ML20238A483

Forwards AEOD Assessment of LERs for Plant During SALP Period Mar 1986 - Jul 1987,for Info.Overall Quality of LERs Improved Slightly from Previous Evaluation.Quality of Discussions of Personnel/Procedural Errors Decreased

ML20238A483
Person / Time
Site:	Oconee
Issue date:	08/31/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8709090314
Download: ML20238A483 (60)

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s. t 4 c' 4 August 31, 1987 Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55 Duke Power Company vATTN: Mr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen:

The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AE0D) has recently completed an assessment of your Licensee Event Reports (LERs) for Oconee 1, 2, and 3 as a part of the NRC's Systematic Assessment of Licensee Performance (SALP) program. This assessment was performed to support a SALP period of March 1, 1986, to July 31, 1987, and is being forwarded at this time for your use and information in order to pattern future submittals.

The summary to the report highlights the findings of the evaluation. This evaluation of Oconee 1, 2, and 3 LERs reflects an overall quality which has improved slightly from our previous evaluation. The quality of discussion of root causes and safety consequences has shown noteworthy improvement. The quality of discussions of corrective actions remained virtually unchanged, while the quality of discussions of personnel / procedural error decreased somewhat. Both areas should receive increased attention. The quality of discussions of operator actions and safety system responses remains very high; however, the quality of discussions of manufacturer and model number of failed components remains very low and should also receive increased attention. Details of the findings are discussed in the body of the evaluation report.

Please let us know if you have any questions.

Sincerely, Original Signed by Luis A. Reyes Luis A. Reyes, Director Division of Reactor Projects

Enclosure:

LER Quality Evaluation for Oconee 1, 2, and 3 cc w/ enc 1:

'E S. luckman, Station Manager bec w/ enc 1: (See page 2) , -

&Da h B709090314 870031 PDR ADOCK 05000269 \

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c Duke Power Company 2 August 31, 1987 bec w/ enc 1:

(NRC Resident Inspector

.H' Pastis, NRR State of South Carolina Document Control Desk T. Peebles, RII

8. Bonser, RII S. Ninh, RII RII RII s RII

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h/87 08 /87 8/tf/87

c ENCLOSURE LICENSEE EVDTI' xtaue (IER)

QUALITY EVAll1ATION FOR 000 NEE 1,2,3 IXJRDIG 'DE PERIOD FRCH MAROI 1 1986 'IO JULY 31 1987 i

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Oconee 1,2,3 during the period from March.1, 1986 to July 31, 1987 was performed. This evaluation provides an overview of the quality of the LERs by comparing their contents to the reporting requirements of 10 CFR 50.73(b) and the guidelines contained in NUREG-1022 and its Supplements Nos. I and 2.

This is the second time the Oconee LERs have been evaluated using this methodology. The results of this evaluation indicate that the overall quality of the Oconee LERs, for the three areas that are evaluated (i.e.,

the text, abstract, and coded fields), has remained virtually unchanged from the previous evaluation. The first evaluation's overall average LER score was 8.2, which was above the industry average (7.7) at that time.

For the current evaluation, Oconee's overall average LER score is 8.4, and l

the current industry average has increased to 8.4. The quality of the discussions concerning root cause, corrective actions, and safety system responses has increased slightly since the previous evaluation, and remain

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l at or above the industry average.

Two deficiencies found in this evaluation concern the requirements to discuss personnel / procedural errors and to adequately identify failed components. The score for the personnel / procedural errors decreased somewhat since the previous evaluation, but remains near the industry average. The score for the requirement to identify those components that failed (e.g., by manufacturer and model number) increased, but is still .

considered inadequate, as it is well below the industry average. .

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LER QUALITY EVALUATION FOR OCONEE, 1,2,3 i

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INTRODUCTION In order to evaluate the overall quality of the contents of the Licensee ~ Event Reports (LERs) submitted by Oconee 1,2,3 during the period from March 1, 1986 to July 31, 1987, a sample of the unit's LERs was evaluated. This evaluation was performed by comparing the contents of each LER to the reporting requirements of 10 CFR 50.73(b) and the guidelines contained in NUREG-1022 I and its Supplements Nos. 1 2 and 2.3 The sample consists of a total of 15 LERs, which is considered to be'the

, maximum number of LERs necessary to be evaluated for a unit / station. See Appendix A for a list of the LER numbers in the sample.

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

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

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

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measures be taken are not intended to increase requirements and should be viewed in that light. However, the minimum requirements of the regulation j must be met. '

The evaluation process for each LER is divided into two parts. The first part of the evaluation consists of documenting comments specific to the content and presentation of each LER. The second part consists of I determining a score (0-10 points) for the text, abstract, and coded fields of each LER.

The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was evaluated. Likewise, the scores serve two purposes: ( O they I serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis j for determining an overall score for each LER. The overall score for each

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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 l score = overall LER score).

The results of the LER quality evaluation are divided into two categories: (1) detailed information and (2) summary information. The detailed information, presented in Appendices A through D, consists of LER sample information (Appendix A), a table of the scores for each sample LER f (Appendix B), tables of the number of deficiencies and observations for the  ;

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

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

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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 l represent the analysts' assessment of the unit's performance (on a scale of. l O to.10) in submitting LERs that meet the criteria of 10 CFR 50.73(b) and the guidance present in NUREG-1022 and its supplements.

Table 1 presents the average scores for the sample of LERs evaluated for the unit. .In order'to place the scores provided in Table 1 in perspective, the distribution of the overall average score for all units / stations that have been evaluated using the current methodology is provided on Figure 1. Figure 1 is updated each month to reflect any changes in this distribution resulting from the inclusion of data for those i units / stations that have not been previously evaluated or those that have l been reevaluated. (Note: The previous score for those units / stations that are. reevaluated is replaced with the score from the latest evaluation).

