ML20235L759

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LER Quality Evaluation for Peach Bottom Units 2 & 3 During Feb 1986 - May 1987
ML20235L759
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 07/10/1987
From:
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:
Shared Package
ML20235L748 List:
References
NUDOCS 8707160816
Download: ML20235L759 (52)
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0 5 LICENSEE EVENT REPORT (LER)

QUALITY EVALUATION FOR PEACH BOTt0M 2,3 -

DURING THE PERIOD FROM FEBRUARY 1, 1986 TO MAY 31, 1987 8707160816 G70710 7 DR ADOCK 0500

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Peach Bottom 2,3 during the period from February 1,1986 to May 31,1987 was perforned using a refinement of the basic methodology presented in NUREG-1022, Supplement No. 2. This is the second time that the Peach Bottom LERs have been evaluated using this methodology. The results of this evaluation indicate that Peach Bottom LERs have improved and now have an overall average LER score of 8.5 out of a possible 10 points, compared to a previous overall average LER score of 8.0 and a current industry average score of 8.4. The industry overall average is the result of averaging the latest overall average LER score for those unit / stations that have been evaluated to date using this methodology.

Some weaknesses identified in the Peach Bottom LERs involve the requirements to: 1) identify failed components in the text (Requirement 50.73(b)(2)(ti)(L)) and 2) provide data on the unavailability of safety system trains [ Requirement 50.73(b)(2)(ii)(H)].

A strong point for the Peach Bottom LERs is the discussions of the failure mode, mechanism, and effect of failed components [ Requirement 50.73(b)(2)(ii)(E)].

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LER QUALITY EVALUATION FOR PEACH BOTTOM 2.3 i

INTRODUCTION a

In order to evaluate the overall quality of the contcnts of the {

Licensee Event Reports (LERs) submitted by Peach Bottom 2,3 during the period from February 1, 1986 to May 31, 1987, a representative sample of i the station's LERs was evaluated using a refinement of the basic I methodology presented in NUREG-1022, Supplement No. 2. The sample consists of a total of 15 LERs (seven LERs from Unit 2 and eight LERs from i Unit 3), which is considered to be the maximum number of LERs necessary to be evaluated for a unit / station. The Peach Bottom LERs were evaluated as one sample because it has been determined that their LERs are both written and formally reviewed at the station, rather than the unit, level. See Appendix A for a list of the LER numbers in the sample, f It was necessary to start the evaluation before the end of the assesssent period because the input was due such a short time af ter the end  !

of the assessment period. Therefore, all of the LERs prepared by the station during the assessnent period may not have been on file and available for review. '

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-10222  !.

and Supplements No. 1 and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the reports. The purpose of this evaluation is to provide feedback to improve the quality of LERs. It is not intended to-increase the requirements concerning the

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

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

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

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

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

The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count.of general deficiencies for the overall sample of LERs that was evaluated. Likewise, the scores serve two purposes: (1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score - overall LER score).

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

I When referring to Appendix D, the reader is cautioned not to try to  !

directly correlate the number of comments on a comment sheet with the LER

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scores, as the analysts have flexibility to consider the magnitude of a deficiency when assigning scores (e.g., the analysts sometimes make  !

comments relative to a requirement without deducting points for that l requirement).

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1 RESULTS j A discussion of the analysts' conclusions concerning LER quality is j presented below. These conclusions are based solely on the results of the

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evaluation of the contents of the LERs selected for review and as such i represent the analysts' assessment of the station's performance (on a scale l of 0 to 10) in submitting LERs that meet the criteria of 10 CFR 50.73(b)

L and the guidance presented in NUREG-1022 and its supplements. Again, the Peach Bottom LERs were evaluated as one sample, rather than two separate samples (by unit) because it was determined that the Peach Bottom LERs are both written and fornelly reviewed at the station, rather than the unit, level.

Table 1 preseats the average scores for the sample of LERs ev'aluated for Peach Bottom. In order to place the scores provided in Table 1 in perspective, the distribution of the latest overall average score for all unit / stations that have been evaluated using the current methodology is provided on figure 1. Figure 1 is updated each month to reflect any changes in this distribution resulting from the inclusion of data for those units / stations that have not been previously evaluated or those that have been reevaluated. (Note: Previous scores for those units / stations that are reevaluated are replaced with the score from the latest evaluation).

Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Peach Bottom's average score for the text of the LERs that were evaluated is 8.5 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 dif ferent requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(11)(A)] to text presentation. The percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the station for the 15 LERs that were evaluated.

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a TABLE 1.

