NUREG/CR-4178, Forwards AEOD SALP Assessment of LERs Submitted by Util. Assessment Performed Using Methodology Similar to That in NUREG/CR-4178, Evaluation of Selected LERs Prepared Per 10CFR50.73. Util LERs Average in Quality

Forwards AEOD SALP Assessment of LERs Submitted by Util. Assessment Performed Using Methodology Similar to That in NUREG/CR-4178, Evaluation of Selected LERs Prepared Per 10CFR50.73. Util LERs Average in Quality

ML20203L622
Person / Time
Site:	Ginna
Issue date:	08/20/1986
From:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kober R ROCHESTER GAS & ELECTRIC CORP.
References
RTR-NUREG-CR-4178 NUDOCS 8608290019
Download: ML20203L622 (56)

Text

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.f 20 AUG se6 Docket No. 50-244 Rochester Gas and Electric Corporation ATTN: Mr. Roger W. Kober Vice President Electric and Steam Production 49 East Avenue Rochester, New York 14649 Gentlemen:

Subject:

Quality of Licensee Event Reports (LERs)

As part of the SALP process, the NRC Office for Analysis and Evaluation of Operational Data (AE00) evaluated LERs submitted by RG&E during the recent SALP assessment period for the Ginna Station. "The assessment (attached) was performed using a methodology similar to that described in NUREG/CR-4178, "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73."

It is important to achieve uniform, high quality LERs.from all.

operating power reactors to enable AE00 to effectively identify " precursor events" and emerging trends or patterns of potential safety significance.

Generic studies triggered by events reported at specific units can lead to improvements in the level of reactor safety only if the available database is uniform and of high quality.

The conclusions of the AE00 review is that, overall, RG&E LERs sampled were average in quality. One LER however, No.85-012 was identified as being deficient in that it lacked a description of the impact of the design change on the system's post accident functions. This item is highlighted in the report for your consideration and further review.

I invite you to review the attached analyses and further improve your system of reporting events under 10 CFR 50.73.

Sincerely,

@_ Signed By a William F. Kane, Director Division of Reactor Projects

Enclosure:

as stated 8608290019 860820 PDR ADOCK 0S000244 S

PDR OFFICIAL RECORD COPY GALLO 8/8/86 - 0001.0.0 08/08/86 l

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and ectr c Company gQ gy$ 1986 cc w/ encl:

Harry H. Voigt, Esquire Central Records (4 copies)

Director, Power Division Public Document Room (PDR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

R. M. Gallo, DRP Section Chief bec w/o encl:

S. J. Collins B. Hillman C. J. Heltemes, AE00 f f, Y

RI:DRP RI:DRP DP Hillman/rhl Gallo 4

8/ /86 8/ /86 8/\\ /86 8/////86 0FFICIAL RECORD COPY GALLO 8/8/86 - 0002.0.0 4 W.Mwie 08/19/86

m Rochester Gas 2

and Electric Company cc w/ encl:

Harry H. Voigt, Esquire Central Records (4 copies)

Director, Power Division Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York bec w/ enc 1:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

R. M. Gallo, DRP Section Chief bec w/o encl:

S. J. Collins B. Hillman C. J. Heltemes, AEOD M. Williams, AE0D i

h1 Coilins ane 8/[/86 8/b/86

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6 0FFICIAL RECORD COPY GALLO 8/8/86 - 0002.0.0 08/08/86

SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Ginna during the January 1, 1985 to June 30, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in NUREG/CR-4178.

The results of this evaluation indicate that Ginna has an overall average LER score of 7.3 out of a possible 10 points, compared to a current industry average of 7.9 for the units / stations that have been evaluated to date using this methodology.

The principle weaknesses identified in the LERs, in terms of safety

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significance, involve the requirements to provide an adequate safety assessment (Requirement 50.73(b)(3)), the requirement to discuss corrective actions (Requirement 50.73(b)(4)], and the requirement to provide adequate identification of failed components [ Requirement 50.73(b)(2)(ii)(L)]. A safety assessment is needed to describe the actual consequences or, more 1

frequently, to assess the possible consequences of the event. The assessment must give specific reasons why there were or were not consequences to the plant and public. Two things should be discussed for corrective actions. One, the actions taken to fix the specific problem and

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two, the actions taken to prevent recurrence of the problem. Anytime an event involves a component that fails or is suspected of contributing to the event because of its design, the component must be identified in the text of the LER so that others in the industry that might have the same component will be aware of the problem.

In addition, Ginna should consider the use of an outline format for their LERs such as the one recommended in Appendix C of NUREG-1022, Supplement No. 2.

A strong point for the Ginna LERs in terms of safety significance is the discussion of failure mode, mechanism, and effect of each failed component (Requirement 50.73(b)(2)(11)(E )).

s One general observation resulting from the evaluation concerns an apparent design change discussed in LER 85-012-00. This LER describes a change that was made to the Containment Fan Cooling System as part of the corrective actions; however, the LER does not discuss what was done'to ensure that the system would continue to perform all of its intended functions (e.g., cooling).

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y AEOD INPUT TO SALP REVIEW FOR GINNA Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) su:ir.:itted by Ginna during the January 1 U.585 to June 30, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178.

The sample consists of 11 LERs, which is half of the_LERs that were on file at the time the sample was selected.

See Appendix A for a itst' of-the L 1 i

selected fon the sample.

It was necessary to start the evaluation before the end of the SALP assessment period because the input was due such a.short time after the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for review.

