ML20238A696

LER Quality Evaluation for Summer During Period Jan 1986 - Jul 1987

ML20238A696
Person / Time
Site:	Summer
Issue date:	09/02/1987
From:	NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:
Shared Package
ML20238A157	List: ML20238A154 ML20238A696
References
NUDOCS 8709090391
Download: ML20238A696 (56)

Text

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ENCLOSURE LICENSEE EVDE REPORP (IER) auAtxrY EVAWATION FOR SumER DURING 'IEE PERIOD FRCH JANUARY 1.1986 'IO JUIX 31 1987

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SUMMARY

An evaluation of the content and quality of a: representative. sample of

-the Licensee Event Reports-(LERs) submitted by Summer during the period from January 1, 1986 to July 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. l'and 2.

This is the second time the Summer LERs have been evaluated using this methodology. The resulis of this evaluation indicate that, while the overall quality of the Summer LERs, for the three areas that are evaluated (i.e., the text,'ab'stract, and coded fields),'has improved somewhat since the previous evaluation, the improvement was.less than was expected. The first evaluation's overall. average LER score was 7.4, which was.slightly below the. industry average (7.6) at that time. For the current evaluation, Summer's overall average LER score is 8.1, which is still below th'e current industry average LER score (8.4). The quality of most text discussions remained' virtually unchanged from the previous evaluation with the exception of the safety consequence discussions and the identification of failed components, both of which improved somewhat but continue to be below average.

In addition to the requirements to discuss the safety consequences of the event and to adequately identify failed components being considered deficient, five other important text requirements have scores that are below average. They are.the requirements to adequately discuss root cause, corrective actions, personnel error, operator actions that affected the course of the event, and safety system responses. It was noted however, that starting in 1987 the LERs were written using an outline format (i.e.,

the last five LERs in the sample). The average score for'these LERs may be indicative of an improvement beyond that shown for the entire sample.

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SUMMER-l l>

INTRODUCTION In' orcier to evaluate the overall quality of the contents;of the Licensee Event Reports (LERs) submitted by. Summer during the period from h

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. January 1,.1986 to. July 31, 1987, a sample of the unit's LERs was evaluated. This evaluation was performed by comparing the contents of each-LERlto the reporting requirements-of 10 CFR 50.73(b) and the' guidelines?

1 contained in NUREG-1022 .and its Supplements No. 1 2 and 2.3 The 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.

This is the second time that the Summer LERs have been evaluated using the same methodology. As before, it was necessary to start the evaluation before the end of ~ the assessment period because the input was due such a short time after the-end of the assessment period. Therefore,.those LERs prepar_ed by the unit late in the assessment period were not available for -

selection.

METHODOLOGY The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the criteria of 10 CFR 50.73(b). In addition, each selected LER is compared'to the guidance for preparation of LERs presented in NUREG-1022 and Supplements No.1 and 2 to NUREG-1022; based on this comparison, suggestions were developed for improving the quality of the LERs. The p'urpose of this evaluation is to provide feedback to improve the quality of LEP.s . It is not intended to increase the requirements concerning the

" content" of these reports beyond the current requirements of 10 CFR 50.73(b). Therefore, statements in this evaluation that suggest 1

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meas'ures be taken are not intended to increase requirements and should be-

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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 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 perce'aved 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 '(1.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 categcries: (1) detailed information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER r sample information (Appendix A), a table of the scores for each sample LER (Appendix B), tables of the number of deficiencies and observations for the text, abstract and coded fields-(Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to Appendix D, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analysts have flexibility to consider the magnitude of a deficien'cy when assigning scores (e.g., the analysts sometimes make comments relative to a requirement without deducting points for that requirement).

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,- TABLE . ' 1. .udMARY OF SCORES. FOR SUt91ER-1.:

Average High Low Text: 7.6 9.5 5.2 Abstract 8.8 9.8 7.6

'Ccded Fields.

B.6 9.2 7.9 Overall- 8.1 9.2 6.5

. 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 SUMMER TEXT Percentage a

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

(21(;;)(A) - - Plant condition prior to event 63 (15)

(2).ii)(B)

Inoperable equipment that contributed b (2)ti;)(C) - - Date(s) and approximate time (s) 88 (15)

-(2)(ii)(D; - - Root cause and intermediate cause(s) 83 (15)

(2)(ii)(E) - - Mode., mechanism, and effect 100 ( 4)

(2)(ii)(F) - - EIIS codes 0 (15)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 67 ( 3)

(2)(ii)(I) - - Method of discovery 90 (15)

(2)(ii)(J)(1) - Operator actions affecting course 83 ( 5)

(2)tii)(J)(2) - Personnel error (procedural deficiency) 72 (10)

(2)(ii)(K) - - Safety system responses 81 ( 7) l (2)(ii)(L) - - Manufacturer and model no. information PS ( 4)

(3) - - - - - - Assessment of safety consequences 77 (15)

(4) ----- - Corrective actions 82 (15) l l (5) - - ---- Previous similar event information 13 (15)

(2)(i, - - - - Text presentation l

79 (15)

ABSTRACT l ________

Percentage a

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

- Major occurrences (immediate cause/effect) 93 (15)

- Plant / system / component / personnel responses 93 ( 7)

- Root cause information 83 (15)

Corrective action information 87 (15)

Abstract presentation 85 (15) 6

. TABLE 2. (continuad) 4 CODED FIELDS Percentage a

Item Number (s) - Descriptions Scores ( )

1, 2. and 3 - Plant name(unit #), docket 8, page as 100 (15) 4------ Title 54 (15) 5, 6, and 7 - Event date,'LER no., report date 99 (15) 8------ Other facilities involved 100 (15) 9 and 10 --

Operating mode and power level 98 (15) 11 - ----

Reporting requirements 97 (15) 12 - ----

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

Coded component failure information 88.(15) 14 and 15 - - Supplemental report information 93 (15)

n. C ercentage 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 paren-hesis is the number of LERs for which the requirement was considered applicable,

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

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

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(1) excluded certain less significant information from a number of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The unit should review the LER specific comments presented in Appendix 0 to determine why it received less than a perfect score for certain requirements.