Table 2 and Appendix Table B-1 provide a summary of the information that is the basis for the average scores in Table 1. For example, Oconee's average score for the text of the LERs that were evaluated is 8.5 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 from the discussion of plant operating conditions prior to the event

[10 CFR 50.73(b)(2)(ii)(A)] to text presentation. The resultant percentage scores in the text s mmary section of Table 2 provide an indication of how well each text requirement was addressed by the unit for the 15 LERs that l were evaluated. Based on similar methodology, the percentage scores for the various sections of the abstract and the items in the coded fields were also computed and are shown in Table 2.

As indicated in Table 2, certain requirements or areas within the text, abstract, and coded fields are causing the unit difficulty when preparing LERs. Relatively low percentage scores may indicate that the unit needs additional guidance concerning these requirements, or it may indicate that the unit understands the basic requirement but has either:

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... -TABLE'1.

SUMMARY

OF SCORES FOR OCONEE 1,2,3 Average High Low Text 8.5 9.5 6.7 Abstract 6.4 9.7 5.0 Coded Fields 8.5 9 .' 3 6.9 Overall 8.4 9.4 6.3

a. See Appendix B for a summary of scores for each'LER that was evaluated.

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TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR OC'. NEE 1,2,3 4

TEXT Percentage a

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

(2)(11)(A) - - Plant condition prior to event 73 (15)

(2)t::)(B) - - Inoperable equipment that contributed b (2)(li)(C) - - Date(s) and approximate time (s) 78 (15)

(2)(ii)(D) - - Root cause and intermediate cause(s) 93 (15)

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

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

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

Estimate of unavailability 79 ( 7)

(2)(ii)(I) - - Method of discovery 97 (15)

(2)(ii)(J)(1) - Operator actions affecting course 100 ( 6)

(2)(11)(J)(2) - Personnel error (procedural deficiency) 84 (11)

(2)(ii)(K) - - Safety system-responses 100 ( 6)

(2)(ii)(L) - - Manufacturer and model no. information 44 ( 8)

(3) - - - - - - Assessment of safety consequences 97 (15)

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- - - - Corrective actions 85 (15)

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

- Text presentation 57 (15)

(2)(i> 86 (15)

ABSTRACT Percentage a

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

- Major occurrences (immediate cause/effect) 98 (15)

- Plant / system / component / personnel responses 97 ( 5)

- Root cause information 89 (15)

- Corrective action information 64 (15) 1 Abstract presentation 80 (15) j I

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TABLE'2. (continued)

CODED FIELDS Percentage a

Item Number (s) - Descriptions '

Scores ( )

1, 2, and 3 - Plant name(unit #), decket #, page #s 92 (15) 4- - ----

Title 65 (15) 5, 6, and 7 - Event date, LER no., report date 93 (15) 8------ Other facilities involved 96 (15) 9 and 10 - -

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

Reporting requirements 88 (15) 12 - - - - -

Licensee contact information 99 (15) 13 - - - - -

Coded component failure information 71 (15) 14 and 15 - - Supplemental report information 90 (15)

a. Fercentage scores are the result of dividing the total points for a requirement by the number of points possible for that requirement.

(Hete: Some requirements are not applicable to al; LERs; therefere, 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*4 if it is provided and is always considered "not applicable when it is not.

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(1) excluded certain less significant information from a number of tne l

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

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

Text Deficiencies and Observations l Discussion of personnel / procedural error, Requirement 50.73(b)(2)(ii)(J)(2), is an area where the score slipped from the previous evaluation to just below the industry average. Five of the 11 LERs containing a personnel / procedural error were considered deficient. Four of l the discussions failed to adequately identify the type of personnel involved (e.g., contractor personnel utility licensed operator, utility I

nonlicensed operator, other utility personnel), and two failed to indicate whether the personnel error was cognitive or procedural.

i As in the first evaluation, the requirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was considered to be inadequate for five of the eight LERs involving a component failure. In most cases this requirement can be met by simply providing the manufacturer and model number for each failed component. For certain components (e.g., pipes, fitting, etc.) the material and size of the failed component may be more appropriate information. Whatever information is provided, it should be specific enough to allow a reader to determine if the failed component is the same as one used at his facility.

In addition, there are instances where information that identifies components (even though these components didn't fail) could be important to the reader. For example, if the design of a component contributes to the event, it would be helpful to provide information that would enable others 8

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\g ifo 1 to specifically identify the component. A&exampleofsuchacomponsnt hp .might be a valve that opens with a clockwise turn of its handle-{mbich could lead to.an improper valve line up due to a personnel error while

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. operating the valve).

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Therequirementtoprovidedatesang: appropriate times of occurrences, '

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Requirement 50.73(b)(2)(ii)(C), was conodered marginal because eight of the 15 LERs lacked sufficient date/ time information. There is obviously not one set of rules concerning what dates and times to include; in some t W LERs,providingonlythe'$ateoftheeventissufficient,whileothers require times in seconds to adequately describe the time history of the

' various occurrences described'in the event. Prior to submitting an LER, i_: \

the reviewers should review the text for obvious places where the addition of a date and/or time would provide meaningful information. In addition, sufficient dete/ time information was not provided in two of the seven LERs e

such that a reader could estimate the elapsed time that a safety system train was inoperable (i.e., unavailable), Requirement 50.73(b)(2)(ii)(H).

, The requirement tIprovide a reference to previous timilar events, y

,$equirement 50.73(b)(5),was not addressed in five of. the 15 LERs and was T

considered-inadequate in three other LERs. Reference to previous similar events is best accomplished by providing LER numbers and some background.

information if the event was reported. If no previous similar events are identified, this might be stated in the text (see NUREG-1022, Supplement No. 2, Appendix D, page 0-4).