Methodology The evaluation consists of a detailed review of each selected LER to determinehcwwellthecon$entofitstext, abstract,andcodedfieldsmeet 2

3 the requirements of NUREG-1022, and Supplements.1 and 2 to NUREG-1022.

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

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

The second part con *sists of determining a score (0-10 points) for the text, abstract, and coded fields of each LER.

j 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 pertain'.'ng to the event, and (2) they prcvide d

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basis for a count of general deficiencies for the overall sample of LERs that was reviewed. Likewise, the scores serve two purposes:

(1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2,) they provide a basis for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded fields (i.e., 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score = overall LER score).

The results of the LER quality evaluation are divided into two categories:

(1) detailed information and (2) summary information. The detaileo information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER

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(Appendix B), tables of the number of deficiencies and observations for the

~ ~ ~ text, abstract and coded fields (Appendix C), and comment sheets containing narrative statements concerning the contents of each LER (Appendix D).

When referring to these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.

General Observation Although the purpose of this evaluation is to assess the content of the individual LERs selected for review, the analysts often make other observations which they believe should be brought to the attention of the licensee. The following is a discussion of an observation that was noted during the evaluation.

A potential problem was observed in LER 85-012-00. This LER discusses an apparent design change made to the Containment Fan Cooli,ng System. The text discussion for this LER adaresses the effect of the change on the filtration and air mixing, but fails to aodress the effect of the

I f change on the ability of the fan coolers to provide adequate cooling during non-LOCA situations at lower levels in the containment (i.e., those levels below the LOCA flood level). The text discussion does not indicate whether the change would affect the cooling of spaces during normal system operation.

By opening additional vent paths above the LOCA flood level, the cooling flow would appear to be less to the lower levels.

Discussion of Results

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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 station's performance (on a scale of 0 to 10) in submitting LERS that meet the reouirements of 10 CFR 50.73(b).

Table 1 presents the average scores for tPe sample of LERs evaluated for Ginna. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology.

Table 2 ano Appendix Table 6-1 provide a summary of the information that is the basis for the average scores in Table.t. For example, Ginna's average score for the text of the LERs that were evaluated is 7.1 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

TABLE 1.

SUMMARY

OF SCORES' FOR GINNA Average High Low Text 7.1 8.9 5.0 Abstract 7.3 8.9 5.4 Coded Fields D.7 9.8 7.6 Overall 7.3 8.7 5.8 i

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 GINNA TEXT Percentage Reauirements [50.73(b)] - Descriptions Scores ( )a (2)(ii)(A) - - Plant condition prior to event 82 (11)

(2)(ii)(B) - - Inoperable equipment that contributed b

(2)(ii)(C) - - Date(s) and approximate times 80 (11)

(2)(ii)(D) - - Root cause and intermediate cause(s) 80 (11)

(2)(ii)(E) - - Mode, mechanism, and effect 100 (6)

(2)(ii)(F) - - EIIS Codes 0 (11)

(2)(11)(G) - - Secondary function affected b

(2)(ii)(H) - - Estimate of unavailability 75 (8)

(2)(ii)(I) - - Method of discovery 100 (11)

(2)(ii)(J)(1)-- Operator actions affecting course 100 (4)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 79 (6)

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(2)(ii)(K) - - Safety system responses 88 (4) 50 (5))

(2)(ii)(L) - - Manufacturer and model no. information 46 (!1 Assessment of safety consequences (3)

Corrective actions 74 (11)

(4)

Previous similar event information 9 (11)

(5)

(2)(i) - - - - Text presentation 72 (11) i ABSTRACT Percentage Requirements [50.73(b)(1)] - Descriptions Scores ( )*

- Major occurrences (Immediate cause and effect 95 (11) information)

- Description of plant, system, component, and/or 84 (4) personnel responses l

- Root cause information

,75 (11)

- Corrective Action information 45 (11) l

- Abstract presentation 74 (11) i i

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(continued)

CODED FIELOS Percentage item Number (s) - Description Scores ( )*

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1, 2, and 3 - Facility name (unit no.), docket no. and 100 (11) page number (s) 4 - - - - - - Title 53 (11) 5, 6, and 7 - Event date, LER No., and report date 100 (11) i 8 - - - - - - Other facilities involved 96 (11) 9 and 10 - - Operating mode and power level 100 (11) 11 - - - -

, Reporting requirements 95 (11) 12 - - - - - Licensee contact information 98 (11) 13 - - - - - Coded component failure information 89 (11) 14 and 15 - - Supplemental report information 100 (11) 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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O before the event [10 CFR 50.73(b)(2)(11)(A)] to text presentation. The percentage scores in the text summary section of Table 2 provide an indication of how sell each text requirement was addressed by the station for the 11 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the station is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these requirements.

Scores of 15 or above, but less than 100, indicate

,7 that the lieensee probably understands the basic requirement but has either:

(1) excluded certain less significant information from most of the discussion concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs.

The licensee should review the LER specific comments presented in Appendix D in order to determine why it received less than a perfect score for certain requirements.

The text requirements with a score of less than 75 are discussed below in their order of importance.

In additicn, the primary deficiencies in the abstract l

and coded fields are discussed.

Eight of the eleven LERs evaluated were considered to be deficient in the area of providing an assessment of the safety consequences and implications of the event, Requirement 50.73(b)(3).

Every LER is required to contain a discussion of the safety assessment that should be performed after every event.

If the conclusion of this discussion is that "there were no safety consequences", sufficient details must be provided to allow the reader to determine how this conclusion was reached..For example, if it was concluded that there were no consequences because there were other

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systems (or means) available to mitigate the consequencef of the event, these systems or means should be discussed in the text.