Specific Deficiencies and Observations The more important deficiencies and observations for the text, abstract, and coded field sections of the LERs are discussed separately below.

Text Deficiencies and Observations Cause information is considered to be deficier,t in seven of the 15 LERs, Requirement 50.73(b)(2)(ii)(D). Most of these deficiencies are attributed to the lack of a few more details in the cause discussion or the failure to provide the cause of failure for all of the failed components mentioned in the text. Refer to Appendix D for details concerning these, as well as other, deficiencies.

Seven of the corrective action discussions are considered deficient, Requirement 50.73(b)(4). Mos.t of these deficiencies resulted because the discussions did not detail what was actually done to correct the problem and/or prevent it from recurring.

Safety assessment information for seven of the LERs was considered to be lacking, Requirement 50.73(b)(3). A detailed safety assessment is required in every LER and, as suggested in NUREG-1022, Supplement No. 2, should include information such as:

1. An assessment of the consequences and implications e3 the event including specifics as to why it was concluded that tac.*e were "no safety consequences", if such was the case. It is inadequate 8

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to simply state "this event had no safety consequences or implications." without explaining how that conclusion was reached.

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2. A safety assessment should discuss whether the event could have occurred under a different set of conditions where the safety implications would have been more severe. If the conditions during the event are considered the worst probable, the LER should so state.

3. Finally, a safety assessment should name other systems (if any) that were available to perform the function of the safety systems that were unavailable during the event.

Eight of the ten LERs that involved personnel errors are considered to lack an adequate discussion of the personnel error, Requirement 50.73(b)(2)(ii)(J)(2). Each personnel error should clearly state: whether the error was considered cognitive or procedural, any unusual circumstances concerning the error, and the type of personnel involved in the error. In addition, if the error -is considered procedural, the discussion should state: whether there was an error in the procedure, the error was contrary to an approved procedure, or the task being performed when the error occurred was not covered by an approved procedure.

Two of the five LERs that contained discussions of operator actions that affected the course of the event, Requirement 50.73(b)(2)(ii)(J)(1),

are considered to lack certain details. Specific comments concerning these two LERs can be found in the Appendix D text comments, pages D-3 and D-13.

The requirement to provide the name of those safety systems that are initiated either manually or automatically is considered deficient for three of the seven events in which safety systems responded. It is not -

adequate to simply state "all safety systems operated as designed". Those safety systems that actuate or are actuated should be named.

The requirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was considered deficient in 9

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three of the four 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 information. Whatever information is provided, it should be specific enough to allow the reader to determine if the failed component is the same as one that is used at his facility. In addition, there are instances when component identification can be important to the reader, even though the component did not fai1. For example, if the design of a component contributes to the event, it would be helpful (although not required) to provide information that would enable others to specifically identify that component.

An estimate for the elapsed time of safety system train inoperability, Requirement 50.73(b)(2)(ii)(H), was not provided for one 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.

Plant operating conditions just prior to the event, Requirement 50.73(b)(2)(ii)(A), were not provided or were considered inadequate for six of the 15 LERs.

Thirteen of the 15 LERs did not provide information concerning previous similar events, Requirement 50.73(b)(5).  !

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The Energy Industry Identification System (EIIS) component function j identifier and system name codes were not provided in any of the 15 LERs.

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These codes should be provided for all components and systems referred to l in the text. l Abstract Deficiencies and Observations i While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as stated in 1

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.f NUREG-1022, Supplement No. 2,5 summarize the following information from the text:

1.- Cause/Effeet What happned that made the event reportable.

2. Respcnies Major plant, system, and personnel responses as a result of the event. {

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3. Root /Intertrediate The underlying cause of the event. What Cause caused the component and/or system failure or the personnel error. I

4. Corrective Actions What was done immediately to restore the plant to a safe and sta.ble condition and what was done or planned to prevent

, recurrence of the ever.t.

Number 3 and 4 were not adequately addressed in seven and six of the LERs, respectively. In addition, five abstracts had minor probler; in the area of presentation; see the abstract comments in Appendix D.

Coded Fields Deficiencies and Observations The main deficiency in the area of coded fields involves the titles, Item (4). All of the 15 titles failed to include adequate cause information, six failed to include an adequate result of the event and three 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 0 for many of the LERs which were considered to have poor titles.

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SUMMARY

Table 3 provides a summary of the areas that need improvement for the Summer LERs. For additional and mure specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and D. General guidance c.oricerning requirements can be found in NUREG-1022, and NUREG-1022 Supplements No. I and 2.

