ML20237F622

LER Quality Evaluation for Catawba Units 1 & 2 During Period from Oct 1986 - Jul 1987

ML20237F622
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Site:	Catawba
Issue date:	08/27/1987
From:	NRC
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ML20237F625	List: ML20237F622 ML20238B669
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NUDOCS 8709010362
Download: ML20237F622 (49)

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ENCLOSURE LICENSEE EVHTT NtJue (LER)

QUALITY EVAUJATION FOR CATAWM 1,2 l DURING '11E PERIOD FROM 1

l l OCIDBER 1 1986 'IO JULY 31 1987 1

f[y90103byg7oggy G ADOCK 05000413 PDR

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Catawba 1,2 doring the period from October 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. 1 and 2.

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

the text, abstract, and coded fields), has improved from the previous evaluation. The second evaluation's overall average LER score was 8.3, which was above the industry average (7.8) at that time. For the current evaluation, Catawba's overall average LER score is 8.8 while the current industry average has increased to 8.4. The quality of the discussions concerning root cause has increased since the previous evaluation.

Two deficiencies found in this evaluation concern the requirements to discuss the corrective actions and to adequately identify failed components. The score for the requirement to identify those components that f ailed (e.g. , by manuf acturer and model number) decreased slightly from the previous evaluation.

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LER QUALITY EVALUATION FOR CATAWBA 1,2 INTRODUCTION In order to evaluate the overall quality of the contents of the-Licensee Event Reports (LERs) submitted by Catawba 1,2 during the period from October 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 3

contained in NUREG-1022 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.

This is the third time that the Catawba 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 LEF< 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

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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 must be met. I I

l The evaluation process for each LER is divided into two parts. The j 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

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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 I concerning the information pertaining to the event, and (2) they provide a basis for a count of general deficiencies for the overall sample of LERs that was evaluated. Likewise, the scores serve two purposes: (1) they l serve to illustrate in numerical terms how the analysts perceived the l

1 content of the information that was presented, and (2) they provide a basis I for determining an overall score for each LER. The overall score for each l

' ER is the result of combining the scores for the text, abstract, and coded l fields (i .e. , 0.6 x text score + 0.3 x abstract score + 0.1 x coded fields score = overall LER score).

I The results of the LER quality evaluation are divided into two i 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

( Appendix B), . ables of the number of deficiencies and observations for the tut, abstrac: 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

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\ "n i f3 A discussion of the analysts' conclusions concerning LER quality is

'presente./ belcw." These conclusions *ere based solely on the results of the evaluatjon of the contents of the LERs selected for review and as such s

represent fbe, analysts' ass (ssment of the unit's performance (on a scale of 0 to 10) ,in suhitting 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 x

the unit. In order to place the scores provided in Table 1 in m

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pergective, the distribution of the overall average score for all un[ts/stationsthathavebeenevaluatedusingthecurrentmethodologyis provided on Figure 1. Figure 1 is updated each month to reflect any changes in this distribution resulting frow the inclusion of data for those 1

, units / stations that have not been previously evaluated or those that have beenreevaluated. (Note: The previous score for those units / stations that 1

are reevaluated is replaced with the score from the latest evaluations. {

Jab)a 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, Catawba 1,2's average score for the text of tne LERs that were evaluated is 9.1 out of a possible 10 points. From Tabl.e 2 it can be seen that the text score actually results from the review and evaluation of 17 different Ja requirements ranging from the discussion of plant operating conditions j prior to the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation.

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resultant percentage scores in the text summary section of Table 2 provide an indication of how well each text requirement was addressed by the unit l for the 15 LERs that 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.

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As indicated in Table 2, certain requirements or areas within the I text, abstract, and coded fields are causing the unit difficulty when i preparing LERs. Relatively low percentage scores may. indicate that the j

unit needs additional guidance concerning these requirements, or it may indicate that the unit understands the basic requirement but has either: l l

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TABLE 1.

SUMMARY

OF SCORES FOR CATAWBA-1,2

______________________________________________________________________, i Average High Low Text 9.1 9.8 8.4 1

Abstract 7.9 10.0 5.6 l Coded Fields 9.5 10.0 8.5 1

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l Overall 8.8 9.7 8.0

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

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

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

(2)(ii)(A) - - Plant condition prior to event 83 (15)  !