The requirement to provide the plant operating conditions before the event, Requirement 50.73(b)(2)(ii)(A), was not provided in four of the 15 LERs. This data could aid the reader in determining how serious the 1

consthiuences of the event could be. Additional data, such as applicable pressures and temperatures, may also be desirable depending on the event.

The Energy Industry Identification System (EIIS) codes were not provided in the text of any.of the 15 LERs. These codes a re required for all components and systems referred to in the text, not just those that fail.

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Abstract Deficiencies and Observations While there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as stated in NUREG-1022, Supplement No. 2, summarize the following information from the text:

1. Cause/Effect What happened that made the event reportable.

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

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

4. Corrective Actions What was done immediately to restore the plant to a safe and stable condition and what was done or planned to prevent recurrence of the event.

While the first three requirements were, in general, adequately addressed in the abstracts of the LERs reviewed, eleven of the LERs failed to adequately summarize the corrective actions. This could easily be corrected by being sure to summarize all corrective actions discussed in the text. The abstract should be a summary of the text and as such should not introduce information that was not included in the text (three LERs discussed new data in their abstracts). If during the review process this is discovered, the text should be revised so as to include the information.

Coded Fields Deficiencies and Observations The main deficiency in the area of coded fields involves the titles, Item (4). Fourteen of the 15 titles failed to include adequate cause information, three failed to include the result of the event and two failed 10 u________. _ >

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. s to include the link between the cause and the result. While the result is considered to be the most important pai? of the title, cause and link

-information (as suggested in NUREG-10?2, Supplewnt No. 2) should be included to make a title complete. Example' titles are presented in Appendix D for a few of the LERs whit.h were considered to have poor titles.

Another area that was fc.und deficier$t in thirteen LERs wa the coceo' field for failed components, Item (13). These fields are s wpo:ed tn be filled out only for failed components. (Note: Two or more identical failed components require only one line to be filled in). < -

SUMMARY

I Tat'le 3 provides a summary of the areas that need improvement for the '

Oconee LERs. For additional and more specific information concern'ing deficiencies, the reader should refer to the information presented ,in ,

Appendices C and D. General guidance concerr f ng requirements can td found 4

inNUREG-1022,andNUREG-1022SupplementsNo)l'and2.

As was mentioned earlier, this is the second tie that the Odonee LERs have been evaluated using the same methodology. The preitous evaluation t

was reported in March of 1986. Table 4 provides a*cosparison of the scores i s for both evaluations. Small improvements in the information provided concerning root cause, corrective actions, and safety systen ref honses helped increase the text score slightly. The increase could have been larger except that drops in areas such as date/ time information partially offset the increases. The overall average lER score of 8.4 is presently 7

the same as the current indestry overall average. (Note: The industry overall average is the result of averg ing the latest overall average LER I score for each unit / station that has been evaluated using this methodology.)

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%E ,.T/CLE 3. AREAS MOST NEEDING IMPROVEMENT FOR OCONEE 1,2,3 LERs T

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y Areas Comments p * "ofrsonnel/p \

edural' error Details should be explicitly stated (e.g.,

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/ involved should be discussed). {

. c- / anufacturn M and model number Component identt fication information b

(manufacture and model number, if possible, or other unique information about the

./4' component) should be included in the text whenever a component fails. In addition, (although not specifically required by current regulatiore)~it would be helpful to identify a component if its design is suspected of contributing to the event.

Date/ time end Sufficient dates and times shov.ld be safety trafn unavailability included in the text to enabla the reader to have a good time history of the event and to (if applicable) estimate the length of time that safety system trains or components are inoperable (i.e. ,

unavailable).

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.

Plant;up? rating conditions Plant operating cl.'nditions prior to the

. event should be ir.cluded in every LER.

EOS codes Codes for each component (and system) referred to in the LER should be provided.

Abstracts Corrective action information from the text should be mentioned (summarized) in the abstract. Don't include new information (i.e., information not discussed in the text) in the abstract.

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'Y a, Titles Titles should be written such that they better describe the event. In particular,

'cause'information should be included in each title, I

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Areas Comments Coded Fields (Continued)

b. Component failure field This field need only be completed for failed components.

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. TABLE 4. COMPARISON OF LER SCORES FOR OCONEE 1,2,3 Report Date March-86 August-87 i

Text average 8.3 8.5 l Abstract average 8.1 8.4 Coded fields average 8.1 8.5 Overall LER average 8.2 8.4 l

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f REFERENCES h

. 1. Of'fice for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, l September 1983.

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

3. Office for Analysis and Evaluation of Operational Data, Licensee Event i

' Report System,. NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory Commission, September 1985.

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APPDIDIX A LER SAMPIE SEIECTION INFORMATION EDR OCONEE 1,2,3 l

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h TABIE A-1. IER SAMPLE SELECTION IDR OCDNEE 1,2,3 Sample 1Arber IER Number Unit ! Amber Comments 1 86-005-00 1 2 86-009-00 1 3 86-011-00 1

1. 86-012-00 1 5 86-014-00 1 6 87-001-00 1 7 87-003-00 1 8 86-004-00 2 SCRAM 9 86-006-00 2 SCRAM 10 87-002-00 2 SGAM 11 87-004-00 2 SGAM 12 86-003-01 3 13 87-002-00 3 ESF 14 87-004-00 3 15 87-007-00 3 A-1

APPDIDIX B EVAIDATION SCORES OF INDIVIDUAL IIRS FOR OOONEE 1,2,3 s

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TABLE B-1. EVALUATION SCORES OF INDIVIDUAL LERS FOR OCONEE 1,2,3 a

LER Sample Number 1 2 3 4 5 6 7 8 Text 8.1 '8.9 7.8 8.6 9.0 6.7 7.9 9.;

