Text

Forwards AEOD Assessment of LERs for Sept 1986 - Aug 1987,as Part of SALP Program.Results of Evaluation Revealed That Facility Overall LER Quality Above Current Industry Average of 8.5 Points
	ML20235W709
Person / Time
Site:	Clinton
Issue date:	10/13/1987
From:	Norelius C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Gerstner W; ILLINOIS POWER CO.
References
	NUDOCS 8710160375
	Download: ML20235W709 (48)
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1981 OCT I1 A 9: 59 OCT 13 987 Docket No. 50-461 Illinois Power Company

~ ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th. Street Decatur, IL.62525 Gentlemen:

As part of the Nuclear Regulatory Commission's (NRC) Systematic Assessment of Licensee Performance (SALP) Program, the NRC's Office of Analysis and

' Evaluation 'of Operational Data ( AE00) perfonned an assessment of Licensee Event Reports (LERs) issued by Clinton during the period of September 1, 1986 through August 31, 1987.

This is the.first time Clinton's LER's have been evaluated by AE0D. This review provides an overview of the quality of the LER's by comparing the contents of the LER's to the reporting requirements of 10 CFR 50.72(b) and the guidelines contained in NUREG-1022. AE00 noted deficiencies in reporting the manufacture and model numbers of failed components, and indicated that the cause and corrective actions were not always summarized in the abstracts.

However, the results of AE0D's evaluation revealed that Clinton's overall LER quality is above the current industry average of 8.5 points, thus Clinton scored 9.2 out of a possible 10 points.

Enclosed for your review is a copy of AE00's evaluation of your LER quality.

Please contact us-if you have any questions.

Sincerely, 8hab cL Charles E. Norelius, Director Division of Reactor Projects i

Enclosure:

AE00 Assessment See Attached Distribution

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Licensing Fee Management Branch j

Resident-Inspector,-RIII Roy Wight,: Manager.

Nuclear Facility Safety

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Mark Jason, Assistant

~ Attorney General, Environmental Control Division Richard Hubbard J..W.McCaffrey, Chief, Public

. Utilities Divi _sion H. S. Taylor, Quality Assurance Division David Rosenblatt, Governor's-i Office of Consumer Services 1

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LICENSEE EVDIT HrJORT (I.ER)

Q@LITY EVAUATION FOR CLINION 1 IIJRDG 'IHE PERIOD Hm SEFIDER 1,1986 'IO AUGUST 31, 1987

SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) subtr.itted by Clinton 1 during the period from September 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. 1 and 2.

This is the first time the Clinton 1 LERs have been evaluated using this methodology.

The results of this evaluation indicate that the overall quality of the Clinton 1 LERs, for the three areas that are evaluated (i.e., the text, abstract, and coded fields), is above the current industry 1

average.

Clinton's average LER score is 9.2 compared to a current industry average score of 8.5.

The only important text requirement that is considered deficient is the requirement to identify (e.g., by manufacturer and model number) each component that fails during ar, event.

In addition, the abstract scores are less than they should be because cause and corrective action information, which was provided in the text, was not always summarized in the abstracts.

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LER QUALITY EVALUATION FOR CLINTON 1 INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee Event. Reports-(LERs) submitted by Clinton I during the period from l

September 1, 1986 to August 31, 1987, a sample of the unit's LERs was

.r evaluated. This evaluation was performed by comparing the contents of each LER to the reporting requirements of 10 CFR 50.73(b) and the guidelines 1

2 and 2.3 The contained in NUREG-1022 'and its Supplements No. 1 sample consists of a total of 15 LERs, which 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.

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.This is the first time that the'Clinton 1 LERs have been evaluated using the same methodology.

It was necessary to start the evaluction before the.end of the assessment period because the input was due such a f

short time after the end of the assessment period.

Therefore, those LERs j

prepared by the unit late in the assessment period were not available for j

selection, j

I METHODOLOGY The evaluation consists of a detailed review of each selected LER to j

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 I

compared to the guidance fer preparation of LERs presented in NUREG-1022 and Supplements No. I and 2 to NUREG-1022; based on this comparisen, suggestions were developed for improving the quality of the LERs.

