission, February 1984.
1 3.
,. 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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I APPDIDIX A IIR SN4 PIE SEUXTION DIFORMATICH I
FOR CRYSTAL RIVER 3 1
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TABIE A-1.
IER SAMPLE SELECITON FOR GYSTAL RIVER 3 i
Sample Naber IER Number Cw.e ds l'
86-005-00 ESF 2
86-008-01 ESF 3
86-011-00 4-86-013-00 S
86-017-00 6
86-021-00 IEF 7
86-023-00 8
86-025-00 9
86-026-00 10 86-027-00 11 87-002-00 12 87-003 13 87-004-00 14 87-006-00 15 87-007-00 J
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APPENDIX B N m SCORES OF Emm IERS FOR CRysIAL RIVER 3 1
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TABLE B-1.
EVALUATION SCORES OF INDIVIDUAL LERC FOR ChYSTAL RIVER 3 a
LER Sample Number 1
2 3
4 5
6 7
'4
-.._.-__.___..__.--___-___-_--_._-..__-___--___--____--____-_-_-.8._
Text 9.8 8.9 9.1 9.5 9.4 7.9 9.1 9.6 Abstract 9.7 8.6 8.2 9.4 9.6 8.0 9.9 9.6 Coded Fields 9.6 8.2 10.0 9.3 92 8.5 9.5 6.0 Overall 9.7 8.8 8.9 9.4 9.5 8.0 9.3 9.4 a
LER Sample Number 9
10 11 12 13 14 15
_-----________-----___ ____-_----_____--__--_-- __. _______________ Average Text 9.1 7.3 9.1 9.9 9.3 8.1 9.4 9.0 Abstract 9.5 9.0 9.4 9.0 9.2 82 9.4 9.1 Coded Fields 7.5 8.7 10.0 9.0 9.8 8.)
8.7 8.9 Overall 9.1 7.9 9.3 9.5 9.3 8.1 9.3 9.0 See Appendix A for a list of the corresponding LER numbers.
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APPDIDIX C DEFICIDiCY AND OBSERVATIQi C0tWPS FOR CRYSIAL RIVER 3
TABLE C-1.
TEXT DEF1CIENCZE5 AND OBSERVAT10NS FOR CRYSTAL R1VER 3 Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
50.73(b)(2)(ii)(A)--Plant operating 2(15) conditions before the event were not included or were inadequate.
50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 7) of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or was inadequate.
50.73(b)(2)(ii)(C)--Failure to include 5 (15) sufficient date and/or time information.
a.
Date information was insufficient.
4 b.
Time information was insufficient.
1 50.73(b)(2)(ii)(D)--The root and/or 4 (15) intermediate cause of the component or system failure 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 1
included or was inadequate.
{
l 50.73(b)(2)(ii)(E)--The failure mode, 1 ( 5) 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 0
inadequate.
i b.
Mechanism (immediate cause) was not 1
included or was inadequate.
c.
Effect (consequence) was not included 0
or was inadequate.
l C-1 i
TABLE C-1.
(continued)'
y Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Tot'a l sa Totals (
)b
'50.73(b)(2)(11)(Fj--The Energy Industry Identification System component function
-5(15) identifier for ecch component or system was not included.
50.73(b)(2)(ii)(G)--For a failure of a 0(1) 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 Lthat rendered a train of a safety system 0 ( 6) inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.
50.73(b)(2)(ii)(1)--The method of discovery of each component failure, system failure 1 (15) personnel error, or procedural error was n,ot included or was inadequate, a.
Method of-discovery for each 0
component failure was not included or was inadequate, b.
Method of discovery for each system 0
f ailure was 'not included or was inadequate..
c.
Method of discovery for each I
personnel error was not included or was inadequate, d.
Method of discovery for each 0
procedural error was not included or was inadequate.
C-2
y.
TABLE C-L (continued) c.
Number cf LERs with Deficiencies and Observations-Sub paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (-
)b
.50.73(b)(2)(ii)(J)(1)--Operator actions that 1 ( 4)-
affected the course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.
50.73(b)(2)(ii)(J)(2 --The discussion of each personnel error}was not included or was 2 ( 9) inadequate, a.
OBSERVATION: A personnel error was 1
implied by the. text, but was not explicitly. stated.
'b.
