IR 05000348/1986014

Forwards AEOD Assessment & Input to SALP Review Re LERs for Jan 1985 - May 1986 for Facilities.Lers of Average Quality. Assessment Will Be Incorporated Into SALP Repts 50-348/86-14 & 50-364/86-14

ML20212D179
Person / Time
Site:	Farley
Issue date:	07/29/1986
From:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mcdonald R ALABAMA POWER CO.
References
NUDOCS 8608120411
Download: ML20212D179 (58)

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July 29, 1986-Docket Nos'. 50-348 and 50-364 License Nos. NPF-2 and NPF-8 Alabama Power Company ATTN: Mr. R. P. Mcdonald Senior Vice President P. O. Box 2641 Birmingham, AL 35291 Gentlemen:

The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AEOD) has recently completed an assessment of your Licensee Event Reports (LERs) for Farley 1 and 2 as a part of the NRC's Systematic Assessment of Licensee Performance (SALP) progra In general, AEOD found your submittals to be of average quality based on the requirements contained in 10 CFR 50.73. We are providing you a copy of AEOD's assessment prior to the issuance of the SALP 50-348/86-14, 50-364/86-14 Board Report, for Farley 1 and 2 respectively, so that you are aware of their findings and may use the information to pattern future submittal We appraciate your cooperation with u Please let us know if you have any question

Sincerely, Original Signed by Luis A. Reyes /for Roger D. Walker, Director Division of Reactor Projects Enclosure:

AE00 Input to SALP Review for Farley 1 and 2 bcc w/ encl:

R. Aiello H. Dance d. Reeves,NRR State of Alabama WRC Resident Inspector Document Control Desk  !

R RI RII RAiello Kd dis DVerrelli 07/ 0/86 07%/86 07/g/86 8608120411 860729 8 8

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ENCLOSURE

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SUMMARY An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Farley 1 and 2 during the January 1, 1985 to May 30, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in NUREG/CR-417 The results of this evaluation indicate that Farley has an overall average LER score of 7.8 out of a possible 10 points, compared to a current industry average score of 7.9 for l those units / stations that have been evaluated to Jete using this l nethodolog l l

The principle weaknesses identified in the LERs, in terms of safety significance ~, involve thetrequirements to provide a safety assessment and to adequately identify 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 ney go unnoticed by the industry for too long a time perio A strong point for the Farley LERs is that the requirement to provide the failure mode, mechanism, and effect cf each failed component was satisfied for all applicable LERs in the sampl L i

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4 AE00 INPUT TO SALP REVIEW FOR FARLEY 1, 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by farley 1 and 2 during the January 1, 1985 to May 30, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the station's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-417 The sample consists of 17 LERs (nine LERs from Farley 1 and eight from Farley 2), which is half of the LERs that were en file at t.he time the evaluation was started. The Farley LERs were evaluated as one sample because it was determined that their LERs are both

, written and fornelly reviewed at the station, rather than the unit, leve '

Se'e Appendix A for a list of the LER numbers in the sampl It was necessary to start the evaluation before the end of the SALP asssessment period because the input was due such a short time cfter the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for revie 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 NUREG-1022 , and Supplements 1 and 2 to NUREG-102 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 LE (

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The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LER 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 the overall score determined for each LER. The overall score for each LER is the result of l combining the scores for the text, abstract, and coded fields (i.e., l 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 inforsation. The ,

detailed information, presented in Appendices A through D, consists of LER l sample information (Appendix A), a table of the scores for each sample LER (Appendix B), tables of the numoer of deficiencies and observations for the text, abstract and coded fields ( Appendix C), and comment sheett 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 analyst has flexibility to consider the magnitude of a deficiency when assigning score Discussion of Results A discussion of the analysts' conclusions concerning LER quality is presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of the station's performance (on a scale of 0 to 10) in submitting LERs that meet the requirements of 10 CfR 50.73(b).

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Table 1 presents the average scores for the sample of LERs evaluated for Farley. 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 methodolog In order to place the scores provided in !able 1 in perspective, the distribution of the overall score for all licensees that have been evaluated using the current methodology is provided in Figure Additional scores are added to Figure 1 each month as other licensees are evaluated. Table 2 and Appendix Table B-1 provide a sunenary of the information that is the basis for the average scores in Table For ,

example, Farley's average score for the text of the LERs that were evaluated is 7.2 out of a possible 10 points. From Table 2 it can be seen that the text score actually resulted t rom the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)) to text j presentatio The percentage ', cores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the station for the 17 LERs that were evaluate 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 LER For example, requirement percentage scores of less than 75 indicate that the station personnel probably need additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the personnel probably understand the basic requirement but have either: (1) excluded certain less significant information f rom 6 large number of the discussions concerning that requirement or (2) totally failed to address a requirement in one or twc of the selected LER Applicable station personnel should review the LER specific conynents presented in Appendix D in order to determine why less than a perfect score was received for certain requirements. The text requirements with a secre l

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a TABLE SUMMARY OF SCORES FOR FARLEY 1, 2 LERs Averaae Hioh low Text .9 Abstract .5 Coded Fields .6 Overall 7.8b .2 See Appe'ndix B for a sunsnary of scores for each LER that was evaluated, Overall Average - 60% Text Average + 30% Abstract Average + 10% Coded Fields Avesag .