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 k

" content" of these reports beyond the current requirements of 1

10 CFR 50.73(b).

Therefore, statements in this evaluation that suggest r

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n measures be taken are not intended to increase requirements and should be j

viewed in that light.

However, the minimum requirements of the regulation 1

must be met.

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The evaluation process for each LER is divided into two parts.

The first part of.the evaluation consists of documenting comments specific to the content and presentation of each LER.

The second part consists of

' determining a score' (0-10 points) for the text, abstract, and coded fields l

of each LER.

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The LER specific comments serve two purposes:

(1) they point out what the. analysts considered to be the specific deficiencies 'or observations I

4 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 i

categories:

(1) detailed information and (2) summary information.

The l

detailed information,. presented in Appendices A through D, consists of !.ER sample information (Appendix A), a table of the scores for each sample LER l

( 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 j

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 I

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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J 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 1 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 j

units / stations that have been evaluated using the current methodology is I

provided on Figura 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: The previous score for those units / stations that i

are reevalu'ted is replaced with the score from the latest evaluation).

Table 2 an. Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1.

For example, Clinton l's i

average score for the text of the LERs that were evaluated is 9.2 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 j

percentage scores for the various 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 oifficulty when preparing LERs.

Relatively low petcentage scures may indicate that the unit needs additional guidance concerning these requirements, or it may indicate that the unit understands the basic requirement but has either:

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TAELE 1.

SUMMARY

OF SCORES FOR CLINTON 1 1

l Average High Low 4

Text 9.2 9.9 8.3 Abstract' 8.9 9.8 7.5 Coded Fields 9.7 10.0 9.0 Overall 9.2 9.7 8.2 c.

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 CLINTON 1 A

.LTEXT Percentage a

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I (2)(ii)(A)

- Plant condition prior to event 87 (15)

Inoperable equipment that contributed b

(2)(ii)(B)

(2)(ii)(C)

- - Date(s) and approximate time (s) 92 (15)

(2)(ii)(D)

- Root cause and intermediate cause(s) 95 (15)

(2)(ii)(E)

- Mode, m(chanism, and effect 100 ( 6)

(2)(ii)(F)

- - EIIS codes 33 (15)

(2)(ii)(G)

- Secondary function affected b

(2)(ii)(H)

- - Estimate of unavailability 17 ( 3)

(2)(11)(I)

- Method of discovery 97 (15) s :

(2)(ii)(J)(1) - Operator actions affecting course 100 ( 3)

( 2 ) ( ii ) (J') ( 2 )

Personnel error (procedural deficiency) 95 ( 8) l

( 2 ) (ii ) -( K)

--- Safety system responses 100 (11) r (2)(ii)(L)

- Manufacturer and model no. information 50 ( 6)

(3) - - - - - - Assessment of safety consequences 95 (15) l (4) - --

- - - Corrective actions 93 (15) h5)

~.- - - Previous similar event information 100 (15)

(2.)(i)

- - - - Text presentation 94 (15) l' l

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ABSTRACT l

Percentage a

Requirements [50.73(h)(1)] - Descriptions Scores ( )

- Major occt. :rences(immediate cause/effect) 98 (15)

Plant / system / component / personnel responses 100 (11)

- Root cause information 88 (15)

Corrective action information 77 (15)

- Abstract presentation 84 (15) 6

TABLE 2!

(continuad) y jiCODEDFIELDS:

Percentage-a-

Item Number (s)

Descriptions Scores-( )

11',f2,Dand 3 -

Plant name(unit #).,

docket #, page as 100 (15).

4! - - - -

Title 87 (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) 11' - - - - -

Reporting requirements 100 (15) 12

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Licensee contact information 100 (15)-

13 Coded component failure information 100 (15) i 14 and 15 Supplemental' report information,/

100 (15) a; Percentage scores are the result of dividing the total points for a

requirement by the number of points possible for that requirement.