50.73(b)(2)(ii)(J)(2)(1)--Discussion 0
i L
.as.to whether the pprsonnel' error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(ii)(J)(2)(ii)--Discussion 0
as to whether the personnel error was contrary to an approved procedure, was a direct result of'an error in an approved procedure, or was associated with.an activity or task that was not covered by an approved procedure was not included or was inadequate, d.
50.73(b)(2)(ii)(J)(2)(fii)--Discussion 0
of any unusual characteristics of the worklocation(e.g., heat, noise)that directly contributed to the personnel error was not included or was l
inadequate.
- 50. 73( b)( 2 )( ii )(J)( 2)( i v)--Di scu s sion 1
j e.
of the type of personnel involved i
(i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadequate.
C-3
m
-TABLE'C-2. -(continued)
Number of LERs with -
Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals
- Totals (
[
50.73(b)(2)(ii)(K)--Automatic and/or manual safety system responses were not included or 1(4) r were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 3 ( 5) model number of each failed component was not included or was inadequate.
50.73(b)(3)--An assessment of the safety 3 (15) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION: The availability of 0
other systems or components capable of mitigating the consequences of the event was not discussed.
If no other systems or components were available, the text should state that none existed.
b.
OBSERVATION: The consequences 1
of the event had it occurred under more severe conditions were not discussed.
If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective actions planned as a result of the event 3 (15) including those to reduce the probability of similar events occurring in the future was not included or was inadequate.
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C-4 r
i TABLE C-1..
(continued)
=.-
Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b a
A discussion of actions required to O
a.
correct the problem (e.g.. return. the component or system to an operational condition or correct che personnel error) was not inc M ed or was inadequate.
l b.
A discussion of act tons required to 2
i reduce the probability of recurrence 1
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
.j
'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 0 (15) similar events was not-included or was inadequate.
l C-5
TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals' Totals (
)b 50.73(b)(2)(1)--Text presentation 2(15) inadequacies.
a.
OBSERVATION: A diagram would have 0
aided in understanding the text j
discussion.
b.
Text contained undefined acronyms 1
and/or plant specific designators, 1
The text contains other specific 1
c.
deficiencies relating to the readability.
The "sub paragraph total" is a tabulation of specific deficiencies or a.
observations within certain requirements.
Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be 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.
i C-6
i TABLE C-2.
ABSTRACT DEFICIENCIES AND OBSERVAT10NS FOR CRYSTAL RTVER 3 Number of LERs with
)
Deficiencies and j
Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (
)b
]
a l
A summary of occurrences (immediate cause 2(15) and effect) was not included or was inadequate.
A summary of plant, system, and/or personnel 0 ( 4) esponses was not included or was inadequate, a.
Summary of plant responses was not included or was inadequate.
b.
Summary of system responses was not included or was inadequate.
c.
Summary of personnel responses was not included or was inadequate.
A summary of the root cause of the event 7 (15) was not included or was inadequate.
A summary of the corrective actions taken or 6 (15) planned as a result of the event was not included or was inadequate.
C-7 I
1<
Y l TABLE ~C-2.
(continued) j Number of LERs with
~
Deficiencies and Observations.
Sub paragraph.
Paragraph-Description of' Deficiencies and Observations Totals Totals (
)b a
Abstract presentation' inadequacies.
5(15) a.
OBSERVATION:
The abstract contains 1
information not included in the text.
The abstract is intended to be a summary of the text, therefore, the i
text should discuss all information summarized in the abstract.
b.
The abstract was greater than 1
1400 spaces, c.
The abstract contains undefined 1
acronyms and/or plant specific designators.
- d. 'The abstract contains other specific.
2 deficiencies (i.e.,: poor summarization, contradictions,etc.).
i 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.
1 i
l 1
i i
C-8 4
)
TABLE C-3.
CODED FIELOS DEFfC1ENCIES AND OBSERVAT10NS FOR CRYSTAL RIVER 3' Number'of LERs with Deficiencies and Observations Sub paragraph.
Paragraph a
- Totals ('
')b Description of Deficiencies and Observations Totals Facility Name
'O(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.
1 Page Number was not included or was 0 (15) l incorrect.
Title was left blank or was inadequate.
13(15)
~
a.
Root cause was'not given or was 11 L
inadequate.
- b. ~ Result (offect) was not given or 6
l was: inadequate.
c.
Link was not given or was 7
inadequate.