(2)(11)(B) - - Inoperable equipment that contributed b i (2)(11)(C) - - Date(s) and approximate time (s) 92 (15) l l

(2)(ii)(D) - - Root cause and intermediate cause(s) 91 (15)

(2)(ii)(E) - - Mode, mechanism, and eff ct 97 ( 9)

(2)(11)(F) - EIIS codes 90 (15)

(2)(ii)(G) - - Secondary function affected b {

(2)(ii)(H) - - Estimate of unavailability 75 ( 4)

(2)(ii)(I) - - Method of discovery 100 (15) l (2)(ii)(J)(1) - Operator actions affecting course 100 ( 9)

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 86 (11)

(2)(ii)(K) - - Safety system responses 100 ( 9)

(2)(ii)(L) - - Manufacturer and model no. information 70 (10)

(3) - - --- - Assessment of safety consequences 93 (15)

(4) - - - - - - Corrective actions 85 (15) ,

(5) - - - - - - Previous similar event information 100 (15) l i

(2)(_J - - - - Text presentation 89 (15)

ABSTEACT l Percentage a

Requirements [60.73(b)(1)J - Descriptions Scores ( )

- Major occurrences (immediate cause/effect) 99 (15)

- Plant / system / component / personnel responses 89 ( 9)

- Root cause information 86 (15)

- Corrective action information 45 (15)

- Abstract presentation 80 (15) 6

TABLE 2. (continued)

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COLED FIELDS {

j Percentage a i Item Number (s) - Descriptions Scorec ( )

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L 1, 0, and 3 - Plant name(unit # J, docket #, page #s 100 (15) i i

4 - - - - -- Title 91 (16) 5, 6, and 7 - Event date, LER no., report date 93 (15) 8-- - - - -

Other facilities involved 100 (15) 9 and 10 - -

Operating mode and power level 100 (15)

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Reporting requirements 100 (15) 12 - - - - -

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

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

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

(Nete: Some requirements are not applicable to all LERs; therefore, the .

nu.vf:er of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered appi; cable,

b. A percentage score for this requirement is meaningless as it is not possiDle to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100% 1 if it is provided and is always considered "not applicable" when it is not.

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(1) excluded certain less significant information from a number of the l discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The unit should review j 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 The discussions of corrective actions, Requirement 50.73(b)(4), are i

considered to be inadequate for seven of the 15 discussions as they lacked j certain information necessary to a complete discussion. Five of these j eight failed to adequately discuss those actions that appeared necessary to prevent recurrence of the event. Corrective actions, both immediate and planned, should be discussed for all causes identified in an LER.

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l The reovirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(ii)(L), was considered deficient in four of the ten LERs involving a failed component. In most cases this requirement can be met by simply providing the manufacturer and model number for each failed component. For certain components (e.g., pipes, fitting, etc.) the material and size of the failed component may be more appropriate information. Whatever information is provided, it should be specific enough to allow the reader to determine if the failed component is the same as one that is used at his facility. In addition, there are instances when component identification can be important to the reader, even though the component did not fail. For example, if the design of a component contributes to the event, it would be helpful to provide information that would enable other- to specifically identify that component.

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. l Requirement 50.73(b)(2)(ii)(H), unavailability of safety trains, is considered deficient for one of the four LERs involving a train failure. I The time a safety system train is unavailable is important because this information becomes part of the generic data necessary to perform I probabilistic risk assessments. Adequate attention paid to providing date and time information for major occurrences [50.73(b)(2)(ii)(C)] will usually ensure that the unavailability time can be determined.

Plant operating conditions prior to the event were not included for three of the LERs. In general, the plant power level is considered minimally sufficient to meet the requirement of this paragraph. Additional data such as pressure and temperature is desirable depending on the event.

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 l

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.

l 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.

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Scores were adequate for Items 1, 2, and 3 above; however, 12 of the abstracts were deficient for Item 4; and six of those failed to include any i mention of corrective actions. Many of the problems arise from the inadequate discussions of corrective actions in the text. In addition  ;

seven of the abstracts were deficient in the area of presentation. Of these seven, three LERs exceeded the specified maximum length of 1400 spaces and three included data not discussed in the text. The abstract is intended to be a summary of the text; therefore, any subject discussed in the abstract should also be discussed in the text.

Coded Fields Deficiencies and Observations Only minor deficiencies were found in the Coded Fields. Comments in Appendix D should be read to determine what deficiencies were found.