In addition, each discussion should include information as to whether or not the oced"rrence

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could have happened under a set of initial conditions that would have made the consequences more severe.

If the occurrence could not have occurred under a more severe set of conditions, the text should so state.

j Eight of the eleven LERs failed to adequately discuss the corrective

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actions, Requirement 50.73(b)(4). The corrective action discussion should include two parts.

The first should discuss actions needed to bring the plant to a safe and stable condition and should include any repairs which l

may be necessary to return the plant to operation. Second, the discussion should address actions necessary to prevent recurrence including investigation of other areas of the plant to determine if similar problems exist. Of the eight LERs, three had incomplete discussions of part one and

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four f ailed-to adequately discuss actions taken or planned to prevent

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recurrence. Providing adequate detail and discussing all actions taken by the plant would probably bring the score (74%) for this requirement up, 4

since it is just below acceptable (75%).

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l Although the score (79%) for Requirement 50.73(b)(2)(ii)(J)(2),

personnel and procedural errors, is marginally adequate, this requirement is discussed anyway because of its importance. Only six LERs were considered to involve personnel error, but three of these were considered to be incomplete. No pattern was noticed, so it will be necessary to refer j

to Appendix 0 for specific consnents. The requirement to discuss personnel error is closely linked to Requirement 50.73(b)(2)(11)(D) for root cause, but asks for specific details concerning the personnel or procedural error. The only reconnendation is to investigate personnel errors to the extent that all aspects of Requirement 50.73(b)(2)(ii)(J)(2) can be discussed.

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While only six LERs involved component failures, three of these failed to provide any identification of the failed component, Requirement 50.73(b)(2)(ii)(L). A component that needs to be repaired l

usually implies a failure and, therefore, should be identified.

If the tailed component is too small to have its own model number, then tfie smallest uniquely ide6tifiable component which contains the failed part i

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should be identified.

Other items, such as broken pipe, may not have a model number.

For an item such as a pipe, the pipe material, pipe size, and system of which it is a part should be provided.

Identification of failed components allows others in the industry to become aware of problems that might be generic within the industry.

Requirement 50.73(b)(2)(11)(H), unavailability of safety trains, had a marginally acceptable score of 75%.

The time a safety system to unavailable is important because this information becomes part of the generic data necessary to perform probabilistic risk assessments. Adequate attention paid to providing date and time information for major occurrences (50.73(b)(2)'ii)(C)) will usually ensure that the unavailability time can

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be determinid.

Requirement 50.73(b)(5) was not adequately addressed in ten of the eleven LERs in that their text did not include the necessary information concerning previous similar # events. All previous similar events should be appropriately referenced (by LER number, if possible) and the history of the on-going problem should be discussed, if necessary.

If there have been no previous similar events, the text should state this. This information

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is important because it can aid a licensee in determining if there is a recurring problem and whether or not the corrective actions are effective.

None of the LERs included the Energy Industry Identification System (E!IS) codes.

Requirement 50.73(b)(2)(ii)(F) requires inclusion of the appropriate Elis code for each system and component referred to in the text.

The text presentations received an overall score of 72%.,This score could probably be improved upon by the use of a consistent text outline (see NUREG-1022, Supplement No. 2, Appendices C and D).

For example, every

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text should include outline headings such as:

Event Description, Reportability, Cause, Safety Assessment, Corrective Actions, and Similar Occurrences.

If applicable, other headings such as: Background Time Sequences, Plant and/or System Responses, System Descriptions or Generis l

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i Implications can be added.

In addition, the text presentation should include diagrams, where appropriate, to supplement the text description and to aid reader understanding.

Finally, all acronyms should be defined in the text on their first usage.

While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, summarize the following infornetton from the text:

1.

Cause/Effect What happened that made the event reportable.

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2.

Responses Major plant, system, and personnel responses as a result of the event.

3.

Root / Intermediate The underlying cause of the Causes event. What caused the component and/or system failure or the personnel error, s

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.

Numbers 1 and 2 above were adequately summarized in the abstracts of the LERs reviewed.

Number 3 had a marginally acceptable score of 75%

and Number 4 had an unacceptable score of 45%.

Both of these can be improved by ensuring that the cause and corrective action information that is contained in the text is adequately summarized in the abstract.

Improvementintheabstractpresentation(Score =74k)wouldaidin fulfilling the summarization needed for Items 3 and 4, above. Be sure to use as much of the space available (i.e., the 1400 space's) as possible, and summarize major items that are discussed in the text.

l The main deficiency in the area of coded fields involves the title, Item (4). Ten of the titles fail to indicate root cause and three failed to include the link (i.e., circumstances or conditions which tie the root cause to the result).

In some of the LERs the result (i.e., why the event was required to be reported) was too vague. For example, "ESF Actuation" is too vague and should be stated more specifically, such as, " Safety Injections" or " Containment Isolation". While the result is considered to be the most important part of the title, cause and link information must be included to make a title complete. An example of a title inat only addresses the result might be " Reactor Scram". This is inadequate in that the cause and link are not provided. A more appropriate title might be

" Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor

_r Scram".

From this title, the reader knows the cause involved either personnel or procedures and that testing " linked" the error to the result.

In addition, eight LERs had titles that included undefined acronyms. When possible (i.e., when space is not a problem), acronyms should not be used in a title.

i Table 3 provides a summary of the areas that need improvement for the Ginna LERs.

For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and D.

General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 2.

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TABLE 3.

