NUREG/CR-4178, Forwards Evaluation of LERs During May 1985 - Jul 1986 Based on Exam of 22 Randomly Selected Lers,Per NUREG/CR-4178
| ML20215F630 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/06/1986 |
| From: | Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| RTR-NUREG-CR-4178 NUDOCS 8610160296 | |
| Download: ML20215F630 (66) | |
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t 007 6 E86 Docket Nos. 50-387 50-388 Pennsylvania Power & Light Company ATTN: Mr. H. W. Keiser Vice President Nuclear Operations 2 North Ninth Street Allentown, Pennsylvania 18101 Gentlemen:
Subject:
Assessment of Susquehanna Steam Electric Station Licensee Event Reports This letter forwards to you an evaluation of Licensee Event Reports (LER's) for the Susquehanna Steam Electric Station (SSES) during the period of May 1, 1985 through July 31, 1986. This assessment was performed based upon an exami-nation of 22 LER's selected randomly from those submitted during the period.
The evaluation was performed generally in accordance with the methods used in NUREG/CR-4178, "An Evaluation of Selected Licensee Event Reports prepared pur-suant to 10 CFR 50.73 (Draft)." Some minor refinements to the technique were employed.
This evaluation does not make a determination as to whether regulatory require-ments were met, but rather assesses the quality of the submittals.
It also makes specific recommendations for improving the overall quality of the SSES LER's, and it is for this reason that it is sent to you for your use.
Your cooperation with us is appreciated.
Sincerely, Origina1 Signed Byt Harry B. Kister, Chief Reactor Projects Branch No. 1 Division of Reactor Projects
Enclosures:
As Stated 9610160296 861006 PDR ADOCK 00000397 S
PDR OFFICIAL RECORD COPY 371FUHRMEISTER9/25/86 - 0001.0.0 10/01/86 23rc/
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Mr. H. W. Keiser, PP&L 2
cc:
A. R. Sabol, Manager, Nuclear Quality Assurance W. E. Barberich, Manager, Nuclear Licensing T. M. Crimmins, Superintendent of Plant-SSES H. W. Hirst, Manager, Joint Generation Projects Department R. J. Benich, Services Project Manager, General Electric Company B. D. Kenyon, Senior Vice President-Nuclear Bryan A. Snapp, Esquire, Assistant Corporate Counsel William Matson, Allegheny Electric Cooperative Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania bcc:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
DRP Section Chief Robert J. Bores, DRSS RI:DRP RI:DRP RI Fuhrme rster Strosnider Kister 9/30/36 lS/3P/86 f0/3/86 0FFICIAL RECORD COPY 371FUHRMEISTER9/25/86 - 0002.0.0 09/25/86
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SUMMARY
An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Susquehanna 1 and 2 during the May 1, 1985 to July 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in a report entitled "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50:73 (DRAFT)",
NUREG/CR-4178, March 1985. The results of this evaluation indicate that the Susquehanna 1 and 2 LERs have an overall average score of 8.0 out of a possible 10 points, compared to a current industry average of 7.9 (i.e.,
the average of the latest overall average LER score for each unit / station that has been evaluated to date using this methodology).
The principle weaknesses identified in the Susquehanna LERs, in terms of safety significance, involve the requirements to provide a safety assessment and to adequdtcly-fdentify failed components in the text. The failure to provide an adequate safety assessment for every event prompts concern as to whether or not each event is being evaluated such that the possible consequences of the event, had it occurred under a different set of initial conditions, are being identified. The failure to adequately identify each component that fails prompts concern that possible generic problems may go unnoticed by the industry for too long a time period.
A strong point for the Susquehanna LERs is that the requirement to provide the failure mode, mechanism, and effect of each failed component was satisfied for all applicable LERs in the sample.
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AE00 INPUT TO SALP REVIEW FOR SUSQU6HANNA 1 AND -2
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Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Susquehanna 1 and 2 during.the May 1, 1985 to July 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative lample of the station's LERs was
. evaluated using a refinement of the basic methodology presented in NUREG/CR-4178.
The sample consists of a total of 22 LERs (i.e., 15 LERs for Susquehann_a,1 and 7 for Susquehanna 2),'wEch is half of the LERs on file at the time the sample was selected. The Susquehanna LERs were evaluated as one sample for this SALP period because it was determined that their LERs are both written and formally reviewed at the station, rather than unit, level.
See Appendix A for a list of the LER numbers in the sample.
It was necessary to start the evaluation before the end of the SALP assessment period because the input was dN such a short time after the end of the SALP period. Therefore, all of the LERs prepared during the SALP
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assessment period were not available for review.
Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet the requirements of 10 CFR 50.73(b), NUREG-1022, and Supplements 1 and 2 to NUREG-1022.
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.
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1 The LER specific conuments serve two purposes:
(1) they point out what theangystsconsideredtobethespecificdeficienciesorobservations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the o'v'erall 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).
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w The results of the LER quality evaluation are divided into two (1) detailed informatig, ag (2) summary information. The categories:
n detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the score.s 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 these appendices, the reader is cautioned not to try to directl[ correlate the number of comments on a commerft' sheet with the LER
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scores, as the analysts has flexibility to consider the magnitude of a deficiency when assigning scores.
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 j
of 0 to 10) in submitting LERs that meet the requirements of 10 CfR 50.73(b). Again, Susquehanna LERs were evaluated as one sample, rather than two separate samples (by unit), because it was determined that the Susquehanna LERs are both written and formally reviewed at the station, rather than the unit, level.
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Table 1 presents the average scores for the sample of LERs evaluated for the station.
The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained 15 NUREG/CR-4178 due to refinements in the methodology.
In order to place the scores provided in Table 1 in perspective, the distribution of the overall average score for-all licensees that have been evaluated using the current methodology is provided on Figure 1.
Additional scores are added to Figure 1 each month as other licensees are evaluated.
Table 2 and Appendix Table 8-1 provide a summary of the information that is the basis for the average scores in Table 1.
For example, Susquehanna's average score for the text of the LERs that were evaluated is 7.5 out of a possible 10 points.
From Table 2 it can be seen that the text score actually results from the review and evaluation of 17 different requirements ranging (rom the discussion of plant operating
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conditionsbeforetheevent[10CFR50.73[b)(2)(11)(A)]totext presentatlon. The-percentage scores in the text summary section of Table 2 provideanindica'tionof'howwekihaI6textrequirementwasaddressedby the station for the 22-LERs that-were evaluated.