As was mentioned earlier, this is the second time that the Summer LERs have been evaluated using the same methodology. The previous evaluation l was reported in January of 1986. Table 4 provides a comparison of the sec.es for both evaluations. Small improvements in the information provided concerning safety consequences, identification of failed components, and dates / times resulted in a small improvement in the average text score. However, Summer's overall average LER score (8.1) is still below the current industry overall average of 8.4. (Note: The industry overall average is the result of averaging the latest overall average LER l

score for each unit / station that has been evaluated using this methodology.)

On a more p sitive note, it was observed that starting in 1987 the Summer LERs were written using an outline format (i.e., the last five LERs in the sample were outlined). An average of the scores for the e five LERs j indicate an improvement beyond that for the entire sample. For example, the average text score for the outlined LERs is 8.3 and the overall average l

LER score is 8.4. If this trend continues, Summer's LER scores for its next evaluation should be about average for the industry.

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TABLE 3. AREA 5 MOST NEEDING IMPROVEMENT FOR SUMMER LERs Areas Comments 1

1 Cause information - Cause information, including root cause if known, should be included for each failure or personnel error involved in the event.

Corrective actions All actions planned or taken to address the i various causes (problems) mentioned in the text should be discussed, especially those actions considered necessary to prevent recurrence of the event or similar events.

Safety assessment information All LERs should include a detailed safety assessment. The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstances and provide information concerning backup sys. ems (if any) that were available to limit the consequences of the event.

Personnel / procedural error Details should be explicitly stated; the cause of personnel error should be discussed, (e.g., cognitive or procedural). Contributing factors should be provided when appropriate.

Operator actions Be sure to discuss operator actions that affect the course of the event in the text.

Automatic / manual safety All safety systems that actuate system responses automatically or that must be manually initiated as a result of the event should be identified in the text.

Manufacturer and model number Component identification information should be included in the text whenever a component fails. Inaddition,(although not specifically required by the current regulation) it would be helpful to identify a compontst if its design is suspected of contributing to the event.

Safety train unavailability Sufficient dates and times should be included in the text to enable the reader to determine the length of time that safety system trains or components were out of service.

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TABLE 3. (Continued)

Areas Comments Previous similar events Previous similar events should be referenced (e.g., by LER nurher) or, as stated in NUREG-1022, Supple. ment No. 2, if none are identified, the text should so state.

L hart erating condition Plant operating conditions just prior to the event should be included in the text.

If at power, the power level would be useful information.

EIIS codes EIIS codes should be provided in the text a for each compor; t or system referred to in the text.

Abstracts Cause and corrective action information from the text should be summarized in the abstract.

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4. IM r. Titles should be written such that they better-describe the event. In particular, cause and result information and the link between them should be included in each title.

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TABLE 4. COMPARISON OF'LER SCORES FOR SUMMER l

Report Date January-86 August-87.

Text average- 7.1 7.6

. Abstract average 7.7 8.8 L

Coded fields average 8.3 8.6 Overall LER average. 7.4 8.1 p.-

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d REFERENCES

1. - Office for Analysis and Evaluation of Operational Data, Licensee Event

. Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September'1T83.

2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Swplement No.1, U.S. Nuclear Regulatory Commission, February 1984.

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

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.O APPMDIX A IER SAMPIE wrmrIcy INFORMNTICH EUR SUMER

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1 TAB 2 A-1. IRR SAMP2 SEWCPIW PCR SW9ER Sanple Number IER Nunbar Coments 1 86-002-00 SCRAM i

2 86-004-00 3 86-006-00 SCRAM 4 86-007-00 .ESE 5 86-009-00 SCRAM 6 86-011-00 SCRAM, ESF 7 86-014-00 SGAM 8 86-016-00 9 86-017-00 10 87-001-00 11 87-002-00 12 87-005-00 13 87-006a40 14 87-007-00 15 87-009-00 A-1

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APPENDIX B WALUATICH SOCRES OF INDIVIDUAL IERS Ft]R SGt!ER i

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TABLE B-1.

... EVALUATION SCORES OF INDIVIDUAL LERS FOR SUMMER a

LER Sample Number 1 2 3 4 5 6 7 8 Toxt 8.2 6.7 6.7 8.2 7.6 7.5 7.8 5.1 Abstract 9.8 9.1 7.9 9.8 7.6 9.0 8;9; 8.5 Coded Fields 9.1 9.2 8.0 8.4 9.0 8.8- 8.3 9.2 Overall 8.8 7.7 7.2 8.7 7. 8 8.1 6. 6.5 a

LER Gample Number 9 10 11 12 13 14 15 Average Toxt 6.6 7.9 9.0 8.2 9.5 7.3 7.7 7.6 Abstract 9.0. 9.4 9.7 8.2 8.9 7.7 8 .' 4 8.8

-Coded Fields 8.9 8.6 8.9 8.7 7.9 8.4 8.0 8.6 Overall 7.5 8.4 9.2 8.3 9.2 7.5 7.9 8.1

e. 5ee Appendix A for a list of the corresponding LER numbers.

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APPD4 DIX C DEFICID CI AND OBSERVATICH COUNIS RR SIMER l,

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TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR SUMMER Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b 50.73(b)(2)(11)(A)--Plant operating 6 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 1)

' of the structures, components, or systems that were inoperable at the start of the event and that contributed to the event was not included or.was inadequate.

50.73(b)(2)(ii)(0)--Failure to include 5 (15) sufficient date and/or time information.

a. Date information was insufficient. 3

b. Time information was insufficient. 2 50.73(b)(2)(fi)(D)--fhe 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 4 included or was inadequate.

b. Cause of system failure was not 3 included or was inadequate.