Event Date 1 (15) a.
Date not included or was incorrect.
1 b.
Discovery date given instead of event 0
date.
l l
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
l within thirty days of event date (or t
discovery date if appropriate).
1 C-9
I t
...~.
TABLE C-3.
(continued)
Number of LERs'with Deficiencies and Observations Sub paragraph -
Paragraph
. Description of Deficiencies and Observations' Totals Totals (-
-)b
~
a Othor 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.
Power level-was not included or was 0(15) inconsistent with text or abstract.
Reporting Requirements 0(15) a.: The reason.for checking the "0THER" requirement was not specified in the abstract and/or-text.
b.
OBSERVATION:
It may have been more appropriate to report the event 'under
- a different' paragraph..
- c. :0BSERVATION:
It may have been
,i appropriate to report this event under an additional unchecked paragraph.
. Licensee Contact 1
1(15) a.
Field left blank.
0 i
b.
Position title was not inc1'.'ded.
I c
Name was not included.
O d.
Phone number was not included.
O Coded Component Failure Information 0(15) a.
One or more component failure sub-fields were left blank b.
Cause, system, and/or compon nt code n
is inconsistent with text.
c.
Component failure field contains data when no component failure occurred.
d.
Component failure occurred but entire field left blank.
i 1
I C-10 l
3.
- +>
TABLE'C-3.
(continued)
Number of LERs'with Deficiencies and I
Observations Sub paragraph.
Paragraph Totals" Totals (
)b
- Description of Deficiencies and Observations
[
0(15)
Supplemental Report l
Neither "Yes"/"No" block of the a.
supplemental report field was-checked.
l b.
The block checked was inconsistent
-with the text.
0(15) i Expected submission date information 1s-l inconsistent with the block checked in l
Item (14).
1 "e. l The "sub paragraph total" is a tabulation of specific deficiencies orSince an LER observations within certain requirements.
j one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up tolthe paragraph total.
i b.
The paragraph total" is the number of LERs that have one or moreThe number in par
[
'-equirement deficiencies or observations.-umber of LERs for which a certain r i
u J
I i
C-11 l
I
W wr-85
- ?
':,lf g a
i
)
i APPENDIX D D N SHTrs yon i
N N RIVER 3 s
1 j
~
4 TABLE D-1.
SPEClFIC LER COMMENTS FOR CRYSTAL RTVER 3 (302)
)
Section Comments 1.
LER Number: 86-005-00 Scores:
Text = 9.8 Abstract = 9.7 Coded Fields = 9.6 Overall = 9.7 1
Text 1.
50.73(b)J2)(ii)(F)--Some of the EIIS codes for components (e.g., bus and relay) referred to in the I
text were not provided.
{
Abstract 1.
The bstract contains greater than 1400 spaces.
l Coded Fields 1.
Item (4)--Title:
Link is not included.
A more appropriate title might be " Personnel Error During Testing Re'sults in Actuation of an Emergency Diesel Gene ra to r".
I i
i 1
l i
)
i l
i i
j l
1 i
L i
l D-1 l
)
l l
l l
.____-________a
]
3 j
~
TABLE D-1.
SPECIFIC LER' COMMENTS FOR CRYSTAL RIVER 3 (302) r Section-Comments i
I 2.
LER Number: 86-008-01 Scores: Text = 8.9 Abstract = 8.6-Coded Fields = 8.2 Overall = 8.8 Text 1.
'50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is inadequate.
The power level at the start of the event is not included.
2.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions
)
that affected the course of the event is inadequate.
Was the disconnection of the main generator from the i
transmission system performed according to a procedure?
-l 3.
50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate.
By how much did the emergency feedwater flowrate to a single OTSG exceed the design value? Was the main turbine trip expected, given the generator disconnect?
Abstract-1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequ' ate.
The main feedwater isolation from B OTSG because of the startup valve closure is not included.
2.
50.73(b)(1)--Summary of the causes of the turbine trip and the startup control valve closure are not included.
1 Coded Fields 1.
Item (4)--Title:
Cause (spurious control valve closure) and link (low level) are not included, and result (turbine trip) is inadequate. A better title might be:
" Spurious Feedwater Startup Valve Closure Causes Low Level Emergency Feedwater Actuation Followed by Turbine Trip from Overexcitation".