(Note:

Some requirements are not applicable to all LERs; therefore, the.

number of points possible was adjusted accordingly.)

The number in parenthesis is the number of LERs for which the requirement was considered applicable.

b.,

A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether-this requirement is applicable to a specific LER.

It is always given 100%

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

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( 3) excluded certain less significant information from a number of the l

, 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 0 to determine why it received less than a perfect score for a requirement.

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 provide adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was not included in three of the six LERs involving a' failed component.

In most cases this requirement can be met by simply providing the manufacturer and model number for each failed component.

For certain components (e.g., pipes, fitting, etc.)- the material and size of the failed component may be more appropriate

' n f orma ti on. Whatever information is provided, it should be specific enough to allow the reader to determine if the failed cc ponent 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 de: sign 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.

An estimate for the elapsed time of safety system train inoperebility, Requirement 50.73(b)(2)(ii)(H), was not provided for two of the LERs involving train unavailability, This requirement can usually be met by providing adequate dates and times for the occurrences discussed in the text.

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-The Energy.3ndustry Identification System (EfIS) component function

' dentifier and/or sy' stem name codes were not provided or were only i

partially provided in 11 of the LERs.

These codes should be provided for-all compone'nts.and systems referred to in:the text.

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Abstract Deficiencies and Observations While there are no specific requirements for an abstract, other than those given in.30 CFR 50.73(b)(1), an abstract should, as stated in NUREG-1022, Supplement No. 2, summarize the following information from the l

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 were not adequately addressed in seven and twelve of the LERs, respectively.

In most instances, the problem was one of not mentioning or summarizing information that was available in the text.

Cause and corrective action information should take precedence over safety assessment and deportability information if space is a problem.

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addition, five abstracts had minor problems in the area of presentation; l

I see the abstract comments in Appendix D.

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i Coded Fields Deficiencies and Observations A minor deficiency (the titles are generally good) in the area of coded fields involves the titles, Item (4).

Three titles failed to include adequate cause information, two failed to include an adequate result of the event and four 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 included to make a title complete.

Example titles are presented in Appendix D for many of the LERs that were considered to have poor titles.

SUMMARY

Table 3 provides a summary of the areas that need improvement for the Clinton 1 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 first time that the Clinton 1 LERs have been evaluated using the same methodology;'their scores are very good for a first-time evaluation.

Clinton l's overall average LER score (9.2) is well 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.)

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I TABLE 3.

AREAS MOST NEEDING IMPROVEMENT FOR CLINTON 1 LERs 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.

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 1

system trains or components were out of service.

EIIS codes EIIS codes should be provided in the text for each component 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 include cause and result information and the link between them in each title.

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s, REFERENCES 1.

Office for Analysis and Evaluation of.0perational Data, Licensee Event t'*

Report: System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.

.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.

.3.

Office for Analysis and Evaluation of.0perational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory Commission, September 1985.

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i APPENDIX A IER SAMPIE SEIECTION i

INFOWATION FOR CLDTION 1 l

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p, hp TAEE A-1.. IER SAMPIE SELECTICH KR CLINIW 1 1:

Sanple Naber IIR Number Cumr.aits 1-86-005-00 1

2 86-010-00 SCRAM l

3 86-016-01 4

86-019 ESF 5

'86-020-00 ESF i

.6 86-021-00 ESF 7

86-024-00 ESF 8

87-001-01 ESF l

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87-003-00 ESF 10 87-014-00 ESF 11 87-015-00 12 87-017-00 SCRAM 13 87-025-00 SCRAM 14 87-029-00 SCRAM

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APPENDIX B EVAIIATION SCORES OF INDIVIDUAL LERS FOR CLINION 1 l

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" TABLE B-l'.

EVALUATION SCORES OF INDIVIDUAL LERS FOR CLINTON-1 m,

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LER Sample Number 1

2 3:

4 5

6.

7 8

. Text' 9.6 9.5 9.6

. 9.1 9.5 9.5' 9-6' 9.3.