Abstract 8.8 8.4 9.0 9.5 8.0 5.0 8.6 9.7 Coded Fields 8.9 8.2 7.9 8.1 9.3 7.7 6.9 9.2 Overall 8.4 8.6 8.2 8.8 8.7 6.3 8.0 9.4 a

LER Sample Number 9 10

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Text 8.6 8.8 8.1 8.8 9.5 8.8 8.3 0.5 Abatract 8.5 9.1 8.5 8.1 8.0 8.7 7.6 8.4 Coded Fields 8.9 9.1 9.3 8.7 9.1 8.7 7.7 8.5 Overall 8.6 8.9 8.4 6.6 9.0 8.7 8.0 8.4

a. See Appendix A for a list of the correspcndir.g LER numbers.

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APPDIDIX C DEFICIDICY AND OBSM%TICt1 CDUNIS FOR OCDIEE 1,2,3 l

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TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR OCONEE 1,2,3 Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b-50.73(b)(2)(ii)(A)--Plant operating 4 (15) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 3) of the structures, components, or systems that were inoperable at the start of.the event and that contributed to the event was not included or was inadequate.

50.73(b)(2)(ii)(C)--Failure to include 8 (15) sufficient date and/or time information.

a. Date information was insufficient. 6

b. Time information was insufficient. 3 50.73(b)(2)(ii)(0)--The root and/or 5 (15) intermediate cause of the component or system failure was not included or was inadequate.

a. Cause of component failure was not 5 included or was inadequate.

b. Cause of system failure was not 0 included or was inadequate.

50.73(b)(2)(ii)(E)--The failure mode, 0 ( 7) mechanism (immediate cause), and/or effect (consequence) for each failed component was not included or was inadequate.

a. Failure mode was not included or was inadequate.

b. Mechanism (immediate cause) was not included or was inadecuate.

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 a Totals ( )b 50.73(b)(2)(ti)(F)--The Energy Industry 15 (15)

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

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

50.73(b)(2)(ii)(H)--For a failure that 2 ( 7) rendered a train of a safety system inoperable, the estimate of elapsed time from the time of the failure until the train was returned to service was not included.

50.73(b)(2)(ii)(I)--The method of discovery 1 (15) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate. {

a. Method of discovery for 'each I component failure was not included or was inadequate.

b. Method of discovery for each system 0 failure was not included or was inadequate,

c. Method of discovery for each 0 personnel error was not included or was inadequate.

d. Method of discovery for each 0 procedural error 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 a Totals ( )b 50.73(b)(2)(ii)(J)(1)--Operator actions that 0 ( 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 5 (11) each personnel error was not included or was inadequate.

a. OBSERVATION: A personnel error was 1 implied by the text, but was not explicitly stated,

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

c. 50. 73( b)( 2 )( i i )(J )( 2)( i ij--Di sc u s s i on 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)(ii)(J)(2)(iii)--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 4 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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'ABLE C-1. (continued)

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

• Totals ( )b t

50.73(b)(2)(ii)(K)--Automatic and/or manual 0 ( 6) safety system responses were not included or were inadequate.

50.73(b)(2)(ii)(L)--The manufacturer and/or 5 ( 8) codel number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of.the safety 4 (15) consequences and impli:ations of the event was not. included or was inadequate.

a. OBSERVATION: The availability of 0 other systems or components capable of mitigating the consequences of the event was not discussed. If no other systems or components were available, the text should state that none existed.

b. OBSERVATION: The consequences 3 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 6 (15) 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.

f L

C-4

i

-TABLE C-1. (continued)

. Number of LERs with-Deficiencies and

_ Observations i

Sub paragraph Paragraph Description ~of Deficier.cies and Observations Totals

• Totals ( )b

a. A discussion of actions required sto 0

. correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate,

b. A discussion of actions required to 2 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 I 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 concerning previous 8 (15) similar events was not included or was inadequate.

C-5 L_2_ _ - ------- - - - - - - - - -

' TABLE C-1. (continued)

Number of LERs with.

Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b 50.73(b)(2)(1)--Text presentation 7(15) inadequacies. (

a. OBSERVATION: A diagram would have 1 aided in understanding the text discussion.

b. Text contained undefined acronyms 5 and/or plant specific designators.

c. The text contains.other specific 3 deficiencies relating to the' readability.

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

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

1 l

y l

i C-6 i

k .. _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

6 TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR OCONEE 1,2,3 I

(

Number of-LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b A summary of occurrences (immediate cause 1 (15) and effect) was not included or was inadequate.

A summary of plant, system, and/or personnel 0 ( 5) responses was not included or was inadequate.

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

b. Summary of system' responses was not

-included or was inadequate.

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

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

A summary of the corrective actions taken or 11 (15) planned as a result of the event was not included or was inadequate.

i l

C-7

.. . . .. .. . . . . . . . . .. . . . . . . . . . . i

I -

TABLE C-2. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals 8 Totals ( )b Abstract presentation inadequacies.

6 (15)

a. .0BSERVATION: The abstract contains 3 i-information not included in the text.

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

b. The abstract was greater than 1

'1400 spaces,

c. The abstract contains undefined 0 acronyms and/or plant specific designators.

d. The abstract contains other specific 4 deficiencies (i.e. , poor summarization, contradictions, etc.).

a. The "sub paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub paragraph totals do not necessarily add up to the paragraph total,

b. The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a.certain requirement was considered applicable.

C-8

CODED FIELDS DEFICIENCIES AND OBSERVATIONS FDR OCONEE 1,2,3 TABLE C-3.