SUMMARY

OF SCORES FOR PEACH BOTTOM 2,3 Average High Low Text 8.5 9.2 7.0 Abstract 8.3 9.3 5.4 Coded Fields 9.1 10.0 8.5 Overall 8.5 9.0 6.7

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

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TABLE ~2. LER REQUIREMENT PERCENTAGE SCORES FOR PEACH BOTTOM 2,3 1

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TEXT Percentage a

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

(2)(li;(A) -

- Plant condition prior to event (2)(ii)(B)- -

. Inoperable equipment that contributed 97 (15) b (2)(ii)(C) - - Date(s) and approximate time (s) 85 (15)

(2)(ii)(D) - - Root cause and intermediate cause(s) 86-(15)

(2)(ii)(E) -

-. Mode, mechanism, and effect 100 ( 5)

(2)(ii)(F) - - EIIS codes 53 (15)-

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

(2)(ii)(I) - - Method of discovery 58 ( 6) j 93 (15) i i

(2)(ii)(J)(1) - Operator actions affecting course 83 ( 3) j

-(2)(ii)(J)(2) - Personnel error (procedural deficiency) 82 ( 9)

(2)(ii)(K) - - Safety system responses 92 (10) i (2)(ii)(L) - - Manufacturer and model no, information 55 ( 5) 1 (3) - - - - - - Assessment of safety consequences 87 (15)

(4) - - - - - Corrective a :tions 77 (15)

(5)'- - - -- -- --Previous similar event information

- Text presentation 100 (15)

(2)(i) 86 (15) )

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ABSTRACT Percentage a

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

______________________________________________________ Scores ( )

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

- Plant / system / component / personnel responses 88 (11)

- Root cause information 83 (15) i

- Corrective action information 63 (15) l Abstract presentation 80 (15) I i

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TABLE 2. (continued)-

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CODED FIELDS Percentage a -

Item Number (s) - Descriptions Scores (. )

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

4------ Title 69 (15) 5, 6,'and 7'- Event date, LER no., report date 98 (15) 8-'----- Other facilities involved 100 (15) 9'and 10 --

Operating mode and power level 100 (15).

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

Licentse contact information 100'(15) 13 -----

Coded component failure information 87 (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 E .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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Specific Deficiencies and Observations l

A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the station probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic requirement but has either: (1) excluded certain less significant information from many of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. Those responsible for preparing LERs should review the LER specific comments presented in Appendix 0 in order to determine why the station received less than a l perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below as are the primary deficiencies in the abstracts and coded fields sections.

Text Deficiencies and Observations Energy Industry Identification System (EIIS) component function identifier and/or system codes were not provided in the text of 10 of the LERs, Requirement 50.73(b)(2)(ii)(F). These codes should be provided for all systems and components referred to in the text and not just those that fail.

For the six LERs in which is was ascertained that failures rendered a train of a safety system inoperab~1e, an estimate of the elapsed time from ,

the discovery of the failure until the train was returned to service was inadequate or not included in three of the six, Requirement 50.73(b)(2)(ii)(H). The time a safety system is unavailable is important because the information becomes part of the generic data necessary to perform probabilistic risk assessments. Adequate attention paid to providing date and time information for major occurrences (Requirement 50.73(b)(2)(ii)(C)) will usually ensure that the unavailability time can be determined. '

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The manufacturer and/or model number (or other unique identification)

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l was not provided in the text of three of the five LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail-l must be identified in the text so that others in the industry can be made aware of potential problems. An event at one unit / station can of ten lead to the identification of a generic problem that can be corrected at other units or stations before they experience a similar event. In addition, although not specifically required by the current regulation, it would be helpful to identify components whose design contributes to an event even though the component does not actually fail.

Four important requirements received percentage scores of 75 or more but are mentioned here because of the large percentage of LERs in which deficiencies were noted for these requirements. The percentage scores for date and approximate time information [ Requirement 50.73(b)(2)(ii)(C)),

root cause [ Requirement 50.73(b)(2)(ti)(D)], personnel error [ Requirement 50.73(b)(2)(ii)(1)(2)),and corrective actions [ Requirement 50.73(b)(4)),

are 85, 86, 82, and 77, respectively. However seven of the fifteen LERs failed to present adequate date and/or time information; seven LERs inadequately addressed the root cause determination and identification; seven of nine LERs involving personnel / procedural error did not adequately discuss the details of the personnel error; and twelve of the fifteen LERs did not adequately discuss the corrective actions taken or planrmd to reduce the probability of recurrence of the event. Comments in Appendix D should be reviewed for specific comments concerning the deficiencies in the date/ time information and in the root cause, personnel error and corrective actions discussions.

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 a minimum, sunnarize the following information from the text:

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1. Cause/Effect What happened that made the event j

reportable.

2. Responses Major plant, system, and personnel responses that resulted because 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 arid 4

what was done or planned to prevent recurrence.