' Abstract 9.4' 9.5 8.5 9.5 9.8 9.2

'9.0 9.0 L

Coded.' Fields-9.8 10.0-

9. 5 9.0 9.5

.9.5 9.0 10.0

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Overall-9.5 9.6 9.2 9.2 9.6

9. 4' 9.4 9.3 a

LER Sample Number 9

10 11-12 13 14 15 Average 1

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- Text-8.5.

9.9' 9.1 9.8 8.3 8.3 8.8 9-2 Abstract

8. 7 -

8.0 8.8 9.5:

8.3 7.5-8.5 8.9 l

l Coded Fields

9. 8 -

9.5-10.0 10.0 9.7 9.5 10.0 9.7 Overall B.7 9.3 9.1

.9.7 8.4 8.2 8.8 9.2 1

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

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DEFICID1CY M1D OBSERVATION COUNIS FOR CLINION 1 i

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TABLE C-1.

TEXT DEFICIENCIES AND OBSERVATIONS FOR CLINTON 1 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 3 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 6) 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.

1 b.

Time information was insufficient.

4 50.73(b)(2)(ii)(D)--The root and/or 3 (15) intermediate cause of the component or system failure was not included or was inadequate.

a.

Cause of component failure was not 2

included or was inadequate, b.

Cause of system failure was not 1

included or was inadequate.

50.73(b)(2)(ii)(E)--The failure mode, 0 ( 6) 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, C-1

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TABLE C-1.

(continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations __ Tota 15 Totals (

)b 8

's 50.73(b)(2)(ii)(F)--The Energy Industry 11 (15)

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

50.73(b)(2)(ii)(G)--For a failure of a

-- ( 0) component with multiple functions, a list of systems er secondary functions which 1

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were also affected was not included or was 1

l inadequate.

1 50.73(b)(2)(ii)(H)--For a failure that 3 ( 3) rendered a train of a safety system j

inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.

-su 50.73(b)(2)(ii)(I)--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 0

failure 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

TABLIC-1.. '(continued)'

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph j

Description of Deficiencies and Observations _ Totals" Totals (-

)b i

50.73(b)(2)(ii)(J)(1)--Operator actions that 0 ( 3) affected the course of the event: including operator errors and/or. procedural deficiencies were not included or were

= inadequate.

50.73(b)(2)(11)(J)(2)--The discussion of 2 ( 8) each personnel error was not included or was l

. inadequate.

1 a.

OBSERVATIONS A personnel error was 0

implied by the text, but was not explicitly stated..

I b

~ 50.73(b)(-2)(11)(J)(2)(1)--Di scussion 0

I as to whether the personnel' error was cognitive or procedural was not included or was inadequate.

c.

50. 73( b)( 2 )( i i )(J )( 2 )( i i )--Di s c u s s i on 0

as to.whether.the personnel error was contrary to an approved procedure, was

=a direct result of an-errcr 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)( i i )(J )( 2 )( i if--Di sc u s s i on 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, e.

50. 73( b)( 2 )( 11 )(J )( 2)( i v)--Di s c u s s i on 2

of the type of personnel involved j

(i.e..; contractor personnel, utility

--licensed operator, utility nonlicensed j

operator, other utility personnel) was j

not. included or was inadequate.

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. ABLE C-1; (continued) j l

Number of LERs.with Deficiencies and Observations Sub-paragraph

. Paragraph Descrip' ion of 0 deficiencies-and Observations Totals' Totals (

_)b t

1.-

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- 50.73(b)(2)(ii)(K)--Automatic and/or-manual 0 (11) l

. safety system responses were not included or were inadequate.

l 50.73(b)(2)(ii)M--The manufacturer and/or 3 ( 6) codel number of each failed component was r.ot included or was inadequate.

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~ 50.73(bj g --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 0

of'the event had it occurred under more severe conditions'were not discussed.

If the event occurred

.under what were considered the most i

severe conditions, the text should so i

state.

50.73(b)(4)--A discussion of any corrective 4 (15)

I actions planned as a result of the event a

including those to reduce the probability I

of similar events occurring in the future was not included or was inadequate.

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a.