_j l
i D-2
Ly
.. N" LTABLE D-l'.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
Section Comments 3.
LER Number: 86-011-00
' Scores:
Text'= 9.1
' Abstract.= 8.2
' Coded Fields = 10.0 - Overall = 8.9
. Text 1.
50.73(b)(2)(ii)(C)--On what date were the' relays recently replaced (i.e., during "a recent outage")?-
2, 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the random intermittent malfunctions of the relay contacts is inadequate.
Given that this is the second time that these relays failed, is there a suspected-cause?
Is a different model or manufacturer being considered as a replacement?.
t 3,
50.73(b)(3)--Were the zone reference indicators in the control rod panel cabinets continuously monitored
}
during the 18 minutes that the normal indication was-inoperable?
'4.
50.73(b)(D--Is any action being.taken to try to prevent the failure of these relays in the future?
See text comment number 2, Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate.
There is no mention of what was wrong with the relays.
2.
50.73(b)(1)--Summary of corrective actions taken or k
planned as a result of the event is inadequate.
See
]
text comment number 4 j
'3.
Additional space is available within the abstract field to provide more information but it was not utilized.
Coded Fields 1.
No comments.
l 0-3
-TABLE 0-1.. SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
~
Section Comments 4.
LER Number:
86-013-00 1
Scores: Text = 9.5
-Abstract = 9.4 Coded Fields = 9.3 Overall = 9.4 i
Text 1.
50.73(b)(2)(ii)(F)--The EIIS component code for the filter was not given.
l 2.
50.73(b)(3)--The consequences of the event had it i
occurred under more severe conditions are not adequately discussed.
What would.the consequences be if this situation had occurred when the charcoal filters were needed (e.g., to remove poison gases)?
3.
Inclusion of the diagram was very helpful.
Abstract 1.
50.73(b)(1)--The root cause (unknown) and corrective actions (replaced) for the. Vacuum pump were not raentioned. ; Additional space is available within the abstract field to provide more information but it was not utilized.
Coded Fieln
.1.
Item (4)--Title:
Cause (personnel error) is vague.
i i
I 1
l D-4
TABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302) i Section Comments 5.
LER Number: 86-017-00 Scores: Text = 9.4 Abstract = 9.6 Coded Fields = 9.2 Overall = 9.5 Text 1.
No comment.
Abstract 1.
No comment.
I Coded Fields 1.
Item (4)--Title:
Cause (personnel error) is not
- included, f
I 1
l l
I I
D-5 i
TABLE D-l'.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
Section Comments 6.
LER Number: 86-021-00 Scores:
Text = 7.9 Abstract = 8.0 Coded Fields = 8.5 Overall'= 8.0
- Text
~1.
50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the ASV-26 failure is not included.
Why did it fail fully open? In addition, was there a.
personnel error involved, that is, should the operator have reopened ASV-27 prior to shutting ASV-267 2.
50.73(b)(2)(ii)(E)--The immediate cause discussion of each failed component is not included. _What was the immediate cause of ASV-26 going full open?
3.
50.73(b)(2)(ii)(L)--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4.
50,73(b)(3)--How long had MSV-107 (and the corresponding vahe for FWP-28) been isolated because of the suspected leaking throttle valvet?
5.
50.73(b)(4)--Discussion of' corrective actions taken or planned is inadequate.
What was done to " repair" ASV-26? To what document (s) was procedural guidance added (concerning the warmup line)? When will the integrity of the high pressure throttle valves be checked?
Abstract.
1.
50.73(b)(1)--Summary of cause information is inadequate. ASV-26 is never mentioned in the abstract.
Likewise, the isolated warmup line and MSV-107 are not mentioned.
2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 5.
3.
Pertinent details are missing.
The reader has no
{
idea (from reading the abstract) why the third corrective action will be performed.
I Coded Fields 1,
Item (4)--Title:
Cause and link are not included. A l
better title might be " Faulty Steam' Supply Valve Causes Loss of Main Feed Pump--Emergency Feedwater i
Actuates".
l D-6 A
q l.
i jdBLED-1.
SPEC'IFIC LER COMMENTS FOR CRYSTAL RIVER.3 (302)
Section Comments 7.
LER Number: 86-023-00 Scores: -Text = 9.1 Abstract = 9.9 Coded Fields = 9.5 Overall = 9.3 Text 1.