50.73(b)(2)(11)(E)--The failure mode, 0 ( 4) meche.. ism'(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 i

included or was inadequate, j i

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 Description of Deficiencies and Observations Totals' ' Totals ( )b 50.73(b)(2)(ii)(F)--The Energy Industry 15(15)

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

50.73(b)(2)(11)(G)--For a failure of a -- ( 0)

' component with multip4 functions, a list of systems or secondary ibactions which were also affected was not included or was inadequate.

' 50.73(b)(2)(11)(H)--For a fa1 L ie that 1 ( 3) rendered a train of a safety system-inoperable, the estimate of elapsed time from '.ne time of- the failure until the -

train was returned to service was not included.

50.73(b)(2)(ii)(Ij--The method of discovery 2 (15) of each component failure, system failure, personnel error, or procedural error was not included.or was inadequate.

a. Method of discovery for each 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 ina.!squate.

d. Method of discovery for each I procedural error was not incluced or was inadequate.

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TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Deser fption of Deficiencies and Observations Totals a Totals ( )b 50.73(b)(2)(ii).(J)(1)--Operator actions that 2 ( 5) 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 8(15) each personnel errur was not included or was inadequate.

a. OBSERVATION: A personnel error was 3 implied by the text, but was not explicitly stated.

b. 50.73(b)(2)(11)(J)(2)(1)--Discussion 2 as to whether the personnel error was cognitive or procedural wcs not included or was inadequate.

c. 50.73(b)(2)(ii)(J)(2)(ii)--Discussion 0 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure was not included or was inadequate.

d. 50 _73( b)( 2)( i i )(J )( 2 )( 111 )--Di scu s si o n 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)(iv)--Discussion 5 of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inadeq*Jate.

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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 ( )b 50.73(b)(2)(11)(K)--Automatic and/or manual 3 ( 7) safety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 3 ( 4) model number of each. failed component was not-included or was inadequate.

50.73(b)(3)--An assessment of the safety 7(15) consequences and implications of the event was not included or was inadequate.

a. OBSERVATION: The availability of 1 other systems or components capable lof 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 consequeno , 1 of the event had it occurred c o . .-

more severe conditions were not l discussed. If the event occurred  !

under what were considered the most severe conditions, the text should so state.

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50.73(b)(4)--A discussion of any corrective 7(15) actions planned as a result of the event i including those to reduce the probability of similar events occurring in the future was not included or was inadequate. l l

I C-4 l

x;;;. ;;. .. ... . 1 .......w.... ..........ua...... ..:..-~............,.................a;.....

TABLE C-1. (continued)

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

a. A discussion of actions required to 2 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 3 reduce the probability of recurrence of the problem or similar event (correct the root cause) v: not included or was inadequatt,

c. OBSERVATION: A discussion of actions 0 required to prevent sirilar failures

.in similar and/or other systen s (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 13(15) similar events was not included or was inadequate.

t C-5

, , _ ; , , ;;, , , ;.-  ;  ;;, ; ,,-- ,,; , ;,m_ , ;, ,,,,,,,;,_,,. ,, ,,,,,_ , ,,,,,_ , _ ,,, _ ,, ,,_ , ,, ,, ,

0

TABLE C-1. (continued)

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

• Totals ( )b 50.73(b)(?)(i)--Text presentation 2(15) inadequacies.

a. OBSERVATION: A diagram would have 0 aided in understanding the text discussion.

b. Text contained undefined acronyms 2 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 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 nun.ber 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.

l C-6

" T .i ;. G ..; ,.. .....<.~.-.u--.: - * - - ~~ ** * - --~* - * - - -

TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR SUMMER Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )b A summery of occurrences (immediate cause ~

5(15) and effect) was not included or was inadequate.

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

a. Summary of plant responses was not 0 included or was inedequate.

b. Summary of system rasponses was not 1 included or was inadequate.

c. Summary of personnel responses was not 1 included or was inadequate.

A summary of the root cause of the event 7 (15) was not included or was inadequate.

A summary of the corrective actions taken or 6 (15) planned as a result of the event was not included or was inadequate.

i l

C-7

1 ,.

4

TABLE C-2. .(continued)

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

' Abstract presentation inadequacies. 5(15)

~

a. OBSERVATION: The' abstract contains 1 information not included in the ~ text.

-The abstract is intended to be a-summary of the text, therefore, the 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 containt other specific 3 deficiencies (i.e., poor summarization,. 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 du not necessarily add up to the paragraph total.

b. The " paragraph total" is the number of LERs-that have one or mor.e deficiency or observation. The number in parenthesis is the number of LERs  :

for which a certain requirement was considered applicable.  ;

\

C-8'

. . m . ._. . . .

q

. v. . ..

]

.. i l

TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SUMMER 1 Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations a Totals _ Totals ( )b i

Facility Name. 0(15)  ;

1

a. Unit number was not included or incorrect.

b. Name was not includea or.was incorrect.

c. Additional unit numbers were included but not required.

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

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

Title was left blank or was inadequate. 15 (15)

a. . Root cause was not given or was 15 Inadequate.

b. Result (effect) was not given or 6 was inadequate.

c. Link was not given or was 3 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 0(15)

a. Date not included.

b. OBSERVATION- Report date was not within thirty days o' event date (or discovery date if appropriate).