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

Totals ( )b Description of Deficiencies and Observations 5(15)

Facility Name 4

a. Unit number was not included or incorrect. 0

b. Name was not included or was incorrect. I

c. Additional unit numbers were included but not required.

0(15)

Docket Number was not included or was incorrect.

1 (15)

Page Number was not included or was incorrect.

15 (15)

Title was left blank or was inadequate.

14

a. Root cause was not given or was inadequate. 3

b. Result (effect) was not given or was inadequate. 2

c. Link was not given or was inadequate.

1 (15)

Event Date 1

a. Date not included or was incorrect. 0

b. Discovery date given instead of event date.

0 (15)

LER Number was not included or was incorrect.

2 (15)

Report Date O

a. Date not included. 2

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

C-9

TABLE C-3. (continued)

Number of LERs with Deficiencies and 00servations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b Other Facilities information in field is 0 (15) inconsistent with text and/or abstract.

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

Power level was not' included or was 1 (15)

-inconsistent with text or abstract.

Reporting Requirements 3 (15)

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

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

c. OBSERVATION: It may have been 2 appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 1 (15)

a. Field left blank. O

b. Position title was not included. I

c. Name was not included. O

d. Phone number was not included. O Coded Component Failure Information 13 (15)

a. One or more component failure 4 sub-fields were left blank,

b. Cause, system, and/or component code 1 is inconsistent with text.

c. Component failure field contains data 7 when no component failure occurred.

d. Component failure occurred but entire 1 field left blank.

I C-10

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - - _ - ._ - - - - - - - - - - - -b

TABLE C-3. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations Totals a Totals ( )b Supplemental Report 2 (15)

a. Neither "Yes"/"No" block of the 1 supplemental report field was checked.

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

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

l

a. The "sub paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub paragraph totals do not necessarily add up to the paragraph total.

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

l C-11

i 1

l l

4 i

i N OIX D SHEETS FOR D E 1,2,3

TABLE D-1. )

SPECIFIC LER COMMENTS FOR OCONEE 1 (269) )

Section Comments

)

1. LER Number: 86-005-00 i Scores: Text = 8.1 Abstract = 8.8 Coded Fields = 8.9 Overall = 8.4 )

Text 1. 50.73(b)(2)(11)(D)--The root and/or intermediate cause discussion concerning the problem with the IRIA-43 monitor is inadequate. What caused the

-{

problems with the solenoid and rack drive mechanism?  !

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

3. 50 73(b)(2)(ii)(L)--Identification (e.g. ,

l j

manufacturer and model no.) of the failed l component (s) discussed in the text is not included. I

4. 50.73(b)(4)--Discussion of corrective actions taken  !

or planned is inadequate. What specifically was done l to repair and prevent recurrence of the problem on  !

monitor 1RIA-43?  !

5. Acronym (s) and/or plant specific designator (s) are j undefined (e.g. , HP and RB weren't defined). '

6. Pages 3 and 4 appear to be switched in order.

l Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The actions to prevent recurrence were not discussed.

Coded Fields 1. Item (3)--See text comment 6,

2. Item (4)--Title: Result is inadequate The fact that a technical specification violation occurred is not clear.

3. Item (13)--Component failure occurred but entire field is blank. The text indicates that components of 1RIA-43 were replaced which usually implies a failure.

l l

D-1 -

TABLE D-1.

SPECIFIC LER COMMENTS FOR OCONEE 1 (269)

Section Comments

2. LER Number: 86-009-00 Scores: Text = 8.9 Abstract = 8.4 Coded Fields = 8.2 Overall = 8.6 Text 1. 50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(C)--When will the planned corrective actions to evaluate the NSM program and to determine the proper method for handling manufacturer revised drawings be implemented?

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

4. 50.73(b)(2)(ii)(I)--Discussion of the method of discovery of the discrepancy between the installation and the drawing for the battery racks is inadequate.

How did NRC personnel make the discovery?

5. Although there is no requirement to do so, a supplemental report may be appropriate to describe the results of the planned corrective actions mentioned under " Corrective Action:" if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The planned corrective actions to reduce the probability of recurrence are not mentioned.

2. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text. The operating conditions are in the abstract but not in the text.

Coded Fields 1. Item (4)--Title: Cause (personnel communication error) and link (curing drawing revision) are not included. A better title might be: "Keowee Battery i Racks Outside of Seismic Design Basis due to I Personnel Error during Drawing Revision".  ;

l 1

0-2

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE I (269) l Comments Section

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

2. Item (8)--Information in field is inconsistent with text and/or abstract. Facility names should be "Oconee, Unit 2" and "0conee, Unit 3".

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

1 i

D-3

TABLE D-1.

SPECIFIC LER COMMENTS FOR OCONEE 1 (269)

-Section Comments

3. LER Number: 86-011-00

. Scores: Text = 7.8 Abstract = 9.0 Coded Fields = 7.9 Overall = 8.2 Text 1. 50.73(b)(2)(11)(C)--Times for occurrences such as the start of the test, restoring CCW flow, and beginning the shutdown are not provided.

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the CCW discharge high point vent valves is not included.

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

4. 50.73(b)(2)(ii)(J)(2)--01scussion of the personnel error / procedural deficiency is inadequate. Were the blind flanges in place when the original testing was performed (i.e., 1/10/72 and 3/18/73)? How often is the ECCW System required to be tested?

5. 50.73(b)(4)--Given that the initial acceptance criteria for ECCW System test was inadequate, are there other systems whose test procedures (and design) should be reviewed?

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

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

Abstract 1. 50.73(b)(1.}--Summary of cause information is inadequate. The part played by the lower than normal lake level would be good information to provide in the abstract.