SUMMARY

Table 3 provides a summary of the areas that need improvement for the Catawba 1,2 LERs. For additional and more specific information concerning deficiencies, the reader should refer to the information presented in Appendices C and D. General guidance concerning requirements can be found j in NUREG-1022, and NUREG-1022 Supplements No. I and 2.

l As was mentioned earlier, this is the third time that the Catawba 1,2 l LERs have been evaluated using the same methodology. The first evaluation I

was reported in October of 1985, and the second evaluation was reported in October of 1986. Table 4 provides a comparison of the scores for the three evaluations. Continued improvements in the information provided in the text and the coded fields were partially offset by abstract scores which are still below the current industry abstract average of 8.6. The overall average LER score of 9.3 remains well above the current industry overall average of 8.4 (Note: The industry overall average is the result of averaging the latest overall average LER score for ear.h unit / station that i has been evaluated using this methodology.) l l

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR CATAWBA 1,2 LERs Areas _ Comments Corrective actions All actions planned or taken to address the various causes (problems) mentioned in the text should be discussed, especially those actions considered necessary to prevent recurrence of the event or similar events.

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

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

Plant operating conditions Operating mode number and name shou'd be l provided. When in Mode I the percent power should be included as well.

Abstracts Corrective action information was often inadequate or was not included. Abstracts should not contain information which was not discussed in the text. If it is necessary to include this information, then the text should be revised to include it.

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TABLE 4. COMPARISON OF LER SCORES FOR CATAWBA 1,2 Report Date- October-85 October-86 August Text average 8.0 8.5 9.1 Abstract average 7.4 7.4 7.9 Coded fields average 8.6 9.2 9 '. 5 Overall LER average 7.9 8.3 8.8' l

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REFERENCES l

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

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

Report System, NUREG-1522 Supplement No.1, U.S. Nuclear Regulatory l Commission, February 1984.  !

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

Commission, September 198S. i l

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r APPD1 DIX A IER SAMPLE SEIECI' ION INFOIEATIQ1 FOR CATAWBA 1,2

a TABIE A-1. IIR SAMPIE SELECTION FDR CATAWIR 1,2 Sample Ihnnber IER thlmber Unit thrber Comments 1 86-057-02 1 2 87-002-00 1 3 87-006-01 1 SCRAM, ESF l

4 87-013-00 1 SCRAM, ESF l 5 87-016-00 1 SCRAM I l

l 6 87-019-00 1

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7 86-045-00 2 8 86-046-00 2 9 86-051-01 2 10 86-054-00 2 11 87-001-00 2 i

l 12 87-003-00 2 ESF 13 87-007-00 2 SCRAM, ESF 14 87-012-00 2 15 87-018-00 2 SCRAM, ESF 1

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APPMDIX B l t

l EVAUJATICH SCORES OF MDIVIDUAL IERS FOR CATAWBA 1,2 i

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TABLE B-1. EVALUATIOli SCORES OF ItJDIVIDUAL LERS FOR CATAWBA 1,2 a

LER Sample llumber 1 2 3 4 5 6 7 8 Text 9.1 9.8 9.6 9.7 8.b 8.7 S.6 9.0 Abstract 9.0 9.3 6.9 9.6 8.7 10.0 6.7 5.6 Coded Fields 9.7 9.9 9.5 10.0 8.5 9.5 9.5 9.2 Overall 9.1 9.6 8.8 9.7 8.6 9.1 8.1 8.0 a

LER Sample 14 umber 9 10 11 12 13 14 lb Avera

._ _ ..___.-________ _ ___________-_____ -_.- ____..__ _.______ -__ ___-__-__ge .

Text 8.8 9.3 9.1 9.8 9.3 8.5 8.4 9.1 Abstract 7.1 7.0 7.1 8.1 7.5 9.4 6.8 7.9 Coded Fields 9.6 9.7 8.7 9.8 9.9 9.2 9.8 i

9.5 Overall 8.3 8.6 8.5 9.0 8.3 9.6 8.0 8.8

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

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APPDIDIX C r

1 DEFICIDK"I AND OBSERVATION COUlfIS FOR CATAWBA 1,2 1

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. j TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR CATAWBA 1,2 4

Number of LERs with Deficiencies and Observations )

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Sub paragraph Paragraph j a j Description of Deficiencies and Observations Totals Totals ( )b l

50.73(b)(2)(ii)( A)--Plant operating 3 (15) conditions before the event were not 3 included or were inadequate.  !

l 50.73(b)(2)(ii)(B)--Discussion of the statcs 0 ( 4) l of the structures, components, or systems :

that were inoperable at the start of the event and that contributed to the event was j not included or was inadequate. l 4

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

a. Date information was insufficient. 5 i

b. Time information was insufficient. 1 50.73(b)(2)(ii)(D)--The root and/or 4 (15) intermediate cause of the component or system failure was not included or was inadequate.

a. Cause of component failure was not 4 included or was inadequate.