All of the above items had acceptable scores, except the corrective actions summaries. The cause summaries while having an acceptable ~ score ,

had minor problems in eleven of the LERs. Being sure to discuss all j corrective actions and causes discussed in the text will help eliminate  !

many of the problems found. The abstract presentation also had an adequate score, but six of the LERs had abstracts significantly shorter than the  ;

1400 spaces allowed which probably contributed to the problem in the corrective actions and cause summaries. 1 Coded Field Deficiencies and Observations I

The main deficiency in the area of coded fields involves the titles, Item (4). Ten of the titles failed to provide adequate cause information, four failed to adequately indicate the result (i.e., why the event was required to be reported), and eight failed to include the link between the cause and the result. While the result is considered the most important I

part of the title, the lack of cause information (and link, if necessary) I results in an incomplete title. Example titles are provided in Appendix 0 I

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. -(Coded Fields Section) for sone of the titles that are considered to be deficient.

SUMMARY

Table 3 provides a summary of the areas that need improvement for the Peach Bottom 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. 1 and 2.

It should be noted that this is the second time that the Peach Bottom

-LERs have been evaluated using the same methodology. The previous evaluation was reported in February of 1986. Table 4 provides a comparison of the scores for the two evaluations. As can be seen, the Peach Bottom LERs have improved since the original evaluation and are at present se;ghtly above the current industry overall average of 8.4. (Note: The industry overall average is the result of averaging the latest overall average score for each unit / station that has been evaluated using this methodology).

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lt TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR PEACH BOTTOM 2,3 LERs Areas Comments

' EIIS code EIIS should be used in the text for each component or system referred to in the text, not just failed components / systems.

l Safety train unavailability Sufficient dates and times should be l included in the text to enable the reader  ;

to determine the length of time that safety '

system trains or components were out of service.

Manufacturer and model number Component identification information should be included in the text whenever a component fails or (although not specifically required by current regulation) is suspected of contributing to the event because of its design.

Abstracts Cause and corrective actions discussed in the text should be summarized in the abstract.

Abstract presentation Abstracts should use the full 1400 spaces ,

available, and include a summary of all  ;

cause and corrective action information discussed in the text.

Coded fleids

a. Title Titles should be written such that they i better describe the event. In particular, cause information should be included in each title.

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4 TABLE 4. COMPARIS0N Of LER SCORES FROM PREVIOUS EVALUATION Report Date February-86 June-87 i

Text average 8.2 8.5 l Abstract average 7.3 I 8.3 q Coded fields average 8.5 9.1

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Overall average 8.0 8.5 13

c REFERENCES

1. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory Comission, September 1985.
2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Comission, September 1983.
3. Of fice for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 1. U.S. Nuclear Regulatory Comission, f ebruary 1984.

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1 APPENDIX A LER SAMPLE SELECTION INFORMATION FOR PEACH BOTTOM 2,3 l I

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TABLE A-1.' LER SAMPLE SELECTION FOR' PEACH BOTTOM 2,3 i Sanole Number LER Number -Unit Number Comments 1 86-006-01 2 ESF 2 86-010-00 2 ESF

-3 86-021-00 2 4 86-022-00 2 SCRAM 5 86-024-00 2 ESF 6 86-025-00 2 7 87-003-00 2 ESF 8 86-002-00 3 ESF 9 86-006-00 3 10 86-008-00 3 11 86-012-00 3 SCRAM 12 86-016-00 3 SCRAM 13 86-021-00 3 14 86-022 3 SCRAM 15 87-001-00 3 SCRAM,ESF i

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t APPENDIX B EVALUATION SCORES Of INDIVIOUAL LERS FOR PEACH BOTTON 2,3

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TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR PEACH BOTTOM 2,3 l

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LER Sample Number  !

I 1 2 3 4 5 6 7 8 l Text 8.7 7.0 8.1 8.5 9.2 E.2 8.0 8.9 Abstract 8.9 5.4 9.0 8.5 8.5 8.5 8.8 7.4 Coded Fields 8.5 9.0 8.5 9.3 9.5 9.0 9.8 9.5 l v

Overall 8.7 6.7 8.4 8.8 9.0 8.9 8.4 8.5 a i LER Sample Number 9 10 11 12 13 14 15 Avera

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Text 8.6 8.3 8.3 8.8 8.9 8.4 8.2 8.5 Abstract 8.8 8.2 9.3 9.1 8.8 7.1 7.8 8.3 Coded Fields 9.0 9.2 9.2 10.0 9.3 8.5 8.5 9.1 Overall 8.7 8.4 8.7 9.0 8.9 8.0 8.1 8.5

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

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O APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR PEACH BOTTOM 2,3 4

TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR PEACH BOTTOM 2,3-Number of LERs with I Deficiencies and Obs er va t i on<,

Sub-paragraph Paragraph a b-Description of Deficiencies and Observations Totals Totals ( l 50.73(b)(2)(ii)(A)--Plant operating 1 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(it)(B)--Discussion of the status 0 ( 8).