C-9

a u;.. - ..: =..e~. ....a ...a...... . . . . . . . ~.. . . . ~ . . . .. . .. . .. . - . ~ . . . . . . .: : ;. =

TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph

' Description of Deficiencies and Observations 8 Totals Totals ( )b Other Facilities information-in field is 0(15) inconsistent with text'and/or abstract.

' Operating Mode was not included or was 1(15) inconsistent with text or abstract.

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

Reporting Requirements 1(15)

a. The reason for checking the "0THER" 0 requirement was not specified in the abstract and/or~ text.

b. OBSERVATION: It may have been more 0 appropriate to report the event under a different paragraph.

c. OBSERVATION: It may have been 1 appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 0(15)

a. Field left blank,

b. Position title was not included.

c. Name was not included.

d. Phone' number was not included.

Coded Corponent Failure Information 8(15)

a. One or more component failure 0 sub-fields were left blank.

b. Cause, system, and/or component code  ?

is inconsistent with text.

c. Component failure field contains data 6 when no component failure occurred.

d. Cc'.nponent failure occurred but entire O field left blank.

1 I

l l- C-10 1

1

r ;2ma . . 2 7 . . . m. ; a . au . .. . u .

.;u..--.....-.~

. .;.x--2_..o.w......~.,...~.. .... .. 6 % .- . - _.,

p 4 3

e -TABLE C-3. (continued)

I Number of LERs with-Deficiencies and Observations-l Sub paragraph Paragraph Description of Deficiencies and Observations Totals" Totals ( )b Supplemental Report 2(15)

a. Neither "Yes"/"No" block of the 0 i supplemental report field was ,

checked.  !

b. The block checked was inconsistent 2 with the text.

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

a. The "sub paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more thai 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.

C-11

• i'7l' . :. . . % '. o - a a e a o e 4

9 l

APPD1 DIX D IER CCHENT SHEEIS KR SONER

TABLE D-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

1. LER Number: 86-002-00 1

Scores: Text = 8.2 Abstract = 9.8 Coded Fields = 9.1 Overall = 8.8 Text 1. 50.73(b) 2)(ii)(C)--Additional times, such as when power was restored to the distribution panel, could be helpful.

S 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)(iv)--Discussion of the type of ,

personnel involved (e.g., contractor personnel, j utility licensed operator, utility nonlicensed i operator, other utility personnel) is inadequate. '

Who (by type) was responsible for preparing the EFL.

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. While it is good that a spot check is being made of approved EFL's, what will  ;

be done in the future to prevent recurrence of a similar situation?

5. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar l events are known, the text should so state.

Abstract 1. No comment.

Coded Fields 1. Item (4)--Title: Cause is not included. A more appropriate title might be " Turbine / Reactor Trip caused by Improperly Prepared Electrical Feeder List (Personnel Error)".

2. Item (13)--Component failure field contains data when no component failure occurred.

0-1

TABLE D-l' .

SPECIFIC LER COMMENTS FOR SUMMER (395) 3.

Section Comments

'2. LER Number: 86-004-00 Scores: Text = 6.7 Abstract = 9.1 Coded. Fields = 9.2 Overall = 7.7 Text 1. 50.73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(C)--When were the operating logs streamlined and simplified?-

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

4. 50.73(b)(2)(ii)(J)(2)(iii)--Discussion of any unusual characteristics of the work location (e.g... heat, noise)~that directly contributed to the personnel-error 1s not included for the operator incorrectly logging the channel checks.

5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.

6. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

e Abstract 1. 50.73(b)(1)--Summary of personnel error is I inadequate. See text comment number 4. '

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The goal of the human factors evaluation to streamline and simplify the operating logs is not included. j Coded Fields 1. Item (4)--Title: Cause information (personnel cognitive error) is not included. A better title might be: " Personnel Error in Logkeeping Results in Missed Surveillance of Instrument Channels--Technical Specification Violation".

i D-2 I

l

1 TABLE 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

) Section Comments

3. LER Number: 86-006-00 Scores: Text = 6.7 Abstract = 7.9 Coded Fields = 8.0 Overall = 7.2 Text 1. 50.73(b)(2)(ii)(C)--On what date was the unit startup completed following the brush replacement?

2. 50.73(b)(2)(ii)(0)--The root and/or intermediate cause discussion concerning the worn brush is inadequate. Why did the brushes fail in less than j three days (i.e., between March 15 and April 2)? 1 Although there is no requirement to do so, a {

supplemental report may be needed pending the results of the laboratory analysis. In addition, what was the cause of the bad connection on the current transformer (CT)?  !

3. 50.73(b)(2)(11)(F1--The Energy Industry i Identification System code for each component and/or system referred to in the text is not included.

4. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.

It is not apparent why the worn brushes could not have been discovered without taking the unit back to power.

5. 50.73(b)(2)(ii)(K)--A11 safety systems that actated (or were manually actuated) as a result of this event should be named.

6. 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.

7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. What was the " minimal impact" of the loss of all three instrument air compressors? What was the specific (numerical) fraction of the allowable limit for the unmonitored release?

8. 50.73(b)(4)--Although there is no requirement to do so, a supplemental report may be appropriate to describe the results of the laboratory analysis if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken. What was the previous surveillance interval for these brushes?

D-3

1 TABl.E D-1, $PECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

3. LER Number: 86-006-00(Continued)

9. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s)andeffects(s)]isinadequate. The unmonitored release should have been mentioned in the abstract.