50.73(b)(2)(ii)(A)--A brief description of the operating mode number [e.g., Mode 5 (cold shutdown)]
was not included.
2.
50.73(b)(2)(ii)(F)--The EIIS component code for the coil.was-not given.
3.
50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of.
')
personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is inadequate.
Who (by type of personnel) was responsible for j
failing to transfer the 'needed information?
4.
The text appears to contradict itself,- In the second paragraph of Event Description the decision was made not to repair the old battery, but two paragraphs -
later it is being used. for CR-2 loads.
It is not clear from the text'that'CR-3 has a redundant battery.
Since both CR-1 and CR-2 have added loads, it appears that CR-1 also needs a new battery to supply'part of CR-1: loads and all CR-3 loads, as is the case for.CR-2.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Cause (error by fossil unit personnel) is vague.
D-7
~
TABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302) t Section Comments 8.
LER Number:
86-025-00 Scores:
Text = 9.6 Abstract = 9.6 Coded Fields = 8.0 Overall = 9.4 Text 1.
No comment.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Cause (personnel design error) and link (during construction) are not included.
2.
Item (5)--It appears that the event date should be the discovery date, 12/14/86, instead of the date of deportability determination, 12/30/86.
i 0-8
TABLE D-1.
SPECIFIC LER COMMENTS'FOR CRYSTAL RIVER 3 (302)
Section Comments l
9.
LER Number:
86-026-00 Scores:
Text = 9.1 Abstract = 9.5 Coded Fields = 7.5 Overall = 9.1 Text 1.
50.73(b)(2)(ii)(C)--When (date) was it " revealed" that " additional Technical Specification valve position verification surveillance requirements were in question -
" (see first paragraph of page 3)?
2.
50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3.
50.73(b)(2)(iij(J)(2)--Why were the event and l
associated NCORs initially evaluated as "not reportable"? Was the resident inspector made aware of QPDR 85-NOA-007 in July of 1985? If not, was he made aware of the additional Technical Specification surveillance that were in question?
1 1
4.
50.73(b)(4)--Is there a need for a corrective action to address the deportability problem (see text comment number 3)?
Abstract 1.
OBSERVATION:
The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract.
This abstract contains information that was not included in the text.
The fact that there was a time differential between the " determination" that a consistent interpretation did not exist and the
" eventual" production of a consistent interpretation was not mentioned in the text.
Coded Fields 1.
Item (4)--Title:
Result and link information are not included and the cause is inadequate. A better title might be " Personnel Misinterpreted Technical Specification Requirements When Preparing Procedures Concerning Valve Position Verification".
2.
Item (5)--Event date is not provided. The date provided is not the discovery date but the date deportability was determined. See question 14.5 on page 22 of NUREG-1022, Supplement 1.
D-9 i
[
l l
TABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
Section Comments 10.
LER Number:
86-027-00 Scores:
Text = 7.3 Abstract = 9.0 Coded Fields = 8.7 Overall = 7.9 Text 1.
Why wasn't the event determined to be reported at the time of discovery?
2.
50.73(b)(2)(ii)(C)--When was it determined that the event was reportable and when were the bolts replaced (Note: A reader has to assume the bolts were replaced before the as-left test on November 20)?
3.
50.73(b)(2)(ii)(D_]--The root and/or intermediate cause discussion concerning the bolts is not included.
4.
50.73(b)(2)(ii)(F)--The EIIS component code for a penetration was not included.
5.
50.73(b)(2)(11)(Lj--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is not included.
6.
50.73(b)(3)--Note: When a valve fails between two leak tests, it could just as easily be cor.cluded that the valve failed just after the first lea ( test.
7.
50.73(b)(4)--A discust. ion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included. Without.a complete root cause discussion (see text comment 2) a reader can't determine if replacing the bolts is adequate to prevent recurrence.
Abstract 1.
50.73(b)(1)--The root cause and corrective action summaries are deficient for the same reasons as given in text comment 3 and 7.
Coded Fields 1.
Item (4)--Title: Cause (loose bolts on valve operator) is not included and the Result (loss of containment integrity) is inadequate.
2.
Item (7J--The thirty day reporting limit can't be determined since the date that deportability was determined is not included (see text comment 2).
I i
l D-10
i-
~ABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
Section Comments 1.