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)(it)(C)--failure to include 7 (15) sufficient date and/or time information.

a. Date information was insufficient. 1
b. Time information was insufficient. 6 50.73(b)(2)(ii)(DJ--The root and/or 7 (15) intermediate cause of the component.or system failure was not included or was inadequate.
a. Cause of component failure was not 5 included or was inadequate.
b. Cause of system failure was not 3 included or was inadequate.

50.73(b)(2)(ii)(E)--The failure mode, 0 ( 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 inadequate.
b. Mechanism (immediate cause) was not included or was inadequate.
c. Effect (consequence) was not included or was inadequate.

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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)(F)--The Energy Industry 10 (15)

Identification System component function identifier for each component or system was not included.

50.73(b)(2)(ii)(G)--for a f ailur e 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 that 3 ( 6) rendered a train of a safety system inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.

50.73(b)(2)(11)(Il--The method of discovery 1 (15) of each component failure, system failure, personnel error, or procedural error was not 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 1 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 0  :

procedural error 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 ( l b

50.73lb)(2)(ii)(J)(1)--Operator actions that 1 ( 3) 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 7 ( 9) each personnel error was not included or was inadequate.

a. OBSERVATION: A personnel and/or 0 procedural error was implied by the text, but was not explicitly stated,
b. 50.73(b)(2)(ii)(J)(2)(1)--Discussion 1 as to whether the personnel error was cognitive or procedural vas not

, included or was inadequa*.e.

i c. 50.73(b)(2)(ii)(J)(2)(11) -Discussion 2 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an l 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)(li)(J)(2)(tii)--Discussion 0 of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
9. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion 1

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l' (i.e., contractor personnel, utility j licensed operator, utility nonlicensed j operator, other utility personnel) was l not included or was inadequate. l C-3

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1 TABLE C-1. (continued)-

a Number of LERs with Deficiencies and Observations-i Sub-paragraph Paragraph a

i Description of Deficiencies and Observations- Totals Totals ( )b

' 50.73(b)(2)(ii)(K)--Automatic and/or maaual 2 (10).

safety system responses were not included or

.were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 3-( 5) model number of each failed component was i not included or was inadequate. l 50.73(b)(3)--An assessment of the safety 6 (15) consequences and implications of the event j- was not included or was inadequate.

l a. OBSERVATION: The availability of 3 other systems orLcomponents capable of mitigating the consequences of the event ~was not discussed. If no other systems or components were available, the. text should state that none existed.

b. OBSERVATION: The consequences' 2 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should so state.

50.73(b)(4)--A discussion of any corrective 12 (15) actions planned as a result of thri event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.

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e 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 O correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.
b. A discussion of actions required to 7 reduce the probability of recurrence of the prnblem or similar event (correct the root cause) was not included or was inadequate.
c. OBSERVATION: A discussion of actions 2 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 0 (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)(i)--Text presentation 2 (15) inadequacies.

a. OBSERVATION: A diagram would have 1 aided in understanding the text discussion.
b. Text contained undefined acronyms 1 and/or plant specific designators.
c. The text contains other specific 2' deficiencies relating to the readability,
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both cate 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.

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TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR PEACH BOTTOM 2,3 Number of LERs with' Deficiencies and Observations Sub-paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )

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

A summary of plant, system, and/or personnel 5 (11) 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 5 included or was inadequate.
c. Summary of personnel responses was not 0 included or'was inadequate.

A summary of the root cause of the event 11 (15) was not included or was inadequate.

A summary of the' corrective actions taken or 14 (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 a

Description of Deficiencies and Observations Totals Totals ( )

Abstract presentation inadequacies. 8 (15)

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

The abstract is intended to be a summary of the text, therefore, the text should discuss all information summarized in the abstract,

b. The abstract was greater than 0 1400 spaces.
c. The abstract contains undefined 0 acronyms and/or plant specific designators.
d. The abstract contains other specific 8 deficiencies (i.e., poor sunnerization, contradictions, etc.).
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
b. The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

C-8

l TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR PEACH BOTTOM 2,3 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a b Description of Deficiencies and Observations Totals Totals ( l Fatility Name 0 (15) l l

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. 13 (15)

a. Root cause was not given or was 10 inadequate,
b. Result (effect) was not given or was 4 inadequate,
c. Link was not given or was 8 inadequate.

Event Date 0 (15)

, a. Date not included or was incorrect.

b. Discovery date given instead of event date.

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

Report Date 1 (15)

a. Date not included or was incorrect. O
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 0 (15) inconsistent with text or abstract.