Discussion of Specific Deficiencies
~9't A review of the_ percentage scores presented in Table 2 will quigkly
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point out where the station is experier.cing the most difficulty in preparing LERs.
For example, requirement percentage scores of less than 75 indicate that the station probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the station probably understands the basic requirement but has either:
(1) excluded certain less significant information from most of the discussion concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs.
The station should review
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the LER specific comments presented in Appendix 0 in order to determine why 1
it received less than a perfect score for certain requirements. The text l
requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance.
In addition, the primary deficiencies in the abstract and coded fields are discussed.
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a TABLE 1.
SUMMARY
OF SCORES FOR SUSQUEHANNA 1 AND 2 Average
' High low
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Text 7.5 8.9 5.8 Abstract 8.7 9.8 6.9 Coded Fields 8.7 9.7 7.9 Overall 8.0 9.2 6.8 a.$e~e'AppendixBforasummaryofscoresforeachLERthatwasevaluated.,_.
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>s ric ure 1.
Distribution of overall average LER scores 15
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14 -
13 -
.t 12 -
Susquehanna 1,2 g
10 -
9-8-
._9 7-
"g-6-
g 5-4-
a 3-Z 2-
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l 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 Overall average scores i
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9 TABLE 2.
LER REQUIREMENT PERCENTAGE SCORES FOR SUSQUEHANNA 1 AND 2
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TEXT Percentage 8
Requirements ISO.73(b)1 - Descriptions Scores ( 1 (2)(ii)(A) - - Plant condition prior to event 59 (22)
(2)(ii)(B) - - Inoperable equipment that conttibuted b
(2)(ii)(C) - - Date(s) and approximate times 86 (22)
(2)(11)(0) - - Root cause and intermediate cause(s) 85 (22)
(2)(ii)(E) - - Mode, mechanism, and ef fect 100 {*0)
(2)(ti)(F) - - EIIS Codes 59.(22)
(2)(11)(G) - - Secondary function affected b
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(2)(11)(H) - - Estimate of unavailability 100 (9)
(2)(11)(I) - - Method g lscovery 100 (22)
(2)(ii)(J)(1) - Operator actions affecting course 89 (6)
(2)(11)(J)(2) - Personnel error (procedural dgficiency) 90 (13)
(2)(ii)(K) - - Safety,1ystem responses
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100 (14)
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(2)(ii)(L) - - Manufacturer and model no. information 30 (10)
Assessment of safety consequences 42 (22)
(3)
Corrective actions 82 (22)
(4)
Previous similar event information 0 (22)
(5)
(2)(1) - - - - Text presentation 77 (22)
ABSTRACT Percentage a
l Requirements ISO.73(b)(1)1 - Descriptions
_ Scores ( l l
- Major occurrences (Immediate cause and effect 99 (22) information)
- Description of plant, system, component, and/or 98 (15) personnel responses
- Root cause information 82 (22)
- Corrective Action information 83 (22)
- Abstract presentation 77 (22) l
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TABLE 2.
(continued)
CODED FIELDS Percentage Item Number (s) - Description Scores ( )a 1, 2, and 3 - Facility name (unit no.), docket no, and 98 (22) page number (s) 4 - - - - - - Title 62 (22) 5, 6, and 7 - Event date, LER No., and report date 98 (22)
?F 8 - - - - - - Other facilities involved 98 (22) 9 and 10 - - Operating mode and power level 95 (22)
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11 - - - - - Reporting requirements 96 (22) 12 - - ~ - - Licensee contact information 93 (22) 13 - - - - - Coded component failure information 92 (22) 14 and 15 - - Supplemental report information 95 (22) 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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The safety assessments for sixteen of the LERs were found to be deficient or not included, Requirement 50.73(b)(3). A detailed safety assessment is required in all LERs and should include information such as:
1.
An assessment of the consequences and implications of the event including specifics as to why it was concluded that there were no safety consequences, if applicable.
It is inadequate to state "this event had no safety consequences or implications" without explaining how that conclusion was reached.
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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 state so.
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Finally, a safety assessment should name-ether systems (1'f any) that were available to perform the function of the safety systems that were unavailable during the event.
The corrective action discussions were considered inadequate in fourteen LERs, Requirement 50.73(b)(4), even though the overall score for this requirement was 82%. The most common deficiency concerning this requirement was that sufficient details were not always provided cor.cerning actions taken to prevent recurrence of the event.
The manufacturer and/or model number (or other unique identification) was not provided in the text of seven of the ten LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that fail, or whose design contributes to the event, should be identified in the text so that others in the industry can be made aware of potential problems. An event at one station can often lead to the identification of a generic problem that can be corrected at other plants or stations before they experience a similar event.
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Operating conditions prior to the event were inadequate in ten of twenty-two LERs, Requirement 50.73(b)(2)(11)(A). The power level and/or the operating ~nede (e.g., hot shut'down) should be provided very early in the event discussion so that the reader has an understanding of plant conditions such as temperature and pressure and/or the activities in progress (e.g., refueling) just prior to the occurrence that made the event reportable.
'SMC;Y Requirement 50.73(b)(5)wasnotadequatelyaddress'EE'inanyofthe twenty-two 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, although not'~specifically required, the history of the-on-going problem should be discussed, if necessary.
If there have been no previous similar i
events, the text should state this. This information 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.
Seventeen of the twenty-two LERs did not include the Energy Industry Identification System (EIIS) codes for each system and component referred to in the text. Generally, these codes were provided for the main system referred to in the text, but codes were not included for most of the l
components. EIIS codes should be used for each system and component referred to in the text, Requirement 50.73(b)(ii)(F).
The text presentations received an overall score of 77%. This score can be improved upon by the use of a consistent text outline (see NUREG-1022, Supplement No. 2 Appendices C and D).
For example, every 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 Generic Implications can be added.
Once a basic outline is adopted by all those responsible for i
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writing LERs, the overall quality of the reports will also improve, based simply on the fact that every LER will contain at least some information concerning the requirements applicable to the event.
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 information from the text:
mm, 1.
Cause/Effect What happened that made the event reportable.
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Responses Major plant, system, and personnel responses as a result
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3.
Root / Intermediate lhe underlying cause of the Causes event. What caused the component and/or system failure
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or the personnel error.
4.
Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence.
Items one and two were discussed very well.
Some LERs did not adequately summarize Items 3 and 4 (see Appendix D-1 for specific comments).