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rigure '. Disrioution  : of overa:I average _E9 scores 15 , , , ,

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TABLE LER REQUIREMENT PERCENTAGE SCORES FOR f ARLEY 1, 2 i TEXT Percentage a

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

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(2)(11)(A) - - Plant condition prior to event 65 (17)

(2)(ii)(B) - - Inoperable equipment that contributed b (2)(ii)(C) - - Date(s) and approximate times 91 (17)

(2)(11)(D) - - Root cause and intermediate cause(s) 86 (17) )

(2)(ii)(E ) - - Mode, mechanism, and effect 100 (7)

(2)(ii)(f) - - EIIS Codes 6 (17)

(2)(ii)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 90 (10)

(2)(11)(1) - - Method of discovery 91 (17)

(2)(ii)(J)(1) - Operator actions af fecting course 90 (7)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 80 (13)

(2)(ii)(K) - - Safety system responses 63 (8)

(2)(11)(L ) - - Manuf acturer and model no. information 21 (7)

(3) ----- Assessment of safety consequences 45 (17)

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Corrective actions 81 (17)

(5) ----- Previous similar event information 6 (17)

(2)(1) - - - - Text presentation 74 (17)

ABSTRACT Percentage a

Reautrements ISO.73(b)(111 - Descriptions Scores ( 1

- Major occurrences (Immediate cause and effect 97 (17)

information)

- Description of plant, system, component, and/or 86 (11)

personnel responses

- Root cause information 88 (17)

- Corrective Action infornetton 83 (17)

- Abstract presentation 79 (17)

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TABLE (continued)

CODED FIELDS Percentage Item Number (s) - Description _ Scores ( )'

1, 2, and 3 i f acility name (unit no.), docket no. and 100 (17)

page number (s)

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4 - - - - - - Title 5, 6, and 7 - Event date, LER No., and report date 97 (17)

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Reporting requirements 94 (17)

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14 and 15 - - Supplemental report information 94 (17)

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a. Percentage scores are the result of dividing the total points for a requirement by the number of points possible for that requiremen (Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in e i parenthesis is the number of LERs for which the requirement was considered applicabl b'. A percentage score for this requirement is meaningless as it is not

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possible to determine from the information availableIt to the analyst whether is always given 100%

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of less than 75 or those with numerous deficiencies are discussed below in their order of importanc In addition, the primary deficiencies in the abstract and coded fields are discusse Eleven of the 17 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). Six of the LERs did not contain any discussion concerning safety consequences and five others lack certain details necessary to a complete discussion. Every LER is required to contain a discussion of the safety assessment that should be performed by the station after every even 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 reache For example, if it was concluded that there were no consequences because there were other systems (or means) available to mitigate the consequences ,

of the safety system failure, these systems or means should be discussed in the text. In addition, each discussion should include information as to whether or not the event could have happened under a set of initial conditions that would have 'made consequences more sever If the event could not have occurred under a more severe set of initial conditions, the text should so state.

j Although the requirements to discuss personnel errors and corrective actions, Requirements 50.73(b)(2)(ii)(J)(2) and 50.73(b)(4), respectively, C

have percentage scores that are greater than 75, both requirements are considered to be deficient in that over half of the LERs, in which these #

requirements are applicable, failed to provide all the required infornation.

i Seven of the 13 LERs involving personnel error failed to provide infornation concerning the specifics of the error. The most common deficiency encountered was that the type of personnel involved in the error was not provided, Requirement 50.73(b)(2)(11)(J)(2)(iv). One LER (85-009-00 for Unit 2) failed to mention personnel error as a possible contributing f actor to the cause of the reactor trip described in the LER;

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however, one of the corrective actions planned was to add a caution statement to applicable procedures. This implies that personnel actions did contribute to the event and these actions should have been discussed in the tex Nine of the 17 LERs failed to provide the necessary details concerning corrective action In addition to providing information as to what was done to correct the immediate problem, the corrective action discussion must also address what was done or planned to try to ensure that the problem does not recur. For certain events (i.e., those involving possible generic problems), the corrective action discussion must also include information concerning those actions taken to ensure that the problem does not (or will.not) extend to other components or systems in the plan Automatic and manually initiated safety system responses were not adequately discussed in six of the eight LERs in which there were safety

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system responses. In general, these LERs contained " boiler-plate" statements such as "all equipment functioned as designed" or "all safety systems functioned as designed". As a minimum, Requirement 50.73(b)(2)(ii)(K) requires that those safety systems that initiate (either automatically or manually) as a result of the event be named in the LE Six of the seven LERs involving failed components failed to adequately identify the failed component. Five of the LERs failed to provide any identification of the failed component in the text and a sixth LER (86-004-00 for Unit 1) failed to state that a penetration module (GE Series 100), whose failure was described in a previous report, is the same one to have failed in LER 86-004-0 Operating conditions immediately prior to the event, Requirement 50.73(b)(2)(11)( A), were not provided in seven of the 17 LERs that were evaluated. In order for the reader to have a clear picture of conditions just prior to the start of the event, the text should provide information such as power level, mode number and description, and in some

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cases plant temperature and pressure. For certain events that are not linked to plant conditions, the text should describe what activity was ,

underway (e.g., planned maintenance during an extended shutdown) just prior to the discovery of the even Sixteen of the 17 LERs failed to provide information concerning previous similar events at the plant (station). The identification of previous similar events is an important part of the LER process in that trends or recurring problems can be identified and addressed. If an event is reported for which there has been no previous similar events, the text i

should state thi l Sixteen of the 17 LERs failed to provide the Energy Industry Identification System (EIIS) component function identifiers and system codas for each component or system involved in the even The text presentations received an overall score of 74%. This score can be improved upon by the use of a consistent text outline (see NUREG-1022, Supplement No. 2 Appendices C and 0). 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 writing LERs, the overall quality of the reports will also improve, based simply on the fact that every LER will contain at least the minimum information concerning the requirements tpplicable to the even The practice of writing LERs that consist of only an abrtract should be avoided except in those instances where the event being reported is extremely simple and involves only a few requirements. Five of the 17 LERs were " abstract-only" reports and three of these involved either a scram or an Engineered Safety Feature (ESF) actuation. The 1400 space limit of the abstract is usually not adequate to provide the discussions required by 50.73(b) for such events.

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i The abstracts were generally adequate based on scores; however, the cause and corrective action information was considered inadequate in five l

and six of the LERs, respectivel In some cases this was a reflection of a text deficiency and in others the information contained in the text did not get summarized in the abstract.