AREAS MOST NEEDING IMPROVEMENT FOR GINNA LERs D

Areas Comments Safety assessment information All LERs should include a detailed safety assessment. The text should discuss whether or not the event could have been worse had it occurred under different but probable circumstanres and provide information about backup systems which were available to limit the consequences of the event.

Corrective actions Be sure to include details about actions required to bring the plant

_y to a safe and stable condition, to repair the plant, and to prevent recurrence.

Personnel error The personnel error discussion should address all applicable requirements of 50.73(b)(2)(ii)(J)(2).

Manufacturer and model number Component identification information information should be included in the text for each component failure or whenever a component is suspected of contributing to the event because of its design.

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.

Previous similar events Previous similar events should be LE8 number) or referenced (e.g., by'ed',* the text if none are identift should so state.

Ells codes Ells codes should be provided in the text for all systems and components discussed in the text.

Text presentation The use of a consistent outline J

format would probably improve the text presentations.

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(continued) 1 Areas Conrnents

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/mtracts Cause and corrective actions j

discussed in the text need to be summarized in the abstract.

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Coded fields 4

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Titles Titles should be written such that they better describe the event.

In particular, include the root cause of the event. Avoid use of acronyms l

in the title.

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REFERENCES 1.

B. S. Anderson, C. F. Miller, 8. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.

2.

Oftice for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.

3.

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

4.

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

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR GINNA O

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TABLE A-1.

LER SAMPLE SELECTION FOR GINNA Sample Number LER Number Comments 1

85-001-00 2

85-004-00 ESF 3

85-007-00 SCRAM 4

85-010-00 SCRAM 5

85-011-01 SCRAM 6

85-012-00 7

85-016-00

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8 85-017-00 9

85-018-00 SCRAM 10 86-001-00 11 86-002-00 O

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APPENDIX B EVALUATION SCORES Of INDIVIDUAL LERs FOR GINNA

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TABLE B-1.

EVALUATION SCORES OF INDIVIOUAL LERs FOR GINNA a

LER Sample Number j

1 2

3 4

5 6

7 8

9 10 11 12 13 14 15 16 l

Text 5.9 7.6 6.7 7.0 6.5 5.0 7.2 7.6 7.3 7.9 8.9 i--

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Abstract 6.1 6.0 8.2 5.4 6.9 6.9 8.9 8.0 8.3 7.0 8.1 Coded F leids 8.3 8.7 8.0 8.5 8.4 7.6 9.0 8.8 9.8 9.3 9.4 Overall 6$2 7.2 7.3 6.6 6.8 5.8 7.9 7.9 7.9 7.8 8.7 4

a LER Sample Number i

17 18 19 20 21 22 23 24 25 26 27 20 29 30 AVERAGE Text 7.1 Abstract 7.3 1

l Coded Fields 8.7 Overall 7.3 1

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

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4 APPENDIX c DEFICIENCY AND OBSERVATION O

COUNTS FOR GINNA 9

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TEXT DEFICIENCIES AND OBSERVATIONS FOR GINNA Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (

)D a

50.73(b)(2)(ii)(A)--Plart operating 3(11).

conditions before the ? vent were not included or were inadequate.

50.73(o)(2)(ii)(B)--Discussion of the status 0 (4) of the structpres, components, or systems that were inoperable at the start of the Gvent and that contributed to the event was not included or was inadequate.

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50.73(b)(2)(ii)(C)--Failure to include 5 (11) sufficient cate and/or time information.

a.

Date information was insufficient.

I b.

Time information was insufficient.

5 50.73(b)(2)(ii)(0)--The root cause and/or 7 (11) intermediate failure, system failure, or personnel error was not included or was inadequate.

a.

Cause of component f ailure was not 6

incluaed or was inadequate 4

b.

Cause of system failure was not 2

included or was inadequate c.

Cause of personnel error was not 1

included or was inadequate.

50.73(b)(2)(fi)(E)--The f ailure 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.

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• T ABLE C-1.

(continued)

Nuniber of LERS with Deficiencies and Observations sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (

)D a

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

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

50.73(b)(2)(ii)(G)--For a f ailure of a 0 (0) co'nponent with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

50.73(b)(2)(ii)(H)--For a f ailure that 3(8) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

50.73(b)(2)(ii)(1)--The method of discovery 0 (11)

I or each component failure, system failure, personnel error, or procedural error was not i

included or was inadequate.

j a.

Method of discovery for each cemponent f ailure was not included j

or was inadequate 4

b.

Method of discovery for each system f ailure was not included or was inadequate 4

c.

Method of discovery for each personnel error was not included or was inadequate d.

Method of discovery for each procedural error was not included or was inadequate.

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(continued)

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

)b a

50.73(b)(2)(ii)(J)(1)--Operator actions that 0 (4) l affected tne course of the event including operator errors and/or procedural deficiencies were not included or were inadequate.

50.73(o)(2)(ii)(J)(2)--The discussion of 3 (6) each personnel error was not included or was inadequate.

~

a.

OBSERVAT]ON: A personnel error was I

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

b.

50.73(b)(2)(ii)(J)(2)(i)--Discussion 1

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

i c.

50.73(b)(2)(ii)(J)(2)(ii)--Discussien 1

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 l

covered by an approved procedure was not included or was inadequate.

d.

50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0

of any unusual characteristics of the t

work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.

e.

50.73(o)(2)(ii)(J)(2)(iv)--Discussion 1

of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) was not included or was inacequate.

1 l

_s 9

--e

-._b a

=

-_.m_..

l

• TABLE C-1.