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

50.73(b)(2)(ii)(E)--The failure mode, 1 ( 9) 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 0 inadequate.

b. Mechanism (immediate cause) was not 1 included or was inadequate.

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c. Effect (consequence) was not included 0 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)(F)--The Energy Industry 4 (15)

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

l l 50.73(b)(2)(ii)(G)--For a failure of a 0 ( 1) component with multiple functions, a list j of systems or secondary functions which were also affected was not included or was I inadequate.

50.73(b)(2)(ii)(H)--For a failure that 1 ( 4)  !

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 0 (15) of each component failure, system f ailure, personnel error, or procedural error was not included or was inadequate.

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

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

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

d. Method of discovery for each 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)--Dperator actions that 0 ( 9) 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 0 implied by the text, but was not explicitly stated.

b. 50. 73(b)(2)(ii)(J)(2)(1 )--Di scussion 1 as to whether the personnel error was cognitive or procedural was not included or was inadequate.

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

d. 50.73(b)(2)(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 3 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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I TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph Description of Deficiencies and Observations a Totals Totals ( )b 50.73(b)(2)(ii)(K)--Automatic and/or manual 0 ( 9) safety system responses were not included or were inadequate.

l 50.73(b)(2)(ii)(L)--The manufacturer and/or 4 (10) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 5 (15) consequences and implications of the ovent was not included or was inadequate,

a. 083ERVATION: 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 2 of the event had it occurred under more severe conditions were not -

discussed. If the event occurred under what were considered the most )

j severe conditions, the text should so i

state.

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50.73(b)(4)--A discussion of any corrective 7(15) actions planned as a result of the event  !

including those to reduce the probability  !

of similar events occurring in the future I was not included or was inadequate. j l

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TABLE C-1. (continued) i Number of LERs with Deficiencies and Observations l

l Sub paragraph Paragraph j a

Description of Deficiencies and Observations Totals Totals ( )b 1

a. A discussion of actions required to 0 l correct the problem (e.g., return the component or system to an operational condition or correct the personnel error) was not included or was inadequate.

b. A discussion of actions required to 5 reduce the probability of recurrence 3

of the problem or similar event (correct the root cause) was not included or was inadequate.

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

in similar and/or other systems (e.g. , l 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 0(15) similar events 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 a Totals Totals ( )b 50.73(b)(2)(i)--Text presentation 5 (15) inadequacies.

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

b. Text contained undefined acronyms 3 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.

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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.

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TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR CATAWBA 1,2 Number of LERs with Deficiencies and Observations Sub paragraph Paragraph a

Description of Deficiencies and Observations Totals 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 1 ( 9) responses was not included or was inadequate.

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

b. Summary of system responses was not 1

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c. Summary of personnel responses was not 0 l included or was inadequate.

A summary of the root cause of the event 5 (15) was not included or was inadequate.

l A summary of the corrective actions taken or 12 (15) s planned as a result of the event was not l included or was inadequate.

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

Description of Deficiencies and Observations Totals Totals ( )b l

Abstract presentat4on inadequacies. 7 (15)

a. OBSERVATION: The abstract contains 3 l

information not included in the text.

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

b. The abstract was greater than 3 1400 spaces,

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

d. The abstract contains other specific 1 deficiencies (i.e. , poor summarization, contradictions,etc.).

a. The "sub paragraph cotal" 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 l for which a certain requirement was considered applicable, i

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1 C-8 1

TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR CATAWBA 1,2 Number of LERs with l Deficiencies and Observations l l

1 Sub paragraph Paragraph  ;

a Description of Deficiencies and Observations Totals Totals ( )b Facility Name 0 (15) l

a. Unit number was not included or l incorrect. l

b. Name was not included or was  !

incorrect. I

c. Additional unit numbers were included but not required.

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

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

Title was left blank or was inadequate. 6 (15) I 1

a. Root cause was not given or was 2 l inadequate.  !

b. Result (effect) was not given or 0 l

was inadequate.

c. Link was not given or was 5 inadequate.

Event Date 2 (15)

a. Date not included or was incorrect. O

b. Discovery date given instead of event 2 date.