! The main deficiency in the area of coded fields involves the title, Item (4). Sixteen of the titles failed to indicate root cause, five failed to include the result (i.e., why the event was required to be reported) and four failed to provide a link between the cause and result. While the result is considered to be the most important part of the title, cause information must be included to make a title complete. An example of a title that 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 De " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title the reader knows the cause involved either personnel or procedures and that testing contributed to the even The position title for the licensee contact named in Item (12) was not provided for any of the 17 LERs. See NUREG-1022, page 24. Item 1 Table 3 provides a summary of the areas that need improvement for the Farley LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and General guidance concerning these requirements can be found in NUREG-1022, Supplement No. l l

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ARE AS MOST NEEDING IMPROVEMENT FOR F ARLEY 1, 2 LERs TABLE Comments Areas Safety assessment inf ormation Statements such as "the health and safety of the public were not affected" are inadequate unless the text contains enough details to allow the reader to see how this conclusion was reached. The text l i

should discuss whether or not the event could have been worse had it ,

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occurred under different but j probable circumstances and provide I infornation about backup systems which were available to limit the l consequences of the even Corrective actions The corrective action discussion should address recurrence prevention and, if appropriate, those actions taken to address the generic aspects of the even All aspects of every personnel error Personnel errors should be discussed (e.g., cognitive vs. procedural, if procedural, what specific procedural deficiency caused the error, and the type of personnel (by title) involved in the error).

Safety system responses All safety systems that actuate automatically or that are manually actuated as a result of the event must be named in the tex Manufacturer and model number Component identification infornetion infornation should be included in the text for each component failure or whenever a component is suspected of contributing to the event because of its desig Power level, mode of operation Operating conditions prior and/or plant temperature and to the event pressure should be provided early in the event discussio , - . -.

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Areas Comments Previous similar events Previous similar events should be referenced (e.g., by LER number) or if none are identified, the text should so stat Ells codes Ells codes should be provided in the text for all systems and/or components discussed in the tex Text presentation A consistent outline format should '

be used by all personnel writing LERs at the station. The practice of writing " abstract-only" reports should generally be avoide Abstracts Cause and corrective action I information should be include ;

Coded fields Titles Titles should be written such that they more accurately describe the event. In particular, include the root cause of the event in all title Licensee contact The position title for the licensee 4

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position title contact named in Item (12) should be provide l

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REFERENCES B. S. Anderson, C. F . Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 198 . Office for Analysis and Evaluation of Operational Data, Licensee Event Repert System, NUREG-1022, U.S. Nuclear Regulatory Commission, ,

September 190 l l Office for Analysis and Evaluation of Operational Data, licensee Event Report System, NUREG-1022 Supplement No.1. U.S. Nuclear Regulatory l Commission, February 198 . Of fice for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory Commission, September 198 .

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APPENDIX A LER SAMPLE SELECTION INFORMATION FOR FARLEY 1, 2

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TABLE A- LER SAMPLE SELECTION FOR F ARLEY 1, 2 LER Number Comments Sample Number Unit Number 85-003-00 ESF 1 1 2 1 85-004-00 3 1 85-011-00 85-012-01 SCRAM 4 1 5 1 85-014-00 6 1 85-015-00 7 1 85-019-00 8 1 86-001-00 1 86-004-00 SCRAM

10 2 85-002-00 ESF 11 2 85-007-00 2 85-009-00 SCRAM

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14 2 85-014-00 15 2 85-015-00 2 86-001-00 SCRAM

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APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR FARLEY 1, 2 l

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TARLE 8- EVALUATION SCORES OF INDIVIDUAL LERs FOR FARLEY 1. 2

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a LER Sample Number 1 ? 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Text .1 .0 .8 .2 .5 .3 .6 .0 Ahstract .5 .5 9.? .4 .5 .3 .5 9.? 8.9 Coded Fields .4 .6 .4 .6 .0 .4 .9 .0 Overall .6 .0 .2 .8 .9 .2 7.3 .7 LER Sample Rumber a 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text .7 Abstract .7 Coded Fields .6 Overall .8 a. See Appendix A for a list of the corresponding LER number J

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APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR FARLEY 1, 2

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l TABLE C- TEXT DEFICIENCIES AND OBSERVATIONS FOR FARLEY 1, 2 Number of LERs with Deficiencies and

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

50.73(b)(2)(ii)(Al--Plant operating 8 (17)

conditions before the event were not included or were inadequat (2)

50.73(b)(2)(ii)(B)--Discussion of the status 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 inadequat (17)

50.73(b)(2)(tilfC)--Failure to include suf ficient date and/or time informatio Date information was insuf ficien Time information was insuf ficien .73(b)(2)(ii)(D)--The root cause and/or 7 (17)

l intermediate failure, system failure, or personnel error was not included or was inadequat Cause of component failure was not 5 included or was inadequate Cause of system failure was not 0 included or was inadequate

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Cause of personnel error was not 2 included or was inadequat .73(b)(2)(ii)(El--The failure mode, 0 (7) l mechanism (immediate cause), and/or effect ,

l (consequence) for each failed component was j not included or was inadequat '

i Failure mode was not included or was inadequate Mechanism (immediate cause) was not included or was inadequate Effect (consequence) was not included

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TABLE C- (continued)

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

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50.73(b)(2)(ii)(F 1--The Energy Industry 16 (17)

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

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component with multiple functions, a list i of systems or secondary functions which were also affected was not included or was .

inadequat .73(b)(2)(ii)(H)--For a f ailure that 1 (10)

rendered a train of a safety system inoperable, the estimate of elapsed time f rom the discovery of the f ailure until the train was returned to service was not include .73(b)(2)(ii)(I)--The method of discovery 2 (17)

of each component failure, system failure, personnel error, or procedural error was not included or was inadequat Method of discovery for each I

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component f ailure was not included  !