2, 50.73(b)(11--Summary of system, component, and personnel responses is inadequate. The loss of the air compressors, the actuation of.the power operated relief valves, and the restart of the unit to test the voltage regulatory were not mentioned in the abstract.

3. 50.73(b)(1)--Cause and corrective action information is lacking in the abstract (as it is in the text).

See text comments number 2 and 8.

Coded Fields 1. Item (4)--Title: Cause and link are not included.

2. Item (14)--See text comments numbers 2 and 8.

D-4 t _ - ------- ----- _ ---- -

? .

L TABLE D-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

4. LER Number: 86-007-00 Scores: Text = 8.2 Abstract = 9.8 Coded Fields = 8.4 Overall = 8.7 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluatec as if it were a text. l

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

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.

2

4. 50.73(b)(2)(ii)(L)--While no actual failure occurred it would be helpful to identify components which could have contributed to the event.

5. 50.73(b)(3)--Would there be any safety significance if water had been injected into the Reactor Building?

6. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comment.

Coded Fields 1. Item (4)--Title: Cause (unknown) is not included and the result is vague. A more appropriate title might be " Inadvertent Reactor Building Spray Pump Start (No Water Injected) due to Unknown Cause".

2. Item (13)--Component failure field contains data when no component failure occurred.

i D-5

.= w z.: ... u .. . .

4 9 'y l TABLE D-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

5. LER Number: 86-009-00 Scores: Text = 7.6 Abstract = 7.6 Coded Fields = 9.0 Overall = 7.8 Text 1, 50.73(b)(2)(ig--When was the condensate system secured and the p ant stabilized in hot standby?

2. 50.73(b)(2)(ii)(D)--The root arNor intermediate cause discussior, co6:erning failure to maintain deaerator level is inadequate. Was operator error or design error invalved? Low did the water hammer transient result from the deaerator problems?

3, 50.73(b)(2)(11)(F1--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

! 4. 50.73(b)(2)(11)(K.'-Discussion of automatic and/or manual safety systw responses is inadequate. What safety related systems responded as a result of the reactor trip?

5. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate, particularly for the water hammer transient. OBSERVATION: The consequences of the t 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 correct the immediate problem and return the applicable systems / component (s) to an operable status is not included for the repairs to the condensate system. What repairs were perfomed?

A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included for the water hammer l transient. I J Were any changes made to the test procedure as a i result of the human factors review?

7. OBSERVATION: The text appears to be somewhat short for an evert as complex as this one. I D-ti I

1

- ---_____ __ ___ _ l

TAB!.E 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

5. LER Number: 86-009-00(Continued)

Abstract 1. 50.73(b)(1)--Summaryofoccurrences[immediate cause(s) and effects (s)) is inadequate for the unmonitored release to the atmosphere through the PORV's as a result of the necessary steam dump and steam generator tube leakage. Problems with >

maintaining the deaerator level are not m.entioned.

2. 50.73(b)(1)--Surmary of cause information for the water hammer transient is not included.

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. The evaluation of improved labeling of instrument drawers and the human factors review of the test procedure are not included.

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

Coded Fields 1. Item [4)--Title: Cause (personnel error) is not included and result (subsequent condensate system water ha ,mer) is inadequate.

D-7

1 .. . . . . . . . ., . . . . . . - . . . . . ;- . . ... ; . . . . . .. ; . - ;;; ::- ;;;;. : :. : .- T:

4 TABLE D-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

6. LER Number: 86-011-00(Continued) l Coded Fields 1. Item (4)--Title: Cause (unknown but suspect I

1 connector) is not included.

2. Item (13)--Cause, sys+im, and/or component code appears inconsistent with information provided in the text. Information (component and manufacturer code) for the connector rather than the valve would be more appropriate.

i l

1 D-9

L TABLE 0-1. . SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

7. LER Number: 86-014-00 Scores: Text = 7.8 Abstract = 8.9 Coded Fields = 8.3 Overall = 8.2 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluated as if it were a text.

2. 50.73(b)(2)(ii)(D)--Was any attempt made to recreate the vibration to verify that this was really the cause?

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.

4. 50.73(b)(2)(ii)(J)(2)--Were the personnel conducting' the test following the procedure, if any, and who, by type, was responsible for conducting the test?

5. 50.73(b)(43--Although there is no requirement to do so, a supp' emental report may be appropriate to describe the results of the conclusions reached in whether or not to relocate the pressure switches if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

6. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comment. i Coded Fields 1. Item (4)--Title: Cause (vibration) and link (testing activity) are not included.

2. Item (13)--Component failure field contains data when no component failure occurred.

3. Item (14)--The block checked appears to be inconsistent with information provided in the text; see text comment number 5.

D-10

TABLE 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

8. LER Number: 86-016-00 Scores: Text = 5.2 Abstract = 8.3 Coded Fields = 9.2 Overall = 6.5

. 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)(11)(D)--The root and/or intermediate cause discussion concerning failures of valves SVR-7160 and XVG-8073-4 is not included, Why did valve XVR-7160 fail to reseat and why did valve SVG-8073-4 leak 7 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.

4. 50.73(b)(2)(ii)(J)(2)--It cppears that personnel error and/or procedural deficiency may be involved it this event, but it is not discussed. Why was the reactor coolant drain tank pumped down to the pump auto trip point 7 Was this part of the leak rate determination procedure 7

5. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of ,

personnel involved (e.g., contractor personnel, '

utility licensed operator, utility nonlicensed operator, other utility personnel) is not included for the leak rate determination procedure.