By ensuring that this information is summarized in each abstract, the abstract presentation score should improve.
The main deficiency in the area of coded fields involves the title, Item (4).
Eighteen of the titles failed to indicate the root cause, four failed to include the result (i.e., why the event was required to be reported), and six failed to include the link. While result is considered the most important part of the title, cause infornation (and link, if necessary) must be included to make a title complete. An example of a title that only addresses the result might be " Reactor Scram". This is i
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' inadequate in that the cause and link a,re not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From th+sfitle, the reader knowQhe cause was
_,..either personnel or procedural and surveillance testing was the link between the cause and the result.
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Table 3 provides a summary of the areas that need improvement for the Susquehanna LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in as -
Appendices C and D.
General guidance concerning these requirements can be found in NUREG-1022, Supplement No. 1 and 2.
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TABLE 3.
AREAS MOST NEEDING IMPROVEMENT FOR SUSQUEHANNA 1 AND 2 LERs Areas Comments Safety assessment information All L4Rs should include a detailed safety assessment. The text should discuss.whether or not the event could have been worse had it occurred under different, yet probable circumstances and provide information concerning backup systems that were available to' mitigate the consequences of the event.
~ Corrective actions Those actions taken or planned to prevent recurrence of the event or similar events (by ad4&essing root causes) should be'provided.
Manufacturer and model number Component identification information should be included in the text
- information whenever a component fails or
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(although not specifically required by the current regulation) is suspected of contributing to the event because of its design.
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Operating conditions prior Operating conditions just prior to to the event the event (e.g., power level, temperatures, and pressures) should be provided in the text. When operating modes are provided by number the mode should be defined (e.g., hot shutdown, startup, refueling, etc.).
Previous similar events Previous similar events should be referenced (e.g., by LER number) or, as stated in NUREG-1022, Supplement No. 2, if none are identified, the text should so state.
Ells codes Codes for each component and system referred to in the text should be provided.
Text presentation An outline format is recommended for the text of all LERs.
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TABLE 3.
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A'reas Comments Abstract Corrective action and root cause information is not being adequately summarized in the abstracts.
Each abstract should contain a good summary of the root cause and corrective action information that is discussed in the text.
Coded fields a.
Titles Titles need to be written such that they better describe the event by including the root cause, result, and link.
b.
Position titles The position title of the licensee contact named in Item 12 should be provided...See NUREG-1022, Item 12, e__.y page 24.
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REFERENCES
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- 8. 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.
Office 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 Eva.luattggpof 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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h APPENDIX A LER SAMPLE SELECTION INFORMATION FOR SUSQUEHANNA 1, 2 no -
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TABLE A-1.
LER SAMPLE SELECTION FOR SUSQUEHANNA 1, 2
-s LER Sample Number Unit Number 11R Number Comments 1
1 85-021-00 2
1 85-023-01 3
1 85-026-01
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4 1
85-032-01 ESF 5
1 85-033-00 6
1 85-034-00 SCRAM
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7 1
85-035-00 ESF
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1 86-001-00
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1 86-002-00 9
10 1
86-003-00 ESF 11 1
86-004-00 ESF 12 1
86-008-00 SCRAM 13 1
86-009-00 SCRAM 14 1
86-011-00 SCRAM 15 1
86-012-00 ESF 16 2
85-017-00 l
17 2
85-019-00 18 2
85-022-00 ESF 19 2
85-025-00 SCRAM 20 2
86-002-00 21 2
86-004-00 SCRAM 22 2
86-005-00 ESF l
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tW-APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR SUSQUEHANNA 1, 2
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TA8LE 8-1.
EVALUATION SCORES OF INDIVIDUAL LERs FOR SUSQUEHANNA 1, 2 f,.
a LER Sample Number 1
2 3
4 5
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7 8
9 10
'll 12 13 14 -
15 16
'i Text 8.3 7.3 6.5 7.3 8.8 8.4 6.3 I8.5 8.0 7.1 6.2 8.8 7.8 6.1 8.9 6.6 -
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Abstract 7.0 9.7 7.0 9.2 9.5 8.5 9.3 99.7 8.8 9.1 8.8 9.8 i 9.2 7.7 9.7 8.2 Coded Fields 8.3 8.5.
8.5 7.9 9.5 7.9 9.2 9.0 7.9 9.0 8.4 9.5 9.0 8.6 9.0 9.0 Overall 7.9 8.1 6.8 7.9 9.0 8.4 7.5 8.9 8.2 7.9 7.2 9.2 8.3 6.9 9.2 7.3 a
LER Sample Nun 6er 17 18 19 20 21 22 23 24 25 26 27 28 29
-30 AVERAGE.
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7.5 Text 8.5 7.9 7.1 5.8 7.7 6.9
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8.7 Abstract 9.7 9.2 8.7 7.7 6.9 8.9 Coded 8.7 Fields 8.8 8.7 9.2 9.7 7.9 9.0 8.0 Overall
' 8.9 8.4 7.8 6.8 7.5 7.7 a.
See Appendix A for a list of the corresponding LER numbers.
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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR SUSQUEljANNA 1, 2 m
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TEXT DEFICIENCIES AND OBSERVATIONS FOR SUSQUEHANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _ Totals' Totals (
)
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50.73(b)(2)(11)(Al--Plant operating 10 (22) conditions before the event were not included or were inadequate.
50.73(b)(2)(11)(B)--Discussion of the status 0 (2) 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)(11)(C)--Fa11ure to include 9 (22) sufficient date and/or time information.
a.
Date information was insufficient.
3 b.
Time information was insufficient.
8 50.73(b)(2)(ii)(D)--The root cause and/or 10 (22) intermediate failure, system failure, or personnel error was not included or was inadequate.
a.
Cause of component failure was not 10 included or was inadequate b.
Cause of system failure was not 0
included or was inadequate c.
Cause of personnel error was not 0
included or was inadequate.
50.73(b)(2)(ii)(E)--The failure mode, 0 (10) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.
a.
Failure mode wa. not included or was inadequate b.
Mechanism (immediate cause) was not included or was inadequate c.
Effect (consequence) was not included or was inadequate.
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TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' T_otals (
)
50.73(b)(2)(11)(F )--The Energy Industry 17 (22)
Identification System component function
-identifier for each component or system was not included.
50.73(b)(2)(11)(G)--For a f ailure of a 0 (0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.