(continued)

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

)D a

50.73(b)(2)(ii)(K)--Automatic and/or manual 1 (4) safety system responses were not included or tere inadequate.

50.73(b)(2)(ii)(L)--The manuf acturer and/or 3 (6) model number of each failed component was l

not included or was inadequate.

50.73(b)(3)--An assessment of the safety 8 (11) consequences and implications of the event

~

was not included or was inadequate.

i a.

OBSERVATION: The availability of 0

l 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 i

existed.

b.

OBSERVATION: The consequences 4

of the event had it occurred u' der n

more severe conditions were not discussed.

If the event occurred l

under what were considered the most l

Severe conditions, the text should so i

state.

50.73(b)(4)--A discussion of any corrective 8(11) actions planned as a result of the event including those to reduce the probability cf similar events occurring in the future was not included or was inadequate.

l e

p 9

TABLE C-1.

(continued)

Number of LERS with l

Deficiencies end.

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

)b a

a.

A discussion of actions required to 3

l l

l 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.

l b.

A discussion of actions required to 4

i reduce the probability of recurrence of the problem or similar event (correc(,the root cause) was not included or was inadequate.

l c.

OBSERVATION: A discussion of actions 0

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

i correct the faulty part in all i

components with the same manufacturer and model number) was not included or was ir. adequate.

50.73(b)(51--Informationconcerningprevious 10(11) similar events was not included or was inaaequate.

l i

i i

80 o

L i

I l

l l

?

TABLE C-1.

(cont' ued)

Number of LERs with l

Deficiencies and Sub-parag ph Paragrapn Descriction of Deficiencies and Observations Totals Totals (

)D a

50.73(b)(2)(1)--Text presentation 8 (11)

Inaaequacies, a.

OBSERVATION: A diagram would have 1

aided in understanding the text discussion.

b.

Text contained undefined acronyms 3

and/or plant specific designators.

c.

The text contains other specific 6

deficiencies relating to the readability.

=

a.

The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total, b.

The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis the number of LER$ for which the requirement was considered applicable.

i l

l

+

l 1

O

[

e i

i

__. _ =.

1 e

l TABLE C-2.

ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR GINf4A l

Number of LERS with Deficiencies and.

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

)D a

A sommary of occurrences (immediate cause 3 (11) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 3(4) responses was not included or was inadequate.

a.

Summary of plant responses was not 0

included or was inadequate.

~

b.

Summary of system responses was not 1

included or was inadequate.

c.

Summary of personnel responses was not 2

incluaed or was inaaequate.

A summary of the root cause of the event 8 (11) was not included or was inadequate.

A summary of the corrective actions taken or 9 (11) planned as a result of the event was not included or was inadequate.

0 0 g

00 e

i e

G 8

e

(

-.--.--~_,,....,__,_cr.._

,,,__,,,__,._.,.m,my,7

_r.,~_y,

TABLE C-2.

(continued)

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

)

Abstract presentation inadequacies 4 (11) a.

OBSERVATION: The abstract contains 0

information not included in the text.

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

b.

The abstract was greater than 0

~

1400 characters c.

The abstract contains undefined 1

acronyhs and/or plant specific designators.

d.

The abstract contains 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 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.

e 6

,., - - =.~,

TABLE C-3.

CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR GINNA Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals Totals (

)b a

Facility Name 0 (11) a.

Unit number was not included or incorrect.

b.

Name was not included or was

^

incorrect.

c.

Additional unit numbers were included but not required.

Docket Number was not included or was 0 (11)

~

~

incorrect.

Page Number was not included or was 0 (11) incorrect.

Title was lef t blank or was inadequate 10 (11) a.

Root cause was not given in title U

I:

b.

Result (effect) was not given in title o

c.

Link was not given in title 5

Event Date 0 (11) 4 a.

Date not included or was incorrect.

b.

Discovery date given instead of event date.

LER Number was not included or was incorrect 0 (11)

Report Date 0 (11) a.

Date not included b.

OBSERVATION: Report date was not within thirty days of event date (or discovery date if appropriate).

Other Facilities information in field is 0 (11) inconsistent with text and/or abstract.

Operating Mode was not included or was 0 (11) inconsistent with text or abstract.

e i

4

-.,, -,,. - ~..,. -

-.-m.,

..n_,n-

,--,,.,--.--,..n-.-.~.n,n a

ai r

i i

TABLE C-3.

(continued) j','

i t

.r Number of LERs with I'

Deficiencies and

~

Observations '

s 3

Sub-paragrapn.

Paragraph DescriptionofDeficienciesandObser)ations Totals Totals (

)b.

a Power level was not included or was 0 (11)

\\

inconsistent with text or abstract t-1 (11)

Reporting Requirements t

a.

The reason for checking the "0THER" 0

.F requirement was not specified in tne y

J.

i abstract and/or text.

b.

OBSERVATION:

It may have been more C.,

appropriate'to report the event under

~

~

}'

a different paragraph..

c.

OBSERVATION:

It may n' ave been 1

s

~

appropriate to report this event under an 4

additional unchecked paragraph.

~ v I (11)

Licensee Contact a.

Field left blank 0

i (.

4 b.

Position title was not includsd' 1'

0 c.

Name was not inclurled d.

Phone number was not included.

0 Coded Component Failure 1 formation 4 (11) a.

One or more component failure 0

sub-fields were left blank.

b.

Cause, system, and/or component code 2

is inconsistent with text.

c.

Component failure field contains data 2

when no component failure occurred.

d.

Component f ailure occurred but entire 0

i-6 field left blank.