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- or was inadequate Method of discovery for each system 0 j b.

failure was not included or was inadequate Method of discovery for each 0 personnel error was not included or was inadequate Method of discovery for each I procedural error was not included or was inadequat l l

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

Description of Deficiencies and Observations Totals Totals ( l l

l 50.73(b)(2)(ti)(J)(1)--Operator actions that 1 (7)

affected the course of the event including l

i operator errors and/or procedural deficiencies were not included or were

inadequat .73(b)(2)(ii)(J)(2)--The discussion of 7 (13)

each personnel error was not included or was inadequate, OBSERVATION: A personnel error was 1 j implied by the text, but was not eiplicitly stated, .73(b)(2)(ii)(J)(2)(11--Discussion 1 as to whether the personnel error was cognitive or procedural was not included or was inadequat c. 50.73(b)(2)(ii)(J)(2)(111--01scussion 1

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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

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with an activity or task that was not covered by an approved procedure was not included or was inadequat " . 73 ( b ) ( 2 ) ( 11 ) ( 3 ) ( 2 )( i i i )--01 s c us s i on 0 j

of any unusual characteristics of the work location (e.g., heat, noise) that

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error was not included or was inadequate,

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t . 73 ( b) ( 2 )( t i l( J )( 2 )( iv )--Di sc us sion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed

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operator, other utility personnel) kas not included or was inadequate, l

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

6 (8)

50.73(b)(2)(ii)(K)--Automatic and/or manual safety system responses were not included or were inadequat (7)

50.73(b)(2)(ii)(L)--The manufacturer and/or model number of each failed component was not included or was inadequat .73(b)(31--An assessment of the safety 11 (17)

consequences and implications of the event was not included or was inadequat OBSERVATION: The availability of 3 other systems or components capable of mitigating the consequences of the event was not discussed. If no other

-

systems or components were available, the text should state that none existed,  %;

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

. stat .

50.73(b)(4)--A discussion of any corrective 9 (17)

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 inadequat .

.

TABLE C- (continued)

Number of LERs with Deficiencies and ,

Observations l Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

a. A discussion of actions required to 3 correct the problem (e.g., return the  ;

component or system to an operational condition or correct the personnel l error) was not included or was inadequat j b. A discussion of actions required to 5 reduce the probability of recurrence of the problem or similar event l l (correct the root cause) was not included or was inadequat c. OBSERVATION: A discussion of actions 3 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.

i

'

50.73(b)(51--Information concerning previous 16 (17)

similar events was not included or was inadequate.

!

l l

l .

,

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

_ _

.

.

TABLE C- (continued)

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

50.73(b)(2)(il--Text presentation 3 (17)

inadequacie A diagram would have 0 OBSERVATION:

aided in understanding the text discussio Text contained undefined acronyms and/or plant specific designator c. The text contains other specific 3 deficiencies relating to the readability, 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 tota The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.

J

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i

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- - - - -

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

- - __

.

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TABLE C- ABS 1RACT DEFICIENCIES AND OBSERVATIONS FOR FARLEY 1. 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations Totals' Totals ( )

A summary of occurrences (immediate cause 2 (17)

and effect) was not included or was inadequate A summary of plant, system, and/or personnel 3 (11)

responses was not included or was inadequat a. Summary of plant responses was not 1 included or was inadequat b. Summary of system responses was not 2 included or was inadequat c. Sunnary of personnel responses was not 1 included or was inadequat A summary of the root cause of the event 5 (17)

was not included or was inadequat A summary of the corrective actions taken or 6 (17)

planned as a result of the event was not included or was inadequat ..

,

.

TABLE C- (continrad)

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

Description of Deficiencies and Observations 1 (17)

Abstract presentation inadequacies 1 OBSERVATION: The abstract contains infornetion not included in the tex The abstract is intended to be a summary of the text, therefore, the text should discuss all information summarized in the abstrac The abstract was greater than 1400 characters 0 The abstract contains undefined acronyms and/or plant specific designator The abstract contains other specific deficiencies (i.e., poor summarization,contradictior,s,etc.) 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 tota The 'p.?qagraph total" is the number of LERs that have one or moreThe num deficiency er observatio for which 's. certain requirement was considered applicabl .

.

.

TABLE C- CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR FARLEY 1, 2 Number of LERs with

-

Deficiencies and Observations Sub-paragraph Paragraph Description of Deficiencies and Observations _ Totals' Totals ( )

'

Facility Name 0 (17) Unit num.b'r was not included or incorrec' Name was not included or was incorrect, Additional unit numbers were included but not require Docket Number was not included or was 0 (17)

incorrec Page Number was not included or was 0 (17)

i incorrec Title was left blank or was inadequate 17 (17) Root cause was not given in title 16 Result (effect) was not given in title 5 Link was not given in title 4 Event Date 1 (17) Date not included or was incorrec I

!

• • Discovery date given instead of event 0 date.

l LER Number was not included or was incorrect 0 (17)

Report Date 0 (17) Date not included l OBSERVATION: Report date was not I within thirty days of event date (or discovery date if appropriate).

Other Facilities information in field is 1 (17)

inconsistent with text and/or abstract.

'

Operating Mode was not included or was 1 (17)

inconsistent with text or abstract.

l l

j

- .

_ . - . . - _ . - _ .

- _ . - . - - - - . .-.- . . _ _ -- .

'

.

.

TABLE C- (continued)

.

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

Power level was not included or was 0 (17)

inconsistent with text or abstract Reporting Requirements 2 (17)

1 The reason for checking the "OTHER" 0 requirement was not specified in the abstract and/or tex OBSERVATION: It may have been more 0 l

appropriate to report the event under a different paragrap OBSERVATION: It may have been 2 appropriate to report this event under an

'

additional unchecked paragrap Licensee Contact 17 (17) Field left bl.!nk 0 Position title was not included 17

, Name was not included 0

' Phone number was not include Coded Component Failure Infornation 3 (17) One or more component failure 0 i

. sub-fields were left blan l Cause, system, and/or component code 2 1 is inconsistent with text.

j Component failure field contains data 0 when no component f ailure occurre I Component failure occurred but entire 1 field left blan ;

i

)

i

!

I I

I

. , _ . .-. - . - . . . _ . . - . . _ _ , - _ . - _ . . - , . . m . _ . _ _ , - , _ . . . _ . _

!

.

)

O TABLE C- (continued)

Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph

!