50.73(b)(2)(11)(H)--For a failure that 0 (9) 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)(I)--The method of discovery 0 (22)
~ -of,each component failure, system failure, personnel error, or procedural error was not included or was inadequate.
a.
Method of discovery for each component failure was not included or was inadequate b.
Method of discovery for each system failure was not included or was inadequate c.
Method of discovery for each personnel error was not included or was inadequate d.
dethod of discovery for each procedural error was not included or was inadequate.
n TABLE C-1.
(continued)
Number of LERs with Deficiencies and Observations
,;gg Sub-paragraph Paragraph Description of Deficiencies and Observations _. Totals Totals (
)
50.73(b)(2)(ii)(J)(ll--Opera' tor actions that 1 (6) 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 4 (13) each personnel error was not included or was inadequate.
a.
OBSERVATION: A personnel error was 0
implied by the text, but was not explicitly stated.
b.
50.73(b)(2)(ii)(J)(2)(1)--Discussion 1
as to whether the personnel error was cognitive or procedural was not included or was inadequate.
c.
50.73(b)(2)(11)(J)(2)(11)--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)(11)(3)(2)(111)--Discussion 0
of any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the personnel error was not included or was inadequate.
e.
50.73(b)(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 inadequate.
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'" TABLE C-1.
(continued)
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Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph a
Description of Deficiencies and Observations Totals Totals (
)
50.73(b)(2)(11)(K)--Automatic and/or nanual 0 (14) ~
safety system responses were not included or were inadequate.
50.73(b)(2)(ii)(L)--The manufacturer and/or 7 (10) model number of each failed component was not included or was inadequate.
50.73(b)(3)--An assessment of the safety 16 (22) consequences and implications of the event was not included or was inadequate.
a.
OBSERVATION: The availability of 2
other syst4Ws or ccmponents capable of mitigating the consequences of the event was not discussed.
If no other systems or components were available, the text should state that none existed.
____ b.
OBSERVATION:
The consequences 2
of the event had it occurred under more severe conditions were not
~~
~~
discussed.
If the event occurred under what were considered the most severe conditions, the text should so state.
50.73(b)(4)--A discussion of any corrective 14 (22) actions planned as a result of the event including those to reduce the probability of similar events occurring in the future was not included or was inadequate.
l l
l
TABLE C-1.
.(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' lotals (
)
A discussion of actions required to 0
- a. -correct the problem (e.g., return the component or system to an operational condition or correct the personnel
'Trror) was not included or was inadequate.
b.
A discussion of actions' required to 10
~~~~
reduce-the probability of recurrence of the problem or similar event (correct the root cause) was not
~
'~~~
included or was inadequate.
c.
OBSERVATION:
A discussion of actions 0
required to prevent similar failures in similar and/or other systems (e.g.,
correct the faulty part in all components with the same manufacturer and model number) was not included or was inadequate.
50.73(b)(5)--Information c6hcerning previous 22 (22) similar events was not included or was inadequate.
9
~
TABLE C-1.
(continued)
Number of LERs with Deficiencies aiid Observations Sub-paragraph"
'iP8agraph Descript1on of Deficiencies and Observations Totals #
. Totals (
)
3 (22) 50.73(b)(2)(1)--Text presentation
_ inadequacies.
a.
OBSERVATION:
A diagram would have 1
aided in understanding the text discussion.
b.
Text conta.ined undefined acronyms ' ~
l and/or plant specific designators.
c.
The text contains other specific 1
deficiencies relating to the readability.
w The "sub-paragraph total" is a tabulation of specific deficiencies or a.observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total.
b.
The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.
l l
TABLE C-2.'
ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR SUSQUEHANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph
~9escription of Deficienc es and Observations Totals #
Totals (
)
i A summary of occurrences (immediate cause 1 (22) and effect) was not included or was inadequate A summary of plant, system, and/or personnel 1 (15) responses was not included or was inadequate.
a.
Summary of plant responses was not
' O included or was inadequate.
b.
Summary of system responses was not 0
included or was inadequate.
c.
Summary of personnel responses was not 1
included or was inadeguate.
A summary of the root cause of the event 11 (22) was not included or was inadequate.
A summary of the corrective actions taken or 10 (22) planned as a result of the event was not included or was inadequate.
t
~
TABLE C-2.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals #
Totals (
)
"y* Abstract presentation inadequacies 5-022) a.
OBSERVATION: The abstract contains 1
information not included in the text.
- sur, 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
acronyms and/or plant specific designators..
d.
The abstract contains other specific 4
deficiencies (i.e., poor summarization, contradictions, etc.)
The "sub-paragraph total" is a tabulation of specific deficiencies or a.observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
The"paragraphtotal"istheimberofLERsthathaveoneormore b.deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.
i i <-
TABLE.C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR SUSQUEHANNA 1, 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observationt _
Totals' Totals (
)
Facility Name 0 (22) x a.
Unit number was not included or incorrect.
b.
Name was not incidde_d or was incorrect.
.co.-Additional unit numbers were included e'but not required.
Docket Number was not included or was 0 (22) incorrect.
Page Number was not included or was 1 (22) incorrect.
Title was left blank or was inadequate 21 (22) a.
Root cause was not given in title 18 b.
Result (effect) was not given in title 4
c.
Link was not given in, title 6,,,
Event Date 0 (22)
I a.
Date not included or was incorrect.
b.
Discovery date given instead of event date.
LER Number was not included or was incorrect 0 (22)
Report Date 2 (22) a.
Date net included 0
b.
OBSERVATION:
Report date was not 2
within thirty days of event date (or discovery date if appropriate).
Other facilities infornation in field is 1 (22) inconsistent with text and/or abstract.
Operating Mode was not included or was 1 (22) inconsistent with text or abstract.
t
TABLE C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _, Totals' Totals (
)
Fower level was not included or was 2 (22)
^ ~ ~
inconsistent with text or abstract Reporting Requirements 2 (22) 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
"j appropriate to report the event under a different paragraph.
c.
OBSERVATION:
It may have been 2
appropriate to report this event under an additional unchecked paragraph.
Licensee Contact 9 (22) a.
Field left blank 0
b.
Position title was not included 9
c.
Name was not included 0
d.
Phone number was not included.
0 Coded Component Fa'11ure Information '
5 (22) a.
One or more component failure 1
sub-fields were left blank, b.
Cause, system, and/or component code 3
is inconsistent with text.
c.
Component failure field contains data 0
when no component failure occurred.
d.