LER Number: 87-002-00 Scores:
Text = 9.1 Abstract = 9.4 Coded Fields = 10.0 Overall = 9.3
~ ext 1.
50.73(b)(2)(ii)(L)--Identification (e.g.,
manufacturer and model no.) of the failed component (s) discussed in the text is not included.
Abstract 1.
50.73(b)(1)--Summary of cause information for the LED failure is not included.
Coded Fields 1.
No comment.
l
!)
j l
1 j
i D-11 l
4
l
(
TABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302) 1 i
Section Comments l
i 12.
LER Number:
87-003-00 Scores:
Text = 9.9 Abstract = 9.0 Coded Fields = 9.0 Overall = 9.5 j
i Text 1.
50.73(b)(3)--Is there an operating procedure that I
requires manual initiation of the subject isolation l
valves under certain (emergency) conditions?
j Abstract 1.
50.73(b)(1)--Summary of corrective actions taken or j
planned as a result of the event is inadequate.
The
" Procedure Review Package" was not mentioned.
j i
2.
Additional space is available within the abstract
{
field to provide more information but it was not utilized.
Coded Fields 1.
Item (4)--Title:
Cause (Personnel Error) and result (Technical Specification Requirement Not Met) are inadequate.
1 D-12
.s.
- i
- TABLE D-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302) i
(..
-)
Section Comments 13.
LER Number: 87-004-00 j
Scores:. Text = 9.3 Abstract = 9.2 Coded Fields = 9.8 Overall.=~9.3
-Text 1.
50.73(b)(2)--The safety. assess' ment didn't indicate how accurate the method used by the-ANO was in calculating the flow.
If it was less accurate than the flow recorder than the 'possible consequences of larger than planned. flow should be discussed.
Abstract 1.
50.73(b)(1)--Summary of cause is, inadequate.
The fact that the ANO was mislead by an alternate method I
of setting the flow in the procedure was not included.
2.
Abstract'contains acronym (s) and/or plant specific designator (s) that are undefined (FPC ws,n't defined).
Coded Fields 1.
Item (4)--Title: ' Result (actual release without compliance) is vague, l
1 4
D413 1
- ;.1 g
W" i
b'
- TABLE D-l'.
SPECIFIC ~ LER COMMENTS FOR CRYSTAL RIVER 3 (302)
.Section' Comments-14.
LER Number: 87-006 '
Scores:' Text'= 8.1 Abst'ract = 8.2 Coded Fields = 8.1 Overall = 8.1 Text 1.
50.73(b)(2)(ii)(C)--The time that Channel A ammonia detector was returned'to service is not. included.
2.
50.73(b)(2)(ii)(I)--Discussion of the method of-discovery of the Channel B ' ammonia detector key
~
switch incorrect position is inadequate.
What was the Nuclear Technical Support Technician doing when i
.the key position was " noticed"?
Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate.
The Channel B key switch being incorrectly left in the
" test" position is not mentioned.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The immediate corrective actions to return Channel B switch to normal and to return Channel A monitor to service are not mentioned.
! Coded Fields 1.
Item (4)--Title:
Cause (procedural inadequacy) and link (leaving monitor key switch in incorrect position during troubleshooting) are not included and result (Technical Specification violation) is vague.
2.
Item (12)--Position title is not included.
D-14
0 TABLE 0-1.
SPECIFIC LER COMMENTS FOR CRYSTAL RIVER 3 (302)
Section Comments i
15.
LER Number: 87-007-00 l
Scores: Text = 9.4 Abstract = 9.4 Coded Fields = 8.7 Overall = 9.3 Text 1.
50.73(b)(2)(ii)(C)--Date the problem was first identified and the date of the internal letter that suggested that the matter might be an unanalyzed situation are not included.
]
2.
50.73(n)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the design oversight is inadequate. Who (what organization) was responsible for the design oversight?
3.
50.73(b)(4)--Are any interim corrective actions planned prior to the design modification?
4.
Acronym (s) and/or plant specific designator (s) are undefined.
Abstract 1.
Abstract contains acronym (s) and/or plant specific designator (s) that are undefined.
Coded Fields 1.
Item (4)--Title: Cause information is not included and the link is inadequate.
A better tile might be
" Design Oversight Result s in the Potential For Exceeding Emergency Dic:.
.-equential Loading Limits",
i
)
1 3
h I
i 0-15 J
-