)

6. 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.

7. 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.

8. 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 for the valves SVR-7160 and SVG-8073-4 and for the implied personnel error involving the pumping down of the reactor coolant drain tank.

I D-11

)

n. .. . . . . . . _ - . _ . . . . . . . . . . . . . . . - . . . . . . . . , . . _ . . . . . . . . . . . . . . ........_......_.............a TABLE D-1. SPECIFIC ~ LER COMMENTS FOR SUMMER (395) {

I l

Section Comments

8. LER Number: 86-016-00(Continued)

9. 50.73(b)(5)--Information concerning previous similar i events is not included. If no previous similar l

events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is not included for the RCD pump trip' leading to the relief valve lifting.

2. Cause and correction actions summaries are deficient for the same reasons as mentioned in the text comments 2, 4, and 8.

Coded Fields 1. Item (4)--Title: Cause (reactor coolant drain pump trip, relief valve failure to reseat and isolation l

valve leakage) is vague.

i l

i D-12 l

l

_ _ _ _ . _ 1

.,..n _ . .. n. . . . -.

n.:. . . ; . - .;.. .

TABLE 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

9. LER Number: 86-017-00 Scores: Text =_6.6 Abstract = 9.0 Coded Fields = 8.9 Overall = 7.5 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to t s abstract that was evaluated as if it were a text.

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

3. 50.73(b)(2)(ii)(D)--The root and/or intermediate t cause discussion concerning the " fault" and the breach is not included.

4. 50.73(b)(2)(11)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

5. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.

Is it a procedural requirement that the status of fire barriers be reviewed by the " responsible individual"?

6. 50.73(_b)(2)(ii)(J)(2)--Discussionofthepersonnel error / procedural deficiency is inadequate. Why wasn't the breach identified prior to this time?

50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

)

7. 50.73(b)(3)--Hov many fire zones were affected by the fault and where are they located (e.g., what building)?

8. 50.73(b)(4)--What corrective action's were taken to address (fix) the fault and the breach? ]

l 9. 50.73(b)(5)--Information concerning previous similar l events is not included. If no previous similar events are known, the text should so state.

l 0-13  !

I l

i

- - - - - _ - - - - - - - - - - - - - - J

9 TABLE 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

9. LER Number: 86-017-00(Continued)

Abstract 1. 50.73(b)(1)--The abstract is deficient in the cause and corrective action areas (see text comment numbers 3, 6, and 8.

Coded Fields 1. Item (4)--Title: Cause and result are inadequate. A better title might be " Continuous Fire Watch Not Established as Required by Technical Specifications--Personnel Error".

\

2. Item (13)--Component failure field contains data but no component failure is discussed in the text. If a component failure caused the fault, information concerning this component would be appropriate.

D-14

- -. ...--~.---.; .. . . . . . . . . . ... . . . _ . . . . . . . . . . . _ . . . . . .

TABLE D-1.

SPECIFIC LER COMMENTS FOR SUMMER (395)

Section __ Comments

10. LER Number: 87-001-00 Scores: Text = 7.9 Abstract = 9.4 Coded Fields = 8.6 Overall = 8.4 Text 1. Submittal of an LER without a text is acceptable; however, the abstract must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to the abstract that was evaluated as if it were a text.

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

3. 50.73(b)(2)(11)(F1--The Energy Industry Ider'ification System code for each component and/or system referred to in the text is not included.

4. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the procedural deficiency is inadequate. What activity lead the Shift Supervisor to realize the problem?

5. 50.73(b)(2)(ii)(J)(2)(iv)--Who, by type, was

' responsible for reporting the PRT venting to the HP's?

6. 50.73(b)(3)--The safety assessment does not indicate the consequences of an excessive amount of noble gases going undetected. Are there any other systems or means to help limit a release of noble gas?

7. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. Item (4)--Title: Cause (procedural deficiency) is not inc'uded.

2. Item (9)--Operating mode is not included.

3. Item (13)--Component failure field contains data when no component failure occurred.

0-15

3- .. .

............_......-...._n....~~,-j TABLE D-1.

SPECIFIC LER COMMENTS'FOR SUMMER (395)

Section Comments

11. lER Number: 87-002-00 Scores: Text = 9.0 Abstract = 9.7 Coded Fields = 8.9 Overall = 9.2 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. l 50.73(b)(2)(ti)(J)(2)(iii)--Discussion of any unusual

' characteristics of the work location (e.g., heat, ,

noise) that directly contributed to the personnel I error is not included.

3, 50.73(b)(5)--Information concerning previous similar j events is not included. If no previous similar events are known, the text should so state.

" Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. See text comment number 2.

Coded Fields 1. Item (4)--Title: Cause (personnel cognitive error) is not included.

0-16

= --

...;.:..;...........-.................-.--.---------.-~~~~-"---

s TABLE 0-1. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

12. LER Number: 87-005-00 Scores: Text = 8.2 Abstract = 8.2 Coded fields = 8.7 Overall = 8.3 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning pressurizer safety valve setpoints is inadequate. Was the nitrogen method (used in April of 1984) used by the same test laboratory that performed the 1987 test (i.e., Wyle)?

Although there is no requirement to do so, s supplemental report may be appropriate to describe the results of the SCE&G evaluation if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

2. 50.73(b)(2)(11)(F)--The Energy Industry

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

3. 50.73(b)(2)(ii)(L)--Even though the safety valves did not fail, the manufacturer and model number of the valves would be good information to provide.