C-9

s TABLE C-3. (continued)

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

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

Reporting Requirements 0 (15)

a. The reason for checking the "0THER" requirement was not specified in the abstract and/or text.
b. OBSERVATION: It may have been more appropriate to report the event under a different paragraph.
c. OBSERVATION: It may have been appropriate to report this event under an additional unchecked paragraph.
d. No requirement was checked.

ticensee 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 2 (15)

a. One or more component failure 0 sub-fields were left blank, i
b. Cause, system, and/or component code 0 I is inconsistent with text. '
c. Component failure field contains data 0 when no component failure occurred,
d. Component failure occurred but entire 2 field left blank.

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C-10

TABLE C-3. (continued)

-Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph j a

-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 1 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 toth1.
b. The " paragraph total" is the number of LERs that have one or more j requirement deficiencies or observations. The number in parenthesis is the  !

number of LERs for which a certain requirement was considered applicable.

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! C-11

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APPENDIX 0 LER COMMENT SHEETS FOR PEACH BOTTON 2,3

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TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277)

Section Comments

1. LER Number: 86-006-01 Scores: Text = 8.7 Abstract - 8.9 Coded Fields - 8.5 Overall - 8.7 Text 1. 50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is inadequate. ,

It would be helpful to define the plant operating mode (e.g., cold shutdown), especially when in a zero power mode.

2. 50.73(b)(2)(it)(F)--The Energy Industry Identification System code for each component ard/or system referred to in the text is not included.
3. 50.73(b)(4)--It is not clear if the time delay will be left in the system logic after changing the power supply.

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

The fact that this is normally not a problem, when power is supplied through the motor generator set, was not nentioned.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The interim fix was not mentioned.

Coded fields 1. Item (4)--Title: Result is vague and the link and cause are not included. A more appropriate title might be " Containment Isolation and Half-Scram due to Low Power Supply Voltage While Starting a Pump". The use of acronyms in the title should be avoided unless space is a problem.

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l D-1

i TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277) 4 Section Comments

2. LER Number: 86-010-00 Scores: Text - 7.0 Abstract - 5.4 Codeo Fields - 9.0 Overall - 6.7 Text 1. 50.73(b)(2)(ii)(C)--Time information for the return to normal operation of the systems which isolated and tripped as a result of this event and the completion of repairs to the fire-damaged equipment is not included.
2. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the No. 1 transformer failure is inadequate. What caused the transformer to rupture? 4
3. 50.73(b)(2)(ii)(H)--A time estinate of the unavailability of the failed train / system is not included for the 'A' RHR. *
4. 50.73(b)(3)--Discussion of the assessment of the 4

- safety consequences and implications of the event is inadequate. OBSERVATION: The availability of other systems, components, or means (e.g. personnel actions, procedural requirements, etc.) capable of mitigating the consequences of the event were not  !

discussed. If no other systems, components, or means i are available, it would be helpful to state so in the text. What other systems were available to substitute for the "RWCU" and the 'A' RHR while they were tripped? What is the liklihood that personnel could have been in the vicinity of the transformer when it ruptured?

5. 50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included.
6. Acronym (s) and/or plant specific designator (s) are undefined for D/W, RWCV, TIP, ADS, B/U.
7. Some ideas are not presented clearly (hard to follow). A definition of "No. 3 Startup Source" l would be helpful.
8. OBSERVATION: A diagram or figure would aid in understanding the event.

D-2

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TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277)

Section Comments

2. LER Number: 86-010-00 (Continued)

Abstract 1. 50.73(b)(1)--Summary of the RWCU and RHR responses is not included.

2. 50.73(b)(1)--Summary of the root cause information for the transformer rupture is not included.
3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.
4. 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 is not included and link is inadequate. A better title might be:

" Transformer Rupture (Cause Unknown) Leads to 011 fire, Damaged Control Circuitry, Loss of 4KV Buses, and Containment Isolations".

I D-3

Q 4

TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277)

Section Comments

3. LER Number: 86-021-00 Scores: Text , 8.1 Abstract - 9.0 Coded Fields - 8.5 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(A)--The fact that the unit was in cold shutdown would have been good information to provide under the first heading (i.e., Unit Conditions Prior to the Event).
2. 50.73(b)(2)(ii)(C)--When was the work on the unblocked minimum flow valves actually started?
3. 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.

Component function identifier codes are not provided.

4. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is inadequate. At what time did the fuses fail, causing the valves to fail in their normally closed position?
5. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. It is not clear from the text discussion whether the inadvertent grounding affected both loops or only loop "A". The second paragraph under " Description of the Event" says - "the Core Spray System" could have been prevented from fulfilling its safety function. '
6. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Why did the inadvertent grounding occur? Why didn't the electrical construction personnel realize that the grounding caused (or might have caused) fuses to fail?
7. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What was done or planned to prevent future inadvertent groundings and unidentified fuse failures?
8. Some ideas are not presented clearly (hard to 1 follow). Some conclusions reached are inconsistent with the facts presented.