TABLE C-1.

(continued) i

-Number of LERs with Deficiencies and.

Observations.

,j Sub paragraph Paragraph' Description of Deficiencies'and Observations Totals" Total s --(-

)b j

a.

A discussion of _ actions required to '

0

' correct the problem (e.g., return the component or system to an operational

-condition or-correct the personnel-

)

error) was not included or.was l

inadequate.

b.' : A discussion of actions required to 2

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. reduce the pro"cability of recurrence.

of the problem or similar event (correct the root cause) was not I

included or was inadequate.

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c. '0BSERVATION: A discussion of actions 0

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

correct the faulty part'in all components with the same manufacturer and model-number) was'not included or i

vas inadequate.

l 50.73(b)(5)--Information concerning previous 0.(15) i similar events was not included or was

)

' inadequate.

1 C-5

c.

?TABLELC-1. 1(continued)'

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V.

Number of LERs with Deficienciesiand-Observations Sub paragraph Paragraph

~ Description-of Deficiencies and Observations Totals

Totals (

)b 50.73(b)(2)(1)--Text presentation 1 (15) inadequacies.

a.

OBSERVATION: _ A diagram would have 0

aided in understanding-the text

-discussion, b.

Text contained undefined acronyms 0

and/or, plant specific designators.

c.

The text contains'other specific 1

deficiencies relating to the readability,

a..The."sub paragraph total" is a tabulation of specific deficiencies or I

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.

J

'i (j

l I

i C-6 I

o

TABLE C-2.

ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR CLfNT.ON 1 r

c

. Number of LERs with Deficiencies and I

Observations i

Sub paragraph Paragraph Description of Deficiencies and Observations Totals Totals (

)b a-h A: summary of occurrences (immediate cause 2 (15)

L and effect) was not included or was inadequate.

A summary of plant, system, and/or personnel 0(11).

responses was not included or was inadequate, a.

Summary of plant responses was not included.or was inadequate.

b.

Summary of system responses was not i

included or was inadequate.

'c, Summary of.personneT 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 12 (15) planned as a.' result of the event was not included or was inadequate.

l C-7

TABLE.C-2.l(continue'd)

L.

Number of LERs with Deficiencies and-Observations l

Sub paragraph Paragraph Description of Deficiencies and Observations Totals Totals (-

)b a

Abstract presentation' inadequacies.

6 (15).

a.

OBSERVATION: The abstract contains 3

information not included in the text.

The abstract is intended to be a i

summary of the text, therefore, the text should discuss all information summarized in the abstract.

-b.

The abstract was greater than 1

1400 spaces.

c.

The~ abstract'contains undefined 0

acronyms'and/or plant specific designators, d.

The abstract contains other specific =

2 deficiencies (i.e., poor summarization, contradictions,etc.).

a.

The "sub paragraph total" is a tabulation of specific deficier:ies 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.

l i

C-8 i

i l

1

~

, j;,.j'

/'

)

5:

1': TABLE 'C-3.

'. CODED FIELDS.DEFICZENCZES AND OBSERVATIONS FOR CLINTON?lf u

. Number'of LERs with

. Deficiencies and.

l Observations e

i7 Sub paragraph' Paragraph

!d Description of' Deficiencies'and Observations' Totals Totals (

')b a

= Facility Name 0(15)

,s

'a, tUnitLnumber was:not~ included or 3

incorrect.

.b..

Name was not included'or was.

incorrect.

'c.

Additional unit numbers were included butLnot required.

t Docket Number was.notLincluded or'was 0 (15):

1 incorrect.

- Page. Number was not' included or.was 0(15) incorrect.-

1

.. Title was;left blank or.was inadequate.

'8(15) 1 a.

Root cause was not'given or was 3

inadequate, b.

Result (effect) was not given'or 2

was inadequate, c.

Link'was not given or was 4

q 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) l a.

Date not included.

~0 l

b.

OBSERVATION:

Report date was not 1

l

.within thirty days of event date (or I

discovery date if' appropriate).