Component failure occurred but entire 1
field left blank.
y e--,
m.n TABLt"C-3.
(continued)
Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph
~
Description of Deficiencies and Observations c-, Totals' Totals (
__ )
Supplemental Report 1 (22)
~
k~ -
a.
Neither "Yes"/"No" block of the O
supplemental report field was checked.
b.
The block checked was inconsistent I
with the text.
Expected submission date information is 0 (22)~
inconsistent with the block checked in N
Item (14).
~
a.
The "sub-paragraph total" is a tabulationiof specific deficiencies or observations within certain requirements. Since an LER qan have more than onf deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
_b.
The " par'agraph 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 requirem'e'nt~was considered applicable.
L l
1
6 e
d 04
<eW'
't N
WO go. "
APPENDIX D
=
LER~ COMMENT SHEETS FOR SUSQUEHANNA 1, 2 m
G e
n w
d
. TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 1.
LER humber: 85-021-00 Scores:. Text = 8.3 Abstract = 7.0 Coded Fields = 8.3 Overall = 7.9 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning relays 62A-20102
~
and 62X1-20304 is not included.
2.
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. No codes are provided for the components referred to in
"",y.
the text.
3.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Without knowing the root cause (see text comment number 1), it is not possible to determine if the corrective actions taken are adequate to prevent recurrence of the event.
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.
LAbsfract 1.
~30.73(b)(1)--Summary of root cause is inadequate.
~
The reason that relays 62A-20102 and 62X1-20304 failed should be given and the procedural deficiency
~ ~ ~
should be mentioned.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The j
actions taken -(recalibration, replacement, and procedural change) should be mentioned.
Coded Fields 1.
Item (4)--Title: Root cause and link are not included. A more appropriate title might be "Three Diesel Generators Declared Inoperable due to Inoperable Load Sequencing Relays Found During Surveillance Testing".
i 4
9 I
I
TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 1.
LER Number: 85-021-00 (continued) 2.
Item (8)--How Unit 2 was involved is not clearly stated in the text or abstract.
3.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.36(c)(2).
~m.,
g,
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
~
. -, +.
2.
LER Numberi 85-023-01 Scores:
Text - 7.3 Abstract = 9.7 Coded Fields - 8.5 Overall = 8.1 Text 1.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is inadequate.
The Operational Condition that required the operability of XV-141f009 should be discussed.
2.
50.73(b)(2)(11)(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)(31--D15Euision of the assessment of the safety consequences and implications of the event is
. _ ' ~ ~
not included.
- 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.
The use of revision " bars" is good.
Abstract __,
1.
No comment.
Coded Fields 1.
Item (41--Title:
Rodt cause is not included.
2.
Item (10)--The power level given is 001 while the text does not give a power level (see text comment 1); is this a typo?
l 3.
It.em (12)--Position title is not included.
l l
t I
i
(
l l
l
,yg TABLE D-1.
SPECIFIC LER COMNENTS FOR SUSQUEHANNA 1 (387)
Section Comments 3.
LER Number: 85-026-01 Scores:
Text = 6.5 Abstract = 7.0 Coded Fields - 8.5 Overall - 6.8 Text 1.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time was the oil leak discovered?
~ ' ~ ~
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)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included. Given that the cause of the loose flange is unknown, but vibration is suspected, others may want to know if they have a valve of the same manufacturer and model at their plant so they can check for loose nuts.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is _
~
not included.
OBSERVATION: The availability of other systems or components capable of mitigating the consequences of l
-the event should be discussed.
If no other systems or components are available, the text should so state.
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.
The use of revision bars in the text is good; however, a supplemental report whose only purpose is to state that a planned action was completed is not necessary.
A supplemental report is appropriate if the results of the bi-weekly inspection indicate a clear cause for the event (e.g., vibration).
This supplement should then document the cause and provide a description of the corrective actions taken to prevent recurrence.
- ~..
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Comments s
Section 3.
LER Number: 85-026-01 (continued)
Abstract 1.
50.73(b)(1)--Summary of root cause information is not Included.
It is not apparent from reading the
"~
abstract that the cause is unknown or that vibration is suspected.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The corrective actions concerning the torque paint and the bi-weekly'inspWEtion of the-flange should have been mentioned.
3.
OBSERVATION: The abstract contains 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 (namely, the information concerning the LCO). This information should have been included in the text as well as some information specific to what the requirements of the LC0 are and whether or not they were met.
4.
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: Cause and result are not included.
A better title might be, "HPCI System Inoperable Due To Turbine Stop Valve Oil Leakage of Unknown Origin".
2.
Item (12)--Position title is not included.
i l
3.
Item (13)--One or more component failure sub-fields are blank. The manufacturer code for the stop valve appears to be applicable to this event.
See text comment number 4.
I l
l l
\\
l
~
TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 4.
LER Number: 85-032-01 Scores: Text = 7.3 Abstract = 9.2 Coded Fields = 7.9 Overall = 7.9 Text 1.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the eroded valve seat is not included.
2.
50.73(b)(2)(11)(FJ.--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system-referred to in the LER js not included.
3.
50.73(b)(2)(ii)(L)--Identification (e.g. manuf acturer and model no.) of the failed component (s) discussed in the text is not included.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was any action taken to prevent the valve seat from failing again?
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.
t 7.
The simplified drawing is a good idea and is encouraged; the LER number should probably be included on the drawing however, so that if it ever becomes ~eparated from the LER form the drawing can be identified as to which report it goes with.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title: Root cause (leaky valve) and link (maintenance) are not included. A more appropriate title might be " Reactor Water Clean-up (RWCU) System Spills and Isolations during RWCU Maintenance due to j
a Leaky Isolation Valve".
1 2.
Item (71--0BSERVATION: Report date is not within l
thirty days of event date (or discovery date if appropriate).
O
- TABLE D-1.
SPECIFIC LER COMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
. 4.
LER Number: 85-032-01 (continued) 3.
Item (121--Position title is not included.
4.
Item (13)--Component failure occurred but entire field is blank.
wg
- 6.,
a 1
e
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 5.
LER Number:
85-033-00 Scores:
Text = 8.8 Abstract = 9.5 Coded Fields = 9.5 Overall = 9.0 Text 1.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is inadequate.
Even though release limits were not approached or exceeded, the possible safety consequences and implications of missing the noble gas sample should be discussed.
2.
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: Result is not included. The title should indicate that_this missed sample was required by Technical Specifications.