1 0-4

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' TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277) )

I Section Comments 1

3. LER Number: 86-021-00 (Continued) )

1

9. It is not clear whether both loops were involved in '

the EQ inspections.

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

inadequate. The abstract could mention the i

" inadvertent grounding".

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The ,

corrective actions in the abstract (and the text) don't address the inadvertent grounding and failure to realize the fuse failure on the part of the construction personnel.

3. It is not clear from the information in the abstract '

(or the text) why, if the event had of occurred at power, only Loop "A"'s safety function would have been affected. See text comment number 5.

Coded fields 1. Item (4)--Title: Result is not provided and the cause and link are inadequate. A better title might be " Personnel Error During Wire Replacement Causes fuses to Fail Resulting in the Core Spray System '

Minimum Flow Valves Failing Closed". ,

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l D-5

o TABLE D-1.

SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277)

Section Comments

4. LER Number: 86-022-00 Scores: Text = 8.5 Abstract = 8.5 Coded fields - 9.3 Overall = 8.6 Text 1. 50.73(b)(2)(ii)(C)--When were the corrective actions  !

completed?

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes for each component referred to in the text were not included.
3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Is it normal procedure to just cut the screens out? If not, who (type of personnel) was responsible?
4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. There is no discussion as to whether or not action was necessary to remove the already loose screen material from the valve and the rest of the system.

Abstract 1. 50.73(b)(1)--Summary of root cause is inadequate. j The details about how cutting out the screen left a l small ring of screen to get into the system was not discussed. >

2. 50.73(b)(1)--Summary of corrective actions taken or planned as e result of the event is inadequate. As in the text, the actions taken, if any, to remove the  ;

already loose screen material was not mentioned.

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

Coded fields 1. Item (4)--Title: The reason for the foreign material being present (personnel error) was not included. l 4

D-6

- _ _ ___ - - - A

a TABLE 0-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277) l Section Comments .

5. LER Number: 86-024-00 Scores: Text - 9.2 Abstract - 8.5 Coded fields = 9.5 Overall = 9.0 Text 1. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Was the technician properly trained with the test meter?
2. 50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is inadequate. Were other }

technicians warned of the importance of I attention-to-detail while performing such duties?

l

3. OBSERVATION: Although the malfunctioning of SV-2980  !

in itself probably would not have caused a reportable event, if this component failed, the root cause, failure mode, corrective actions, and manufacturer /model number should be provided.

Abstract 1. 50.73(b)(1)--Summary of the cause information concerning the technicians' proper training with the test meter is inadequate.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as,a result of the event is inadequate. The  !

counseling of the technician is not included. See  ;

text comment number 2. j Coded fields 1. Item (4)--Title: Link (during investigation of nm1 functioning valve) is not included.

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TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOT 10M 2 (277) j Section Conments 1 j

6. LER Number: 06-025-00 I l

Scores: Text - 9.2 Abstract - 8.5 Coded Fields - 9.0 Overall - 8.9 j Text 1. 50.73(b)(2)(ii)(C)--When did the NRC inspector bring the problem to the attention of the Shift Supervision and technical staff? j l

2. 50.73(b)(2)(ii)(F )--The Energy Industry )

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

Component function' identifier codes are not provided i (e.g., for bell,' diesel generator, switch). ]

1

3. 50.73(b)(3)--Discussion of the assessnent of the safety consequences and implications of the event is i inadequate. From what area or room can the Cardox system be manually actuated? It appears that it is j not good to assume that the operator would re-arm the I system upon actuation of the alarm, given that he failed to follow other guidance'(under a less stressful situation).

Abstract 1. 50.73(b)(1)--Sunnary of corrective actions taken or planned as a result of the event is inadequate. The revision to Surveillance Test ST 8.1 should have been mentioned in the abstract.

Coded fields 1. Item (4)--Title: Result (Technical Specification Non-Conformance) was not provided.

2. Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if 'l appropriate). Text does not say why.
3. Item (8)--Text does not indicate why Unit 3 was named as another facility involved. Assumption is that the diesel generator rooms involved are for both or different units.

D-8

I TABLE 0-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 2 (277)

Section Comments

7. LER Number: 87-003-00 Scores: Text = 8.0 Abstract = 8.8 Coded Fields = 9.8 Overall = 8.4 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes for each component referred to in the text were not included.
2. 50.73(b)(2)(ii)(J)(2)(il--The discussion of the personnel error does not indicate whether or not a procedural error was involved.
3. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is j inadequate. Justification needs to be provided that  !

more severe conditions would cause no safety problem. For example, the length of time that the RHR can be shut off without a problem even with a

' maximum decay heat load for the RHR could justify the 20 minute shutdown. If 20 minutes is too long with a maximum decay heat load for the RHR, then the consequences should be discussed.