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

Report Date 1 (15)

a. Date not included. O

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

C-9

TABLE C-3. (continued) 1 Number of LERs with l

Deficiencies and l

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

1 Operating Mode was not included or was 0(15) inconsistent with text or abstract.

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

Reporting Requirements 0(15)

a. The reason for checking the "0THER"

{

requirement was not specified in the abstract and/or text. ];

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

c. OBSERVATION: It may have been appropriate to report this event under an .

additional unchecked paragraph.

Licensee Contact 0 (15) I

a. Field left blank, l

b. Position title was not included.

c. l Name was not included. '

d. Phone number was not included.

Coded Component Failure Information 4 (15) l a. One or more component failure 0 i sub-fields were left blank.

l b. Cause, system, and/or component code 2 l is inconsistent with text.

c. Component failure field contains data 0 when no component failure occurred.

t

d. Component failure occurred but entire 3 field left blank.

C-10 l

i I

TABLE C-3. (continued)

Number of LERs with Deficiencies and l Observations .

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

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

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

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

i

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.

D. 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 l

C-11

1 4

0 l

l l

)

APPDOIX D

- -e - - i CATAhM 1,2 l l

l 1

)

I I

f I

t i

I h '

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

. i

. \

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 1 (413) ]

l Section Comments

1. LER Number: 86-057-02 Scores: Text = 9.1 Abstract = 9.0 Coded Fields = 9.7 Overall = 9.1 i J

Text 1. 50.73(b)(2)(11)(D)--It is not necessary to assign a cause code to the event. These codes are intended to be used for failed components in Item (13) of NF.C Form 366.

2. 50.73(b)(2)fii)(F)--The Energy Industry Identification System codes for the safety systems listed in the " Safety Analysis" section were not included.

3. 50.73(b)(2)(ii)(J)(2)--Why hadn't the torque settings ever been tested before; and who, by type of personnel, was responsible for setting up the valves ,

originally? I

4. 50.73(b)(2)(ii)(L)--It would be helpful to give the manufacturer's model number of all the Rotork 3 actuators involved. j

5. 50.73(b)(3)--Were there any systems where adequate backup valves didn't exist and, if not, what would -l the safety consequences be7 Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or j planned as a result of the event is inadequate. The  ;

commitment to check all safety related M0V's was not i mentioned. I Coded Fields 1. No comment, j

i i

i i

D-1  !

l

TABLE 0-1. SPECIFIC LER COMMENTS FOR CATAWBA 1 (413)

Section _

Comments

2. LER Number: 87-002-00 Scores: Text = 9.8 Abstract = 9.3 Coded Fields = 9.9 Overall = 9.6 Text 1. OBSERVATION: The paragraph heading " Conclusion" might better be split into "Cause" and " Previous l Event".

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

Corrective actions to prevent recurrence, namely, procedure IP/0/A/3890/03 to be used in any future work on instrument line fittings, and the welding of all Unit 1 RTD tubing fittings are not mentioned.  ;

Coded Fields 1. Item (13)--The manufacturer's ende can be obtained from INPO. I I

D-2

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 1 (413)

Section Comments

3. LER Number: 87-006-01 Scores: Text = 9.6 Abstract = 6.9 Coded Fields = 9.5 Overall = 8.8 Text 1. 50.73(b)(4)--When does the operator (OATC) usually '

block the High Flux-Low Power Reactor trip? Is a change needed in this area?

Abstract 1. 50.73(b)(1)--Summary of system responses is inadequate.

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

3. The use of " revision bars" in the right margio is good.

{ Coded Fields 1. Item (4)--Title: Link is not included. A better title might be "High Flux-Low Power Reactor Trip I

Whil' Bringing Turbine Generator On Line--Defective Procedures and Deficient Training".

l 1

D-3

\

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 1 (413) l Section Comments

4. LER Number: 87-013-00 Scores: Text = 9.7 Abstract = 9.6 Coded Fields = 10.0 Overall = 9.7 Text 1. 50.73(b)(2)(ii)(D)--It is not necessary to assign a 1 i

cause code to the event. These codes are intended to i be used for failed components in Item (13) of Form 366. j Abstract 1. The abstract contains greater than 1400 spaces.

Coded Fields 1. No comment.

1 1

1 l

1 1

l D-4

TABLE D-1.

SPECIFIC LER COMMENTS FOR CATAWBA 1 (413)

Section Comments

5. LER Number: 87-016-00 1

Scores: Text = 8.5 Abstract = 8.7 Coded Fields = 8.5 Overall = 8.6 Text 1. Although there is no requ'rement to do ..>, a supplemental report may Fa appropriate to describe the results of the work request to repair DRPI data Channel A, to present the manufacturer and model numbers of any failed components, to discuss the necessary immediate corrective actions to return the affected components to an operable status, and to discuss the actions required to reduce the probability of recurrence.