1
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 6.
LER Number: 85-034-00 Scores: Text = 8.4 Abstract = 8.5 Coded Fields = 7.9 Overall = 8.4 Text 1.
50.73(b)(2)(11)(C)--Date/ time information for major occurrences is inadequate. When (time) were both units placed in a safe and stable condition following their scram? When were the plant modifications, which provide an uninterruptable power supply to the_
feedwater control circuitry, installed?
2.
50.73(b)(2)(11)(0)--It is not apparent from the text discussion whether Diesel Generator C experienced a failure (because it did not pick up any load) or whether it had no load to pick up.
If it experienced a failure, the cause and corrective actions should be discussed.
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. No codes are provided for the components referred to in the text.
4.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate.
The
" actions""'(3rd sentence of 3rd paragraph, page 2 of
- 3) taken that led to the scram on low vessel levels should be described.
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.
A supplemental report appears to be needed to describe the results of the manufacturer's analysis and the permanent corrective actions concerning the sudden pressure relay trip function. Without a commitment to submit a supplemental report, this LER must be considered incomplete.
Abstract 1.
50.73(b)(1)--Summary of root cause is inadequate.
The abstract should state that the reason for the "misoperation" of the sudden pressure relay is unknown (but under investigation).
r.
i TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 6.
LER Number:
85-034-00 (continued) 2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The fact that the sudden pressure relay trip function was bypassed on all four ESS transformers as an interim measure should be provided in the abstract.
Coded Fields 1.
Item (4)--Title: Root cause (unknown) is not included. A better..t.i,tje might be, " Unit 1 and 2 Reactor Scram Due To Level Control Problems Caused By Interruption Of Electrical Power When ESS Transformers Sudden Pressure Relay Malfunctioned".
2.
Item (12)--Position title is not inETuded.
-~~
3.
Item (141--The block checked is inconsistent'with information in the text. See text comment number 5.
~
p
-gh a
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 7.
LER Number: 85-035-00 Scores:
Text - 6.3 Abstract = 9.3 Coded Fields - 9.2 Overall - 7.5 Text 1.
50.73(b)(2)(11)(A)--Discussion of the operating conditions for Units 1 and 2 before the event is not included.
2.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. For example, times for the units being stabilized and restoring the affected systems should have been provided.
3.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identiffer(s) and/or system name of each component or system referred to in the LER is not included. Codes for the transformer, bus, and breaker components were not included.
3 4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50.73(b)(4)--The discussion should be more specific as to what was required to stabilize the units.
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: The result (i.e., reason for reporting event) is vague, and should indicate that multiple Engineering Safety Features actuated. A more appropriate title might be " Multiple Engineering Safety Feature Actuations And A Bus Load Transfer Due To An Offsite Transmission Fault".
2.
Item (12)--Position title is not included.
TABLE D-1.
SPECIFIC LER COMMENTS f0R SUSQUEHANNA 1 (387)
Section Comments 8.
LER Number: 86-001-00 Scores:
Text - 8.5 Abstract'= 9.)
Coded Fleids - 9.0 Overall = 8.9 Text 1.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The safety conrequences and implications of not knowing if the HD-07Cl2 and HD-07814 dampers would close on a-high chlortne signal should be discussed.
2.
50.73(b)(5)--Informat. ion concerning previous similar
~~
events is not included.
If no previous similar events are known, the text should so state.
3.
The diagram provided in this LER is very helpful to the reader. You may want to consider providing the LER number on the diagram in case the diagram ever becomes detached from the report.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--Title:
Root cause is not included. A suggested title:
Isolation Dampers Not Tested As Required By Technical Specifications Due To Procedural Deficiency.
4 I
l
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 9.
LER Numbcr: 86-002-00 Scores: Text = 8.0 Abstract = 8.8 Coded Fields = 7.9 Overall = 8.2 Text 1.
50.73(b)(2)(11)(C)--Date and time information for major occurrences is inadequate. Date and time
~'T4 ;g information should have been provided so the reader 5
would have an idea of how long the " manual locked closed" valve was leaking (e.g., What was the date of the last quarterly flow surveillance performed on the system?). When was the leaking valve finally " closed tightly"?
2.
50.73(b)(2)(11)(F1--The Energy Industry Identification System component function identifier (s) and/or system name of cach component or system referred to in the LER is not included. No code was provided for the tank (TK).
3.
10.73(b)(2)(11)(J)(21--Discussion of the personnel error is inadequate.
50.73(b)(2)(11)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility per.sonnel) is not included.
4.
50.73(b)(4)--01scussion of corrective actions taken or planned is inadequate. What was done or planned to prevent the subject valve from being left slightly open in the future?
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.
i 6.
Some ideas are not presented clearly (hard to follow)
(e.g., - the solution "had been previously found leaking"-).
Abstract 1.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment number 3, 2.
Abstract says " system declared inoperable", text says, "LC0 was entered"; the text and the abstract should be consistent as to which terminology is used.
l f
i
- TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 9.
LER Number: 86-002-00 (continued)
Coded fields 1.
Item (4)--The present title does not adequately describe the event. A better title might be, " Sodium Pentaborate Weight less Than Required By T.S. 3.1.5 Due To Valve Not..Being fully Shut-Personnel Error".
2.
Item (12)--Position title is not included.
t t_
.e 4
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1'(387)
Section Comments
- 10. LER Number: 86-003-00 Scores: Text = 7.1 Abstract - 9.1 Coded Fields - 9.0 Overall = 7.9 Text 1.
50.73(b)(2)(11)(Al--Although loss of shutdown cooling r
implies that the plant was shutdown, the plant conditions should be stated more specifically and the text should indicate whether the plant was in cold or hot shutdown.
2.
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.
- """Qomponentcodeforthebreakerwasnotincluded.
1 3.
50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequate. Who mislabeled the breakers and why the error was overlooked should be discussed.
4.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
5.
50 73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e correction of the root cause) is not included or is inadequate.
l Do any checks need to be instigated to ensure that components are not mislabeled in the future?
6.
50.73(b)(5)--Information concerning previous similar events is not included.
If no previous similar j
events are known, the text should so state.
i Abstract 1.
The root cause and corrective actions summaries are deficient for the same reason stated in text comments 3 and 5.
Coded Fields 1.
Item (3)--The page number on page 2 is incorrect.
2.
Item (4)--Title: Root cause (mislabeled breaker) is not included.
3.