I f

1 C-9 l

l

\\

?

i. 3 ;

TABLETC-M L(continued),

o

[..

Number of LERs with l'

Deficiencies and Observations L

l:

l;

.Sub paragraph'

. Paragraph j,

Description of Deficiencies and Observations Totals Totals (

.)b a

l Other' Facilities informationLin field is

'O(15) inconsistent with text,and/or' abstract.-

l 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. '0BSERVATION:- 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.

Licensee' Contact 0 (15)

~

a.

Field left blank.

b.

Position title was not included, c.

Name was not included.

d.

Phone number was not included.

l Coded Component Failure'Information 0 (15) a.

One or more component failure sub-fields were left, blank.

-b.

Cause, system, and/or component code is inconsistent with text, c.

Component failure field contains data when no component failure occurred.

l d.

Component failure occurred but entire field left blank.

l j

i l

C-10

TABLE C-3.

(continued)

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

)b 8

s

,, e l

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.

u Expected submission date information is 0 (15) inconsistent with the block checked in Item (14).

a.

The "sub paragraph total" is a tabulation of specific deficiencies or observations within certain requirements.

Since an LER can have more than one deficiency for certain requirements, the sub paragraph totals do not necessarily add up to the paragraph total.

b.

The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations.

The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

e e

C-11

-m_---_

m-_.

i e

a I

d

[

APPDOIX D LER CatDn' SHEPS EDR CLINION 1 4

l 1

\\

l l

l

ETABLE D-1.

SPEC!FIC LER COMMENTS FOR CLINTON 1 (461)

Section Comments 1

1.

LER Number: 86-005-00 Scores: Text = 9.6 Abstract = 9.4 Coded Fields = 9.8 Overall = 9.5 1

Text 1.

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.

2.

50.73(b)(2)(ii)(I)--More detail about the type of review (e.g., daily surveillance) would be helpful.

In other words why was the review being done? This information was stated more clearly in the Abstract, but still doesn't indicate how of ten " routine" is.

Abstract 1.

50.73(b)(1)--Summary of cause is vague..The abstract.

doesn't make it clear that the employee was negligent in performing his duties.

2.

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 abstract contains details not noted in the text [e.g., the times of the first missed fire watch and more detail about the review (see text i

comment 2)).

{

Coded Fields 1.

No comment.

I

~

j D-1 i

i

(')l.

[

o.

TABLE'D-1.. SPEC 3FIC LER COMMENTS FOR CLINTON 1 (461)

Section Comments

'2..

LER' Number: 86-010-00 21 Scores:. Text = 9.5 Abstract = 9.5 Coded Fields = 10.0~

Overalll=9.6 Text

'1.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each compor,ent and/or 1 system referred to'in the text is not included.

Abstract' 1.

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

]

immediate corrective' actions to temporarily defeat the MSL radiation detector channels is not mentioned.

Coded Fields 1.

No comment.

e D-2 1

4

.4,

TABLE D-1.

SPECIF!C LER COMMENTS FOR.CL8NTON 1 (461)

]

l Section Comments 1

3, LER. Number: 86-016-01 Scores: Text = 9.6 Abstract = 8.5 Coded Fields = 9.5

- Overall = 9.2 Text

1. -

How did new information become available (the information that prompted this revision)?

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.

The use of " revision bars" in the margin is good.

Austract 1.

50.73(b)(1)--Summary of cause information is inadequate. The abstract says the entire Standby Gas i

Treatment System was removed from service while the text says Train B was removed from service.

2.

50.73(b)(1)--Summary of corrective actions taken or l

planned as a result of the event'is inadequate.

The

. \\..

revision to procedure CPS 3007.02 was'not mentioned in the abstract.

Coded Fields 1,

The title lacks some detail.

A better title might be i

" Failure of Operator To Recognize Technical L

l Specification (TS) Requirements Concerning LCDs I

Causes Violation of TS 3.0.4".

7 1

l.

i l

l l

L l

l D-3 Lr

________-_________-____-__-----a

[

yQ

Y r,

.~

. TABLE D-1.