1. r 4

e

~

(

4.

h

()

,t-a 5

g s

s

/

1

.g

TABLE L-3.

(continued)

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

b Description of Deficiencies and Observations Totals Totals (

l Supplemental Report 0 (11) a.

Neither "Yes"/"No" block of the supplemental report field was checked.

b.

The' block checked was inconsistent with the text.

Expected submission date information is 0 (11)

_ ~

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.

'o, D

e

6 9

O e

l APPENDIX D m

LER COMMENT SHEETS FOR GINNA O

e e

e o,

O O

e e

TABLE D-1.

SPECIFIC LER COMMENTS FCP GINNA (244)

Section Comments 1.

LER Number: 85-001-00 Scores: Text - 5.9 Abstract = 6.1 Coded Fields - 8.3 Overall = 6.2 Text 1.

50.73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event is not included.

2.

50.73(b)(2)(ii)(D)--The text should discuss the root cause of the blown fuses in the computer.

3.

50.73(b)(2)(11)(F)--The Energy Industry Identification System component function

~

identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(31--Discussion of the assessment of the safety consequentes and implications of the event is not included.

5.

50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The corrective action discussion should be more specific as to whether or not the frequency of computer checks was_ increased.

The corrective action discussion should also indicate if any action is needed to correct the problem which caused the computer fuses to blow.

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.

7.

Some ideas are not presented clearly (hard to follow).

i j

Abstract 1.

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

The abstract should indicate that the messages printed on the typewriter are not accompanied with an alarm.

2.

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

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Ccmments 1.

LER Number:

85-001-00 (continued)

Coded Fields 1.

Item (4)--Title:

Root cause is not included and the result is misleading since there was no audible alarm. A more appropriate title might be " Computer Rod Position Deviation during Periodic Testing due to a Blown Fuse (f rom Personnel Error) in the Computer".

2.

Item 8--This field is for other units which may be involved, since there is only one unit at the Ginna station this field should be left blank.

d e

O e

6 0

m,

J r

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 2.

LER Number:

85-004-00 Scores: Text - 7.6 Abstract - 6.0 Coded Fields - 8.7 Overall = 7.2 Text 1.

50.73(b)(21(ti)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2.

50.73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with da

~~

a:tivity or task that was not covered by an appraved procedure is not clear for the sccond event.

_ = _ -

3.

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

OBSERVATION: The contequences of the event had it occurred under more severe conditions shodid be discussed.

If the event occurred under what are considered the most severe conditions, the text should so state.

4.

50.73(b)(51--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 system responses is inadequate. What systems responded to the safety injection actuation signal.

2.

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

The deficiencies in the maintenance procedures should be mentioned.

3.

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

4.

Abstract does not adequately summarize the text.

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 2.

LER Number:

85-004-00 (continued)

Coded Fields 1.

Item (4)--Title:

Root cause is not included and the result is vague. A more appropriate title might be

" Spurious Safety Injection Signals during Maintenance Work due to Procedural Deficiencies".

2.

Item (13)--Component failure field contains data when no component failure occurred. The text does not indicate that the diesel generator breaker failed.

~

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 3.

LER Number:

85-007-00 Scores:

Text = 6.7 Abstract = 8.2 Coded Fields = 8.0 Overall = 7.3 Text 1.

50.73(b)(2)(ii)(8)--It is not clear whether the steam flow and feed flow indications were just unreliable at that power level or were "not available" because they were not in service.

2.

50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time (date) was the reactor coolant system stabilized in hot shutdown?

3.

50.73(b)(2)(ii)(0}--The root and/or intermediate cause discussion concerning the mechanical binding of the 20 ET solenoid plunger is not included.

4.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

5.

50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is inadequate.

When was the last time (date) that the turbine trip system was tested?

6.

50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. Why were the operations personnel unable to stabilize the steam generator levels? Was the adjustment of the 20 AST solenoid mechanical stop a personnel or procedural problem?

j What group is responsible for this adjustment?

l 7.

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.

8.

50.73(b)(31--Discussion of the assefsmen't of the safety consequences and implications'tf- {he event is not included. What would have been the consequences of the turbine failing to trip had*the power level been 100%?

i l

l 1

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 3.

LER Number: 85-007-00 (continued) 9.

50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was anything done to try to prevent operations personnel from losing control of the steam generator levels in the future?

Was the 20 ET solenoid replaced with a solenoid of the same manufacturer and model number?

10, 50.~/3(b)(5)--Information concerning previous similar events is not included.

If no previous similar events are known, the text should so state.

11.

Some ideas are not presented clearly (hard to follow).

Abstract 1.

The fact that the main steam isolation valves were closed by operations personnel should have been mentioned.

2.

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

" repairs" to the selenoid valves should have been provided in more detail (i.e., state replaced and adjusted).

The procedural change to verify operability should have been mentioned.

Coded Fields 1.

Item (4)--Title: Root cause and link are not included. A better title might be " Reactor Trip from 12% Power due to Personnel Error while Manually Feeding Steam Generators".

2.

Item (13)--Cause, system, and/or component code is inconsistent with text.

It appears from the text that "SDL" should be the component code and "A" should be the cause code for the 20 AST solenoid.

l

~

TABLE 0-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 4.

LER Number: 85-010-00 Scores: Text = 7.0 Abstract = 5.4 Coded Fields - 8.5 Overall = 6.6 Text 1.

50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. When was the NIS instrumentation tested successfully?

2.

50.73(b)(2)(ii)(D)--The ruot and/or intermediate cause discussion concerning the Channel N-35 annunciation failure is not included.