Description of Deficiencies and Observations Totals' Totals ( )

Supplemental Report 1 (17)

O

Neither "Yes"/"No" block of the supplemental report field was checke The block checked was inconsistent I with the tex Expected submission date information is 0 (17)

l inconsistent with the block checked in

~

< Item (14). 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 tota The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observ&tions. The number in parenthesis is the number of LERs for which a certain requirement was considered applicabl l .

-

!

i i

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-

4

_ _ _ . _ _ _ . . _ _ _

. _ . _ ___ - _ _ . . -

.

.

APPENDIX D LER COMMENT SHEETS FOR FARLEY 1, 2

.

$

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Section Comments LER Number: 85-003-00 Scores: Text Abstract . Coded Fields . Overall Text 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 l spaces. The following comments apply to the abstract that was evaluated as if it were a text.

) .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 include .

l l l .73(b)(2)(11)(K)--Discussion of automatic and/or

penual safety system responses is inadequate. The

! affected safety systems should be listed. If none

]

were affected then so stat l 50.73(b)(51--Information concerning previous similar

' events is not included. If no previous similar events are known, the text should so stat ,

'

Abstract No comment Coded Fields Item (41--Title: Root cause and link are not

< included and the result is vague. A more appropriate

title might be " Inadvertent 4160V Bus Load Shed Due

,

to Personnel Error during Circuit Testing".

l Item (121--Position title is not included.

I

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Section Comments LER Number: 85-004-00 Scores: Text - Abstract = Coded Fields Overall = Text .73(b)(2)(11)(D)--The root and/or intermediate .s

"

cause discussion concerning the personnel error is inadequate. Why did the worker use the auxiliary airlock? .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 include . 50.73(b)(2)(ti)(J)(21--Discussion of the personnel error is inadequat }_0.73(b)(2)(11)(J)(2)(ivi--Discussion of the type of personnel involved ().e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not include This information would be particularly helpful in determining why the worker used the auxiliary instead of the main airlock. For example, if the worker was a contractor personnel, then this might mean that these type people may not be fully aware of the requirements concerning access to containment and that additional training in this area is neede . 50.73(b)(2)(it)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed

in the text is not included. Since the interlock system failed to perform its function and required repairs, this information should be provide . 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not included, i ,13(b)(11--01scussion of corrective actions taken !

or planned is inadequat l A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequat Since the root cause can not be determined from the

_

O O

TABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 1 (348)

Section Comments LER Number: 85-004-00 (continued)

information in the text (see text comment 1), what

<

was done to reduce the probability of this event recurring in the future? Could someone else make the

same error during f uture core alterations? .73(b)(5)--Infornation concerning previous similar

events is not included. If no previous similar events are known, the text should 50 stat Abstract .73(b?(11--Sunnery(of occurrences (immediate cause(sj and effects s)) is inadequat The abstract should mention that the worker broke the interlock devic . 50.73(b)(11--Summary of root cause is inadequat .

How and why did the worker use the auxiliary airlock l

j 1mproperly?

50.73(b)(11--Summary of corrective actions taken or

l 3.

" planned as a result of the event is inadequate. The abstract should mention the repairs made to the i

interlock device as well as actions to prevent l recurrence (see text comment 6).

Coded Fields Item (41--Title: Result and root cause are not include . Item (111--The text fails to provide sufficient  !

,,

inf ormation to allow the analyst to determine under which 10 CFR 50.73(a) requirements this LER should

,

have been reported; however it is clear that core

'

alterations and movement of irradiated f uel took l place over a period of four hours with both auxiliary containment doors open, thus it appears it would have been appropriate to also report this event under other paragraphs of 50.73(a) such as 50.73(a)(2)(11),

(v), and (wit).

! Item (121--Position title is not include !

,

l

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- __ -_. _. . . _ _ - - . - _ . . ._- _ .-. _ _ . .-- , . . _ - _-

.

.

TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

! Section Comments LER Number: 85-011-00 Scores: Text = Abstract . Coded Fields Overall - Text .73(b)(2)(11)(C)--Date and time information for

,

nejor occurrences is inadequate. Phrases such as

"upon completion", and "the error was recognized" should be accompanied by appropriate dates and/or times 50 that the reader will have a perspective of the time-history of the overall even , .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.

,

' .73(b)(2)(ii)(Il--Discussion of the method of discovery of the A and B trains both being inoperable is not included. How was it determined (i.e., what activity was in progress that led to the

.

determination) that both trains were inoperable?

.

' .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 personnel) is inadequate.

,

Who (by title or organization) was responsible for )

,

preparing and reviewing the subject maintenance work ;

-

request?

l

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

! inadequate. The discussion of consequences basically states that there were no consequences because the l trains would have performed all their functions,

except humidity control for train 8. Had the design

'

change been more extensive (e.g., had it involved input power to the trains) the result may have been

,

that both trains would not have been available if

required; what would have been the safety l implications of this situation? Is there any other j system or method available to provide clean emergency air? The requirements of Technical Specification 3.0.3 should be provided in the discussion. Was a time limit exceeded?

l

._ - .

. .- -_ . _ _ _ - . .

. . - _ . . -. .- . . _ .-.-

_ _ _ _ _ _ _ _ _ - - -

.

.

TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Section Comments LER Number: 85-011-00 (continued) .73(b)(4)--Discussion of corrective actions taken

or planned is inadequate. The corrective action discussion should have provided some details concerning how the STP was correcte " Appropriate personnel" should be defined. Did this group include all those who prepare and review maintenance work requests (MWRs) as well as all those technicians assigned to work on NWRs? .73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract No comment Coded fields Item (41--Title: Root cause (personnel error) is not include The fact that a Technical Specification was involved should have been mentioned. A better title might be,

" Personnel Error During Design Change Results in Both Trains of the Control Room Emergency Air Cleanup System Being Technically Inoperable-Technical Specification Problem".

l Item (81--Infornation in field is inconsistent with text and/or abstract. The text does not indicate how Unit 2 is involved. Is the control room common to

, ,

.

both units? Item (121--Position title is not included.