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. More information concerning the " test method" to be used to do the in-situ testing after the third refueling outage would be helpful. In addition, see the last sentence of text comment number 1 above.

5. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The abstract should indicate that the as-found setpoints were outside the limits in the non-conservative direction.

2. 50.73(b)(1)--Summary of cause information is inadequate. It would be useful to provide information in the abstract concerning the differences between the test methods used in 1984 and 1987.

(

D-17

-- ;. : ; ; - . . . . . . . . . . . . . . . . . - . . . . . . . , . . . . . . - . . . . - - - - - - - - - - ~ ~ ~ ~ -

y TABLE D-1. SPECIFIC LER COMMENTS FOR SUMMER (395) l Section Comments i

12. LER Number: 87-005-00(Continued)

3. Additional space is available within the abstract ,

field to provide more information but it was not utilized. 3 Coded Fields 1. Item (4)--Title: Cause information is not included and the result is inadequate. A better title might be "Setpoints for the Pressurizer Safety Valves Above the Technical Specification Limit--Apparent Cause Differences in Testing Methodology".

D-18

_ _ _ _ _ _ - _ - _ - - - = - - - - - - - - - - - - - - - - - - - - - - - - - - - -

l-

a. 4 ,

' TABLE 0-1. SPECIFIC LER COMMENTS' FOR SUMMER (395) {

Section Comments

13. LER Number: 87-006-00 Scores: Text = 9.5 -Abstract = 8.9 Coded Fields = 7.9 Overall = 9.2 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.

Abstract 1. The corrective action summary does not mention the stress relieving process and the extra surveillance.

Coded' Fields 1. Item (4)--Title: Cause (manufacturing defect) and result (inoperable steam generator tubes) are not included.

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

3. Item (13)--Cause, system, and/or component code appears inconsistent with information provided in the text. The system code "AE" appears to be incorrect.

1 l

0-19

. . . . . . . . ~ . - - - . - . . ~ . . . . . - . - - . . .. ~ -- -

1 1

s l TABLE D-1.

{

SPECIFIC LER COMMENTS FOR SUMMER (395) }

}

t I

_Section Comments 1

14. LER Number: 87-007-00 Scores: Text = 7.3 Abstract = 7.7 Coded Fields = 8.4 Overall = 7.5 Text 1. 50.73(b)(2)(ti)(C)--When were the two defective tubes in steas generator C which required plugging, but were plugged only on the hit leg side, repaired?

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

3. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Why was the tube plug basket not used for the C steam generator cold leg side and the D steam generator hot leg side? Did a procedure require the use of the basket?

4. 50.73(b)(4)--A discussion of actions required to correct the immediate problem and return the applicable systems / component (s) to an operable status is not included for the incorrectly plugged C steam generator tubes.

5. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

6. Acronym (s) and/or-plant specific designator (s) are undefined for F* criteria.

7. The text appears to contradict itself. Under

" Identification of Event" and " Description of Event",

statements are made that Row 15-Column 35 and Row 9-Column 44 tubes in C steam generator should have been plugged for tube wall degradation.

However, under " Analysis of Event", the statement,

" Cracks of this nature are currently permitted to remain in service without plugging, depending location by the F* criteria." is made. Does this mean that the plugging criteria changed during the previous 16 months?

l l

D-20

..,v' TABLE 0-1. ' SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

14. LER Number: 87-007-00(Continued)

Abstract 1. 50.73(b)(1)--Summary of cause information concerning the misuse of the tube plugging template and the failure to use the suspended basket-and the environmental effects influence on the personnel error is not included.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a' result of the event is not included ~for any immediate repairs to.the two C generator defective tubes.

Coded Fields 1. Item (4)--Title: Cause (personnel error) is not included and result (Technical Specification Violation) is inadequate.

2. Item (13)--Component failure field contains data when no component failure occurred.

I D-21 1

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e' .

TABLE 0-1.

SPECIFIC LER COMMENTS FOR SUMMER (395)

Section Comments

15. LER Number: 37 009-00 Scores: Text = 7.7 Abstract = 8.4 Coded Fields = 8.0 Overall = 7.9  ;

Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry i

{

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

j

2. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included.

3. 50.73(b)(2)(fi)(I)--Discussion of the method of discovery of the tripped pump is not included.

4. 50.73(b)(2)(ii)(L)--Even though the SEBP did not

" fail", enough specific information would be helpful in the text concerning the design deficiency to enable a reader to determine if he might have the same problem at his unit or station.

5. 50.73(b)(3)--What was the specific reactor building temperature calculated for the MSLB accident?

6. 50.73(b)(4)--Was the pump restarted (if required)?

7. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

8. Acronym (s) and/or plant specific designator (s) are undefined. More information could have been provided concerning the " matched flags" and the "after-start position".

Abstract 1, 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The loss of the RBCVs should have been mentioned.

2. 50.73(b)(1)--Summary of cause information is inadequate. The water draining from the RBCUs should have been mentioned.

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

l l

D-22 i

}

t: ty TABLE D-I. SPECIFIC LER COMMENTS FOR SUMMER (395)

Section- Comments

15. LER Number: 87-009-00(Continued)

Coded Fields 1. Item (4)--Title: Cause and result are not included.

A better title might be " Design Deficiency Results in Trip of Service Water Booster Pumps on Restart After Load Sequencing".

c h

D-23

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