2. 50.73(b)(2)(ii)(D)--How was the suspicion determined that a bad detector / encoder card for D-14 was the cause?

Abstract 1. The summaries of cause and corrective actions are deficient for the same reasons as in text comment number 1. In addition, the summary of the Technical Specification interpretation changes in the CR and SRO manuals is not included.

Coded Fields 1. Item (4)--Title: Cause (suspected rod position encoder card failure) is vague.

2. Item (14)--The block checked appears to be inconsistent with information provided in the text (see text comment number 1).

D-5

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 1 (413)

Section Comments

6. LER Number: 87-019-00 Scores: Text = 8.7 Abstract = 10.0 Coded Fields = 9.5 Overall = 9.1 Text 1. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the back leaking check valves 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. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. It is not apparent how the corrective action will prevent recurrence of this type of event in the distant future when new personnel replace the old.

4. Some ideas are not presented clearly (hard to follow). The difference between " functional verification requirements" and " retest requirements" (first paragraph under DESCRIPTION OF INCIDENT) is not clear.

Abstract 1. No comments.

Coded Fields 1. Item (13)--Component failure occurred but entire field is blank.

I l

1 1

l D-6 1

1

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)

Section Comments j j

7. LER Number: 86-045-00 1 1

Scores: Text = 8.6 Abstract = 6.7 Coded Fields = 9.5 Overall = 8.1 Text 1. 50.73(b)(2)(ii)(D)--It is not necessary to assign.a '

cause code to.the event. These codes are intended to be used for failed components in Item (13) of NRC Form 366. J

2. 50.73(b)(2)(ii)(F)--The Energy. Industry Identification System codes for each component referred to in the text are not included.

j 1

3. 50.73(b)(2)(ii)(J)(2)(iv)--Discussion of the type of personnel' involved (e.g., contractor personnel, j utility licensed operator, utility nonlicensed operator, other utility personnel) is not included.

4. 50.73(b)(2)(ii)(L)--Although not required since the components didn't actually fail, it could be helpful to identify the components anyway.

5. 50.73(b)(3)--Discussion of the assessment of.the safety consequences and implications of the event is inadequate. What are the implications of not having the Standby Shutdown System when needed?

6. The use of the acronym (CAPT) was confusing since it was never actually defined but appears to be a ,

combination of two acronyms defined separately. i Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or l planned as a result of the event is not included.

Coded Fields 1. Item (7)--0BSERVATION: Report date is not within thirty days of event date (or discovery date if appropriate).

D-7

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414) 1

)

Section Comments

8. LER Number: 86-046-00 l

Scores: -Text = 9.0 Abstract = 5.6 Coded Fields = 9.2 Overall = 8.0  !

}

Text 1. 50.73(b)(2)(ii)(C)--When was the isolation valve 2CA-152 repaired?

2. 50.73(b)(2)(ii)(DJ--The root and/or intermediate cause discussion concerning transducer for valve 2CF-57 is inadequate. Why did the transducer fail?. )

l

3. 50.73(b)(4)--A discussion of actions required to i reduce the probability of recurrence (i.e, correction j of the root cause) is inadequate for the transducer  !

for valve 2CF-57. What repairs were performed? )

Although there is no requirement to do so, a' supplemental report may be appropriate to describe the results of the review of the repetitive failures of Borg-Warner air actuator if these results significantly change the reader's perception of the event and/or require additional corrective actions be 4 taken. 1 Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The failure of valve 2CA-152 is not mentioned.

2. 50.73(b)(1)--Summary of cause information for the failures of the valves 2CF-57 and 2CA-152 is l inadequate. See text comment number 2.

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

4. 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 auxiliary feedwater pump auto-start logic being defeated is not discussed in the text.

Coded Fields 1. Item (4)--Title: Cause is vague and link is not included. A better title might be " Main Feedwater Isolation on Hi-Hi Level During Startup Due To Failures of. Feedwater Bypass Valve Transducer and Bypass Isolation Valve Actuator".

D-8

s'.

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)

Section Comments )

9. LER Number: 86-051-01 Scores: Text = 8.8 Abstract = 7.1 Coded Fields = 9.6 Overall = 8.3 Text 1. 50.73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. j l

50.73(b)(2)(ii)(J)(2)(i)--Discussion as to whether the personnel error was cognitive or procedural is not included. Why were the CF Pump Tripped / Reset logic contacts ". incorrectly reversed"?