It is not clear from the text whether or not the "first out' annunciation from the source range relay blocked the "first out" annunciation for the intermediate range instrumentation.

3.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included (see text comment 1).

5.

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

~~

and model no.) of the failed component (s) discussed 8

in the text is not included.

6.

50.73(b)(4)--Were any repairs needed to correct the N-35 channel problem?

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.

Some ideas are not presented clearly (hard to follow).

Abstract 1.

50.73(b)(1)--Summary of root cause is inadequate (see text comment 2).

~~

2.

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

Se

. TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 4.

LER Number: 85-010-00(continued)

Coded Fields 1.

Item (4)--Title: Root cause and link are not included. The result is also misleading. A more appropriate title might be " Inadvertent Actuation of the Reactor Protection System during Operational Testing due to a Faulty Relay".

d e

e O

f I

i l

.a l

I L

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 5.

LER Number: 85-011-01 Scores:

Text - 6.5 Abstract = 6.9 Coded Fields 8.4 Overall = 6.8 Text 1.

50.73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event is inadequate. When was the reactor stabilized at hot shutdown conditions?

2.

50.73(b)(2)(ii)(D)--The root cause discussion for the loss of condenser vacuum and failure of the "A" reactor trip breaker to open is very good. However, the root cause discussions of the "various mechanical and electrical problems encountered following the reactor trip" are inadequate, and the failure of the main turbine to trip discussion leaves the reader with many questions.

For example, why was the mechanical stop for the auto stop tripper bar out of adjustment? Why did the MSIVs position limit switches stick? Why was sufficient oxidation present on a relay contact that resulted in a rod bottom indicating light failing to illuminate? These appear to be recurring problems (as referenced in other LERs).

It is not clear why intermediate range Channel N-35 was overcompensated due to a detector changeout during the refueling outage.

Is there a procedure to set compensating voltage for this channel that was in error, or had the reactor not yet reached the required conditions, since the detector changeout, to adjust the compensating voltage correctly?

3.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(2)(ii)(J)(2)--It appears that personnel error is involved in this event, but'it is not discussed. Were some of the problems that occurred (see text comment 2) personnel or grocedural errors?

5.

50.73(b)(2)(ti)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) dis. cussed in the text is not included.

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 5.

LER Number: 85-011-01 (continued) 6.

50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The safety consequences and implications of the inability to reliably initiate a manual trip of the Main Turbine from the control room should be discussed.

OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.

If the event occurred under what are considered the most severe conditions, the text should so state.

~

7.

50.73(b)(41--Ditcussion of corrective actions taken or planned is inadequate.

A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.

Several problems (see text comment 2) have occurred previously as referenced to other LERs.

8.

The requirement to reference previous similar events by LER number is met, however the reader gets the impression that much of the required information for this event is not included in this LER because it may be found in LERs for previous similar events.

Since these various mechanical and electrical problems also occurred during this event (see text consent 2), the necessary information should be included in this LER rather than referencing a previous LER to provide this information.

Abstract 1.

50.73(b)(1)--Summary of the root cause of the decreasing condensor vacuum is not inclu,ded.

2.

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

Replacement of the baffle plate and plugging of the damaged condenser tubes should be mentioned.

p T ABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 5.

LER Number: 85-011-01 (continued) 3.

Abstract does not adequately summarize the text.

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

Coded Fields 1.

Item (4)--Title: Root cause is not included.

2.

Item (13)--Cause, system, and/or component code is inconsistent with text.

~

O e

e 1--i,-

r

- ~.,,,

,.-,-w--.

--,e---,-

_--,-r---

_y,_

_.--e_-_----

s w.

t TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 6.

LER Number:

85-012-00 Scores:

Text 5.0 Abstract = 6.9 Coded Fields - 7.6 Overall = 5.8 Text 1.

50.73(b)(2)(ii)(C)--Date and time information for major occurrences is not included.

2.

50.73f b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the apparent design error is not included.

The source of the error should be provided (i.e., what organization was responsible for the system design and/or installation?).

3.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is inadequate.

The reader must assume that the design error has existed since initial startup; but does not know how long a time period that is without going to some other source of data.

5.

50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The discussion does not address why it is alright to now have less cooling flow to the basement during non-LOCA situations.

6.

50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate.

It is not clear from the text discussion whether the opening and securing of the dampers downstream of the A and B filter exit are temporary measures (until a further evaluation is completed) or are the final corrective actions.

7.

50.73(b)(5)--Information concerning' prev'ious similar events is not included.

If no previous }imilar events are known, the text should so state.

8.

OBSERVATION: A diagram or figure would aid in understanding the event.

~

u e-e e

wm w

w

e, TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 6.

LER Number:

85-012-00 (continued) 9.

Some ideas are not presented clearly (hard to follow). Without any date or time information, it is difficult to gain a perspective of the time-history of the event.

Abstract 1.

50.73(b)(11--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate. The concern involving the iodine removal should have been stattd.

2.

The fact that the event was the result of an (apparent) design error should have been mentioned.

~

See text comment number 2.

3.

The corrective action stated in the abstract contradicts the text in that the aspect of " required cooling being reestablished" is not addressed in the text.

See text comment number 5.

4.

Abstract does not adequately summarize the text.

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

Coded Fields 1.

L'em (4)--Title:

Root cause and link (containment cooling and filtration system) are not included.

A better title might be " Design Error Discovered that Could Result in Loss of Flow through Containment Charcoal Filter During a Large Break LOCA".

2.