2. The abstract contains greater than 1400 spaces. The information contained in the last paragraph of the abstract could have been excluded.

t l

D-4

TABLhD-1. SPECIFIC. LER COMMENTS FOR OCONEE I (269) m Sec. tion Comments &

a .. 1

3. LER Number: '

86-011-00(Continued)!

\

f~

Coded Fields 1. Item (4)--Title: Cause and link are not included. A better title might be " Inadequate System Design and Initial' Testing Determined To Be The Root Cause of Inoperability of the E'CCW System". r

~

2. Item (7)--0BSERVAT10H: Report date is not within r thirty days of' event date (or discovery date if appropriate). It appears that a report should have g

been submitted within 30' days of October 2,1986.

3. Item (13);-$on'ponent failure field c6ttains data when no componeht failure occurred. If the design error is to be Mn'sidered a component failure, the 3 manufacturer field should be filled in. '

t, ai Us e

'4, t

'. A s py v.,

.s t (4, -

f,

.. b}j y

,e jf[ . '

A 8

s i

s,

\.

a t 41

\ N y .

"f,n ,.

,,r

. p

~

ij') ,#

t ,

.s 95

. e ,1' h

r

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 1 (269)

L -Section Comments

4. LER Number: 86-012-00 Scores: Text = 8.6 Abstract = 9.5 Coded Fields = 8.1 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(C)--How long had the S$F been in service before the discovery was made that it was inoperable?

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

3. 50.73(b)(2)(ii)(H)--A time estimate of the -

unavailability of the failed train / system is not included (see text comment 1).

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. Were there tny other incidents where inadequate design review caused a problem?

5. Acronym (s) and/or plant specific designator (s) are undefined (e.g., HVAC wasn't defined in the test and SSF wasn't defined on its first usage).

Abstract 1. No comment.

Coded Fields 1. Item (1)--The facility name should indicate that the report is being submitted under Unit "1".

2. Item (4)--Title: Cause (design and insufficient design review) is not included.

3. Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).

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

5. Item (13)--Com~ p onent failure field contains data when no component failure occurred. When a failure occurs then all fields should be filled in.

0-6

- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ b

y

. 0  !

3 ,

^

e i

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 1 (269) a t

Section Comments

5. LER Number: 86-014-00 t

Scores: Text = 9.0 Abstract = 8.0 C5ded Fields = 9.3 Overall = 8.7 -

Text 1. 50.73(b)(2)(ii)( A)--Information concerning the plant operating conditions before the event is not included. Although operating conditiens may not be '

relevant for this event, the Units' conditions prior to the event date are requh ed to be included.

2. 50.73(b)(2)(ii)(C)--When will the planneo corrective actions as discussed un' der " Corrective Action" be implemented?

3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for (ach con.ponent and/or system referred to in the text is not; included.

4. 50.73(b)(4)--Discussion of corrective actions taken i or planned is inadequate. Were HP persor.mel counselled on the importance'of attention to detail?

+

Anstract 1. 50.73(b)(1)--Summary of cause information concerning the deletion of the applicable leak test requirement for ONS-64 from the " Source Inventcry Log Book" is not included.

2. 50.73(b)(1)--Summary of' corrective actions taken or planned as a result of the event is inadequate. The planned corrective actions discussed in the' text are not mentioned.

Coded Fields 1. Item (1)--Additional unit number is included but not required.

2. Item (4)--Title: Cause (personnel cognitive error) is not included.

3. Item (10)--The power letel in this field should be numeric. See text comment number 1. -

l l 4. Item (13)--Component failure field contains data when no component failure occhered.

D-7

s y' <

,s-d,

)

TABLE [D-I. SPECIFIC LER C0l%hTL FOR OCONEE.1 (269)

. ._ s .

. _ _ _ ~

6 U '

g-  ;

j'!!! Section Comments

6. LER Number: 87-001-00 7 Scores: Text = 6.7 Abstndt = 5.0 Coded Fields = 7.7 Overall = 6.3 g i Text > 1. 50.73(b)(2)(ii)('A)--Information concerning the plant operating conditions before the event is not p, V

. .f included. (This information is in the abstract).

q. v, I 2. Sr[.73fb)(2)(ii)(C)--Dates were not provided for many of the occurrences discussed in the text (e.g., date

.\ >$

syrtem operability testing was performed, system completion dates, date of NUREG-0737). Without 3 adequne datesia time history of' the event.is hard to

';( , visus 112e m

,. 3. 50.73(b)(2)(ii)(F)--The Energy Industr/

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

4, '

50.73@)J2)(11)(J)(2)--Discussion of the personnel

'H +

error / procedural deficiency is inadequate. Who (by

? s 3 type /t Q1e) gave the chemistry section the 7 ' responsibility for the system without' providing training or instru::tions?

5. 50.73(b)(3)--What is the magnitude of the increased risk of high per$ar.nel dose due to personnel having to obtain samples from alternate sample locations? j

6. 50.73(b)(4)--Discussion of corrective actions taken I or planned is inadequate. If the ineffectiveness of i'

the RBNS screen was known in February of 1984, why wasn't the problem addressed? The problem is pointed out agau in the second paragraph on page 3 (dated January of 1986). The " enhancement modifications" I recommended by the Task Force shocid be presented.

7. 50_.73(b)(5)--Information concerning previous similar 3 events is r+t included. If-no previous similar

u.  ! events are known, the text should so state.

f, - ; '-

8. A logical transition does not exist between all ideas.

( ,y (

.e y

'f}.

J ,

, D'S h- , p , ,

r js .

_,__,,__,____,_______._.amL___----_ - - _ _ _ _

-_= - _ - _ _ _ _ _ _ _ _ _ - ___ - _

4 TABLE'0-1. SPECIFIC LER COMMENTS FOR OCONEE 1 (269) i Section- Comments

6. LER Number: 87-001-00(Continued)

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. Two important aspects of this event are missing from the abstract (i.e., the duration of the problem and the system deficiencies).