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.

Who (by type /ticle) was responsible?

)

2. 50.73(b)(3)--Discussion of the assessment of the j safety consequences and implications of the event is 1 inadequate. What were the safety implications of j l uncovering the top of the tube bundle? Is it normal 1 to " expect" this to occur on any feedwater flow / pressure transient that results in a reactor

~

trip from high power?

3. 50.73(b)(4)--Discussion of corrective actions'taken or planned is inadequate. Was anything done to prevent recurrence of improperly implemented NSMs and improper calibration of the Barton pressure switch?

4. 50.73(b)(5)--It appears the LER number 86-038 is somewhat similar to this event.

j 5. The use of revision bars in the right margins is good.

6. Some ideas are not presented clearly (hard to follow). It is not apparent whether the incorrectly wired logic contacts (by themselves) would have resulted in 2CF-13 opening when not expected (under some different circumstances). See the second paragraph on page 4.

Abstract 1. 50.73(b)(1)--The reversed contacts and their importance, if any, (see text comment number 6) is not mentioned in the abstract.

D-9

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414) .

i Section Comments

9. LER Number: 86-051-01 (Continued) .

2. 50.73(b)(1)--Sumrcary of corrective actions taken or planned as a result of the event is not included.

3. Additional space is available within the abstract field to provide more information but it was not utilized. 3 Coded Fields i Item (4)--Title: Link (Recirculation Control Valve Opening Unexpectedly) is not included.

l l

l I

1 1

0-10 j i

l

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)

Section Comments

10. LER Number: 86-054-00 Scores: Text = 9.3 Abstract = 7.0 Coded Fields = 9.7 Overall = 8.6

.. i Text 1. 50.73(b)(2)(ii)(A}--Informationconcerningtheplant operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System codes were not included for the Containment Air Release and Addition System nor for i the alarm. l l

3. 50.73(b)(2)(ii)(L)--While not required, since no  !

I failure occurred, it would be helpful to identify the monitor causing the problem.

Abstract 1. 50.73(b)(1)--Summary of cause information is l inadequate. The problems with spurious signals were I not mentioned.

1

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

The abstract is intended to be a

3. OBSERVATION:

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 (in particular, the operating conditions prior to the event, see text comment 1).

Coded Fields 1. No comment.

I l

l D-11

, 1 E_____________.___.__.__._____________.____._ _ _ _ . _ _ _ . _ _ . . . . _ _

l TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414) l Section Comments

11. LER Number: 87-001-00 Scores: Text = 9.1 Abstract = 7.1 Coded Fields = 8.7 Overall = 8.5 Text 1. 50.73(b)(2)(ii)(A)--Information concerning the plant 1 operating conditions before the event is not included.

2. 50.73(b)(2)(ii)(C)--When will the procedure MP/0/A/7150/07 undergo the next major rewrite?

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

l Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or  !

l planned as a result of the event is not included.

Coded Fields 1. Item (4)--Title: Link (during inspection) is not included.

2. Item (5)--Discovery date is given instead of event I date.

I l

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l l

l l

l i 1

l l

D-12

es -

-TABLE 0-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)

Section Comments l

12. LER Number: 87-003-00 Scores: Text = 9.3 Abstract = 8.1 Coded Fields = 9.8 Overall = 9.0 l Text 1. 50.73(b)(2)(ii)(A)--Information concerning the plant operating conditions before the event is inadequate. j The text does not give the initial power level. '

2. 50.73(b)(2)(ii)(C)--On what date was the 2C High-High i

! Level Condenser Dump Valve (2HS68) isolated because its seat was leaking?

3. 50.73(b)(3)--Discussion of the assessment of the  !

safety consequences and implications of the event is inadequate. The statement concerning operator 1 response (fif th paragraph under CONCLUSION)

" appropriate considering the rate of S/G level increase", implies that the response would not have i been appropriate under other circumstances. Given the apparent hectic circumstances and the low initial power, was it wise to worry about keeping the reactor  !

1 from tripping while trying to stabilize the feedwater transient?

4. Acronym (s) and/or plant specific designator (s) are I undefined. CFPT is not defined on first usage in the l

text. (It is defined in the abstract).

l Abstract 1. 50.73(b)(1)--Summary of cause information is inadequate. The contributing factors (i.e., the other level transmitter and valve 2H568) were not l mentioned.

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

l 1

Actions taken to prevent recurrence are not mentioned.

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.