Item (12)--Position title is not included.
e
r TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
- 11. LER Number: 86-004-00 Scores:
Text - 6.2 Abstract 8.8 Coded Fields - 8.4 Overall - 7.2 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)(11)(A)--Discussion of plant operating conditions before the event is not included.
3.
50.73(b)(2)(11)(C)--Time information for major occurrences is inadequate. A time should be given for the discovery of HD-17520B exceeding the maximum isolation time allowed by the Technical Specifications.
A time should also be given for when the Zone III HVAC was tripped, and when the SGTS was manually initiated.
4.
50.73(b)(2)(ii)(D)--It appears to the reader the wording "the Zone III HVAC was eventually tripped" that some period of time elapsed between the discovery of HD-17502B exceeding the maximum
"~~
isolation time and when it was decided to enter the LCO. Why wasn't the LC0 entered immediately? If a period of time was allowed prior to entering the LCO, this information should be given.
6.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
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.
1 Abstract 1.
50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)) is inadequate.
See text comment 4.
Coded Fields 1.
Item (4)--Title:
Root cause is not included.
The use of acronyms in the title should be avoided unless i
space is limited.
2.
Item (13)--Cause, system, and/or component code is inconsistent with text. The text does not indicate that the regulator failed, only that it needed adjustment.
.~;
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
- 12. LER Number: 86-008-00 Scores: Text = 8.8 Abstract = 9.8 Coded Fields = 9.5 Overall = 9.2 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. No codes were provided for the components referred to in the text.
- 2., 50.73(b)(3)--Discussion of the assessment of the
~ safety consequences and implications of the event is ~
inadequate. Given that scrams can result in unnecessary challenges which are undesirable, it w3^uld be good to point out th'at because the under-vessel area is normally not accessible during operating conditions, a scram will probably not be initiated from this area during power.
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. The last sentence of the text implies that there may have been other " mishaps" that prompted the department's effort.
Abstract 1.
No comment.
Coded Fields 1.
Item (4)--A better title might be, " Inadequate RPS Actuations Apparently As A Result Of The Disturbance Of LPRM Cables During Maintenance Activities In The Under-Vessel Area".
TABLE D-1.
SPECIFIC LER COMMENTS-FOR SUSQUEHANNA 1 (387)
Section Comments 13.
LER Number: 86-009-00 Scores:
Text - 7.8 Abstraht=9.2 Coded Fields - 9.0 Overall = 8.3' Text 1.
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. The component codes for the relay and monitor should be included.
2.
50.73(b)(3)--0BSERVATION: 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.
3.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate.
The text should state why no further action is planned. For example, could the procedure be changed to prevent unnecessary challenges of the RPS system, and if not, the text should explain why nothing will be done to prevent a similar event?
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.
5.
Acronym (s) and/or plant specific designator (s) are undefined. HFA should be defined.
Abstract 1.
Abstract contains acronym (s) and/or plant specific designator (s) which are undefined. HFA should be defined.
Coded Fields 1.
Item (4)--Title:
Link (during surveillance) is not included.
2.
Item (9)--The symbol gis:n appears to be an improper i
entry.
The common refueling mode number for a BWR is 5.
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.~D TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
- 14. LER Number: 86-011-00 Scores:
Text - 6.1 Abstract - 7.7 Coded Fields - 8.6 Overall - 6.9 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)(11)(Al--The plant operating conditions before the event are not explicitly stated.
s.'~
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the broken shield is not included.
4.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each ccaponent or system referred to in the LER is not included.
Some system codes are provided, codes should alsa be provided for components (cable, support, detector).
5.
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.
6.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
7.
50.73(b)(4)--Discussion 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.
8.
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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TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments 14.
LER Number: 86-011-00 (continued)
' Abstract 1.
50.73(b)(1)--Summary of root cause of the broken shield is not included.
2.
50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate.
See text comment 7.
3.
Coded Fields 1.
Item (4)--Title: Root cause is not included. The use of acronyms in the title should be avoided unless space is limited.
2.
Item (13)--Component code SLN appears to be incorrect.
~
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 1 (387)
Section Comments
- 15. LER Number: 86-012-00 Scores: Text - 8.9 Abstract = 9.7 Coded Fields - 9.0 Overall - 9.2 Text 1.
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. No codes were provided for the components referred to in the text.
2.
50.73(b)(3)--Although full credit was given for this requirement, it would have been appropriate to make a statement, such as:
"Because the (named) systems actuated as expected and responded properly, there were no safety consequences or implications as a result of this event".
2.
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. The " work practices" and
" precautionary measures", which were discussed so as to avoid such occurrences in the future, should have been listed so that others could learn from this event.
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.
Abstract 1.
The abstract space could have been more fully utilized.
By doing so, more details from the text would have been available in the abstract.
For example, details concerning how the electrician caused the short would have been good information to include in the abstract.
Coded Fields 1.
Item (4)--Title:
Root cause and link are not included.
A better title might be, " Accidental Short Caused By An Electrician Results In The Actuation Of Two Engineered Safety Features".
2.
The use of acronyms in titles should be avoided unless space is limited.
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments 16.
LER Number: 85-017-00 Scores: Text = 6.6 Abstract = 8.2 Coded fields - 9.0 Overall = 7.3 Text 1.
50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the packing-leaks is not included.
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.
The component code for valves was not given.
4.
50.73(b)(2)(ti)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
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 or is inadequate (see text comment 2).
7.
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 personnel responses is inadequate. The cycling of various valves to determine where the leak was should be mentioned.
2.
The root cause and corrective actions sunnaries are deficient for the same reasons as given in the text.
Coded Fields 1.
Item (4)--Title: Root cause (leaky valve packing) is not included.
2.
Item (ll)--0BSERVATION:
It appears it would have been appropriate to also report this event under paragraph (s) 50.73(c)(2).
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 17. LER Number: 85-019-00 Scores:
Text - 8.5 Abstract - 9.7 Coded Fields - 8.8 Overall - 8.9 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)(C)--Date information for nejor occurrences is not included.
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)(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: Root cause is not included.
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l TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
I Section Comments
~~
- 18. LER Number: 85-022-00 Scores:
Text - 7.9 Abstract - 9.2 Coded Fields - 8.7 Overall - 8.4 Text 1.
50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time did the RWCU containment isolation valve close? When was the RWCU system restored to service?
3.