SPECIFIC; LER COMMENTS FOR CLINTON gs (461)

(,

' ti 1

N Section Comdents

't a

4.

LER Number: 86-019-01 V

' )f I

?

r Scores: Taxt = 9.1 Abstract = 9.5 Coded Fields = 9.0, Overall = 9.2 g

t 7 ;y 3

Text 1.

50.73(b)(2)(ii)(A)--A brief descript(on of the' C :.)

operating mode was not* included with hach operating

?

i 4

l mode number referred.to in the text. (/

'l,.

'2.

50.73(b)(2)(ii)(F)--The Energy IndustNy' f

Identification System code for. eacli corpc. pent and/or-system referted to in the text is not 1ncEuded.

l 3.

50.73(b)(4) 41n,the last paragraph.of the Corrective s

Action Section a reference is made.to " temporary

?

i d

modifications, but tFf.(text isn't clear what these t

j

,i

. modifications were.

1 i '

4.

The text is not clear a$o}Jt how long) tie i'B" i

ventilation system was in the'High Rad'.ation Mode.

i i

Did it remain in tthis moda ias lonb}as' it was tripped

- # # j' : i downscale?

^

j.

, J ;'

1 4

Abstract 1.

50.73(b)(11--Thecorrectiveactionsummaryhasthe

('

y same deficiency as the text (see text comment 4).

2.

The abstract contains gr' eater than 1400 spaces.

If j

space is needed or the abstract is' too long, it is'

),'

okay to eliminate the summary of the safety 3i N i' consequences and deportability.

j,

,c

'\\

Coded Fields 1.

Item (4)--Title:

9esult is-inadequate and;cause

l-i\\

i information is not'iricluded. A more appropriate title might be "En.dtgency Ventilation System Actuation from Spurious High Radiation Monitor Signal l

due to Improperly Seated Electrical Boy".

-i

(

.i b

L l

i D-4

Lf

,. y,'

. TABLE D-1.

, SPEC 3F2C LER COMMENTS:FOR CLINTON 3 (461) t w

l.

~ Section Comments L,

5.

LER Number:

86-020-00 l.

Scores: Text = 9.5

.hbstract = 9.8 Coded Fields ='9.5-Overall = 9.6 Text.

1.

50.73(b)(2)(11)(F)--The-Energy Industry Identification System code for each cornponent and/or system referred to-in the text is not included.

F-

' Abstract' 1.

No comment.

Coded Fields' 2.

Item (4)--Title:

Cause (rust particulate in transmitter) is' inadequate.

4

)!f Os

'}'1 4

3 z.,

t ep e

y'l

.r

. 'f D-5 i

g:

TABLE D-1.-

SPECfFIC LER COMMENTS FOR CLINTON 1 (461).

Section' Comments

'6.

LER Number: 86-021-00 Scores:. Text = 9.5 Abstract = 9.2 Coded Fields = 9.5 Overall = 9.4-Text.

1.

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.

2.

50.73(b)(2)(ii)(J)(2)(iv)--Who (by. type of personnel) experienced difficulty in reading the logic diagrams?

Abstract 1.

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

None of the contributing factors were mentioned.

2.

50.73(b)(1)--Summary of corrective actions taken or

{

planned as a result of the event is inadequate.

There are'too many corrective actions to summarize them all in the abstract but the aspects concerning

. l personnel (i.e., the training and counseling could j

have been mentioned).

Coded Fields

-1.

Item (4)--Title:

Link (while performing maintenance activity) is not included.

O i

i l

l 1

D-6 l

1

J a

. TABLE D-1.

SPECIFIC LER COMMENTS TCA CL1NTON 1 (461)-

+

,g

+x e

\\

Section-Comments 7.

LER Number: '86-024-00

+

Scores: Text = 9.6 Abstract = 9.0' Coded Fields = 9.0 Overall = 9.4 i

-Text 1.

50.73(b)R](Ji)(A)--Thetermshutdownneedsfurther explanation so the reader will'know the plant.

i condition (e.g., cold, hot,'or refueling shutdown).

2.