Coded Fields 1. Item (4)--Title: The Link would have been better had the acronym "MSRH" been added before the " Level Transmitter".

l D-13 l

.- i ,

TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)-

Section Ccmments

13. LER Number: 87-007-00 Scores: Text = 8.5 Abstract = 7.5 . Coded Fields = 9.9 Overall = 8.3 Text 1. 50.73(b)(2)(ii)(D)--The root cause of the optical isolator and the-feed breaker failures were not discussed. The root cause discussions for the valve-out air supply line, limit switch problem,fand various valve problems were also not included.

2. 50.73(b)(2)(ii)(F)--The proper EIIS code for a breaker is "BKR".

3. 50.73(b)(2)(ii)(L)--Many of the components which were either repaired or replaced were not identified by manufacturer and model number.

4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. In many cases the fix was to replace or repair a component, but without an adequate root cause discussion (see text comment 1).

It isn't'possible to determine if repair / replacement is adequate to prevent recurrence.

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

Coded Fields 1. Item (13)--It would be appropriate to fill'out a line-for each of the other failed components (e.g., the valves which needed repair).

D-14

.I, TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414)

Section Comments i

14. LER Number: 87-012-00 Scores: Text = 9.8 Abstract = 9.4 Coded Fields = 9.2 Overall = 9.6 1

Text 1. 50.73(b)(2)(ii)(C)--When will the controlling 1 procedure for support / restraint maintenance i activities be revised?

l l Abstract 1. The abstract contains greater than 1400 spaces. The l safety assessment is not necessary in the abstract.

Coded Fields 1. Item (5)--Discovery date is given instead of event date. I

! l I

l D-15 l

)

.. . 1,

.+ ,

. . l TABLE D-1. SPECIFIC.LER COMMENTS FOR CATAWBA 2 (414).

Section Comments

15. LER Number: 87-018-00 l l

Scores: Text = 8.4 Abstract'= 6.8 Coded Fields = 9.8 Overall = 8.0-Text 1. 50.73(b)(2)(ii)(C)--At what time was'2RN-C04 manually opened? On what date were the NSMs previously initiated to redesign the YV System controls?

2. 50.73(b)(2)(ii)(E)--The immediate cause discussion of l each failed component is not included. Why did relay j K619 fail-to latch properly? l

3. 50.73(b)(2)(ii)(H)--A time estimate of the l unavailability of the failed train / system is not included. For how long was the cooling water to the Reactor Coolant pumps unavailable?

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 inadequate.  !

More information concerning the " Supervisor" and the l

" engineer" would be useful (e.g., what organization /section they work for).

5. 50.73(b)(2)(ii)(L)--Identification (e.g. ,  !

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

(i.e., for relay K619).

6. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Recurrence prevention discussions are not adequate. Although there is no I requirement to do so, a supplemental report may be appropriate to describe the results of the current evaluation of the Subject NSMs, the evaluation of the advisability of periodic cycling for 2RN-C04, and the review of procedures to enhance critical path testing if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

7. Phrases such as " dead headed" should probably be replaced by more conventional terms.

8. The fact that cooling was' reestablished to the Reactor Coolant pumps prior to their restart is not stated in the " Description of Incident" (last i- paragraph).

D-16 l

k----_---_.---_-_--_--_-__._---_.--_.-_-__--_________._'_..._-_- _ _ - - -

_ _- )

1

~ L , \

l 1

1 TABLE D-1. SPECIFIC LER COMMENTS FOR CATAWBA 2 (414) i l

Section Comments __

15. LER Number: 87-018-00 (Continued) 1 1

9. The order of the text pages appears to be wrong. l Page 4 of 6 apparently should be 5 of 6 and vice versa. 1 Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or )

planned as a result of the event is inadequate. i Those actions taken to prevent recurrence of this event are not mentioned. l

2. The acronym "RN" is not defined on first usage.

)

3. The abstract contains greater than 1400 spaces. Too '

much detail is provided concerning some aspects of the event and none are provided concerning others.

The abstract should briefly (in less than 1400 spaces) summarize cause-result, plant / system responses, root cause, and corrective actions (including those necessary to prevent recurrence).

Coded Fields 1. Item (13)--Cause, system, and/or component code l

appears inconsistent with information provided in the text. Specifically, the "cause code" should apparently be "X"

2. Item (13)--Comp 6nent failure occurred but entire field is blank (relay K619).

l l

l 3. Item (14)--The block checked appears to be

inconsistent with information provided in the text (see text comment number 6).

l l

l l

l l

l D-17 L -- - - - - - ___a