2. 50.73(b)(1)--Summary of cause information is i inadequate. The system design problems were not i

mentioned as a contributing cause.

3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is not included.

4. Abstract does not adequately summarize the text.

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

L

'5. OBSERVATION: The abstract is intended to be a i

summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text (" stroke tests").

Coded Fields 1. Item (1)--Unit number is not included.

2. Item (4)--Title: Cause information is not included.

3. Item (5)--Why isn't the event (discovery) date 1/14/86 (see second paragraph on page 3) or 1/19/87 (see first sentence of Abstract)?

4. Item (12)--Fosition title is not included.

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

6. Item (14)--Neither "Yes"/"No" block of the supplemental report field is checked.

l l

D-9

' TABLE 0-1. SPECIFIC LER COMMENTS FOR OCONEE 1 (269)

Section Comments

7. LER Number: 87-003-00 Scores: Text = 7.9 Abstract = 8.6 Coded Fields = 6.9 Overall = 8.0 Text 1. 50.73(b)(2)(11)(A)--Information concerning the plant operating conditions before the event is not included.

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

3. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed train / system is not included. Since this condition appears to have existed since the plants started operation, it would be helpful to provide the dates when the plants began operation.

4. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel involved (e.g., contractor personnel, utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

5. Although there is no requirement to do so, a

. supplemental report may be appropriate to describe the results of the design review into permanent corrective actions if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

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

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The long term corrective actions weren't mentioned. t Coded Fields 1. Item (1)--The facility name should indicate that the report is being submitted under Unit "1".

2. Item (4)--Title: Cause (design calculation deficiency) is not included.

3. Item (8}--The text doesn't clearly state that the problem affects all three units. It is implied by f

some valve numbers.

1 D-10 )

W n

[ TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 1 (269)

Section Comments

7. LER Number: 87-003-00(Continued)

4. Item (11)--Reporting requirement is not included.

5. Item (13)--Component failure field contains data when no component failure occurred. When a failure occurs, however, all fields should be filled in.

l

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

D-11

4 TABLE D-1. _ SPECIFIC LER COMMENTS FOR OCONEE 2.(270)

Section Comments

~ 8 .~- LER Number: 86-004-00 Scores: Text =.9.2 Abstract = 9.7 Coded Fields = 9.2. Overall = 9,4 Text 1, 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.  ;

2. 50.73(b)(3)--0BSERVATION: The consequences of the event had it occurred under.more severe conditions were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text.

3. 50.73(b)(5)--Information concerning previous similar events is inadequate. The LER numbers of the two amplifier failures resulting in reactor trips at Oconee Unit 3 could be included.

4 Acronym (s) and/or plant specift: designator (s) are undefined for Statalarm "ICS in Track" and ICS Cross-limit.

Abstract 1. 50.73(b)(1)--Summary of operator responses in assuming manual feedwater control is not included.

Coded Fields 1. Item (4)--Title: Cause (flow transmitter amplifier i failure) is not included.  ;

i i

j D-12

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 2 (270) i Section Comments

9. LER Number: 86-006-00 Scores: Text = 8.6 Abstract = 8.5 Coded Fields = 8.9 Overall = 8.6 Text 1. 50.73(b)(2)(11)(C)--Times were not provided for many of the occurrences discussed in the text ().g., when the pressure-feedwater swings occurred, replacement of Module 261, the unit trip, an.4 when the plant was stabilized).

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

3. 50.73(b)(2)(ii)(L)--Identification (e.g. ,

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

4. 50.73(b)(3)--0BSERVATION: The safety assessment discussion need not be a summary of information already provided but instead should simply state why the health and safety of the public was not affected (if such was the case). For example, backup systems or means (if any) should be discussed, as well as, whether or not the event could have been worse had it occurred under different but probable circumstances.

If operator actions mitigated the consequences, the consequences had those actions not been taken should be discussed.

5. 50.73(b)(5)--Information concerning previous similar events is inadequate. LER numbers for the "past incidents" would be helpful.

6. The text appears to contradict itself. The minimum pressurizer level is given as 75" on page 3 and 71" on page 5.

7. Steam generator levels are given in " percent" in certain paragraphs and " inches" in another.

' Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. The abstract should specifically state that the specific cause could not be determined.

l 0-13

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 2 (270) ,

Comments

. Section

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

2. 50.73(b)(1)--Summary of corrective actions taken orThe planned as a result of the event is inadequate.

supplemental corrective actions are not mentioned in the abstract.

1. Item (4)--Title: Cause information is not included Coded Fields

2. Item (13)--The manuf acturer code appears to be wrong; (possible typo "D" vs "0").

t D-14 L_ - _-

. 1

)

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 2 (270)

Section Comments

10. LER Number: 87-002-00 I

Scores: Text = 8.8 Abstract = 9.1 Coded Fields = 9.1 Overall = 8.9 l Text 1. 50.73(b)(2)(ii)(D)--W111 anything be done to continue to look for the short in the BTU limit circuit and i fix'it?  !

2. 50.73(b)(2)(ii)(F)--The Energy Industry ,

Identification System code for each component and/or j system referred to in the text is not included. I 1

3. 50.73(b)(2)(ii)(L)--Failure of components are implied I by the LER title, the inclusion of data in Item (13),

and in the text; but no failed components are identified in the text. '

Abstract 1. The root cause summary is deficient for the same reasons as the text.

Coded Fields 1. Item (4)--Title: Cause (unknown intermittent short) is inadequate.