.

- . _ . _ _ _ . _ _ _ . _ _ _ . . _ . _ _ _ _ _ _ . . _ _ _ _ . _ _ . _ _ _ _ . _ _ . _ _ . -- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ _ , . _ _ _ _ _

_ _ .

.

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Section Comments LER Number: 85-012-01 (continued)

' . .73(b)(31--Discussion of the assessment of the  !

safety consequences and implications of the event is inadequate. The safety assessment should address the possible safety consequences of dropping two rods and give specifics as to why this particular event was or was not considered seriou OBSERVATION: The consequences of the event had it i

occurred under more severe cor.ditions should be

'

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

! 1 .73(b)(41--Discussion of corrective actions taken or planned is inadequat :

A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate. Will anything be done to prevent these cables from

,

shorting out again?

'

1 .73(b)(5)--Information ccncerning previous similar i

events is not included. If no previous similar i

events are known, the text should so stat ,

Abstract The root cause and co:ective actions are deficient

for the same reasons as in the text (see text *

,

'

comments 4 and 10).

!

I Coded Fields Item (4)--Title: Root cause is not include i

) Item (12)--Position title is not include . Item (131--Cause, system, and/or component code is

,

inconsistent with text. The text does not indicate that the penetration failed; a more appropriate

component code might be "CBL" for cable.

i i

!

!

i i

!

I

- - - . , . _ . ..,.._. -.___-.-__ , _ .

,.,,_se - _ , _ _ . . _ - - , - , _ _ _ . _ _ . . , . . _ , - . . . _ . . . . _ . . , _ . . _ _ - . - . , _ , _ - - - - - - . , , . _ - _ . - . _ ,

-

_

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Comments Section LER Number: 85-012-01 (continued) .73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequate. The safety assessment should address the

'

possible safety consequences of dropping two rods and give specifics as to why this particular event was or was not considered seriou 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 stat . 50.73(b)(41--Discussion of corrective actions taken or planned is inadequat A discussion of actions required to reduce the probability of recurrence (i.e correction of the root cause) is not included or is inadequate. Will anything be done to prevent these cables f rom shorting out again?

l 1 .73(b)(51--Infornation concerning previous similar events is not included. If no previous similar events are known, the text should so stat I Abstract The root cause and corrective actions are deficient for the same reasons as in the text (see text comments 4 and 10).

,

-

. Coded Fields Item (41--Title: Root cause is not include . Item (12)--Position title is not include . Jtem (13)--Cause, system, and/or component code is

! inconsistent with text. The text does not indicate

! that the penetration failed; a more appropriate J component code might be "C8L' for cable.

\

l l

r i

__ - , . . _ _ _ _ _ _ _ _ _ _ _ . .

. . _ _ _ . _ . . _ _ . . _ _ _ _ . _ _ _ . _ _..___ __.._. _. - . _ _ _ . . ._ . _ _ . _ -

. _ _ _ _ _ _ _ _ _

- .-. __ - . - -

O

.

7ABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 1 (348)

Comments Section LER Number: 85-014-00  :

8.9 Overall Abstract = Coded Fields Scores: Text - . Submittal of an LER without a text is acceptable; Text however, the abstract nost then meet all the renuirements 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 tex . 50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not include . 50.73(b)(2)(ii)(C)--Time information for nujor occurrences is inadequate. When was the diesel shut down?

l .73(b)(2)(ii)(F_)--The Energy Industry l

!

Identification System component function identifier (s) and/or system name of each component or i

system referred to in the LER is not included.

j .73(b)(2)(ii)(3)(21--Were there any unusual l characteristics of the work location (e.g., poor l lighting, cramped quarters) that contributed to this

• error? .73(b)(2)(ii)(K)--Discussion of automatic and/or It is j manual safety system responses is inadequat not clear if the statement "All equipment functioned

as designed" refers only to the diesel generator

,

start or to other equipment as well.

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

,

not include . 50.73(b)(5)--Information concerning previous similar

,

' events is not included. If no previous similar events are known, the text should so stat . Some ideas are not presented clearly (hard to follow).

l )

i

'

Abstract .73(b)(11.-Sunnury of plant and systems responses is inadequate. See text comment 6.

i

. .. -

-. - - -. --- . . - . - - - - - -

- ,

.

a TABLE D- SPECIFIC LER COMENTS FOR F ARLEY 1 (348)

Section Comments LER Number: 85-014-00 (continued)

,

Coded Fields Item (41--Title: Root cause is not include . Item (12)--Position title is not include L k

t i

- -_- - - , _

.

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I

TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Section Coments LER Number: 85-015-00 Scor e s: Text - Abstract = Coded Fields - Overall = 8.2

,

Text .73(b)(2)(ii)(C)--Date information for major

' occurrences is inadequate. When was the "information obtained from the reactor vendor- " (last sentence of first paragraph)? What was the date on which the

information was incorrectly interpreted thus i

l resulting in the procedural inadequacy? .73(b)(2)(ii)(F1--The Energy Industry Identification System component function 1

!

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

! .73(b)(2)(11)(Il--Discussion of the method of discovery of the June 1985 determination is not included. Was information provided by the vendor?

l .73(b)(2)(11)(J)(21--Discussion of the personnel error is inadequate.

,!

'

50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of l

personnel involved (i.e., contractor personnel, i

utility licensed operator, utility nonlicensed j operator, other utility personnel) is not include Who (by title or organization) was responsible for the information being incorrectly interpreted?

l .73(b)(4)--Discussion of corrective actions taken l

'

or planned is inddequate. What was done to prevent i

~

future misinterpretation of information of this l importance?

i .73(b)(51--Informationconcerningprevioussimilar

! events is not included. If no previous similar j

events are known, the text should so stat Abstract No comment ,

!

Coded Fields Item (4)--Title: Root cause is not included. A better title might be " Misinterpretation of

l l

Information from Vendor Results in Nonconservative i

Settings for Nuclear Instrumentation Rate Trips",

i i

) .