Item (11)--The requirements listed in the cover letter for this LER should have been checked on Form 366.

3.

Item (12)--Position title is not included.

Item (131--Componentfailurefieldcont[insdatawhen

~

4.

no component failure occurred.

Faulted components (systems) need not be provided in I, tem (13).

~

5.

Item (14)--If a further evaluation is being performed (see text comment number 6), a supplemental r.eport, which provides information as to what permanent 1

. design changes were implemented, should be prpvided.

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 7.

LER Number: 85-016-00 Scores: Text - 7.2 Abstract - 8.9 Coded Fields - 9.0 Overall - 7.9 Text 1.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2.

50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.

~

3.

50.73(b)(4)--The last paragraph of the text implies that only some of the corrective actions are listed.

All corrective actions taken or planned should be discussed.

4.

50.73(b)(5)--Information concerning previous similar events is not included.

If no previous similar events are known, the text should so state.

5.

Acronym (s) and/or plant specific designator (s) are undefined.

Abstract 1.

The root cause summary should indicate that' testing of the power supplies did not reveal the cause of the problem.

=

2.

The corrective actions summary should indicate that replacing the power supplies solved the problem.

3.

Abstract contains acronym (s) and/or plant specific designator (s) which are undefined.

Coded Fields 1.

Item (4)--Title:

Root cause (faulty power supplies) is not included.

i

1. s e

I

TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 8.

LER Number:

85-017-00 Scores: Text - 7.6 Abstract = 8.0 Coded Fields - 8.8 Overall 7.9 Text 1.

50.73(b)(2)(ii)(Al--01scussion of plant operating conditions before the event is not included.

2.

50.73(b)(2)(ii)(D)--Information concerning the "particular failure in the firing circuit card" should be included.

This information could be very useful to other plants that might use this type card.

3.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function

_r identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate.

OBSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed.

If the event occurred under what are considered the most severe conditions, the text should so state.

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.

PORC should be defined.

7.

Some ideas are not presented clearly (hard to follow).

Abstract 1.

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

See text comment 2.

2.

50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The surveillance required by operations"and the modifications to procedures should be mentioned.

Coded Fields 1.

Item (4)--Title: Root cause is not included.-

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TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 9.

LER Number:

85-018-00 Scores: Text - 7.3 Abstract - 8.3 Coded Fields - 9.8 Overall = 7.9 Text 1.

50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. The tine that the reactor was stabilized in hot shutdown should have been provided.

2.

50.73(b)(2)(ti)(D)--The root and/or intermediate cause discussion concerning the output relay (CR-3) and the Type BCF mutli-pass heat exchanger is inadequate. Why were the contacts on CR-3 dirty?

Was the tube leak on the heat exchanger considered to CD be a nornel wear problem or something else such as cracking due to vibration?

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3.

50.73(b)(2)(ii)(F 1--The Ene=gy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

4.

50.73(b)(2)(ii)(K)--Discussion of automatic and/or nanual safety system responses is inadequate. The safety systems that " operated as designed" should have been named.

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5.

50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not formalized within the text (i.e., there is not a few sentences or a paragraph devoted to this requirement).

6.

50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What was done to correct the problem with CR-3 and to prevent recurrence?

prev,ious similar 50.73(b)(5)--Information concerning{Aus similar 7.

events is not included.

If no prev events are known, the text should so st' ate.

Abstract 1.

50.73(b)(1)--The fact that the rod",oottom light did not illuminate and the operator immediately commenced j

boration should have been mentioned in the abstract.

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O TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Section Comments 9.

LER Number: 85-018-00 (continued) 2.

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

Coded Fields 1.

The acronym EH in the title should not have been used; instead, the title should say "--Manual Turbine and Reactor Trip Due to a Turbine Electro-Hydraulic Control System Problem".

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o TABLE D-1.

SPECIFIC lek COMMENTS FOR GINNA (244)

Section Comments

10. LER Number: 86-001-00 Scores: Text - 7.9 Abstract - 7.0 Coded Fields = 9.3 Overall - 7.8 Text 1.

50.73(b)(2)(ii)(C)--Time infornetton for major occurrences is inadequate. When will corrective a-tions be completed?

2.

50.73(b)(2)(ii)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3.

50.73(b)(3)--Although out only a short time, the JP

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safety assessment should address the consequences of one transmitter being out when needed.

4.

50.73(b)(4)--Corrective action number 3 raises the question as to whether or not the " proper precautions" are listed or a reference given where they can be found. Will the corrective action be completed before the surveillance is needed again and how will personnel be made aware of the changes?

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.

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Abstract 1.

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

Coded Fields 1.

Item (4)--Title:

Root cause is not included.

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TABLE D-1.

SPECIFIC LER COMMENTS FOR GINNA (244)

Sect *c Comments

11. lei humber: 86-002-00 Scores:

Text = 8.9 Abstract - 8.1 Coded Fields - 9.4 Overall = 8.7 Text 1.

50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2.

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

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3.

_50.73(b)(5)--Information concerning previous similar events is not included.

If no previous similar events are known, the text should so state.

4.

Acronym (s) and/or plant specific designator (s) are undefined. CCW and RHR are fairly common acronyms, but they should be defined when they are first used in the text.

Abstract 1.

50.73(b)(1)--Summary of occurrences (immediate cause(s) and effects (s)) is inadequate.

The abstract should mention that these valves were required by the Technical Specifications to be operable for the refueling mode.

2.

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

The statement summarizing the cause is confusing.

Coded Fields 1.

Item (41--Title: Root cause is not included.

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