OBSERVATION: The availability of other systems, components, or means (e.g. personnel actions, procedural requirements, etc.) capable of mitigating the consequences of the event were not discussed. If no other systems, components, or means are available, it would be helpful to state so in the text, i

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. How will new employees be made aware of the problem? More than counseling of the personnel appears to be needed, since this is the fifth incident of inadequately reviewed blocking permits. Is a procedural change or procedural warning needed? <

~

Abstract 1. The root cause and corrective action summaries are deficient for the same reasons as discussed in the text.

Coded Fields 1. No comments.

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0-9 1

TABLE 0-1.

SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278) .

{

Section Comments l

8. LER Number: 86-002-00 Scores: Text 8.9 Abstract = 7.4 Coded Fields = 9.5 Overall = 8.5 Text 1. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is {;

inadequate. OBSERVATION: The consequences of the j event had it occurred under more severe conditions '

were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text. OBSERVATION:

The availability of other systems, components, or means (e.g. personnel actions, procedural requirements, etc.) capable of mitigating the i consequences of the event were not discussed. If no other systems, components, or means are available, it would De helpful to state so in the text. What would have been the consequences had the time for the RWCU out of service been significantly longer than 2 minutes?

2. 50.73(b)(4)--A supplemental report would be appropriate to describe the results of the engineering evaluation of a design change to prevent recurrences if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

Abstract 1. 50.73(b)(1)--Summary of the 'C' RWCU pump trip is not included.

2. 50.73(b)(1)--Summary of the root cause of the de-energization of the RWCU outlet temperature switch is not included.
3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The immediate corrective actions are not mentioned.
4. 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 (personnel cognitive error) and link (during temperature switch maintenance) are not included.

D-10

l TABLE 0-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278) i Section Comments

9. LER Number: 86-006-00 l Scores: Text - 8.6 Abstract - 8.8 Coded Fields - 9.0 Overall - 8.7 Text 1. 50.73(b)(2)(11)(C)--When were the failed fuses replaced?
2. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning how the wires could have grounded and how the socket became loose is not included. ,

3 50.73(b)(2)(ti)(F)--The Fnergy Industry Identification System coue for each component and/or system referred to in the text is not included.

4. St.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included. See text comment number 1.
5. 50.73(b)(4)--Are there other similar panels in which light sockets could be loose (with similar end results)? If so, were these panels also checked for loose sockets and wires?
6. The " Acronyms Used" list is good!

Abstract 1. 50,73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. All the corrective actions provided in the text are not I mentioned in the abstract.

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

Coded Fields 1. Item (4)--Title: Cause and link are not provided. A i better title might be, " Loose Socket Wires (Cause Unknown) Causes Fuse Failure and Subsequent loss of 3A Core Spray Logic".

. 1 1

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's 8 TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278)  !

]

l Section Consnents

10. _LER Number: 86-008-00 Scores: Text = 8.3 Abstract = 8.2 Coded ftelds - 9.3 Overall = 8.4 I Text 1. 50.73(b)(2)(ii)(D)--Why/how was the contact dislodged?
2. 50.73(b)(2)(ii)(F)--The Energy Industry l Identification System codes for each component referred to in the text were 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 inadequate. It <

is not obvious if device number 538 is a manufacturer's model number or a plant specific l designator.

4. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is  :

inadequate. Any increased safety significance at a l higher power was not discussed.

5. 50.73(b)(4)--A discussion of actions required to-reduce the probability of recurrence (i.e correction of the root cause) is inadequate. Is any action necessary to prevent the contacts from becoming j dislodged again?

Abstract 1. The details about the root cause and corrective actions were not discussed.

2. 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 (HPCI inoperable) is inadequate.

1 0-12

TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278)

Section Comments I

11. LER Number: 86-012-00 Scores: Text - 8.3 Abstract - 9.3 Coded Fields - 9.2 Overall - 8.7 Text 1. 50.73(b)(2)(ii)(C)--Time information to restore the isolations and reactor water level is not included.
2. 50.73(b)(2)(ii)(f)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 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 is inadequate. Is the information that the fault protection for the #15 and #65 breakers is electrically interlocked contained in the testing procedure?
4. 50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The Group II/III systems are not defined.
5. 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 were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text. >
6. 50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is inadequate. Since the text contains inadequate information concerning the testing procedure for #15 and #65 breakers, it is not clear that the instruction to the personnel involved is sufficient to prevent recurrence of this event.

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D-13

e TABLE 0-1. SPECIFIC'LER COMMENTS FOR PEACH BOTTOM 3 (278)

}

Section Comments 11 ~. LER Number: 86-012-00 (Continued)

' Abstract 1. 50.73(b)(1)--Summary of the safety system responses is inadequate. See text comment number 4.