I . -

- . _ _ - - - - _ - - _ - - _ - . - ___ - - - - - _ _ _ _ _ - - - - - - - - - .

_ _ _ _ _ _ _ . . _ _ - . - _ _ _ _ _ _ - _ - - - - - _ - - - - _

l

'

. l TABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 1 (348)

Section Comments LER Number: 85-015-00 (continued)

i Item (51--Event date is incorrect. The " event date" is the date that rate trips were se; nonc'onservatively for the first time. The " discovery s ,_, /

date" is June of 1985. The "reportability date" is

9-25-85. See NUREG-1022 Supplement No. 1. Page 22, i

question and answer number 1 . Concerning "reportability", it would be more conservative to submit an LER at the time of discovery (i.e., June of 1985 for this event) and then submit a supplement that provides the results of the evaluation requested from the vendor as soon as the results become available rather than wait for the vendor's inf ormation before submitting an LER.

.I Item (91--Operating mode is not included.

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

' Item (12)--Position title is not include I j

-

l

, .

,

I

l

!

!

l i

i i l

'

i

!

,

{

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

-

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

_ _ _ _ _ - _ _ __ _ _ -

.

.

TABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 1 (348)

Section Comments LER Number: 85-019-00 Scores: Text = Abstract = Coded Fields = Overall = Text .73(b)(2)(ii)( A)--Discussion of plant operating conditions before the event is not incinde . 50.73(b)(2)(ii)(D)--What was the sour'ce (root cause)

of the inadequate verification (i.e., is there a need to change the procedure)? .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 include . 50.73(b)(2)(ii)(J)(21--Discussion of the personnel error is inadequat .73(b)(2)(ii)(J)(2)(ii)--Discussion as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure is not include .73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not include ' .73(b)(4)--What will be done to assure adequate verification of the work in the future? See text

comment number . 50.73(b)(51--Information concerning previous similar t

l events is not included. If no previous similar

!

events are known, the text should so stat ;

l Abstract No comment l l

Coded Fields Item (4)--The title is misleading in that it is not clear why the smoke detectors were inoperabl ]

Without describing the root cause, the reader has no idea that the smoke detectors were inoperable due to a personnel error. A more appropriate title might be

" Inoperable Smoke Detectors Due to Improper Wiring by Personnel". Item (121--Position title is not include .-_

__ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

Comments Section LER Number: 86-001-00 Abstract = Coded Fields Overall = Scores: Text = Text .73(b)(2)(ti)(Al--Discussion of plant operating conditions before the event is not include . 50.73(b)(2)(ii)(F 1--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 include . 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is not include . 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract .73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should mention the valves were properly labeled, that valve alignments on other radiation

' monitors were checked, and that appropriate personnel were counseled concerning their failure to recognize the low count rat Coded Fields Item (4)--Title: Root cause is not include . Item (12)--Position title is not included.

I

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 1 (348)

)

Section Comments l LER Number: 86-004-00 Text - Abstract - Coded fields Overall - Scores:

Text .73(b)(2)(ti)(D)--The root and/or intermediate cause discussion concerning the electrical short in the penetration, the failure of the source range detector, and the second blown fuse is inadequat Although not explicitly stated, it can be inferred from the last paragraph that the penetration that shorted is a General Electric Series 10 If this is the case, some background infornation should have been provided in this LER concerning the apparent generic problem described in LER 85-016-0 No cause is provided for the failure of the source range detector or the second blown fus . 50.73(b)(2)(ii)(F)--The Energy Industry Identification System con.ponent function identifier (s) and/or system name of each component or system referred to in the LER is not include . 50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The safety systems that " functioned as designed" should have been name . 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is inadequate. The panufacturer and

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model number of both the penetration module and the source range detector should have been provided in the tex . 50.73(b)(3)--Discussion i f the assessment of the 6 safety consequences and implications of the event is inadequate. The statement concerning the health / safety of the public should be followed by the reasons the statement is believed to be true. In addition, given that there appears to be a potential generic problem involving shorting of certain penetration modules, has there been an evaluation of what other safety system (if any) might be adversely affected by a short in the future?

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TABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 1 (348)

'Section Comments LER Number: 86-C04-00 (continued) .73(b)(41--Discussion of corrective actions taken or planned is inadequate. What are the control rod drive system electrical penetration modules scheduled to be replaced with (manufacturer /model number)? Why are only the control rod drive modules going to be replaced? A logical transition does not exist between all idea Abstract .73(b)(11--Summary of system responses following the scram is not include . 50.73(b)(11--Summary of corrective actions taken or planned as a result of the event is inadequate. The generic implications of the event are not mentione . It is not apparent why the information concerning the

" additional" blown fuse is provided in the abstrac Coded Fields Item (4)--The title should have contained a reference to the GE Series 100 modul . Item (12)--Position title is not include . Item (13)--Component failure occurred but entire field is blank. A field should have been filled in for the source range detecto !

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Comments 1 LER Number: 85-002-00 Scores: Text = Abstract = Coded Fields - Overall = Text .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 include . 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error is inadequat .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 personnel) is not include . 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not include . 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract .73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The reinstruction of personnel should have been mentione Coded Fields Item (4)--Title: Root cause is not include . Item (12)--Position title is not included.

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Comments 1 LER Number: 85-007-00 Scores: Text = Abstract = Coded Fields Overall = Text Submittal of an LER without a text is acceptable; however, the abstra:t must then meet all the requirements of a text and still be less than 1400 spaces. The following comments apply to tha abstract that was evaluated as if it were a tex . 50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not include . 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 include . 50.73(b)(31--Discussion of the assessment of the safety consequences and implications of the event is inadequat 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 stat 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 stat . 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract No comment Coded Fields Item (4)--Title: Root cause is not include . Item (12)--Position title is not included.