50.73(b)Rj(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

Abst-act 1.

50.73{,blO,1Spacetodothiscouldbemadeby

-More summary of the corrective actions is needeo.

elimtrating the summary of the deportability and the safety anessment.

2.

OBSERV4 TION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract.

This abstnet contains information that was not included in the text. The initial plant conditions are described better in the abstract than in the text (see tut comment 1).

' Coded Fields 1.

Item (4)--Title:

Link (during maintenance activities) is not included.

2.

Item (7)--0BSERVATION:

Report date is not within thirty days of event date (or discovery date if appropriate).

l l

l L

D-7 r

L.

4.'

.a

)

TABLE'D-1.

SPECfFIC LER COMMENTS'FOR CLfNTON'1:(461) 1 J:

.)

Section Comments

'8.

LER Number:

87-001-01 Scores: Text = 9.3 Abstract =.9.0 Coded Fields = 10.0.

Overall = 9.3' i

Text 1.-

50.73(b)(2)(ii)(A)--Information concerning the plant operating. conditions before the event is not included.

2.

50.73(b)(2)(ii)(F)--The Energy Ind'ustry Identification System ' for each component and/or system referred to in t...

text is not included.

Abstract

.1.

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

The calibration checks of the level transmitters and the checks of other instruments with common sensing lines and power supplies are not mentioned.

2.

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 plant operating conditions are not included in the text.

Coded. Fields 1.

No comment.

i D-8 l

___--__--_-_a

TABLE D-1.

SPEC 1FIC LER COMMENTS FOR CL!NTON 1 (461)

Ll.

Section Comments o

9 '.

LER Number:.87-003-00 H

Scores: Text = 8.5 Abstract = 8.7 Coded Fields = 9.8 Overa ll =. 9.7 Text-1.

50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the broken pin is inadequate. Why was the pin broken? Was the second actuation also the result of placing the switch in the," unload" position?

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)(L)--Identification (e.g.,

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

4.

50.73(b)(3)--Was the 0.1 ppm chlorine reading also the result of the broken pin?

If not, what was the reason for the higher than normal reading?

Abstract-1.

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

Those corrective actions designed to prevent recurrence (fix the problem) were not mentioned.

2.

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

Coded Fields 1.

Item (4)--The title does not indicate that the "high chlorine mode" is an Engineered Safety Feature.

s D-9

i

)

ETABLE D-1.

SPECIFICLLERCOMMENTSLFORCLINTON;l(461) 3

.]

Section Comments j

l

'10.

LER-Number:.87-014-00

{

J

' Scores:

Text'= 9.9 Abstract = 8.0 Coded Fields'= 9.5 Overall = 9.3

. Text l '. -

50.73(b)(2)(ii)(C)--When were the systems. secured?

Abstract 1.

50.73(b)(1)--Summary of cause is inadequate. The fact that the technician failed to follow the

. procedure was not made clear.

2.

50.73(b)(1)--Summary of corrective' actions to prevent i

recurrence of this event are not included.

3.

If space is needed for the items discussed above the deportability and safety assessment summaries could' 1

be left out of the abstract.

Coded Fields 1.

Item (4)--Title:

Link. (while performing a calibration procedure) is not_ included.

Since the

. title is already getting long some' details in the title could be eliminated.

For example, the title might read "High Pressure Core Spray Actuation during-Calibration Procedure due to Technician's Error".

i

)

I i

)

D-10 l

1

TABLE D-1.

SPECIF1C LER COMMENTS FOR CLlNTON 1 (461)

Section Comments 11.

LER Number: 87-015-00 Scores: Text = 9.1 Abstract = 8.8 Coded Fields = 10.0 Overall = 9.1 Text 1.

50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Were the procedural deficiencies in the area of snubbers corrected?

Since two more procedural deficiencies were identified from the " expanded sample" of audited surveillance procedures, could any other deficiencies have occurred that weren't audited?

Abstract 1.

50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is not included for the snubber procedural deficiencies.

2.

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

The audit of other procedures is not mentioned.

ML20235W709

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