2. 50.73(b)(1)--Summary of the root cause information is '

inadequate. See text comment number 3.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 6.

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

I D-14

TABLE-0-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278)

Section Comments

12. LER Number: 86-016-00 Scores: Text = 8.8 Abstract - 9.1 Coded fields = 10.0 Overall - 9.0 Text 1. 50.73(b)(2)(11)(C)--The use of the phrase "a few l minutes" is acceptable, but the word "prcmptly" does not have a consistent meaning relative to time.
2. 50.73(b)(2)(11)(0)--The root and/or intermediate cause discussion concerning the switchyard fault is not included.
3. 50.73(b)(2)(ii)(H)--See text comment number 1.
4. 50.73(b)(2)(ii)(L)--Identification (e.g.,

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

5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What was done to prevent similar switchyard faults?. Given the problem with the DC MSIV coils appears to be recurring, what factors are being' considered to justify not replacing the DC coils each refueling outage?
6. The use of a diagram for discussions such as this is l a good practice.  ;

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. All the corr.ective actions discussed in the text were not mentioned in the abstract.

Coded fields 1. No comments.

D-15

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. e TABLE D-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278) j

'sec t ion Comments j l

1

13. LER Number: 86-021-00 Scores: Text = 8.9 Abstract - 8.8 Coded Fields - 9.3 Overall = 8.9 Text 1. 50.73(b)(2)(ii)(D)--The problem with the turbine speed indicator was not discussed.
2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.
3. 50.73(b)(2)(11)(I)--Discussion of the method of discovery of the high suppression pool level is not included.
4. 50.73(b)(2)(ii)(J)(2)(11)--Discussion 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 is not included. The corrective actions imply that the procedure was inadequate.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The change to ST-6.5 was not mentioned.

2. 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 (personnel / procedural error) is not included.

0-16

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TABLE 0-1. SPECIf1C LER COMMENTS FOR PEACH BOTTOM 3 (278)

Section Comments

14. LER Number: 86-022-00 Scores: Text = 8.4 Abstract = 7.1 Coded Fields - 8.5 Overall - 8.0 Text 1. 50.73(b)(2)(ii)(C)--Time information for when the filter element was replaced is not included.
2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the leaking valves in the

'E' Filter Demineralized is inadequate. Why were the i valves leaking?

3. 50.73(b)(2)(ii)(J)R)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility non11rensed operator, other utility personnel) is not included.

Who left the resin in the demineralized resin?

I i

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

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

Abstract 1. 50.73(bl G --Summary of the Group II/III system definitions and responses is inadequate.

2. 50.73(b)(1)--Summary of the root cause information  !

for the leaking demineralized valves is not included.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included. 4 1

l Coded fields 1. Iten. (4)--Title: Root cause information for the i leaking valves and for the personnel error and link '

(resin left in demineralized plenum) are not included.

2. Item (13)--Component failure occurred but entire field is blank.

1 D-17 1

j

TABLE D-1.

i SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278)

Section Comments

15. LER Number: 87-001-00 Scorcs: Text - 8.2 Abstract - 7.8 Coded fields - 8.5 Overall 8.1 Text 1. 50.73(b)(2)(ii)(C)--When (date) did the fans start experiencing mechanical failures (i.e., intermittent stops and starts)?
2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the pressure spikes and fan stops and restarts is inadequate. Weren't operations personnel aware of both of these situations prior to the scram? If not, why not? If so, why wasn't action taken prior to the scram?
3. 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.-

Components referred to in the text do not have a corresponding component function identifier code.

4. 50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. Those safety systems that " functioned properly" during the event should be named. '
5. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Are the five fans, that were electrically disconnected, going to remain disconnected until the fans in all six EHC electronics bays are replaced? If so, is this justified (i.e., why are only four fans needed)?

Does Unit 2 have the same kind of fans and if so were they examined? If additional corrective actions result from the continuing investigation, a supplemental report would be appropriate.

Abstract 1. 50.73(b)(1)--Summary of system responses is inadequate. There is no mention of safety systems functioning properly in the abstract.

2. 50.73(b)(1)--Summary of cause information is inadequate. The cause of the malfunctioning fans should have been mentioned in the abstract.

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  1. 1 TABLE 0-1. SPECIFIC LER COMMENTS FOR PEACH BOTTOM 3 (278) l e

Section Comments

15. LER Number: 87-001-00 (Continued) .

l

3. The abstract discusses the event as if everything happened almost at once (see text consnent numbers 1 and 2).

Coded Fields 1. Item (4)--Title: Cause (Malfunctioning fans) and link (Induced Electrical Noise) are not provided.

2. Item (13)--Component failure occurred but entire i l

field is blank.

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1 l

D-19

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