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Comments Section 12. LER Number: 85-009-00 Abstract = Coded Fields = Overall = Scores: Text = Text .73(b)(2)(ii)(C)--Time infornation for major occurrences is inadequate. At what time (date) were the steam dumps restored to operability? .73(b)(2)(ii)(01--The root and/or intermediate cause discussion concerning the blown fuse and the leak-by of V538 is not include . 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 include . 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is inadequat What actions did the operators attempt to reduce reactor power and why were they unsuccessful? .73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequat .73(b)(2)(ii)(3)(21--It appears that personnel error is involved in this event, but it is not discussed. The caution statements that are to be added to the applicable procedures are for the purpose of trying to prevent personnel from making

,, another erro e .73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The safety systems that " functioned as designed" should have been name . 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not include . 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not include . 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What was done to prevent recurrence of the fuse blowing? What was V538

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TABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 2 (364)

Section Comments 1 LER Number: 85-009-00 (continued)

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replaced with (manufacturer and model number)? What will the caution statements say? Why are caution statements concerning air in-leakage only being added to procedures for condenser _ pressure transmitters and switches?

1 _50.73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat . A logical transition does not exist between all idea . It is not apparent to the reader why the loss of the 28 steam generator feed pump caused the low-low level in steam generator 2 Abstract .73(b)(11--Summary of occurrences (immediate cause(s) and effects (s)) is inadequate. The fact that operation of the steam dumps was blocked by the low condenser vacuum signal should have been mentioned in the abstrac . 50.73(b)(1)--Summary of system and personnel responses are is inadequate. See text comments

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number 4 and . 50.73(b)(11--Summary of root cause information is inadequate. No reason is given for the leak-by of

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V53 Also, V538 should have been stated explicitly rather than referring to it as "the isolation valve to PT502". .73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number . 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 sumnerized in the abstract; namely, a discussion concerning the health / safety of the publi .

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Consnents 1 LER Number: 85-009-00 (continued)

Coded Fields Item (41--Title: Root cause and link are not include . Item (121--Position title is not include l i

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Comments 13. LER Number: 85-011-00 Scores: Text - Abstract - Coded Fields Overall - Text 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 tex . 50.73(b)(2)(11)(D)--When a root cause cannot be determined, the actions taken to try to determine the cause should be discussed. What was the cause of the high thrust bearing temperature? .73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system nane of each component or system referred to in the LER is not include . _50.73(b)(2)(11)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not include . 50.73(b)(3)--Discussion of the assessment of the safety consequences and implications of the event is not include . 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What actions were taken to

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fix the pump? Will anything be done (e.g., more frequent surveillance) to try to determine the problem with the FRV? .73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract No comment Coded Fields Item (4)--Title: Root cause (unknown) and link (low steam generator level) are not include . Item (12)--Position title is not include . - - ._ - . . _ _ . - . . -_

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Comments 14. LER Number: 85-014-00 Scores: Text = Abstract = Coded Fields Overall = Text .73(b)(2)(ii)(Al--Plant operating conditions prior to the event are required to be included in the text of each LER. While this requirement may not appear to be applicable to this event, personnel using this LER as a source of data may need to know this informatio . 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 if the fuel cladding had been breeched? .73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat I Abstract No comment Coded Fields Item (4)--Title: Root cause is not include . Item (12)--Position title is not include .

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TABLE D- SPECIFIC LER COMMENTS FOR FARLEY 2 (364)

Section Concent s 15. LER Number: 65-015-00 Scores: Text - Abstract - Coded Fields - Overall Text .73(b)(2)(ii)(Al--Discussion of plant operating conditions before the event is not include . 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 include . 50.73(b)(2)(11)(J)(21--01scussion of the personnel error is inadequat .73(b)(2)(11)(J)(2)(11--Discussion as to whether the personnel error was cognitive or procedural is '

not include i 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of ,

l personnel involved (i.e., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not include . 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract .73(b)(1)--Summary of root cause information is inadequat See text comment number Cbded Fields Item (4)--Title: Root cause and result (Technical Specification violation) are not included. A better i title might be, " Personnel Error During Surveillance i Procedure Resulted In Nuclear Instrumentation System l Rate Trips Being Outside the Range Allowed by l Technical Specification 3.3.1". l Item (121--Position title is not included.

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1ABLE D SPECIFIC LER COMMENTS FOR F ARLEY 2 (364)

Section Comments 16. LER Number: 86-001-00 Abstract Coded Fields - Overall Scores: Text = Text .73(b)(2)(ti)(D)--When the root cause of a failure cannot be determined, the actions taken to try to determine the cause should be discusse . 50.73(b)(2)(ti)(F1--lhe Energy industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not include . 50.73(b)(2)(11)(K)--Discussion of automatic and/or manual safety system responses is inadequate. As a minimum, list the safety systems that actuated as a result of the even . 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not include . 50.73(b)(31--01scussion of the assessment of the safety consequences and implications of the event is not include . 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. A supplemental report appears to be needed to describe the results of the engineering study. Without a commitment to submit a supplemental report, this LER must be considered incomplete.

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l events is not included. If no previous similar events are known, the text should so state.

! Abstract No comment Coded Fields Item (41--Title: Root cause (short circuited power supply) is not include . Item (12)--Position title is not include . Item (14)--The block checked is inconsistent with information in the text (see text comment 6).

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1ABLE D- SPECIFIC LER COMMENTS FOR F ARLEY 2 (364)

Section Comments 17. LER Number: 86-002-00 Scores: Text Abstract Coded Fields Overall - Text 1, 50.73(b)(2)(11)(Al--Discussion of plant operating conditions before the event is not included, .73(b)(2)(ti)(F)--The Energy Industry i

Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not include . 50.73(b)(51--Information concerning previous similar events is not included. If no previous similar events are known, the text should so stat Abstract .73(b)(11--Summary of root cause is inadequat The abstract should mention that a cause for the actual tubing configuration being inconsistent with the drawing could not be determine Coded fields Item (4)--Title: Root cause is not included. The title should indicate that the cause of the tubing

! being missing was unknow . Item (12)--Position title is not include t l Item (131--Cause, system, and/or component code is l inconsistent with text. The tubing did not fail; it was not installed. Component code Al might be more appropriate, as the hydrogen analyzer itself may not '

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