2. Item (13)--One or more component failure sub-fields are blank.  ;

0-15

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 2 (270)

Comments Section

11. LER Number: 87-004-00 Abstract = 8.5 Coded Fields = 9.3 Overall = 8.4 Scores: Text = 8.1 Text 1. 50.73(b)(2)(ii)(C) -When was the unit stablilized in hot shutdown, and when were the repairs of the multiplier module completed?

2. 50.73(b)(2)(ii)(D}--The root and/or intermediate cause discussion concerning why the multiplier module failed is not included.

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

The consequences of the

4. 50.73(b)(3)--0BSERVATION:

event had it occurred under more severe conditicns were not discussed. If the event occurred under what are considered the most severe conditions, it would be helpful to state so in the text.

5. 50.73(b)(4)--Discussion of why the BTU limit circuit output is not needed while the units are at power is not included. What actions were planned to correct the contributing cause to this event, i.e., the steam generator fouling?

6. 50.73(b)(5)--Information concerning previous similar events is inadequate. The four previous failures of the Bailey multiplier module at Oconee should be identified by LER number and unit number.

7. Acronym (s) and/or plant specific designator (s) are undefined for FDW, OTSG, and Category "A" Event.

8. Some ideas are not presented clearly (hard to  ;

follow). The statement in the first paragraph under Description of Occurrence, "This f ailure caused the ICS to reratio FDW" could be explained in more detail.

l Abstract 1. 50.73(b)(1)--Summary of cause information concerning l

why the multiplier module failed and the contributory I

steam generator fouling is not included.

l D-16

_ _ _ _ _ _ - - - - i

TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 2 (270) l l

Section Comments

11. LER Number: 87-004-00(Continued)

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment number 5.

Coded Fields 1. Item (4)--Title: Cause (multiplier module failure) is vague.

2. Item (13)--One or more component failure sub-fields are blank.

J l

D-17

(

l 1

e TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 3 (287)

Section Comments

12. LER Number: 86-003-01 Scores: Text = 8.8 Abstract = 8.1 Coded Fields = 8.7 Overall = 8.6 Text 1. 50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is not included in the text.

2. 50.73(b)(2)(ii)(C)--The date in the first paragraph under DESCRIPTION OF OCCURRENCE is wrong; it appears it should be~ October 6 instead of September 6.

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

4. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate.

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

5. . 50.73(b)(3)--The safety assessment discussion (i e. ,

ANALYSIS OF OCCURRENCE) is very good.

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 corrective actions taken or planned as a result of the event is inadequate. The supplemental corrective action is not mentioned. I

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

3. OBSERVATION: The abstract is intended to be a summary of the text; therefore, the text must include all information summarized in the abstract. This abstract contains information that was not included in the text.

D-18

TABLE D-1. SPECIFIC LER C0hMENTS FOR OCONEE 3 (287)

Section Comments

12. LER Number: 86-003-01 (Continued)

Coded Fields 1. Item (4)--Title: Cause information (Procedural Deficiency) is not included and the result (Technical Specification Violation) is inadequate.

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

D-19

.... I TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 3 (287) l Section . Comments

13. LER Number: '87-002-00 Scores: Text = 9.5 Abstract = 8.0 Coded Fields = 9.1 Overall = 9.0 Text- 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

Abstract 1. 50.73(b)(1)--Summary of corrective actions to prevent recurrence is not included.

Coded Fields 1. -Item (1)--The facility name should indicate that the report is being submitted under Unit "3".

2. Item (4)--Title: Cause is inadequate.

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

, occur then all fields should be filled in.

1 i

I

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D-20 L__---__-__---_----- 1

e TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 3 (287)

Section Comments

14. LER Number: 87-004 Scores: Text = 8.8 Abstract = 8.7 Coded Fields = 8.7 Overall = 8.7 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System code for each component and/or system referred to in the text is not included.

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

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

3. A logical transition does not exist between all ideas. The Background and Description of Event sections refer to ". . . where this crack developed" and "the pipe that cracked," respectively, before the discussion of the discovery of the leak that pinpointed the crack location. Therefore, the reader is confronted immediately with the question, "What Crack?" ~

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The planned corrective actions as discussed in the text are not mentioned.

2. The safety assessment is not required in the abstract, especially when space is needed to adequately describe the cause and corrective actions.

Coded Fields 1. Item (4)--Title: Cause (construction deficiency) is vague.

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

3. Item (13)--One or more component failure sub-fields are blank.

l D-21 l

- - _-- - - 4

o f

f l TABLE D-1.

! SPECIFIC LER' COMMENTS FOR OCONEE 3 (287)

Section Comments

15. LER Number: 87-007-00 Scores: Text = 8.3 Abstract = 7.6 Coded Fields = 7.7 Overall = 8.0 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the service induced fouling is not included. Why can't the efficiency of the RBCV be tested without heating up the Reactor Building? Is the cleaning process not a proven fix?

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

3. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Why did the NASS also close the RBCV's inlet valves? Why weren't the inlet valves reopened at 0700 on April r

10th instead of waiting until 0820?

l 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)(4)--Discussion of corrective actions taken or planned is inadequate. Are any actions being planned to take care of the service induced fouling t

(e.g, more frequent or better cleaning, or a design change)?

Abstract 1. 50.73(b)(1)--Summary of cause information does not provide enough details.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The planned corrective actions are not mentioned.

3. Abstract contradicts the text. The second paragraph '

of the abstract implies the RBCV inlet valves were reopened at 0700 when, in fact, they were not i reopened until 0820.

Coded Fields 1. Item (4J--Title: Result (Technical Specification l

Violation) and the cause (Personnel Error) are not mentioned.

D-22

.n

,.9 TABLE D-1. SPECIFIC LER COMMENTS FOR OCONEE 3 (287)

Section Comments

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

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

3. Item (13)--One or more component failure sub-fields are blank.

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