50.73(b)(2)(11)(F)--The Energy Industry Identification System component function i
identifier (s) and/or system name of each component or system referred to in the LER is not included. No codes are provided for the components referred to in the text.
4.
50.73(b)(3)--Discussion of the assessment of the t
safety consequences and implications of the event is inadequate. Were there any safety implications due to isolating RWCU? If not, so state.
5._
50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Given the Human Performance Evaluation System situation evaluation may determine that additional actions to prevent recurrence need to be implemented, the text should commit to provide a supplemental report that would list any additional corrective actions so determined.
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.
50.73(b)(1)--Summary of root cause information is inadequate. The abstract should state that the personnel error was considered to be cognitive and that the present procedures were not considered to be deficient.
2.
Additional space is available within the abstract field to provide the necessary information but it was not utilized.
1 I
I
TABLE D-1.
SPECIFIC LEP COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 18. LER Number: 85-022-00 (continued)
Coded Fields 1.
Item (41--Title: Root cause is not included.
The use of acronyms in the title should be avoided unless space is limited. A better title might be, "I&C Technician Inadvertently Causes Isolation of Containment Isolation Valve for the RWCU System While Performing Quarterly Calibration".
~
TABLE D-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 19. LER Number: 85-025-00 Score:: Text - 7.1 Abstract - 8.7 Coded Fields = 9.2 Overall = 7.8 Text 1.
50.73(b)(2)(11)(A)--Discussion of plant operating conditions before the event is not included.
2.
50.73(b)(2)(ii)(C)--Date and time information for major occurrences is inadequate. When was the reactor brought to a safe and stable condition, and when was the relay repaired?
3.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the relay failure is not included.
4.
50.73(b)(2)(11)(F)--The Energy Industry Identification System confanent function identifier (s) and/or system name of each component or system referred to in the LER is not included. The EIIS component codes were not provided.
5.
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.
6.
E0.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause') is not included or is inadequate (see text comment 3).
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.
50.73(b)(1)--Summary of root cause is inadequate.
The summary should be more specific by indicating that the relay stuck closed. The summary is also deficient, as is the text, in failing to tell why the relay stuck closed.
Coded Fields 1.
Item (4)--Title:
Root cause (stuck relay) is not included.
2.
Item (12)--Position title is not included.
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TABLE D-1.
SPECIFIC LER CDMMENTS FOR SUSQUEHANNA 2 (388)
Section _
Comments
' ~ ' "
~~'
- 20. LER Number: 86-002-00 Scores:
Text - 5.8 Abstract - 7.7 Coded Fields - 9.7 Overall - 6.8 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)(11)(Al--Discussion of plant operating conditions before the event is not included.
3.
50.73(b)(2)(11)(01--The root and/or intermediate cause discussion concerning the tear in the main diaphram of PCV-2F035 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. An EIIS Code is provided for the HPCI system, codes should also be provided for the components mentioned (i.e., cooler, condenser).
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included.
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.
OBSERVATION: The availability of other systems or components capable of mitigating the consequences of the event should be discussed.
If no other systems or components are available, the text should so state.
6, 50.73(b)(41--Discussion 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.
I 1
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n TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 20. LER Number: 86-002-00 (continued) 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.
50.73(b)(1)--Summary of the root cause of the torn diaphram is not included.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment 6.
Coded Fields 1.
The use of acronyms in the title should be avoided unless space is limited.
2.
Item (131--System code appears to be incorrect. The code is BJ for the HPCI system. BQ is the code for The High Pressure Safety Injection System in a PWR.
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TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 21. LER Number: 86-004-00 Scores:
Text - 7.7 Abstract - 6.9 Coded Fields - 7.9 Overall = 7.5 Text 1.
50.73(b)(2)(tilfC)--Time information for major occurrences is inadequate. The time of the runback and manual scram should have been provided.
2.
50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the reason the cooling fan caused a ground fault is not included.
3.
50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate.
50.73(b)(2)(11)(3)(2)(il--Discussion as to whether the personnel error was cognitive or procedural is not included.
Is there a procedure,that covers alarm acknowledgment? Is Electrical Maintenance required to inform the main control room when they complete their work? Why were the knife switches in the wrong position?
4.
50.73(b)(2)(it)(L)--Identification (e.g. manuf acturer and model no.) of the failed component (s) discussed in the text is not included.
5.
50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. What would have been the consequences of the "B" Phase Main Transformer failing (or the other transforners that were found to have both cooling loop aligned to the same power source)?
6.
50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. What corrective action was necessary to fix the cooling fan and to prevent recurrence of its failure? What was done to correct the apparent problem discussed in the last two sentences of paragraph three on page three?
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.
OBSERVATION: A diagram or figure would aid in understanding the event.
e TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 21. LER Number: 86-004-00 (continued)
Abstract 1.
50.73(b)(1)--Summary of cause information is inadequate. The communication problem between the maintenance personnel and the control room personnel as well as the failure to acknowledge the "B" Phase
_ Ma_1p Transformer alarm should have been mentioned.
2.
50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The corrective actions to prevent recurrence were not provided.
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 Ficids 1.
Item (4)--Title: Root cause is not included.
2.
Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).
The reason for this should be provided in the text (as it was in the cover letter).
3.
It_em (10)--The power level in field differs from text or abstract.
The power level should have been given as 100 in Item (10).
This event started at that power level.
4.
Item (12)--Position title is not included.
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TABLE D-1, SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388) 1 Section Comments
- 22. LER Number: 86-005-00 Scores: Text - 6.9 Abstract - 8.9 Coded Fields - 9.0 Overall - 7.7 Text 1.
50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the broken belts and linkage is not included.
2.
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.
the component codes were not included.
~
3.
50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate. Although the reason for the open door could not be found, the text should discuss possibilities that were considered but rejected.
4.
_50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
5.
50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not included.
6.
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 or is inadequate (see text comment 1).
Do personnel need to be reminded of the need to keep the door shut, or is an automatic door closing mechanism needed?
7.
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 root cause is inadequate. As in the text the reason for the broken belts and sticky linkage should be given.
2.
50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequate.
The fact that the belts shculd be mentioned, and as in the text, the actions to prevent the door from being left open again should be discussed.
TABLE 0-1.
SPECIFIC LER COMMENTS FOR SUSQUEHANNA 2 (388)
Section Comments
- 22. LER Number: 86-005-00 (continued)
Coded fields 1.
Item (4)--Title: Link (low secondary containment delta-P) and root cause (failed components and personnel error) are not included.
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